HomeMy WebLinkAboutAPA2903~erged~.'.~~AR r~S~RESOURCES LIBRARlANCHORAG~,r.~,,os,JDEPT.Of INTERIOR
n.,E.ALASKA"
EsLi<l97 /'.,-~~-nrc
\L--t :2 '5
<,'<;.;,/
4 ...~~
FEDERAL ENERGY REGULATORY COMMISSION
SUSITNA HYDROELECTRIC PROJECT
PROJECT NO.7114
RESPONSE OF THE
ALASKA POWER AUTHORITY
TO
COMMENTS
ON THE
ALASKA POWER AUTHORITY'S
APPLICATION FOR LICENSE FOR MAJOR PROJECT
February 15,1984
VOLUME I
ARLIS
FY~+(
r'lD'c9-90 3
Alaska Resources
Library &InfonnatlOn Services
Anchorage,A~aska
------~-,._-:----,---~-------
-
FEDERAL ENERGY REGULATORY COMMISSION
SUSITNA HYDROELECTRIC PROJECT
PROJECT NO.7114
RESPONSE OF THE ALASKA POWER AUTHORITY
TO COMMENTS ON
APPLICATION FOR LICENSE FOR MAJOR PROJECT
FEBRUARY 15,1984
TABLE OF CONTENTS
Page/Tab
Preface ...........................•............•.ii -iii-
Table of Contents ...............•..•.............i
Subject Index,e-.••• • • • • • • ••• ••• • • •••• • ••iv -lxxvii
Bibliography ..e-.• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • ••lxxviii -xc
Alaska Power Authority Response to
Comments of the United States Department
of the Interior,Office of the Secretary.........I
-i-
ARLIS
Alaska Resources
Library &Informatwn ServICes
Anchorage,Alaska
....
-
i~
,-
.-
PREFACE
On December 12,1983,the United States Department
of the Interior,Office of the Secretary,filed a 108-page
letter with the Federal Energy Regulatory Commission on the
Alaska Power Authority's Application for License for fhe
Susitna Hydroelectric Project,Federal Energy Regulatory
Commission Project No.7114-000.On or before November 28,
1983,eight other state and Federal agencies had each filed
a letter with the Federal Energy Regulatory Commission on
FERC Project No.7114-000,as well.The Alaska Power
Authority's response to the specific comments contained in
the eight comment letters filed on or before November 28,
1983,was submitted to the FERC on January 19,1984.The
document in which this Preface appears (the JlComment/
Response Document")contains the Alaska Power Authority's
detailed'response to the more than 500 specific comments
contained in the December 12,1983 letter filed by the
Department of the Interior,Office of the Secretary.
Responses to Comments filed by other organizations within
the Department of the Interior can be found in the Power
Authority's earlier Response Document filed with the FERC on
January 19,1984.
In preparing its Responses to Comments,the Power
Authority has assigned each commenting agency a letter tab.
Those agencies filing comments on or before November 28-,--
1983,were assigned letter tabs "A-H."The 001,Office of
the Secretary has been assigned letter tab "I."A copy of
the 001 comment letter is enclosed in this Comment/Response
Document behind letter tab I.
To ensure the preparation of thorough responses to
each of the nine agency comment letters,the Power Authority
divided each comment letter into specific individual
comments.Each individual comment has been assigned an
alphanumeric comment code •.The alphanumeric code simply
identifies the commenting agency (alphabetically by letter
tab)and the specific comment (by consecutive number).In
this Comment/Response Document,alphanumeric comment codes
are shown in brackets in the left-hand margin of the 001
comment letter.
Behind the December 12,1983 DOI comment letter are
all of the specific comments--directly quoted from their
corresponding comment letter--with comment codes,followed
-ii-
by corresponding Alaska Power Authority Responses.Some
Power Authority Responses contain cross-references to other
responses.Cross-referenced Responses to Comments with
letter tabs A-H (e.g.,A.1,B.10,C.2S,etc.)can be found
in the Alaska Power Authority's January 19,1984 filing of
Responses to Agency Comments on License Application before
the Federal Energy Regulatory Commission.Cross referenced
Responses to Comments with letter tab "I"(e.g.,I.21,I.55
etc.)can be found in this Comment/Response Document.
Bibliographical references to the III"series Comment/
Responses can be found in this Comment/Response Document
following the Subject Index.
-iii-
-
SUBJECT INDEX
This Index classifies Comments and Responses by
subject matter.Each Comment/Response combination is listed
by an alphanumeric identifying code opposite a subject
discussed in the Comment and its accompanying Response.If
a Comment/Response deals with more than one subject,it is
listed opposite each subject with which it deals.
.....
Subject
Access
Comment/Response
Code Nos.
A.1
A.3
A.6
A.16
A.17
A.18
A.22
B.43
C.77
F.7
F.40
I.40
I.77
I.113
I.218
I.240
I.253
I.267
I.274
I.286
I.287
-iv-
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
1
2
2
5
5
5
5
20
21
2
11
5
12-13
19
35
38
40
42
42-43
44
44
Page of Each Agency's ~j
Original Comment Doc-
Comment/Response ument on which Coded
Subject Code Nos.Comment Appears
~
Access (cont.)I.289 44
~
I.294 44
I.303 46
I.305 46-47
I.308 47
I.312 48
I.344 56 ".;),
I.353 57 -I.363 58
I.364 58 -,
I.378 60-61
I.382 61 ~
I.384 62
I.385 62
I.386 62
""'"'
I.395 64
I.408 66
I.490 88
I.517 93
I.519 94
I.521 94
I.532 97
I.533 97
I.536 98
I.537 98
~~
-v-
Subject
Access (cont.)
Comment/Response
Code Nos.
I.539
I.553
I.554
I.575
I.576
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
98
101
101
106
106
~li\-Aesthetic Impact A.7 2
A.19 5
I.538 98
,~
Air Quality C.91 25
C.92 25
C.93 25
C.94 25-26
I.352 57
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
Alternatives (cont.)C.24
C.25
C.26
C.27
C.28
C.29
C .30
C.91
C.92
C.94
F.33
F.39
F.40
I.5
I.6
I.198
I.201
I.236
I.252
I.346
I.364
I.393
I.499
I.521
I.540
-vii-
7
8
8
8
8
8
9
25
25
25-26
9
11
11
2
2 (a)
31-32
32
38
40
56
58
64
90
94
99
~,
-
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appea.rs
-
-
-
,....
.-
Alternatives (cont.)
Aquatic Impacts
I.541
I.542
I.543
I.544
I.545
I.546
I.548
I.552
I.558
I.562
I.565
I.568
I.569
!o571
I.572
I.573
I.574
I.577
I.578
I.579
A.9
B.8
B.9
B.10
-viii-
99
99
99-100
100
100
100
100
101
102
102
103
104
104
104
104
104-105
105
106
106
107-108
3
6-7
7-8
9
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
Aquatic Impacts (cont.)B.11
B.13
B.19
B.24
B.28
B.37
B.39
B.40
B.41
B.44
B.45
B.54
B.55
B.57
B.62
C.35
C.36
C.37
C.39
C.40
C.41
C.so
C.51
C.S8
C.59
-ix-
9
9-10
11
13
14
18
18-19
19
19
20
20
23
23
23
25
10
10
10
11
11-12
12
14
14
15
16
~,
~,
~-
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
--
\
-
-
-
Aquatic Impacts (cont.)C.60
C.63
C.64
C.69
C.70
C.71
C.72
C.73
C.74
C.75
C.76
F.6
F.7
F.11
F.12
F.13
F.19
F.20
L7
LIS
L18
1.24
L 25
1.26
L35
-x-
16
17
17-18
19
19
19
19
20
20
20
21
2
2
3
3
3
5-6
6
2 (a)
1
1
2
2
2
4
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
Aquatic Impacts (cont.)I.41
I.49
lo50
lo53
lo 59
I.65
I.69
I.74
lo 75
lo89
I.91
I.93
lo 94
lo 96
lo97
1.98
lo104
lo109
I.1l0
r.114
I.115
r.116
lo117
r.130
lo131
-xi-
5
6
6
7
8
9
9
12
12
15
16
16
16
16
16-17
17
18
18
18
19
19
19
19
21
21
-
-
MiIDi
~,
.....
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
Aquatic Impacts (cont.)I.133
1.134
1.135
1.136
1.137
1.138
1.143
I.145
1.172
1.181
1.213
1.214
1.217
1.236
1.242
1.256
1.261
1.278
1.296
1.298
1.324
1.326
I.330
I.342
1.373
-xii-
22
22
22
22
22
22
23
23-24
28
29
35
35
35
38
39
41
41
43
45
45
51
51
52
55
60
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
~I
Aquatic Impacts (cont.)I.377
I.391
I.505
I.506
I.522
I.552
I.562
60
63
91
91
94
101
102
Archeological ~\
Resources A.2 1
A.12 4
E.1 1
F.38 10-11
F.52 14-15
~1
I.481 80
.I.495 89
~
I.496 89
~,
Bear A.10 3
C.87 23-24 """'"
F.35 10
~'f,
I.83 14
I.159 27 ....
I.160 27
I.161 27 ~.
I.162 27
~-
-xiii-
-xiv-
Subject
Commissioning
Facilities
Comment/Response
Code Nos.
B.12
B.25
I.43
I.59
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
9
13
6
8
-
mJI.1j\
Construction and
Construction Methods A.4 2
A.8 2-3
A.22 5
B.42 19
C.35 10
D.1 all
I.91 16
I.92 16
I.108 18
I.111 19
I.113 19
I.114 19
I.115 19
I.119 19-20
I.121 20
I.122 20
I.123 20
I.125 20
I.127 20
-xv-
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
-
....'
Construction and
Construction Methods
(cont.)I.146 24
T.190 30
I.191 30-31
I.192 31
I.194 31
I.222 36
I.226 37
I.227 37
I.248 40
I.262 41
I.275 43
I.286 44
I.287 44
I.288 44
I.294 44
I.305 46-47
I.336 54
I.337 54
I.343 55
I.355 57
I.356 57
I.363 58
I.365 58
I.367 59
-xvi-
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument!on which Coded
Comment Appears
Construction and
Construction Methods
(cont.)I.S43
loSS1
loSS7
loS76
99-100
101
101-102
106
....
.....
Coordination with
Agencies A.2 1
A.6 2
A.11 3
B.1 2
B.9 7-8
B.42 19
B.S8 24
B.S9 24
C.32 9
0.1 all
F.1 2(a)-3(a)
F.6 2
F.28 8
G.1 1
G.3 1
G.4 1
I.12 3 (a)
lo 71 12
I.81 13
I.119B 19
-xviii-
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
~,
Coordination with
Agencies (cont.)L147 24
L185 30
L219 35
1.225 36-37
L 246 39-40
L 250 40
1.253 40
L 263 41
L265 41-42
1.267 42
L 274 42-43
1.282 43
L289 44
L291 44
L302 46
1.367 59
L 382 61
L 386 62
L389 63
1.403 66
L408 66
1.409 66-67
1.424 70
1.496 89
L525 95
-xix-
~,
~\
~,
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
Coordination with
Agencies (cont.)
Costs (Economic)
I.537 98
A.15 4
C.16 5
C.17 5
C .18 5-6
C.19 6
1.301 46
1.531 97
I.579 107-108
Cumulative Impact F.43
I.82
12
14
Dam Safety C.62 17-I.60 8
1.143 23.....
I.346 56
1.563 102-103
Development Plans
Energy Conservation
1.549
C.8
C.9
-xx-
100
3
3
Subject
Energy Demand
Comment/Response
Code Nos.
B.65
C.2
F.3
1.560
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
26
1
1
102
'JIWr),
-
-
-
-
Subject
Fisheries (cont.)
Comment/Response
Code Nos.
C.69
C.70
C.71
C.72
C.73
C.74
C.75
C.76
C.77
F.2
F.3
F.9
F.10
F.11
F.12
F.13
F.14
F.15
F.16
F.17
F .18
F.19
F.20
F.22
F.23
-xxii-
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
19
19
19
19
20
20
20
21
21
1
1
2
2-3
3
3
3
3-4
4
4-5
5
5
5-6
6
7
7
Subject
Fisheries (cont.)
Comment/Response
Code Nos.
F.24
F.26
F.27
F.33
F.54
F.55
F.56
F.57
F.S8
I.7
I.23
I.25
I.26
I.27
I.29
I.41
I.4S
I.SO
I.57
I.6l
I.73
I.75
I.84
I.85
I.86
-xxiii-
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
8
8
8
9
15
15
16
16
16
2 (a)
2
2
2
3
3-4
5
6
6
8
8
12
12
14
15
15
~,
.-
.-.
"...
I
..-
Subject
Fisheries (cont.)
ALASKA RESOURCES LIBRARY
U.S,DEPT,OF INTERIOR
Page of Each Agency's
Original Comment Doc-
Comment/Response ument on which Coded
Code Nos.Comment Appears
I.87 15
I.88 15
I.89 15
I.90 16
I.94 16
I.95 16
I.97 16-17
I.98 17
I.99 17
I.104 18
I.106 18
I.117 19
I.118 19
I.121 20
I.132 21
I.13?22
I.138 22
I.140 23
I.141 23
I.142 23
I.293 44
I.296 45
I.298 45
I.342 55
I.491 88
-xxiv-
Page of Each Agency's ~,
Original Comment Doc-
Comment/Response ument on which Coded
Subject Code Nos.Comment Appears
~I
Fisheries (cont.)I.504 91
~1,
I.505 91
I.506 91
~
I.508 92
I.522 94 ~""'1
I.547 100
I.550 100-101
,~l
I.558 102
~
I.561 102
I.563 102-103 ",,",
I.570 104
Flow Regimes B.7 5-6
~
B.10 9
B.20 12
""'"
B.21 12
B.24 13 ~
B.26 13
B.35 17 <1/Il~,
B.39 18-19
""'"B.44 20
B.46 21
fllJi!ii'l',
B.64 26
B.65 26 ~~
C.60 16 -
-xxv-
-
.-
Comment/Response
Subject Code Nos.
Flow Regimes (cont.)C.70
C.71
C.87
F.2
F.3
F.10
F.11
F.12
F.13
F.19
F.25
F.26
I.5
I.24
I.26
I.27
I.28
I.29
I.33
I.35
I.61
I.63
I.94
I.102
I.110
-xxvi-
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
19
19
23-24
1
1
2-3
3
3
3
5-6
8
8
2
2
2
3
3
3-4
4
4
8
8-9
16
17-18
18
Subject
Comment/Response
Code Nos.
Page of Each Agencyrs
Original Comment Doc-
ument on which Coded
Comment Appears
~l
Flow Regimes (cont.)1.131
1.133
1.139
1.149
1.198
1.201
1.236
I.326
1.346
1.348
1.349
1.362
1.373
1.542
1.550
1.551
1.552
1.558
1.559
1.560
1.561
1.562
1.563
I.564
-xxvii-
21
22
23
24
31-32
32
38
51
56
56
56
58
60
99
100-101
101
101
102
102
102
102
102
102-103
103
-
~l
-Gas Supersaturation B.30 15
B.34 16-17
B.5S 24
B.63 25
C.47 13
1.55 7
1.58 8
-xxviii-
~~~-~~--~-~--------~-------------
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
Gas Supersaturation
(cont.)1.60 8
1.67 9
1.91 16
1.105 18
~>
1.143 23
.....
General Comments B.2 3
B.7 5-6
B.9 7-8
C .1 1
C.14 4
C.31 9
C.34 9-10
C.G5 18
C.82 22
C.83 23
C.89 24
C.90 24-25
F.l 2(a)-3(a)
F.5 1-2
F.29 8-9
F.44 12
F.45 12-13
F.48 13
F.72 19
-xxix-
..,..
Page of Each Agency's
Original Comment Doc-
Comment/Response urnent on which Coded
Subject Code Nos.Comment Appears.-
General Comments
(cont.)F.73 19
H.1 1
1.2 1 (a)
1.5 2 (a)
1.7 2 (a)
1.14 3 (a)
1.15 1
1.70 12
1.265 41-42
1.273 42
1.369 59
1.374 60
1.407 66
1.546 100
~!.lWI'I
Geology A.21 5
A.22 5
1.336 54
1.535 98
F'""
Groundwater B.1S 11
B.19 11
1.22 2
.....
1.42 5
1.562 102.-
-xxx-
Page of Each Agency's
original Comment Doc-~
Comment/Response ument on which Coded
Subject Code Nos.Comment Appears
Hunting 1.513 92-93
~~
Hydrology B.14 10
""",'
B.17 10-11
B.1S 11
B.19 11
B.43 20 ~
B.46 21
~'!"
B.S5 23
C.31 9
~,
C.34 9-10
C.3S 10 ~)
C.37 10
C.38 10
C.39 11
C.40 11-12
C.42 12 -,
C.45 13
C.46 13
C.47 13
14 -C.49
C.60 16
~\
I.15 1
1.22 2
I.36 4
~
-xxxi-
Subject
Hydrology (cont.)
Comment/Response
Code Nos.
1.42
1.44
1.61
1.65
1.74
1.96
1.101
1.102
1.129
1.148
1.293
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
5
6
8
9
12
16
17
17-18
20-21
24
44
Ice B.6 4-5
B.22 12
B.31 15
B.32 15-16
B.33 16
B.40 19
B.44 20
C.42 12
C.43 12
C.44 12
C.61 16
1.29 3-4
1.39 5
-xxxii-
Subject
Ice (cont.)
Land Titles
Comment/Response
Code Nos.
1.40
1.48
1.50
I.53
1.54
I.65
1.73
l.107
1.132
1.183
1.188
I.198
1.278
1.346
1.347
1.348
1.349
1.352
1.373
1.562
A.5
1.534
-xxxiii-
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
5
6
6
7
7
9
12
18
21
29
30
31-32
43
56
56
56
56
57
60
102
2
98
"""
,~
Comment/Response
Subject Code Nos.
License Conditions I.3
I.128
lo283
lo377
I.395
I.425
lo551
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
l(a)
20
43
60
64
71
101
Local Land Use A.17 2
F.4 1
F.68 18
F.69 18
F.70 18-19
I'"''F.71 19
lo533 97
.-
Mitigation,Mitigation
Measures and
Mitigation Plans A.9
A.I0
B.6
B.9
B.36
B.41
B.43
B.47
-xxxiv-
3
3
4-5
7-8
17
19
20
21
,-----------------"""----
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
Mitigation,Mitigation
Measures and
Mitigation Plans
(cont.)B.48 21
B.49 22
B.50 22
B.51 22
B.52 22
B.53 22
B.54 23
B.56 23
B.57 23
B.59 24
C.21 7
C.50 14
C.56 15
C.60 16
C.63 17
C.74 20
C.75 20
C.76 21
C.82 22
C.88 24
D.1 all
F.6 2
F.9 2
F.10 2-3
-xxxv-
1""",
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
~I
Mitigation,Mitigation
Measures and
Mitigation Plans
(cont.)I.15 1
lo 45 6
lo69 9
lo 72 12
lo 74 12
I.75 12
lo 79 13
I.80 13
lo 81 13
I.84 14
I.91 16
I.119 19-20
I.120 20
I.121 20
I.124 20
I.126 20
lo127 20
I.128 20
lo130 21
I.131 21
I.132 21
lo133 22
lo134 22
I.135 22
-xxxvi i-
Subjec"t
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
..."
..-
Mitigation,Mitigation
Measures and
Mitigation Plans
(cont.)1.137 22
1.138 22
1.139 23
1.140 23
1.141 23
1.143 23
1.144 23
1.145 23-40
1.146 24
1.148 24
1.153 26
1.174 28
1.179 29
1.181 29
1.185 30
1.198 31-32
1.205 33
l.207 33
1.209 34
1.213 35
1.216 35
1.219 35
1.222 36
1.230 37
-xxxviii-
-----_._.-.._--_._----_.~.--_._~._._-_.._.-----,---,-~-_.__._--,---~-----------------
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
Mitigation,Mitigation
Measures and
Mitigation Plans
(cont.)I.231 37-38
I.232 38
I.236 38
I.245 39
1.246 39-40
1.247 40
1.253 40
I.259 41
I.261 41
I.262 41
I.263 41
.I.264 41
1.265 41-42
I.273 42
1.274 42-43
I.276 43
I.279 43
I.280 43
1.281 43
I.289 44
I.290 44
I.291 44
1.292 44
I.293 44
-xxxix-
~,
~i
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
.....
Mitigation,Mitigation
Measur,es and
Mitigation Plans
(cont.)I.295 44-45
I.296 45
I.298 45
I.301 46
1.312 48
I.313 48
I.314 48
I.323 51
I.328 51
I.331 52
I.343 55
I.346 56
I.356 59
I.366.58-59
I.374 60
1.375 60
I.376 60
I.377 60
I.379 61
I.380 61
I.381 61
1.384 62
I.391 63
I.394 64
-xl-
._..._.__•.._~-~--------_.
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
Mitigation,Mitigation
Measures and
Mitigation Plans
(cont.)I.395 64
I.397 64-65
I.400 65
I.401 65
I.402 66
I.406 66
I.409 66-67
I.411 67
I.419 68
I.420 68
1.421 68
I.424 70
I.490 88
I.494 88
I.497 90
I.498 90
I.514 93
I.516 93
I.522 94
I.525 95
1.526 95
1.528 95
I.536 98
I.548 100
-xli-
~I
~I
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
Mitigation,Mitigation
Measures and
Mitigation Plans
(cont.)I.553
I.554
-xlii-
101
101
_..._,_,..~..~..=~---_'~_..."l1l'I'_
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
Modeling
(Environmental)
(cont.)B.G5 26
C.14 4
C.20 6
C.34 9-10
C.42 12
C.58 15
C.71 19
C.86 23
F.42 11-12
L2 1 (a)
L3 1 (a)
L10 2(a)
L16 1
L 22 2
1.38 5
L39 5
L41 5
L46 6
L47 6
L 48 6
L49 6
1.51 6-7
L52 7
L53 7
-xliii-
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
-
Modeling
(Environmental)
(cont.>1.60 8
1.62 8
1.64 9
1.66 9
1.73 12
1.100 17
I.I07 18
I.130 21
1.145 23-24
1.168 28
1.178 29
1.186 30
1.187 30
1.188 30
1.198 31-32
1.203 32
1.214 35
1.229 37
1.242 39
1.246 39-40
I.278 43
1.295 44-45
1.314 48
1.315 50
-xliv-
~~
Page of Each Agency's
Original Comment Doc-
Comment/Response ument on which Coded
Subject Code Nos.Comment Appears
~
Modeling
(Environmental)~!
(cont.)lo 366 58-59
lo394 64
lo403 66
lo405 66 ~;
lo 491 88
lo 497 90 --
1.500 90
~
lo501 90
lo558 102
1.561 102
~
Monitoring A.4 2
fPi$.1
B.8 6-7
B.56 23 -,
B.57 23
B.58 24 ~,
B.59 24
B.60 24 "'1
C.34 9-10
C.38 10-11
C.39 11
C.41 12
C.67 18 ~
C.68 18-19
C.69 19 ~l
-xlv-
-
....
I'....
Comment/Response
Subjec~Code Nos.
Monitoring (cont.)C.71
C.85
F.13
F.30
F.42
F.47
F.74
I.3
I.4
I.10
I.14
I.18
I.34
I.35
I.46
I.77
I.78
I.85
I.89
I.90
I.99
I.101
I.119
I.136
I.147
-xlvi-
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
19
23
3
9
11-12
13
19--20
1 (a)
1 (a)
2 (a)
3 (a)
1
4
4
6
12-13
13
15
15
16
17
17
19-20
22
24
,~~~
Page of Each Agency's
Original Comment Doc-
Comment/Response ument on which Coded
Subject Code Nos.Comment Appears
~
Monitoring (cont.)1.154 26
L156 27
L160 27
I.168 28
L169 28 1"""
I.170 28
1.171 28
,~-
L172 28 -
L178 29
L181 29 ~.
L185 30
L 213 35
L242 39
I.251 40
L265 41-42
L266 42
L267 42
I.268 42
I.269 42
I.271 42
""'"L 272 42
I.302 46
L313 48
L314 48 ~
I.315 50 -
-xlvii-
-xlviii-
-dl-
''''''''
Page of Each Agency's
Original Comment Doc-
Comment/Response ument on which Coded
Subjec1=.Code Nos.Comment Appears
Moose (cont.)Ll66 27
1.178 29
Ll79 29
~
Ll80 29
,-Ll82 29
L183 29-1.184 29
L186 30
1.227 37
1.234 38
L 235 38
!"""1.237 38
1.246 39-40
L248 40
L249 40
L250 40
1.272 42
L 276 43
1.277 43
1.298 45
L306 47
L347 56
L 388 62-63
,~L394 64
1.403 66
-1-
Page of Each Agency's
Original Comment Doc-~
Comment/Response ument on which Coded
Subject Code Nos.Comment Appears
~,
Moose (cant.)I.492 88
I.518 93 ~
I.519 94
~~,
Navigation C.61 16
~
Net Benefits ~~
(Economic)C.14 4
C.15 5
"""
I.560 102
~
Oil Prices C.5 2
C .10 3 -
~'I'
Oil Spills C.51 14
C.52 14
C.54 14
~I.
Project Changes B.1 2
flPJf',
B.2 3·
B.3 3
~\
B.4 3
B.5 3-4
B.27 13-14
B.35 17
-li-
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-.
urnent on which Coded
Comment Appears
Project Changes
(cont.]1 B.36 17
B.61 25
B.63 25
B.65 26
C.13 4
C.30 9
C.33 9
Projec·t Operation B.27 13-14,-I.552 101
~...
Recrea'tion A.7 2
C.21 7
C.61 16
F.15 4
F.16 4-5
F F.17 5
F .18 5
.~
F.19 5-6
......F.21 6
F.22 7
r~F.23 7
F.63 17-F.64 17
F.65 17-18
"'-
-Iii-
Page of Each Agency's
Original Comment Doc-
Comment/Response ument on which Coded
Subject Code Nos.Comment Appears
Recreation (cont.)F.G6 18
~l
F.67 18
F.68 18
~,
F.G9 18
r.40 5 ..,
r.150 26
r.155 26
I.190 30 -r.202 32
I.233 38
""'"
I.264 41
I.291 44 .~iI!~
I.307 47
~
I.502 91
I.511 92
I.538 98
Settlement Process B.7 5-6
B.59 24 .-
F .1 2(a)-3(a)....
F.6 2
F.2~8
F.28 8
F.64 17 ~
F.71 19
-liii-
Comment/Response
Subject Code Nos.
Settlement Process
(cont.)I.12
I.13
I.422
I.423
I.425-I.489
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
3 (a)
3 (a)
69
69
71-83
Socioeconomics A.2 1
A.12 4
A.13 4
A.14 4
A.15 4
A.16 5
A.17 5
C.61 16
F.4 1
F.8 2
F.14 3-4
F.15 4
F.17 5
F.18 5
F.19 5-6
F.22 7
F.23 7
F.53 15
F.54 15
-liv-
--~------------------
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
""'"
Socioeconomics (cont.)F.SS
F.56
F.57
F.58
F.S9
F.60
F.61
F.62
F.64
F.65
F.66
F.68
1.6
I.91
1.150
1.155
1.170
I.176
1.190
I.203
1.233
I.264
1.292
1.495
1.497
-lv-
15
16
16
16
16-17
17
17
17
17
17-18
18
18
2 (a)
16
26
26
28
29
30
32
38
41
44
89
90
-
Subjec·t
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
-
-
.-
-
Socioeconomics (cont.)I.49B
L500
L 501
I.502
L503
I.506
L507
L50B
L 509
I.5l0
L511
I.5l2
L5l3
L514
L5l5
I.516
I.517
L SIB
L5l9
I.520
I.52l
I.523
L524
I.526
L527
-lvi-
90
90
90
91
91
91
91
92
92
92
92
92
92-93
93
93
93
93
93
94
94
94
95
95
95
95
Subject
comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
Socioeconomics (cont.)I.529
I.530
1.531
1.532
1.533
97
97
97
97
97
--Soil Stability 1.109 18
1.111 19
I.126 20
1.136 22 ""'"
1.336 54
1.338 55 ~'J,
1.344 56
_!it':
1.345 56
1.355 57
~.
1.357 57
1.361 58
Transmission Lines ~t
and Corridors A.18 5
A.19 5
C.81 22
D.1 11 ~
F.39 11
G.1 1
~
-lvii-
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
-
Transmission Lines
and Corridors (cont.)G.2 1
G.3 1
G.4 1
1.77 12-13
1.78 13
1.113 19
I.225 36-37
1.226 37
1.227 37
1.228 37
1.231 37-38
1.249 40
I.254 40
1.263 41
I.277 43
1.303 46
1.305 46-47
I.320 50
1.327 51
1.328 51
1.329 51
1.344 56
1.365 58
1.366 58-59
1.367 59
-lviii-
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
--
Transmission Lines
and Corridors (cont.)1.370 59
1.371 59-60
1.382 61
1.385 62
1.387 62
1.392 63
1.393 64
1.394 64
1.395 64
1.409 66-67
1.415 67
1.419 68
1.499 90
1.539 98
1.555 101
1.556 101
1.577 106
~,\
Vegetation A.10 3
C.42 12 fN;ii
C.48 13-14
C.87 23-24 ~
C.89 24 -,
F.45 12-13
F.50 14 Jmi>\~
-lix-
-
SUbject
Vegeta'tion (cont.)
Comment/Response
Code Nos.
F.51
I.29
I.76
I.77
I.78
1.79
1.80
1.81
1.82
1.91
1.110
1.124
1.151
1.152
1.180
1.181
1.192
1.198
1.213
1.221
I.225
1.226
I.235
1.239
1.248
-lx-
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
14
3-4
12
12-13
13
13
13
13
14
16
18
20
26
26
29
29
31
31-32
35
36
36-37
37
38
38
40
Subject
Vegetation (cont.)
Comment/Response
Code Nos.
I.266
I.272
I.276
I.277
I.278
I.279
I.293
I.299
I.300
I.304
I.306
I.309
I.311
I.316
I.317
I.31B
I.319
I.320
I.321
I.322
I.323
I.324
I.325
I.326
I.327
-lxi-
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
42
42
43
43
43
43
44
45
45
46
47
47
48
50
50
50
50
50
50
50
51
51
51
51
51
-
-
~\
.,...
pv~
Page of Each Agency's
Original Comment Doc-
Comment/Response ument on which Coded
SUbjec~Code Nos.Comment Appears
~
Vegetation (cont.)1.328 51
1.329 51
I.330 52
f"~
I.331 52
1.332 52-53
1.334 54
~1.336 54
I.337 54
1.338 55
1.339 55
1.340 55
..,.,1.341 55
I.342 55
I.343 55
1.344 56
""'"
1.345 56
1.346 56
1.347 56
1.348 56
I.350 57
1.351 57
1.352 57
F'""
I.354 57
-1.356 57
1.357 57
-lxii-
------------,------------~_.-,--------
Subject
Vegetation (cont.)
Comment/Response
Code Nos.
I.360
I.362
I.363
I.365
I.366
I.368
I.370
I.372
I.373
I.378
I.379
I.383
I.388
I.392
I.394
I.396
I.397
I.402
I.404
I.405
I.406
I.409
I.413
I.414
I.415
-lxiii-
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
58
58
58
58
58-59
59
59
60
60
60-61
61
61
62-63
63
64
64
64-65
66
66
66
66
66-67
67
67
67
~,
.,.....,.
..."
-
-
Subject
Vegetation (cont.)
Wastewater
Comment/Response
Code Nos.
1.416
I.4l9
I.492
1.562
1.563
1.566
C.51
C.54
C.55
C.56
I.20
-lxiv-
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
67
68
88
102
102-103
103
14
14
14-15
15
1
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
Water Quality (cant.)C.40
C.46
C.48
C.49
C.51
C.53
C.54
C.5S
C.S7
C.S8
C.S9
C.72
C.74
L17
L19
1.20
I.21
L 28
L32
L34
1.41
I.43
I.49
LS4
1.56
-lxv-
11-12
13
13-14
14
14
14
14
14-15
15
15
16
19
20
1
1
1
2
3
4
4
5
6
6
7
8
-
~i
'"""
Subj ec1=.
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
-
-
Water Quality (cont.)1.68
1.73
1.87
1.93
1.103
1.111
1.112
1.113
1.116
1.128
1.342
1.359
9
12
15
16
18
19
19
19
19
20
55
58
Water Temperature A.9 3
B.6 4-5
.tm~
B.15 10
B.16 10
B.22 12
B.23 12
B.26 13
B.29 14-15
B.30 15
B.31 15
B.32 15-16
B.33 16-
-lxvi-
r-
-----------
Page of Each Agency's ~
Original Comment Doc-
Comment/Response ument on which Coded
Subject Code Nos.Comment Appears
~
Water Temperature
(cont·.)B.36 17 -
B.38 18·
B.40
~
19
B.58 24
~7\
C.47 13
I.22 2 """
I.30 4
I.31 4
I.37 4 -,
I.38 5
L45 6
~
L51 6-7
L52 7
I.54 7
I.62 8 ~~
I.63 8-9
~
I.64 9
I.66 9
I.73 12
I.I00 17 ~,
I.I04 18
I.139 23
~
I.149 24
I.278 43
I.352 57
-lxvii-
Subject
Water Temperature
(cont.)
Comment/Response
Code Nos.
I.491
I.551
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
88
101
Page of Each Agency's ""'"Original Comment Doc-
Comment/Response ument on which Coded
Subject Code Nos.Comment Appears
~
Wetlands (cont.)I.416 67
~~
I.417 67
I.420 68 ~
I.424 70
I.566 103 ~l
-lxix-
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
-
Wildlife Impact
(cont.)F.33 9
F.34 9
F.35 10
F.36 10
F.37 10
F.38 10-11
F.39 11
F.41 11
F.42 11-12
F.43 12
F.45 12-13
F.46 13
F.47 13
F.50 14
F.51 14
-
F.52 14-15
1.7 2 (a)
1.11 3 (a)
1.29 3-4
1.39 5
1.40 5
1.77 12-13
I.79 13
1.83 14
I.84 14
-lxx-
---------,
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Conunent Appears
Wildlife Impact
(cont.)I.ISS 26
LIS7 27
LIS8 27
LIS9 27
Ll60 27
Ll61 27
I.163 27
Ll64 27
Ll6S 27
Ll66 27
I.167 27
Ll68 28
I.169 28
Ll71 28
Ll72 28
I.173 28
I.174 28
Ll7S 29
Ll77 29
Ll80 29
Ll82 29
Ll83 29
Ll84 29
Ll88 30
Ll89 30
-lxxi-
~,
-
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
-
-
wildlife Impact
(cont.)I.190 30
I.191 30-31
I.192 31
I.193 31
I.194 31
I.195 31
I.196 31
I.197 31
I.198 31-32
I.199 32
I.200 32
1.201 32
I.202 32
I.203 32
I.204 32-33
I.205 33
I.206 33
1.207 33
I.208 33
I.209 34
1.211 35
I.212 35
I.213 35
I.214 35
I.215 35
-lxxii-
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
~\
Wildlife Impact
(cont.)1.216 35
1.217 35
I.219 35
I.220 36
1.221 36
I.223 36
I.224 36
I.226 37
I.227 37
1.229 37
1.230 37
I.231 37-38
1.232 38
I.234 38
1.235 38
I.237 38
1.238 38
1.239 38
1.240 38
1.241 39
I.242 39
1.243 39
1.244 39
I.246 39-40
1.248 40
-lxxiii-
~,
-
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
,....
-
.....
wildlife Impact
(cont .]1 1.249 40
1.251 40
1.252 40
1.255 40
I.256 41
1.257 41
I.258 41
I.259 41
I.260 41
1.261 41
1.263 41
1.264 41
I.267 42
I.268 42
I.269 42
1.270 42
I.271 42
1.272 42
I.274 42-43
I.276 43
1.280 43
1.281 43
1.282 43
1.283 43
1.284 44
-lxxiv-
Subject
Comment/Response
Code Nos.
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
wildlife Impact
(cont.)1.285 44 '"""
1.286 44
1.287 44 ~
1.289 44
~'1,
I.290 44
1.293 44 -,
1.295 44-45
1.296 45 ~,
1.297 45
1.298 45
1.299 45
1/Ji!I?£\
1.300 45
I.305 46-47
1.306 47
I.307 47 ,~
I.308 47
""'"1.309 47
I.310 47
~
I.311 48
I.312 48
1.317 50
1.323 51 -,
1.324 51
~
I.338 55
1.340 55
~j\
-lxxv-
-
-lxxvi-
Comment/Response
Subject Code Nos.
Worst Case Analysis A.I0
B.5
B.6
C.66
C.93
F.33
F.34
-lxxvii-
Page of Each Agency's
Original Comment Doc-
ument on which Coded
Comment Appears
3
3-4
4-5
18
25
9
9
.....
Bibliography
For
Response of
Alaska Power Authority To
December 12,1983 License Application Comments
of
United States Department of the Interior,
Office of the Secretary
-
i~,
REFERENCE TITLE:
Acres American,Inc.,Geotechnical
Report,Volume 2,Appendix K -Reservoir
Slope Stability (1980-1981).
Acres American,Inc.,Susitna Hydro-
electric Project,Development Selection,
Final Report (December 1981),previously
submitted to the FERC on March 15,1982.
Acres American,Inc.,Nitrogen Super-
saturation Studies Memorandum
(September 13,1982).
Acres American,Inc.,Susitna Hydro-
electric Project,1982 Supplement to the
1980-81 Geotechnical Report,Volume 1
(December 1982).
Acres American,Inc.,Susitna Hydro-
electric Project,Subtask 7.12 -Phase I
Final Report,Environmental Studies,
Plant Ecology Studies (1982).
Steigers,W.D.,Jr.,D.Helm,
J.G.MacCracken,J.D.McKendrick
and F.V.Mayer report.
McKendrick,J.,W.Collins,D.Helm
J.McMullen and J.Koranda report.
Acres American,Inc.,Susitna Hydro-
electric Project,Task 2 -Survey and
Site Facilities,Subtask 2.15 -Slope
Stability and Erosion Studies Closeout
Report,Final Draft (1982).
-lxxviii-
COMMENT/RESPONSE
CODE NOS.
1.336
1.544
1.579
1.60
1.194
1.192
1.321
1.326
1.336
---------"""--------_._-----------_.._-----_.._-------------
REFERENCE TITLE:
Acres American,Inc.,Supplement to the
Fea~ibility Report (March 1983).
Acres American,Inc.,Susitna Hydro-
electric Project -Feasbility Report,
Volume I Engineering and Economic
Aspects,Final Draft (1982),previously
submitted to the FERC on March 15,1982.
Acres American,Inc.,Draft Susitna
Hydroelectric Project Slough
Hydrogeology Report (March 1983),
previously submitted to the FERC on
July 11,1983.~
Alaska Department of Fish and Game
(ADF&G),Alaska Wildlife Management
Plans,South-Central Alaska (1976),
previously submitted to the FERC on
October 31,1983.
ADF&G,Preliminary Environmental Assess-
ment of Hydroelectric Development on the
Susitna River (1978).
ADF&G,Susitna Hydro Aquatic Studies,
Subtask 7.10 -Phase I Final Draft
Report,Aquatic Habitat and Instream
Flow Project (1981).
ADF&G,Susitna Hydroelectric Project,
Phase I Final Report -Big Game Studies
(1982),previously submitted to the FERC
on May 31,1983.
Ballard,W.B.,J.H.Westlund,
C.L.Gardner,and R.Tobey,
Volume VIII,Dall Sheep (1982).
Miller,S.D.and D.C.McAllister,
Volume VI,Black Bear and Brown
Bear (1982).
Pitcher,Kenneth W.,Volume IV,
Caribou (March 1982).
-lxxix-
COMMENT/RESPONSE
CODE NOS.
1.384
1.544
1.22
1.514
1.75
1.7
1.63
1.99
1.189
1.163
1.254
1.293
1.299
1.516
".,..
J~
~,
REFERENCE TITLE:
ADF&G,Susitna Hydroelectric Project,
Subtask 7.11 -Phase I Report,
Environmental Studies,Furbearer Studies
(1982)•
Gipson,P.S.,S.W.Buskirk and
T.W.Hobgood (April 1982).
ADF&G,Su-Hydro Stock Separation
Feasibility Report,Adult Anadromous
Fisheries (1982).
ADF&G,Susitna Hydro Aquat{c Studies,
Phase II Basic Data Reports for 1982,
5 Volumes (1983),previously submitted
to the FERC on October 31,1983.
Synopsis of the 1982 Aquatic Studies
and Analysis of Fish and Habitat
Relationship (1982).
Volume 2,Adult Anadromous Fish
Studies (1982).
Volume 3,Resident and Juvenile
Anadromous Fish Studies on the
Susitna River below Devil Canyon
(1982)•
ADF&G,Susitna Hydro Aquatic Studies,
Phase II Basic Data Reports,Index of
Data and Analyses (1983).
-lxxx-
COMMENT/RESPONSE
CODE NOS.
1.171
1.172
1.310
1.506
1.99
1.8
1.23
1.27
1.85
1.86
1.88
1.97
1.99
1.57
1.95
1.99
1.117
1.99
REFERENCE TITLE:
ADF&G,Susitna Hydroelectric Project,
Phase II Progress Report ~Big Game
Studies (1983),previously submitted to
the FERC on May 31,1983.
Ballard,W.B.,J.S.Whitman,
N.G.Tankersley,L.D.Aumiller and
P.Hessing,Volume III,
Moose-Upstream (1983).
Miller,S.,Volume VI,Black and
Brown Bear (1983).
Modafferi,R.D.,Volume II,Moose-
Downstream (1983).
Tankersley,N.G.,Volume VIII,Dall
Sheep (1983).
ADF&G,Susitna Hydro Aquatic Studies Draft
Phase II Data Report -Winter Aquatic
Studies,October 1982-May 1983 (1983),
previously submitted to theFERC on
October 31,1983.
ADF&G,Summary of Preliminary Plans for
FY 1984 Aquatic Studies Program
Activities by Habitat Type and River
Mile.
Alaska Power Authority,Response to FERC
Supplemental Information Request,
Comment 34 (April 12,1983),previously
submitted to the FERC on July 11,1983.
Alaska Power Authority,Letter from Richard
Fleming to Chris Beck,Department of
Natural Resources (August 23,1983).
Alaska Power Authority,Susitna Hydro-
electric Project Watana Airstrip
Feasibility Study Phase I,Task 39,
Draft Report (September 1983),pages 8,
19-20,Figure 1,Appendix E.
-lxxxi-
COMMENT/RESPONSE
CODE NOS.
1.184
1.237
I.254
I.293
I.154
I.189
1.99
I.172
1.75
I.525
I.251
I.92
~I
--
REFERENCE TITLE:
Alaska Power Authority,Susitna Hydro-
electric Project FERC License Application
Project No.7114-000 (1983)Volume lOB,
u.s.Fish and Wildlife Service Letter on
the Draft License Application
(January 14,1983),previously submitted
to the FERC on July 11,1983.
Alaska Power Authority,Susitna Hydro-
electric Project FERC License
Application Project No.7114-000 (1983)
Volume lOB,Response to U.S.Fish and
Wildlife Service Letter on the Draft
License Application,previously
submitted to the FERC on July 11,1983.
Alaska Power Authority,Susitna Hydro-
electric Project FERC License
Application Project No.7114-000 (1983)
Volume lOA,U.S.Fish and Wildlife
Service Letter (Janaury 24,1983),
previously submitted to the FERC on
July 11,1983.
Alaska Power Authority,Response to FERC
Supplemental Information Requests 3-B-15
and 3-B-16 (1983),previously submitted
to the FERC on July 11,1983.
Alaska Power Authority,Response to FERC
Supplemental Information Request,3W-4
(1983),previously submitted to the FERC
on July 11,1983.
Alaska Power Authority,Response to FERC
Supplemental Information Request 5-22
(1983),previously submitted to the FERC
on September 1,1983.
Alaska Power Authority,Response to FERC
Supplemental Information Request 5-23
(1983),previously submitted to the FERC
on July 11,1983.
Alaska Power Authority,Response to FERC
Supplemental Information Request 5-26
(1983),previously submitted to the FERC
on July 11,1983.
-lxxxii-
COMMENT/RESPONSE
CODE NOS.
I.5
I.22
I.5
I.117
I.367
I.209
I.519
I.518
I.519
I.501
REFERENCE TITLE:
Alaska Power Authority,Response to FERC
Supplemental Information Request 6-7
(1983),previously submitted to the FERC
on July 11,1983.
Alaska Power Authority,Typical Cross
Section,Susitna Transmission Concept
For Construction,Maintenance Access and
Clearing -Two Single Circuit Lines
(January 1984).
American Ornithologists'Union (A.O.U.),
Check-list of North American Birds (6th
Ed • ) (19 8 3)•
Asherin,D.A.,Changes in the Elk Use and
Available Browse Production on North
Idaho Winter Ranges Following Prescribed
Burning,pages 122-134 in:Proc.
Elk-Logging-Roads Symp.-,-UniV.of Idaho,
Moscow (1976).
Arctic Environmental Information and Data
Center (AEIDC),Susitna Hydroelectric
Project Aquatic Impact Assessment:
Effects of Project-Related Changes in
Temperature,Turbidity,and Stream
Discharge on Upper Susitna Salmon
Resources During June Through September
(January 1984),previously submitted to
the FERC on January 20,1984.
Ballard,W.B.,T.H.Spraker and K.P.
Taylor,Causes of Neonatal Moose Calf
Mortality in South-central Alaska,J.
Wild.Manage.,45(2):335-342 (1981).
Barry,T.W.and R.Spencer,Wildlife
Response to Oil and Well Drilling,Can.
Wildl.Servo Prog.Note No.67 (1976).
-lxxxiii-
COMMENT/RESPONSE
CODE NOS.
1.336
1.226
1.83
1.227
1.18
1.24
1.38
1.145
1.505
1.299
1.227
,...
.....
REFERENCE TITLE:
Battelle Pacific Northwest Laboratories,
Railbelt Electric Power Alternatives
Study,Volumes 1-17,prepared for the
Office of the Governor,State of Alaska
(1982),previously submitted to the FERC
on July 11,1983.
Volume I,Evaluation of Railbelt
Electric Energy Plans (1982).
Volume II,Selection of Electric
Energy Generation Alternatives for
Consideration in Railbelt Electric
Energy Plans (December 1982).
Volume IV,Candidate Electric Energy
Technologies for Future Application
in the Railbelt Region of Alaska
(October 1982).
Bechtel Civil and Minerals,Chakachamna
Hydroelectric Interim Feasibility
Assessment Report (1983),previously
submitted to the FERC on July 11,1983.
Buskirk,S.W.,The Ecology of Marten in
South-Central Alaska,Ph.D.Thesis,
Univ.of Alaska,Fairbanks (1983).
CRREL,Environmental Engineering and
Ecological Baseline Investigations Along
the Yukon River,Prudhoe Bay Haul Road,
Report 80-19,u.S.Army Corps of
Engineers (1980).
Commonwealth Associates,Inc.,
Environmental Assessment Report,
Anchorage-Fairbanks Transmission Intertie
(1982),previously submitted on July 11,
1982.
Conner,R.N.,Seasonal Changes in Wood-
pecker Foraging Patterns,
Auk.98 (3):56 2- 570 (19 8 3).
-lxxxiv-
COMMENT/RESPONSE
CODE NOS.
1.541
1.569
1.6
1.547
1.246
1.340
1.328
1.83
REFERENCE TITLE:
Cowardin,L.M.,V.Carter,F.C.Golet
and E.T.LaRoe,Classification of
Wetlands and Deepwater Habitats of the
United States,Office of Biological
Services,U.S.Fish and wildlife
Service,FWS/OBS-79-31 (1979).
Cugnasse,J.M.,Adoption d'une aire
artificielle par un couple de faucons
pelerins et note sur la maturite
sexuelle de la femelle,Nos.Oiseaux
35:238-242 (1980).
Curatolo,J.A.,M.S.Boyce,M.A.
Robus and R.H.Kacyon,Aquatic Furbearer
Habitat Survey-Final Report,Alaska
Biological Research,Fairbanks,Alaska
(1981).
de S.Pinto,N.L.,S.H.Neidert and
J.J.Ota,Water Power and Dam
Construction Aeration at High Velocity
and Flows (February-March 1982).
Densmore,R.V.,Aspects of the Seed
Ecology of Woody Plants of Alaskan Tiaga
and Tundra,Ph.D Thesis,Duke
University,North Carolina (1979).
Dills,G.G.,Effects of Prescribed
Burning on Deer Browse,J.wildl.
Manage.,34:540-545 (1970).
Dunstan,T.C.and M.Borth,Successful
Reconstruction of Active Bald Eagle
Nest,Wilson Bull.82:236-237 (1970).
Ecological Analysts,Inc.,Lake Comanche
Dissolved Nitrogen Study (1982).
Erickson,A.B.,V.E.Gunvabon,M.H.
Stenlund,D.W.Burcalow and L.H.
Blankenship,The White-Tailed Deer of
Minnesota,Minnesota Div.of Game and
Fish Tech.Bull.No.5 (1961).
Errington,P.L.,Muskrats and Marsh
Management (1961).
-lxxxv-
COMMENT/RESPONSE
CODE NOS.
I.324
I.325
I.331
I.332
I.205
I.199
I.105
I.354
I.227
I.205
I.60
I.227
I.199
~l
-
....
REFERENCE TITLE:
Euler,D.,The Economic Impact of
Prescribed Burning on Moose Hunting,J.
Environ.Manage.3:1-5 (1975).
Falvey,Henry J.,Air-Water Flow in
Hydraulic Structures,Free Falling Water
Jets,U.S.Department Of the Interior,
Water and Power Resources Service (now
Bureau of Reclamation),Denver,CO
(December 1983).
Fancy,Steven G.,Movements and Activity
Budgets of Caribou Near Oil Drilling
Sites in Sagavanirktok River Floodplain,
Alaska (June 1983),previously submitted
to the FERC on May 31,1983.
Ffolliott,P.F.,R.E.Thill,W.P.
Clary and F.R.Larson,Animal Use of
Ponderosa Pine Forest Openings,J.
Wildl.Manage.,41:782-784 (1977).
Friedman,B.F.,The Ecology and
Population Biology of Two Targon Shrubs,
Lingonberry and Alpine Blueberry,
unpublished M.S.Thesis,University of
Alaska,Fairbanks (1981).
Fyfe,R.W.and H.I.Armbruster,Raptor
Research and Management in Canada,
pages 282-293 in:R.D.Chancellor
(ed.),Proceedings of the World
Conference on Birds of Prey,Vienna,
1975,IntI.Council Bird Preserve
(1975)•
Geist,V.,On the Behaviour of the North
American Moose (Alces alces andersoni
Peterson 1950)in British Columbia,
Behav.,20:377-416 (1963).
Gerard,L.,Notes on Ice Jams,for Ice
Engineering in Rivers and Lakes,
University of Wisconsin,Madison (1983).
Gysel,L.W.,Bulldozing to Produce
Browse for Deer,Michigan Agr.Exp.
Sta.,Lansing,Quarterly Bull.,
No.43:722-731 (1961).
-lxxxvi-
COMMENT/RESPONSE
CODE NOS.
1.227
1.105
1.251
1.227
1.299
1.205
1.227
1.348
1.227
REFERENCE TITLE:
Hall,I.V.and L.E.Aalders,Lowbush
Blueberry Production and Management,in:
Lowbush Blueberry Production (1979).
Harza-Ebasco,Susitna Hydroelectric
Project Reservoir and River
Sedimentation,Draft Report (1983).
Harza-Ebasco Susitna Joint Venture,
Eklutna Lake Temperature and Ice Study
(with 6-month simulation for Watana
Reservoir),Draft Report (January 1984).
Harza-Ebasco,Susitna Hydroelectric Pro-
ject River Stage Fluctuation Resulting
from Watana Operation (January 1984).
Frank Orth &Associates,working Paper
No.1,Susitna Hydroelectric Project,
Subtask 4.5 -Socioeconomic Studies:
Project Assumptions,Methodology and
Output Formats (1983).
Jakimchuk,R.D.,Disturbance to
Barren Ground Caribou;a Review of the
Effects and Implications of Human
Developments and Activities (July 1980),
previously submitted to the FERC on
May 31,1983.
Joint Federal-State Land Use Planning
Commission for Alaska,Major Ecosystems
of Alaska,Map (1973),previously
submitted to the FERC on July 11,1983.
Klein,D.R.,The Reaction to Produce
Browsing for Deer,Michigan Agr.Exp.
Sta.,Lansing,Quarterly Bull.,
No.43:722-731 (1971).
Krefting,L.W.,Methods of Increasing
Deer Browse,J.Wildl.Manage.,5:95-102
(1941).
Larin,B.A.,The Relationship Between
Muskrats and Beaver,Referet.Zhur.
BioI.[1964 translation of Russian
abstract}(1964).
-lxxxvii-
COMMENT/RESPONSE
CODE NOS.
I.354
I.36
I.101
1.49
I.346
I.542
I.552
1.497
1.166
I.251
I.511
I.328
I.227
1.227
I.199
.-
.-
"""
REFERENCE TITLE:
Masters,M.A.,R.A.Densmore,J.C.
Zasada and B.J.Neiland,Moose
Utilization of Riparian Willow in the
Central Alaskan North Slope (in press)•
Mathisen,J.E.,Effects of Human
Disturbance on Nesting Bald Eagles,J.
wildl.Manage.,32:1-6 (1968).
McCaffrey,K.R.,L.D.Martoglio and
F.L.Johnson,Maintaining Wildlife
Openings with Picloram Pellets,Wildl.
Soc.Bull.,2:40-45 (1974).
McGhan,J.,Ecology of the Golden Eagle,
Auk.85:1-12 (196 8).
Milke,G.,Animal Feeding:Problems
and Solutions,Joint State/Federal Fish
and Wildlife Advisory Team,Special
Report No.14 (1977).
Neumann,P.W.and H.G.Merriman,
Ecological Effects of Snowmobilies,Can.
Field Nat.86:207-212 (1972).
Newton,I.,Population Ecology of
Raptors (1979).
Olendorff,R.R.,A.D.Miller and R.N.
Lehman,Suggested Practices for Raptor
Protection on Powerlines,The State of
the Art in 1981,Raptor Res.Rep.No.4
(1981)•
Peratrovich,Nottingham and Drage,Inc.,
Susitna Reservoir Sedimentation and
Water Clarity Study (November 1982),
previously submitted to the FERC on
July 11,1983.
R&M Consultants,Hypothetical Dam Break
Analysis for Acres American,Inc.(March
1983).
-lxxxviii-
COMMENT/RESPONSE
CODE NOS.
I.352
I.227
I.227
I.204
I.202
I.202
I.204
I.230
I.49
I.373
REFERENCE TITLE:
R&M Consultants,Susitna Hydroelectric
Project,Glacial Lake Studies (December
1982),previously submitted to the FERC
on July 11,1983.
R&M Consultants,Susitna Hydroelectric
Project,Susitna River Ice Studies.
Ice Observations 1980-1981,
1981-1982 (1982),previously
submitted to the FERC on July 11,
1983.
Ice Observations 1982-1983 (in
preparation).
Riis,J.C.and N.V.Friese,Fisheries
and Habitat Investigations of the
Susitna River - A Preliminary Study of
Potential Impacts of the Devil Canyon
and Watana Hydroelectric Projects
(1978).
Roseneau,D.G.,C.E.Tull and R.W.
Nelson,Protection Strategies for
Peregrine Falcons and Other Raptors
Along the Proposed Northwest Alaskan Gas
Pipeline Route (1981).
Schwassermann,H.O.,Biological Rhythms:
Their Adaptive Significance,in:
Environmental Physiology of Fishes,
M.A.Al i,ed .(1980).
Scott,W.B.and E.J.Crossman,
Freshwater Fishes of Canada,
Bulletin 184,Fisheries Research Board
of Canada,Ottawa (1983).
Tracy,D.M.,Reactions of Wildlife to
Human Activity Along the Mt.McKinley
National Park Road,Mast~r's Thesis,
University of Alaska (1977).
Trihey,E.W.,Preliminary Assessment of
Access by Spawning Salmon to Side Slough
Habitat above Talkeetna,Draft Report
(1982),previously submitted to the FERC
on July 11,1983.
-lxxxix-
COMMENT/RESPONSE
CODE NOS.
I.49
1.348
1.40
1.348
1.99
1.204
1.87
1.87
1.202
1.25
REFERENCE TITLE:
u.s.Army Corps of Engineers,Office of
the Chief Engineer,Final Environmental
Impact Statement,Hydroelectric Power
Development,Upper Susitna River Basin,
South-Central Railbelt Area,Alaska
(January 1977).
u.S.Army Corps of Engineers,Alaska
District Corps of Engineers,Letter to
Alaska Power Authority transmitting
permit (November 9,1983).
u.S.Army Corps of Engineers,Permit
Enabling Alaska Power Authority to
Discharge Dredged or Fill Material,
Application No.071-0YD-4-830374
(November 9,1983).
u.S.Forest Service,Joe Mehrkens,
Regional Economist,personal
communication to Ellen Hall,
Envirosphere (December 12,1983).
USGS,Quadrangle Map of Talkeetna-
Mountains C-6 and D-6 .
.....
Viereck,L.A.,and C.T.Dyrness,A
Preliminary Classification System for
Vegetation of Alaska (1980).
COMMENT/RESPONSE
CODE NOS.
I.81
1.544
1.569
I.92
I.92
1.507
1.508
1.42
I.325
....
Viereck,L.A.,C.T.Dyrness and A.R.
Batten,Revision of Preliminary
Classification for Vegetation of Alaska,
unpublished report,Workshop on
Classification of Alaskan Vegetation,
December 24,1981,Anchorage (1982).
Wangaard,D.B.and C.V.Burger,Effects
of Various Temperature Regimes on the Egg
and Alevin Incubation of Susitna River
Chum and Sockeye Salmon,u.S.Fish and
Wildlife Service (1983),preViously
submitted to the FERC on November 29,
1983.
-xc-
1.327
1.332
I.23
I.27
1.97
~--~'''''f'!ll'''_iia:l_f2'''-''''''-_
{Jnited States Department of the Interior
ER 83/1034
OFFICE OF THE SECRETARY
WASHINGTON,D.C.20240
r.;:-:,.......
RECEtVED
DEC121983
P.ilfsbu%Ma.~i.~~.~.~~!!!-.
.,
.._-.......
[,4]
,~.3]
n.2]
HOD!:>rable Kenneth F.Plumb,Secretary
Fed4:!ral Energy Regulatory Commission
825 North Capitol Street,N.E.
Washington,D.C.20426
Dear Mr.Plumb:
The Department of the Interior has reviewed the application for major license for the
Susitna Project (FERC No.7114),Matanuska -Susitna Division,Alaska.We have the
fo114)wing comments and recommendations based upon our several jurisdictions and our
spe(~ial expertise.This cover letter outlines our major concerns.Enclosed are detailed
comments organized by chapter.
I [.lJ----r'-The application suffers from outdated information,particularly in the areas of load
forElcasting,reservoir and river computer modeling effects,fish and wildlife studies,
projiect design,and evaluation of alternatives.··
The load forecasts included in the application reDect an economic evaluation that was
conducted 2 years ago,prior to the severe drop in oU prices.The applicant,Alaska
Power Authority (APA),recognizes these changed conditions and has updated its eco-
nomic evaluation.This reevaluation,however,is not reDected in the application.The
significant decline in projected loa~forecasts has large implications to many of the
proJect assumptions which have constrained mitigation planning,for example:available
water for downstream flows;mode,timing,and routing of construction access;and
scbeduling of work.
ThEi computer modeling efforts would appear to be outdated since the models have either
been replaced ,or modified.These changes make it extremely difficult to establish base-
linE:impacts and address mitigation measures presented in Chapters 2 and 3.
Pro1ject stUdies will continue through the licensing process,and some of these studies will
continue after license issuance as monitoring programs.Due to the ongoing nature of the
studies and the time lag in information distribution,we consider it essential that the
future studies referenced in the application be fully discussed in the application.A
pro,cedure should be established for upda ting the results and analyses from the ongoing
anel planned studies.
Many of the studies and reports that were planned for 1983 were not conducted (e.g.,
fiolt"istic surveys (p.E-3-193),wetlands mapping (p.E-3-20I),detailed construction method
(p.E-3-268),Design Criteria Manual (E-3-150),analysis of instream flows and tempera-
tures (ll.E-3-189)etc.).We consider it necessary that a study update be provided to our
In severa.l of the chapters of Exhibit.E we are confronted with mitigation options that are
designed to address adverse impacts.For example,in Chapter 3 the potential value of
spiking spring flows for salmon out-migration and the installation of a fifth portal on the
multi-level intake structure are discussed.However,neither of these proposals are incol'~
porated into the mitigation plan.If these options have validity,they should be incorpo-
rated into the project design and operational plan.
.Mitigation which is proposed should have proven success in Alaska,or in a similar environ-
ment.Examples include:the proposals to improve habitat through controlled burning;
hatchery propagation of Arctic grayling;and various manipulations of the upper Susitna
River sloughs.'
'Project studies should begin to focus on identifying enhancement opportunities which the
project provides.The present task is to identify those resources which would be adversely
affected a"d attempt to "correct"these problems.For example,without examining water
quality and quantity changes in terms of opportunities to improve habitat,we cannot satis-
factorily examine whether there exists a realistic potential to trade-off losses to one
species fol'another,and,as a by-product,identify enhancement opportunities..
The PWS defines enhancement as the ft•••development or improvement of wUdlife re-
source values of the area affected by the project beyond that which would occur without
the project"(F.R.Vol.44,No.98,p.29305).We consider enhancement to be habitat
Fish and Wildlife Service (FWS)indicating which studies have been canceled,delayed or -
modified and which are still planned.
The intent of the Fish and Wildlife Coordination.A.et (16 U.S.C.661,et seq.)and the
National Environmental Policy Act (NEPA)(42 U.S~C.-437l et Seq.)is that environmental .
resources be given equal consideration with projectCeatures.Consistent with NEPA,as"
well as the applicant's Mitigation Policy (Appendix 3.A),avoidance of adverse impacts .
should be given priority as a mitigation measure.We have found this generally not to be -
the case,for example:mode,timing,and routing of construction access;scheduling of
work;type and si ting of construction airstrips,camps,villages,and permanent town;
recreation development;and instream flow regime.
Research of background information is frequently inadequate and incomplete.Examples,
which we noted in our draft application review <included in Chapter n of Exhibit E),
include discussions of subsistence (Chapters 3 and 5)and alternative power generation
sources,specifically natural gas and geothermal (Chapter lO).The FWS provided the
applicant with references and suggestions in these draft application comments.·
Potential major project impacts to fish and wildlife resources still lack an adequate level
of quantification.Examples include:fishery resources and changes downstream of
Talkeetna;changes in reservoir and river temperatures,water quality and ice processes;
and wetlands impacts.Other examples are noted throughout our specific comments.The
potential impacts to these resources should be quantified and then evaluated over the life
of the project.Only after tha t is accomplished can specific,effective mitigation meas-
ures emerge.We consider "quantification of existing resources and impacts and a specific,
effective mitigation plan essential to the development of an acceptable environmental
impact statement..
2
..
Honorable Kenneth F.Plumb
[1.5]
L 4]
(cant.)
[L 6]
[1.7]
[L 8]
[I.9 ]
[LID]
[loll]
-Honorable Kenneth F.Plumb 3
.•L I.11]improvements beyond mitigation and not synonymous with improvement of habitat for
~(cont.)mitigation.We believe the applicant should adopt these definitions.
I.121
~I.13]
[I.VI]
/
/
We strongly support the applicant's proposed establishment of an interagency monitoring
prog'ram (p.E-3-180).This program should be funded by the project,containing repre-
sentatives from appropriate State,Federal and local agencies.On-site representation
from the FERC would be highly desirable to maximize the responsiveness of the team.
The board should have the authority to recommend modifications of how activities are
conducted to assure that mitigation is effective.Recommended changes in the mitiga-
tion program should be adopted through a mechanism incorporated into the license as a
binding article,mutually acceptable to all concerned bodies.
Your attention is also called to Attachment A of our Chapter 3 comments in the
enclosure ..Attachment A represents those items which we believe should be conditions
of ~IJ1Y license issued based upon the current application documents.
SUmmary
We conclude that the applicant's request poses serious environmental problems from a
lack of quantification of natural resources and.an inability to formulate proper mitiga-
tion and enhancement plans.We recommend that FERC carefully consider all of these
aspects of the project when processing the application.The recommendations supplied.
abolve and in the accompanying detailed comments should be used in preparation of any
environmental impact statement issued for this project and in any terms and conditions
of liny license iissued.
Sincerely,
.A~:~~(~,~~Lt~/
.'Bruce Blanchard,Director
Environmental Project Review
Enc~losure
cc:Mr.Fred Springer
Mr.Robert A.Mohn,Project Manager
Ms.D.Jane Drennan
CHAPTER 2.WATER USE AND QUALITY
General Comments
[,1.15]
",
.,..
[L16]
Chapter 2 has been vastly improved qualitatively from the draft we reviewed
last year 2-1/,however,it still does not provide the quantification
necessary for assessing project-related impacts or formulating a mitigation
plan.In particular,Chapter 2 fails to fully discuss all of the six habitat
types identified by the Alaska Department of Fish and Game (AOF&G)Susitna
Hydro Aquatic Studies Program;impacts to riparian zones;resources and
potential impacts downstream of the Talkeetna River;groundwater relationship
between the sloughs and mainstem;and enhancement opportunities.
The modeling efforts discussed in Chapter 2 suffer from lack of verification
and/or insufficient input data (see our comments on pages E-2-62,E-2-87,
E-2-88,E-2-114,E-2-117,E-2-118, E-2-119,E-2-121,E-2-123,etc~).
Additional modeling efforts should be undertaken to address post-project
conditions reg~rding sediment and bedload transport (see our comments on pages
E-2-34,E-2-84,and E-2-96).
[I.17]The chapter should also describe studies,ongoing and proposed,which may
address the concerns we have identified.
Specific Comments
[I.18]Page E-2-3:2-BASELINE DESCRIPTION:The discussion divides the Susitna River
into two habitat components between the dam sites and the Talkeetna River;the
mainstem and the sloughs.Below the Talkeetna River,the discussion is
non-specific regarding habitat sites.In contrast,the ongoing ADF&G studies
2-2/have identified six habitat types utilized moderately to heavily by
sarmon.These are:tributaries,tributary mouths,upland sloughs,side
sloughs,side channels,and mainstem.Each of these habitat types would
undergo a different degree of impact due to the project.Some habitats could
become less useful for one life phase but may become more valuable for another
life phase.Only by examining potential impacts in all ~ix habitat types can
mitigation and enhancement opportunities be identified.In ~ddition to the
habitat types identified by ADF&G,the adjacent wetlands should be fully
described and the potential impacts to these habitats discussed in latter
sections,both upstream and downstream from the mouth of the Talkeetna River.
[LJ.9]Pa e E-2-19:2.3-Susitna River Water Quality:Para raphs 6 and 7:It is noted
that water qua lty standards are exceeded,under natura condltions.We
disagree with the conclusion that,since these conditions are naturally
occuring,they have an insignificant effect upon the aquatic organisms.We
recommend a further examination of how changes in water quality would affect
aquatic organisms.An examination of the available literature may be
sufficient.
[L 20]pa~e E-2-32:2.3.7-Nutrients:The communities of Cantwell.Trapper Creek,and
Ta keetna would be affected by changes in water quality relative to sewage
treatment.drinking water,etc.Baseline descriptions and.in latter
sections,impacts attributable to the project should be provided.
-
-1.21]~aT~~:-2-34:(e)Q!i:.Due to the wi de pH range (6.0 to 8.1)measured above
o ;reek,and the potenti a1 for increased aci di ty due to i nundati on of bogs
by thE!reservoirs,we recolllnend that pH monitoring be continued.
F''''',
.....
j~.23]
[1.24]
"'"'
[1.25 ]
Eo 26 ]
Page E:-2-40:2A.4-H drauiic Connection of Mainstem and Slou hs:The water
temperature re atlon5 1 p etween t e mal nstem an,.t e s oug s as well as
other wat~r quality parameters)must be establishe"t:r.To this end,one slough
(#9)has been closely examined and a second slough,18A,has been
preliminarily exami ned.These examinations have focused on the'groundwater
relationship.According to Tony Burgess (Acres American),in his Susitna
Hydro Exhibit E Workshop presentation (December 1,1982)on groundwater
upwelling and water temperature in sloughs,the groundwater regime can be
modelE!d,but locally the match is not very good:The groundwater temperatures
near the surface do not match the predicted temperatures.Continued study is
indicclted for slough #9.After an understanding is achieved for sloughs #9
and #BA the program needs to be expanded to other sloughs,possibly sloughs
#11,#19,#20 and #21.These sloughs have been more intensively examined than
other sloughs in this reach of the Susitna River.Please outline the studies
for these slough investigations..
Page E-2-44:"2.6.2-Fi shery Resources:The recently conducted salmon
incubation study 2-3/indicated that churn salmon outmigrate after a particular
numbet of degree-days are exceeded,coinci dental with the receedi ng limb of
the spring hydrograph.Further investigation is necessary to fully understand
the m~edfor peaking spring flows in relation to chum salmon outmigration.
Page E-2-58:3.,4.l-Range of Flows:Paragraeh 2:The assumption that CaseD
flows would result in "•••essentially no lmpact to the downstream fishery
durinlg the anadromous fi sh spawni ng period,II fail s to recogni ze impacts other
than flows (e.g.temperature,turbidity,water quality,etc.).In addition,
the recent examination of access t~nine sloughs 2-41 indicated that the Case
D maximum flow of 19,000 cubic feet per second (cfsT could create acute access
problems in several sloughs.Five of the nine sloughs achieve unrestricted
.access at flows grea~er than 20,000 cfs.Evidence from the ADF&G studies
indicate that the natural1y-occuring 1982 summer flows resulted in a
significant reduction of available habitat for chum salmon in sloughs.2-5/
Case 0 flows could result in similar significant reductions in available -
habitat.
~E-2-59:3.6.l-Susitna River Fishery Impacts:As indicated in Section
~ner6Y Production and Net Benef;ts,.the 12,000 cfs maxim~m Augus~flow
was esta lished through a power productlon versus net economlC benef,ts
analysis.The flow level was established prior to an evaluation of access to
sloughs in the Susitna River upstream of the Talkeetna River and is not
biologically based.The 1982 AOF&G studies 2-6/and Trihey's (l982)2-71 work
on slough access indicate flows of 12,000 cfs would restrict access to six of
the nine sloughs studied.
T=-'~-r-:~;.;;.:.-=..;~.;;;:;..,~~~~FnimsrTh.;;.,erirll\Y~Im7Pra~c~t.;:;,.;s:Accord i ng to AOF &G,2 -81 the
Rlver ml e R •cou d become perched given the
appl icant I s proposed post-project flows.Spawning coho salmon were observed
in this creek during 1981 and 1982.
[1.27]
[1.28 ]
[1.29 ]
Potential fishery impacts related to post-project flows above the mouth of the
Talkeetna River are not limited to access to side sloughs (for chum salmon)or
tributaries (for chinook.coho.and pink.salmon)•.The analysis of impacts to
salmon should be by life phase.i.e.adult passage,spawning,incubation.
rearing,and outmigration.The habitats used moderately or heavily by.salmon
for at least one life phase are tributaries.tributary mouths,upland sloughs,
side sloughs,side channels,and the mainstem.2-81 As a species proceeds
from one life phase to another it frequently proceeds to a habitat type better
suited for the next life phase.Access would need to be assured at times
other than that which allows adult chums to pass into side sloughs.
Post-project changes in water quality and quantity could severely degrade
these habitats.Based upon the 1982 flows,ADF&G studies 2-9/indicate that
significant reductions in available spawning habitat in the side sloughs could
occur post-project.Post-project flows could also significantly change the
existing relationship between the mainstem and the other-habitats previously
mentioned.Post-project changes in other water quality parameters would
affect the fisheries.For example.burbot show a high positive correlation
with turbidity levels,while juvenile ,coho salmon are negatively correlated.
2-10/
It should also be recognized that post-project changes in water quality and
quantity would (given Case C)result in identifiable changes in the Susitna
River down to the estuary.2-11/The Arctic Environmental Information and
Data Center (AEIDC)2-12/conCTuded Case C would result in an increase in
flows of 127.2%at SusTrna Station (downstream of the'Yentna River}during
March.During July,flows below the Chulitna River would be decreased by 25%,
and at Susitna Station by 12%.Identifiable changes in river temperature
2-13/and other water quality parameters (e.g.turbidity)would also be
preaicted below the Chulitna River.These project-related changes would be'
attenuated downstream;however,our knowledge of the fishery resources and
habitats downstream of the mouth of the Talkeetna River is considered to be an
order of magnitude below that in the Devil Canyon to Talkeetna River reach.
2-14/At present,escapement data are not available for the Talkeetna and
ChUTitna Rivers,thus,the number of salmon dependent upon the Susitna River
below the mouth of the Talkeetna River,other than for migration,is not
known.It is likely many more fish are dependent upon the lower reaches of
the Susitna River than on the reach above the mouth of the Talkeetna River.
In addition,the Susitna River downstream from the mouth of the Chulitna River
is broad,and relatively shallow;a configuration whi"ch would lead one to
expect greater impacts from smaller changes in flow.Dismissal of impacts
downstream of the mouth of the Talkeetna River would be premature at this
time,and should be fully discussed.2-22/
Page E-2-61;Cd)Riparian Vegetation and Wildlife Habitat:The post-project
;nstream flow regime has tremendous potential to impact the tin.ing and extent
of floods.freeze-up,and spring ice jams,as well as the riparian groundwater
relationships.We do not understand how it can be stated that the regime.
1I •••is unrelated to any of these factors.11 It is stated that,"•••it may be
desirable to maintain riparian vegetation by simulating spring floods for a
short period of time.However,the spring runoff storage is a key element of
the project.Large releases for even a few days would have severe economic
impact on the project.Hence.no minimum flood discharges were considered."
In response to our concern that the receeding limb of high spring flows may be
important to stimulate smelt outmigration,it is stated in Chapter 11.
-3-
-
•[I~29~Response W-3-026,"When the significance of flow-related stimuli to smolt
rcont.)out-migration is defined,the flow regime can be adjusted."The apparent
conflict in the statements in the application should bereeonciled and the
environmental implications.of this flow dec';sion examined.-i :30]
!.32]
r.33:1
!
-I .34 :I
[1.35 :I
.-,
i
I[I.36 ]
,-
Page E-2-62:Ce)Water Quality:The pre-versus post-project temperature
changes should be described throughout the year..
At the present time reservoir release temperatures are available for only one-'-
year (1981).With only one year's data it is impossible to estimate the range-
of effects.Ifli addition,the data indicate that 1981 temperatures were
atypical when compared to computer-predicted temperatures for water years 1968
to 19182.Of the fifteen years examined by AEIDC 2':'16/,1981 was the only year
in which temper'atures declined from June to July.--
Other'pre-versus post-project water qual ity changes should also be described
.(e.g.,turbidity,sediment,metals,nutrients,etc.).
Pfige E-2-64:Maximum Orawdown Selection:This section should discuss that in
t e event both reservoirs are drawndown to their minimum.elevation,downstream
flow!;would be provided such that outflow would equal inflow.
Page E-2-69:(iii)Suspended Sediment/Turbidity/Vertical Illumination:
ParaCJraph 9:The basis for the conclusion,ilDownstream from Talkeetna,
turbldlty and suspended'sediment levels should remain essentially the same.as
baseline eonditions t "stlou1d be provided for the winter elear water period.
We recorrmendfurther i nvestigati on of post-project turbi dity and suspended
Sediment levels due .to impoundments in discontinuous permafrost regions.
Several references are footnoted for your convenience.2-.!Z!
Pfige E-2-78:('i)r~1nimum Downstream Target Flows:Project operations f10ws t
w erE~they differ from naturally occuring flows.should be provided during
resel'"voir filHng.It may be useful to gradually increase winter flows during
the filling period so that changes in the river and fisheries due to increased
wi ntE~r flows can be mont tored •..
rage E-2-84:Cd}River Morphology:Sediment would be expected to aggrade
over a long period of time)at the Chulitna-Susitna confluence until a new
equi'librium is reached.We are unaware of any data or study being initiated
to attempt to quantify the distance at which downstream aggradation could
oeculr'or what changes are possible in bed elevation.Changes at the
confl uence caul d affect fi sh movement or boat navi gation.exacerbate winter
rivelr'ice conditions,and have unfortunate consequences for the village of
Ta1kl~etna.We recomnend more thorough evaluation of sediment transport,
bedlload movement,and aggradation at the Chulitna-Susitna confluence.
Page E-2-87:Watana to Talkeetna;Paragraph 5:It is our understanding that
reservoir'temperature outflows are currently available for water year 1981
only.Water year 1981 was atypical when compared to water years 1968 to 1982,
and was the only year in which computer-predicted temperatures declined from
June to July.2-18/We recommend that the temperature studies reflect at
least two data.--
-4-
[1.38 ]
[I••39 ]
[1.40 ]
[1.41
[1.42 ]
Page £-2-88:Talkeetna to Cook Inlet:Modeling by AEIDC 2-19/based upon
water year 1981 for Watana alone,and Watana and Devil Canyon together,
indicates identifiable post-project temperature impacts below the confluence
of the Chulitna River.We suspect this might also occur during filling of
Watana.We recommend this potential impact be re-examined.
Page £-2-88:Reservoir:We recommend that modeling be undertaken for
reserVOlr ice formation and breakup during filling,as well as operation.The
time of breakup has significant implications to potential crossings by animals
(e.g.caribou).We expect this modeling may not be possible until several
years of temperature data have been collected for the reservoir model.
Page E-2-90:Talkeetna to Cook Inlet:The expected delay in ice cover
formation downstream from the Talkeetna River should be discussed.This will
,have potential impacts to beaver caches,movement by animals such as moose,
and recreational access.
age E-2-96:(vii)Total Dissolved Solids,Conductivity,Significant Ions,
Alkalinity,and Metals:Long-term increases in mercury levels in fish are
quite possible.ThlS potential problem is inadequately researched in the
application.We refer you to several references.2-20/Based upon available
data,Boda1y and Hecky (1982)2-21/concluded that in-cool-temperate North
Pmerica high mercury levels in fISh prC?bab1y result from reservoir formation
in a large proportion of cases.Boda1y,Hecky,and Fudge (1984)2-22/found
fish mercury levels responded quickly to impoundment,increasing notrceably
within two to three years.The elevated mercury levels appear to be
long-term.Generally,they found mercury levels had not decl i ned after five
to eight years of impoundment.Data from Boda1y and Hecky (1982)2-23/
suggest mercury concentrations in predatory fi"sh is related to the amount of
terrestial material flooded and not "increased nutrients levels,increased
suspended c1 ay sediments,or changes in water exchange times.Boda1y,Hecky,
and FUdge (1984)2-24/concluded,liThe widespread nature of the high fish
mercury level-new reservoir association makes it imperative that elevated fish
mercury levels be conside-red in all impact assessments of proposed reservoirs."
The references cited 2-25/discuss bioaccumulation of mercury in impoundment
fisheries,not fisheriesdownstream from the reservoirs.The inmediate
implications would.be for those fisheries in the reservoirs (e.g.arctic
grayling)or for any evaluation of the fishery potential of the reservoirs.
Prior to an investigation of the available literature (the reference section
of Boda1y,Hecky,and FUdge (1984)2-26/is extensive)one should not dismiss
the potential for bioaccumu1ation of mercury in downstream fisheries,
particular given the high natural mercury levels in the Susitna River (see
Table 2-17).We recommend that a predictive water quality model be
I incorporated into the overall AEIDC modeling effort and baseline mercury
'I levels continue to be monitored in the future impoundment areas and
._downstream.Mercury levels in soils and fish should also be monitored.
pate E-2-98:(ii)Sloughs:Please refer to our comments on page £-2-40.The
re ationship between mainstem surface flow,groundwater dynamics,upwelling in
salmon spawning zones of side sloughs,and local runoff to these sloughs needs
to be characterized.
-
~r .43]
"""
Page E:-2-10l:4.1.3 -Watana Operation:The appl ication should discuss the
potential impacts on water quality and quantity parameters associated with the
.testing of the turbines at Watana.
r :44]Page £-2-112:(b)River Morphology:Please refer,~o our comments on page
£-2-84._.
l .45]
[r.46 ]
f .47
~.48]
-
l_.50]
i":.51]-
.-.-
Page E-2-ll4:Watana Reservoir:Paragraph 4:It is indicated that Watana,
Ii ...w·j 11 be operated to take advantage of the tempe~ature stratification
within the reservoir.,"Basic assumptions underlying this statement should be
discussed in detail.
Page 1£-2-117:Eklutna Lake Modeling:The Ek1utna Lake data collection program
was important t'o the efforts to verify the applicability of the DYRESM
computer model.Th~ability of DYRESM to cqrrect the consistent one to two
degree C underestimation should be demonstrated.We recommend meteorological
data be provided for the period of record to show how the 1982 data compare to
this record.The data collection program should be extended over a second
year to lend confidence to the model 's ability to mimic actual temperature
releases..
Page E-2-118:Watana Reservoir Modeling:Paragraph 1:It is indicated that
meteorological data from June through December 1981 (seven months)were ,
input.ted to DYRESr·1.Page E-2-121 indicates that June through September (four
months)data were used as DYRESM input.The November 15,1982 draft U cense
application indicates that data from June through October,1981 (5 months)
were used in DYRES~1 simulation modeling ..These apparent discrepancies should
be explained.
P1ea~ie refer to olJr comments on page E-2-87 on reservoir temperature
modelling.We continue to recolTlllend two full years of data collection for
input to DYRESI~(see Comment W-2-048,Chapter 11).
Page E-2-119:Watana Reservoir Modeling:Paragraph 7:It is important to have
an understand;Ing of the potenti al range of post-project occurrences '.Exampl es
wpu1d be the r,ange of dates when reservoir ice form,ation would occur,ice
thiclcness,and ice breakup.At the present time,since DYRESM has not been·
run 'for October to June (or January to June?)the time of reservoir ice
brealkup cannot be confidently predi cted.
Page E-2-121:Mainstem:Para2raph 1:Please refer to our comments on the
reservoir modeling efforts,11111lediate1y above.In addition,tributary
temperature and flow data and the influence of turbidity and suspended
sediment should be detennined and incorporated into the model.
pa g
h
E-2-122:Sloughs:During the winter,ice formation in conjunction with
muc,higher flows (compared to natural winter flows)could result in
sigT1lificant downstream staging and overtopping of the side sloughs.
Over'topping would dramatically lower slough temperatures and adversely impact
fish incubation and rearing.2-27/This potential impact should be thoroughly
di scussed.- ,
Page E-2-123:Talkeetna to Cook Inlet:AEIDC recently examined river
temperature profiles for one and two dams for June through September.2-281
-6-
The timing,ice thickness,and river staging due to the ice has large,
obvious,implications 1n regard to severity of breakup,extent of freeze-up,
.ice jamming and the extent of open water (downstream from dam).Large amounts
of ice deposited at tributary or slough mouths during spring could effect
~molt ouunigration and/or adult inmigration.
Page £-2-127:Talkeetna to Cook Inlet:We recommend that the predicted
post-project changes 1n ice processes be quantified and analyzed in.this
reach.At present,evidence points to identifiable post-project changes to
flows,temperatures,ice conditions,water quality (e.g.turbidity and
suspended sediment),and frequency of flooding.These would occur in a broad
and shallow river system for which we have rather limited knowledge of the
aquatic resources.The morphology of the reach downstream from the mouth of
Talkeetna River would lead one to expect greater impacts to result from
smaller changes.
Page £-2-132:(vi)Total Dissolved Gas Concentration:The current natural
level of diSSOlved gas in Devil Canyon exceeds the State water quality
criteria of 110~.Further increases in gas downstream from the dames}could
adversely effect juvenile and adult fisheries,in addition to resident
fisheries.It is indicted the,11 •••fixed-cone valves will be used to
discharge all releases with a recurrence interval of less than 1:50 years.11
Wp assume events greater than 1:50 years would,therefore,necessitate
spilling.It should be clarified if this would occur,when it would occur,
and how often (based upon the 32 years of record)we could expect spilling.
Modeling of the formation of dissolved gas and downstream dissipation may be
appropriate.We suspect supersaturated gas formed by spilling at the Watana
dam may not sufficiently dissipate in the Devil Canyon reservoir.This could
create releases of high dissolved gas through the Devil Canyon turbines and
valves.This.scenario should be fully analyzed.
[1.52]
[I.51]--~~T·heir computer models SNTEMP predicted identifiable temperature changes below
(cant)the Chulitna River,ranging up to an approximately one degree C difference in
June for the one dam senario.Post-project operations with two dams showed
greater changes downstream from the Chulitna River.
When DYRESM has been input with data throughout the year,for a two-year
period,the potential post-project temperature effects for the reach below the
Chulitna River will need to be re-examined.
The application.should explain'why the discussion on river temperatures uses
_HEATSIM,and AEIDC uses a different model,SNTEMP.
Page E-2-124:Watana Reservoir:It is indicated that DYRESM was run using
1981 data collected throughout the year.It is our understanding this was not
the case.Please clarify this apparent discrepancy.Please refer to our
cormnents on pages E-:2-119 and E-2-121.
[I.53]---~·-age £-2-124:Watana to Talkeetna:Please refer to our comments on pages
E-Z-119,E-2-121,E-2-123.When DYRESM is input with data collected
throughout the year,and over a 2-year period,it would be appropriate to
re-examine river ice dynamics.
[1.54 ]
[I.55 ]
-
-7-
1'-.56]
.58 1
.59]
.....
l .60]
(1.61 ]
l-.62]
......
[J...63 Y
-
pare E-2-146:(f)lnstream Flow Uses:During 1982,ADF&G documented chinook
sa mon spawning above the Devil Canyon dam site -at the confluence of and
within two small clear water tributaries.'2-W··-,
Page E-2-152:(v)Total Dissolved Gas Concentration:Please refer to our
comments on page £-2-132 •
~hge E...2-158 to 162:(iii)Floods:The discussions concerning floods up to
e'probable maximum flood (pMF)should examine the potential creation of
supersaturated dissolved gas and.through modeling,examine the fate of the
gas;downstream.Pl ease refer to our cor.mentson page E-2-132.
;j9re E-2-164:(b)River Morpho10~:It is stated,It •••the occurrences of high
ows capable of 1nitiating grave bed movement in the Susitna River above
Talkeetna will be increased ll
•To 'our knowledge the bedload and suspended
sediment studies to date have only examined general morphological changes in
pos;t-versus pre-project conditions.These studies should be extrapolated
qua:ntitative1y to existing,as well as potential fish habitats with regard to
spa.wning and rearing substrates.An analysis of the potential reduction of
spa,wning gravel with an examination of long-tenn effects of removing spawnab1e
substrate sotJlrces above the dam sites should be initiated.The flows needed
to maintain slough,side channel,tributary mouths,and mainstem spawning
gralve1 shoul d also be exami ned.'
Page E...2...164:Watana and Devil Canyon Reservoirs:para,raPh 1:It is stated,
-rs1nce the available simulation data ended at the end 0 FY 1981 (September
30"1981),mean weekly flows from the Case C,2010 demand simulation were used
for'the OCtober to December period."If it is possible to simulate
temperatures from flows in this manner we recommend that flows and
temperatures be simulated using the inflow/outflow data for the 32 years of
rec:ord.It should be noted that the year modeled (water year 1981)was an
unusual year from several aspects.First,it was the only year of the 15
simulated by AElOC,through SNTEMP,displaying a decrease in temperature from
Jurte to JUly.2-30/A1 so,on page E-2-167 it 1s cited as the worst case of
thE!32 years of record in tenns of frequency of rel ease and discharge through
Devil Canyon.This confinns our view that we need at least two years of input
to DYRESM to allow some understanding of post-project temperature impacts.
Page E-2-167::Watana and Devil.Canyon Reservoir:paraaraph 12:We gain the
impression that releases of 12,000 to 15.000 cfs woul be provided at Devil
Canyon when temperatures of 80 C occur.This would mean flows downstream of
Golld Creek of perhaps 13,000 to 17.000 cfs during July and August;comparable
to Case C...1,or Case C-2 flows.We had.previously understood this was not
considered acceptable by the applicant.rhe applicant should clarify this
apparent discrepancy.
-8-
[Io 63]
(cant)
[I ..64]
[Io6S]
[Io 66]
[I.67]
.-
Figures E-2-215 and E-2-216 display the predicted ability of the Devil Canyon
intake fadlities to match outflow temperatures to inflow temperatures.It
would be helpful to also display pre-project temperatures on these figures.
Page E-2-167:Mainstem:The downstream temperature predictions in this
section do not agree with the recent work by AEIDe.2-31/We assume since
AEIDC is responsible for this analysis.the model they-are using is current
and the model in the application.HEATSIM.has been discontinued.If this is'
the situation.we recommend that those sections evaluating pre-versus
post-project downstream temperature shifts be revised to reflect the current
AEIDC work using SNTEMP.Additionally.replacement of HEATSIM with SNTEMP
should also mean a total replacement of the ICESIM input data.
paTe E-2-169:Sloughs:Please refer to our comments on page E-2-40.We
be ieve the relationship between the side sloughs and the mainstem needs to be
better defined.This position is supported in the ADF&G Synopsis Report.
2-32/"Mainstem influence upon the side slough habitats •••is not presently
weTT defined.Such influences are most likely related to indirect impacts
such as influences on rates of upwelling water sources and winter overflow of
the slough heads caL:sed by ice processes."
Page E-2-169:Talkeetna to Cook Inlet:The expected downstream temperature
changes should be discussed as well as the downstream limits of these changes.
by month.-
Page E-2-171:(v)Total Dissolved Gas Concentration:According to the ADF&G
Synopsis Report.-2-331 liThe relatively low rates of dissipation of the
naturally entrainedaisso1ved gas in the reach of river below the [Devil
Canyon]rapids suggests that higher levels of supersaturation that may be
created by water spillage at eith~r of the proposed dams would not dissipate
sufficiently to reduce the hazard to either adult or juvenile chinook salmon
as well as other species of salmon".Please refer to our comments on page
E-2-132.
~,
[I.68]
and
[Io 69]
Chapter 2 Footnotes -
2-1/see FWS .letter dated January 14.1983 to Eric P.You1d.APA.Included in
Chapter 11.
2-2/ADF&G 1983.Synopsis of the 1982 Aquatic Studies and Analysis of Fish
ana Habitat Relationships.Prepared for the APA.
-9-
2-3/Wangaard,D.B.and C.V.Burger.1983.Effects of Various Temperature
Reglmes on the Incubation of Susitna River Chum and Sockeye Salmon.FWS.
Prepared for the APA •.-
2-!!See Footnote 2-2,supra.
-2-5/See Footnote 2-2,supra.
~-§.!see Footnote 2-2,supra.
all
r"ne
ootnote
2-7/Trihey,E.W.1982.Preliminary ·Assessment of Access by Spawning Salmon to
Sicie Slough Hlabitat above Talkeetna.Prepared for the APA.
2-~~See Footnote 2-2,supra.
2-91/See Footnote 2-2.supra.
2-1~See Footnote 2-2.supra.
2-11/AElDC.1983.Examinativ:'l of Discharge and Temperature Changes due to
th'E!"""'Proposed Susitna Hydroelectric Project.Prepared for the APA.
2-]y See Fo()tnote 2-11,supra.
2-111 See Fo()tnote 2-11,supra.
2-g/See Footnote 2-2,supra.
2-J2I See Footnote 2-11,supra.
2-l§!See Footnote 2-11,supra.
2-17/Boda1y,R.A.,D.M.Rosenberg,M.N.Gaboury.R.E.Hecky,R.W.Newburg.
ana-k.Pata1as.1983.Ecological Effects of Hydroelectric Development in
NOlrthern Manitoba,Canada:The Churchill -Nelson River Diversion.
IN Sheehan.P.J ••Miller,D.R.,Butler.G.C ••and Bourdeau,Ph.(Eds).
rTfects of Pollutants at the Ecosystem Level.John Wiley &Sons.New York.
Hecky,R.E.,and H.A.Ayles.1974.Sunmary of Fisheries-Limnology
Investigations on Southern Indian Lake.Lake Winnipeg.Churhill and Nelson
Ri'vers Study Board Report.Winnipeg,Manitoba.
Newbury.R.W ••K.G.Beaty.and G.K.McCUllough.1977.Initial Shoreline
Erosion in a Permafrost Affected Reservoir.Southern Indian Lake.Canada.
Dept.Environ.,Fish and Marine Servo Winnipeg,Manitoba.
2-J!!see Footnote 2-11.supra ..
2-!2!See Footnote 2-11,supra.
2-20/Bodaly,R.A.and R.E.Heck.y.1979.Post-Impoundment Increases in Fish
Mercury Levels in the Southern Indian Lake Reservoir,Manitoba.Can.Fish.
Mar.Servo Manuscript Rep.1531:iv +15 pp.
(footnote cont.)
-10-
(foot-\Bodaly,R.A.and R.E.Hecky.1982.The Potential for Mercury Accumulation in
note 20 Fish Muscle as a Result of the Proposed Peace River Site C Reservoir Can.
cont)Dept.Fish and Oceans •.Winnipeg,Manitoba.
Bodaly,R.A.,R.E.Hecky,and R.J.P.Fudge.1984.Increases in Fish Mercury
Levels in Lakes Flooded by the Churchill River Diversion,Northern Manitoba,
_Can.J.Fish.Aquat Sci.Supple (in Press).
2-f!!See Footnote 2-20,supra.
2-22/See Footnote 2-20,supra.
2-~See Footnote 2-20,supra.
2-24/See Footnote 2-20,supra.
2-25/See Footnote 2-20,supra.
2-26/See Footnote 2-20,supra.
2-27/See Footnote 2-2,supra.
2-28/See Footnote 2-11,supra.
2~29/See Footnote 2-2,supra.
2-30/See Footnote 2-11,Supra.
2-31/See Footnote 2-11,supra.
2-32/See Footnote 2-2,supra.
2-33/see Footnote 2-2,supra.
-11-
~,
[I.70].....
r......71]
r-.72]
[..,J;;.73 ],
•74 1
~•75 ]
-
.....76 ]
~.771
-
CHAPTER 3.FISH,.WILDLIFE AND BOTANICAL RESOURCES
General Comments
Chapter 3 gener-ally fail s to quanti fy the exi sti rig resources,quantify the
poterltial impacts,and provide specific mitigation measures to deal with
identified,quantified,adverse impacts:
Through consul tation,the FWS can advi se the appl icant as to the breadth of
our responsibi"lities.In the area of botanical resources ,recent budget
cutbacks have precluded in depth analysis of existing data.
Propi:>sed mitigation measures should have proven success in Alaska,or in a
similar environment.If proposals are not proven,they should be demonstrated
effective in the project area.For example,hatchery propagation of grayling
needs to be demonstrated as an effective mitigation option since previous
grayling hatchery programs have not been particularly successful in Alaska.
Likewise,the proposed slough modifications are unproven and should be
demonstrated effective in the Susitna River system.Proposed vegetation
manipulations have not been tested.The viability of providing alternative
raptor<nest sites in presently unoccupied areas has not been proven.The
legality of such measures to mitigate for bal~eagle nests is untested.
Fishery Resources of the Susitna River Drainage:
The current pr'oblems with the water quality computer modeling efforts
invalidates much of the fisheries discussions.For example,if we lack a
valid river temperature model and/or ice process model,we cannot confidently
discuss potential impacts nor discuss viable mitigation for these concerns .
We continue to lack specificity on the mitigation proposals.Mechanical
manipulation of sloughs is being proposed.This section should describe
specifically being proposed and which sloughs,side channels,and mai~stem
reaches are proposed for alteration.There is no indication as to the overall
effectiveness of such measures.
The significance of the reach below the Chulitna River confluence should be
determined.At present,the number of fish using this lower reach,other than
for migration,is unknown.We do not believe the fishery impacts will cease
at 'the Chulitna River (please refer to our cOllltlents on page E-3-100).Studies
should be undertaken to examine the resources of this lower reach and to
examine potential impacts and determine mitigation needs.
Botanical Resources
This section has been considerably improved over the November 15,1982 draft
license application.We appreciate the incorporation of our comments on the
draft,most notably with regard to baseline sections.
Alt.hough the impacts section now identifies the full range of vegetation
impact i ssuese,there ;s no estimate of the size of areas whi ch may be
potentially affected by changes in vegetation cover.Refinement of the
vegetation map to better relate it to wildlife habitat is necessary before the
(1)
(2)
(3)
[1.77]
(cant)
[I:78]
[1.79]
impacts analysi s can be compl eted.Informati on is then needed on the
tradeoffs relative to fish,wildlife,and botanical impacts,as well as cost
and design considerations in the siting of project support facilities,roads,
and transmission lines.
Three other concerns with the impacts section are:
Incorrect assessment of wet1ands (see comments on Section 3.2.3,3.3);
Incompatibility of vegetation typing within the different transmission
corridor segments (see comments on Section 3.2.2(e),and 3.3);and
Calculation errors in summing areas of each vegetation type affected
by the transmission corridor (see comments on Table E.3.86).
The Mitigation Plan is considerably improved over the draft license
application;however,it is still incomplete and too general.Implementation,
construction,and operation schedules are not clear for many re~ORIIIended
mitigation measures (e.g.land acquisition and management).Incorporation of
recommended mitigation measures into project plans is uncertain (e.g.
construction techniques,limitations on spoil areas,etc.).Neither
replacement lands nor habitat manipu1ations have been identified as to
suitable size,location or type.Moreover,replacement lands and habitat
manipulations cannot be realistically identified until:
,..,
(1)Moose carrying capacity as·well as associated brow~e,and .vegetation
mapping studies are completed;
(2)Appropriate wetlands interpretations are made;
(3)Possible mitigation 1ands,are identified,their potential mitigation
benefits calculated,and their availability determined.
[1.80)Numerous general references are made to browse habitat impovement techniques,
land acquisition for habitat management,and increasing browse by clearing or
prescribed burning of forests.However,specific information on the potential
benefits,time-frames,and suitable vegetation cover types for controlled
burning,clearing,and crushing are not provided.The applicant had indicated
that such information would be included in Section 3.4.2 in response to our
original comments (Chapter 11,W-3-183).
[1.81]We believe that mitigation agreements should be worked out with applicable
landowners and incorporated into project licensing.Otherwise,there is no
guarantee that necessary management polices (e.g.restrictions on use of
project access roads and off-road or all terrain vehicles,habitat
manipulations,control of other uses,etc.)will be adopted.Our main concern
with the Mitigation Plan stem from its development within a short time period
which allowed no agency consultation before the formal license review.There
is need for joint efforts by the resource agencies and principle study
investigators,in conjunction with the app1icant t s consultants,to:(1)
clarify issues;(2)analyze mitigation options;(3)agree on remaining data
gaps and how to fill them;and (4)modify this proposal into a mutually
acceptable,effective Mitigation Plan.Such a procedure and useful dialogues
among the different resource study groups were initiated during the August
1982 Adaptive Environmental Assessment (AEA)workshop and February 28 -March
2,1983 follow-up modeling session.Much of the progress made then relative
to identifying data gaps has since been lost due to delays and budget cuts.
-13-
-
~.
•82 ]
""'"1.84J
.....
-
We remain concerned that the cumulative impacts of both reservoir sites,
borrow and spoil sites,access roads,transmission corridors and potential
indir1ect vegetation losses are not addressed in accordance with our·cOlJlJlents
on the draft (Chapter 11,'W-3-ll4 and W-3-149).
Wildlife Resources
A concern that we have with the discussion of impacts is the repeated
inference that wildlife will generally move to adjacent areas a"s project area
habitats are altered or destroyed.·Little is known of adjacent habitat values
and \lIlhether those habitats are already funy utilized or even suitable for the
speci es of interest "are minimal.A further probl em is that no source is
provided for many of the conclusions presented here.
The majority of recollltlended compensation measures are generally insignificant
and unsubstantiated.For example:increases in ungulates through browse
imprclvement would compensate for losses to their predators (bears and wolves);
carrion from increased road mortal ity and impoundment hazards woul d compensate
for wolverine habitat losses;salmon benefitting through slough modifications
would compensate for decreases in other bear foods;flow regulation resulting
in dc)wnstream nabi tat improvement compensates for upstream losses of moose and
beavf~r habitats;and general habitat improvements for larger species would
compensate for small bir.ds and small mammal losses .
[:E'.86]
[I.87]
[I'.88]
[1.89]
"Specific Comments
2-FISH RESOURCES OF THE SUSITNA RIVER DRAINAGE
Pa e E-3-24:- Incubation and Emer ence:Based upon their apparent inability.
o 1 s 1 ngul supper USl na lover soc eye salmon stocks from Tal keetna or '.
Chulitna River drainage stocks,Bernard et al.(1983)3F-l/concluded that fry -
do not rear above Curry Station (River Mile (RM)120.5).The outmigration
data from 1982 appears to support this hypothesis.However,outmigration may .
have been substantially complete when the outmigration trap was installed
(June 18)~Growth exhibited by juveniles collected in the trap throughout the
summer and the observations of outmigrants during the spring of 1983 at slough
#11 indicated important sockeye salmon rearing habitat may be found in the
upper Susitna River.3F-2/Further investigation appears warranted in regard
to sockeye salmon rearms.
Page E-3-32:Junvenile Behavior:Juvenile chum salmon are generally thought
to outrnigrate qUlte soon after emerging.Data collected by ADF&G in 1982
3F-3/indicate chum salmon juveniles spend up to three months in the Susitna
liVer.This rearing period may be important since the Susitna River estuary
is very turbid and may not provide adequate rearing ~abitat.The density
patterns observed by ADF&G suggests juvenile chums prefer lower velocity areas
and "are associated with backwater areas near the mouths of sloughs and clear
water.tributaries.3F-4/The report should be expanded to include a
~iscussion of chum salmon rearing.The implications of the ADF&G finding
should be discussed in the analysis of 'post-project impacts.
paSe E-3-41:{v}Burbot:The ADF&G Synopsis Report 3F-5/states that burbot
ha itat shows a strong correlation with turbidity.These findings should be
discussed in Jight of the post-project implications on turbidity.
Page E-3-42:(vi)Round Whitefish:The ADF&G data indicate that significant
numbers of round whitefish remain in the mainstem of the Susitna River.They
are associated with the mouths of tributaries and turbidity mixing zones of
clear water sloughs.~
Page E-3-62:(i)Mainstem and Side Channels:We suspect the Susitna-Chulitna
confluence area is important to the anadromous fisheries for rearing and
milling.We suspect chinook,coho,sockeye,and chum rearing and/or
overwintering may occur here.The importance of the confluence area to the
fisheries of the Chulitna and the Talkeetna Rivers are not known since fishery
runs into these two river systems were not included in the ADF&G studies.
Post-project winter flows would be approximately four times greater than
pre-project flows;winter turbidity would be noticeably higher (affecting
feeding and predator-prey relationships);aggradation is probable;and
temperature and ice processes would probably be dramatically changed from .
pre-project conditions.We recommend that the value of this area be evaluated
and the post-project impacts assessed.
-15-
-
~.90]
I
li.91]
-
lI.92J1
.-
r .93 J
r"'.94]
t.L.95J[
~.96J[
.97]
.-
Page E-3-62:Salmon:The importance of the reach between the Yentna River and .'
tlle susitna River above the Chulitna and Talkeetna Rivers to anadromous
fi~sheries 1s presently unknown.The Yentna River Station a1,lows ADF&G to
separate out the Ventna,River run from the Susitna River run upstream from
th'is point.Lack of stations on the Chulitna and Talkeetna Rivers prevents
determining the importance of these two river systems to the overall Susitna
Rh'er run.We recorrmend that stations be established on the Chulitna and
Tao,keetna Ri vers.
Page E-3-80:(i i)Constructi on and Operati on of Watana Camp,Vi 11 afe and
Xi'rstrips:Last Paragraph:We understand that current plans call or
expandl ng the 2500-foot temporarY.7 airstrip to 6000 feet in 1ength rather than
constructing two airstrips.~We concur with this proposal..
Page E-3-B4 to 86:Mainstem Habitats:We believe that the knowledge of
potent;a1 post-project water quall ty impacts is inadequate.P1 ease refer to
our comments on Chapter 2,pages E-2-19,E-2-34,E-2-69,and E-2-96.
Post-project reservoir fisheries should be re-examined after the reservoirs'
water quality parameters are assessed.
__(--Page E-3-96~Slough Habitats:Paragraph 4:According to the ADF&G Synopsis
1fE!port 3F=aI,unrestr;cted access .to slough #9 does not occur unti 1 the
ma.instem discharges at Gold Creek exceeds 20,000 cubic feet per second (cfs).
Acute access problems occur at flows less than 18,000 cfs.The applicant
should revise the discussion to reflect the more current AOF&G assessment.
Nine sloughs were examined by AOF&G 3F-9/;Whiskers Creek Slough,and
sloughs 16A l •#BA,#9,III J 1168;120,#21,and #22.Five of the sloughs (#9,
#168,#20,#21,#22)show acute access problems below 18,000 cfs,and
'ullrestricted access is not achieved until flows exceed 20,000 cfs to 26,400
cfs.
Pelse E-3-97 to 98:Slough Habitats:paratraSh 6:The relationship between .
Ricl1 nstem flows and slough upwe 11 i ng shou d e further exami ned (see paragraph
3 of this section and our comments on Chapter 2,page E-2-98)•
-16-
-
[1.97 1
(cant)
result in significant differences in outmigratfon timing and/or survival.We
recommend that the study be re-initiated to determine timing and survival
through smolting.
Page E-3-100:(iii)Cook Inlet to Talkeetna:It is stated that the Chulitna
River contribution is 39%and the Talkeetna River contribution is 181.We..
assume the upper Susitna River contribution is the remaining 431.Lacking
hydrological.modeling and biological data to the contrary.it could be
assumed that greater impacts would occur upstream'of the mouths of Talkeetna
and Chulitna Rivers than to downstream.
[1.99]
[1.102]
[1.101]
[1.100]
-
-
However.given that our understanding of the fishery use in the lower reach is
a magnitude below that for the upper Susitna River.and the river is broad and
relatively shallow.we would not dismiss significant project-related impacts
in this reach.Although we do not know the.level of fishery use in this
reach.we suspect this reach contains important spawning and rearing habitat.
In a report prepared for the APA.the Arctic Environmental Information and
Data Center (AEIDC)3F-ll/concluded.lithe effort to delineate river reaches
[I.98l-----l where post-project flows differ significantly from natural flows has been
unsuccessful.The purpose of this effort was to limit the area where
flow-related impacts (other than water quality issues)need to be considered.
Being unable to establish these limits.it appears necessary to include the
entire length of river when considering aquatic habitat effects.1I
It appears that an aquatic studies program is necessary to examine
post-project impacts downstream of the Chulitna River.We request the
applicant provide the FWS with a copy of the downstream studies program
IJProposed to be undertaken in 1984 by APA.
Page E-3-101:Mainstem Habitats:Paragraeh 1:We believe that the information
on fish use downstream of the Chulitna R1ver is due to the very limited data
gathering efforts expended in this reach rather than limited fish use.Please
refer to our coments on page E-3-100.iJl1l1ediately above.and on Chapter 2.
page E-2-60.
Pa e E-3-101:Mainstem Habitats:Para ra h 2:Regarding water temperature
c anges.we ave commente t roug out apter 2.Please refer to our comments
on pages E-2-60.E-2-62. E-2-87.E-2-88.E-2-119.E-2-123.E-2-124.To
summarize.due to insufficient data and the recent changes in computer
temperature models we believe that the predictions in the application are
inadequately supported.Identifiable temperature changes are predicted by
AEIDC below the Chu1itna River confluence.3F-12/
Further analysis should be made of potential aggredation at the Chulitna River
confluence (see our comments on Chapter 2.page E-2-84).and of sediment
transport and bedload movement (see our comments on Chapter 2.page E-2-164).
Pa e E-3-l0l:Mainstem Habitats:Para ra h 3:Reduction in the occurrence of
t e -In-year 00 event so t at,t ecomes a 1-in-5 or 1-in-10 year event
could result in dramatic changes in habitats of particular importance.such as
sloughs.Information from the ADF&G Aquatics Studies Program from the last
li.l02]
",""cont)
two low flow years may provide valuable insight.For instance,observations'
of successional processes and beaver activities should provide indications of
PClst-project impacts due to decreased flows and flood events.
[1.103]
!.105]
[LI06]
~
·Pclge E-3-l06:(i)Reservoir Habitats:Please-,refer to our coments on Chapter.
~.pages £-2-69,and E-2-96.We bel ieve the hsues of reservoir turbidity and·
suspended sediment in dhcontinuous permafrost n~ed further 'investigation •.,
ll.104+---"-Pcl e 114:W,inter/lce Season:Para ra h 7:According to the ADF&G Synopsis
l«!port ....:...::_, c urn sa mon may rear 1n t e Susitna River for up to three
mcmths rather than just the one month indicated in this $.ection.The
significancl~of this infonnation is that it may indicate the Susitna River
estuary,~eing very turbid,does not provide good rearing habitat.The
dt~pendance of chum salmon on the Susitna River environments,thus,may be much
gl"eater than first thought.
The incubat'ion study.conducted by the.FWS showed the timing of chum and
sl)ckeye salmon development to yoH absorption in 4°C water compared to the
s"ough fl8A temperature regime to be nearl y i denti cal.We recommend the
studies be continued,comparing chum smolt development with anticipated
_post-project to pre-project temperature conditions.
f1:tge 114:W'j nter/lce Season:'Paragraph 8:It i·s stated that gas
supersaturation would not be a problem because of the use of cone valves in
the spilling design.According to Chapter 2,the cone valves would be
frequently /Used,particularly in the early years of project operation.One oftl~e conclusions of Acres American in their design of cone,valves 3F-14/is
that:"In view of the nature of analyses and .lack of precedence for the
proposed valves arrangement,it'is recommended that a physical model stUdy be
carried out to confinn the perfonnance of the valves."
Pa e E-3-l24:(iii)0 eration 1m acts:Last Para ra h:Please refer to our
oomments on pages - -an
[1.107]
~I
Page E-3-131:Mainstem Habitats:Paragraph 3:The discussion on the ice front
with both dams operating is inconsistant with the discussion on ice formation
in Chapter 2,page E-2-169.Neither explanation appears to reflect current
modeling of post-project conditions.Please refer to our coments on,the
reservoir,river,and ice modeling efforts in Chapter 2 (page E-2-124).
l-.10B]Pa e E-3-136:
es ruct10n 0
Use of heavy equipment could also result in
:.109]
U.II0]
fage E-3-136:Erosion:Access to upstream habitat could also be limited.
Page E-3-136:Fill Placement:The severity of fill placement impacts would
ilso be related to timing.Streams used by grayling in summer may be dry in
w'inter.
Sheetflow discharge,when concentrated through culverts,may tear the
~~getative mat and result in thennokarst in permafrost areas.
[1.111 ]
~,
[I~112]---~=Page E-3-139:Changes in Water Quality:Fuel should be banned within 100 feet,
of a flowlng water course.
To facilitate cleanup,the project oil spill plan should contain project area
maps with all water drainages,direction of flows,and sites and access points
identified where cleanup actions could be initiated.
[1.113]---'-Pa e E-3-142:Alteration of Waterbodies:Para ra hs 1 and 8:It is stated,
ennanent roa s may e Ul t to prOVl e a -season access.1 The discussion
in these sections should be limited to the proposed project development.This
would consist of access to the transmission line corridor via trails from
existing access routes at intermittent points along the corridor.A more
~etailed description of the transmission line access proposal is found on page
A-4-6.
~,
[1.114 ]
[1.115 ]
[1.116 ]
[1.117]
If the towers are to be set in concrete,excavations will be required and
provisions for pumping of silty water needed.
Page £-3-144:Alterations of Waterbodies: Paragraph 6:Use of ramps rather
"than bank cuts would help to minimlZe impacts to the aquatic habitats.
last Para ra h:We recommend~~-r-~~~~~~~~---,~~~~~~-:r-~-,-~~~,"""",,""""-oes not occur during periods
PaSE E-3-148:2.4.2 Selection of Project Evaluation Species:We recommend
ralnbow trout,Dolly Varden,and burbot be included as evaluation species by
the applicant,since these species meet the criteria established in this "
section.For additional justification please refer to our January 24,1983
1etter.
[1.118 ]6:
'-Pa"e £-3-150:2.4.3 Miti ation of Construction 1m acts U on Fish and"A uatic
a ltats:eave oot recelve t e eSlgn crlterla manua or t e constructl0n
practices manuals.3F-15/Both manuals should be provided to resource
agencies for a minimum of 30 days for review and approval.The manuals should
then be incorporated into the license as binding articles.
[1.119]_..,
I
We support the establishment of a monitoring program funded by the prqject,
and a board of representatives from appropriate State,Federal,and having the
l authority to recommend project modifications to assure that mitigation is
L.L.119 ]
Jcont:)
....:.120]
l_.121J
tr.122]-
t.L.123J
r .124]
....
I .125J
--
l.J...126J
t .127J
l ~.128]
.....r .•129]
effective.The procedure by which this would occur should be incorporated
inlto the 1icense as an ·article.
CCIStS would be incurred for the mitigationi~ritified.We rec01lll1end
specifications pertaining to environmental prot!"ction contain provision for
payment at r'ates similar to that payable for regularly scheduled production <
wClrk.When the 1icensee I s contract goes out to b.i d,those'competi ng for the
ccmtract shoul d be aware of monies specified for environmental protection
tasks .
Paige £-3-152:(ii)Mitigation:Beaver control measures related to fish
passage should be controlled by ADF&G.
Pclge £-3-152:Presence or Absence~of Fish/Fish Habitats:Provisions should be
irlcluded in the mitigation plan for modifications if fish are discovered
upstream at a later date.
Pclge £-3-153:Flow Re¥ime:All cul verts shoul d be annored at both ends wi th
r:1ip-rap at iEhe time 0 installation,or flared-end culverts should be used.
Pclge £-3 ..153:Methods of Installation:Intennittent water courses should be
SlJr'(eyed in.sUl1IJIer and staked for culvert installations.
pCl ae£-3-154':(ii)Mitigation:Paragraeh 1:Revegetation measures should be
un ertaken immediately after surface dlSturbance,or as soon as use ceases •
Pase £-3-155:(ii)Mitigation:Paragraph 4:The settling ponds should be
iiiin ntai neB by c1 eani n9 them out when one-half of the;r ori gi na 1 capaci ty is
11:)st.
Piage £-3-155:(ii)Mitifiation:Paragraph 1:The references mentioned should
De incorportated into t e erosion control manual.
Page £-3-156:{ii}Mitigation:parafraph 3:Stockpiling in the floodplain may -
l);e preferable to moving the mater1a outside of the floodplain.This would
d1epend upon the timing and location of the intended activity.
Pa e £-3-156:(ii)Miti ation:Paragra h 1:The Spill Prevention Contaiment
in ountermeasure an s ou e provided to the resource agencies for
a minimum 30-day review period and,following approval,be incorpora:ted into
the license application.The SPCC should be a part of the licensee1s
construction contract for the project •
Pa e £-3-161:(ii)Measures to Avoid 1m acts:Paragra h 2:The project may
a ect a tree 0 e actors ment10ne ,rat er t an Just mainstem stage.
We suspect channel geometry is related,in the side sloughs,to frequency and
severity of breaching of the slough1s upstream benne This process is directly
related to mainstem stage,and in the winter,location of the ice front.If
t,he river does not freeze,as is predicted for the river downstream from the
dlams for an unknown distance,then this major influence on slough geometry and
succession would be eliminated.
[1.129 ]
(~ont)
[1 ..130]
[1.131]
[1.132]
The relationship between mainstem stage and slough flows has been an assumed,
yet unproven,assumption.Please refer to our comments on page E-3-98 and on
Chapter 2,page E-2-98.
Pa e E-3-162:(ii)Measures to Minimize 1m act:In the FWS letter on the
uS1tna y roe ectr1c proJect pre-app 1cat10n -16/,the ongoing AEIDC
modeling·efforts were summarized.The FWS continues to support the AEIDC
modeling efforts.The AEIDC study should provide the basis for determining
project instream flow impacts and a reasonable assessment of mitigation
alternatives.
Page £-3-162:Winter Flow ReGime (October-April):Paragraeh 2:It is unclear
as to what project stage is e1ng discussed.The discuss10n appears to be
restricted to pre-Devil Canyon conditions,based upon the assumption that the
ice front would be upstream of Sherman RM 130.With Devil Canyon operating,
it was assumed that the ice front would form between Talkeetna (RM 99)and
Sherman (RM 130)(see page E-3-134)or downstream of Talkeetna (see Chapter 2,
page E-2-169).Discussion should be provided as to:how the sloughs needing a
protective berm were selected;how it was established which sloughs would be
overtopped more frequently than once every five years;and how these sloughs
waul d be managed after Devi 1 Canypn is operati ng..
The benefits of establishing maximum winter flows should be discussed.If
staging due to ice formation in the upper Susitna River occurs only prior to
the initiation of operations at Devil Canyon,the overtopping of sloughs could
be controlled by maintaining flows below a maximim level.Disturbance of the
ten sloughs due to the construction of protective berms may,therefore,be
avoided.Flows to cleanse the sloughs could also then be provided,if
needed.Again,it is premature to establish aninstream flow regime since the
AEIDC study is not complete.
Winter flows,downstream of the Chulitna River,are expected to be uP.to 373%
higher under post-project than pre-project conditions.3F-17/The ice front
would probably form downstream from Talkeetna (Chapter 2,page E-2-169)and be
delayed for an indeterminent period of time (Chapter 2,page £-2-170).
Downstream from the Chulitna River confluence,the Susitna River is broad and
relatively shallow.We consider this reach more susceptible to impacts due to
this channel geometry.Impacts and mitigation needs in this lower reach
should be included in this section.
With the construction of the protective berms,the ice cover formed on the
sloughs would not be flushed out in the spring.Ice could remain in these
protected sloughs well into June.The impact of this phenomenon upon the
fishery should be included in this section along with a discussion of
mitigative measures for any potential impacts.Adverse impacts may be related
to changes in timing of outmigration,early inmigration,and quality of
reari ng habi tat.
~\
,~.
~I
rI
I
l.L .133 ]Page E-3-165:SUllll1er .F10ws:The tenn "rectifying measures"should be
CTarified,as should the manner in which the listed sloughs were selected.
According to the ADF&G Synopsis Report 3F-18/,slough III (RM 135)has
unrestricted access at flows greater than 6,700 cfs while slough 19 has an
acute access problem with flows of less than 18,000 cfs.We are unable to
locate slough B and,apparently,sloughs 18,18A,188,18C,Moose,Al,19A,
19B,and 117 have nyt been exami ned by ADF&G to detenni ne whether an access,
problem exists.3F-9/We assume that different measures are proposed for
the different slo11ghs.Since Table £.3.39 lists a specific number of sloughs
which would receive a particular rectification,we assume specific mitigation
plans for each slough are being proposed.we would like to review any such
plans along with an explanation of the selection process and reasons as to why
flow manipulations could not be utilized to avoid and/or minimize the adverse
impacts.Also,it is unclear as to whether short-tenn augmenting flows are
being proposed or not.,....,
1.134f ]-..,.-on needing
In the third!paragraph it is indicated that lowering the slough mouths by 1.5'
feet would provide unrestricted access.Please refer to our comments on page
E-3-163.It is not specified which sloughs would undergo the proposed
modifications.We would expect lowering of all the sloughs by the same amount
wo!u1d result in different post-modification access conditions.We would like
tO'review the analysis which lead to the conclusion that the decrease in
elevation by the specified 1.5 feet would allow unrestricted access to
specified sloughs.
lJ;,.13S]!a:ge E-3-166:Access Mitigation:"Last Paragraph:Sloughs which would be
rE~structurecl Should be identified and the specific proposals described.We
ar'e not cogrJizent of what is being proposed in this section,or where it is
bE~i ng proposed.-t.0136]-\tige E-J-166:Se awn ;ng Hab!tat H;t;gat;on:PI ease refer to our coments on
patge E-3-98 ..
~.
The referenc:ed ongoing aquatic studies should be described •.....
[1.137]
I"""
.....
l .13B]
-
PClae E-3-167:Scarifying Side-Channels:This section should identify the four
:Sir e channels proposed to be scarified.We are interested in the analysis of
the specific:side channels,inclUding timing,volume,and duration of the
P"oposed high-flow release,the maintenance schedule proposed (if needed).the
sJlecies (by life stage)that are expected to benefit due to the proposed
lIK)dificatiol1 for each side channel,and the number of each species the
specific side channels would b~'expected to produce •
ilge E-3-168:Slough Gravel Cleaning:The utility of a high-flow release to
cleanse sloughs should be discussed.
The 10catiol1 of the mainstem spawning sites should be provided and gravel
SIJUrCeS identified.An analysis as to which species are expected to benefit,
81nd the anticipated production should be provided.
[1.139 1---+
[1.140]
[1.141 ]
[1.142 ]
~I
reservoir
In the last paragraph it is unclear whether the temperature discussions are,
for Watana alone,or for both dams.Temperature impacts are expected to
change during the filling and opration of Watana,the construction of Devil
Canyon,operation of the two dams under low and high power needs,and
operation during dry and wet years.The potential benefits of a low level
intake port in the Watana dam should be discussed as a mitigation measure for
adverse temperature impacts during filling.
Page E-3-l73:Grayling propafation Technology:Last Paragraph:We recommend
that the viability of a gray ing propagation program be established prior to
license issuance since it is a major element of the proposed mitigation
program..
Page E-3-l74:Introduction of Rainbow Trout into Devil Canyon Reservoir:The
potent,a 1 of the Devil Canyon r~servo i r as fi shery habi tat shou 1d be
re-examined in light of our.comments on Chapter 2,pages E-2-69,and E-2-96.
[I.143 ~~The referenced test of the Lake Comanche cone valves was evaluated for the
applicant by Acres American.3F-20/Please refer to our comments on page
E-3-114.
Given the lack of a strong endorsement by the applicant's consultant,the
anticipated frequent use of the valves,and the potential magnitude of
supersaturation as a fisheries problem,we recommend that the physical model
.study be undertak.en.--
[1.144]
[1.145 J pate E-3-l77:(ii)Mitigation for Downstream Impacts:The modeling effort by
AE DC is in an embryonic stage and coula not have been the basis of either the
impacts analysis or mitigation mitigation proposals in this section.The
forthcoming AEIDC report should demonstrate that their system of models is
functional.One of the initial findings of AEIDC's work is that,contrary to
-23-
r
l ....·145J
(cant)
r .148 J
t .149 J
.the assumption of the mitigation plan,project impacts do extend downstream of ~
the Chulitna River.3F-211 We recommend that the impact assessment include .
effects downstream of the Chulitna River,and appropriate mitigation for any·
adverse impacts identified.
~-.-
Page £-3-179:2.5.2 Construction Phase:The mitigation planning related to
pre-construction and construction phases,should.occur prior"'to license
issuance.
Page E-3-180:2.6 Monitoring Studies:We agree that an interagency mitigation
monitoring team must be established to ensure the proper and successful
execution of the mitigation plan and to detennine its effectiveness.The
composition,funding,mandate,and authorities should be specified as a
license article.We look forward to the anticipated discussions which will
lead to establishing this team.
Page £-3-188:2.8.1 U.S.Fish and Wildlife Service:Recommendation at Bottom
0'T'l;2e:To ensure its effectiveness as a mitigation measure,a sloughmo,1 1cationl demonstration should be undertaken in the Susitna River.The
de:monstratioln slough should display,prior to modification,the anticipated
POlst-proj ect condi ti ons for sloughs for whi ch mi ti gati on is proposed.For
example,the slough selected for demonstration should be characterized by
inladequate ac!=ess,silt accumulation,insufficient groundwater flow,and
limited spawning habitat.Preferably,the demonstration slough should be a
slough which does not currently support spawning and/or rearing salmon.
Page £-3-189:2.8.2 Alaska De artment of Fish and Game:Second RecolTD11endation:
iJile reSponSE!states a report ana yZl ng 1 nstream ows an temperatures
re:quired to maintain existing populations would be available after June 30,
19183.We request that the applicant provide the FWS with a copy of the report.
Chapter 3,Section 2 Footnotes
3F,:lJ Bernar"d,D.R.,et al.1983.Comparision of Scale Patterns from Sockeye
Salmorl Sampled from Different Rivers within the Susitna River Watershed
in 1982.ADF&G.Div of Com.Fish.
~~-2/ADF&G ..1983.Synopsis of the 1982 Aquatic Studies and Analysis of Fish
and Habitat Relationships.Prepared for the APA.,-
3f::Y See Footnote 3F-2,supra.
3f::Y See footnote 3F-2,supra.
3f:':y See Footnote 3F-2,supra.
!!:~-6/See Footnote 3F-2,supra.
3F-7/See Footnote 3F-2,supra.
3F-8/See Footnote 3F-2,supra.
3F-9/See Footnote 3F-2,supra.
3F-10/Wangaard,D.B.and C.V.Burger.1983.Effects of Various Temperature
Regimes on the Incubation of Susitna River Chum and Sockeye Sal mOD.
U.S.FWS.Prepared for the APA.
3F -11/AEI DC.1983.Exami nation of Di scha·rge and Temperature Changes due to
the Proposed Susitna Hydroelectric Project.Prepared for the APA.
3F-12/See Footnote 3F-ll,supra.
3F-13/See Footnote 3F-2,supra.
3F-14/Krishnan,G.September 13,1982.Gas Concentration and Temperature of
Spill Discharge Below Watana and Devil Canyon Dams.Acres American.
Prepared for the APA.
3F-15/Personal communication on September 30,1983 with Thomas J.Arminski,
APA Deputy Project Manager,Susitna Hydroelectric Project.
3F-16/See FWS letter dated January 14,1983 to Eric P.Yould,APA.Included
in Chapter 11.
3F-17/See Footnote 3F-ll,supra!
3F-18/See Footnote 3F-2,supra.
3F-19/See Footnote 3F-2,supra.
3F-20/See Footnote 3F-14,supra.
3F-21/'See Footnote 3F-ll,supra.
-25-
-
~,
Specific Comnents -
4 -WILDLIFE
I •
lJ..150]
[L151 ]
~.152 J
.....
~ase~E-3-295 and E-3-296:4.1.3 -Species Contributing to Recreation,
u slstence and Commerce:The section should be-eX'panded to reflect that not
only birds,but many wild.1ife species in the project area contribute to
non-cQnsumptive forms of recreation.'Incidentia1viewing of wi-ldlife in
conjunction with other activities is an unquantifiable but well documented _
value,.These non-consumptive values,the subsistence and commerce values and
the e!co10gica1 values mentioned in the Introduction,Section 4.1,were all
considered in selecting evaluation species within the FWS Mitigation Policy
(46 F.R.No.15,January 23,1981)and Resource Category determinations for
this project (FWS letter to Eric P.You1d,January 24,1983).-
Page E-3-304:··Cover Requirements:Paragraph 7:Proposed remapping of
vegetation to better reflect moose habitat components snou1d be described
here.Please also refer to our previous comments,Section 3.2.2(a).
pa 9j E-3-305:Habitat Use in the Middle Susitna Basin:Paragraph 1:The
eva lJat;on of moose use of different vegetation types by month woul d be
impr-l::lved by cornsidering the comparative availability of these types and
subareas important to moose throughout the middle Susitna basin.Vegetation
mapping,including understory.characteristics did not occur in 1983 as ,had
been indicated by the app1 icant in response to our comnents on the draft
license application (Chapter 11,14-3-204).Once vegetation is retyped we
recomnend that this and other baseline data be.reevaluated.The availability,
of different vegetation types and understory val ues of those types shou1 d be
considered within the constraints described on page E-3-304 •
t1..155 ]
.1531 Page 307:-Food Habits:Paragraph 3:WhHe we support attempts to quantify
moose winter carrying capacity as a first step in simulation modeling tjos
sectopm sjpi;d a;sp ;ost references and reflect concurrence of principal moose
investigators.The assumptions included in Appendix E.3.H should be
validated.Please refer to our comments on Section 4.3.1(a){iii)and on the
Mitigation Plan .
•154]Page E-3-310:•Lower Susitna Basin;Paragraph 2:The applicant should
confirm that all biotelemetry data indicated here as being available in June
1983 is contained in the ADF&G report prOVided to the FWS in September 1983.
3W-l!We have similarly assumed that other information to be supplied in
Jun.!1983 ;s also in the September report (e.g.,responses to our comments on
'the draft,Chapter 11,W-3-209).
Page E-3-315:•Mortality Factors:We reiterate our draft application
recommendation that this discussion include hunting as a mortality factor.
Although the applicant's response indicated that the subject was covered in
Chapter 3,Section 5,we find no such section (Chapter 11,W-3-216).Please
also see our comments on Chapter 5,Section 3.7.2.Treatment of hunting
should be better coordinated between Chapters 3 and 5,given the effect that
both recreational and subsistence hunting can have on wildlife population
size,structure,and distribution.
--
[I.156]pafe E-3-325:Cc)Oa11 Sheep:Paragraph 1:The preliminary nature of
in ormation presented here should be stated in view of ADF&G's proposal for
intensive ground observations and sheep studies which were conducted fro~
March through July,1983 •.
[I.157]Page E-3-327:(ii)Mineral Lick Use:Paragraph 1:The Jay Creek mineral lick
area should be better described and defined by elevation range and special
area.
[L158]Page E-3-328:(i1)Mineral Lick Use:Paragraph 5:During ADF&Gts intensive
1983 summer studies,moose were not observed using the lick itself (Nancy
Tankersley,personal communicati-on).ADF&G nO\'I consiaers previous
observations of moose use to be incidental.
[L159]Page £-3-328:Cd)Brown Bear:Paragraph 1:Current study delays and funding
cutbacks are preventing collection of valuable information and may make later
comparisions of year-to-year variations difficult.3W-2/
[L160]Page E-3-331:-Seasonal Movements:Paragraph 4:Given-the 1argehome range
sizes of brown bear documented on page E-3-323 (last paragraph through page
E-3-334,paragraph 1),we do not believe that bear use of the Susitna River
area has been overestimated as indicated here.~,
[L161 ]
rL162 ]
[L163 ]
[I.164 ]
[L165 ]
fI.166 ]
(L167 ]
Page E~3-335:Home Ranges:Paragraph 5:Our proceedi ng comments apply here.
Page E-3-337:(cl Black Bear:Paragraph 1:Funding cutbacks and study delays
are precluding necessary study progress and will make later data analyses
needlessly difficult and incomplete..
Page E-3-341:-Food Habits:Paragraph 2:The applicant should describe
ongol ng studi es which address the ·importance of ungu1 ate prey to b1 ack bear
(page 236;paragraph 1 of the draft application).
Page E-3-342:Home Range:Paragraph 2:It should be clarified how overlaps in
home ranges with the impoundment area can be greater than 100%.
Page £-3-342:pOfu1ation Size:Funding cutbacks prevented the 1983 spring
recensuslng of back bear.
Page £-3-344:(f)Wolf:Funding cutbacks have curtailed monitoring.Since
May 1983 only 2 relocation flights have been made for radio-collared wolves.
Page E-3-347:-Food Habits:Paragraph 6:Given the habitat losses,
disturbances,and other project impacts discussed in Section 4.3,it would
seem doubtful that the caribou population will increase,thus benefitting
wolves and relieving some moose predator mortality as suggested here.
Page £-3-349:(9)Wolverine:As with other big game species,funding cutbacks
are interfering with needed data collection.No funds have been available
since spring of 1983 to track the six wolverine radio-collared for the project.
-27-
~I
~.168]
.169]
[1.170]
....
l.1.•171]
l.L.172]
~.173]
P!~~-3-354:(a)Beaver:There have been no further beaver studies or model
aeveToprnent since March 1983.Additional data have not been provided as
indicated in response to our comments on the draft license application
(Chapter 11,W-3-237).'We are parti cu1 arly di sappointed that the opportuni ty
has been lost to verify and expand upon 1982 cache counts and to better
evaluate beaver habitats and populations which could be affected by the
proposed project.
Page E-3-356:(ii)Population Characteristics:At present there is no
relialble estimate of the beaver population below Talkeetna (Phil Gipson,
persclnal communication).Such an estimate would serve as a baseline for
evaluating upstream habitat losses and downstream habitat improvement.Fall
cache!counts,marking of'those caches,and 1ater spri ng surveys to determi ne
overwinter survival are necessary to assess impacts.Surveys could help
identify the mover:1ent patterns of young animals and downstream habitats which
may be improved due to project construction.Coordination between furbearer
biologists and hydrologists to assess icing conditions was not accomplished in
spring,1983 as agreed to at the February 28 -March 2,1983 follow-up AEA
worklshop.3W-3l
Page E-3-357:(ii)Population Characteristics:Paragraph 3:The need fo~
trapper surveys was agreed to at the February 28 -March 2,1983 follow-up
AEA workshop •.3W-41 Si nce no such work has been undertaken,we recolllllend
that a trapping survey be made of residents along the railroad,in Talkeetna,
in Cantwell,along th~Denali Highway,and in the Watana area •
Page E-3-357:(b)Muskrat:Sufficient water depth below ice is a habitat
requisite for muskrat as well as beaver.Measurement'of lake depths in the
middle Susitna River basin would allow assessment of which lakes are critical
overwintering areas.Shallower lakes wllere pushups may be visible but
muskrats do not successfully overwinter could also be then identified (Phil
Gipson,personal communication).
Page~E-3-358:(c)River Otter:Paragral'h 2:We suggest that fur-bearer and
aquatic resear·chers.determine whether areas where otter track concentrations
were observed in November 1980 correspond with grayling movements to
overwintering areas.
Pbge £-3-365:(h)Coyote:An addition to the tnfonnation provided here is an
o servation of a coyote feeding on remains of a moose on ice in the Susitna
River,about 7 miles downstream from the mouth of Portage Creek during March,
1983 (Phil Gipson,personal communicatation).
Page £-3-369 (a)Raptor~and Raven:Paragraph 1:Definitions for raptor
"nesting 10ca'tions i'and "nest sites li were found in Section 4.3.1 (n)(1),page
E-3-443,paragraph 1;not in Appendix 3.1 as indicated here.
,":.174]-
-.
,~
The draft report stated l·...precise elevations of nests and cliff-tops
relative to maximum impoundment fill levels are integral to a sound mitigation
pl an .••If (Chapter 11,W-3-251).That information is essenti al to several of
the recommended mitigation plans (e.g.Section 4.4.2(a){9),and (b)(lO),(20),
and (21]).T'he applicant should confinn that these data were obtained,and by
whom,and how the data will be incorporated into the Mitigation Plans.
-28-
[1.175]Pa e E-3-385:(v)Middle Basin Bird Communities:We appreciate inclusion of
a e an t e expan e discusslon on aVlan habitat types and
densities.Once the proposed vegetation and wetland maps are completed.these
data should be reexamined for further understanding of middle"basin bird
communities and project impacts.
[1.176]
[1.178 ]
Page E-3-396:4.3 Impacts:Paragraph 1:While we agree that acceleration of
secondary development in the Susitna River basin is an indirect rather than
direct project impact.the potential for such development should be fully
assessed within the intent of NEPA (42 U.S.C.4321 et seq.)
[1.177]Page E-3-396:4.3 1m acts Paragra h 2:Please refer to our comments on Table
regar lng lnconslstencles Wlt data presented elsewhere and to
additional comments on the species -specific impact tables.
"Pages £-3-396 to £-3-397:Moose:The qualitative statements which
characterize this section confHm the need to aggressively pursue development
of the moose carrying capacity model and completion of necessary background
studies.Please refer to our previous concerns with the validity of these
numbers (Secti on 4.2.1 (a Hi i]).
[1.179]Page £-3-396:(a)Moose:Paragraph 1:Oetails on specific locations and the
magnitude of benefits from theWatana project should be provided here.
~J
[1.1.80 J
[1.181 ]
[1.182]
[1.183 ]
Page E-3-405:-Permanent Loss of Habitat:Paragra h 1:In addition to
escrl lng ow lncrease moose ensltles cou cause a decline in habitat
quality adjacent to project impact areas.consideration should be given to .
existing utilization of those areas by moose and whether displaced moose could
ultimately survi ve.
Page £-3-406:•Upper Susitna Basi~:Please refer to our previous comments on
altered habitats,including needed quantification of these areas (Section
3.3.l(a){ii)and (;ii),(b)(ii),(iii).and [iv]).We are concerned that due
to decreased funding,plant phenology data obtained in 1983 may not be
analyzed.These data and analyses are essential to assess implications of the
reservoir impoundment and potential values of proposed habitat improvements.
See our comments on Section 3.3.1(b)(iv).
Page £-3-409:-Blockage of Movements:To better understand potential
movement blockages,we recommend that concentration areas and timing of moose
crossings of the Susitna River be analyzed relative to slopes in the drawdown
zone.
Page £-3-410:-Blockage of Movements:Para~raph 2:As we commented on
Chapter 2,page E-2-90.the expected delay ln ice cover formation downstream
from Talkeetna should be re-evaluated and,the results provided to allow better
quantification of the potential for interference with moose movements.
[1.184 ]The applicant should
information.
~,.
-29-
F""':.185]
-
[1.187 ],-
Wi.188]
-
.189 ]
•190]
,.191 ]
.
~E-3-411 -Mortality:Paragraph 1:The need to provide baseline data on
lliJritfing demand iind harvest was previously identified,as was the need to
coord'inate cons'ideration of hunting between Chapter 3 and Chapter 5 (Section
4.2.1(a)[iii]).Whether hunting will remove displaced animals and·thus
prevent overbrows ing of rema i ni ng habi tats wi 11 depend on the magni tude of
that displacement and regulation of hunting by the.Alaska Board of Game.....~
Page E-3-412:(iii)Quantification of Project Eff~cts:We support efforts to
model moose carrying capacity and subsequently simulate the cumulative effects
of habitat loss,habitat alteration,and various mortality factors.This
model will al so all ow a quantitative eval uation of the habitat v41 ues of
a1ter'native replacement lands.It should also be used to evaluate habitat
values of a1ter'native habitat improvement methods,e.g.,burning,clearing,
crushing,etc.Budget cutbacks and study delays are,however,interfering
with the timely completion of this habitat quantification.Contrary to
information presented here and responses to our previousrecommendati ons
conce~rning vege!tation values (Chapter 11,W-3-203 and W-3-204),the necessary
vegetation mapping may not be available until State fiscal year 1985.
pa[e E-3-414:I[iii)Quantification of Project Effects:Paragraph 6:The scope
an 1dming of preliminary model analyses to be available in 1983 should be
desc 11'i bed.
Page (-3-4168:(ii)Filling and Operation:Paragraph 7:Please refer to our
previous commelnt on page E-3-409 that slopes w.ithin the'drawdown zone be
analyzed relative to wildlife crossings (Section 4.3.1 (a)[iiJ).We again
recol111lend moqelin.gof reservoir ice formation and break-up during filling as
well as operation (see our comments on Chapter 2,page E-2-88).The time of
break-up has significant implications with regard to potential crossings by
animals such as caribou.
Page (-3-417:(c)Dall Sheep:Sheep studies,particularly in the Jay Creek
mineral lick area,were not undertaken until March through July,1983.
Information presented here should be qual ified as pre1 iminary .
Page (-3-418:(i)Constructi on:Para~raph 2:Oi sturbance of .sheep a:t the Jay
Creek mineral lick may be more immed1ate than lick inundation.However,
di sturbance fr'om recreati oni sts cou1 d extend through the proj ect 1ife.The
cumulative impacts should be evaluated.
Pages (-3-419 to (-3-420:eil Construction:Paragraphs 2 through 4:The Jay
Creek mineral lick area is apparently more extensive than it was originally
thought to be,.Additional downstream 1 ick areas discovered during AOF&G 1 s
recent work in the area would also be fully or partially inundated (Nancy
Tankersley,p.!rsonal conrnunication).While erosive water action could cause
exposure of additional mineral soil,it will more likely cause loss of the
steep rocky c'l i ffs resul ting in added stress and exposure to predators when
sheep use the area.
Given the apparent elevation range of the Jay Creek lick area,it is uncer-tain
that the 1 ick was ori ginally created or is mai ntained by the water act;on
along the creek.
-30-
(I.D91Jlihe discussion should consider impacts from proposed reservoir clearing
(cont)activities and provide information on how access for those activities is to be
provided.Timber clearing and associated access are further sources of
.di sturbance and coul d impact sheep use of the Jay Creek .1 i ck area.
[1.192]Page E-3-42l:(i)Construction:Potential disturbance and loss of habitat
from borrow area activities should be discussed.3W-5/
[1.193].;..;;;.a.rr:;--F-~~..;-;-~~~~~~~~~~~~~~ra~Phh,;,-;;3.,j-:Wh i1e brown bearsd1e y be inhibited by
[1.1941 Page E-3-427:(i)Construction:Para ra h 3:According to Figure E.3.37,
orrow area E is more extenslve than lt was originally thought to be and
represents a significant source of disturbance to the high density black bear
denning in the area (Sterling Miller,personal communicaton).
[1.195]Page E-3-428:(i)Construction:Para rapil 4:The ADF&G Phase II Annual Report
Aprl 983 shows the Watana lmpoundment area to be more important to black
bear janning than previously realized.~hirteen of 24 black bear dens found
within the project area will be flooded.3W-7/
[1.196 ]
[1.197]
[I .198 ]
Page £-3-431 to E-3-432:(f)Wolf:Last Paragraph:We agree that wolves may
temporary increase as a result of increased availability of prey due to
displacement adjacent to the reservoir area.Those initial benefits may later
mean more significant impacts to wolves as hunters and predators eliminate
prey.
Page £-3-435:(ii)Filling and Operations:Paragraph 3:Line 1:A more
accurate statement would be that no beavers are known to overwinter in the
river reach bebleen Watana and Devil Canyon (Phil Gipson,personal
comnunitation).
Pages £-3-435 to £-3-436:(ii)Filling and Oper~tion:Paragraph 4:The value
of sites occupied by beaver in the winter depends on water stability.Thus,
flow fluctuations for even a few days could affect downstream beaver.Beaver ~,
could be frozen out of their lodges and/or food caches if water levels
suddenly drop.Alternatively,their lodges and food caches could be destroyed
should sudden flow releases cause ice movements or flooding out of beaver
sites.The potential for daily flow fluctuations in winter should be
described.
As we commented on Chapter 2.page E-2-90,the expected delay in ice cover
formation downstream from Talkeetna should be described here and the
implications discussed in regard to beaver habitat improvement proposals.We
recommend using hydrologic data in conjunction with revised vegetation maps
and with information on vegetation succession to quantify downstream areas
likely to be affected under different flow regimes.Please refer to our
previous comments on the uncertainties in existing reservoir temperature and
Iicing models which make these conclusions on downstream vegetation succession
.and icing processes questionable {Section 3.3.1{b)[iii]}.
~,
-31-
.198]
(cont.)-.
[1.199]
[1.200 ]
[1.201 ]
[1.202]
r.203]
i
I .204]
An explanation ~should be provided of when,how,and by whom,"•••ava ilable
hydro'iogic data will be used to determine the most 1 ikely locations for
enhancement [habitat improvement]in downstream sections,I.as indicted in the
applicant's response to our previous comments on this subject (Chapter 11,
W-3-324)..
,.-...
We questi on whether beaver habitat can be improved~Other than to create
stable but high,er winter flows and deeper water in some sloughs and
side-channels for beaver'use,there may be other phy.sical manipulations which
could improve beaver habitat.These would be to:(l)dig out sloughs to
increase their depth;(2)put in bems at upstream channel openings to slow
dO\'In flows;or (3)put a dam at downstream channel mouths to deepen the water
in the channel.These are all drastic measures whose values have not been
proven in Al aska,and which potenti ally conflict wi th management and
mitigation plans for other species.
Page £-3-436:(j).r·1uskrat:Paragraph 1:The effectiveness of proposed
downstream improvements to muskrat habitat should be demonstrated.
Page £-3-436:(i)Muskrat:Paragraph 2:Because of the above concern we
quest.ion the certainty of the conclusion that,"Improved downstream habitat
will compensate~for .••[the impoundment area]10ss.1I
Page £-3-436:(i)Muskrat:Paragraph 3:The potential for negative impacts to
muskr'at from dalily flow fluctuations should be fully addressed.
Page £-3-440:(l)Coyote and Red Fox:paragra~h 5:Red fox habituation to
human activity may be overemphasized.The re erenced studies were in areas
protE!ctedfrom hunting and where vehicle use may be less frequent and at
slower speeds than it will be during project development activities.
~~fri £-3-441 to £-3-442:fm)Other Furbearers:Paragraphs 4 and 5:The
,,icult;es w,ith the marten model described here are sufficient to suggest
that the attempted quantification of marten populations,although eventually
desirable,is premature.In addition to seasonal differences in trapabi1ity,
the fact that a professional trapper worked in that area the previous winter
further negate!)the validity of this estimate.We suggest that the trapper be
contacted for 'further information on Watana area marten populations.
Page £-3-442:(n)Raptors and Ravens:Section discussions leave the unproven
imprl!Ssion that raptors and ravens wi 11 be di splaced to downstream and
adjacent areas.For example,on page 445,paragraph 5,it is inferred that
downstream cliffs may increase in importance to golden eagles who lose
upstream cliff nesting locations;however no analysis is made of comparable
foraging habitat at downstream locations.On page 448,paragraph 1,it is
similarly concluded that raven use of areas downstream from the Watana damsite
will increase after filling and before development of Devil Canyon.Response
W-3-339 (in Chapter 11)to our comments on the draft license application and
page 446,paragraph 3,includes no reference or criteria for assuming that
bald eagles now inhabiting nests to be inundated by the Watana impoundment
could later nest in adjacent areas upstream on the Susitna or Oshetna Rivers'
or downstream along Portage Creek,Prairie Creek,or near Stephan Lake.
-32-
[I.20S]
[I.204t-,little consideration has been given to the relative habitat values of these
(cant.)other areas,and why it is concluded that these areas are presently not fully
utilized.If food is unobtainable after project completion,it would be
meani ngless to provi de al ternative nesting locations •.Where al ternative
nesting habitat values are described,the potential mitigation values from
manipulating those habitat areas or otherwise attempting to provide
alternative nesting locations are unproven,and primarily speculative.For
example,the one documented case where a bald eagle nest.was successfully
reestablished involved an existing site w~ich was restored,not establishment
of a nest in an area currently uninhabited and unsuitable for nesting by bald
eagles.The viability of such measures in Alaska or similar environments must
be shown before they can be found acceptabl e ..
-page E-3-443:-Nesting Habitat:Review of Appendix 3.1 shows that successful
provision of artifical nest sites in Alaska remains unproven and untried.
While we agree that lack of opportu~ity rather than lack of knowledge may be
1imiting such appl ications,we bel ieve that such experiments do not serve as
mitigation for raptor nest loss from project activities.Lack of opportunity
is no reason to readily accept such measures without first demonstrating their
viability within the project area.
Information sources cited in the artificial nest examples 1,3,and 9 are not
included in the references listed for the Wildlife Section.Although nesting
parameters are thoroughly ·described here,no information is provided on
whether manipulated nesting locations are in areas with adequate foraging
habitat for additional eagles.The usefulness of providing or manipulating
nesting locations has not been proven for Interior Alas.kan raptors.
~,
[I.2061
[I.207]
[I.2081
Page £-3-445:Paragraph 4 through Page E-3-447:Paragraph 1:As cited in the
following section,(ii),on disturbance,bald and golden eagles are protected
under the Bald Eagle Protection Act (16 U.S.C.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 development or recovery operations (16 U.S.C.668a).The Act
provides for the taking of bald eagles or their nests only for certain
specific exhibition or scientific purposes when compatible with the
preservation of this species.That taking may be permitted by the appropriate
FWS Regional Director under eagle pennit regulations (50 C.F.R.22).I'Take"
is defined to include molest or disturb.
-33-
U.209]
U.210]
Page E-3-450:Bald Eagles:Last Sentence:The text should clarify whether the
assessment that food will,"•••be adequate for those eagles that remain after
construction and filling of the Watana reservoir,"includes the potential new
nests and eagle population to be provided in those areas by the Mitigation
Pl an.
b~gt E-3-451:Paragraph 2 through Paie E-3-454:Parasraph 1:(ii)
1S urbance:The ApA has inltlatedconsultat1on"wlth the Alaska oRegiona1
Director of thE!FWS with regard to the taking of eagle nests.-The applicant's"o
initial Februar'y 3,1983 and subsequent May 23 and June 21,1983 letters
request information on the FWS·s legal obligations and advice on how the
apparent conflict can be resolved.Our June 9 and June 3D,1983 responses
included a copy of the Bald Eagle Protection Act and app~opriate regulations.
We have described how the recent amendment to the Act does not allow
indiscriminate destruction of nests but could allow nests to be moved on a
case by case basis,under the appropriate conditions of a pennit issued by the
Secrl~tary.Thl~re are no provisions for issuing pennits to take or move bald
eagl~es nests for other than,.....the scientific or exhibition purposes of
public museums,public scientific societies,or public zoological parks"(16
U.S.C.668a).That the act merely prevents taking "without a permit"is an
incorrect description of the Act by the applicant,in Section (li)
Disturbance,paragraph 1,and in the Chapter 11 response (W-3-344,paragraphrr:-
In their letter to the FWS Regional Director and in the Wildlife Resources
section of the Exhibit E,the applicant has explained no such scientific Dr
exhibition purposes for the taking of bald eagle nests in the project area;
nor have any steps been taken by the applicant to obtain a case by case permit
for the similalr taking of golden eagle nests.The applicant has seemingly
accepted the fact that up to five bald eagle and eight golden eagle nests will
be destroyed 'fIli th project constructi on.An addi ti onal bal d eagl e nest and up
to seven additional golden eagle nests will be subject to disturbance from
project acceS~i,construction.and associated activities.The Exhibit E
Mitigation Plan assumes that provision of alternate nesting locations and nest
sites will adequately mitigate for these impacts.The previously cited
response to our comments o~the draft application suggests that the Bald Eagle
Protection Act will be met by implementing the Mitigation Plan:
I'•••in a manner that shoul d satisfy taking of ba1 d eagle nests as part of
a scientific study to learn about the effectiveness of several possible
mitigation methods useful as evaluative and mitigation tools should
similar conflicts arise between this species and other future
developmental or industrial projects"(Chapter 11,W-3-344).
We have not agreed to the need for such a study.Nor have we reached
agreement with the applicant on this subject.Successive comments on portions
of the license application which deal with bald and golden eagles concern
biological rather than legal aspects of this problem.We anticipate that the
applicant will initiate discussions with the FWS Regional Director for
resolving the!project's apparent conflict with the Bald Eagle Protection Act.
-34-
[I.211 ]Page E-3-453:(ii)Disturbance:Paragraphs 8 and 9:Recognition of the
eventual inundation of at least five of the seven golden eagle and two of the
four bald eagle nests due to the Watana impoundment makes the issue of
disturbance .from reservoir clearing operations somewhat of a moot point.
[I.212]Page E-3-461:(q)Non-game (Small)Matmla1s:Paragraph 4:The text should
explain how the estimated 5%decrease in northern red-backed vole numbers was
derived.
~I
[1.213 ]
[I.214 ]
Page E-3-465:-Alteration of Habitat:Please see our previous comments ~nd
references on altered habitats under impacts from the Watana development
(Section 4.3.1 (a}[ii]).
Page E-3-469(i)Beaver:References in support of the conclusions drawn here
should be provided.Please refer to our previous comments regarding
uncertainties in the potential for downstream habitat improvement (Section
4.3.1[i]).We are concerned that.although modeling of hydrology.floodplain
vegetation.and beaver populations is highly desirable.it is not now occuring
as indicated in the response to our previous recommendations on this subject
(Chapter 11.W-3-367).
I -e ages E-3-47l through E-3-474:en)Raptors and Ravens:Please refer to our!comments on Se~;on 4.3.1(n)regarding the potential for conflict with the
Bald Eagle Protection Act...
,[I.215]
Impacts of operating the Devi 1 Canyon dam shou1 d be described.
[I.216]
1.l.217]
[I.21SI]
[I.219]
Page E-3-474:(0)Waterbirds:Paragraph 1:We question the attributed
benefits to migratory waterbirds from project-induced open water areas.We
would not expect birds to arrive in the area any earl ier.Birds which rema.in
in the area longer may have problems finding food when encountering frozen
waterbodies once they do leave.No data have been provided on any
supplemental food values in the reservoir area;the discussion indicates
shorebird feeding habitat would not be created.
Page £-3-476:(0)Waterbirds:Paravrahh 2:Data should be provided to support
the contenti on that "di stri but;ona s ifts"woul d occur and downstream .
habitats can support additional waterbirds.
Page £-3-476:4.3.3 -Access Roads and Railway:Please refer to our previous
comments and correspondence for any recommendations;those include dropping of
the proposed Denali Highway-to-Watana access road segment (Sections 3.4.2(a).
pages 256-262,and letters from the FWS to Eric P.Yould,APA,August 17,1982
and January 14.1983).A description of the proposed access plan should be
included here for clarity.
Pa e £-3-477:(i)Mortality:Para ra h 2:While we agree with the statement
•••care u y managed unt1ng may e ect1ve1y mitigate for the indirect
project effect of overutilization of remaining forage,"such management is the
responsibility of the Alaska Board of Game and cannot be determined by the
applicant.As proposed,the project will result in impacts which may
foreclose some of the Board's options and desires for managing area game
resources.
~'J
~l
[......220]P~B_~_1E-3-48l:{b}Caribou:paragra~h 7:
~es estimates of vehicle traf ic.
We can find no Table E.3.l62 which
[-.221]
[J,.2221
[r .,223]
224:]
--
[.2251
-
~E-3-487:(h)Furbearers:Para raph 3:Poten.t-ial use -of material sites
aTOfl9 ea an ree con lets Wlt assurances in the Botanical Resources
secti on that us,e of such areas wi 11 be avoided through use of $i de-borrow and
balanced cut-and-fill techniques for road development (Section 3.4.2[i]).
This apparent discrepancy should be corrected.
pasS E-3-489:(i)Raptors and Ravens:Please refer to our previous comments
on ection 4.3,,1{n)regardi~g requirements of the Bald Eagle Protection Act.
age E-3-489:(i)Denali Hitway to Watana Damsite:Para2raph 3:
Incol1sistencie!;regarding w ich bald eagle nesting locatlons will be destroyed
by which project access features should be addressed.According to this
section,one bald eagle nesting location,BE-6·,in Deadman Creek,"••·.will be
physically destroyed by access road construction.It The same statement,
without the identifying location number,is repeated in Table E.3.l59 under
item (l).It is unclear whether the nest identified in that table is the same
as the one previously described.
In "able E.3.1S0,it is said that nest BE-6,1I •••may be affected by the access
corr'idor in Deadman Cl7eek,"and nesting location BE-8,"•••may be affected by
the construction of the rail road between Devil.Canyon andGol d Creek.II These
statements appear to contradict earlier descriptions in the Botanical
Resources Mitigation Plan and Figure E.3.8l that,IlAbalsam poplar stand near
Deadman Creek at access milepost 37.5 has been avoided by a one-hal f-mile
route realfgnment to protect a bal d eagle nest in the stand"(page E-3-258,
paragraph 2).While such road realignment is also described in Wildlife
Resources Mit<igation Plan (20),Section 4.4.2{b),the affected bald eagle nest
is described as BE-8 (page E-3-537).No mention is made of BE-6 or mitigation
for a bald eagle nesting location which would be disturbed by the railroad
between Devil Canyon and Gold Creek.These apparent inconsistencies should be
corrected.
Page E-3-492:4.3.4 -Transmission Lines:We have previously described the
problems with comprehensively assessing transmission line impacts in view of:
(1)different vegetation classification schemes used for different segments of
the line;(2)apparent inaccuracies in sums provided for affected vegetation
tYJlfeS (e.g."able E.3.86);and (3)inconsistent references to existence of a
69kv,34kv,or no temporary service transmission line adjacent to the Denali
Highway-to-Watana access road.Please see Section 3.4.2(a)(i),page 269.
We recommend that the resource agencies be consulted during detailed
engineering design with regard to on-ground siting of the line and any
mai ntenance ilccess trai 1s.Access trail s to the 1;ne shaul d be 1 imi ted to
reaches betwl!en major river crossings or topographical barriers.locked gates
or other imp,assible barriers should be placed at intersections of the
maintenance ,access trails with pUblic roadways.Please refer to our proposed
-36-
[I.22stiBiological Stipulations,Attachment A,and Wetlands Construction Methods,
(cont.)lattachment C for further recommendations.
Page E-3-493:4.3.4 -Transmission Lines:Paragraehs 2 and 3:To minimize
clearing requirements along the transmission corridor.we recommend that the
25-foot mai ntenance access trail be adj acent to the towers,in the area where
vegetation will be kept to a minimum height.The applicant should provide the
anticipated schedule and height criteria for safely maintaining vegetation
clearing along the line.Opportunities to alter the schedule to maximize
production of early successional vegetation types for moose and black bear
should remain an option throughout project life.Clearing should be done
after the ground has frozen and a snow cover is present to minimize the
potential to damage soil and vegetation ground cover,assuming no bear dens
are in the area.
[1.226]The referenced map of the transmission corridor (Figure E.3.37)is
incomplete.We suggest addition of an overview map showing the locations of
Figures E.3.48 through E.3.52.
Changes in vegetation diversity will vary depending on which types are
cleared,the existing interspersion of vegetation types and existing wildlife
uses in specific areas.~.
1.227]Page E-3-494 through E-3-495:(a)Big Game:The contention that animals will
relocate during construction and later return to the area should be
scientifically supported or dropped.No information is provided on the
availability and current wildlife use of areas immediately adjacent to the
line.During detailed transmission line siting we would expect that
additional bear denning areas would be located and efforts made to site the
line away from those areas.At a minimum,restrictive time-frames should be
set during which construction of those segments would be allowed.This
secti on fail s to indicate that the "temporary effects"of di sturbances caused
.by human activities during construction will be repeated during
as-yet-undefined periods of maintenance.Where increased browse production
along the transmission line attracts moose,-there is a potential negative
effect if the transmission line is adjacent to roads or railways.
"""
'~
cr.22S]
[I,229]
[1.231]
(1.230]Page E-3-497:(c)Birds:Paragraph 3:Reasons as to sh:'the 34kv construction
transmission line could not be built to avoid the possibility of electrocution
should be discussed.Electrocution is another reason why this should not be
the power source for project construction.Please also refer to our previous
comments on the construction of transmission lines,Section 3.4.2(a)(i).,-
pare E-3-498:(c)Birds:Paragraph 7:Because of potential disturbance to
go den eagle and raven nesting locations (GE-18,R-13,and R-21 ),we recommend
....,;
-37-
[.1.231]
cant:.)
[1.232]
[,J;,.23:1]
-
....
that construction of the transmission line between Watana dam and the Intertie
occur'before Malrch 1 and after May 10 (per Table E.3.128)if those nests are
inactive,or bE!fore March 1 and after the interagency monitoring team confinns
that the young have fledged and left (in July for ravens and in September for
golden eagles)if the nests are active.
ra h ~'l ::..Cri teri a ·used to detenni newheth~e-r~l~'m-p-a-c~tc·.-)-o~n--w~l~~l~e~p-o~p-u~a~to~n-s--w-e-re~,~.-.~.o~f sufficient magnitude to
influence miti!~ation planning,"should be provided.We are concerned that
emphasis appealrs to be on impacts for which mitigation measures can later be
recommended.Uncertainties in predicting project impacts on the basis of
existing infonnation are evident here.The general and incomplete nature of
the resu1 ti ng Mi ti gati on.P1 an alre due to these uncerta inti es.
Page Ew3-499:4.3.5 -Impact SUlTII1arl:Paragraph 2:We previously commented on
tJi'eneed to integrate discussions of hunting with those in the Socioeconomic
and Recreation Chapters of the Exhibit E.Hunting demand and harvest data
presented throughout Section 4.3 are minimal and not up-to-date._The location
'of -the section on socioeconomic/~i1dlife relationships,whlch has apparently
been added to Chapter 3 in response to our cOll1l1ent (Chapter 11,W-3-424),
should be noted .
n .234]Page Ew3-499:Cal Big Game:Paragraph 2:The preliminary estimate of 300
moose whi ch wi nter in the Watana impoundrnent·shou1 d be i ndi cted here;a1 so see
~our comments on Section 4.2.1(a}(ii).Apparently more recent censuses by
ADF&G have found over 600 moose wintering in the impoundment zone (Warren
Ballard,persc1 na1 cOlTlllunic.ation).
r-
[i .235]
[1.237]
[,I..238]
[....239]
[1.240]-
-
Page,E-3-500:Paragraph 2:Estimated moose losses to other project faci1 ities
should be qualified as above.The last sentence in this paragraph is
unsubstantiated and ·subjective.The amounts of existing vegetation types and
the vegetation succession expected for each of those types,overtime,should
be quantified"
PagE!Ew3-500:para gra 5h 3:Although it may not be possible to accurately
predict downstream ha itat changes,alternative scenarios should be presented
for different flow regimes,snow depths,and river morphologies.Such
information would allow assessment of the range of possible impacts and thus
necessary mit'igation..
Pag~!E-3-500:para~raPh 4:Whether alternative areas can support displaced
moose or whether t ose moose will alter their movements in response to
specific habitat alterations is unknown throughout the project area.
Page E-3-502:Paragraph 1:We concur with the ADF&G's concern.
Page E-3-502:Paragraph 2:Loss 'of escape cover and disturbance from
reservoir clearing activities in the Vlclnlty of the Jay Creek mineral lick
area should be discussed.
Page E-3-502:Paragraphs 3 and 4:Increased access and developments near
Prairie Creek are a further source of disturbance to brown bears using those
salmon food resources.
-38-
[1.241]Para ra h 2:-
[Io 243 ]
[I;242 ]Page £-3-504:para~raph 3:Work on the beaver habitat model has been at a
standstill since t e February 28 -n March 2 1983,follow-up AEA workshop.
With no additional data collection or modeling efforts funded in the State's
fiscal year 1984 bUdget,we question how this mode.1 will be developed.
Page £-3-506:pararaPh 1:The quantification of marten losses provided here
!also see Section.3.1[mJ)is inconsistent with the discussion under Devil
Canyon impacts,Section 4.3.2(m),where losses are predicted to be 14 marten.
The discrepancy should be corrected.
~.244]Pages £-3-506 through £-3-507:(c)Birds and Non-game Mammals:Taking of bald
and golden eagles is generally prohlblted under the Bald Eagle Protection Act
(see Section 4.3.1[n]).
[1.245]
[1.246]
Page £-3-508:4.4 -Mitigation Plan:This is a good first step in developing
a comprehensive plan for mitigating project impacts.Presentation of the plan
in the 1icense app1 ication is the first opportuni ty for interagency scrutiny
and review by principal investigators.Studies must be completed,measures
refined,numerous details added.and implementation assured before the plan
can be approved.We suggest that the applicant works closely together with
appropriate agencies to develop a detailed,mutually acceptable mitigation ~
plan.The intent of this comment is to initiate and encourage continuation of
studies to close data gaps identified in previous sections of the license
application.'
Since many wildlife mitigation measures are identical to botanical mitigation
measures.our concerns and mitigation reconunendations on Section 3.4 are thus
applicable to Section,4.4;e.g.,facility siting,reclamation,access
regulation,habitat acq~isition and improvement,etc.Please also refer to
~ttachments A through C.
......
Page £-3-508:4.4 -Mitigation Plan:Paragraph 2:In addition to the
vegetation and wetlands mapping and vegetation data analysis described
previously (Section 3.2.2),other requried studies include:(l)moose food
habits and browse information necessary to complete the moose carrying
capacity model;{2l continued radio-tracking of collared big game,.inclUding
moose downstream,and reco11aring of animals whose collars will soon become
nonfunctioning (a1 so see footnotes 3W-S and 3W-8);(3)fall cache counts and
marking of beaver lodges for follow-up,(4)use of snow transects to census
marten tracks,in and adjacent to the impoundment area,(5)examination of
otter tracks for concentration in late fall relative to grayling overwintering
areas.(6)continued development of species models through both small.single
discipline work sessions and larger interdisciplinary workshops to ensure that
objectives are coordinated,a common base of project assumptions are used,and
plans are complimentary;and (7)testing of recommended mitigation measures.
e.g.,disturbed site reclamation.habitat improvement (completion and
follow-up of the proposed Alphabet Hills burn,fOllow-up on disturbed logging
and mining areas near Palmer,etc.).
r"'''.246]We recommend that the Environmental Guidelines incl uded as Appendi x E.3.B to
conL)the Ex.hibit E,Ia •••be incorporated by the Alaska Power Authority,lI (Chapter
11,W··3-437).We have attached to our cOlTll1ents a more complete set of
Biological Stipulations.We recommend that Attachment A be incorporated into
the 1iicense and the construction contracts.
~.247]Page E-3-509:(ell Reductio'n in Carrying Capacity:Our previous comments on
minimizing disturbed areas,consolidating features,and using mi.tigative
construction techniques apply here (see Section 3.4.2).
r,;.o;:<.248]·Page £-3-509:(1)Moose:Paragraph 1:Calculations of losses in vegetated
habitat should be corrected.An additional 406 ha will be pennanent1y lost to
roads and railways.Neither borrow sites nor spoil areas for road
construction we're included in the 1875 ha calculated for temporary facilities
and borrow sites (also see our comments on Tables E.3.83 and E.3.84).
[1.249]......Page E-3-51 0:(i)Moose:Paragraph 6:We agree with the concept of
transmission corridor clearing to maximize browse production for moose.The
potential benefits should be quantified and then discussed in terms of
adjacent'moose uses,movements and limiting factors.
[~.250]Page £-3-510:(il Moose:Paragraph 7;Hunting is controlled by the Alaska
Board of Game.To the extent that the need for a controlled hunt is caused by
.....the project,then the project 'ha$foreclosed management opti ons of the Board ~
[I.251],Page E-3-511:eii)Caribou:Given the unknown nature of project impacts to
_'.caribou',provisions must be included in the license to later compensate for
impacts found thru project monitoring..
(.253]
-
['J..254]
.....
[1.255]
-I
Page £-3-512:(iii)Dall Sheep:Lowering the Watana dam height would minimize
or a\roi d impac1~s to sheep.I f the dam were about 185 feet lower than now
propclsed,phys ji cal loss of the Jay Creek mi nera 1 1i clc.and escape cover wou1 d
be hrge1y avo'j ded and di sturbance would be somewhat minimized.
Page £-3-513:I(iv)Brown Bears:Paragraph 6:Cooperati ve management
agrel:ments to mitigate potential impacts of secondary development and access
shou'ld be reached among the APA,resource agencies,and pri~ate landowners and
incorporated into the project license.We recOflll1end that public access not be
allowed on the project spur road across the Watana dam.'Such access -
prohibitions are necessary to prevent disturbance to bear concentrating on
Prairie Creek during salmon runs.
..
Page E-3-513:(v)Black Bears:Para ra h 2:Aligning transmission corridors
throug tun ra areas may not mlnlmlze lmpacts to black bears,and may disturb
brown bears;thus we question the rational for this alignment.
Page E-3-514:(vi)Wolves:Wolves'may ultimately be negatively affected by
reductions in prey populations and increased harvest pressures (page E-3-432,
paragraph 1 and page E-3-518,paragraph 3).The text should acknowledge these
impalcts.
-40-
[1.256]Page £-3-514:(viii)Beavers and Muskrat:and (ix)Mink and Otter:The APA
should clarify the magnitude and certainty for downstream habitat improvements
(see our conments on Section 4.3.1(i}{ii)).
[1,257J Page £-3-515:(x)Marten:Please refer to our previous comments on the
preliminary nature of quantified of marten losses (Section 4.3.1[m]).-
[1.259 ]Page"E-3-515:(xi)Raptors and Raven:Paragraphs 3 and 4:While the total
golden eagle population wi'l not be greatly affected,limited nesting habitat
and sparse populations in the interior make project impacts locally
significant.
""'"
[1.260.J Please
[1.261 ]
[1.262 J
[1.263]
[1.264:]
Pages E-3-518 to E-3-519:(i)Hunting and TrapPin a Mortality:Paragraph 5:We
have previously commented on the need to improve ownstream sloughs for
aquatic furbearers (Section 4.3.1{i)[ii]).It is currently unknown which
lakes are deep enough to allow successful overwintering and disper.sal for
beaver .and muskrat.
Page £-3-520 through E-3-522:(ii)Additional Mortality:An environmental
orientation program should be requisite at a worker's initiation of employment
(see Attachment A).Animal control measures should be coordinated.For "
example,beaver control efforts at culverts or sloughs may be desirable for
salmon yet beaver colonization may be encouraged in other project areas.
Page E-3-522:(c)Disturbance Impacts:Paragraph 2:Disturbance of denning
bears from transmission corridor,reservoir clearing,and reservoir filling
activities is potentially a significant problem.Efforts should be made to
locate dens before undertaking such activities.Transmission line routing and
clearing schedules could be designed to avoid such impacts.Where dens within
the impoundment area are to eventually be lost,it may be desirable to keep
bears from denning rather than to disturb them while denning.Consultation
with the resource agencies is necessary to plan these activities so as to
minimize impacts.
Page E-3-522:(c)Disturbance Impacts:Paragraph 3:Disturbance from
on-ground recreational activities could further disturb sheep in the Jay Creek
mineral lick area.
~'
[1.265]Page £-3-523:(a)Continued Monitoring and Study Needs:Overall,we endorse
the intent and substance of continuing stUdies (1)through (11)described
here.Monitoring is essential to determine additional mitigation needs.This
section should include data needs for continuing impact assessment and
mitigation planning efforts (see notes from the AEA modeling efforts)3W-9/
Those efforts must be completed prior to project construction and concurrent
with project design.A mechanism should be outlined for determining and
1 ...265r
cant:.)
[;•.266 ]
[.L.267]
D .268]
D .269]
L.270 ]
[I.271]
fl.272-}
n 273 ]
[i.274 ]
.implementing additional study and mitigation needs.The l.ength of time or
desired results of post-construction monitoring should be discussed.
Key components of a monitoring program are that it:(1)include appropriate
Federal,.State,and local agency participation;<.2J be fully supported by
project fundingl;and (3)be utilized to modify~>ctelete,or add to the
Mitigation Plan in response to both infonnation fFom ongoing studies and needs
which become apparent as project impacts are realized.
Another general recommendation on the Mitigation Plan is that consultation
between the l.ic:ense applicant and resource agencies include of working
sessions with project design engineers to fully incorporate wildlife
mitigation plans.
Page E-3-523:(2):We recommend that low-level aerial photographs be made in
both summer and winter and at least biannually to better quantify project
impacts to determine downstream changes in vegetation cover.
Page E-3-524:(3):Results of caribou monitoring may require further
restrictions on access as recommended by the interagency monitoring team.
paae E-3-524:(6):Surveys of active dens for brown bear,black bear,wolf,
an fox dens s~d continue during operation.
Page E-3-525:(8):Downstream beaver surveys should extend to the Ventna·
R,ver to estab~a baseline control for assessing upstream losses and
downstream habitat modificati.ons (see Section 4.3.1[;]).
Page E-3-525:(9):We concur with the need for annual raptor nest surveys.
Should surveY$identify the presence of the endangered peregine falcon.
Section 7 consultation should promptly be initiated with the FWS.
Page E-3-525:(10):If swan nesting is identified in areas where there is
possib,l;ty for di sturbance,surveys should continue through operati on and
maintenance..
Page E-3-525:(11):Monitoring of moose habitat improvement efforts should
begin now by evaluating disturbed areas in applicable vegetation types.
Candidate sites easily accessible for a low cost analysis include recently
logged and chained area near Palmer,Alaska.
Annual big game counts and compilation of harvest·records by location should
be continued so that long-term changes can eventually be eval uated.
Page E-3-525:(b)Mitigation PlarTs:Expected mitigation benefits should be
more adequately quantified.The potential effectiveness of many
recommendations is unknown.
Page £-3-525 to E-3-526:(l ):Delaying reservoir clearing a few years may aid
a few individuals,but will have minimal 10ng-tenm affects on wildlife
populations.Access as well as schedules for clearing should be planned in
consultationl with the resource management agencies.Clearing activity in the
[I.274]Jay Creek mineral area should be restricted to the period August 15 to May 1
(cont.)to prevent disturbance to sheep using the area.
[Io27S]Page E-3-526:(2):Please refer to our previous comnents,Section 3.4.2(a)(i)
pages E-3-254 through E-3-268.To prevent significant habitat losses,
disturbance,and loss of the remaining delta tributary to be unaltered by the
Watana or Devil Canyon impoundment,we recomnend that no borrow activities
occur in the porti on of borrow s;te E at the confl uence of Tsuseria Creek wi th
the Susitna River.
[Io276]
[Io 277]
[r.2713]
[Io 279 ]
IT.280]-
[I.281]
[I.282]
[Io 283 ]
Page E-3-526:(3):Information on existing vegetation cover and wildlife uses
is necessary to assess the extent to which revegetation will provide forage
desired by moose and bears.Black spruce may revegetate areas cleared of
black spruce;terrain features,interspersion with other vegetation types,and
habitual movements may stimulate or interfere with moose and bear use of
revegetated areas.Please also see our comments on Section 3.4.2(a}(i),pages
£-3-275 through E-3-281.
Page £-3-525:(4):Anticipated forage gains from clearing of the transmission
corridor ~hould be compared with anticipated forage losses due to p'ermanent
project facilities.Also see Section 3.4.2(a)(i},pages £-3-269 through
E-3-274.
Pages E-3-526 and £-3-527:(5):This statement is inconsistent with previous
statements about expected downstream areas of open water and frosting of
vegetation (e.g.,page E-3-408,paragraph 2;pa~e E-3-435,paragraph 4).
Also,refer to our comments on the uncertainty of reservoir temperature and
river icing models (Section 3.3.1(b)(iii)and pages E-2-119,E-2-12l,£-2-123,
and E-2-124l.
Page £-3-527 through E-3-530:(6):The lands to be managed must be examined
to determine whether desired plant species will revegetate ,the areas.In
evaluating the mitigation potential of candidate management lands,the
management options foregone should be identified.
Page £-3-529:Paragraphs 3 and 4:Projected improvement of bear habitat
should be quantititively supported'through controlled burns and revegetation.
It was stated earlier that pennanent loss of bear habitats can be mitigated
only through compensation (see page E-3-512,last paragraph).Provision of
one seasonal food has little benefit if another seasonal food is the limiting
factor to bears.
Page E-3-531:Paragraph (3):During 1983 field studies,AOF&G found the Jay
Creek mineral lick area to be larger than they had previously believed"Thus,
we recomnend that the applicant consult with the ADF&G in defining the actual
dates,and,and vertical distances from the lick in which aircraft activities
may be prohibited.
Page £-3-531:Paragraeh 5:Restrictions on aircraft activity near active fox
dens should be establ,shed through consultation with ADF&G.
Page E-3-532:Paragraph 4:Ground activity near the Jay Creek mineral lick
should be prohibited between May 1 and July 30.,
-43-
~I
-
[1.284]......Page E-3-532:Paragraph 5:The text should clearly indicate that sensitive
areas lnclude brown bear and blacK bear dens and ~he Jay Creek mineral lick
area.
r~.285]Page E-3-532:Paragraph 8:Active fox dens should be included here.
[1.286]
r.287]
(".288]
[,.I..289]
~~.29()]
~.291]
....
t ....292]
(.293]
[I.294]
l1..295]
-
,~
Page E-3-533:Paragraph 3:Final siting and schedullng of construction and
use of the Watana to Devil Canyon access road near nesting location GE-1S
should be decided in consultation with the FWS to ensure compl'iance with the
Bald Eagl~Protection Act..
Page E-3-533:Paragraph 4:Our previous comment on siting in consultation
Wi'tli'""the FWS also holds for the railroad alignment near nesting location BE-S.
Page E-3-533:l~In areas of permafrost,higher road profiles may be
requi red.
Page E-3-534:(l2):We recommend that the APA consult with resource agencies
in reviewing options for reducing traffic volume.If our recommendation to
drop the propo!ied Denal i Hi ghway to Watana access road is not adopted,then we
recornmend that the road not be maintained following project construction.
Rehabilitation of this link would inhibit public access and thus minimize
impa(:ts to all species from continued disturbance and habitat loss.Continued
acce$S for pro;iect maintenance could be through the railway and Devil Canyon
to Watana road..
Page E-3-534:(13):The criteria for establishing a population-level effect
on Dall sHeep should be provided.Since loss of escape cover may be as
cri t'ical as loss of portions of the 1 ick,exposi ng new mineral soi 1 may be of
little value as mitigation (Nancy Tankersley,personal cotmlunication).
Pages E-3-534 through E-3-535:(14):Mitigation of project impacts through
regulation of hunting will occur independently of project activities.When
such regulation is determined necessary by the Alaska Board of Game,it will
be at the expense of other managewment options (see Section 4.4.l(a)[i]).
pa gk E-3-535:(15):Environmental briefings should also be developed for
wor ers'familles who will be residing in the construction village.
Page E-3-536:(16):Please refer to our previous comments as to the
uncertainty that downstream slough modifications will effectively compensate
for upstream impacts to salmon and bear (Section 4.4.l(a)[iv]).Anticipated
reductions in predator populations are somewhat inconsistent with Mitigation
Plan.Before compensation can be made,quantification is necessary for the
timing,locations,and quality of seasonal forage gained at revegetated sites
compared to ar-eas where it wi 11 be los t..
Page E-3-356:(17):Please refer'to our previous comments on access road
borrow areas (Section 3.4.2(a)[i]).
Page E-3-537:(18):Development of the beaver model will not,1I ...mitigate
for residual impacts on furbearers.1I Use of the model will provide
-44-
[1:296J
[1.295]information for developing and implementing mitigative flow releases or other
(cont.)habitat manipulations.
Page £-3-537:(19):Please refer to our previous comments on the unproven
nature of slough modification for beaver (Section 4.3.l{i)[iiJ).The text
should indicate which sloughs are to be managed for beaver and which for
salmon and then define exactly what is meant by "•••s 10ugh enhancement
measures.II Exi sting beaver popu1 ati ons in all sloughs shou1 d be assessed.
Coordination between aquatic and furbearer investigators is necessary to
resolve potential conflicts between salmon and beaver uses and to determine
how best to exclude beaver from sloughs which are to be managed for salmon.
[I.298
[1.299 ]
[1.300 ]
Pages E-3-537 through E-3-539:(20)and (21 ):Please refer to Section
4.3.1 (n).
Pages E-3-540 through E-3-544:ec)Residual Impacts:While this section
generally identifies add;tional miti gat;on needs,it lacks any procedures or
mechanisms for implementing mitigation measures.There is no quantification
to ~tatements that most impacts will be mitigated -primarily though
increasing moose browse.The value of proposed browse manipulation is
unknown,yet these measures are claimed as out-of-kind mitigation for several
other species.
Alternative mitigation scenarios not yet developed may be foreclosed by
dependence of the mi"tigation plan on increasing moose browse.The benefits of'
such measures',wil1 not be known for 10 to 20 years,by which time it may be
too late,to do anything else..
The overall objectives of the Miti gati on P1 an are aimed primari 1y at moose and
salmon.Other proposals are generally of unproven value (e.g.exposing new
mineral soil for sheep;providing artificial nesting locations for raptors).
A possible effect of this narrow approach is a decrease in species diversity.
Out-af-kind mitigation proposals under (ii)Caribou,(iv)Brown Bears,and
(vi)Wolves conflict with FWS designation of those species as being within
Resource Category 2 and requiring in-kind mitigation under the FW5's
Mitigation Policy (see section 4.1 .3).
Page £-3-541:(iv)Brown Bears:The losses of foo~resources are viewed as
the most significant proJect impact.3W-10/It has not been shown that
burning will increase berry production.The statement that improved caribou
recruitment will provide out-of-kind mitigation is inconsistent with previous
information on the unknown and potentially negative nature of project impacts
(see Section 4.4.1{a)(ii),page E-3-511,and Section 4.4.2(b}(16),paragraph
2,page E-3-536).
Page E-3-543:(x)Raptors and Ravens:Potentially additive impacts of
disturbance,loss of nesting locations,loss of foraging habitat,etc.remain
unknown.The value and existing use of foraging areas near proposed
artificial nesting locations has not been shown.
-45-
-
~,
[;J;..302 ]
~.303]
[1.301 Jpafes E-3-544 through E-3-545:Cost Analysis and Schedul i"9:To provide for
,-un orseen contingencies,we recommend that a trust fund be established at the
start of license construction.Unspent monies would revert to the project
spons,or at the end of the.1 icense period.
It shou1 d not be assumed that appropri ate habi tat management 1ands wi 11 be
avail ab 1e through the Sta te or Federa 1 government.The appl i cant should
initiate discussions with resource and land management agencies as soon as
possible to identify potential management lands.
Page E-3-548:While we support monitoring,as well as plans to consult with
the resource a!~encies,we believe that an interagency team should be
established to oversee monitoring with some follow-up through project
operation and maintenance.
PagesE-3-549 through E-3-550:Transmission Corridor Reconmendations:Access
could be better controlled by signs,zoning (to prohibit Off-road vehicle
use),monitoring,and enforcement of fines.
Specific Comments on Tables for Wildlife Resources Section
\Table E.3.87:Problems with the comparisor.of aerial habitat with Viereck and[1.304:]~'~~::-=-=--r"r-uyrness vegetation classifications should be noted here as discussed in
Section 4.2.1{a)(ii),page E-3-304,paragraphs 3 and 4.
Table E.3.92:The very preliminary nature of this data should be indicated in
~tab'e title.
-
L.305]
Table E.3.144:This table is a useful,preliminary assessment,Of overall
project impacts.However,we have identified the following errors:
1.Pennanent Habitat Loss:
AccClrding to Table E.3.83,the Watana impoundment area is 14,736 ha.There is
some confusion with the area calculated for the access corridors.The
appllicant should clarify how borrow sites included here correlate with figures
given in Tab11~E.3.85 and the discussion in the text which states that use of
bor,"ow areas for access road construction will be minimal (Section
3.4.1(a)[i]).Figures for a permanent village of 27 ha and temporary village
of 49 ha are "inconsi,stent with the 70ha village (8ha of which is a lake)
listed in Tab'le E.3'.83.We find no description in the text or drawing in
Plates F70 or F71 of a 9 ha airstrip for the Devil Canyon development.
2.IHabitat Alteration and Temporary Habitat Loss:
As above,the figures given.here for impoundment clearing,temporary village
and temporary camp do not agree with figures in Table E.3.83.Figures for the
Devil Canyon temporary vi 11 age and temporary camp given here do not agree wi th
figures given in Table E.3.84.lhe figures given for the transmission
corridor are not consistent with Table E.3.80.According to Table E.3.80,the
Devil Canyon to Gold Creek segment will alter 131.7 ha;no information or
additional clearing for the Intertie is given here;and the source for the 209
,ha of additional "transmission corridor with Devil Canyon is unclear from Table
iE.3.80.
-46-
Potential alterations in ice staging.scouring,etc.are further impact
mechanisms which will result from hydrologic alterations.
Barriers,Impediments,or Hazards to Movement:3.
[1.305
(cant.)The permanency of these features·shou1 d be menti oned.
4.Disturbance Associated with Construction Activities and 5.Increased Human
Access:
While we agree that project studies resulted in initiation of these impacts in
1982,increases in impacts that will result from the onset of project
construction should also be noted.-
~-
[I.30 7 ]
[1.306]
~,
~l
Table E.3.146:The comparison presented here is of little value until
vegetation is retyped to reflect understory values and geographic units
corresponding to moose movements and habitat requirements.The larger the
study area boundary,the smaller the proportionate loss will be,irrespective
of what seasonal ranges are limited in a particular area..
Table E.3.l48:Anticipated and Hy othesized 1m acts to Oa11 Shee :(2)and
:Borrow areas and roads in the ViCln1ty 0 Tsusena Cree are an addltlonal
potential impact.
(5):Float 'plane landings and on-ground disturbance from recreational hikers
and campers are an additional recreational disturbance to be considered.
able E.3.l49:Anticipated and Hypothesized Impacts·to Brown Bear:(3):Roads
have been found to affect movement of bears .andcould inhibit crossings.3W-9
(4):Because of altered movements due to roads and construction activity,
young bears may not learn about available food resources in certain areas.
Thus,the project could influence the way future bear generations utilize the
I area.
[I.308]
[1.309]Table E.3.150:Antici ated and Hy othesized 1m acts to Black Bear:Please
re er to our comments un er Ta e 6 a out mis eading comparisions of the
proportion of conifer forest to be lost because of the project.The
proportion of conifer forest to be lost in the Watana dam area,as compared to
the entire basin,is much higher.Moreover,the even more limited areas of
deciduous forest may be the sites most preferred by black bears.3W-10
of
(2):Confirmation of those lakes supporting overwintering muskrats could be
obtained by measuring water depths.Lakes of greater than 2 meters would
likely be suitable for either overwintering muskrats or beaver (Phil Gipson,
personal communication).Potential downstream improvements have not been
uantified nor spacia11y identified in coordination with fish mitigation plans.
-47-
[,I,."311 ]
-
-~..
[1.312
(~
.-
[.313J
...
[.314]
,.,..
-
Table E.3.l57:,/\ntici ated and H othesized Im acts to Marten Weasel and
Lynx:and 2):Please refer to our previous comments on prob ems 1n
quantifying marten losses {Section 4.3.l[m]}.Fi"gures for areas of spruce
forest to be impacted by the project do not agree with information in Tables
E.3.83 and E.3.84.As we "colTlllented on Table E.3.l50,figures for proportions
of conifer forest to be lost are misleading."0 •
.'-Table E.3.l59:Anticipated and Hypothesized Impacts to Raptors and Ravens:
ffi;The text should lndlcate whether destruction of the bald eagle nest in
Deadman Creek will be avoided by access road rerouting shown in Figure .'
E.3.8l.According to the text,an additional golden eagle nest may be lost at
borrow site E (Section 4.3.1(n)[i],page E-3-445,paragraph 4).
(2):Claimed benefits of increased availability of small mammal prey appear
doubtful when cons i deri ng the 1ength of time tho se areas woul d have been out
of production during construction.
TablE!s E.3.17l throu h E.3.l75:Estimated ~1fti ation Costs:Costs for
1O'ITOw-up mon;tor1 ng to eva uate the e ectweness 0 the recommended programs
should be included.Provisions for funding additional measures,should
init~al mitigation prove ineffective,should also be included •
Table E.3.l78:Wildlife t1itigation SUl1lilary:Estimated costs for Monitoring
!tii'Cfj(2 and Mitlgation Plans 6 and 21 should be inclUded in project capital
costs,as shou'l d costs of any other miti gation necessary because of the
projl2ct.
-48-
Chapter 3,Section 4 Footnotes
31~-1/Modafferi,Ronald D.Apri 1 1983.Susitna Hydroel ectri c Project,Phase
II Progress Report,Big Game Studies.Volume II.Moose-Downstream.
Submitted to the APA by the ADF&G.
Ballard,Warren B.,Jackson S.Whitman,Nancy G.Tankersley,Lawrence
D.Aumiller,and Pauline Hessing.April 1983.Susitna Hydroelectric
Project,Phase II Progress Report,Big Game Studies.Volume III.
Moose Upstream.~ubmitted to the APA "by the ADF&G.
3W-2/APA~September 8,1983.-Appendices 2 and 3 to Agenda Item IV,Action
Item No.1,FY 1983 Program Changes and Their Impact on the FY 1984
Program and Current Proposed FY 1984 Budget Allocations,Susitna
Hydroelectric Project.Prepared for the APA Board of Directors.
3W-3/Everitt,Robert R.,Nicholas C.Sonntag,Gregory T.Auble,James E.
Roelle,and William Gazey.October 22,1982.Susitna Hydroelectric
Project Terrestrial Environmental Workshop and Preliminary Simulation
Model."LGL Alaska,Anchorage and Fairbanks.
Everitt,Robert R.,Nicholas C.Sonntag,Gregory T.Auble,James E.
Roelle,and William Gazey.April 27,1983.Susitna Hydroelectric
Project,Draft Report,Terrestrial Environmental Mitigation Planning
Simulation Model.ESSA Ltd.,USFWS and LGL Alaska for Harza/EBASCO,
Anchorage.
3W-4/See Footnote 3W-3,supra .
.3W-5/Miller Sterling D.and Dennis C.McAllister.1982.Susitna Hydro-
electric Project.Phase I Final Report.Big Game Studies.Volume
VI,Slack Bear and Brown Bear,page 60.Submitted to the APA by the
ADF&G.
3W-6/See Footnote 3W-5,supra.
3W-7/Miller,Sterling D.April 1983.Susitna Hydroelectric Project,
Phase II Progress Report,Big Game Studies.Volume VI;Black Bear
and Brown Bear.Submitted to the APA by the ADF&G.
3W-8/Modafferi,Ronald D.March 1982.Susitna Hydroelectric Project,Phase
I Final Report,Big Game Studies.Volume II.Moose-Downstream.Sub-
mitted to the APA by the ADF&G.
Ballard,Warren B.,Graig L.Gardner,John H.Westlund,and James R.
Dau.March 1982.Susitna Hydroelectric Project,Phase I Final
1 Report,Big Game Studies.Volume III.Moose-Upstream.Submitted
to the APA by the ADF&G.
Also see Footnotes 3W-1 and 3W-3,supra.
3W-9/See Footnote 3W-3,supra.
3W-10/See Footnote 3W-S,supra.
-49_
~i
,~
A
~,
;315]
JL.1..316 ]
&J;..317 1
-
.318 ]
Specific Comments
3-BOTANICAL RESOURCES
Page E-3-191::J.1 -Introduction:Paragraph 1:Jt-'is our understanding the
dowmitream study area extended only to the Deshka-·River,not all the way to
Cook Inlet.-3B':LI
pa ge,E-3-193:I[a)General:Last Paragraph:Floristic surveys were not
completed in 1983 as described here and under ec)Summary,page E-3-198.
curn!nt schedu 'I e of \'/hen the surveys wi 11 be conducted,and when the
infol~ation will be distributed,should be provided by the applicant.
Page E-3-195:3.1.3 -Contribution to Wildlife,Recreation,Subsistence,and
Com~erce:More specific information on different wildlife species'uses of
varlousvegetati on cOlTlTluni ties throughout the project area shou1 d be i nc1 uded
in this sectiol1.
Page E-3-196::3.2.1 -Threatened or Endangered Plants:Thirty-three,not 37,
plant taxa are currently under review as candidate threatened or endangered
spec'j es.A1 thlJUgh the proposed surveys for candi date endangered p1 ants were
not done in 1983,it is felt that the like1ihoqd of finding these species in
those areas is very low •
-
.Page £-3-196:(a)Watana and Gold Creek Watersheds:The word "candidate"
b--.319]shou'ld be added before "endangered plant taxa"in the last sentence on the
page.'.
~.320]
[1.321]
.322]
Page E-3-198:(a)Methods:Paragraph 1:The comparative widths of the
different access and transmission corridor segments which were mapped and used
for calculations in Tables E.3.77 and 78 should be stated.Also,see our
cOrmTllents on all of Section 3.2.2 (e)and Tables £.3.79 and £.3.86.Please see
our more detai1ed"coRments under Wetlands,Section 3.2.3,regarding the
.inaccuracies of typing wetlands solely from a vegetation-type map.
Phge E-3-199:(a)Methods:Paragraph 3:The 1982 browse inventory,plant
p enology,and Alphabet Hills pre-burn inventory and assessment studies should
be briefly described.
Page £-3-201:(a)Methods:Paragraphs 2,3,and 4:We support the proposed
vegetation and wetlands mapping programs.An additional objective is to
produce more realistic impact assessments by better integrating wildlife and
botanical studies.For the vegetation maps,the necessary detail should be to
Level V of Viereck,et a1.for forests and Level IV for other types.3B-21
Wetlands should be mapped directly from aerial photographs,and incorporate
soils and drainage characteristics,according to Cowardin et a1.(please also
see our Comments on Section 3.2.3).3B-31 The application should be updated
to include CUfTent mapping plans and information on how delays may affect the
proposed permitting schedule.Continued mapping delays could lead to
difficulty in re-siting facilities for environmental considerations.The
preliminary mapping scheduled for completion by June 30,1983 was not
accomplished.-
-50-
[Ie 323]
[1:324]
[1.325]
[1.326]
[1.327
[1.328]
[1.329]
Page E-3-204:eb)Watana and Gold Creek Watersheds:Information on the
seasonal values of vegetation types for food,cover,etc.,should be related
to specific wildlife species to document the importance of vegetation in
wildlife habitat.This would allow better integration of vegetation as
wildlife baseline data for impact assessment and clarify mitigation p1anni'ng
efforts.
Page E-3-211:(v)Aquatic Vegetation:The relationship of the aquatic
vegetation surveys to wetland types,and values of these areas to specific
wildlife species,should be described.
Page E-3-214:ec)Devil Canyon to Talkeetna:A comparison should be made of:
(l)characteristics of the Viereck et al.vegetation types as classified in
the upper and middle Susitna River Basins;and (2)the successional stages
into which vegetation along downstream portions of the Susitna River were
classified.Prevalence and association of wetlands types to downstream
successional types should also be covered here.
Page E-3-217:(d)Talkeetna to Cook Inlet:An analysis of early,middle,and
late successional stages above Talkeetna compared to the area below Talkeetna
should be provided.We suggest that the unvegetated islands and braided
channels of this section of the Susitna River indicate a more dynamic,rather
than stable,character as compared to the river upstream of Talkeetna.
Because.of significant flow changes which can be expected with project
construction,separate vegetation mapping should be undertaken of the 10-year
floodplain downstream from Talkeetna (e.g.Table E.2.4~in Chapter 2 documents
an expected doubling of mean flows at the Susitna Station (RM 26.0)from
·December through March with project operation).
Page E-3-2.7:ee)Transmission Corridors:The applicant's response to our
corrments on the draft license application indicates that,because of different
mapping resolutions,vegetation types quantified in Table E.3.79 cannot be
correlated with other segments of the transmission corridor beyond Level I of
Verreck et a1.(Chapter 11.,W-3-ll2).Different map scales and corridor
widths prevent a comparision or cumulative assessment of vegetation types to
be impacted by the four transmission corridor segments.
(We have previously corrmented on the interdependence of the
Anchorage-Fairbanks Intertie and Susitna hydroelectric project,recommending
these projects be analyzed as one (January 5,1982 and January 14,1983
letters to Eric P.Yould,APA).
Page E-3-219:(iii)Willow to Healy:We recommend remapping so that this
corridor can be compared to other sections mapped in greater detail by
McKendrick et a1.This would allow an assessment of cumulative transmission
line impacts and mitigation needs.
Page E-3-220:eiv)Dams to Intertie:Figures E.3.39 and E.3.40,showing
vegetation types crossed by thi s transmi ssi on corri dor segment and other
project facilities,are unreadable due to reduction for pUblication.
-51-
-
"""'.33,0 J
r"'.331J
-
-
(1.332]
.
Page E-3-220 and 221:3.2.3 -Wetlands:Color infrared aerial photograph
portions of the maps identified as Figures E.3.46~E.3.47,E.3.69 and £.3.70
were stereoscopically examined.The FWS found wetland and non-wetland areas
were inaccurately distinguished.Large areas'of upland are included in the
map LIInits classified as wetland.Many of these areas are greater than 100
acres in size.In addition,areas that have been designated as upland include
many wetlands,some of which are larger than 50 acres.A reasonably accurate
assessment of the amount of wetland to be impacted by the project cannot be
made with the ~information provided in the license application ..Another
problem involvl~s the use of only five broad wetland categories.The many
wetland types that are known to occur in the area have been lumped into these
categories.Wletland types vary considerably in their value as fish and
wildlife habitat.The impacts of the project on wetland types that have high
values are difficult to determine with the present wetland inventory
information.A more detailed classification using lower levels of the
Cowardin et al.(1979)system 36-41 would provide much of the needed data.
The existing wetland maps break down wetlands to the class level (e.g.
forested,scrub-shrub,and emergent wetlands).We recol'llllend that wetlands be
classified to the subclass and water regime level.We should be contacted for
assistance prior to additional wetland mapping efforts in the project area.
Pagf-E-3-221:3.2.3 -Wetlands:Paragraph 4:The application defines wetlands
as 'areas at least partly characterized by hydrophytic vegetation and the
presence of standing water or sheet flows."This definition needs
c1al"ification.It implies'that wetland types that do not have standing water,
but neverthelE~ss exhibit saturated soil conditions throughout the growing ,
sea$on,are nf)t addressed in the di scussions.These saturated wet1 ands
i nc'l ude many of the bO,g,f1 oati ng-mat,and muskeg type wetl ands in the project
area.Since some of these types are of concern to the FWS~and since the U.S.
Army Corps of Engineers (CEl extends permit authority to many of these
wetlands,they should be included in mitigation and impact discussions.
Pages E-3-221 and 222:3.2.3:(a)Methods:Table E.3.81 attempts to display
Viereck and Oyrness (1980)types which are interchangeable with Cowardin et
al.(1979)system wetland types.The table points out several major
pro1b 1ems.Enough i nforma ti on is presented in most of the Vi ereck and Dyrness
(19180)vegetaltion types to allow for more detailed classification in the
Cowardin et a1.(1979)wetland categories.For example,open black spruce can
be correlated to Palustrine,needle-leaved forests instead of Palustrine
forests.Willow shrub can be correlated to Palustrine,broad-leaved deciduous
sCl"ub-shrub,not just Pal ustrine scrub-shrub.In addition,field data
gathered during the initial vegetation mapping phase probably could provide
enough infonnation to add water regime modifiers to some of the Cowardin et
a1.(1979)wetl and types.Open b1 ack spruce in wet1 and si tuati ons in the
project area is nearly always characterized by a saturated water regime.The
open black spruce vegetation type could be correlated with Palustrine
needle-leaved evergreen,saturated.The wetland classes used in the license
application are too broad.Assessments of project impacts wetland types of
concern cannot be made with these lumped wetland categories.Some of the
Viereck and Oyrness (1980)vegetation types that appear in Table £.3.81 would
seldom occur in a wetland situation.This is especially true of the closed
white spruce.category.That category should have been classified as
-52-
[I.332
(cont.
non-wetland (upland).With the mapping procedures described in the
application,closed white spruce areas would be classified as wetland unless
the mapping personnel excluded them due to the "presence of steep slope and
likely good drainage."
The process of classifying the vegetation types into wetland categories,and
then excluding those areas that meet the ambiguous criteria of having "steep
slope and likely good drainage,1I results in an inaccurate depiction of the
wetlands in the project area.
Separation of wetland and non-wetland portions of each of the Viereck and
Dyrness (l980)vegetation types has to be done on the original aerial
photography that was used to map the vegetati on.Preferably thi s shoul d be
done during,the initial photo interpretation.If a Viereck and Dyrness (1980)
vegetation type appearing on the photo is only partially wetland,the wetland
area should be made a separate polygon and given a modifying code that
designates it as a wetland.To derive the wetland map,only those polygons
containing the modifying code would be transferred.The Viereck and Dyrness
(l980)classification would thery be converted to the appropriate wetland
classification.
Page E-3-222:(a)Methods:Paragraph 3:The application states that "Because
the system of Coward,n et a1.(1979)requires additional data on hydric soils
and periodic ambient water conditions to characterize wetlands completely,the
mapping is liberal and indicates areas whi.ch potentially qualify 'as wetlands
under that system.II This impl ies that detailed soil and water permanancy data
need to be available if wetlands are to be ma.ppedaccurately using the
Cowardin et al.(1979).
.~j
In most areas,however,such data are not necessary if the wetland types are
interpreted directly from aerial photography.The hydric soil and hydrologic
conditions that are an important component of the Cowardin et al.(1979)
system can be inferred from the information present on an aerial photograph.
The experienced photointerpreter who is mapping wetlands synthesizes
information on vegetation,slope,landform,drainage,etc.that is present on
[I.333 the imagery to derive a line that represents the boundary of a wetland.Soil
and water permanancy data are only collected at sample field sites where the
photointerpreter is determining the boundaries of representative wetland types
on the ground,and comparing these boundaries to the tones and textures that
appear on the aerial photography.
The wetland mapping methodology described in the application does not involve
direct interpretation of wetland types on aerial photography.An attempt was
made to derive wetland maps from the existing vegetation maps.If efforts to
refine the wetland maps does not involve additional photointerpretation,then
collection of extensive soil and water data would be necessary.The FWS
reconrnends that any wetlands map refinement involve direct interpretation of
aerial photos.The Viereck and Dyrness (1980)vegetation units on the
original aerial photography could be analyzed so that wetland portions are
differentiated,or entirely new wetland mapping could be done with delineation
and classification of the wetland types on the aerial photos being done in
accordance with the Cowardin et a1.(1979)system.Costs and time involved to
perform either method would be approximately the same.
-53-
'The FWS does not agree with the baseline report.conclusion that detailed
wetlclnd maps in the project area would be extremely difficult to produce using
s:tandard photointerpretation techniques.The primary reason for this
diffiiculty,according to the report,is the conclusion that "wet1ands are
highly integrated with non-wetlands,"and p1an,1;species composition in wet and
non-~,et1and is similar,differing only in the qUa~tities of individuals.
Analysis of the high altitude aerial photography covering the project area by
FWS.personnel indicates that detailed wetland map~can be produced,and tJ1e
wetlainds can be accurately classified to the subc1a'ss and water regime levels
of the Cowardin et al.(1979)classification system.Although there are some
wetla,nd types that will initially be difficult to distinguhh from adjacent
upland areas.a'moderate amount of ground truthing can provide the
photointerpreters with enough information to draw the wetland boundaries with
reasonable accuracy.The intricate pattern of mixing between wetland and
non-wetland areas that occurs in portions of the project area would result in
some generalizing,but the generalizing would be far less than that in the
existing ,wetlands mapping.A minimum mapping size of approximately four acres
cauld be 'displayed if the wetland maps were produced at a scale of 1:63,360.
We suggest that site-specific f;e1d confirmation of wet1an'ds be undertaken in
coordination with concerned agencies (e.g.CE,FWS.EPA,and Alaska Department
of Environmental Conservation).Particular concern would be where preliminary
design shows potential conflict between project facilities and wetlands.
SupP01rt ,and prel imi nary pl ans for such agency coordination were establi shed at
the December 2.1982 wetlands meeti ng (pl ease refer to notes from APA's
license application workshop included as Appendix E11.H to Chapter l,l).
~ge E-3-223:(b)General Description:Discussion should be provided on
successional patterns and fire predominance in wetland types.
We qUE!stion the wetl ands c1 assi fi cation of mapped vegetation types without use
of other factors or field verification.Please refer to our two previous
comments.
2:It should be indicated on~~~~~~~~~~~~~~~~~.3.66 through E.3.73}that
~]Page E-3-225:(a)Construction:Other than the direct vegetation losses due
.•336 to inundation.and construction of camp,village,and borrow areas described
here and in Tables E.80. E.82, E.83,and E.85,there is no quantification of
~types and areas to be potentially impacted by erosion,permafrost,melting,
etc.Several of those impacts can and shoul d be analyzed based on i nfomati on
in Chapter 6,Geological and Soils Resources,and Figures E.6.30 through
£.6.45.
11 337]Page E··3-225:(i)Ve etation removal:Para raph l:We concur with intentions
•to confine spo,depos1tl0n to areas wlthln the impoundment or areas already
disturl)ed.We siggest that the potential size and locations of spoil areas be
mapped and quantified in the discussion and accompanying tables.
_5 4 -
[I.338 J
II.339J
[r.340J
[1.341 J
Page E-3-226(;i)Vegetation Loss by Erosion:We recommend quantifying the
permafrost and unstable slope areas mapped in Chapter 6,Figures E.6.30
through E.6.45,by vegetation type.Overlay maps of a readable size are
necessary to fUlly assess botanic41 impacts and resultant implications to
food,cover,movements,and other habitat needs of key wildlife species.An
explanation should be given as to how the cited 1379 acres of unstable slopes
were derived.
Page E-3-226:(iii)Vegetation Damage by Wind and Oust:Paragraph 1:We find
it difficult to quantify the miles of shoreline and the aneartiy area where
b1owdown of trees may occur.Tree b1owdown could be critical with regard to
loss of nest trees and wildlife cover adjacent to the reservoir.Please also
refer to our comments on Wildlife Sections X and Y.
Page (-3-226:(iii)Vegetation Dama~e by Wind and Oust:Paragraph 2:As
above,we suggest that:(1)quantiflcation be made of the areas likely to be
affected by dust accumulations,(2)time frames be outlined within which such
areas are likely to be affected,and (3J correlation be made with wildlife
uses in those areas.
Page E-3-227:(vii)Effects of Increased rires:We concur with this
description and note that fires occuring near populated areas will likely be
repressed.Thus ,the potential for using precribed burns to stimulate natural
successional patterns may be reduced.
-
LI.342 J
Page E-3-228(b):Filling and Operation:Another impact which should be fully
assessed is the pot~ntial for increases in fish mercury 1ev'e1s.Canadian
studies have found reservoir impoundment to cause mobilization of natural soil
mercury to occur,even where natural mercury levels in soil and vegetation are
not high 36-4/We recommend that baseline mercury levels be measured in
soils and vegetation.Such measurements should be made in similar areas which
will and will not be inundated.Mercury levels should be monitored during and
following project construction.Please also refer to our more detailed
comments and references cited on Chapter 2,Section 4.1.1{e)(vii),Page E-2-96.
[1.343 +-'T"I'I':age £-3-228:(i)Vegetation Succession Following Removal:Natural plant
succeSSlon may also be lnhlbited or precluded followlng disturbance unless
topsoil is restored and steps taken to minimize erosion,changes in area
drai nage,etc.
Please refer to our comments on the Mitigation Plan,Section 3.4 Attachment A,
Biological Stipulations,XI and to the restoration plans and analyses prepared
for the Alaska Natural Gas Transportation System..
The discussion has not been expanded to include wetland types as the applicant
had indicated it would be in response to our comment on the draft application
(Chapter 11,W-3-122).We are concerned that the browse nutritional stUdy
referred to in that response has been reduced in scope,some aspects have been
delayed,and others.such as the vegetation remapping,will probably be
completed too late to optimize sampling.
-""--
-55-
-
~.344
II'"":.34 5]
-
[1.346J.-
lI.347 ]
rJ.I.348]
[Io 349 J
~E-3-229:Tundra:The areal extent of permafrost relative to vegetation
cover types and project features should be quantified and figuratively
represented here for the dam,impoundment,and associated construction
facilities,and in the following sections for access and transmission
corridors.Please also refer to our previous comment on Section 3.3.1
(a)(iii),Vegetation Loss by Erosion (page E-3~225l.
~~gl=E-3-232:-Watana to Devil Canyon:Paragraph 4:We appreciate the
1scussion of rime ice formation in response to our previous conunents (Chapter
11,W-3-125),but note omission of Wood et a1.(1975)from the document's
reference list.An important concern with rime ice formation would be
potential impacts to birch adjacent to the impoundment and winter use of those
areas by moose.
;ige £-2-234:Talkeetna to Yentna River:The project is expected to alter
ows to the extent that mean winter flows at the Sunshine Station (RM 84)
will be three times pre-project flows (Chapter 2,Table E.2.47).Scouring of
vegetated banks resulting from river staging due to ice formation could be
extensive and should be discussed.
Paqe £-3-235:Yentna River to Cook Inlet:We are concerned that minimal
~,nstream impacts have been assumed even though a doubling in mean winter
flows has been predicted at Susitna Station (RM 261 (Chapter 2,
Figure E.2.49);and ice staging and break-up impacts are unknown.
-56-
[1.350]Pa2e E-3-236:(iv)Climatic Changes and Effects on ve1etation:The areas in
Wh1Ch vegetation changes will occur must be known toully assess implications ~
to wildlife habitats.
[1.351 ]
[1.352 ]
[1.353 ]
[1.354 ]
[1.356 ]
LI.357]
Page E-3-236:eiv)Climatic Changes and Effects on Vegetation:Paragraph 2:
Although phenology stud1es were undertaken 1n spr1ng,1983 to obta1n data for
oetter assessing project-induced temperature/vegetation/wildlife impacts,
funding for analysis of that data cannot be assumed before State fiscal year
1985.We recommend that a list of available botanical data compiled by the
University of Alaska be included as Attachment B to our comments,be
critically scrutinized with regard to further study needs.Funding should be
provided to complete analyses of critical information.
Page E-3-237:(vl Effects of Increased Human Use:We concur with this
assessment and again cite the opportunity for minimizing project impacts on
fish and wildlife by carefully siting and regulating access.Please refer to
our comments on Sections 3.3.3 and 3.~.2(a)(i)and previous letters to the APA
on the issue of access dated August 17,1982 and January 14,1983 (the latter
letter is included i~Chapter 11).
Page E-3-238:-Fires:Paragraph 2:An additional point which should be
considered in assessing the values to wildlife of post-fire regrowth is
whether productivity,as well as density,of berry producing plants increases.
Page E-3-240:(a)Construction:There is no quantification of vegetation
types and geographic areas to be potentially impacted by erosion,permafrost,
melting,etc.other than for direct vegetation losses due to inundation and
construction of camp,village,and borrow areas described here and in Tables
E.3.80, E.3.82,E.3.84,and E.8S.Several of those impacts can and should be
analyzed in conjunction with information in Chapter 6,Geological and Soils
Resources,and Figures E.6.21 through E.6.29.
Page E-3-240:eil Vegetation Removal:Natural vegetation of disturbed sites
will occur only with proper site preparation,including storage of topsoil.
Analysis of the figures given shows that,at most,no more than 10 percent of
the vegetation to be lost from the Devil Canyon peve10pment will be replaced
by reclamation.We again recommend prompt mapping of wetlands,
reinterpretation of vegetation in a manner that is meaningful to wildlife,and
consultation with resource agencies such as the FWS to confinm optimum siting
of camp,vi 11age',and borrow areas.
Page £-3-240:(iil Vegetation Loss by Eros;on:Please refer to our previous
comments on the need to quantify permafrost and unstable slope areas mapped in
Chapter 6,Figures E.6.21 through E.6.29,by vegetation type (Section
3.3.1(a)[ii]).
-57-
-
-
-.
~\
~,
-
~I
"""..
-ATTACEMENT B ·Agriculrurel Experiment Stefion
Polmer Research Center
-Box AE
Palmer.Aicslc.a 99645
-
-
~,
-I
l;
<
-
UNIVERSITY OF ALASKA
January 24~1983
Dr.Robin G.B.Sener
Susitna Program r4anager
Wi]dlife &Botanical Resources
LGL Alaska Research Associates~Inc.
1577 C Street
Am:horage,Al aska 99501
Dear Robin:
Attached are two lists of data,with brief descriptions,available on
thle Susitna drainage.This was prepared in response to our telephone
conversation of December 16,1982,when we were concerned about data
bei ng forgotten.The fi rst 1ist summarizes 'da ta that the Alaska PO\'ler
Authority has funded to at least some degree.The second list summarizes
..Susitnadrainage data col1ected by other projects and incomplete data
where the field sampling was funded by the Power Authority.In some
cases,samples need to·be -ground ·or ha'/e laboratory analysis .performed
but in other cases the data only need to be analyzed statistically.
The descriptions of old studies were not meant to be detailed,but
rather to make people aware of the depth of data collected in the past.
One thing becomes apparent from these lists:There is an enormous
amount of vegetation data and smaller amounts of soils data and soils-
v€!getation data that could be available if we had funds and time to
analyze and integrate the data.Even though some of the data may not be
e);actly what is needed now,the data could certainly be used as a foundation
for future experimental design,assessing impacts,and making revegetation
rE!commendations.The wheel t So already been invented a couple times;
mZlybe these lists \'Ii11 help produce a better wheel in the future.
Sincerely,
Dot Helm
Plant Synecologist
cc:Richard Fleming,Alaska Power Authority
:".
!getation mapping
~getation inventory
Yfj tWhCj I,_fi~I..Lfund~-Lii~tudl ~,~•Lot....ion i
Middle,upper basin
Middle,upper basin
i
1980 Plant Ecology
1980 USFS
SCS
Plant Ecology
Sus i tna
Cooperative River
.Bas i n Study
-t -r -'ld.L~I"_(
Vegetation means in annual rer
(variances calculated,not
reported)
Maps of vegetation,potential
lands produced
Some vegetation (timber)aha1:
oth~r (understory)being
processed;not sure about s'
Some soil &vegetation sample
collected
Jwnstream succession Delta Is.-Chase
"I.
1901 Plant Ecology Susitna Vegetation means in annual re
(variances calculated,not·
reported)
Soils collected
ertilizer trials Watana Base Camp
e1fcopter transects Delta Is.-Go1d Cr.
1980 Plant Ecology Partly Susitna
1981 Plant Ecology Susitna
Data need to be summarized.
Crude vegetation analysis -%
of vegetation types on f100
Referenced in Final Report
'ransmi ss i on
corridor mapping
N.S transmission corridors 1981 Plant Ecology Susitna,Maps produced:·no ground-trut
lownstream succession Curry-Devil Canyon
:rowse
'heno1ogy
lurn
Middle basin'
Middle basin
Alphabet Hills
.t
1982 Range Ecology Susitna
1982 Range Ecology Susitna
1982 Range Ecology Susitna
USFS USFS
BlM BlM
I
1982 ·Range EfolO9y Susitna
,
Vegetation means,variances f
1eve 1 V given to lGl
Vegetation samples,some l1tt
samples collected
Vegetation.tree cores,temp(
tures taken;being analyzec
Photos taken each week.
Crude vegetation statistical
analysis performed by USFS
litter samples collected
Permanent photo plots.
Shrub cores collected:no rir
counted
Study location Year Wllo l---rETu ~j UHI.l '11::/
{egetation inventory lower basin Cooperative River Not sure
Basin Study Some vegetation samples collected
{egetation mapping Upper basin pre 1980 BlM
pre 1980 USFS
SCS
Denali Project Map produced.Cover,frequency ani
Middle,upper basin 1980
Middle,upper basin 1980 Plant Ecology Susitna
Cooperative River
Basin Study
USFS
SCS
Plant Ecology
Soil chemical analysis performed a'
expense
Some plant species ground &ana1yz'
soils analyzed at AAES expense
Other plant species collections ar
available,but not ground
Data partly analyzed by USFS.
Plant Ecology Logistics-Susitna Materials provided at AAES expense
Data collected,chemical analysis;
MES 'expense
Data unanalyzed
1980WatanaBaseCamp
,(
Jegetation mapping
F~...Hizer trials..
~
'/egetation inventory
Oown~tream succession Delta Is.-Chase 1981 P1ant Eco~ogy.5usitna Vegetation height class informatio
available,not reported
Soil chemi Cil 1 ana lys is performed a
expense
Soil texture need to be obtained
Brm'lse
P'1010gy
Burn
Middle basin
Middle basin
Alphabet Hi 11 s
1982
1982
1982
Range Eco1~gy Susitna
Range Ecology Susitna
Range Ecology Susitna
USFS USFS
8lM .BlM
Soil,litter samples laboratory an
at AAES expense
Data are unanalyz~d
Vegetation samples collected,but
ground or analyzed
Tree rings need to be counted.A'
nutrition data need to be analy;
Soil,litter samples laboratory a,
at AAES expense
Vegetation samples collected,but
ground or analyzed
Vegeta tiOii fi e1d da ta sun!l!arized t
Downstream succession Curry-Devil Canyon 1982
t t {("-ILl ~l t t \
,{(
Range Ecology Susitna
I
-86-
Rings need to be counted.Need t(
bine this information with hydn
I
Description of Susitna Vegetation Data Sets
I
Vegetation inventory -Cooperative River Basin Study -USFS,SCS
Fairly intensive permanently located vegetation plots
Measurements include:
timber inventory
ground cover %-below &above 4 1/2 ft.basal,moss,lichens,
residue,bare ground,rock,water,total
wildlife signs-hedging,browsing,number and type of trails,
nesting trees ..
wildlife habitat data -slope,aspect,vegetation structure
tall shrub -productivity,available browse by species
habitat -height,canopy,density by plant species
range production -weights by plant species
50il.s -SCS descriptions
~,
Vegetation Mapping -Susitna
.Qualitative vegetation cover estimates
Some soil s data
Fertilizer trials
1980
1980
Annual ryegrass was planted in factorial design using NPK treatments
with 3 levels of each
Responses measured included height,production,nutrief'lt analysis
and photos of individual plots,l34.H..('·...L toil IQJan-r.JY"',/IIl'llo'yrU IJ'tr"'l!:
Downstream succession 1981
Vegetation cover by height class;density by size class;ages,heights,
dbh1s of shrubs,trees.Belt transects were used.~.
Soil pits sampled by horizons or fluvial layers
Helicopter transects
Vegetation types at systematic points along transects
Downstream succession
1981
1982
Shrub cores collected in early-middle successional types along
hydrology transects.
Range ecology studies 1982
Detailed description/and data formats have been provided previously
(December 14,1982,to Steve Fancy,LGl)
PO'''''.359]
-
-
[~.358]~asi £-3-241:(iv)Eff~cts of Altered Drainage:Please see our comments on
~e E.3.82 regarding the likely overestimation of wetlands'as described here.
Page 'E-3-241:(b)Filling 'and Operation:Please refer to our previous
coments and study recommendations on the potential for
soil/Vegetation/reservoir interactions which result in increased mercury
levels in fish (Section 3.3.l(b)and in Chapter 2,Sectio'n 4.l.l(e)[vii]).
L....360]
r .361]
-
r..362]
r-.363]
n ~364 J
rr-365 J
,.-.
I
~.366]
~E-3-242:(ii)Erosion and Deposition:This statement is inconsistent
WTt]Ithe previous discussion of erosion,Section 3.3.2(a){ii),the proceeding
paragra~h which assumes some soil losses following clearing [Section
3.3.2(b)(i)],the description of the large landslide at RM 175,and the steep
area topography.
Page E-3-242:(iii)Effects of Regulated Flows:Frost build-up on'vegetation
adjacent to the reservoir could result in a sign{ficant changes in
vegetation.Wildlife would subsequently be affected,as.we commented under
Sect"ion 3.3.1(b)(iii).Please also see conments there regarding the need to
quantify the range of areas which may become available for successional
vegetation development.
Page E-3-243:(a)Construction:,Additional impacts from access road
~truction and use include thawing of adjacent permafrost and associated
drainage and.vegetati on ct\.anges.
Page E-3-244:(b)Operation:Use and management of access routes in addition
to those required for project construction will detennine the magnitude of
impacts to area fish,wildlife,and socioeconomics.
Page E-3-244:(a)Construction:Paragraph 1:In addition to the botanical
impact analysis of individual transmission line segments described here and in
Tables E.3.79,£.3.80 and E.3.86,we reconrnend a cumulative assessment of
these impacts utilizing the same vegetation and wetlands classification
systems for each segment.Please refer to our previous comments that existing
analyses cannot be compared (Section 3.2.2 [e]).
Pleclse also note apparent calculation errors in Table £.3.86 which double the
estimate of total areas to be impacted by the Healy-to-Fairbanks and
Willow-to-Cook Inl et transmi ssi on corri dors.Subtotaled areas of forest,
tundra,shrubland,and unvegetated cover types crossed appear to have been
addE!d to the i ndi vi dual si xteen forest,three tundra,four shrub 1and,and two
unvt!getated types in arriving at an overall total.
Ref terence shoul d be made to our cOll111ents on Tabl e £.3.86 regarding potential
inaccuracies in recalulation of transmission line right-of-way widths 'from 400
to 300 feet.
Page E-3-244:(a)Construction:Paragraph 2:Please explain whether
vegetation impacts were recalculated where the currently proposed route
-58-
[1.366]extends outside the corridor in which vegetation was originally mapped (e.g.,
(cont.)see Figure E.3.52).Quantification of potential increases in browse should be
based on eventual remapping of vegetation,succession models,and proposed
.vegetation studies.Such .quantification is needed to compare overall losses
and thus mitigation requirements for the project.
i'l'age E-3-245:(b)Operation:According to the project description in Exhibit
A,section 4.2{d),page A-4-6,a 25-foot wide access strip is to run along the
entire length of the corridor,lIexcept at areas such as major r-iver crossings ...-
and deep ravines where an access strip would not be utilized for the movement
of equipment and materia1s.11 Please clarify whether low shrub and tundra
types will be cleared within the access strip and the anticipated schedule for
maintaining that access.
[I.367
[r.368 ]
[1.369 ]
[1.370 ]
[I.371J
We recommend that the applicant consult with the eE,FWS and ADF&G in siting
of the proposed access strip to ensure that potential adverse impacts to
wetlands and fish streams are avoided.
During planning for the Intertie,the applicant assured the resource agencies
that all access for construction and maintenance would be by helicopter to
minimize the size of the area disturbed,length of time of disturbances,and
potential off-road vehicle (CRV)use.However,pressure from the public
utilities,who will eventually take over operation of the Intertie,resulted
in design changes allowing on-ground access.Thus we are concerned that
access plans for other segments of the transmission line not be similarly'
changed to the detriment of aquatic and terrestrial resources.
Page E-3-245:3.3.5 -Impacts to Wetlands:The app1 ication states that the'
estimates of wetland acreage to be impacted by the proposed project lIare
extremely liberal and all values should be considered preliminary.1I Acreage
data for more specific wetland types are needed.Evaluation of the project's
impact on those specific wetland types of special interest to the FWS cannot
be made with the generalized information that is now available (see comments
on Secton 3 •.2.3 -Wetlands).Thus,we reconmend that impacts from access and
transmission corridors not be assessed by applying the applicant's current
wetlands c1 ass;fi cati on by vegetation type system.
Page £-3-246:3.3.6 -Prioritization of Impact Issues:In order to quantify
project impacts over the 1ife of the project,further detail s are needed on
the anti c ipated 1ength of time for each impact di scussed here.
Page £-3-246:(a)Direct Loss of Vegetation:This section is repeated
verbatim from the November 15,1982 draft license application,thus,figures
given here do not reflect the latest routing or project design as reflected in
the accompanying tables.For example,Table E.3.83,shows direct vegetation
losses from the dam,impoundment,and spillway as 14,829 ha;Section
3.3.1 (a)(i),page E-3-225 lists those losses as 14,329 ha;yet.this section
cites a 12,667 ha loss.Similar inconsistencies are found in the Devil
Canyon,Access Roads,and Transmission Corridors summaries.
-59-
-
r.371]calculation of transmission line impacts.Inconsis'tencies between the
,cont.}description of access trails in Exhibit A~Sections 4.2(d),Section 3.3.4(b),
.and the applicant1sresponse to our question on the draft license application
that,"TranSmission corridor design has been revised and no longer'
incorporates a longitudinal access strip"(Chapter 11,W-3-l52)~should be
removE~d •
..372]
L.L.373]
Page [-3-248:.(b)Indi rect Loss of Vegetati on:The cumu1 ative impacts of
projec:t features described under the previous section and here should be
considered.Many identified losses will be in riparian habitat important to
wil d1 He species..
Page 1:-3-249:(c)(i)Downstream Floodplain:,Please refer to our previous
comments (Section 3.3.l{b)(iii))on the uncertainties underlying current
downstream analyses,particularly downstream of Talkeetna.We again recormnend
quant'ification of potential vegetation changes over the life of the project
for a variety of possible flow and ice scouring scenarios.
Page E-3-251:Ca)Item 3:Where information for determining the extent to
tL.374]which mitlgation will be achieved is unaYailab1e~requisite studies,including
,_monitoring~should be outlined and their implementation assured.
[.L.375]
,.376]
.377
~E-3-25l:Item 8:We are concerned that illustrations of mitig.ative
deSTgn features are minimal and generally limited to road construction without
specific data on the extent to which area materials will allow implementation
of the side-borrow or balanced cut..and-fill techniques.Location maps should
also be included for all mitigative design features.
~E-3-25l:(b):The FWS supports funding and implementation of mitigation
concurrently with project planning and construction.We are concerned that
'outlined mitigation studies are generally limited to planning studies with
some follow-up monitoring (Table E-3-l77).Provisions are lacking for
implementing measures that will be recommended through these study efforts.
Pl eas,e also see our comments on Table Eo 3.177 .
~agl E-3-252:Paragraph 1 to 4:We recommend that the Biological Stipulations
lnc uded with our comments as Attachment A be made conditions of the FERC
1 icense and incorporated in any project contracts and bidspeci fications;
With the exception of wetlands mitigation planning,we concur with the
mitiflation objectives and framework outlined here.As stated previously in
Sectiions 3.2.3·and 3.3.5,inadequate identification of wetlands means that
highE!r priority mitigation options to avoid and minimize impacts may no~.be
more difficult to incorporate in project planning.,.'
~
We believe that a mechanism and responsible parties should be identifi~d for
ensul"'ing that~"features of this mitigation plan will be correspondingly
refined with,respect to specific locations,procedures~and costs"as project
design and planning proceeds.
[1.378];age E-3-252:(a)Direct
or access orrow areas.
-
-60-
estimated area
(i )~(page
I
[Io 378]
(cant.)
[I.379']
.
[Io 380]
[Io 381]
[Io 382]
[Io 383]
E-3-265,paragraphs 2 and 4)borrow needs could run from 90 to 180 acres for
the Denali Highway-to-Watana road segment and from 50 to 100 acres for the
road between the Watana and Devil Canyon Dams.Potenti a1 borrow needs for the
railroad link,work pads,airstrips,and camps/villages are not clearly
identified,and the size of potential spoil disposal areas are not
quantified.Our specific comments on the five mitigation options follow under
Sections (i)through (v).
Pa es E-3-254 throu h E-3-275:eil Minimization:The discussion i~limited by"
the:inadequacy 0 wet ands mapP1ng see our comments on Sections 3.2.3
and 3.3.5),and (2)vegetation classification which cannot be usefully
integrated with the wildlife impact analyses and mitigation determinations.
Without these items,it is impossible to assess the adequacy of minimizing
impacts through siting •
Pa e E-3-254 Last Paragraph throu h Pa e E-3-256:Para ra h 2:We recommend
t at the proposed temporary airstr1p eS1ted so that 1t can ater be 'expanded
to become the permanent airstrip.This suggestion is compatible with the
app1icant 1 s recent request to fund a 2500-foot temporary airfield at the
Watana base camp which would subsequently be eXQan~ed to the 6000-foot
airfield necessary during project construction ~5/.
We also recommend consolidation of the Watana constuction camp,village,and
townsi te.We note these facll i ti es (.Exhibi t F,P1 ate F35)are spread out
compared to the Devil Canyon camp and village (Exibit F,Plate F70).·We also
note the Watana facilities are close to the environmentally sensitive ,Deadman
Creek area.Following remapping of wetlands,the siting of Watana facilities
should be reviewed.. ,
The purpose and scheduled use of the circular road system outlined in Exhibit
F,Plate F35,between the emergency spillway.Susitna River,and Tsusena Creek
should be explained.As we commented on the draft license application,we
have not had input into the decisions regarding the type,administration or
siting of the construction camp,vi11age,and townsite (Chapter 11,W-3-046).
We concur with the concept of common corridor routing for the Watana-to-Gold
Greek access and transmission corridors although the map scale represented in
Figures E.3.39 and E.3.40 makes it difficult to evaluate those project
features.Consultation with resource agencies during the on-ground planning
of detailed project design may indicate areas where winter movement of
construction equip'~ent and materials is preferable to prevent impacts in
biologically sensitive areas.Please refer to our preVious conments on access
for line maintenance,Section 3.3.4{b).
PageE-3-256:Paragraph 3:and Page £-3-258:Paragraph 2:Facility sitings
presently are located in low biomass areas.It is important that these areas
be not only economically advantageous to clear,but that such areas be of low
value to wildlife,as acknowledged on page E-3-260,paragraph 2.For example,
a low birch/mixed shrub area may be more important in providing moose forage,
particularly if cover is available nearby,than the higher biomass of a tall
alder area which provides cover but no food.
-61-
_.
~i
~,
:.384]
~
.385]
-
IX.386
-
~aragraPh 3 through Page £-3-258,and Pages £-3-260:Paragraph 4 through 262:
e relterate our recommendation to drop the Denali Highway-to-Watana access
segment because of big ga~e resource values described here,as well as'area
furbearer,raptor,and wetland values.Moreover,significant secondary
impacts of increased disturbance will result from.~he increased access allowed
by that route.P1 ease refer to our 1etters date.d.,August17,1982 and January
14,1983 to Eric P.You1d,APA.Eliminating the Denali Highway-to-Watana
access road is the design change with the greatest potential for mitigating -
access road impacts to wi1 d1 i fe.
Page £-3-258:Paragraph 1:Although the Wat~na-to-Devi1 Canyon transmission
~lccess routes share a common corridor,it does not appear that they have
adjal:ent or combined rights-of-way.Higher resolution mapping and field
verification should be used to·evaluate the viability of combining
rights-of-way to minimize adverse impacts.
P~ge E-3-256:Paragraphs 1 and 2 and Pages £-3-261 through 266:We concur
wlth the Objective of siting borrow areas adjacent to the access road and with
the recommended si de-borrow or ba1 anced cut-and ...fi 11 techni ques.These
methods will work only where suitable materials exist within the proposed
access corridor or when it is stipulated in project licensing requirements and
contractor specifications and then monitored throughout project development.
For side-bo'rrow construction,we reconmend that the project engineers work
with interagency monitoring team in the selection of temporary overburden and
topsoil stockpile locations.Schedules should be provided for use and
reclamation of access borrow and spoil areas.Borrow areas which would remain
open for maintenance of roads,workpads,or other facilities should also be
indicated.Necessary reclamation,whether simply recontouring,scarification,
and fertilization to promote reestablishment of native species,or seeding and
pos~jib1y sprigging of willows in moreerodab1e areas,should be detailed 'in
project reclamation plans and receive concurrence of the monitoring team.
SitE!preparation should be undertaken as soon as construction use of an area
is completed;seeding should be done by the first growing season after site
disturbance has been completed.Please refer to the Biological Stipulations
we have induded as Attachment A and our coments on Section 3.4.2{a}(.ii)
Rectification.
1,L.388]
rPagle £-3-263:Paragraph 4:This section should explain how the transmission
corridor 1n the Jack Long Creek area will be maintained since "temporary!1
~bridging of the creek will be accomplished for construction.We recommend
transportation of construction materials and equipment via helicopter in this
area to minimize potential disturbance,erosion,and loss of fish and wildlife
387]_habitats.
Please refer to·Attachment C,for additional recommendations.
Pfige E-3-264:Para~raph 1:We concur with realignments and improved siting of
t e railhead facillty to further minimize project impacts to furbearers,
eagles,and wetlands.The discussion should include how such siting will
mir,imize disturbances to big game.Until additional assessment data can be
inc:orporated into moose,black bear,and brown bear models,it is not possible
to compare habitat values of alternative locations.
~,
1.Settling ponds should be sized for gravel processing quantities,and
fines.38-61.
2.Generally,when half the capacity of settling ponds are filled with
silt,they should be cleaned out.
3.If the settleable fines are to be deposited between the flood pool's
high"and low water marks~they should be covered with.a rock blanket for
stab;lizati on.i
I "I
1I The 1ength of time and potenti al areas to be covered by any "temporary"spoil s
~isposals should be designated.
Page E-3-267 Last Paragraph through Page E-3-268:Paragraph 1:This section
should explain the proposal to deposit spoil above the 50-year flood level for
the Devil Canyon Reservoir.Werecorrmend that all disposal be within the
impoundment area and that vegetation slash be burned to preclude debris
accumulations in water entrainment systems.
[Io388]Ifarasraph 3:A road crown of 2 to"3 feet above original ground level may not
(cant •.l!..E:rovl de an adequate thennal bl anket in areas of penna frost.
Page 266:Paragraph 3 throu~h Page 268:We recommend that resource agency
concurrence be obtained durlng deta;led engineering design for final site
selection and procedures for spoil"disposal.Spoil should be annored with
rock.and/or gravel to stabilize the soils against wave action and prevent
sedimentation during reservoir drawdown.Spoil which may be unsuitable for
disposal because of cost~composition~or proposed construction schedules
should be identified.Settling ponds may be necessary in conjunction with
temporary construction berms or borrow pi ts.No spoil shoul d be pl aced upon
snow,even for "temporary disposal,and overburden should not be pushed onto
areas adjacent to roadways which cross tundra vegetation.I
J
1 Additional recommendations for settling ponds,should they be used in spoil
[r.389l-t disposal,follow:
I
~
fI.390)
[Io 391 ]Page E-3~268:Paragraph 3:Accurate wetlands maps should be used in
geotechn;cal alignment studies so that wetlands and ice-rich soils can be
avoided.Involvement of the environmental monitors should help further
minimize sitings or drainage crossings potentially detrimental to fish and
wildlife.~I
1iI.392]Pase E-3-26~:Paragraph 2:It is unclear what portion of the Anchorage to
Fa1rbanks transmission corridor to "be widened to accomodate an additional
single-tower right-of-way 190 feet (58 m)widell has been included in·the
previous vegetation assessment (Section 3.3.4(a)and Tables E.3.79,C3.80 and
E.3.86).The statement that this alignment "may depart from the previously
established corridor"substantiates our previous concerns that by nQt
evaluating the Intertie as an integral part of the Susitna project,Turther
impacts could result from later needs to upgrade the line.
-
-63-
:~
[,.1:..393]
-
,...
U .394]
[.395]
.396]
[1.397]
-
Page E-3-269:Paragraph 4:The referenced 69 kilovolt (kv)service
transmission line has not been previously mentioned and appears inconsistent
the ~itatement that diesel generators will be used to maintain the-camp and
village and construction activities (Exhibit A,Section 1.13(d)(i),page
A-1-4~7).Please clarify the purpose of this line,proposed right-of-way,
height of utility poles,distance of the centerline from.the access road,and·
connE~ctions at the Dena1 i Highway end.According to the APA,three
a1 tel'"nati ves are under consi derati on for supplying power during project
construction;(1)a 69kv service transmission line from Cantwe11 along the
Dena'i iHighway-to-Watana access route;(2)a transmi ssion 1ine from the
Intelrtie near Gold Creek along the railroad and access road which follow the
Susitna River;and (3)use of diesel generators (Thomas A.Arminski,APA
Deputy Project Manager,personal communications of September 30,1983).The
existence of those three alternatives should be described in detail in the
license application.We recommend that alternative (3)t diesel generation,be
used to avoid impacts of an additional transmission line.
Pages E-3-269 through E-3-274:The mitigative practices that are described
here should be part of Biological Stipulations included in project licensing
and contract bid specifications.Once the moose carrying capacity model and
more detailed vegetation mapping is completed,an analysis should be
undertaken of the potential to optimize browse production by additional
transmission line clearing or varying vegetation heights by changing
maintenance schedules within constraints of safe line operation.Follow-up
studies should be'initiated to confirm the value of expected browse
enhancement and aid planning and implementation of such vegetatio'1
mani pulat.i ons.
Pag:E-3-273:Paragraph 4:Potential policy conflicts should be identified in
conJunctlon with access road and transmission line siting studies.Agreements
with public and private landowners which provide for the mitigation detennined
necessary by the applicant should be confirmed prior to project licensing.
Unless such agreements are incorporated into the license,there is no
guarantee that mitigative managment policies will be adopted.The record on
nego,tiation settlement proceedings for the Terror Lake hydroelective project
now under construction by the app1 icant on Kodi ak Is1 and supports such careful
planning.
pagj!E-3-274:Para raph 4 and Pa e E-3-275:Para ra h 1:The text shoul d
exp aln:lnconslstenC1es etween these 19ures an those in Section
3.4.2(a);and (2)calculations of areas where vegetation removal will be
minimized.
Pfi9E!S E-3-275 throu h E-3-281{ii)Rectification:A preliminary assessment
s ou be made 0 vegetatlon cover type osses rom the standpoint of how long
each area will be disturbed.As reclamation and revegetation take effect and
disturbance by construction activJties decreases,some habitat values would be
expected to slowly increase.We agree that predictions of how plant
succ:ession will proceed on these lands over time are difficult to justify.
HOWE!Ver,we suggest that the information presented here,coupled with the
succ:essiona1 information presented earlier (Section 3.3.1(b)[i]and in Table
E.3.l441 will allow an assessment of the range of possible vegetation
-64-
[I:39 8 J
[I 397J restoration over time.The typical lO-year time frames within which each area
(~o t )will be completely out of production must be coupled with the up to 150 year
n •time spans necessary for'r~vegetation in order to thoroughly assess project
impacts.Although these losses may be IItemporaryU,they are significant
within the average life-spans of area wildlife.
Page E-3-276:Construction Camp:The text should clarify the double listing
for dismantling and redraining the 78 acres involved here.,
[1.399J
[1.400
[1.401 J
Page E-3-277:Borrow Area 0:It appears that an additional 70 acres should be
listed under the excavation and reclamation category for 1986.
Pages E-3-279 to 280:(iil Rectification:Refer to our Attachment A,
Biological Stipulations,additional references,and ongoing revegetation work
of the Alaska Plant Material Center for further guidance on site
restoration.
Individual site restoration plans should be developed with the concurrence of
the monitoring team.We recommend prompt site restoration (i.e.,site
preparation)upon concluding use of a construction site.This includes
recontouring,replacement of the organic mat/topsoil,fertilization,and
scarification and seeding and willow sprigging where necessary during the
first growing season following conclusion of construction activities at a
given si te..
We recommend tnat the resource agencies have the opportunity.to review and
conment on the reclamation plans at least one year prior·to construction.The
successful implementation of reclamation plans would be facil itiated by
limiting surface disturbances as the application has indicated.
An essential step to achieving reclamation will be to develop a monitoring
program which assigns monitoring responsibilities,and includes funding for
yearly operation and maintenance.The plans must include criteria for
measuring the relative successes of reclamation activities and a procedure for
implementing additional measures if initial reclamation objectives are not
achi eved.. .
,The text should clarify the process by which uslopes will be serrated.u
:>-
ages [-3-281 through E-3-282:(iii)Reduction:By itself,monitoring is not
mitigation.It should provide data on which to base mitigation
recommendations,impact evaluations,and assess mitigation effectiveness.
Monitoring can result in improvements to ongoing mitigation efforts,by
leading to modification or additions to measures already implemented.For
example,schedules for clearing to enhance browse production may be changed or
additional acreage acquired or manipulated for wildlife uses as a result of
monitoring findings.
We concur with the assessment of additional impacts on page E-3-281,last
paragraph.A mechanism for promptly implementing results of the monitoring
program is needed here.
-65-
.402]
.403]
,....
~.404]
~.405]
.....
[1.406J
,-
~'407]
r .408]
r.409J
Pages £-3-282 through £-3-285:eiv)Compensation:We support the chosen
option for compensation of vegetation losses.The incremental habitat values
gained from selecti\lely'altering vegetation or acquiring and/or managing lands
which would otherwise be developed or used represent a mitigation potential
which can be used as compensation.Please note that location,interspersion
with other vegetative cover types,and other habi'tat characteristies al so
affect the wildlife habitat values of potential''lreplacement lands.1I
Page £-3-283:Paragraph 4:and Page £-3-285:Paragraph 2:We certainly
support the efforts of the ADF&G,the Unlverslty of Alaska,and the APA,in
conjunction with the FWS,to develop lI a habitat-based model for moose carrying
capac:i ty based on moose bi oenergeti c requi rements and browse nutri ti anal
val UE:.n Unfortunately that program has been jeopardized by stop-work orders,
budget cutbacks,and study delays.While progress has recently been made in .
some of the necessary vegetation data collections,no interagency modeling
work has occurred since the workshop on February 28 to March 2,1983.We are
aware of no allocations within the state fiscal year 1984 project bUdget for
further model i ng work.38-8 I .
Pa~e £-3-284:pararraph 1:We have encouraged the Bureau of Land Management
to widen the time--rame \o/ithi n which they woul d undertake the prescribed burn
at tine Alphabet Hills site.This would increase the possibility of obtaining
suitiable weather,soils,etc.for burning.Specifically,we recommend that a
spring 1984 burn be lHldertaken.A spring burn would facilitate an assessment
of r1evegetati on and subsequent wil dl i fe uses.
age £-3-284:Paragraph'2:We support proposed vegetation mapping and
integration of that mapping with modeling efforts.
Please note that periodic maintenance should be an integral part of any
enhancement programs •
Page,s £-3-285 through £-3-289:(b)Indirect Loss of Vegetation:While we
appreciate efforts to describe areas SUbJect to erosion,blowdown,and other
vege~tation losses,it is impossible to fully assess replacement la.nds or
enhancement needs without some quantification of these cumulative impacts.We
suggest that i~pact areas be modeled.For example,information from Chapter 6
and this chapter should be used to measure the areal extent of each vegetation
type within the lO-mi1e reach near the headwaters of the Watana Reservoir.
;agE!E-3-286:.Paragraph 5:Please refer to our Attachment A,Biological
tipulations,I.Environmental Briefings,for further gUidelines..
Pagt!£-2-289:Paragraph 2:We recomnend that the APA detenni ne and pursue
agrl!ements on necessary regulatory options in coordination with Federal and
state resource management agencies as well as private landowners.
Pag1es £-3-289 through 291:ecl Alteration of Vegetation Types:Wetlands
mapping referred to in this section has not been initiated (see our comments
on Sections 3.2.3 and 3.3.5).Other than mitigative siting and a few general
construction practices outlined in Section.3.4.2(a)(i),w~find no spetific
examples here of measures for minimizing drainage alterations in wet
rC
[1.409]sedge-grass tundra as refered to on page E-3-259 t paragraph 3.As previously
(cont.)mentioned t we dOt however t agree with proposed procedures for mapping and
agency coordination.
We support plans for aerial and on-ground investigations to finalize
mitigative transmission corridor siting upon the assumptions that:(l)the
more detailed vegetation and wetlands mapping efforts will have been completed
and will be available for use t and (2)resource agency concurrence will be
obtained..
~I
-
[1.410 ]
[1.411]
Page £-3-290 Last Paragraph through"Page E-3-291:Paragraph 1:Reference to
moni tori ng and lIongoi ng studi es of moose t raptors t and other wil dl i fe by the
ADF&G and USFWS"is confusing.While we heartily endorse post-and
pre-construction monitoring and studies t and will continue raptor and ~wan
surveys within our funding constraints and legislative responsibilities t we
caution that responsibility for funding and implementing project impact
studies lies with the project sponsor.We will provide technical assistance
to the maximum extent possible.
Page £-3-291:Section 3.4.3 -Miti gation Summary:Thi s section 1acks a
comprehensive analysis of overall project irnpacts t potential for achieving
mitigation priorities t and tradeoffs among mitigation options for various area
resources.
~\
.....
[r.412]
Specific cooments on tables from the Botanical Resources Section follow:
Table E.3."49:The taxa t Papaver alboroseum t was withdrawn from consideration
as.a candidate threatened or endangered species (FR 45 t December 1S t 1980).
IT.413]Table E.3.51:The text should indicate whether the mesic sedge-grass
classification here and in Table £'3.71 and £.3.72 is the same as the
sedge-grass classification in Tables E.3.52 t E.3.77 t E.3.80 t and E.3.83
through E.3.86.
-
rr.414 ]
[I.415 ]
[1.416 ]
[1.417]
[Io 418 ]
Tables E.3.71 and E.3.72:There is an apparent inconsistency between the text
which says that 1%of the study area is open spruce and these tables which
show nearly 8%of the Watana Watershed and over 2%of the Gold Creek watershed
to be open spruce forests (Section 3.2.2(b)(i)t paragraph 1).
Table E.3.79:The vegetation classification is not directly comparable to
that used for other transmission line segments t Tables E.3.77 t E.3.78 t E.3.80 t
and E.3.86.
Table E.3.81:Please refer to our comments on the inadequacy of this
correlation t Section 3.2.3.
Table E.3.82:Please refer to our comments on the inaccuracies in wetland
typing which make this table meaningless t Sections 3.2.3 and 3.3.5.
Tables E.3.83 and E.3.84:Potential spoil areas outside of the impoundment or
already disturbed areas should be quantified here.
~-
-
r~.419]
-
r~·
-(.420]
Table E.3.86:Please refer to our comments under Section 3.3.4(a)regarding
cal cul ab on errors which apparently resul t in doub.1e counting of forest,
shrub II tundra,and unvegetated cover types.Mosaics of two or more vegetation
cover types may sometimespe the optimum mapping unit.However,no
explanation is provided for the four mosaic vegetation types included in this
table~but not in any other botanical resources _~a~1es or discussions.Where
Table E.3.86 refers to an adjustment of right-of~w~width,there is no
explanation of how that adjustment was made.I~appears that recalculation of
transmission line impacts on the basis of a 300-foot clearing width used in
Table E.3.86 as compared to the 400-foot 5lei'ging width used in McKendrick et
al.(982)was by a straight proportion.~J As the line is finalized
and a:ssuming vegetation is remapped in a manner more meaningful to wildlife,
the affected vegetation types should be recalculated.Quantification of
pbtential increases in browse should be possible on the basis of remapping,
succession models,and continuing vegetation studies.Such quantification is
needed to compare overall losses for a determination of mitigation
requirements.
ATTACHMENT C
Recommended Construction Metl10ds for Mitigating Impacts to Wetlands which
cannot be Avoided by Project Development
The first step in-outlining mitigation recommendations pertinent to activities
affecting wetlands-is to define IIwe tland.1I This has been descriptively done
in Chapter 3 of Exhibit E.However until the wetlands mapping proposed.and
conme!nted upon in Section 3.2.3,and 3.3.5 is completed,wetlands will not have
been defined geographically or in the field.Where wetlands are underlain by
l..E!!:mclfrost,constructi.on activities may need to be further altered.
The following is based on options outlined by the applicant in the
Suppllemental Submittal to FERC,Volume IIA of III.We are here prOViding
further infonnation and recommendations.
~(A)Construction methods in wetlands:
-
~.42]]:
'1.Clearing and construction should be undertaken when the ground is
frozen;access should be by ice roads.Excavated spoil should not be
wasted in wetlands.The workpads and access roads should be
consturcted so as to prevent thennal degradation while prOViding
structual integrity.
2.Hand clearing should be utilized to avoid scalping or removal of .the
vegetative mat.
3.Slash disposal in wetlands should be prohibited.
4.Fill material for roads or pads should be placed over the original
surface without stripping vegetation and organic layer.The
objective is to minimize·surface disturbance and prevent siltation of
wetl ands and wa terbodi es.
5.Geotechnical fabric should be utilized to minimize the need for
stripping,and reduce settlement of finished road surface.Fabric
use areas should be field staked so the fabric is not ripped up
during road maintenance of blading operations.
6.Wetlands should not be used for material or disposal sites.
-68-
[1.422]
(B)Techniques for minimizing alterations to wetland drainage patterns:
1.Hydrologic assess.ments of quantity,direction,and timing of surface
drainage should be conducted in the field in late spring/early summer
when flow patterns are readily visible.Culvert locations should be
staked,sketches made of culvert locations,elevations of culvert
inverts determined,and direction of water flow nuted and culvert
size detennined.
2.Sufficient numbers of culverts of adequate size should be installed
in the proper locations to prevent uphill ponding and downslope
dewatering,avoid erosion from lateral flow along embankments,and
minimize flow velocity and flow concentration in culverts.Areas
should be evaluated for any fish passage needs.Temporary culverts
(i .e.for--two years or 1ess)shoul d be desi gned to handl e a fi ve-year
flood event and pennanent culverts (ioe.to remain in use for more
than two years)should be designed to handle a 50-year flood event.
3.Install culverts with sufficient camber to prevent settlement.The
camber may also be dependent upon fish passage requirements.
4.Install culverts low enough to intercept sheet flow.The culverts
should maintain natural cross drainage patterns.Discharge should be
diffused to preclUde washing away of vegetative mat (of particular
importance in permafrost areas'to preclude thennokarst).
5.Install steam pipes in culverts where icing is likely to ·occur.The
stearnfitted uprights should be installed to provide access in snow
and ice conditions.Guide markers to the steam pipes will need to be
able to withstand the rigors of road maintenance.Maintenance will
need to be in accordance with a schedule..
6.After construction,monitoring will be necessary to determine if
additional or improved drainage structures are required.In addition
to assessing further mitigation construction practices,a monitoring
schedule for maintenance of fish passage effectiveness should be
developed.
~l
~.
-(C)Additional recommendations
wetlands are:-
1.Any placement of fills
the stream flow.
for mitigating impacts of road construction on
in a watercourse should be perpendicular to
[1.423]
2.Roads.should be maintained in a crowned configuration and maintenance
activities should be accomplished so as to prevent material being
pushed into drainages,blocked culverts,or roadside benns along the
dri vi ng surface."
3.Road fills at fish streams less than 50 feet wide should not exceed a
30-foot top width through the stream crossing.
4.There should be no storage of fuel in floodplains or wetlands.
5.Refueling and equipment servicing should be restricted to gravel fill'
areas and confined to preclUde any product from reaching wetlands.
-
-(0)Celse by case exemption to the above recommendations may be granted by the
~.424]interagency monitoring team.
-
-
-
Chapter 3,Section 3 Footnotes
38-1/McKendrick,J.W.Collins,D.Helm,J.McMullen and J.Koranda.
1982.Susitna Hydre1ectric Project,Phase 1 Final Report,
Environmental Studies,Subtask 7.12:Plant Ecology Studies.
University of Alaska Agricultural Experiment Station,Palmer.
Prepared for the APA.
1
38 -2 /Viereck,L.A.,T.T.Dyrness and A.R.Batten.1982.Revision of
Preliminary Classification for Vegetation of Alaska.Unpublished
Report from Workshop December 24,1981,Anchorage.Workshop on
Classification of Alaskan Vegetat~on:77 pp.
38-3/Cowardin,L.M.,V.Carter,F.C.Go1et and E.T.LaRoe.1979.
Classification of Wetlands and Deep Water Habitats of the United
States.Publication FWS/OBS-79-31.U.S.FWS.
38-4/See Footnote 3B-3,supra.
OffiCe of Environment,Office of the'Federal Inspector.1981.
Revegetation Philosophy for the Proposed Gas1ine.June 26,1981.
Anchorage,Alaska.3 page mimeo.
Kubanis,S.A.1982.Reveg~tation Techniques in Arctic and Subarctic
Environments.Office of the Federal Inspector,Alaska Natural Gas
Transportation System,Office of Environment,Biological Programs.
Anchorage,Alaska.40 pp.
38-5/Construction of Temporary Airfield at Watana.Appendix 4 to Agenda
Item IV,Acti on Item No.1,prepared for the APA Board of Di rectors.
38-6/U.S.Forest Service.Guidelines for Reducing Sediment in P1 acer
Hi ning Wastewater.No date,avail abl e from Al aska Resources Library,
Anchorage,Alaska.31 pp .
•
38-7/Office of Environment,Office of the Federal Inspector.1981.
Revegetation Philosophy for the Proposed Gasline.June 26,1981.
Anchorage,Alaska.3 page mimeo.
38-8/APA.September 8,1983.Appendices 2 and 3 to Agenda Item IV,
Action Item No.1.FY 1983 Program Changes and Their Impact on the FY
1984 Program and Current Proposed FY 1984 Budget ~locations Susitna
f1ydroe1ectric Project.Prepared for the APA Board of Directors.
3B-9/See Footnote 38-8,supra.
-70-
""
-r 2.
[I.428]
[1.425
[I.426]-
[1.427]
ATTACHMENT A
Biological Stipulations
By incorporating the Environmental Guidelines af Appendix E3.B,Chapter 3,
Exhibit E of the draft Susitna Hydroelectric Project Federal Energy Regulatory
Commission (FERC)License Application with other stipulations applicable to
Alaska construction projects,a set of project stipulations has been
compiled.It is our recol1'lllendation that these stipulations be incorporated
into the FERC license as a binding exhibit.They should then become part of
project contracting agreements.
Preamble
Implementation of these stipulations are appropriate during the construction,
operation and maintenance,and tennination/of the Susitna Hydroelectric
Project.Sound engineering practices shall be employed to preserve and
protect fish and wildlife resources and their habitats.
The Licensee,through guidance and direction to the Designer.Engineer and
construction Contractor.sha"l1 balance environmental amenities and values with
economic considerations and technical capabilities to be consistent with State
and National policies.This evaluation shall include benefits or detriments
to people,property and environmental resources which may result from a course
of conduct.
I.Environmental Briefings
1.The Licensee shall develop,"in consul tati on wi th concerned resource
agencies,and provide environmental briefings for all supervisory and
field personnel directly related to the project either prior to the
commencement of construction or during new hire orientations.
2.The Environmental Briefings Program shall famil iarize project
personnel with environmentally sensitive features of the project
area,Federal and State regulations,agency permit stipulations,and
specific project policies and restrictions regarding protection of
vegetation,fish,wildlife,and cultural resources.The
"Environmental Briefings Program shall be combined with the project
Safety Program and involve continUing updates and reviews through
regularly scheduled weekly meetings.The Environmental Briefings
Program shall be positive and informative in nature and use visual
aids to stimulate interest.The program shall strive to explain why
a certain feature or organism is vulnerable to disturbance.and
therefore why protective measures are needed in each case.
Pollution Control
1.The Licensee shall construct,operate,maintain and terminate the
project in a manner which adheres to all State and Federal air,land
and water quality standards,laws and regulations relating to
pollution control or prevention.
The liqUid waste treatment system shall be operated by State of
Alaska accredited personnel.Grey water must be treated along with
-
~,
-
rIo 4 34 ]8:
c~
9.
.435]r
,PI:"'"
10.
l.t.436)-
flo 437]111--
[,I,.428]
cant.}
r;r...429 ]
[-.430]
,~
1.431 ]
1.432 ]
[1.433]
other liquid wastes.A regular effluent sampling and testing program
shall be followed to ensure compliance with National Pollutant
Oischarge Elimination System (NPDES)and State of Alaska Wastewater
Oisposal Standards (18 AAC 72).Effluent .testing shall be conducted
by a State of Alaska certified water quality laboratory.Effluent
discharge to streams shall be located --t;o·,achieve .maximum dilution •
.-.-
3.Mobile ground equi pment shall not be operated in wetl ands and/or
other bodies of water.
4.The temperature ranges of natural surface or ground waters,as
determined by pre-project baseline studies,shall not be changed by
the project or any construction related activities.
5.The Licensee shall use only non-persistent and inunobi1e types of
pesticides,herbicides and other chemicals.Each chemical,including
any fuels and oils,to be used in project construction,operations
and maintenence,its storage,applications and clean-up shall be
addressed in the project Oil and Hazardous Substances Control pl an
prior to the arrival of such substances and chemicals on site.
6.All hazardous substances utilized and wastes generated in
construction,operation,maintenance and termination of the project
shall be removed or otherwise disposed of in accordance with State
and Federal standards,rules,and regu1 ati ons.
7..Solid waste disposal sites shall be established in stable,
well-drained locations.Siting shall utilize existing excavations
such as depleted upland borrow pits.Intermittent drainages,
ice-rich soils,or other erosion-susceptible features shall not be
used.Deposited material-shall be covered daily with non-silty
excavation spoil stockpiled for this purpose at the site.Solid
waste disposal site design and operation shall conform with
guidelines established by the Alaska Department of Environmental
Conservati on.
Incinerators for the daily burning of putrescible and combustible
wastes must beat each camp location and be in operating condition
before construction camps are occupied.
To minimize scavenging by birds and mammals,with resultant adverse
contacts between people and animals,all putrescible kitchen waste
shall be stored indoors in sealed containers and incinerated on the
same day they are produced.
Camp incinerators shall be properly sized and operated by trained
personnel to ensure that all putrescible wastes are completely burned
to mineral ash.Incinerator capacity shall be carefully specified to
accommodate peak camp occupancy.
Camp perimeters and inCinerators.shall be protected with
animal-resistant fencing designed and built to specifications
provided by the environmental consultant and subject to State and
Federal resource agency review and approval.
-72-
1.438
TIL
12.Open burn pits for the disposal of putrescib1e waste shall not be
used.
Buffer Strips
1.439
1.440
1.441
1.442
1.443
.I
1.Unless detennined on a site specific permitted basis that a wider
buffer strip is warranted a SaO-foot minimum width buffer of
undisturbed vegetation shall be maintained between a facility and any'·
stream,lake,or wetland.
2.Undisturbed buffer strips at least 500 feet wide will be maintained
between borrow areas,disposal sites and other project appurtenances
and any.State of Alaska Department of Transportation and Public
Facility (ADOT/PF)highway and/or Alaska Railway.Buffer strips
wider than 500 feet may be reqUired on a site specific pe~itted
basis.
3.A minimum distance of 1/2 mile shall be maintained between any
facility and the following:
Fish spawning area;
Bald eagle nest;
Golden eagle nest;
Bear den;,
Wo1 f den;
Da11 sheep lambing area;and
Mineral lick
Erosion and Sedimentation Control
1 ~The design of the project shall provide for the control of erosion
and sediment prOduction,transport and deposit in accordance with
State of Alaska "Water Quality Standards".
2.Erosion control measures,inclUding the use of erosion control
structures shall be implemented on the project to limit induced and
accelerated erosion,limit sediment production and transport and
limit the fonmltion of new drainage channels.The design of such
measures shall be based on the rainfall and snowmelt combination
characteristic of the region,the effects of thawing produced by
flowing or ponded water on permafrost and the effects of ice.
Permanent erosion control structures shall be designed to accommodate
a 50-year flood.
3.Specific erosion control methodologies shall be delineated within a
project Erosion Control Plan developed by the Licensee that shall be
approved by concerned State and Federal agencies prior to initial
construction activities.The approved project Erosion Control Plan
.shall be incorporated into project technical specifications by
reference.
4.If otherwise permitted,crossings of wetlands,other bodies of water,
and active (25-year flood event)floodplains shall neither cause nor
result in erosion and/or sedimentation in excess of the State of
~-
~i
l.L.443]
(cont.)
.~
:444]
;.:.445]
:.446]
.448J
~.
Alaska "Water Quality Standards."Temporary access over stream banks
shall be made through use of fill ramps rather then by cutting
through streambanks.Such ramps shall be removed upon termination of
seasonal and/or final use and disposed of in accordance with the
project Erosion Control Plan.
+-..-
s.Excavated material in excess of the amounts required for backfilling
and restoration shall be disposed in a manner as delineated in the -
project Erosion Control Pl an.
6.Excavated materials shall not be stockpiled in wetlands or in other
bodies of water.
7.Overburden and excavated materials from the construction of access
roads shall not be side caston road side slopes exceeding a grade of
10 percent.
8.Where gravel pads must be used,prOV1Slon for cross-drainage shall be
made to prevent impoundment of sheet flow.
9.Facility siting shall not be located in thaw susceptible areas
(discontinuous permafrost zones)capable of slumping or thermal
erosion.
v.Fish and Wildlife Protection
A.449]
!!.450]
""".451 ]
.0;.452]
-
1.·All project associated pers~mnel.shall be governed by appro.prhte
State and Federal rules and regulations pertaining to fish and
wi 1dli fe resources;such rul es and regu1 ati ons shall be incorporated
into project technical specifications by reference.
2.A condition of employment for all project personnel will be inmediate
termination with no chance of rehire on the project for violating
said rules and regulations.
3.The Licensee shall design,construct,operate,maintain,and
terminate the project in a manner to assure free passage and movement
of fish.Temporary blockages of fish,not to exceed 24 hours in a
calendar week,necessitated by instream activities,may be allowed
provided the proposed design and construction plans include the times
and places such temporary blockages may occur.
4.Pump intakes shall be screened to prevent harm to fish.Screening
requirements as provided by the Alaska Department of Fish and Game
(ADF&G)shall be incorporated into project design.
5.When abandoned,water di version structures shall be removed or
plugged at both ends and stabilized.
6.The Licensee shall not disturb fish spawning beds,fish rearing areas
and overwintering areas.Where disturbances are included in project
design,proposed modifications and mitigation measures shall be
included as a portion of the project bidding documents..
[I.452 ]
(cont.)
[1.4 ~3 J
[r.-454 ]
[1.455]
[1.456]
[1.457J
[1.458]
[I.459]
7.The Licensee,in accord with State of Alaska "Water Quality
Standards,U shall protect fish spawning beds,fish rearing areas and
overwintering areas from sedimentation and/or siltation resulting
from construction activities.Settling basins or other sediment
control structures,as included in the project Erosion Control Plan,
shall be constructed and maintained to intercept such sediments and .
silts before they reach designated areas.
8.The Licensee shall not take water from fish spawning beds,fish
rearing areas and overwintering areas of waters that directly
replenish those areas during the critical periods as identified by
ADF&G.
-g:-The Licensee shall design the project to accommodate the times and
areas of fish and wildlife breeding,nesting,spawning,rearing,
lambing,calving,overwintering,denning and migrating.State and
Federal resource managing agencies shall review and approve the fish
and wildlife periodicity charts as prepared by the Licensee to be
used in co'nstruction-related scheduling.
10.The Licensee shall design,construct and maintain the project to
assure free passage and movement of big game animals.
11.Project construction and operation activities shall be planned and
scheduled to not disturb fish streams.Where activities affecting
fish streams cannot be avoided (e.g.,construction of stream
crossings),activities shall be scheduled.for periods when fish~re,
not present.Where stream crossings are planned for winter .
construction,the thalweg,banks,and other 10cationa1 features shall
be identified and staked.in the field prior to snowfall or freeze-up.
VI.Acquisition and Disposition of Materials
1.The Licensee shall make application to the United States for the
purchase of mineral materials on Federal lands in accordance with 43
CFR Part 3610 and shall submit a mining plan in accordance with 43
CFR Part 23.No materials,regardless of land ownership,may be
removed by the Licensee until a given mining plan is reviewed and
approved by concerned resource managing agencies.
)
2.Material site boundaries and mining techniques shall blend with
surrounding natural land patterns.Regardless of the layout of
material sites.primary emphasis shall be placed on the prevention of
soil erosion,the preclusion of damage to vegetation,and the
protection of fish and wildlife habitat.
3.The Licensee shall make application to the United States for the
purchase of merchantable timber on Federal lands in accordance with
43 CFR Part 5400.
4.Design shall minimize gravel requirements by avoiding wet areas or
pennafrost zones,conso1 i dati n9 structures,and bal ancing cuts and
fi 11 s.
-75-
-
~,
....
,....,
P 460]
-
-q 461]
lI.462]......
Q 463]
'5.A detai 1ed,site-specific mi ni ng pl an shall be prepared for each
borrow operation.Design shall be an interdisciplinary team effort
involving civil~ngineers and environmental specialists experienced
in design,construction,and permit requirements.Mining plans,as a
minimum,shall include all roads,facilities,mining techniques,
schedules,rehabilitation procedures,the kind or type of borrow
material and quantities expected to be mined.
6.Dependent upon material quality and availability,borrow areas
required for dam and ancillary facility construction shall be sited
.in the future impoundment area of the dam under co~struction.
7.Siting of borrow areas outside the impoundment zone shall place first
priority on well-drained upland locations.Second priority
consideration shall be given to first-level terrace sites.Active
floodplain and streambed sites shall not be used unless they are
within the impoundment area of the dam under construction.
Stockpiling within active floodplains shall be prohibited.
Floodplain gravel mining shall follow the guidelines set forth in the
U.S.Fish and Wildlife Service "Gravel Removal Guidelines Manual for
Arctic and Subarctic Floodplains,1I 1980.
8..All material sites shall be developed in phases by aliquots as
presented in the site specific mining plan.The phases shall be
pri ori tized to save unti 1 1ast those porti ons of the si te whi ch are
more sensitive from an environmental standpoint.
9.Fjrst-level terrace sites outside the impoundment zone shall be
located on the inactive side of the floodplain and mined by pit
excavation rather than by.shallow scraping.Excavations shall be
separated from the active (2S-year flood event)floodplain by a
SOD-foot buffer of undisturbed,vegetated terrain.
10.Excavation spoil shall be disposed of in the future impoundment area
of the dam under construction,or spoil shall be used in the
rehabilitation of depleted or non-operational material sites,or for
solid waste disposal site maintenance.Spoil retained for these
.applications shall be stockpiled in stable,well-drained locations,
and benned to contain runoff.Spoil shall not be placed upon snow,
even for temporary disposal.
11.Abandoned access roads,camp pads,aAd airstrips shall be used
wherever feas.ible as material sources for operation in lieu of
expanding existing sites or initiating new ones.Where riprap is
required,material produced during excavation of the powerhouse,
galleries,and tunnels shall be used.
Clearing
1.The Licensee shall identify clearing boundaries on the ground for
approval by State and Federal resource managing agencies prior to
initiating clearing operations.All timber and other vegetative
material outside clearing boundaries and all blazed,painted or
posted trees which are on or mark clearing boundaries are reserved
from cutting and removal with the exception of danger trees or snags.
[Io 464]---I
(cont.)
[Io 465
[Io 466 ]
[Io467]
2.All trees,snags and other wood material cut in connection with
clearing operations shall be cut so that resulting stumps shall not
be higher than sjx (6)inches measured from the ground on the uphill
side.
3.All trees,snags and other wood material cut in connection with
clearing operations shall be felled into the area within the clearing
boundaries and away fram water courses.
4.All debris resulting from clearing operations and construction that
may olock streamflow,delay fish passage,contribute to flood damage,
or result i~streambed scour or erosion shall be removed immediately.
5.All slash shall be disposed of in construction pads or roads as
directed by the Engineer.Slash shall be disposed of prior to the
end of t~e first winter after cutting.
6.Disposal of vegetation,non-merchantab1e timber,overburden and other
materials removed during clearing operations shall be in accordance
with the project Erosion Control Plan.
7.Siting shall minimize requirements for clearing removal of vegetation.
8.Where removal of vegetation is required,organic overburden shall be
segregated and stockpiled for use in subsequent rehabilitation.
Stockpiles shall be placed in well-drained locations and bermed to
contain runoff.Dep1 eted orn.on-operati ona1 borrow pi ts shall be
used as overburden storage areas.
9.Structures shall be consolidated to disturb the minimum necessary
area of ground surface.
0;sturbance or Use of Natural Waters
1.All activities of the Licensee in connection with the project that
may create new lakes,drain ~xisting lakes,significantly divert
natural drainages and surface runoff,permanently alter streams or
groundwater hydrology-,or disturb areas of streambeds are prohi bi ted
unless such activities along with mitigation measures.are reviewed
and approved by State and Federal resource managing agencies.
2.Wells shall be established for potable water withdrawal.If wells
are not feasible at a given location,water shall be withdrawn from
lakes.Streams shall be considered only as a last resort,and only
after determination is made on a case-by-case basis that fish or
wildlife will not be adversely affected by water withdrawal,
particularly during overwintering and reproductive periods.Intake
structures shall be designed to preclude entrapment or entrainment of
fish eggs and small fish.
3.If wet processing i.s required for borrow material,water withdrawal
and discharge locations shall be sited to preclude fish and wildlife
disturbance.Drawdown in overwintering pools used by fish or aquatic
mammals and any disturbance to spawning areas must be avoided.Water
~,
-
-.471 ~-l
U;.467]
,cont.)
-
-
[1.468]
l .469]
.~
[1.4 70
intake structures shall be designed to preclude entrapment or
entrainment of fish eggs and small fish'.Gravel washing shall employ
recycl ed water.If pi t dewateri ng is requi red because of pondi ng or ..'-
wet processing,settling ponds shall be designed,operated,and
monitored to ensure that NPOES standards.for discharge are achieved.,
Settli n9 ponds shall be designed and -~.it~d to avo;d fi sh entrapment.
Water di scharge shall be di rected ina manner that will precl ude
erosion.Energy dissipators shall be used.
-rx.Off Right-of-Way Traffic
11.The Licensee shal1 not operate mobil e ground equi pment off the
ri ght-of-way,roads or authori zed areas except as necessary to
prevent immediate harm to any person or property.
FX:-Use of Explosives
1.No bl asting shall be done under water or withi n one quarter (1/4)
mile of streams or other bodies of water with identified fish and
~ildlife resources.
2.Blasting shall avoid times and locations which are sensitive to fish
and wildlife.These times and locations shall be determined on a
case-by-case basis by the environmental consultant and in accordance
with State and Federal resource agency guidelines.Proper sizing and
sequencing of blasting charges can minimize fish and wildlife
.impacts.Streamside excavation shall not be done by blasting •
Blasting procedures and schedules must be sufficiently flexible to
allow alteration at short-notice for the protection of wildlife.
ADF&G blasting guidelines shall be followed.
T Restoration
1.Speci fi c restorati on and revegetation methodologies shall be
delineated within a project Restoration/Revegetation Plan that shall
be approved by concerned State and Federal agencies prior to initial
construction activities.The approved Restoration/Revegetation Plan
shall be incorporated into project technical specifications,by
reference.
---.Z.Upon completion of use,the Licensee shall restore all lands
disturbed by project activities in accordance with the
Restoration/Revegetation Plan.
3.Restoration includes erosion and.sediment control.revegetation,
re-establishment of native species and stabilization.All disturbed
areas shall be'left in such stabilized condition that erosion will be
controlled through such means as waterbars,berms,ditching,
revegetation,and other techniques included in the Erosion Control
and Restorati on/Revegetati on Plans.Cul verts and bri dges shall be
removed and slopes shall be restored.
4.Revegetation of di sturbed areas shall be acco-mpl i shed in accordance
with the Restoration/Revegetation Plan and approved schedules.The.....
-78-
[Io473]
[I.471]~-p'arameters to determine the success of revegetation shall be included
(cont.)L-ln the plan.'.
[I.472]5..The Licensee shall dispose of all materials from roads,haul ramps.
berms.dikes and other earthen structures in accordance with the
project Restoration/Revegetation Plan.
6.Pending the restoration/revegetation of a disturbed area,the
Licensee shall contour grade and stabilize each area prior to the end
of the growing season and/or prior to the onset of the freezing
season immediately following the time of disturbance.
[I.474]
[Io475]
[Io476]
[Io 4 77]
[Io 478]
[Io479]
7.Upon completion of restoration/revegetation of an area.the Licensee
shall remove all equipment and material from the area in accordance
with approved plans.
8.Slopes shall incorporate a diversity of contours created during
actual excavation,rather than during restoration.
9.Where pond~ng will occur,as in first-level terrace sites.irregular
boundaries and slope contours shall be accentuated.Islands of
undisturbed vegetated terrain shall be left within the perimeter of
the operational site.
10.Organic·overburden,slash,and debris stockpiled during clearing .
shall be distributed over the excavated area prior to fertilization...
n.Once operational material sites are depleted or no longer required,
"they shall be rehabilitated by the end of the next grOWing season
following last use.
12.Erosion-prone slopes shall be fertilized and dry seeded with a
fast-growing native grass.
~.
XII.Oil and Hazardous Substances
[Io 480]
1.The Licensee shall submit an oil and hazardous substance control,
cleanup and disposal plan that shall be approved by concerned State
and Federal agencies prior to initial construction activities.The
approved Oil and Hazardous Substances Plan shall be incorporated into
project technical specifications by reference.Asa minimum the plan
shall address fuel distribution systems,storage and containment,
containerized products,leak detection systems.handling procedures.
training programs.provisions for collection,st1rage and ultimate
disposal of waste oil.cleanup methods and disposal sites.The plan
shall outline all areas where oil and/or hazardous substances are
stored.utilized.transported.or distributed.The Licensee shall
demonstrate its capability and readiness to execute the plan to the
satisfaction of the Engineer and concerned State and Federal agencies.
2.Storage containers for fuels and hazardous substances shall be
located at least 1.500 feet from water bodies and bermed to containnopercentofthemaximumvolumeto.be stored.Containment areas
shall be lined with impervious material..
~.480]~3.
,cont.)L
rnI
The Licensee shall update the plan and methods of implementation as
appropriate,but at least annually will submit a revised plan to the
Engineer and concerned State and Federal agencies for approval.
Cultural Resources
.
:.481]
-
1•The L;censee shall undertake the aff;nriatfve respons i bi 1i ty to
identify.protect and preserve cultural.historic.prehistoric and
archeological resources that may be impacted by related activities in,
the overall construction project on lands consistent with the
National Historic Preservation Act of 1966.as amended.16 U.S.C.
470.et seq.the Archeological and Historic Preservation Act of 1974.
16 U.S.C.469.etseq ••and the implementing procedures of the
Advisory Council on Historic Preservation.36 CFR Part 800.
-xiV.Standards for Roads
'I.The Licensee shall submit a layout of each proposed road for approval
by the resource agencies and the Engineer.As a minimum.the layout
shall include areas of fills and cuts,the locations of culverts.
bridges and low water crossings.spoil disposal.dimensions and
roadside ditching necessary for runoff water control.
2.The ma,ximum allowable grade shall be 12 percent.
3.Maintenance grading of road surfaces shall be done in such a manner
that berms of material left on the road shoulder wi.1l not cause
surface runoff water to flow parallel to the road"alignment.
4.Road design shall provide for runoff drainage on the road surface to
be perpendicular to the road alignment.
5.Maintenance grading shall be done in a manner that cross drainage
culverts and side ditches will not be blocked with road material.
Drainage ditches and culverts shall be inspected weekly and cleaned'
out as needed during the seasons of surface grading and snow removal.
6.Road design speeds shall be kept to the minimum consistent with
project requirements and shall not exceed 40 miles per hour.Lower
design speeds allow greater flexibility for alignment adjustments to
avoid environmentally sensitive features and reduce requirements for
major road cuts.Lower design speeds also enable routing to follow
higher.drier terrain.thereby reducing requirements for gravel
extraction and fill placement in wetlands.A 40-mile-per-hour design
speed will increase road safety and enhance recreational resource
potential.
7.Routes shall avoid wetTand and riparian areas,and minimize stream
crossings and encroachments.
8.Road,design shall keep gravel extraction requirements to a minimum by
avoiding wet areas and emphasizing balanced cut and fill.
-80-
[I.483]
[Ie 484]
9.Where stream crossings cannot be avoided,they shall be aligned at
right angles to the stream and located to preclude bank cutting and
streambed disturbance.Fish spawning and overwintering areas within
streams shall be·avoided by route adjustments.
10.Where stream crossings are planned for winter construction,the
thalweg,banks,and other 10cationa1 features shall be identified and
staked in the field prior to snowfall or freeze-up.Overwintering .
areas of fish or aquatic mammals must not be disturbed during winter·
construction.
11.All access roads not required for project operation or recreational
purposes,shall be "pu t to bed"as soon as they are no Tonger
required,if possible during the same season.Drainage structures
shall be removed and the roadbed recontoured to a stable
configuration providing proper drainage.Rehabilitation shall
include scarification,fertilization,and blockage with a berm
followed by a cut.Erosion-prone locations shall be stabilized by
contour grading,water control structures or seeding with
fast-growing native species.Where impoundment of sheet flow has
occurred,non-operational roads shall be structurally altered to
restore normal flow.
12 •.Road dust control shall util ize water rather than oi 1 or other
synthetic compounds.Water withdrawal procedures and sources for
dust control shall be approved on a case-by-case basis by
environmental personnel following site~specific inspection.
Culverts,Bridges,Low Water Crossings
1.Low water crossings (fords across moving waters where any mobile
ground equipment is moved on the water course)shall be designed,
constructed,maintained and restored to standards contained in the
project Erosion Control Plan.
'-2.Culverts and bridges necessary for operation and maintenance of the
project shall be designed at a minimum to accommodate a 50-year flood
in accordance with criteria established by the American Association
of State Highway Officials and the Federal Highway Administration and
endorsed by the ADOT/PF.
3.Culverts necessary for construction or operation of the project shall
be installed with the culvert invert a minimum of six (6)inches or
20 percent of the culvert diameter,whichever is·greater,below the
thalweg in fish streams.
4.All bridge abutments and culvert inlets and outlets will be
rip-rapped or armored at the time of installation.
5.Culverts installed in fish streams shall be designed to provide fish
passage at the Q2 flood,with the following parameters:
a)No fish passage culvert shall exceed 100 feet in total length.
-81-
b)Maximum average allowable velocity of water flow through a fish
passage culvert shall not exceed 4.52 feet per second for
culverts up to 40 feet in length.Additional data not to be
exceeded are:
Ave.Velocity (FPS)
Cul vert Length (Ft)
[1.484
r-:cont.)
4.0
3.6
3.3
3.0
2.8
2.5
50
60
70
80
90
100
[.;t.4 8.S ]
:.486 ]
-
[1.487 ]
6.All culverts installed in fish streams shall'be inspected and
maintained to allow fish passage in accordance with the design
specifications above.The inspection and maintenance schedule shall
be subject to approval by ADF&G.
7.Bridges shall be installed in preference to culverts or low-water
crossings (fords).Bridge supports shall be located outside of
active chann~ls.
8.Low-water crossings shall be used only where a stream will not be
subject;to construction traffic.Such crossings shall conform to the
slope of the:undisturbed streambed and shall be constructed·of
materials that will preclUde water percolating through rather than
over them.
X Transmission Corridors
1.Where they are not adjacent to an existing road,transmission
corridors shall be constructed by helicopter support to avoid
unnecessary clearing of vegetation.In all locations where clearing
is not required for access,winter construction or access shall not
cOll11lence until a frost ,depth of six inches (6")has occurred and
vehicles not exceeding four (4)psi shall be used.Transmission
corridor development shall not create an alternate access route for
all-terrain vehicles.
2.Transmission line additions shall be made adjacent to established
transmission corridors.Where transmission lines have a common
destination,they shall follow a common route.
3.Transmission towers shall not be placed in active floodplains and
shall avoi d streams and·l akes by a mi nimum of 500 feet.
4.Herbicides shall not be used for vegetation control along
transmission corridors.
5.Transmission corridors not adjacent to an existing road or railway
shall follow the forest edge (i .e.,the transition zone between
forest and shrub or forest and tundra)and avoid crossing wetlands.
0.,
1.488 XVII Implementation
1.Nothing contained in the preamble and body of ·stipulations shall
prohibit the Licensee from applying for a waiver or modification to
any stipulation on a site specific,case-by-case basis.Such
application shall be submitted in writing to the concerned State and
Federal resource managing agencies for review and action.
1.489 -see entire Attachment A -pgs.71-82
~'
~I
ATTACHMENT B 'Agricu!lura!Experiment Station
Palmer Research Center
.Box AE
Palmer.Aioska 99645
!""I .
-
.....
UNIVERSITY OF ALASKA
January 24,1983
Dr.Robin G.B.Sener
SUS"j tna Program f1anager
Wildlife &Botanical Resources
lGL Alaska Research Associates,Inc.
1577 C Street
Anchorage,Alaska 99501
Dear Robin:
Attached are bJO lists of data,\'lith brief descri"ptions,available on
the:Susitna drainage.This was prepared in response to our telephone
conversation of December 16,1982,when we were concerned about data
being forgotten.The first list summariles 'data that the Alaska Power
Authority has funded to at least some degree.The second list summarizes
.Susitna drainage data collected by other projects and incomplete data
\'lhE~re the field sampling \'J8S funded by the Power Authority.In some
cases,samples need to be ~round ~have laboratory analysis ,performed
but in other cases the data only need to be analyzed statistically.
ThE!descriptions of old studies \oJere not meant to be detailed,but
rather to make peopl e aware of the depth of data coll ected in the past.
One thing becomes apparent from these lists:There is an enormous
amount of vegetation data and smaller amounts of soils data and 5011s-
vegetation data that could be available if we had funds and time to
analyze and integrate the data.Even though some of the data may not be
exactly what is needed now,the data could certainly be used as a foundation
for future experimental design,assessing impacts,and making revegetation
recommendations.The wheel's-already been invented a couple times;
maybe these lists \'Iil1 help produce a better wheel in the future .
Si ncerely,
Dot Helm
Plant Synecologist
CrC:Richard Fleming,Alaska Power Authority
-Q 1._
study__._._~.Loca ti on
1980 Plant Ecology
1980 USF~
SCS
Plant Ecology
'..
~getation mapping
~getation inventory
.Middle,upper basin
Middle,upper basin
Year Who Field Funding
Susitna
Cooperative River
Basin Study
Status
Vegetation means in annual rer
(variances calculated,not
reported)
Maps of vegetation,potential
lands produced
Some vegetation (timber)arlal:
other (understory)being
processed;not sure about Sl
Some soil &vegetation sample
collected
ownstream succession Delta Is.-Chase
'{.
1981 Plant Ecology Susitna Vegetation means in annual re
(variances calculated,not
reported)I
Sol1 s collected
1980 Plant Ecology Partly Susitna
1981 Plant Ecology Susitna
ertilizer trials Watana Base Camp
e1icopter transects Delta Is.-Gold Cr.
,·ra·nsmi ssion
corridor mapping
N,S transmission corridors 1981 Plant Ecology Susitna
Data need to be summarized.
Crude vegetation analysis -%
of vegetation types on floo
Referenced in Final Report
Maps produced;·no ground-trut
J I ~.~,~]")~
)ownstream succession Curry-Devil Canyon
Vegetation means,variances f
level V given to lGl
Vegetation samples,some 11tt
samples collected
Vegetation,tree cores,tempE
tures taken;being analyzec
Photos taken each week.
Crude vegetation statistic.a1
analysis performed by USFS
litter samples collected
Permanent photo plots.
Shrub cores collected;no rir
counted
:rowse
'henology
·Iurn
Middle basin
Middle basin
Alphabet Hills
.1
1982 Range Ecology Susitna
1982 Range Ecology Susitna
1982 Range Ecology Susi tna
USFS USFS
BLM BLM
,
1982 ·Range Ef0109y Susitna
0
~~i i .J Jij ~I ,~~
I 1 iStudy L~dtti6rl Yt:a,]-j Whb--fi e'']und--'I.-J 'I 1 ~t-~-'L 'I-'1
{egetation inventory 'Low~'r'basin Cooperative River Not sure
Basin Study Some vegetation samples collected
{egeta ti on mappi'ng'Upper'basin pre 1980 BLM
pre 1980 USFS
SCS
Dena 1i Project,Map produced.Cover,frequency ani
Middle,upper basin 1980
Middle,upper basin 1980 Plant Ecology 5usitna
Cooperative River
Bas in Study
USFS
SCS
Plant Ecology
Soil chemicai analysis performed a
expense
Some plantispecies ground &ana1yz
soils analyzed at AAES expense
Other plant species collections ar
available,but not ground
Data partly analyzed by USfS.
Plant Ecology Logistlcs-Susitna Materials provided at AAES expense
Data collected,chemical analysis
MES 'expense
Data unanalyzed
1980
.'.
Watan~Base Camp.(
~egetation inventory
Jegetation mapping
Fertilizer trials,.
~
Downstream succession Curry-Devil Canyon 1982
Down~tream succession Delta Is.-Chase
Bro\'lse
Phenology
Burn
Middle basin
Middle basin
Alphabet Hill s
1981
1982
1982
1982
P'l ant Ecology.Sus i tna
,
Range EcolDgy Susitna
Range Ecology Susitna
Range Ecology Susitna
USFS USFS
BlM -BLH
Range Ecology 5usitna
I
Vegetation height class informatio
available,not reported
Soil chemical analysis performed a
expense
Soil texture need to be obtained
Soil,litter samples laboratory an
at AAES expense
Data are unana1yz~d
Vegetation samples collected,but
ground or analyzed
Tree rings need to be counted.Al
nutrition data need to be analy;
Soil,1itter samples laboratory al
at MES expense
Vegetatlon samples collected,but
ground or analyzed
Vegetation field data sunluari zed I
Rings need to be counted.Need tl
bine thi s information wi th hydrf
-86-
Description of Susitna Vegetation Data Sets
Vegetation inventory -Cooperative River Basin Study -USFS,SCS
Fairly intensive permanently located vegetation plots
Measurements include:
timber inventory
ground cover %-below &above 4 1/2 ft.basal,moss,lichens,
residue,bare ground,rock,water,total
wildlife signs-hedging,browsing,number and type of trails,
-nesting trees ..
wildlife habitat data -slope,aspect,vegetation structure
tall shrub -productivity,available browse by species
habitat -height,canopy,density by plant species
range production -weights by plant species
.soil.s -SCS des~riptions
Vegetation Mapping -Susitna
.Qualitative vegetation coVer estimates
Some soils data
Fertilizer trials
..1980
1980
~Annual ryegrass was planteq in factorial design using NPK treatments
with 3 levels of each .
Responses measured included height,production,nutrieAt analysis
and photos of individual plots.64H..('-",t.;0;1 l"blln-rJ"')'ll""lylu 1oAr-t dt..:k,...)}
Downstream succession 1981
Vegetation cover by height class;density by size class;ages,heights,
dbh's of shrubs,trees.Belt transects were used.
Soil pits sampled by horizons or fluvial layers
Helicopter transects
Vegetation types at systematic points along transects
Downstream succession
1981
1982
Shrub cores collected in early-middle successional types along
hydrology transects.
Range ecology studies 1982
;.
Detailed descriptionj and data formats have been provided previously
{December 14,1982,to Steve Fancy,LGL}
-
CHAPTER 3.SUPPLEMENTAL COMMENTS
[I •490 ]ACCf~Road$
PagE!E-3-256 Side Borrow adjacent to or access balanced cut and fill techniques ~
minimize certain impacts,however,materials mu~t be available in the access corridor.
It should be stipulated the construction will have to be closely monitored.'Monitoring
will ensure contractors comply with licensing requirements and contract specifications•
~.491 ]
F".492 ]
l-.49 3 ]
i .494 J
-
..
Pag4~E-32-264 is two to three feet of road crown,enough in areas of permafrost?
We have the following additional comments on fish and wildlife resources.
Fist!:We submit that the quality of the fisheries is highly dependent on water use and
quaJlity.The Chapter 2 analysis has SOnt'L de+-\.<::.,-en-c16.most notably a valid temperature
model and the lack of data on fj9j 115t.1..dc\O~rPt~Gf~ulitnaRiver .
.!!g-etatiCl1:Vegetation section ~Cftll\-Mliication of areas which could be affected by
changes in cover.A given species may benefit by vegetation cover changes whereas'
othlar species may be adversely affected.The vegetation map should be improved to
beUer analyze moose and bear habitat..
Will~:The Jay Creek mineral lick for Dall Sheep will be impacted.Mitigation by
exposing new soil in the area is suggested.No mention of an alternative,such as
lowering the dam height to reduce the amount and escape route from'being inundated,is
meJlltioned.The dam will inundate Bald Eagle and Golden Eagle nest sites,which is in
violation of the Bald Eagle Protection Act.
In summary,mitigation agreements should be arranged with landowners prior to licensing
anel incorporated in the license to ensure they will be adopted.Also,we concur with the
applicant's proposal to establish an interagency monitoring team which should include
monitoring construction activities to ensure compliance.The team should be funded by
thE!project.
-88-
[1.495]
CHAPTER 4.HISTORIC AND ARCHEOLOGICAL RESOURCES
BLM will consider any archeological sites in this project that are under its jurisdiction
and that have tephra chronology to have cumulative research potential (36 CFR GO.6(d»."
We view these items as represneting part of a significant entity,whose components may'
lack individual distinction (36 CF"R 60.6(c».. .
'The Advisory Council on Historic Preservation must be given the opportunity to comment
on this project and the cultural resource reports.
BLM agrees with the applicant's approach to inventory and systematic testing since we
are in the process of developing an agreement with the State Historic Preservation
Officer that incorporates an analogous approach.
It is expressed several times that the project area ''holds excellent.potential for
addressing many long standing anthropological questions."What these questions are is
not specified.If sites are important for their ability to answer these questions,which
sites answer which questions,and why,should be specified•
•---.0
-
~i
-
~,
-I
::4971
:.4981
~.499J
~.500 J
"""
[1.501]
CHAPTER 5.SOCIOECONOMIC IMPACTS
General Comments
This evaluation should include:(l)a widely accepted projection of future
population and economic growth (increasing user,'9TouPs)or,if there is
substantial uncertainty as to the validity'of k'ey-assumptions (as we believe
there is),then a multiple scenario model should be.pursured examining at .
least high,medium,and low projections;and (2)a·tradeoff analysis examinin.g.
the c:ompeting mitigation proposals for the different interests.Chapter 5
fails in respect to both points.
Speciific Comments:
pas;E-5-6:(b)Population:The population projections are outdated.Impact
'ana yses and mitigation planning are tied to population projections with and
withl:lut the project.We recommend that the population projections be
updated.
PageE-5-6:{b)Population:Paragraph 5:The Knik Arm crossing should not be
CO'n"Sidered a foregone conclusion.The Alaska Department of Transportation 'and
Public Facilities (ADOT/PF)has only recently begun their assessment of this
project.The alternatives being given serious consideration by ADOT/PF for
the'draft environmental impact statement would result in minimal savings in
driving time to the conrnunities indicated.. .
Page!E-5-2A-'~(b)Population:Paragraph 2:We concur with the underlying
iSS'iilmption Sthat, in Alaska,population growth is strongly associated with
natural resource development projects.An updated eval uation of the projects
which are expected to be developed should be provided in this section.
-pagE~£·5-27:3 -EVALUATION OF THE IMPACT OF THE PROJECT:The eval uation of
project-related impacts ignores the State's most recent experiences with large
development projects;population and related impacts are due to the number of
people the project attracts,not the number of people.with dependents,the
pr~ject employs.We would agree that establishing a number,or narrow range,
for this potential impact would be difficult.However,to ignore this
pot,entially overwhelmi ng factor would r~nder much,if not all,of the
fine-tuning in the socioeconomic models irrelevant.Recent large hydropower
projects in Canada may provide case examples,in addition to the Trans-Alaska
Pipel ine System and Terror Lake hydropower project.
We recommend that the impacts of the project be reassessed in light of an
updated Base Case.
We expect that a high percentage of those attracted to the region would become
fish and wildlife resource users.This would result in increased demand for
the resources at the same time and in the area of more direct project-related
impacts to these resources.Activities such as trapping,fishing,hunting,
berry-gathering,and disruptive uses of fish and wildlife habitats would be
expected to increase,possibly resulting in greater regulation of consumptive
.fi ~sh and wi 1dl i fe uses.
[1.502J
-.
Pa~e £-5-79:(a)Natural Resource -Dependent Businesses:We recommend that
gUldes registered for Game Management Unit (GMU)13 be surveyed to determine
their reliance on ~1U 13 •.Since most of these guides are also registered for·
other (up to three)GMU's it is difficult to detennine,without a survey,the
present reliance of these guides on Q~U 13 and thus the potential impact of
the project on this group.
Tlrc!ge £-5-80:Ca}Natural Resource -Dependent Businesses:Based upon,the
present status of the fish and wildlife stUdies,we consider the most likely
potential impacts of the project on these resoucas to be unknown.
[r.503J With respect to furbearers,the increased accessibility may not result in
greater trapping success should habitat losses result in significant
population decreases.Changes in quality of consumptive fish and wildlife
uses from potential shifts and concentrations of hunting and fishing activity
should also be discussed.
[r.504]
[1.505
[I.506]
[r.507]
Page £-5-80:3.7 -Local and Regional Impacts on Fish and Wildlife Groups:
Please refer to the above comments and our remarks on chapters 2 and 3.
T1"age £-5-96:(a)Methodology:We consider it premature to concl ude that
impacts downstream of Talkeetna would be 1I1imited ll to the extent that they can
be di $mi ssed.The number of fi sh util i zi ng the reach downstream of Ta"lkeetna
is much higher than the number usingtne reach between Talkeetna and Devil
Canyon.Thus,a smaller adverse 'impact,resulting 1n a loss to a·small
percentage of thi 5 fi shery coul dmean a greater loss of fi sh.The exami na ti on
also appears to consider spawning access to sloughs between Talkeetna and
Devil Canyon to be the sole detenninant of fish losses."Temperature changes.
ice regime changes,chemical changes,impacts to tributary mouths,and access
to sloughs for rearing,are changes which could also influence the future
viability and productively of the Susitna River in regard to fishery
resources.AEIDC's report for Alaska Power Authority (APA),scheduled for
completion in October,1983,should provide insight as to the interactions of
~me of these factors.
Page E-5-98:(1)Specific Impacts:The discussion again fails to recognize
the potential impact to fiSheries downstream of Talkeetna (reference our
comments immediately above),the potential of the river above Devil Canyon to
support salmon (future opportunities lost),the importance of commercial
fishing in tenns of secondary and induced job creation,and the value of the
fishery lost over the life of the project (based upon the same economic
assumptions as the rest of the project).
Pa2e E-5-100:(c)Non-Commercial Use -The Sport Fishery:We recommend that
thlS section provide an examination of impacts for the resident fisheries of
the impoundment zones.
-
iii
."
In conjunction with identifying potential impcts to the sport fishery.impacts ol!i!t.
to the sports fisherman should be evaluated.Efforts to evaluate these
impacts,as stated above,have been dropped (reference response W-S-020 in
Chapter 11).We recommend that these studies be reinstated.The type of
evaluation necessary should be discussed with the appropriate resource
agencies.
-
[.508
[F"".509]
D .510]
f-.511
-
[_.512]
-
[,J;•513 ]
'"
-
Page E-5-l00:(d)Non-Commercial Use -Subsistence Fishin:The impact of the
project on su S1 stence 1 s ery use as not een eva uate·.The importance of
the Susitna River system to sUbsistence,potential losses of subsistence
resources,and ho~/mitigation proposals affect subsistence use should be
addressed.The data currently provided is not~pp}icab1e to the project •
.'-The discussion skirts the issues of economic,cultural,social,and
recreational values of the subsistence fishery.Those issues should be
clarified by defining subsistence use,clearly distinguishing between sport
and siubsistence fishing.As we have previously stated (see Chapter 11,
respclnse W-10-038),additional references are available on this subject.5-1/-
Page E-5-101:3.7.2-Game:The nutritional,cultural,religious,and other
socioeconomic factors which make the non-commercial taking of fish and
wild"life essential to the livelihood and lifestyle of many Alaskan residents
shou'ld be discussed and quantified here.
Quantification of impacts to game species (reference our comments on Chapter 3
of the Exhibit E)and of the subsistence use'of those resources is
inadequate •.Ana1ysi s of economi c impacts to hunters,subsi stence users,and
associ ated busi nesses shoul d occur after quantification of wiT d1 i fe impacts
and fonnulation of mitigation proposals.
Page~£-5-102:(i )Guides and Guide Services:Please refer to ou.r cormnents on
page!E-5-79.'
PagE~£-5-103:(i)Guides and Guide Services:Last Paragraph on Page Through
PfgE~E-5'-104:Theavai1abihty and qual1ty of guide serVlces and current use
o cllternatlve hunting areas should be discussed.These factors,together
with the remote nature of project.and alternative hunting areas,will
detl~rmine the magnitude of project impacts on area guiding and of secondary
imp,acts on alternative areas.The suggestion that guides and their clients
can move to other hunti ng areas is analogous to the suggestion that wil dli fe
may move to adjacent areas when their habitats are altered or destroyed.
Page £-5-104:(1)Guides and Guide Services:Para raph 2 on pa e:The
potentla or b oc lng 0 car,ou movements remalns un nown.Chapter 3,
Sections 4.3.1 (b)and 4.3.3(b»described possible significant decreases in
car'ibou subherd populations.Potential population losses will affect hunting
quail i ty and shou1 d be acknowl edged here.
Paf/e £-5-104:Last Paragraph through Page E-5-105:(i)Guides and Guide
Ser'vices:The non-resident proportion of guided hunts should be evaluated.
Aaditiona1 information should be provided on the schedule and scope of
suggested user interviews.
Page £-5-107:(ii)Lodge Operators:Please refer to our comments on the
previous section.The quality,availability,location,and present
utilization of alternative hunting areas should be discussed here.Inundation
and the presence of project features will result in decreased quality and
restrictions in areas used by lodge clients even if the lodges themselves are
not directly affected.
[1.515 ]
[1.516 ]
Page E-S-109:The Hunter:Last Paragraph:An explanation should be given for
the large increase in subsistence caribou permits allotted in 1982.Present
and future management plans and options should be discussed.
Page E-5-109:(ii)Resources and Use Patterns:The discussion provides some
quant1ficat1on for the importance of GMO 13 relative to state-wide game
harvests.Quantification of the economic importance of consumptive wildlife
uses should include consideration of travel costs,lost work time,support
equipment,food,lodging,etc.Limitations to the data available on this
subject are described,but.no plans for overcoming these limitations are
provided...
Pages E-S-112 and 113:Suppl y and Demand for Hunti ng Opportuni ty:Gi.ver:!
fluctuating harvests,demands,and populations in recent years,a clearer
picture of caribou hunting pressure would be obtained with the addition of
1981 and 1982 data.
Potential impacts to the caribou herd and related harvest opportunities should
be evaluated inlight of existing information available from the Alaska
Department of Fish and Game (ADF&G).Tjos omc;ides present and future
management plans,projected demand forecasts,likely behavioral responses of
caribou to the reservoirs,access routing and control.alternative reservoir
filling and operation schemes,construction and public use of the access
routes,and the tradeoffs of different mitigative proposals which conflict
among user groups.
-.~
[1.517 ]
Page E-5-ll5:Trans
to
[1.518]
.;;4 4i\4
Page E-5-115:Hunting Pressure:The discussion should explain why hunting
pressure in GMU 13 has generally decreased in the last decade while the
Railbe1t region population has increased nearly 50 %.The influence of
changing regulations,lifestyles of area residents,or quality of the hunt on
hunting pressure should be examined.Better understanding of the moose
harvest issue would come from inclusion of comparable demand.harvest,and
population data for GMU's 14 and 16,as well as GMU 13.
-93-
.519,
rI.5201 ]....
~~.521 J
[1.522]
-
Page E-S-1l7:Importance of Regul ati ons:Access routes,restrictions on
access,and construction schedules will greatly influence opportunities to
hunt in the project area.,Impacts should be evaluated under at least two
scenarios:1)severely restricted public access and hunting permits,and 2)
unrestricted access and permits.Such evaluation should be coordinated with
ongoing big game studies and discussed in Chapter 3.Given resource agencies'
recommendations to omit any project access from the Denali Highway,and the
lmpor'tance of those recOl1l!lendations as a wildlife mitigation measure,we
recommend the impacts on hunter access and harvest distribution·both with and'
without that road corridor be evaluated.Additional consideration should be
given to impacts both with and without restrictions on worker access aAd
hunting.Again,regulation of such use can be a significant mitigation
measure.
Other game species (black bear,brown bear,Dall sheep,wolf,and wolverine)
shou'ld be discussed.Harvest and (if applicable)permit information should be
provided,with projected demand and access discussed.For example,bear
harvlest data and statistical analysis is contained in ADF&G annual ,
reports.S-2I Harvest data on other species is similarly available.5-3/
Annual hunter surveys for all big game include questions on harvest
locations.While the data are not exact,they do indicate approximate take
locations relative to existing access,proposed access,and project features.
Such information should be evaluated and descriptive maps provided for this
section of the license application.
Future study plans for filling data gaps on these species and incorporating
those data into project pla~ning should be discussed.
Page:E-S-120:Ca)Data Limitations:Studies necessary to fill data gaps
should be pursued by the applican~.Need for a survey of trapping pressure
and estimates of socioeconomic impacts from increased trapping due to the
proJect were two of the study recommendations from the Susitna Modeling
Workshop held February 28 -March 4,1983.That workshop invol ved agency
representatives,principal investigators,consultants,and the project sponsor.
Pag1es E-S-120 and 121:(b)Trapping Activity:The issue of future
opportunities lost or gained as a result of the project should be examined in
det,ermining project impacts.Consideration should also be given to -the number
of additional trappers the area could support under alternative access and
management scenarios.
Pages E-5-122 and 123:(ii)Impacts of the Project:The extent to which
negative impacts will be "partially offset"should be described.
For'mitigation planning,coordination between project study components should
include an assessment of the number,sizes,and potential habitat v'a1ues of
slofughs which are to be managed for salmon mitigation as compared to the
number,size,and habitat values of those which are now and will remain
aVeli1ab1e as beaver habitat.Tradeoffs in mitigation for one species over
another should be clarified in ter-ms of overall objectives for project
mitigation.The potential for overharvest and need for regulation as a result
of increased project access should be considered here.
-94-
[1.523]
[I.524
Page E-5-124:(f)Fox:Please provide comparative information on the
commercial value of fox pelts as was provided for other furbearers.
The last sentence in the first
or eliminated.
We are concerned that no outline or schedule is provided for the development
of fish and wildlife use·information referred to in the last paragraph here.
Under current reduced project funding,we are unaware of additional studies or'
information which will be provided during the proposed licensing schedule'.'-
[I.526]
I '
[1.525 ,....,.~P~age E-5-128:4.4.1 -Mitigation Measures That Would Help Avoid Significant
Adverse Project-Induced Impacts:The proposals lack spec1ficity and adequate
oversight.The mitigation plan should contain specific mitigation proposals
in response to specific identified adverse impacts.We concur that close
monitoring of the effectiveness of the mitigation plan would be necessary.
However,no details on the recommended monitoring are provided,e.g.,
responsibility,participation,schedule,criteria for determining "significant
adverse impacts"and then modifying mitigation measures,etc.Furthermore,
supplemental information provided in response to FERC's questions deletes
parts of the mitigation proposed in the license application without offering
any alternatives (Vol.IIA of III,Supplemental Information from page
5-30-1).The Supplemental Information was not distributed with the license
application nor made generally available.
We recommend the establishment of a monitoring panel,at project expense,
consisting of representatives of appropriate local,State,and Federal
,agencies to carry out the functon of assessing the extent of actual impacts
and recommending modifications to the mitigation program.Modification of the
mitigation plan included in the license would be through license amendment.
Page £-5-132:4.4.2 -Mitigation of Significant Adverse Impacts that Remain in
Communities:Clarification is needed on whether costs of technical and
financial assistance referred to here have been estimated and included in
overall project costs.The potential magnitUde of those costs should be
described.
[I.527
[.5281
rPige £-5-133:4.5.1 -Developing Imract Information:Please refer to our
comments on page E-5-125.No detai s are provided on proposed or ongoing of
impact assessments.It is our understanding that no community surveys are
funded for State fiscal year 1983,contrary to the Supplemental Information,
Vol.II A of III,pages 5-29-3 and 5-34-3.
page £-5-134:4.5.1 -Developing Impact Information:Paragraph 3:An outline
an schedUle of studies necessary to obtain more detailed fish and wildlife
use data should be included here.Need for this information was agreed upon
by project investigators,the APA,and resource agency representatives during
,the February 28 -March 4 1983,mitigation planning workshop.as well as
l~r1ier workshops on resource modeling and project licensing.
Pa e £-5-135:4.5.3 -Refinin and 1m 1ementin Mitigation Measures:·Please
re er to our comments un er Sect10n on t e need to estab 1S a
monitoring panel and describe responsibilities and criteria for adjusting
mitigation measures.
-95-
...~.-
Chapter 5 Footnotes
5~1/Foster,Dan.November 1982.The Utilization of King Salmon and the
Annual Round of Resource uses in Tyonek,Alaska •.•ADF&G,Division of
Subsistence,Anchorage.62 pp.
Darbyshire and Associates.December 1982.Socioeconomic Impact Study of
Resource Development in the Tyonek/Beluga Coal Area.·Anchorage,Alaska.
5-2!ADF&G.1982..Susitna Hydroelectric-Project Phase I Final Report,Big
Game Studies,Volume VI,Black Bear and Brown Bear.Prepared for APA.
ADF&GI.1983.Susitna Hydroelectric Project Phase II Progress Report,Big
Game Studies,Volume VI,Black Bear and Brown Bear.Prepared for the APA.
5-3/ADF&G.1982.Susitna Hydroelectric Project Phase I Final Report,Big
Game Studies,Vol.V,Wolf;Vol.VII,Wolverine,and Vol.VIII,Da11 Sheep.
Prepared for the APA.
-96-
[1~529]
[1.530]
[1.531]
[1.532]
[Io 533]
CHAPTER 5.SUPPLEMENTAL COMMENTS
It appears that regional-statewide impacts or effects of the project are understated since
as the State's oil revenue decreases,a higher percentage of available capital and/or
financing may be concentrated on the project,at the expense of other projects or pro-
grams. Other regional energy development may be adversely affected,as an example.'
The effects of in-migration on the economy are understated.Migration may include indi-
viduals travelling to speculate on employment,especially if employment or economic
conditions in other parts of the State or Nation are unfavorable.A large in-migration'
affects the demand for road maintenance and public works expenditures,for example.
The cost of bringing the existing Alaska Railroad up to the operating level and line
capacity which would be required for project use is not discussed.There is additional
uncertainty surrounding railroad operation costs or charges due to the uncertain status of
rail ownership.
Access will be opened to private lands when the State purchases the rights to build the
necessary roads.The cost of access could perhaps be mitigated by landowner participa-
tion,being a potential recipient of economic benefit of the roads themselves.The cost
of access road construction may not be 10096 related or attributable to the hydro project
alone ..
.Access development,if exaggerated,will cause development of the region in general,not
only development of a powersite.The effects of increased use and development,cannot'
be underestimated in effect upon the eXisting resident human population and local living
conditions.
CHAPTERS 6,7,8,AND 9.GEOLOGY AND SOILS,RECREATION,
AESTHETICS,AND LAND-USE
~aandSons
P "._
:-.534]TherE!is no mentidn of the impact of the impoundment on Federal mining claims located,..
for example,along Jay Creek.-
"i.535]-
[1.536]
'-t.537]
[1.538]-
l1.539]
Section 2.1 -Regional geology,seismic geology,and geologic conditions appear to be well
written,accurate,and concise.
Sections 2,5,8 and 3.7 -Borrow pits and quarry sites -planning for eventual inundation of
borrc)w pits,or their rehabilitation is sufficient unless the impoundment area is altered
due to a change in project design.It is unclear where the borrow sites or material
sources for the entire Denali access roadway are located.
RecreatiOl1,Aesthetics,and Land Use
.,
Sites 3.1.3 and 3.1.4 infer that access roads will be open to public use.Such decision,
when made by the responsible land managers,should detail policy governing use and also
the extent .of facilities necessary to control or enhance public use and pUblic safety.
Public-Access is not a foregone conclusion.
The Denali Highway is a scenic attraction to the touring public.Therefore,all facilities
and .developments required by the project in relation with the Denali access corridor
should be planned for minimum visual impact.This is to include temporary power lines,
borrow pits,and staging locations as well as the roadway and its eventual operation and
maintenance.
Th4~transmission line rights-of-way may eventually be used as access corridors for ORV
or other unplanned uses.
-98-
[1.540 ]
CHAPTER 10.ALTERNATIVE LOCATIONS,DESIGNS,AND ENERGY SOURCES
General Comments
This chapter should assess the effect of time delays in project construction.
Listing various types of alternative energy sources does not allow an
evaluation of what would,or should,occur in the event the Susitna
hydroelectric project is delayed for a period of years,or is never built.We·
recommend that this type of planning effort be carried out to examine the
effects of short-term and long-term delays.
IT.541]In the assessments provided on hydropower alternatives,the proposed Susitna
project and alternative basin developments are not evaluated on an equitable
basis.There are explanations and tables (e.g.Tables E.10.6 and E.10.7)
which compare alternative hydropower sites relative to the types and
significance of environmental,cultural,recreational,and land use
constraints,as well as power supply potentials.Yet,since the strengths and
weaknesses of Su'sitna River proposals are not similarly included here,it is
not possible to directly compare the Susitna p'roject with other power
alternatives.This is particularly unfortunate since the detailed evaluation
of Susitna (e.g.Chapter 3)would leave one with the initial impression that
it would have significant adverse impacts to many of the environmental
criteria,inclUding:(l)big game,{2}anadromous fish,(3)de facto
wilderness,{4}cultural (subsistence),(S).recreation (existing),(6)
restricted land use,and (7)access.Moreover,combinations of hydropower
alternatives or hydropower with other power sources which.would provide
equivalent power are not contrasted direC1=ly with the.Susitna project.
1I.542 ]
rr.543 ]
-previously,we reco~ended that further details on alternative power sources
be provided.We reiterate that recommendation here while agreeing that,in
some cases·,information may be laCKing.Where assessments of environmental,
cultural,social,land use,and other constraints can be compared among
non-hydropower alternatives,as well as with the Susitna project and other
hydropower alternatives,a more systematic and complete evaluation of
alternatives will result.We have noted the applicant's disagreement with our
recommendations to include fish,wildlife,social,and land use assessments in
comparisons among non-hydropower and hydropower ~lternatives (e.g.comments
W-10-024,W-10-027, W-10-029,W-10-031 ,W-10-032,W-l0-034 and responses to
those comments included in Chapter 11,Exhibit E).It is our view that
without such information,the license application does not provide an adequate
basis for preparation of an environmental impact statement (EIS)under the
National Environmental Policy Act (NEPA).
Such information would complement the environmental comparison of Susitna
River hydropower alternatives,Tables E.10.16 and E.10.19,as well as the
overall summary evaluation of those alternatives (Table E.10.20).
Alternatives to the proposed construction camps,village and permanent town
should be assessed in this Chapter.These construction facilities have large
implications for the fish and wildlife resources and users.At a mimimum,the
alternative of combining the three Watana facilities should be discussed.The
alternative of a Prudhoe Bay type camp should also be considered.In
-99-
:.543]addition,project design includes three airstrips (two at Watana,one at Devil
lcont.).Canyon).The alternatives of consolidating two of the airstrips,and all
_three of the stri ps,should be discussed.Construction fad 1ities
alternatives should be discussed in terms of minimizing adverse impacts to
fish and wildlife resources and their use.Resource agencies have not been
consu'lted in regard to project facilities.-
1"""'.5441
[1.545]
~.546 ]
.547]
•548]
[r.549]
.550 1
-
Specific Comments
~_E-10-l:1 -ALTERNATIVE HYDROELECTRIC SITES:We recommend that all
evaTij'ation matrices include the project as proposed and other Susitna River
basin alternatives.
Page E-10-6:1.1.5 -Plan Formulation and Evalu'ation:The tables referenced
in this section should include the proposed project and other Susitna River
basin alternatives.If the Susitna project proposal is superior to the
variClus alternatives,incorporating the proposal into the tables would help to
demonstrate this conclusion.
Page E-10-7:1.2.1 -Description of Chakachamna Site:The accompanying tables
should be corrected to indicate that the potential installed capacity would be
330 megawatts (MW),rather than the indicated 500MW.
....-
Page E-10-9:(d)Aquatic Ecology:Paragraph 2:The'low number of spawning
salmon observed in the ma;nstem and side ..channel habitats was possibly a
result of the methods utilized.Data were previously gathered through counts
from helicopters with ground verification.This type of methodology is
appropriate for the clear water tributaries but not for the glacial flow main-
stems and side-channels •
~agE~E-10-l4:1.2.4 -Environmental Impacts of Selected Alternatives:
aragraph 7:The tunnel alternatives are in conjunction with a dam to raise
the Chakachamna Lake level.The imp.acts to the aquatic system could,,
potE!nti al 1y,be 1essened through the al ternative of restricting the project to
the Chakachatna River system instead of diverting flows to the McArthur
RivE~r.Fish passage facilities have been proposed by the Alaska Power
Authority (APA)as a component of the preferred Chakachamna project plan.
Pag1e E-10-l8:1.3.3 -Formulation of Susitna Basins Development Plans:The
subplans should be corrected to indicate the current proposed Watana dam
installed capaci ty of 1020MW.
Page £-10-31:2.1.1 -Oiversion/Emer ency Release Facilities:Para ra h 1:
ine ase ows m1n1mum ows 0 ,c s were not esta 1S e as
proposed "•••to avoid adverse affects on the Salmon [sic]fishery
do·"mstream.11 The Chapter 11,Exhibit E,W-10-008 Response states that
avoidance flows (i.e.flows necessary to avoid adverse effects on the salmon
fisihery downstream),11 •••would be 19,000 cfs in August.1I According to the
Alctska Department of Fish and Game (AOF&G)Synopsis Report prepared for the
Susitna project,five of nine sloughs examined do not achieve unrestricted
access until flows exceed 20,000 cfs.!£:l!In addition,the applicant 1 s
-1 no-
[1.551 ]
[1.550]letter.'dated May 16.1983,to the Regional Director,U.S.Fish and Wildlife
(cont.)(FWS).stated that the applicant's analysis of flows versus habitat would not
be available until September 1983.Given the preliminary status of the
instream flow studies.the FWS believes that recommendation of an appropriate
flow regime,at this time',is premature (please reference the May 27,1983,
FWS letter to Eric P.You1d,APA).
Pa e E-10-32:2.1.3 -Power Intake and Water Passa es:Para raph 2:The
statement 1$made that a mu tl -1ntake structure wou d be use ,.•••in order to'-
control the downstream river temperatures within acceptable 1imits.1I Since
temperature change's are inevitable,it is important that lIacceptab1e 1imits ll
be established and agree.d upon by resource agencies."""
[1.552 ]
[1.553]
~Page E-10-32:2.1.3 -Power Intake and Water Passa es:Para ra h 3:Please
1~eference our comments on page E-10-3l concerning minimum lows.
Page E-10-33:2.2.1 -Installed Capacity:Paragraph 1:It is stated that the
Devil Canyon fac;l i ty woul d be operated,Jj •••primaril y as a base loaded
p1ant •••11 The circumstances and anticipated operating regimes under which
peaking operations at the Devil Canyon dam are envisioned need to be
explained.The potential impacts of peaking operations at the Devil Canyon
dam on the aquatic resources should be discussed.
Page E-10-34:2.3 -Access Alternatives:Please refer to our letter dated
August 17,1982 to Eric P.Yould,APA (included in Chapter 11)for our
comments and recommendations specific to access routing.With the elimination
of the.Denali Highway to Watana roadway link,the FWS would endorse the access
routing corridors and mode.Timing of access route construction is very
.important to avoiding or minimizing adverse environmental impacts.
Page E-10-43:(v)Denali Highway to.Watana:Paragraph 1:Impacts to caribou
[1.554]--would be largely avoided by eliminating the Denali Highway-to-Watana access
road.This would be consistent with the APA Mitigation Policy,the
recommendations of the resource agencies,and Access Plan Recommendation
Report (August 1982)which states:
[1.555]
[1.556]
[1.557]
"From a caribou conservation viewpoint,the Denali access route is far
less desirable than proposed routes originating on the Alaska Railroad and
Parks Highway-.The Denali route would most certainly have imnediate _
detrimental impacts on the resident subherd and future negative impacts on
the main Ne1china herd although these impacts cannot be quantified.~1
Page E-10-54:2.4 -Transmission Alternatives:Please refer to our letter
dated January 5,1982,to Eric P.Yould,APA (included in Chapter 11)for our
comments and recommendations specific to transmission corridors.
Page E-10-83:2.4.11 -Conclusions:We concur with the recommended
transmlss;on corridors.
Page E-10-83:2.5 -Borrow Site Alternatives:Except in situations where no
practicable alternatives exist,borrow sites should be restricted to areas
within the future impoundments and/or to upland sites.Guidance on minimizing
-101-
/
~.557]specific adverse environmental impacts are contained in the Biological
)Stipu~ations provided in the FWS comments on Chapter 3,Appendix E38.,cant.
-
[1.558
..-
!
.559 ]
-
fl.560 ]
h.561 ]
fI.562J.....
'u...563]
~ge E-10-105:3.1 -Project Operation and Flow selections:The effects of
varlOUS reservoir releases on flshery habitats between Talkeetna and the
.reservoir(s)is currently insufficient for recqmmending f10w releases.The
relationship of mainstem and groundwater flows mus-t be understood.The
interrelated effects of ice,sediments,stream flow,and temperature changes.
which will accompany construction,fi11ing,'and operation of the dam(s)must.
be understood for predictive"purposes..
The Arctic Environmental Information and Data Center (AEIDe)is under contract
to the APA to develop a linked system.of simulation models which will rely on
data from other project studies,available literature,and professional
judgE!ment.The AElDC study is intended to:1)predict system-wide stream flow
and temperature effects of the dam(s},and 2}interprete the effects of such
chan!~es in terms of aquatic habitats and fish populations.An AEIOC report
scheduled fo·r completion in October,1983,is expected to demonstrate how the
mode"functi ons.If the model proves sati sfactory,and the appropri ate 1evel
of b,aseline infonnation is made available,we will be able to examine the
relationship between flows and aquatic habitat.Much of the discussion on
flows as they relate to habitat is speculative.
Page E-10-106:3.1.2-Pre-project:The impacts of the 1969 water year
(extreme drought)should be fully addressed,not dismissed.The effect.of
this naturally occurring event should be described in regard to project
operations and AOW biological resources would be affected.We recomend this
analysis continue through water year 1970,which was also dryer than average.
PagE~E-10-108:3.1.4 -Energy Production and Net Benefits:It is our
understanding that the power demand projections,alternative fuel costs"and
economic growth evaluation included in the application are considered to be
high and have been re-eva1uated by the applicant.We recommend that the net
benefits versus flows discussions utilize the current economics evaluation.
Pagl:!E-10-109:3.2.1 -Susitna River Fishery Impacts:Please refer to our
COJinents on page E-10-I05.
Page E-10-llO:3.3.4 -Riparian vefietation and·Wi1d1ife Habitat:The
post-project instream flow regime as tremendous potential to impact the
timing and extent of floods,freeze-up,and spring ice jams,as well as the
riparian groundwater relationships.We do not understand how it can be stated
that the regime,II •••is unrelated to any of these factors."
Paqe E-10-111:3.3.4 -Ri arian Ve etation and Wildlife:It;s stated that,
~.•1 may e eSlra e to malntaln rlparlan vegetatlon by simulating spring
floods for a short period of time.However,the spring runoff storage is a
key element of the project.Large releases for even a few days would have
se"ere economic impact on this project.Hence,no minimum flood discharges
were considered."In response to our concern that the receeding limb of high
spiring flows may be important to stimulate smo1t outmigration,it is stated in
the Chapter 11,Response W-3-026,II When the significance of flow-related
-102-
[I.563]stimuli to smolt out-migration i's defined,the flow regime can be adjusted.II
(cont.)The apparent conflict in the statements in the application should be
reconciled and the environmental implications of this flow decision examined.-
[I.564
•565
.566 ]
.567]
age E-10-112:3.5 -Maximum Orawdown Selection:This section should be
reexamined in light of the most recent economic evaluation.
·rhe environmental impacts implications of water year 1969 alone,and in
c'onjunction with water year 1970,should be examined.This is'a naturally
occurring sequence and could repeat during the life of the project.
mge E-1 0-115:4.1 -Coal -Fi red Generation A1 ternati ve:The Nenana and/or
Bering River coal fields are potential sources of coal for power generation.
The Usibelli mine is expected to double its coal production in the next year
for export to Korea.The proximity of that mine to the Rai1be1t area,the
ongoing nature of mine operations,and indications that with a market the
Usibelli mine could be further expanded to produce 4 million tons per year for
the next six decades,suggest that greater attention should be given to this
potential power supply and its comparative environmental impacts •
Although less accessible,Bering River coal should also be considered here as
an alternative generating resource.Exploratory work on Bering River coal
development is currently being undertaken by a joint venture of the Chugach
Native landowners and Korean inter~sts.Preliminary environmental and
engineering work for the associated transportation infrastructure is being
supported by the State.. .
,Although specifics of Beluga plant design and location are not available,
existing Beluga lease-areas are well-defined.A tentative 30-year mine pit
and alternative transportation corridors have been outlined by Diamond
Shamrock-Chuitna Coal,a major area leaseholder.General ~nvironmenta1 data
on the Beluga area,as referenced in Chapter 3 of this Exhibit (Alaska
Department of Natural Resources (ADNR),1982b),are available.Baseline
.environmental studies are in their second year.Preliminary reports on the
1982 studies are now available and should be incorporated into the
i di scuss ions.10-2/
We note that the referenced economic and technical feasibility analysis is
.included in Exhibit 0,not Exhibit B as stated here.Please also see our
j
',General Comments on this Chapter's failure to directly compare non-hydropower
alternatives with the Susitna proposal,even to the general extent that those
I comparisons are provided for other hydropower alternatives.
Page £-10-116:4.1.1{d)Terrestrial Ecosystem:(i)Flora:More detailed
vegetation type maps of the area have been developed by the U.S.Soil
Conservation Service and Forest Service.The FWS has completed National
Wetland Inventory maps which are available for the area's coastal wetlands.
Those wetlands are important habitats for the bird life described under
section (f)Marine Ecosystem.
Page £-10-117:(ii)Fauna:Nests of trumpeter swan in the Beluga and 5usitna
areas have been mapped and the location data computerized.This information
is readily available from the FWS for comparative analyses.
-103-
r-:.568]
,~
JJ:.569]
I .570J
[1.571]
1 .572]
r.573]
Page E-10-1l8:ec}Aquatic Ecosystem:Preliminary quantitative baseline data
are nl)W ava,1 abl e on Bel uga area resources.10-3/-
iPaQe E-10-120:4.1.2 -Environmental Impacts:With recent acceptance of the
Alaska Surface Coal Mining Control and Reclamation.Program by the Federal
Offi cle of Surface Mi ni ng,a comprehens i ve regulatory program for Beluga,
Nenana,and other Alaska coal development exists and should be mentioned
here.We assume that the intended reference in paragraph 5 is to the Clean
Ai r Act.
To fully compare alternative power developments within the NEPA process as
described previously,a comparative discussion on environmental impacts should
be provided here.For example,Susitna hydropower development will result in
significant and irreversible habitat losses,with primary habitat impacts
occur'ing within a concentrated time frame,and a work force of several
thous;and individuals during the first several years of project development.
In cClmparison,Beluga coal development would result in small but continual
annucl1 habitat losses,potenti ally reversib1 e habi tat impacts,and an
initiia11y smaller work force which would remain for the project life.
Quantitative estimates of these habitat impacts,work force needs,and
tra.n~;portation requirements,should be provided and compared here for the
Be1u~~a development,the incremental impacts of expanding the Nenana coal mine,
a~d the proposed Susitna project.
Page £-'10-122:Aquatic'and Mad'ne Ecosystems:'We appreciate inclusion of
quant,tat,ve estimates on area fi shery resources and potenti a1 impacts to
them.Similar estimates for consumptive use and for Susitnaarea resources
shoul d a1 so be incl uded:
Page E-10-141:4.3.1 -Natural Gas:Since natural gas is considered by many
tolbe the best single energy source alternative to the Susitna project 10-4,
it is disconcerting to see so minimal an effort expended examining this
alternative.The effort should be at least equal to that provided for
assessments of alternative hydropower sites and of coal.Anything less must
be considered inadequate.No specific examination is made of natural gas and
potemti aq envi ronmental impacts nor is a tradeoff exam;nati on made of natural
gas and other alternatives..
PagE!E-10-143:4.3.4 -Environmental Considerations of Non-Coal Thermal
'SOiii'ces:We do not consider the potential environmental impacts of burning
natural gas to be the same as for diesel,oil,or coal.We recommend that
environmental considerations be examined separately for each of these fuel
a1t~!rnatives.Then they should be examined through a tradeoff analysis which
would include the proposed Susitna project,within basin alternatives,
hydll'opower projects outside the Susitna basin,and non-hydropower ,alternatives
to the proposed Susitna project..
Pagle E-10-162:4.6.3 -Potentia"Application in the Railbe1t:Greater
emphasis 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
(ADNR).Although the interest level (as reflected by the bids offered)was
low,the ADNR considered this the best potential geothermal development site
-104-
[I 573]within their jurisdiction.The lease sale was undertaken because the site:l}
(•t)has high potential (until exploratory drilling occurs,the viability"of the
con.site will'be unknown);2)is located on State land;and 3)is close to
existing transmission lines (Beluga Station).In addition,it is located
between the Chakachatna River'and the Beluga Coal fields,an area already
being explored for power development,and crisscrossed by logging roads.It
would also seem logical tQ explore the possibility of a West Cook Inlet power
generation alternative to the Susitna project.This combination could
include:Mt.Spurr geothermal,Chakachamna hydropower,Beluga coal,and West
Cook Inlet natural gas.Obvious advantages would be found in the restriction
of adverse environmental impacts to a relatively small area which already has
transmission facil ities..
-
~,
-
[1.574]
Page E-10-173:5 -ENVIRONMENTAL CONSEQUENCES OF LICENSE DENIAL:The
evaluation should assess the timing and probable mix of alternatives if the
license is denied.The objective should be to examine the enviromenta1
consequences of meeting the incremental increases in power demands as they
occur,in light of current economic and power demands projections.The "
analysis should be directed at:1)short-term planning,in the event that the
Susitna project is delayed for various lengths of time;and 2)long-term
planning so that the Railbe1t region does have a fall back.plan in the event
that the Susitna project is not licensed.We reconvnend that such planning be
undertaken.
Chapter 10 ~ootnotes
10-1/ADF&G.1983.Synopsis of the 1982 Aquatic Studies and Analysis of the
Fish and Habitat Relationships.Prepared for the APA.
10-2/Environmenta1 Research and Technology,Inc.April 1983.Surface
Hydrology and Water Quality,Interim Report,Volumes I-IV.Fort Collins,
Colorado Environmental Research and Technology,Inc.April 1983.Preliminary
Analysis of Terrestrial Biology Data Collected in the Diamond Chuitna Study
area,May 3,1982 through February 13,1983,Interim Report,Volumes I and II.
Fort Collins,Colorado.Environmental Research and Technology,Inc.and OTT
Water Engineers,Inc.April 1983.1982 Data Report Aquatic Biology,Diamond -
Chuitna Project Baseline Studies.Fort Collins,Colorado.
10-3/See Footnote 10-2,supra.
10-4/Erickson,G.K.March 1981.Natural Gas and Electric Power
Alternatives for the Railbelt.Legislative Affairs,State of Alaska,9 pp.
Tussing,A.R.and G.K.Erickson.August 1982.Alaska Energy Planning
Studies:Substantive Issues and the Effects of Recent Events (Draft).
Institute for Social and Economic Research,University of A1ask.a,15 pp.
See Footnote 10-1,supra.
-105-
-
--
-
-
r""t.5 75]
ti.576]
_~.577]
:.578]
CHAPTER 10.SUPPLEMENTAL COMMENTS
The total proposed access plan is duly influenced by the preferences of private land-
owners in the Susitna project area.However,the more complete the project area is
opened,the more significant attendant impacts on natural values and resources of the
area will result.
It !is indicated that bridges are preferred (to culverts)but specific locations or limitS ·of
USEl are not specified..
The transmission corridors are acceptable if state of the art siting and construction
prllctices are employed.
Section 4.3.1 infers that there is a supply of natural gas far exceeding expected demand
in Cook Inlet.This source of fuel for energy generation was abruptly discussed and
insufficiently weighed as an alternative.
-106-
1.579 ]
POWER SITE CONSIDERAnONS
From the standpoint of resource utilization we note potential flaws with the plan Cormu;"
latioo and selection methodology.Two basic assumptions were made which limited full
consideration of the hydroelectric potential of the basin.
The first assumption made was that rockfill dams should be used for comparison purposes
at all damsites evaluated.We believe that valid comparisons can only be made if the
type of dam that best suits the particular site is used for evaluation.To emphasize this
point,it is noted that final designs use a thin arch dam at Devil Canyon and an earth fill
dam at Wa~ana rather than rockfill.
The second assumption is that hydroelectric power sites can be compared on an individual
basis when evaluating the potential of a river system.This simply is not so.The entire·
river system must be evaluated.The four principal local factors that determine the
value of a power site are flow,head or water drop,damsite characteristics and storage.
which determines the percentage of flow that can be regu~ated so that it will pass
through the turbine rather than over the spillway.Alaska hydroelectric sites need a
large amount of storage because most of the streamflow is in the summer months and the
heaviest electric loads are usually in the winter.An excellent damsite such as Vee would
receive a low rating on an individual basis because of low storage unless it is combined
with a site such as Denali which develops a large amount of storage with a low,relatively·
inexpensive dam.All of the upper Susitna sites except Denali have inadequate storage.
Adequate storage can be developed at Vee and Watana only by building very high dams
that are very expensive because it is necessary to extend the dam above the existing
canyon....
All of the sites on the upper Susitna River,i.e.,Devil Canyon,Watana,Susitna No.3,
Vee,Maclaren and Denali could be developed at a cost that should be at least $1 billion
less than the proposed plan by limiting Watana height to the tailwater of Susitna No.3
and not submerging Susitna No.3 and Vee.This would permit utilizing the full available
head of about 1,550 feet versus about 1,300 feet in the proposed plan.Power could also
be developed at Denali.A past decision not to install a powerplant at Denali was made
when crude oil cost about $2 per barrel.Further cost reduction may be possible by
utilizing either a rock fill or thin arch dam at Watana after the height reduction brings
the dam back within the natural canyon.
"1
The application appears to have rejected Denali solely on economic grounds with the
single dam evaluation methods employed.The Corps of Engineers in its 1975 report on
the Upper Susitna Basin also decided not to investigate Denali further because of
geologic considerations.It does not appear that a thorough geologic examination was
conducted to reach this conclusion.
In 1958-59,our Bureau of Reclamation drilled five holes and excavated fourteen test pits
and trenches at the Denali site.Samples were sent to the laboratory at the E&R Center,
Denver Colorado.After the geologic examination was complete,it was concluded that
-107-
-
~l
_.
.-
[:r ..579]
(cont.
(
.IlenB.1i was a physically suitable damsite.Even it considerable!oundation workls re--
Quired,it would appear that this key darnaite should not be abandoned without a thoroUKh
investigation.It otfers the only low-eost storage in the Upper sumtna Basin.
PuU system development offers the advantage ot staiing wher8U the applicant's propoSal-
does not.Its propos.al is saddled with the enormous initial costs required.tor the first
s'tage which would be the high Watana Dam ..In contrast,Denall.Maclaren and Vee,along·
with all transmission facilities,could all be built tor halt the cost of Watana•
--
-
PROJECT NO.7114
RESPONSE OF ALASKA POWER AUTHORITY TO COMMENTS OF
UNITED STATES DEPARTMENT OF THE INTERIOR,
OFFICE OF THE SECRETARY
COMMENT 1.1 (underlined text):
"The application suffers from outdated information,
particularly in the areas of load forecasting,reservoir and
river computer modeling effects,fish and wildlife studies,
project design,and evaluation of alternatives.
liThe load forecasts included in the application reflect ~
economic evaluation that ~conducted ~.xears ago,prior to
the severe drop in oil prices.~appl~cant,Alaska Power
Authoritx (APA),recognizes these changed conditions and has
updated its-eGonomic evaluation.This reevaluation,
however,is not reflected in the application.The
si9nificant deCline in proJected load forecasts has large
implications to manx of the project assumptions which have
constrained miti9ation plannin9,for example:available
water for downstream flows;mode,timin9 and routin9 of
construction access;and schedulin9 of work.
liThe computer modeling efforts would appear to be outdated
since the models have either been replaced or modified.
These changes make it extremely difficult to establish
baseline impacts and address mitigation measures presented
in Chapters 2 and 3."
RESPONSE:
The conclusion that the FERC License Application includes
load forecasts that reflect economic evaluations that were
conducted two years ago and that a decline in load
projections has large implications on availability of water
for downstream flows is incorrect.
More current load forecasts and economic evaluations,
representative of available data and conditions in the
spring of 1983,were used in the evaluations presented in
License Application Exhibits Band D,submitted to the FERC
on July 11,1983.
The estimates of future world oil price presented in the
exhibits are based on the 1983 OPEC benchmark price of
$28.95/bbl and the reasoning,methodology and experience of
well-known forecasters.Nine estimates of world oil price
were used in the spring of 1983 to estimate Railbelt
RESPONSE TO COMMENT 1.1 (cont.):
electrical energy demand,and four of the forecasts were
carried through the generation expansion planning studies.
PERC License Application Exhibit B,Table B.90 identifies
the forecasts selected and the level of analysis to which
each forecast has been carried.FERC License Application
Exhibit D,Table D.24 shows present worth of system costs
and net benefits of the forecasts carried through the
generation planning studies.
Water for downstream flow regimes agreed to with agencies
will be made available regardless of the energy demand
forecast.
The most current information will continue to be provided to
the FERC as available.
COMMENT 1.2 (underlined text):
liThe application suffers from outdated information,
particularly in the areas of load forecasting,reservoir and
river computer modeling effects,fish and wildlife studies,
project design,and evaluation of alternatives.
liThe load forecasts 'included in the application reflect an
economic evaluation that was conducted 2 years ago,prior to
the severe drop in oil prices.The applicant,Alaska Power
Authority (APA),recognizes these changed conditions and has
updated its economic evaluation.This reevaluation,
however,is not reflected in the application.The
significant decline in projected load forecasts has large
implications to many of the project assumptions which have
constrained mitigation planning,for example:available
water for downstream flows;mode,timing and routing of
construction access;and scheduling of work.
liThe computer modelin2 efforts would appear to be outdated
since the models have either been replaced ££modif~ed.
These chan2es make it extremely difficult to establJ.sh
baseline impacts and address mitigation measures presented
in Chapters 2 and l.II
RESPONSE:
River and Reservoir Modelin2 Efforts
The HEATSIM and ICESIM models used in the License
Application were adequate for estimating potential project
impacts.Those models,however,are proprietary to Acres
~,
~,
~i
~I
-
-
RESPONSE TO COMMENT 1.2 (cont.):
American,Inc.and are not available to be used for the
current study.Therefore those models have been replaced by
the SNTEMP and 1CECAL models developed respectively by the
U.S.Fish and Wildlife Service and Darryl Calkins of the
Cold Regions Research and Engineering Laboratory of the U.S.
Army Corps of Engineers.
For a more thorough discussion of hydrological,hydraulic
and thermal modeling,refer to the Responses to Comments
B.6,B.22,B.29 and C.31.
COMMENT 1.3:
"Project studies will continue through the licensing
process,and some of these studies will continue after
license issuance as monitoring programs.Due to the ongoing
nature of the studies and the time lag in information
distribution,we consider it essential that the future
studies referenced in the application be fully discussed in
the application.A procedure should be established for
updating the results and analyses from the ongoing and
planned studies."
RESPONSE:
The Power Authority does not anticipate revising the FERC
License Application to "fully discuss ll referenced studies.
The Power Authority will,however,continue with its
approach of annually presenting study programs to agencies
and other interested parties.Results of studies and
analyses will continue to be provided in the form of study
documents and workshops.The Power Authority anticipates
that scientific environmental monitoring programs may be
reflected in appropriate FERC license conditions.
COMMENT 1.4:
"Many of the studies and reports that were planned for 1983
were not conducted (e.g.,floristic surveys (p.E-3-193),
wetlands mapping (p.E-3-201),detailed construction method
(p.E-3-268),Design Criteria Manual (E-3-150),analysis of
instream flows and temperatures (p.E-3-189)etc.).We
consider it necessary that a study update be provided to our
Fish and Wildlife Service (FWS)indicating which studies
have been canceled,delayed or modified and which are still
planned."
RESPONSE TO COMMENT 1.4:
This Comment summarizes several concerns that are addressed
more explicitly elsewhere.Responses to the specific
Comments may be found as follows:
(a)Floristic surveys (FERC License Application page
E-3-l93)-see the Response to Comment 1.316;
(b)Wetlands mapping (FERC License Application page
E-3-201)-see the Responses to Comments I.322 and
1.330;
(c)Detailed construction methods (FERC License Application
page E-3-268)-see the Responses to Comments I.391,
B.42 and 1.425;
(d)Design construction manual (FERC License Application
page E-3-150)-see the Responses to Comments 1.119 and
B.42;
(e)Analysis of mainstem flows and temperatures (FERC
License Application page E-3-189)-see the Response to
Comment I.149.
COMMENT I.5:
"The intent of the Fish and Wildlife Coordination Act
(16 U.S.C.661,et seq.)and the National Environmental
Policy Act (NEPA)(42 U.S.C.4371 et seq.)is that
environmental resources be given equal consideration with
project features.Consistent with NEPA,as well as the
applicant's Mitigation Policy (Appendix 3.A),avoidance of
adverse impacts should be given priority as a mitigation
measure.We·have found this generally not to be the case,
for example:mode,timing and routing of construction
access;scheduling of work;type and siting of construction
airstrips,camps,villages,and permanent town;recreation
development;and instream flow regime.1I
RESPONSE:
The Power Authority feels that the proposed Project reflects
a realistic balancing of engineering,economic and
environmental considerations.In this context,
environmental cOllsiderations include not only fish and
wildlife aspects,but also consideration of archaeological
resources,socioeconomic impacts,current and future
~\
-
-
..-
-
RESPONSE TO COMMENT I.5 (cont.):
recreation and land use plans.In short,the incorporation
of environmental considerations is deeply embedded in basic
project development and design.Please also see Responses
to Comments I.346,I.542 and I.552.
The Power Authority's response to the January 14,1983 USFWS
letter provides examples of project features that have been
modified in response to environmental concerns.
The Power Authority anticipates that the DEIS will describe
reasonable mitigation and alternatives.
REFERENCES
Alaska Power Authority,Susitna Hydroelectric Project FERC
License Application Project No.7114-000 (1983)Volume lOB,
U.S.Fish and wildlife Service Letter on the Draft License
Application (January 14,1983),previously submitted to the
FERC on JUly 11,1983.
Alaska Power Authority,Susitna Hydroelectric ProjectFERC
License Application Project No.7114-000 (1983)Volume lOB,
Response to U.S.Fish and Wildlife Service Letter on the
Draft License Application,previously submitted to the FERC
on July 11,1983.
COMMENT I.6:
"Research of background information is frequently inadequate
and incomplete.Examples,which we noted in our draft
application review (included in Chapter 11 of Exhibit E),
include discussions of subsistence (Chapters 3 and 5)and
alternative power generation sources,specifically natural
gas and geothermal (Chapter 10).The FWS provided the
applicant with references and suggestions in these draft
application comments."
RESPONSE:
It is believed that the subject of alternative power
generation sources,particularly natural gas and geothermal,
has been adequately researched as may be concluded from a .
review of the references contained in Volumes 2A and 9 of
the License Application.Although not readily noticeable in
the listings,we refer to Battelle Pacific Northwest
Laboratories'Candidate Electric Energy Technologies for
RESPONSE TO COMMENT 1.6 (cont.):
Future Application in The Railbelt Region of Alaska,
Volume IV,October 1982 which is one of the 17 volumes
referred to in the Volume 2A listing of references.
We anticipate refining our information about the Project's
potential impacts on fish and wildlife resource users,
including subsistence users.Recently completed household
surveys of Talkeetna,Trapper Creek and Cantwell residents
will help supplement the information presented in the
License Application.The survey included questions on the
number of persons in each household who hunt,fish and trap;
where and how often they hunt,fish and trap;what species
they hunt,fish and trap;and the importance of hunting,
fishing and trapping for recreation,food,income and cul-
tural pursuits.The results of the survey are being
tabulated and the results will be available in March 1984.
REFERENCES
Battelle Pacific Northwest Laboratories,Railbelt Electric
Power Alternatives Study,Volume 1-17,prepared for the
Office of the Governor,State of Alaska (1982),previously
submitted to the FERC on July 11,1983.
Volume IV,Candidate Electric Energy Technologies for
Future Application in the Railbelt Region of Alaska
(October 1982).
COMMENT 1.7:
"Potential major project impacts to fish and wildlife
resources still lack an adequate level of quantification.
Examples include:fishery resources and changes downstream
of Talkeetna;changes in reservoir and river temperatures,
water quality and ice processes;and wetlands impacts.
Other examples are noted throughout our specific cownents.
The potential impacts to these resources should be
quantified and then evaluated over the life of the project.
Only after that is accomplished can specific,effective
mitigation measures emerge.We consider quantification of
existing resources and impacts and a specific,effective
mitigation plan essential to the development of an
acceptable environmental impact statement.1I
"""..
RESPONSE TO CO~~NT I.7:
The Power Authority feels that the current level of
quantification is more than adequate for mitigation
planning.Past reports have specifically addressed the
habitat relationships between fish and flow for existing and
post-project conditions (ADF&G 1981).See Response to
Comment I.14.Of course,quantification is still ongoing
with the objective of finalizing mitigation plans.
The mitigation plan presented in the License Application did
provide,however,for specific measures to maintain the
existing resources.For example,in addition to proposing
operating flows that represent a compromise between optimum
economic operation and minimum environmental impact,to
maintain slough habitat for spawning salmon,the Power
Authority has proposed specific modifications (use of
protective berms,structural modifications for access and
enhanced groundwater flow,etc.).The Power Authority has
also proposed a monitoring program to assure that these
measures achieve their goals.Based on other studies and
projects in the Pacific Northwest,Canada and Alaska,the
measures described for slough modification are expected to
have a high level of success (see Response to Comment B.9).
Alternative mitigation measures to maintain the productivity
of the Susitna system that may potentially be impacted were
also proposed in the License Application.
Furthermore,the applicant will be working closely with
resource agencies throughout the next year in the Settlement
Process to arrive at mutually acceptable final mitigation
plans.
REFERENCES
ADF&G,Susitna Hydro Aquatic Studies,Subtask 7.10 -Phase I
Final Draft Report,Aquatic Habitat and Instream Flow
Project (1981).
COMMENT I.8:
"In several of the chapters of Exhibit E we are confronted
with mitigation options that are designed to address adverse
impacts.For example,in Chapter 3 the potential value of
COMMENT I.8 (cont.):
spiking spring flows for salmon out-migration and the
installation of a fifth portal on the multi-level intake
structure are discussed.However,neither of these
proposals are incorporated into the mitigation plan.If
these options have validity,they should be incorporated
into the project design and operational plan."
RESPONSE;
The reason that these options (and other similarly mentioned
options)have not been incorporated into the Mitigation Plan
is that they are currently under consideration by the Power
Authority.For example,the Alaska Department of Fish and
Game (1983)has attempted to establish the relationships
between habitat variables and outmigration,particularly for
chum salmon.Results thus far indicate that outmigration is
most highly correlated with time of year.However,this
correlation is not strong.Therefore,ADF&G is continuing
studies to better understand these relationships.When
completed,measures to avoid or minimize any potential
impacts will be incorporated into the mitigation plans,if
necessary.
The option of adding a mid-level intake should be evaluated
in light of the temperatures anticipated during the second
year of filling.See also Response to Comment B.30.
The Power Authority anticipates that the DEIS will
reasonably describe feasible mitigation options,including
those described in the License Application and perhaps new
options developed in the EIS process.
REFERENCES
ADF&G,Susitna Hydro Aquatic Studies,Phase II Basic Data
Reports for 1982,5 Volumes (1983),previously submitted to
the FERC on October 31,1983.
Synopsis of the 1982 Aquatic Studies and Analysis of
Fish and Habitat Relationship (1983).
-
-
-
-
-
"""',
~,
-
,~
COMMENT I.9:
"Mitigation which is proposed should have proven success in
Alaska,or in a similar environment.Examples include:the
proposals to improve habitat through controlled burning;
hatchery propagation of Arctic grayling;and various
manipulations of the upper Susitna River sloughs."
RESPONSE:
Please refer to the Responses to Comments C.88,F.sO and
F.sl for a discussion of terrestrial mitigation feasibility
and Responses to Comments B.8,I.72,I.133, I.134,I.13s and
I.148 for a discussion of slough modification.
COMMENT I.10:
"Project studies should begin to focus on identifying
enhancement opportunities which the project provides.The
present task is to identify those resources which would be
adversely affected and attempt to 'correct'these problems.
For example,without examining water quality and quantity
changes in terms of opportunities to improve habitat,we
cannot satisfactorily examine whether there exists a
realistic potential to trade-off losses to one species for
another,and,as a by-product,identify enchancement
opportunities."
RESPONSE:
The Power Authority feels that project studies are adequate
for the evaluation of the existing conditions and the
potential impacts that the Project may create.
The Power Authority is reviewing the potential for aquatic
enhancement along with mitigation.The Power Authority's
mitigation policy is to have "no net loss to the resource,"
thus mitigating the impacts of the Project.There may be
various enhancement opportunities and the Power Authority
intends to identify and quantify these as appropriate.The
system of models and supporting analyses developed by the
Power Authority should identify various trade-offs between
--------------,-----------------~-
RESPONSE TO COMMENT I.IO (cont.):
species,if any significant trade-offs are anticipated,with
alternative flow regimes.Some of these trade-offs will
provide enhanced habitat for some species/life stages.
Thus,in establishing flow regimes,enhancement for
different species/life stages will be one of the options
available to decisionmakers.
The Power Authority anticipates that the DEIS will summarize
and incorporate models,supporting analyses and basic
information regarding enhancement opportunities.
COMMENT I.II:
"The FWS defines enchancement as the '** *development or
improvement of wildlife resource values of the area affected
by the project beyond that which would occur without the
project'(F.R.Vol.44,No.98,p.29305).We consider
enhancement to be habitat improvements beyond mitigation and
not synonymous with improvement of habitat for mitigation.
We believe the applicant should adopt these definitions."
RESPONSE:
The Power Authority used the term "enhancement"in the same
context as employed by the Department of the Interior in
their Comment I.394.
The Power Authority anticipates that the DEIS will utilize
the appropriate definitions under NEPA.
COMMENT I.12 :
"We strongly support the applicant's proposed establishment
of an interagency monitoring program (p.E-3-180).This
program should be funded by the project,containing
representatives from appropriate State,Federal and local
agencies.On-site representation from the FERC would be
highly desirable to maximize the responsiveness of the team.
The-board should have the authority to recommend
modifications of how activities are conducted to assure that
-,
~,
....
-
COMMENT I.12 (cont.):
mitigation is effective.Recommended changes in the
mitigation program should be adopted through a mechanism
incorporated into the license as a binding article,mutually
acceptable to all concerned bodies."
RESPONSE:
The Power Authority anticipates continuing to work with
interested resource agencies (see Responses I.119B and
I.147).Suitable mitigation mechanisms will be developed in
the Susitna Settlement Process (see Response to Comment
F.1)•
COMMENT I.13:
"Your attention is also called to Attachment A of our
Chapter 3 comments in the enclosure.Attachment A
represents those items which we believe should be conditions
of any license issued based upon the current application
documents.11
RESPONSE:
See Response to Comment 1.425.
COMMENT I.14:
llWe conclude that the applicant's request poses serious
environmental problems from a lack of quantification of
natural resources and an inability to formulate proper
mitigation and enhancement plans.We recommend that FERC
carefully consider all of these aspects of the project when
processing the application.The recommendations supplied
above and in the accompanying detailed comments should be
used in preparation of any environmental impact statement
issued for this project and in any terms and conditions of
any license issued."
RESPONSE:
As stated elsewhere (see Response to Comments C.34,F.44 and
F.46),the Power Authority feels that sufficient
quantitative information has been provided to permit an
independent analysis of the project by the FERC,and to
enable the FERC to prepare the Draft EIS,a decision-making
document.The CEQ NEPA Regulations,40 C.F.R.§1500.1(c),
state that II [t]he NEPA process is intended to help public
RESPONSE TO COMMENT I.14 (cont.):
officials make decisions that are based on understanding of
environmental consequences,and take actions that protect,
restore and enhance the environment."Thus,as with other
FERC licenses for major hydroelectric projects,the Power
Authority anticipates that the FERC License for this Project
will include license terms and conditions reflecting
environmental matters.
Quantitative assessments of baseline conditions and project
impacts were provided in the Application and supporting
documents.Specific mitigation programs and their
construction and operating costs were also proposed.
COMMENT I.lS:
"Chapter 2 has been vastly improved qualitatively from the
draft we reviewed last year 2-1/,however,it still does not
provide the quantification necessary for assessing
project-related impacts or formulating a mitigation plan.
In particular,Chapter 2 fails to fully discuss all of the
six habitat types identified by the Alaska Department of
Fish and Game (ADF&G)Susitna Hydro Aquatic Studies Program;
impacts to riparian zones;resources and potential impacts
downstream of the Talkeetna River;groundwater relationship
between the sloughs and mainstem;and enhancement
opportunities."
"2-1/See FWS letter dated January 14,1983 to Eric P.
Yould,APA.Included in Chapter 11.
RESPONSE:
The Power Authority anticipates that the DEIS will describe
these matters with reasonable qualitative and quantitative
detail.See the Response to Comment I.10.
FERC License Application Chapter 2 provides information
necessary for assessing project-related impacts and
formulating a mitigation plan.See the Responses to
Comments C.63,C.64 and C.6S.
-
-
-
-
COMMENT 1.16:
liThe modeling efforts discussed in Chapter 2 suffer from
lack of verification and/or insufficient input data (see our
comments on pages E-2-62,E-2-87, E-2-88,E-2-114,E-2-117,
E-2-118, E-2-119, E-2-121, E-2-123,etc.).Additional
modeling efforts should be undertaken to address
post-project conditions regarding sediment and bedload
transport (see our comments on pages E-2-34,E-2-84,and
E-2-96).1I
RESPONSE:
Please refer to the Responses to Comments 1.30, 1.37,1.38,
1.39,1.46, 1.47,1.48 and 1.51.Also,please refer to the
Responses to Comments B.6,B.16,B.22,B.23,B.26,B.29,
B.3l,B.32,B.33,B.38,C.43 and C.44 for discussions of
stream and reservoir temperatures and temperature modeling.
001 Comments 1.21 and 1.41 refer to pH and total dissolved
solids,conductivity,significant ions,alkalinity and
metals,and do not refer to sediment and bedload transport.
Please refer to the specific Response to Comment 1.36 and to
the Response to Comments B.14 and C.38,for a description of
sediment and bedload transport.
COMMENT 1.17:
11 CHAPTER 2.WATER ~AND QUALITY
liThe chapter should also describe studies,ongoing and
proposed,which may address the concerns we have
identified."
RESPONSE:
Please refer to the Responses to Comments B.6 through B.9
for discussions of temperatures,flow regimes,lower river
and mitigation.Also,please refer to Responses to Comments
C.32,C.34,C.39,C.40 and C.41,regarding availability of
information.from additional and on-going studies for
inclusion in the EIS process.
------------......,--~~--~------,--------
COMMENT I .18:
"Page E-2-3:2-BASELINE DESCRIPTION:The discussion
divides the Susitna River into two habitat components
between the dam sites and the Talkeetna River;the mainstem
and the sloughs.Below the Talkeetna River,the discussion
is non-speeific regarding habitat sites.In constrast,the
ongoing ADF&G studies 2-2/have identified six habitat types
utilized moderately to heavily by salmon.These are:
tributaries,tributary mouths,upland sloughs,side sloughs,
side channels,and mainstem.Each of these habitat types
would undergo a different degree of impact due to the
project.Some habitats could become less useful for one life
phase but may become more valuable for another life phase.
Only by examining potential impacts in all six habitat types
can mitigation and enhancement opportunities be identified.
In addition to the habitat types identifed by ADF&G,the
adjacent wetlands should be fully described and the
potential impacts to these habitats discussed in later
sections,both upstream and downstream from the mouth of the
Talkeetna River."
"2-2/ADF&G 1983.Synopsis of the 1982 Aquatic Studies and
Analysis of Fish and Habitat Relationships.Prepared for
the APA."
RESPONSE:
As part of ongoing studies for the proposed Project,the
Alaska Department of Fish and Game (ADF&G)has provided
additional detail to the habitat classification for areas
between Talkeetna and Devil Canyon.The ADF&G has done this
to further examine and refine the analysis of potential
impacts on each habitat type as a result of the Project.
The Arctic Environmental Information and Data Center (AEIDC)
is using this information in combination with other informa-
tion (reservoir operations,modeling studies,temperature
modeling studies,etc.)to further provide a detailed exam-
ination of the potential changes within each habitat in
response to the Project.The results of this examination
will be incorporated into the mitigation planning efforts.
The AEIDC has already completed (in January 1984)a final
report which demonstrates the methodology to achieve this
goal.
-
-
~:,
-
-
-
~,
RESPONSE TO COMMENT 1.18 (cont.):
Potential impacts to wetlands adjacent at the lower Susitna
River will be addressed during impact assessment refinement
efforts.See also Responses to Comments B.9,1.7,1.22,
1.50,1.84,1.85,1.278 and 1.591.
REFERENCES
Arctic Environmental Information and Data Center (AEIDC),
Susitna Hydroelectric Project Aquatic Impact Assessment:
Effects of Project-Related Changes in Temperature,Turbidity
and Stream Discharge on Upper Susitna Salmon Resources
During June Through September (January 1984),previously
submitted to the FERC on January 20,1984.
COMMENT 1.19:
"Page E-2-19:.2.3-Susitna River Water Quality:Paragraphs
6 and 7:It is noted that 22 water quality standards are
exceeded,under natural conditions.We disagree with the
conclusion that,since these conditions are naturally
occuring,they have an insignificant effect upon the aquatic
organisms.We recommend a further examination of how
changes in water quality would affect aquatic organisms.An
examination of the available literature may be sufficient."
RESPONSE:
The Power Authority anticipates that the DEIS will
incorporate available literature.See also Responses to
Comments C.31 and C.34.
COMMENT 1.20:
"Page E-2-32:2.3.7-Nutrients:The communities of
Cantwell,Trapper Creek,and Talkeetna would be affected by
changes in water quality relative to sewage treatment,
drinking water,etc.Baseline descriptions and,in latter
sections,impacts attributable to the project should be
provided.II
RESPONSE TO COMMENT 1.20:
It is impossible to respond to this Comment in a specific
manner as the commentor does not specify which water quality
parameters are felt to be of concern.Please also note that
all point discharges will be constrained by NPDES and all
non-point discharges by Alaska DEC Water Quality Standards.
The community of Cantwell,Alaska lies outside the drainage
basin of the Susitna Hydroelectric Project and,therefore,
should not be significantly affected by changes in water
quality related to the Project.
Residents of Trapper Creek and Talkeetna dispose of
household sewage via individual septic systems and obtain
potable water from individual water wells (see FERC License
Application page E-5-l3).Project-related changes in water
quality which might affect the sewage treatment of drinking
water of Trapper Creek or Talkeetna are not anticipated.
COMMENT 1.21:
"Page E-2-34:(e)pH:Due to the wide pH range (6.0 to 8.1)
measured above Gold Creek,and the potential for increased
acidity due to inundation of bogs by the reservoirs,we
recommend that pH monitoring be continued."
RESPONSE:
Flooding of acidic bogs is not anticipated to cause
significantly increased acidity in the proposed reservoir
system.The Susitna River drains thousands of square miles
of mountains and highland tundra.Much of the tundra is
underlain by glacial till and covered by acidic,saturated,
peaty soils.Acidic bogs (Sphagnum bogs commonly have pH
less than 4.5)are common on the tundra terrain and perhaps
in the reservoir inundation zone.However,the wate!f of
the river basin maintain moderate to high (46-88 mgl
CaI03 )alkalinity during all seasons.The pH of the project
reservoirs are expected to be largely regulated by the
carbonate-bicarbonate buffering system of the waters in the
Susitna River and smaller peripheral tributaries.The
alkalinity of the tributaries and therefore the reservoirs
reflects the biogeochemistry of the entire drainage basin
and not merely the relatively small,recently inundated
impoundment areas.
~,
..-
,.....
RESPONSE TO COMMENT 1.21 (cont.):
pH monitoring is not anticipated to be necessary relative to
acidity changes caused by inundation of bogs.See also
Responses to Comments C.48 and C.59.
COMMENT 1.22:
"Page E-2-40:2.4.4-Hydraulic Connection of Mainstem and
Sloughs:The water temperature relationship between the
mainstem and the sloughs (as well as other water quality
parameters)must be established.To this end,one slough
(#9)has been closely examined and a second slough,#8A,has
been preliminarily examined.These examinations have
focused on the groundwater relationship.According to Tony
Burgess (Acres American),in his Susitna Hydro Exhibit E
Workshop presentation (December 1,1982)on groundwater
upwelling and water temperature in sloughs,the groundwater
regime can be modeled,but locally the match is not very
good:The groundwater temperatures near the surface do not
match the predicted temperatures.Continued study is
indicated for slough #9.After an understanding is achieved
for sloughs #9 and #8A the program needs to be expanded to
other sloughs,possibly sloughs #11, #19,#20 and #21.
These sloughs have been more intensively examined than other
sloughs in this reach of the Susitna River.Please outline
the studies for these slough investigations."
RESPONSE:
A similar comment was made by the 001 U.S.Fish and Wildlife
Service on the draft License Application in a letter dated
January 14,1983 contained in Exhibit E,Chapter 11 of the
License Application.The cited comment is on the fourth
page of USFWS specific comments,referenced as 2.3{a)(i)-
Sloughs:Paragraph 1.
The March 1983 Acres American Draft Slough Hydrogeology
Report discusses the discharge and temperature relationships
among the Mainstem Susitna and the sloughs.Additional
studies of the discharge and temperature relationships among
the mainstem Susitna and the sloughs are ongoing.
It is anticipated that results of the ongoing studies will
be available for use by the FERC by April 1984.Additional
discussion of the relationships between main stem and slough
hydrologic conditions has been given in the Responses to
Comments B.18 and B.19 .
._---_._._-----------~~--~----~---------------~
RESPONSE TO COMMENT 1.22 (cont.):
The Power Authority anticipates that the DEIS will analyze
the adequacy of previous studies.
REFERENCES
Alaska Power Authority,Susitna Hydroelectric Project FERC
License Application Project No.7114-000 (1983)Volume lOB,
U.S.Fish and Wildlife Service Letter on the Draft License
Application (January 14,1983),previously submitted to the
FERC on July 11,1983.
Acres American,Inc.,Draft,Susitna Hydroelectric Project
Slough Hydrogeology Report (March 1983),previously
submitted to the FERC on July 11,1983.
COMMENT 1.23:
"Page E-2-44:2.6.2-Fishery Resources:The recently
conducted salmon incubation study 2-3/indicated that chum
salmon outmigrate after a particular-number of degree-days
are exceeded,coincidental with the receeding limb of the
spring hydrograph.Further investigation is necessary to
fully understand the need for peaking spring flows in
relation to chum salmon outmigration."
"2-3/Wangaard,D.B.and C.V.Burger.1983.Effects of
Various Temperature Regimes on the Incubation of Susitna
River Chum and Sockeye Salmon.FWS.Prepared for the APA."
RESPONSE:
Although Wangaard and Burger (1983)did establish the
relationship between temperature and incubation rates,they
did not indicate that chum salmon outmigration was
coincidental with the receding limb of the spring
hydrograph.The hydrograph for the Susitna River varies
considerably from year to year during the open water season.
Therefore,the establishment of any correlation between
outmigration and the receding limits of the hydrograph would
be difficult to achieve.
This is demonstrated in Table I.23.A below which presents
the average weekly discharges at the Gold Creek USGS gaging
~,
-
-
-
RESPONSE TO COMMENT 1.23 (cont.):
station for the period April 1 through June 30,when peak
outmigration of juvenile chum salmon occurs,for the years
1981 and 1982.
Extensive studies to determine the relationship between
environmental conditions and chum salmon (and other salmonid
species)outmigration from the Susitna have been conducted
by the Alaska Department of Fish and Game (ADF&G,1983).
Studies in 1982 suggested that peak outmigration of chums
may have occurred prior to June 18.The ADF&G outmigrant
trap was intalled at the Talkeetna Station on this date and
the results were that "the number of outmigrants peaked
about the time of installation and rapidly decreased after
this time"(ADF&G 1983,page 71).Although insufficient
data were available to provide definitive statements on
outmigration,the strongest factor relating to outmigration
was time of season.The relationship with discharge was
modest and the relationship with temperature was poor.
During 1983,two outmigrant traps were operated by ADF&G at
the Talkeetna Sampling Station to obtain additional
information on outmigration.Also,coded wire tagging was
done on several sloughs upstream of the outmigrant traps.
The analysis of the data from these studies is currently
being performed and will be available in spring 1984.These
studies will contribute to the understanding of the need for
peaking spring flows in relation to chum salmon
outmigration.
RESPONSE TO COMMENT 1.23 (cont.):
Table 1.23.A
Average Weekly Discharge of the Susitna River
As Measured at the Gold Creek USGS Gaging Station
Average Weekly Discharge
Week 1981 1982
(cfs)(cfs)
April 1-7 1700 1500
8-14 1771 1500
15-21 1886 1657
22-28 2443 2200
April 29-May 5 5623 3386
May 6-12 20400 5100
13-19 20486 15000
20-26 13500 20143
May 27-June 2 21943 22714
June 3-9 18629 26143
10-16 16914 21857
17-23 18200 28857
24-30 21257 28000
,."".,
,-
"""
,~
RESPONSE TO COMMENT I.23 (cont.):
REFERENCES
ADF&G,Susitna Hydro Aquatic Studies,Phase II Basic Data
Reports for 1982,5 Volumes (1983),previously submitted to
the FERC on October 31,1983.
Synopsis of the 1982 Aquatic Studies and Analysis of
Fish and Habitat Relationship (1983).
Wangaard,D.B.and C.V.Burger,Effects of Various
Temperature Regimes on the Egg and Alevin Incubation of
Susitna River Chum and Sockeye Salmon,U.S.Fish and
Wildlife Service (1983),previously submitted to the FERC on
November 29,1983.
COMMENT I.24:
"Page E-2-58:3.4.1-Range of Flows:Paragraph 2:The
assumption that Case D flows would result in I •••
essentially no impact to the downstream fishery during the
anadromous fish spawning period,f fails to recognize impacts
other than flows (e.g.temperature,turbidity,water
quality,etc.).In addition,the recent examination of
access to nine sloughs 2-4/indicated that the Case D
maximum flow of 19,000 cubic feet per second (cfs)could
create acute access problems in several sloughs.Five of
the nine sloughs achieve unrestricted access at flows
greater than 20,000 cfs.Evidence from the ADF&G studies
indicate that the naturally-occuring 1982 summer flows
resulted in a significant reduction of available habitat for
chum salmon in sloughs.2-5/Case D flows could result in
similar significant reductIons in available habitat."
"2-4/See Footnote 2-2.[Footnote 2-2/ADF&G 1983.
Synopsis of the 1982 Aquatic Studies and Analysis of Fish
and Habitat Relationships.Prepared for the APA.]
"2-5/See Footnote 2-2,supra."
RESPONSE:
During the spawning period,anticipated changes in
temperature,turbidity and other water quality paramaters
are not expected to significantly affect the fishery.
RESPONSE TO COMMENT I.24 (cont.):
Mainstem turbidity is expected to be in the range of 50 to
300 NTUs under with-project conditions during the summer
months.At these ranges,little difference in the apparent
transparency over natural conditions is expected.If
anything,turbidity will be reduced.This is true for all
operating scenarios described with the FERC License
Application.See also the Responses to Comments C.49,
Figure 1 and I.32.
Temperature regimes under with-project conditions during
August are not expected to be outside the range of
temperatures observed under natural conditions.Under the
Watana-only scenario,temperature of the mainstem is
expected to be approximately equivalent to existing
conditions (AEIDC 1984).Under the two-dam scenario,water
temperature in the mainstem is expected to be I-2°C lower
during the month of August (AEIDC 1984).Under both
scenarios,water temperature of the mainstem is expected to
be 2-3°C warmer in September than under natural conditions
(AEIDC 1984).
Other water quality parameters are not expected to be
significantly changed under with-project conditions
regardless of the operating regime defined.
For a detailed discussion of access conditions related to
mainstem discharge,please refer to the Response to Comment
I.94.Based upon the information presented in FERC License
Application Figure E.2.39,a discharge of 19,000 cfs is
equalled or exceeded approximately 70 percent of the time.
However,in September,this discharge is equalled or
exceeded only approximately 15 percent of the time.In
1982,average discharge for August was 15,000 cfs during
which adult salmon did gain access to the sloughs for
spawning.
REFERENCES
Arctic Environmental Information and Data Center (AEIDe),
Susitna Hydroelectric Project Aquatic Impact Assessment:
Effects of Project-Related Changes in Temperature,
Turbidity,and Stream Discharge on Upper Susitna Salmon
Resources During June Through September (January 1984),
previously submitted to the PERC on January 20,1984.
~,
....
,.....
i
.....
r
COMMENT 1.25:
IIPage E-2-59:3.6.1-Susitna River Fishery Impacts:As
indicated in Section 3.5-Energy Production and Net Benefits,
the 12,000 cfs maximum August flow was established through a
power production versus net economic benefits analysis.The
flow level was established prior to an evaluation of access
to sloughs in the Susitna River upstream of the Talkeetna
River and is not biologically based.The 1982 ADF&G studies
2-6/and Trihey's (1982)2-7/work on slough access indicate
flows of 12,000 cfs would restrict access to six of the nine
sloughs studied.1I
..2-6/See Footnote 2-2.[Footnote 2-2/ADF&G 1983.
Synopsis of the 1982 Aquatic Studies and Analysis of Fish
and Habitat Relationships.Prepared for the APA.]
112-7/Trihey,E.W.1982.Preliminary Assessment of Access
by Spawning Salmon to Side Slough Habitat above Talkeetna.
Prepared for the APA.II
RESPONSE:
Quantitative analysis of mainstem discharge necessary to
provide access to the slough spawning area was considered in
the selection of the 12,000 cfs minimum flows for the August
through mid-September period.The selection of the 12,000
cfs minimum was based in part upon results presented by
E.W.Trihey (1982)in which it is stated:
"Upstream passage into Slough 9 by adult chum salmon
would not appear to be restricted when mainstem
discharge were 18,000 cfs or higher.Access becomes
increasingly more difficult as mainstem discharge
decrease (sic).At stream flows of 12,000 cfs and less
an acute access problem exists.II
This consideration is discussed in FERC License Application
Exhibit E,Chapter 3 on pages E-3-96 and E-3-97.Please
RESPONSE TO COMMENT I.25 (cont.):
refer to the Response to Comment I.94 for further discussion
related to this question.
REFERENCES
Trihey,E.W.,Preliminary Assessment of Access by Spawning
Salmon to Side Slough Habitat Above Talkeetna,Draft Report
(1982),previously submitted to the FERC on July 11,1983.
COMMENT I.26:
"Page E-2-60:3.6.2-Tributary Fishery Impacts:According
to ADF&G,2-8/the Gash Creek mouth (River mile (RM)111.6)
could become-perched given the applicant's proposed
post-project flows.Spawning coho salmon were observed in
this creek during 1981 and 1982."
"2-8/See Footnote 2-2.[Footnote 2-2/ADF&G 1983.
Synopsis of the 1982 Aquatic Studies and Analysis of Fish
and Habitat Relationships.Prepared for the APA.]II
RESPONSE:
According to our analysis,Gash Creek is expected to degrade
(R&M Consultants,1982,pages 4-12).However,due to
inaccessibility,this assessment consisted of an aerial
reconnaisance which revealed fairly fine-grained sediments.
The ADF&G Synopsis Report cited by the Department of the
Interior makes no reference to post-project flows.The
report states that,"Gash Creek,a small tributary near
river mile 111.6,has had significant numbers of spawning
coho during 1981 and 1982.This creek flows through a
culvert under the Alaska Railroad.Dewatering of the side
channel during very low flow periods could potentially block
access"(i.e.,access into the side channel).
Apparently,there is no reference to perching of the mouth
of Gash Creek.Hence,statements in the ADF&G Synopsis
report are not inconsistent with the results of the R&M
report.However,because of the significant numbers of
spawning coho and the level of analysis to determine that
Gash Creek will degrade,the perching potential of Gash
Creek will be reexamined.
~,
~,
-
.....
COMMENT 1.27:
"Potential fishery impacts related to post-project flows
above the mouth of the Talkeetna River are not limited to
access to side sloughs (for chum salmon)or tributaries (for
chinook,coho,and pink salmon).The analysis of impacts to
salmon should be by life phase,i.e.adult passage,
spawning,incubation,rearing,and outmigration.The
habitats used moderately or heavily by salmon for at least
one life phase are tributaries,tributary mouths,upland
sloughs,side sloughs,side channels,and the mainstem.
2-8/As a species proceeds from one life phase to another it
frequently proceeds to a habitat type better suited for the
next life phase.Access would need to be assured at times
other than that which allows adult chums to pass into side
sloughs.Post-project changes in water quality and quantity
could severely degrade these habitats.Based upon the 1982
flows,ADF&G studies 2-9/indicate that significant
reductions in available-spawning habitat in the side sloughs
could occur post-project.Post-project flows could also·
significantly change the existing relationship between the
mainstem and the other habitats previously mentioned.
Post-project changes in other water quality parameters would
affect the fisheries.For example,burbot show a high
positive correlation with turbidity levels,while juvenile
coho salmon are negatively correlated.2-10/"
112-8/See Footnote 2-2.[Footnote 2-2/ADF&G 1983.
Synopsis of the 1982 Aquatic Studies and Analysis of Fish
and Habitat Relationships.Prepared for the APA.]
II 2-~j See Footnote 2-2,supra.
"2-.!..Q/See Footnote 2-2,supra."
RESPONSE:
Studies of impacts to salmon above the mouth of the
Talkeetna have not been limited to access to side sloughs or
tributaries.Studies have been undertaken in the mainstem
river,side sloughs,side channels and upland sloughs to
determine existing habitat conditions and use by adults,
incubating eggs and juveniles.Please refer to the
Responses to Comments 1.18,B.9,B.10,B.37,B.57,C.66 and
F.2 .
RESPONSE TO COMMENT 1.27 (cont.)
Neither access to the tributaries nor the tributaries
themselves will be significantly impacted by the Project.
See the Response to Comment B.ll regarding tributary mouth
perching above Talkeetna.This habitat type (tributaries)
is where the majority of the upstream (above Talkeetna),
migrating,Susitna salmon spawn.Approximately 100 percent
of the chinook,pink and coho spawning,85 percent of the
chum spawning and 20 percent of the sockeye spawning occurs
in the tributaries (ADF&G 1983a).Because there will be no
effect on the tributaries the major emphasis has been placed
on the other habitat types which will be affected.
Studies have indicated that access to side sloughs could
potentially be impacted by projected flow regimes.
Mitigation measures have been proposed to avoid or minimize
this potential impact.Other studies,particularly by
ADF&G,refine the relationship between flows and habitat.
These studies are specifically designed to examine the
relationships between river flows and individual life
stages.For example,ADF&G has specific groups in the
SUHydro Study Team that examine anadromous adults and
resident and juvenile anadromous species.Within the latter
group,specific studies have been made on incubation
rearing,and outmigration (ADF&G 1983b).In addition,ADF&G
has specific studies on adult passage and spawning (ADF&G
1983b).Also,the U.S.Fish and Wildlife Service (Wangaard
and Burger,1983)has specifically investigated the effects
of various water temperature regimes on the egg and alevin
incubation of Susitna River chum and sockeye salmon.
Although with-project flows may change water quantity and,
perhaps,quality (e.g.,temperature)it is not necessarily
true that these changes will result in significant habitat
degradation.For example,natural overtopping of the berms
at the head end sloughs can destroy favorable habitat by
disrupting substrate and causing deposition of silt.Under
with-project conditions,the frequency of overtopping is
expected to decrease,particularly if protective berms are
added.In this example,the deposition of silt and scouring
of substrate is expected to decrease with the consequent
habitat improvement over existing conditions.
As a species moves between habitats,it should be recognized
that it does not always freely migrate to an optimum
habitat.Instead it may be forced to one that will allow
the slight advantage of survival versus mortality.For
example,a juvenile in a tributary may either have the
choice of outmigrating during freezeup or staying and not
surviving.The alternative habitat may be the mainstem
~,
.-rr,
-
-
-
"..";,
RESPONSE TO COMMENT 1.27 (cont.):
river but the conditions in this habitat are not necessarily
(or even usually)optimum.
This habitat may be better suited for the next life phase,
particularly if it is a choice between survival and
mortality.However,this does not preclude that this
alternative habitat might be significantly improved due to
the Project.
The 1982 studies in the sloughs by ADF&G (1983)considerably
expanded the information base on side sloughs.Also,
incremental analyses (IFG analysis)of instream flow versus
fish habitat for selected side sloughs were initiated in the
1982 field season to determine how spawning activity by
salmon in this habitat-type would respond to various flows.
These studies were completed during the 1983 field season
(analyses are expected to be complete in spring 1984).
Therefore,the 1982 indications by ADF&G are being refined.
Refinement of the relationships between mainstem flow and
the other habitat-types is also being completed (primarily
in spring to summer 1984).Therefore,prior to completion
of these studies the statement by the USFWS that "[b]ased
upon the 1982 flows,ADF&G studies 2-9 indicate that
significant reductions in available spawning habitat in the
side sloughs could occur post-project"is premature.Also,
this statement does not account for the mitigation plans
proposed by the Power Authority that are designed to provide
for the existing productivity of spawning habitat.See the
Response to Comment B.9 for detail concerning these
mitigation plans.
The Power Authority anticipates that the DEIS will summarize
and incorporate prior work on fisheries impacts.
REFERENCES
Alaska Department of Fish and Game,Draft 1983 Phase II
Adult Anadromous Fish Investigation Report (1983a).
ADF&G,Susitna Hydro Aquatic Studies,Phase II Basic Data
Reports for 1982,5 Volumes (1983),previously submitted to
the FERC on October 31,1983.
Synopsis of the 1982 Aquatic Studies and Analysis of
Fish and Habitat Relationship (1983).
RESPONSE TO COMMENT I.27 (cont.):
Wangaard,D.B.and C.V.Burger,Effects of Various Water
Temperature Regimes on the Egg and Alevin Incubation of
Susitna River Chum and Sockeye Salmon,u.S.Fish and
Wildlife Service (1983),previously submitted to the FERC on
November 29,1983.
COMMENT I.28:
nIt should also be recognized that post-project changes in
water quality and quantity would (given Case C)result in
identifiable changes in the Susitna River down to the
estuary.2-11/The Arctic Environmental Information and
Data Center (AEIDC)2-12/concluded Case C would result in
an increase in flows o~127.2%at Susitna Station
(downstream of the Yentna River)during March.During July,
flows below the Chulitna River would be decreased by 25%,
and at Susitna Station by 12%.Identifiable changes in
river temperature 2-13/and other water quality parameters
(e.g.turbidity)would also be predicted below the Chulitna
River.These project-related changes would be attenuated
downstream;however,our knowledge of the fishery resources
and habitats downstream of the mouth of the Talkeetna River
is considered to be an order of magnitude below that in the
Devil Canyon to Talkeetna River reach.2-14/At present,
escapement data are not available for the Talkeetna and
Chulitna Rivers,thus,the number of salmon dependent upon
the Susitna River below the mouth of the Talkeetna River,
other than for migration,is not known.It is likely many
more fish are dependent upon the lower reaches of the
Susitna River than on the reach above the mouth of the
Talkeetna River.In addition,the Susitna River downstream
from the mouth of the Chulitna River is broad,and
relatively shallow;a configuration which would lead one to
expect greater impacts from smaller changes in flow.
Dismissal of impacts downstream of the mouth of the
Talkeetna River would be premature at this time,and should
be fully discussed.2-..!.i/"
"2-11/AEIDC.1983.Examination of Discharge and
Temperature Changes due to the Proposed Susitna
Hydroelectric Project.Prepared for the APA.
"2-1:1/See Footnote 2-11,supra.
"2-Q/See Footnote 2-11,supra.
~,
-
COMMENT 1.28 (cont.):
"2-14 I See Footnote 2-2.[Footnote 2-2 I ADF&G 1983.
Synopsis of the 1982 Aquatic Studies and Analysis of Fish
and Habitat Relationships.Prepared for the APA.]
"2-.!i1 See Footnote 2-11,supra.1I
o RESPONSE:
Please reference the Response to Comment B.8 and the
Responses to Comments C.39 through C.41 which discuss the
Lower River.Also,please refer to the Responses to
Comments B.16,B.23, B.33,B.38 regarding water temperatures
downstream of the confluence and Responses to Comments B.14
and C.38 on sediment and bedload transport in and downstream
of the confluence area.Please refer to the Response to
Comment F.13 on impacts in the Lower River.
COMMENT 1.29:
"Page E-2-61:(d)Riparian Vegetation and Wildlife Habitat:
The post-project instream flow regime has tremendous
potential to impact the timing and extent of floods,
freeze-up,and spring ice jams,as well as the riparian
groundwater relationships.We do not understand how it can
be stated that the regime,'.••is unrelated to any of these
factors.I It is stated that,l •••it may be desirable to
maintain riparian vegetation by simulating spring floods for
a short period of time.However,the spring runoff storage
is a key element of the project.Large releases for even a
few days would have severe economic impact on the project.
Hence,no minimum flood discharges were considered.'In
response to our concern that the receeding limb of high
spring flows may be important to stimulate smolt
outmigration,it is stated in Chapter 11,Response W-3-026,
'When the significance of flow-related stimuli to smolt out-
migration is defined,the flow regime can be adjusted.'The
apparent conflict in the statements in the application
should be reconciled and the environmental implications of
this flow decision examined."
RESPONSE:
The statement from the FERC License Application quoted by
the U.S.Fish and Wildlife Service (USFWS)that the flow
regime "is unrelated to any of these factors"has been
incompletely quoted.The full sentence states that "Minimum
flow selection for the cases considered is unrelated to any
of these factors."Please refer to the Response to Comment
-~-~-----
RESPONSE TO COMMENT 1.29 (cont.):
1.562 for a more thorough discussion of this citation which
also appears in Exhibit E,Volume 3 of the License
Application (page E-10-110).
The USFWS also includes riparian groundwater relationships
as one of the factors.The License Application did not
state that groundwater relationships were not related to
minimum flow nor were these relationships excluded from
consideration of project minimum flow selection.The
License Application studied the relationship between
groundwater and changes in mainstem flow.The goal of these
studies has been to determine if such a relationship exists.
There does not appear to be an apparent conflict between
statements in the Application.The flow regime proposed in
the License Application has examined both economic and
environmental requirements.Results from both the ongoing
studies and the negotiation process may refine this regime.
COMMENT 1.30:
"Page E-2...,62:(e)Water Quality:The pre-versus
post-project temperature changes should be described
throughout the year."
RESPONSE:
Please refer to the Response to Comment B.6.In summary,
simulations for post-project reservoir and stream
temperatures are considering entire water years.
COMMENT 1.31:
"At the present time reservoir release temperatures are
available for only one year (1981).With only one year's
data it is impossible to estimate the range of effects.In
addition,the data indicate that 1981 temperatures were
atypical when compared to computer-predicted temperatures
for water years 1968 to 1982.Of the fifteen years examined
by AEIDC 2-16/,1981 was the only year in which temperatures
declined from June to July."
"2-16/See Footnote 2-11.[Footnote 2-11/AEIDC.1983.
Examination of Discharge and Temperature-Changes due to the
Proposed Susitna Hydroelectric Project.Prepared for the
APA.]II
~I
~.
~,
..-
I~
RESPONSE TO COMMENT I.3l:
Please refer to the Response to Comment B.G.In summary,
simulations are being carried out for three water years
representing years of low,average and high flows and for
three water years representing cold,average and warm winter
conditions.
COMMENT I.32:
"Other pre-versus post-project water quality changes should
also be described (e.g.turbidity,sediment,metals,
nutrients,etc.)."
RESPONSE:
Project-related water quality changes are anticipated to
include changes in concentration and temporal distribution
of suspended sediments.Since nutrients and metals are
chemically associated with suspended sediments in relatively
large concentrations (when compared to their dissolved
fraction),we are currently focusing some of our attention
on studies to determine the ecological effects of altering
the Susitna River suspended sediment regime.
The effects of the Project will be a reduction in the
amplitude of the temporal cycles of both suspended sediments
and turbidity.The seasonal distribution of suspended
sediments and the concentration of suspended sediments are
important in determining the ability of salmon to spawn in
the mainstem or other fish to otherwise utilize mainstem
habitats.These factors are also important for juvenile
rearing through provision of cover thus reducing predator
pressure on the juvenile fish.The Project is expected to
delay the natural clearing of the riverine discharges in
fall,winter and spring with respect to suspended sediment.
Both reservoirs and the downstream riverine flows are
predicted to have continuous suspended_~ediment
concentrations between 50 and 300 mg L under project
operation conditions.Sustained moderate to high
concentrations of suspended sediments (and also turbidity)
could possibly produce biological effects during
October-April (when compared to the natural or existing
situation)in all riverine areas directly influenced by
mainstem discharges.
Since the net effect of the Project will be storage of at
least 70 percent of the natural sediment discharge,
RESPONSE TO COMMENT 1.32 (cont.):
downstream transport of particulate metals and nutrients
will be reduced.Reduction of downstream transport of
biologically active and/or dissolved metals and nutrients is
also expected to occur.
Studies are continuing to assess the ecological effect of
project-related changes in the water quality with respect to
turbidity,suspended sediment,metals and nutrients.
COMMENT 1.33:
"Page E-2-64:Maximum Drawdown Selection:This section
should discuss that in the event both reservoirs are
drawndown to their minimum elevation,downstream flows would
be provided such that outflow would equal inflow.1I
RESPONSE:
During a low flow event both the Watana and Devil Canyon
reservoirs would be drawn down to their minimum levels and
the outflow from the Project would be not less than the
natural inflow to the Project until inflow increased
sufficiently to permit storing water.The first sentence of
the paragraph on FERC License Application page E-2-64 (also
on FERC License Application page E-IO-113)could be revised
to read as follows:
liThe downstream flow requirement at Gold Creek will be
met at all times unless both the Watana and Devil
Canyon reservoirs are drawn to their minimum level and
the combination of project outflow,which is not less
than natural inflow under these conditions,and
intervening natural flow between the project and Gold
Creek are less than the flow requirement.II
COMMENT 1.34:
"PageE-2-69:(iii)Suspended Sediment/Turbidity/Vertical
Illumination:Paragraph 9:The basis for the conclusion,
'Downstream from Talkeetna,turbidity and suspended sediment
levels should remain essentially the same as baseline
conditions,'should be provided for the winter clear water
p~riod.We recommend further investigation of post-project
turbidity and suspended sediment levels due to impoundments
..-
!
r-,
I
,~
,~
COMMENT 1.34 (cont.):
in discontinuous permafrost regions.Several references are
footnoted for your convenience.2-l1./tl
"2-17/Bodaly,R.A.,D.M.Rosenberg,M.N.Gaboury,R.E.
Hecky,R.W.Newburg,and K.Patalas.1983.Ecological
Effects of Hydroelectric Development in Northern Manitoba,
Canada:The Churchill -Nelson River Diversion.IN
Sheehan,P.J.,Miller,D.R.,Butler,G.C.,and Bourdeau,
Ph.(Eds).Effects of Pollutants at the Ecosystem Level.
John Wiley &Sons.New York.
IIHecky,R.E.and H.A.Ayles.1974.Summary of Fisheries-
Limnology Investigations on Southern Indian Lake./Lake
Winnipeg,Churchill and Nelson Rivers Study Board Report.
Winnipeg,Manitoba •
IINewbury,R.W.,K.G.Beaty,and G.K.McCullough.1977.
Initial Shoreline Erosion in a Permafrost Affected
Reservoir,Southern Indian Lake,Canada.Dept.Environ.,
Fish and Marine Servo Winnipeg,Manitoba."
RESPONSE:
The commentor refers to a section of FERC License
Application Exhibit E dealing with "Watana Development"
(FERC License Application page E-2-65,Section 4.1.1).The
discussion involving the quoted statement deals specifically
with the section discussing water quality changes during
construction (Section 4.1.1 c.iii).Discussions prior to
the quoted statement explain that the impoundment expected
during construction will only extend a few kilometers
(probably less than 10km)upstream of the cofferdam used for
diversion of the river into the diversion tunnels.We
anticipate little detectable increase of suspended sediments
due to river impoundment during construction and none
associated with the type of bank/shoreline erosion of
permanently frozen glacio-lacustrine 'fine sediments
discussed in the three documents referenced by the
commentor.Natural levels of suspended sediments and
turbidity are very low in the Susitna River during the
winter season,therefore any increase in wintertime
suspended sediments will be detectable.However,
stockpiling of draglined material,together with proper
scheduling of construction activities and implementation of
environmental safeguards should minimize downstream impacts
from suspended sediments.
--·,----_·__..."""'__7 __-----_
RESPONSE TO COMMENT I.34 (cont.):
Substantial settling and/or dilution of construction-related
suspended sediment will occur in the 50-plus mile reach
between the Watana Dam site and Talkeetna.
COMMENT I.35:
IIPage E-2-78:(i)Minimum Downstream Target Flows:Project
operations flows,where they differ from naturally occuring
flows,should be provided during reservoir filling.It may
be useful to gradually increase winter flows during the
filling period so that changes in the river and fisheries
due to increased winter flows can be monitored~1I
RESPONSE:
It would be impractical to fill the reservoir and to release
discharges similar to normal project operations since both
inactive and active storage must be filled prior to
operation,and the Power Authority plans to minimize the
filling period while still maintaining acceptable instream
flows.
The Alaska Power Authority has proposed the filling schedule
in the FERC License Application as a compromise between
filling the reservoir as rapidly as possible and maintaining
flows.Monitoring of project effects will occur when the
Project becomes operational.Although progressive steps in
implementing project flows might be desirable in terms of
analysis,they still would not be the same conditions as
actual operation.In addition,there will be plenty of time
to monitor project effects when the Project comes on line.
There will be an extended period of time for monitoring
project operations that will support the refinement of
mitigation programs.See also,Responses to Comments B.26
and F.l9.
COMMENT I.36:
"Page E-2-84:(d)River Morphology:Sediment would be
expected to aggrade (over a long period of time)at the
Chulitna-Susitna confluence until a new equilibrium is
reached.We are unaware of any data or study being
initiated to attempt to quantify the distance at which
downstream aggradation could occur or what changes are
possible in bed elevation.Changes at the confluence could
affect fish movement or boat navigation,exacerbate winter
river ice conditions,and have unfortunate consequences for
~,
-~
~,
~,
L~
COMMENT 1.36 (cont.):
the village of Talkeetna.We recommend more thorough
evaluation of sediment transport,bedload movement,and
aggradation at the Chulitna-Susitna confluence."
RESPONSE:
Please refer to the Responses to Comments B.14 and C.38 for
discussions of the results ·of sedimentation studies.A
draft report on the suspended sediment and bedload transport
characteristics of the Susitna River near the Chulitna River
confluence is available.The report will be finalized by
March 1984.
REFERENCES
Harza-Ebasco,Susitna Hydroelectric Project Reservoir and
River Sedimentation,Draft Report (1983).
COMMENT 1.37:
"Page E-2-87:Watana to Talkeetna;Paragraph 5:It is our
understanding that reservoir temperature outflows are
currently available for water year 1981 only.Water year
1981 was atypical when compared to water years 1968 to 1982,
and was the only year in which computer-predicted
temperatures declined from June to July.2-18/We recommend
that the temperature studies reflect at least two data."
"2-18/See Footnote 2-11.[Footnote 2-11/AEIDC.1983.
Examination of Discharge and Temperature-Changes due to the
Proposed Susitna Hydroelectric Project.Prepared for the
APA.]"
RESPONSE:
Please refer to the Responses to Comments B.6 and 1.31.
COMMENT 1.38:
IIPa e E-2-88:Talkeetna to Cook Inlet:Modeling by AEIDC
2-19 based upon water year 1981 for Watana alone,and
Watana and Devil Canyon together,indicates identifiable
---_._--'--_._-~~----------------------------------
COMMENT I.38 (cont.):
post-project temperature impacts below the confluence of the
Chulitna River.We suspect this might also occur during
filling of Watana.We recommend this potential impact be
re-examined."
"2-19/See Footnote 2-11.[Footnote 2-11/AEIDC.1983.
Examination of Discharge and Temperature-Changes due to the
Proposed Susitna Hydroelectric Project.Prepared for the
APA.] "
RESPONSE:
An additional report by AEIDC (1984),referenced below,
which was supplied to the FERC on October 31,1983,further
examines the potential impacts of the temperature changes.
Please refer to the Responses to Comments B.16 and B.38 for
more detailed discussion of temperatures downstream of the
Susitna-Chulitna confluence.The program of studies on
instream and reservoir temperatures is explained in the
Response to Comment B.6.
REFERENCES
Arctic Environmental Information and Data Center (AEIDC),
Susitna Hydroelectric Project Aquatic Impact Assessment:
Effects of Project-Related Changes in "Temperature,
Turbidity,and Stream Discharge on Upper Susitna Salmon
Resources During June Through September (January 1984),
previously submitted to the FERC on January 20,1984.
COMMENT I.39:
"Page E-2-88:Reservoir:We recommend that modeling be
undertaken for reservoir ice formation and breakup during
filling,as well as operation.The time of breakup has
significant implications to potential crossings by animals
(e.g.caribou).We expect this modeling may not be possible
until several years of temperature data have been collected
for the reservoir model.II
jI~,,,
-
-
RESPONSE TO COMMENT I.39:
Please refer to the Response to Comment B.32 regarding
modeling of ice cover formation and melting on the
reservoir.Also,please refer to the Response to
Comment B.6 regarding the selection of water years and cases
to be examined.The ice routine developed by Hamblin and
Patterson has been applied on several Canadian lakes.We do
not believe that several years of data on Eklutna Lake would
be necessary to model ice cover formation and melting.A
report on calibration of the model is being prepared by
Harza-Ebasco and is expected to be available to the FERC in
March 1984.
COMMENT I.40:
"Page E-,2-90:Talkeetna to Cook ,Inlet:The expected delay
in ice cover formation downstream from the Talkeetna River
should be discussed.This will have potential impacts to
beaver caches,movement by animals such as moose,and
recreational access."
RESPONSE:
The FERC License Application (page E-2-89)discusses the
potential delay in ice processes including frazil ice
generation in the Watana to Talkeetna reach during filling
of the Watana Reservoir.A similar delay may be expected in
the formation of an ice cover on the river downstream of
Talkeetna (page E-2-90).It has been suggested (R&M,1983)
that much of the ice which forms the ice cover on the lower
river downstream of Talkeetna is generated in the Susitna
River upstream of Watana.This is due to the generally
colder air temperatures in the reach as compared to farther
downstream.When filling of Watana Reservoir begins,ice
generated upstream of Watana will accumulate in the
reservoir and will not contribute to ice cover formation in
the lower river.In addition,the temperature of water
released from the reservoir will be elevated above
pre-project levels during the winter.This will also affect
the production of frazil ice in the Susitna River and will
contribute to later formation of an ice cover in the lower
river.
The ice simulation studies described in the Response to
Comment B.6 utilize a mathematical model of ice processes
for the Susitna River between the Susitna-Chulitna
confluence and the dam sites (middle reach).Detailed ice
RESPONSE TO COMMENT 1.40 (cont.):
simulations downstream of the confluence would not be
reliable because of the complexity of the channel in the
lower river.However,based on the studies for the middle
reach,we expect to be able to estimate the changes in the
ice cover development in the lower reach.For instance,
based on existing winter ice conditions at Sunshine and
Susitna Station,and expected changes in winter flow with
the dam(s)in place,changes in the water/ice cross-section
configuration can be estimated.With the reduced ice
contribution from the middle reach,the reduced progression
rate for the leading edge in the lower river may be
estimated.
To the extent that ice cover of the lower river is delayed,
moose movements may be restricted since moose are apparently
reluctant to cross open water in extremely cold weather (see
FERC License Application pages E-3-408,E-3-466 and
E-3-467).Likewise,recreational and other use of the river
as a travelway will be inhibited.It is anticipated that a
delay in ice cover formation would have no adverse effect on
the creation or utilization of beaver caches and could be
beneficial.
REFERENCES
R&M Consultants,Susitna Hydroelectric Project,Susitna
River Ice Studies.
Ice Observations 1982-1983,page 32 (in preparation)•
COMMENT 1.41:
"Page E-2-96:(vii)Total Dissolved Solids,Conductivity,
Significant Ions,Alkalinity,and Metals:Long-term
increases in mercury levels in fish are quite possible.
This potential problem is inadequately researched in the
application.We refer you to several references.2-20/
Based upon available data,Bodaly and Hecky (1982)2-21/
concluded that in cool-temperate North America high mercury
levels in fish probably result from reservoir formation in a
large proportion of cases.Bodaly,Hecky,and Fudge (1984)
2-22/found fish mercury levels responded quickly to
impoundment,increasing noticeably within two to three
years.The elevated mercury levels appear to be long-term.
Generally,they found mercury levels had not declined after
-
COMMENT 1.41 (cont.):
five to eight years of impoundment.Data from Bodaly and
Hecky (1982)2-231 suggest mercury concentrations in
predatory fish is related to the amount of terrestial
material flooded and not increased nutrients levels,
increased suspended clay sediments,or changes in water
exchange times.Bodaly,Hecky,and Fudge (1984)2-24/
concluded,"The widespread nature of the high fish mercury
level -new reservoir association makes it imperative that
elevated fish mercury levels be considered in all impact
assessments of proposed reservoirs."
"The references cited 2-251 discuss bioaccumulation of
mercury in impoundment fisheries,not fisheries downstream
from the reservoirs.The immediate implications would be
for those fisheries in the reservoirs (e.g.arctic grayling)
or for any evaluation of the fishery potential of the
reservoirs.Prior to an investigation of the available
literature (the reference section of Bodaly,Hecky,and
Fudge (1984)2-26/is extensive)one should not dismiss the
potential for bioaccumulation of mercury in downstream
fisheries,particular given the high natural mercury levels
in the SusitnaRiver (see Table 2-17).We recommend that a
predictive water quality model be incorporated into the
overall AEIDC modeling effort and baseline mercury levels
continue to be monitored in the future impoundment areas and
downstream.Mercury levels in soils and fish should also be
monitored."
"2-20/Bodaly,R.A.and R.E.Hecky.1979.Post-Impoundment
Increases in Fish Mercury Levels in the Southern Indian Lake
Reservoir,Manitoba,Can.Fish.Mar.Servo Manuscript Rep.
1531:iv +15 pp.
"Bodaly,R.A.and R.E.Hecky.1982.The Potential for
Mercury Accumulation in Fish Muscle as a Result of the
Proposed Peace River Site C Reservoir Can.Dept.Fish and
Oceans.Winnipeg,Manitoba.
"Bodaly,R.A.and R.E.Hecky,and R.J.P.Fudge.1984.
Increases in Fish Mercury Levels in Lakes Flooded by the
Churchill River Diversion,Northern Manitoba,Can.J.Fish.
Aquat Sci.Suppl.(in Press)•
"2-QI See Footnote 2-20,supra.
"2-ll1 See Footnote 2-20,supra •
._--~----~---~.__._---------------------------------------
Current literature as cited by the reviewer in this Comment
and Comment 1.342 concerning the accumulation of mercury in
fish tissues of new impoundments indicates that:
1.Higher mercury levels in fish tissue are more likely to
occur in predatory (piscivorous)fish than in fish
feeding lower on the food chain;
2.High fish tissue mercury concentrations could occur in
new impoundments anywhere in North America;
3.High fish tissue mercury concentrations can be expected
in a very high proportion of new reservoirs in
cool-temperate areas of North America;
4.Fish tissue mercury concentrations are probably not
closely related to new impoundment flushing rate~
suspended sediment levels,nutrient levels or
limniological parameters commonly related to the
.reservoir's long-term trophic status;
5.Fish tissue mercury concentrations in new reservoirs
will probably be more closely related to the amount of
shallow areas containing large amounts of organic
material which will be newly flooded.
Based on the preceding information,the Power Authority does
not anticipate a significant problem with high
concentrations of mercury in tissues of fish in the two
reservoirs of the Susitna Hydroelectric Project.Our
conclusion is primarily based on the fact that the
reservoirs will not flood relatively large terrestrial areas
covered by great quantities of organic detritus and
vegetation.In addition,we expect extensive blanketing of
flooded organic detritus and vegetation by precipitating
inorganic sediment particles,and low production of labile
organic materials by autochthonous primary productivity.
Mercury appears to be bioaccumulated to relatively high
concentrations by piscivorous fish,therefore resident
~-
RESPONSE TO COMMENT 1.41 (cont.):
predatory fish (rainbow trout,Dolly Varden,burbot)may be
the most likely candidate fish in the Susitna River
downstream of the project to achieve significantly high
mercury tissue concentrations.We do not presently
anticipate high concentrations of biologically available
(bacterially methylated or biomass accumulated)mercury
being discharged from the project reservoirs.At present,
we do not anticipate increased primary or secondary
productivity of labile organics to take place downstream
from the project reservoirs because of high,year-round
suspended sediment concentrations in the mainstem.
Consequently,we do not presently anticipate downstream
mercury bioaccumulation problems in the Susitna River
fishery.
The Alaska Power Authority will continue to consider the
subject of fish mercury contamination.Review of the
growing scientific literature on this subject will be done
and appropriate action taken.
COMMENT 1.42:
"Page E-2-98 :(ii)Sloughs:Please refer to our comments on
page E-2-40.The relationship between mainstem surface
flow,groundwater dynamics,upwelling in salmon spawning
zones of side sloughs,and local runoff to these sloughs
needs to be characterized."
RESPONSE:
Please refer to the Response to Comment 1.22.Also,please
refer to the Responses to Comments B.18 and B.19 for a
discussion of the relationship between groundwater,
mainstem,upwelling and elevation.
REFERENCES
USGS,Quadrangle Map of Talkeetna Mountains C-6 and D-6.
COMMENT 1.43 :
"Page E-2-l0l:4.1.3 -Watana Operation:The application
should discuss the potential impacts on water quality and
quantity parameters associated with the testing of the
turbines at Watana."
RESPONSE TO COMMENT I.43:
Testing of the turbines is scheduled to commence during
filling when the reservoir water elevation is above the
minimum drawdown elevation (page E-2-82,Volume SA of the
FERC License Application).Flow through the cone valves
will be adjusted as necessary to maintain a constant flow
downstream from Watana during testing of the turbines.The
flows discharged from Watana during the testing of the units
will be essentially the same as those during filling.The
only difference will be that the flow through the turbines
will displace some of the flow that would have passed
through the fixed cones.Therefore,there will be no change
in water quantity during testing and only minimal change in
water quality.
COMMENT 1.44:
"Page E-2-112:(b)River Morphology:Please refer to our
comments on page E-2-84.11
RESPONSE:
Please refer to the Response to Comment I.36.
COMMENT I.45:
"Page E-2-ll4:Watana Reservoir:Paragraph 4:It is
indicated that Watana,'•••wi11 be operated to take
advantage of the temperature stratification within the
reservoir.'Basic assumptions underlying this statement
should be discussed in detail."
RESPONSE:
Watana will be operated to take advantage of the temperature
stratification within the reservoir to minimize the
pre-project to with-project water temperature difference
downstream.The basic assumption .is that Watana will be
operated to maintain with-project temperatures as close to
natural (pre-project)temperatures as possible.In early
summer,it is acknowledged that temperatures throughout the
reservoir will likely be less than natural temperatures.
Since it will be desirable to maintain warm water
temperatures for the fisheries during this time,the intake
gates will be operated to pass the warmest water possible.
During this period the warmest water will be at the surface
~I
-
I·...
-.
-
RESPONSE TO COMMENT 1.45 (cont.):
of the reservoir.Therefore,water will be drawn through
the intake which is nearest the surface.Since the
reservoir will be filling during this period of the year,
the intake gates will be operated successively to draw water
from near the surface.That is,water will initially be
drawn through a lower intake gate because the reservoir will
be drawn down.As the reservoir fills,the next higher gate
will become submerged.Once this gate is sufficiently
submerged to pass the power house flow,the gate below will
be closed.This procedure will continue until the annual
filling cycle is complete.
Using this procedure of drawing water near the surface in
mid-and late summer,the surface temperature of the
reservoir should be near the natural river temperatures.
Therefore,it should be possible to approximately match
natural temperatures during this period.It is assumed that
natural temperatures are preferable during mid-and late
summer.
In fall,the natural water temperature decreases to near aoc
and remains near this temperature through winter until
break-up in the spring.During this period,it has been
assumed that with-project outlet temperatures approximating
the natural temperature of near aoe are preferable.
Therefore,water will be withdrawn to provide the coldest
possible water downstream.This water will be drawn from
near the surface,as this will be the source of the coldest
water during the winter.However,alternative outlet
temperature scenarios suggested by ice and fishery studies
will be analyzed as appropriate during the ongoing process
of impact assessment refinement and mitigation planning.
See the Response to Comment B.38 for a discussion of the
most recent analyses of predicted with-project downstream
temperatures.
COMMENT 1.46:
"Page E-2-117:Eklutna Lake Modeling:The Eklutna Lake data
collection program was important to the efforts to verify
the applicability of the DYRESM computer model.The ability
of DYRESM to correct the consistent one to two degree e
underestimation should be demonstrated.We recommend
meteorological data be provided for the period of record to
show how the 1982 data compare to this record.The data
collection program should be extended over a second year to
COMMENT I.46 (cont.):
lend confidence to the model's ability to mimic actual
temperature releases."
RESPONSE:
Please refer to the Response to Comment B.6 for a discussion
of the reservoir temperature modeling.This Response
references a response to FERC's Schedule B Request for
Supplemental Information No.2.28 which includes a schedule
for calibration and production runs for the DYRESM model
study.A calibration report based on Eklutna Lake data from
June 1,1982 to May 30,1983 is expected to be available in
March 1984.The model calibration can be verified with data
from June 1983 to May 1984 when these become available.
COMMENT 1.47:
"Page E-2-118:Watana Reservoir Modeling:Paragraph 1:It
is indicated that meteorological data from June through
December 1981 (seven months)were inputted to DYRESM.Page
E-2-121 indicates that June through September (four months)
data were used as DYRESM input.The November 15,1982 draft
license application indicates that data from June through
October,1981 (5 months)were used in DYRESM simulation
modeling.These apparent discrepancies should be explained.
"Please refer to our comments on page E-2-87 on reservoir
temperature modeling.We continue to recommend two full
years of data collection for input to DYRESM (see Comment
W-2-048,Chapter 11)."
RESPONSE:
There does not appear to be a discrepancy between pages
E-2-118 and E-2-121 of the FERC License Application
regarding the period of meteorological data input to DYRESM.
As indicated on page E-2-118,meterological data from the
period June 1981 through December 1981 were utilized in the
DYRESM model.Referring to the HEATSIM simulation,the last
sentence of the first paragraph on page E-2-121 reads:
"Meteorological data for 1981 was used for June through
December."DYRESM was run for the same period using the
same hydrological and meteorological data described as for
HEATSIM.License Application page E-2-121 indicates that
the Watana discharges used in the HEATSIM simulation were
taken from two sources:
~,
-
....
-
.....
.-
....
RESPONSE TO COMMENT I.47 (cont.):
1.For the period June 1981 through September 1981,
discharges simulated by the project operation model
study (described in Section 3.2)were used;and
2.For the period October 1981 through December 1981 "long
term average weekly simulated discharge"was used.
The apparent discrepancy between the Draft License
Application (page E-2-S7)and the final License Application
(pages E-2-118,E-2-121)resulted from additional studies
which included the months of November and December which
were made for the final License Application.
Please refer to the Response to Comment I.37 regarding
reservoir temperature simulation .
COMMENT I.48:
IIPa e E-2-119:Watana Reservoir Modelin :Para ra h 7:It
is important to have an understan ~ng of the potential range
of post-project occurrences.Examples would be the range of
dates when reservoir ice formation would occur,ice
thickness,and ice breakup.At the present time,since
DYRESM has not been run for October to June (or January to
June?)the time of reservoir ice breakup cannot be
confidently predicted."
RESPONSE:
Please refer to the Response to Comment I.39 on modeling of
reservoir ice formation and melting.Also please refer to
the Response to Comment I.47 on the period for which DYRESM
was run for the FERC License Application.
COMMENT I.49:
"Page E-2-121:Mainstem:Paragraph 1:Please refer to our
comments on the reservoir modeling efforts,immediately
above.In addition,tributary temperature and flow data and
the influence of turbidity and suspended sediment should be
determined and incorporated into the model.II
RESPONSE:
Temperature data are available for Denali Station since
August 29,1974 and for Cantwell Station since May 29,1980 .
There are no water temperature data available before 1983 in
---~-----''FP--------------------------------------
RESPONSE TO COMMENT I.49 (cont.):
the tributaries between Cantwell Station and Devil Canyon
Damsite.
A water temperature data collection program was carried out
by ADF&G to collect water temperature in the mainstem and
tributaries during the summer of 1983.Thermographs were
placed in the mainstem and some tributaries above the Devil
Canyon Damsite.These data,when available,may be used to
estimate tributary temperatures influent to the reservoir.
Stream flow data are available for Gold Creek Station since
August 1949 and at Cantwell Station from May 1961 to
September 1972 and from June 1980 to the present.
There are no stream flow data available in the tributaries
between Cantwell Station and Gold Creek.Tributary flow
data may be estimated from the Gold Creek and Cantwell
Stations using the drainage area ratio.
These data may be applied to simulate the thermal behavior
and ice formation of the proposed reservoirs.
The principle influence of suspended sediments on the
simulation of the thermal structure and outflow temperature
of lakes and reservoirs is through the contribution of the
suspended sediment load to the density of the water.For
example,at 20°C a suspended sediment conc3ntration of
100 mg/l of material of density 2,650 Kg/m 'would cause
approximately O.SoC change in temperature.Whereas at 4°C,
because of the nonlinear relation of temperature to density,
the same concentration would cause a 5°C temperature change.
The errors caused in the thermal predictions occur mainly in
the inflow dynamics,and to a lesser extent in the
calculation of the vertical diffusion of heat.As an
example,an inflow temperture of 9°C and suspended sediment
concentration of 100 mg/l would have a density equal to pure
water at 4°C,and thus should be inserted at the bottom
(underflow),whereas the model would insert the inflow at a
higher level (interflow)at which the temperature is 9°C
(neglecting the entrainment effect).Another possible
source of error occurs in the simulation of the vertical
mixing due to downward settling of suspended sediments.
Such settling occurs from a level where the temperature
profile is stabilized to a level lower in the profile where
the temperature is close to 4°C,and thus the suspended
sediments contribute substantially to the density.At this
point,the profile may become unstable and form an internal
mixed layer.In summary,the neglect of suspended sediments
~,
-
-
-
.-.
RESPONSE TO COMMENT I.49 (cont.):
would result in a thermal profile which is too warm at the
surface and too cold at the bottom.If the intake structure
is located well below the surface,the simulated outflow
temperatures would be too low.The Watana multi-level
intake is located in the upper 150 feet of the 600-foot deep
reservoir and is generally in or above the thermo-cline.
The magnitudes of these errors are to be determined by the
residence time of the lower layer where the insertion errors
and internal mixing take place,the inflow temperatures,and
the suspended sediment concentrations.Because of the
complex relation among these variables,it is extremely
difficult to estimate the value of possible errors,
theoretically.However,from the experience of the Eklutna
Lake study,the lower layer (hypolimnion)minimum residence
time at maximum inflow was about 120 days and at an average
measured inflow temperature of approximately 4°C (July),and
estimated suspended sediment concentration of the order of
magnitude of 900 mg/l.These values may be compared to the
minimum summer residence time of the proposed Watana
reservoir of 120 days (July)and inflow temperature of 10°C
and average suspended sediment load of 1,000 mg/l.
Because of the similar nature of the residence times,the
inflow temperatures and suspended sediment concentration in
the two reservoirs,it is concluded the errors in simulating
outflow temperatures by the neglect of the suspended
sediments in the model would be about the same as those
found in the Eklutna Lake simulations.Thus,
underestimation of outflow temperature of about 1°C would
result during the early summer period.This error would be
smaller at other times of the year.
The above analysis indicates that the neglect of the effect
of the suspended sediment load will not affect the accuracy
of the temperature simulation of the proposed reservoir,
significantly.Therefore,the suspended sediment load and
hence,the turbidity are not incorporated in the reservoir
temperature simulation model..
The influence of turbidity and suspended sediment on the
riverine morphology and biological ecology are currently
being assessed on a primarily qualitative basis since
quantitative effects are not predictable at present.The
effects of the project will be a reduction in the amplitude
of the temporal cycles of both suspended sediments and
turbidity.The project should also delay the annual
fall-winter clearing of riverine discharges by sedimentation
and flushing actions resulting in sustained high
RESPONSE TO COMMENT I.49 (cont.):
concentrations of suspended sediments (predicted to range
between 50-300 mg/l)and turbidity (predicted to range
between 10-50 NTU)in both reservoirs and the downstream
river flows.
Since the dams will significantly retard peak flows and
suspended sediment and bedload discharges of the river,
scouring activity downstream should result in a
predominantly amoured and more confined river channel in the
Devil Canyon to Talkeetna reach.(Please refer to the
Responses to Comments B.14 and C.45.)Sustained moderate to
high concentrations of suspended sediments and turbidity are
expected to produce relatively positive biological effects
during May-September,but negative biological effects during
October-April,when compared to the natural situation.
Suspended sediments have well recognized negative impacts on
aquatic biota of cold water streams.The effects are
primarly mechanically mediated and include:'
~'
1.
2.
Clogging and abrasion of gills and other respiratory
surfaces of aquatic organisms;
Adhering to the chorion of incubating eggs;
3.Providing conditions conducive to the entry and
persistence of disease-related organisms;
4.Inducing behavioral modifications;
5.Entombing of different life stages;
6.Affecting useable habitat by scouring and filling pools
and riffles,and by changing bedload composition of
particulates;
7.Abrading and smothering of phytobenthos and other
immobile life stages;
8.Affecting intragravel permeability;
9.Affecting the fishing for and catchability of sport
fishes by causing turbidity;and
!lJI'f,
....
RESPONSE TO COMMENT 1.49 (cont.):-I
1~.Reducing the quantity of light useable to phytobenthos
by causing turbidity.
REFERENCES.-
R&M Consultants,Susitna Hydroelectric Project,-Glacial
Lake Studies (December 1982),previously submitted to the
FERC on July 11,1983.
Peratrovich,Nottingham and Drage,Inc.,Susitna Reservoir
Sedimentation and Water Clarity Study (November 1982),
previously submitted to the FERC on July 11,1983.
Harza-Ebasco Susitna Joint Venture,Eklutna Lake Temperature
and Ice Study (with 6-month simulation for Watana
Reservoir),Draft Report (January 1984)•
....
-----,,-_..._-,---,-------··-~"-"_F _
-
COt-1MENT I.50:
"Page E-2-122:Sloughs:During the winter,ice formation in
conjunction with much higher flows (compared to natural
winter flows)could result in significant downstream staging
and overtopping of the side sloughs.Overtopping would
dramatically lower slough temperatures and adversely impact
fish incubation and rearing.2-27/This potential impact
should be thoroughly discussed.n-
"2-27/See Footnote 2-2.[Footnote 2-2/ADF&G 1983.
Synopsis of the 1982 Aquatic Studies and Analysis of Fish
and Habitat Relationships.Prepared for the APA.]11
RESPONSE:
See Response to Comment I.131 for discussions of the use of
protective berms to prevent slough overtopping.
Overtopping of sloughs is a natural phenomena that
frequently occurs on the Susitna River.In addition to
overtopping that occurs during spring and summer,
overtopping occurs during winter as was observed on Slough
SA during the winter season of 1982.As part of the
Mitigation Plan,the Power Authority has included the
construction of protective berms at the upstream ends of the
productive sloughs so as to.decrease the frequency of or
completely avoid overtopping.This mitigation measure will
stabilize the slough habitat and help to minimize potential
impacts on incubation and rearing that naturally occur.
Please refer to the Response to Comment B.G concerning plans
of s~udy for reservoir and stream temperature and ice
studies.The ice process simulations described in the
Response to Comment B.G include estimation of water surface
staging with the Project in operation.This information
allows for determination of sloughs which may be overtopped
during the winter due to project implementation.Ice
process simulations carried out for the License Application
and described therein for Watana in operation (FERC License
Application pages E-2-123 to E-2-127,Figures E.2.184,
E.2.185),Devil Canyon in operation (FERC License
Application pages E-2-1G9 to E-2-170)and Watana filling
(FERC License Application pages E-2-88 to E-2-90)allow an
estimation of the expected staging for 1981 hydrological and
meteorological conditions with the Project(s)in place.
COMMENT I.51:
"Page E-2-123:Talkeetna to Cook Inlet:AEIDC recently
examined river temperature profiles for one and two dams for
June through September.2-28/Their computer models SNTEMP
predicted identifiable temperature changes below the
Chulitna River,ranging up to an approximately one degree C
difference in June for the one dam senario [sic].
Post-project operations with two dams showed greater changes
downstream from the Chulitna River.
"When DYRESM has been input with data throughout the year,
for a two-year period,the potential post-project
temperature effects for the reach below the Chulitna River
will need to be re-examined.
"The application should explain why the discussion on river
temperatures uses HEATSIM,and AEIDC uses a different model,
SNTEMP."
"2-28/See Footnote 2-11.[Footnote 2-11/AEIDC.1983.
Examination of Discharge and Temperature-Changes due to the
Proposed Susitna Hydroelectric Project.Prepared for the
APA.]..
RESPONSE:
Please refer to the Responses to Comments B.1G,B.23 and
B.38 for discussions of the temperatures downstream of the
Susitna-Chulitna confluence.Please refer to the Response
to Comment B.G for a discussion of the temperature models.
Please refer to the Responses to Comments B.8 and C.39
through C.41 on Lower River.
Additionally,please refer to the Response to Comment B.G
for a comparison of HEATSIM and SNTEMP.The HEATSIM model
is proprietary to Acres American,Inc.(Acres)and was
utilized by Acres in their studies for the License
Application.SNTEMP is available to AEIDC and includes
consideration of topographic shading and tributary
temperatures,refinements which HEATSIM does not include.
For these reasons,SNTEMP was selected for further studies
on the Susitna Hydroelectric Project.
-
-
-<
-
-
COMMENT I.52:
"Page E-2-124:Watana Reservoir:It is indicated that
DYRESM was run using 1981 data collected throughout the
year.It is our understanding this was not the case.
Please clarify this apparent discrepancy.Please refer to
our comments on pages E-2-119 and E-2-121."
RESPONSE:
The source of the apparent discrepancy cited in the Comment
is not clear.The first paragraph of Exhibit E Chapter 2
Section 4.1.3(c)(ii)on FERC License Application
pages E-2-123 and E-2-124 refers the reader to section
4.1.3(c)(i)in which it is explained (FERC License
Application pages E-2-118 and E-2-121)that meteorological
data from Watana Camp for the period June 1981 through
December 1981 were used in DYRESM simulations for the Watana
Reservoir.The second and third sentences of the first
paragraph of Section 4.1.3{c)(ii)specifically state that
the period after December 31,1981 was not modeled using
DYRESM.
Also,please refer to the Responses to Comments I.47 and
r.49.
COMMENT I.53:
"Page E-2-124:Watana to Talkeetna:Please refer to our
comments on pages E-2-119,E-2-121,E-2-123.When DYRESM is
input with data collected throughout the year,and over a
2-year period,it would be appropriate to re-examine river
ice dynamics.
"The timing,ice thickness,and river staging due to the ice
has large,obvious,implications in regard to severity of
breakup,extent of freeze-up,ice jamming and the extent of
open water (downstream from dam).Large amounts of ice
deposited at tributary or slough mouths during spring could
effect smolt outmigration and/or adult immigration.1I
RESPONSE:
Please refer to the Responses to Comments I.39,1.48,1.49
and 1.51.In particular,please refer to the Response to
Comment B.G on reservoir and stream temperature and ice
studies.
--_._-~--------------------------------
RESPONSE TO COMMENT I.53 (cont.):
Downstream of Devil Canyon,the existing natural freeze-up,
ice jamming and breakup are frequently severe events.Under
these natural conditions,smolt outmigration and/or adult
inmigration takes place.
As indicated in the FERC License Application (page E-2-126),
under with-project conditions the ice cover will tend to
melt in place due to warmer discharge from the reservoir and
the regulation of spring floods which normally cause breakup
ice runs.
The severity of spring ice cover breakup jamming is expected
to be reduced when the Project is operating.Thus,it is
likely that there would be a reduction in the amount of ice
deposited at tributary or slough mouths during spring
breakup runs.Therefore,any negative effects on smolt ..
outmigration and/or adult inmigration would be expected to
be significantly less severe than under natural conditions.
Please refer to the Responses to Comments I.132 and B.44
regarding protective berms for the productive sloughs and
the role of ice-related water surface staging in slough
overtopping.
COMMENT I.54 :
npage E-2-127:Talkeetna to Cook Inlet:We recommend that
the predicted post-project changes in ice processes be
quantified and analyzed in this reach.At present,evidence
points to identifiable post-project changes to flows,
temperatures,ice conditions,water quality (e.g.turbidity
and suspended sediment),and frequency of flooding.These
would occur in a broad and shallow river system for which we
have rather limited knowledge of the aquatic resources.The
morphology of the reach downstream from the mouth of
Talkeetna River would lead one to expect greater impacts to
result from smaller changes.n
RESPONSE:
The current state of the art is not advancled to the point
that mathematical computer models are available to simulate
braided channels (as in the Lower River)having different
water levels and ice thicknesses.Please refer to the
Responses to Comments B.16,B.23 and B.38 regarding
project-related changes to temperatures and turbidities
downstream of the Chulitna-Susitna confluence.Please refer
to the Responses to Comments B.14 and C.38 regarding
-
-
,~
-
.-
~,
-
-
-
RESPONSE TO COMMENT I.54 (cont.):
aggradation and degradation downstream of the
Chulitna-Susitna confluence.Please refer to the Response
to Comment F.13 regarding the expected impacts in the Lower
River.Please refer to the Responses to Comments B.33 and
I.40 regarding the expected changes in ice conditions in the
lower river.
It is not practical,at the present time,to simulate ice
conditions with-project in the Susitna River downstream of
the Chulitna-Susitna confluence,in the same manner as for
the reach upstream of the confluence.
COMMENT I.55:
"Page E-2-l32:(vi)Total Dissolved Gas Concentration:The
current natural level of dissolved gas in Devil Canyon
exceeds the State water quality criteria of 110%.Further
increases in gas downstream from the dames)could adversely
effect juvenile and adult fisheries,in addition to resident
fisheries.It is indicted the,'•..fixed-cone valves will
be used to discharge all releases with a recurrence interval
of less than 1:50 years.'We assume events greater than
1:50 years would,therefore,necessitate spilling.It
should be clarified if this would occur,when it would
occur,and how often (based uopn the 32 years of record)we
could expect spilling.Modeling of the formation of
dissolved gas and downstream dissipation may be appropriate.
We suspect supersaturated gas formed by spilling at the
Watana dam may not sufficiently dissipate in the Devil
Canyon reservoir.This could create releases of high
dissolved gas through the Devil Canyon turbines and valves.
This scenario should be fully analyzed.lI
RESPONSE:
The FERC License Application (pages A-1-9 and A-7-S)
indicates that the purpose of the fixed cone valve outlet
works at Watana and Devil Canyon is to discharge floods with
recurrence intervals of less than 50 years after they have
been routed through the reservoirs.Floods having
recurrence interva.ls of greater than 50 years occurring when
the reservoir is full would require spillway operation.
Discussions of the frequency of spillway operation based on
the 32 years of reservoir operation modeling are given in
the License Application (pages E-2-111,E-2-132, E-2-163,
E-2-171 and Tables E.2.50 and E.2.5S).As indicated in
Table E.2.50,the spillway would not be operated during any
of the 32 years simulated for Watana,only operation based
RESPONSE TO COMMENT I.55 (cont.):
on year 1995 and year 2000 load forecasts.Table E.2.58
indicates that,based on year 2002 simulation,the Devil
Canyon spillway would operate once in the 32 years of record
(1967).We do not believe it is necessary to model
formation and dissipation of dissolved gas for floods having
a recurrence interval of greater than 50 years.Please
refer to the Response to Comment I.60 for further discussion
of this subject.
COMMENT I.56:
"Page E-2-135:(viii)Total Dissolved Solids,Conductivity,
Significant Ions,Alkalinity,and Metals:Please refer to
our comments on pages E-2-34 and E-2-96."
RESPONSE:
Please refer to Responses to Comments I.21 and 1.41.
COMMENT I.57:
llPage E-2-146:(f)Instream Flow Uses:During 1982,ADF&G
documented chinook salmon spawning above the Devil Canyon
dam site at the confluence of and within two small clear
water tributaries.2-29/"
"2-29/See Footnote 2-2.[Footnote 2-2/ADF&G 1983.
Synopsis of the 1982 Aquatic Studies and Analysis of Fish
and Habitat Relationships.Prepared for the APA.]"
RESPONSE:
The FERC License Application states on the referenced page
(page E-2-146)that 11 •••the Devil Canyon and Devil Creek
rapids act as a natural barrier to most upstream fish
movement."The word "most"must be clearly understood.
Although the Alaska Department of Fish and Game did document
chinook salmon spawning above the Devil Canyon site,the
numbers observed must be placed into perspective.The total
number of spawners observed in 1982 above Devil Canyon was
11 fish,compared to an estimated escapement of about 1~,913
chinook past Curry Station.Based on these findings,the
statement that "most"fish do not migrate upstream of Devil
Canyon is correct.In fact,the statement should indicate
~"
~,
~,
RESPONSE TO COMMENT 1.57 (cont.):
that virtually all (99.9%)adult salmon spawn below Devil
Canyon.
REFERENCES
ADF&G,Susitna Hydro Aquatic Studies,Phase II Basic Data
Reports for 1982,5 Volumes (1983),previously submitted to
the FERC on October 31,1983.
Volume 2,Adult Anadromous Fish Studies (1983).
COMMENT 1.58:
"Page E-2-152:(v)Total Dissolved Gas Concentration:
Please refer to our comments on page E-2-132."
RESPONSE:-
Please refer to the Response to Comment 1.55.
-COMMENT 1.59:
"Page E-2-154:4.2.3 -Watana/Devil Canyon Operation:The
anticipated te5tiRg of the Devil Canyon turbines should be
,discussed.Potential impacts on water quality and quantity,
and mitigation for adverse impacts should be described."
-
-
-
RESPONSE:
Please refer to the Response to Comment B.12 for a
discussion of testing and commissioning of the Devil Canyon
units,and the potential downstream impacts.
COMMENT 1.60 :
"Page E-2-158 to 162:(iii)Floods:The discussions
concerning floods up to the probable maximum flood (PMF)
should examine the potential creation of supersaturated
dissolved gas and,through modeling,examine the fate of the
gas downstream.Please refer to our comments on page
E-2-132."
-.----=~------------~--------------------------
RESPONSE TO COMMENT 1.60:
The FERC License Application (page E-2-16l)indicates that
floods having recurrence intervals of less than or equal to
50 years would be released through the powerhouse and outlet
works cone valves,thus providing for minimal gas
supersaturation of the water released from Devil Canyon Dam.
The justification for using the 1:50 year flood is given in
the License Application (page B-2-19)as follows:
"On the basis of an evaluation of-the related impacts
and discussions with interested federal and state
agenci~s,spillway facilities were designed to limit
discharges of water from either Watana or Devil Canyon
that may become supersaturated with nitrogen to a
recurrence period of not less than 1:50 years."
As is discussed in the Response to Comment B.34,the
anticipated performance of the cone valves with respect to
preventing downstream nitrogen supersaturation was verified
through prototype tests at Lake Comanche and are documented
in a Lake Comanche Dissolved Nitrogen Study by Ecological
Analysts,Inc.Additionally,Acres American,Inc.has
indicated that the jet issuing from the cone valves would
plunge less than one foot into the tailwater and that the
expected supersaturation would thus be less than 3 percent.
To pass floods with recurrence intervals greater than 50
years,the spillway will be operated.Depending on the
dilution of spillway flow by flow through the cone valves
and powerhouse,gas supersaturation levels may increase
downstream of Devil Canyon Dam.This tendency would be
minimized by a specially designed dispersal-type flip bucket
for the spillway.Physical model studies will be utilized
in the design of the spillway and flip bucket.However,it
was judged unnecessary to model the gas saturation levels
occurring so infrequently.
Please also refer to the Response to Comment I.55.
REFERENCES
Ecological Analysts,Inc.,Lake Comanche Dissolved Nitrogen
Study (1982).
-
~,
,--.
--
-
-
-
RESPONSE TO COMMENT I.60 (cont.):
Acres American,Inc.,Nitrogen Supersaturation Studies
Memorandum (September 13,1982).
COMMENT I.61:
"Page E-2-164:(b)River Morphology:It is stated,'.••the
occurrences of high flows capable of initiating gravel bed
movement in the Susitna River above Talkeetna will be
increased.'To our knowledge the bedload and suspended
sediment studies to date have only examined general
morphological changes in post-versus pre-project conditions.
These studies should be extrapolated quantitatively to
existing,as well as potential fish habitats with regard to
spawning and rearing substrates.An analysis of the
potential reduction of spawning gravel with an examination
of long-term effects of removing spawnable substrate sources
above the dam sites should be initiated.The flows needed
to maintain slough,side channel,tributary mouths,and
mainstem spawning gravel should also be examined.ll
RESPONSE:
The statement that lithe occurrences of high flows capable of
initiating gravel bed movement in the Susitna River above
Talkeetna will be increased"refers to the first few years
after Devil Canyon becomes operational and is relative to
the flows occurring during watana operation.The flood
flows occurring during the first few years of Devil Canyon
will remain much lower than the natural flood flows.
The higher flood flows (relative to Watana operation)will
occur only during the late summer period after Watana
reservoir is filled.As energy demand increases,the flood
magnitude for a given recurrence interval will be reduced.
This is illustrated in FERC License Application
Figure E.2.199.After the first few years of Devil Canyon
operation,the occurrences of high flows will be similar to
those occurring during Watana operation.As stated in the
FERC License Application,the impacts described for Watana
operation will remain relevant.
---_._------'"'----------~._...,~--------'-------------------
RESPONSE TO COMMENT 1.61 (cont.):
A draft report on the reservoir and river sedimentation has
been completed.The final report is scheduled for release
in March 1984.To the extent possible,these studies have
quantitatively examined with-project morphological changes.
These changes are expected to result in a degradation of
approximately zero to 0.3 foot in the Devil Canyon to
Talkeetna reach.Refer to the Response to Comment C.45.
This is due to the armored condition of the mainstem in this
reach.
COMMENT 1.62:
IIPage E-2-164:Watana and Devil Canyon Reservoirs:
Paragraph 1:It is stated,'Since the available simulation
data ended at the end of FY 1981 (September 30,1981),mean
weekly flows from the Case C,2010 demand simulation were
used for the October to December period.'If it is possible
to simulate temperatures from flows in this manner we
recommend that flows and temperatures be simulated using the
inflow/outflow data for the 32 years of record.It should
be noted that the year modeled (water year 1981)was an
unusual year from several aspects.First,it was the only
year of the 15 simulated by AEIDC,through SNTEMP,
displaying a decrease in temperature from June to July.
2-30/Also,on page E-2-167 it is cited as the worst case
of-rhe 32 years of record in terms of frequency of release
and discharge through Devil Canyon.This confirms our view
that we need at least two years of input to DYRESM to allow
some understanding of post-project temperature impacts.1I
112-30/See Footnote 2-11.[2-11/AEIDC.1983.Examination
of Discharge and Temperature Changes due to the Proposed
Susitna Hydroelectric Project.Prepared for the APA.]II
RESPONSE:
Please refer to the Response to Comment B.6 in which
reservoir temperature simulation is outlined.The reservoir
temperature simulations are being carried out for three
years representing minimum,average and high releases (water
years 1974,1982 and 1981,respectively).Additional
simulations are being made for cold,average and warm
-
....
RESPONSE TO COMMENT I.62 (cont.):
winters for the ice process simulation studies.Simulating
the extreme hydrological events rather than meteorological
events is justified since under with-project conditions,the
hydrothermal characteristics of the river near the project
area will be modified to a certain extent.With the
moderating effect of the new reservoirs,the downstream
river temperature near the project area will not respond as
rapidly to the climatic changes.The inflow and outflow of
the reservoirs will play important roles in the modification
of the river temperatures.It is therefore considered more
appropriate that temperatures under with-project conditions
be examined based on the range of the inflow variations
instead of temperature variations.It is not practical to
simulate reservoir temperatures for the entire 32 years of
streamflow record because of insufficient meteorological and
water temperature data.Simulation of mean and extreme
events coupled with sound judgments will provide a
reasonable assessment of potential downstream impacts.
The Power Authority anticipates that the DEIS will summarize
and incorporate previous temperature modeling studies.
COMMENT 1.63:
npage E-2-167:Watana and Devil Canyon Reservoir:Paragraph
12:We gain the impression that releases of 12,000 to
15,000 cfs would be provided at Devil Canyon when
temperatures of 8°C occur.This would mean flows downstream
of Gold Creek of perhaps 13,000 to 17,000 cfs during July
and August;comparable to Case C-1,or Case C-2 flows.We
had previously understood this was not considered acceptable
by the applicant.The applicant should clarify this
apparent discrepancy.
"Figures E-2-215 and E-2-216 display the predicted ability
of the Devil Canyon intake facilities to match outflow
temperatures to inflow temperatures.It would be helpful to
also display pre-project temperatures on these figures."
RESPONSE:
The FERC License Application does not indicate that releases
of from 12,000 cfs to 15,000 cfs are unacceptable;only that
the target minimum flows given by Case C were jUdged to be
economically and environmentally acceptable.The License
Application states on page E-2-62:
RESPONSE TO COMMENT 1.63 (cont.):
"3.7 -Operational Flow Scenario Selection
"Based on the economic analysis discussed above,it was
judged that,while cases A,Al and A2 flows produced
essentially the same net benefit,the loss in net
benefits for Case C is of acceptable magnitude.The
loss associated with Case C1 is on the borderline
between acceptable and unacceptable.However,as
fishery and instream flow impacts (and hence mitigation
costs associated with the various flow scenarios)are
refined (see Table E.3.39 in Chapter 3),the potential
decrease in mitigation costs associated with higher
flows will not offset the loss in net benefits.Thus,
selecting a higher flow case such as C1 cannot be
justified by savings in mitigation costs.The loss in
net benefits associated with Cases C2 and Dare
considered unacceptable and the mitigation cost
reduction associated with these higher flows will not
bring them into the acceptable range."
Case C provides target minimum flows that must be released
from the most downstream reservoir as an impact mitigation
measure.This minimum release may be exceeded when the load
demand on the Project requires a greater discharge or if the
reservoirs are full and incoming flow must be passed to
prevent excessive dam surcharging and overtopping.The
paragraph cited in this Comment describes the means which
will be used to release flows to minimize temperature-
related impacts when the reservoirs are full.FERC License
Application Table E.2.S8 indicates that releases of this
nature would occur in 21 and 13 of the 32 years simulated
for the 2002 and 2010 project operation simulations,
respectively.
The selection of the target minimum flow is further
discussed in the License Application (page E-2-S9)as
follows:
"As flow is transferred from the winter to the
August-September time period for fishery and instream
flow mitigation purposes,the amount of usable energy
decreases.This decrease is not significant until the
flow provided at Gold Creek during August reaches the
12,000 to 14,000 cfs range.For a flow of 19,000 cfs
at Gold Creek,a flow scenario that represents minimum
downstream fishery impact,approximately 46 percent of
the potential project net benefits have been foregone."
~,
-
-
~!
I~
-
RESPONSE TO COMMENT 1.63 (cont.):
ADF&G did measure water temperatures on the Susitna River
above the mouth of Portage Creek (RM 148-8),for the period
of July 17,1981 to October 3,1981.These data are
reported in the Phase 1 Final Draft Report Volume 2,Part 1
Aquatic Habitat &Instream Flow Project,pages EC-88 through
EC-91.
REFERENCES
ADF&G,Susitna Hydro Aquatic Studies,Subtask 7.10 -Phase I
Final Draft Report,Aquatic Habitat and Instream Flow
Project,Volume 2,Part 1,pages EC-88 through EC-91 (1981).
COMMENT 1.64:
"Page E-2-167:Mainstem:The downstream temperature
predictions in this section do not agree with the recent
work by AEIDC.2-31/We assume since AEIDC is responsible
for this analysis-,-the model they are using is current and
the model in the application,HEATSIM,has been
discontinued.If this is the situation,we recommend that
those sections evaluating pre-versus post-project
downstream temperature shifts be revised to reflect the
current AEIDC work using SNTEMP.Additionally,replacement
of HEATSIM with SNTEMP should also mean a total replacement
of the ICESIM input data."
"2-31/See Footnote 2-11.[2-11/AEIDC.1983.Examination
of Discharge and Temperature Changes due to the Proposed
Susitna Hydroelectric Project.Prepared for the APA.]"
RESPONSE:
Please refer to the Response to Comment B.6 for a discussion
of the HEATSIM,ICESIM,SNTEMP and other models.Please
refer to the Response to Comment B.31 for a discussion of
the use of SNTEMP results with the ice process simulation
model.Note that AEIDC predicted temperatures on a monthly
average basis using SNTEMP and the temperature predictions
in the License Application were based on daily iterations.
---,------------------------------_......_---------
COMMENT I.6S:
"Page E-2-169:Sloughs:Please refer to our comments on
page E-2-40.We believe the relationship between the side
sloughs and the mainstem needs to be better defined.This
position is supported in the ADF&G Synopsis Report,2-32/
'Mainstem influence upon the side slough habitats •••is-not
presently well defined.Such influences are most likely
related to indirect impacts such as influences on rates of
upwelling water sources and winter overflow of the slough
heads caused by ice processes.'"
"2-32/See Footnote 2-2.[2-2/ADF&G 1983.Synopsis of the
198~Aquatic Studies and Analysis of Fish and Habitat
Relationships.Prepared for the APA."
RESPONSE:
See Response to Comment I.22.
COMMENT I.66:
"Page E-2-169:Talkeetna to Cook Inlet:The expected
downstream temperature changes should be discussed as well
as the downstream limits of these changes,by month."
RESPONSE:
Please refer to the Responses to Comments B.16,B.23 and
B.38 which discuss potential stream temperature changes in
the reach between the Chulitna-Susitna confluence and Cook
Inlet.
COMMENT I.67 :
"Page E-2-171:(v)Total Dissolved Gas Concentration:
According to the ADF&G Synopsis Report,2-33/'The
relatively low rates of dissipation of the-naturally
entrained dissolved gas in the reach of river below the
[Devil Canyon]rapids suggests that higher levels of
supersaturation that may be created by water spillage at
either of the proposed dams would not dissipate sufficiently
to reduce the hazard to either adult or juvenile chinook
-
.-
COMMENT 1.67 (cont.):
salmon as well as other species of salmon.'Please refer to
our comments on page E-2-132."
"2-33/See Footnote 2-2.[2-2/ADF&G 1983.Synopsis of the
198~Aquatic Studies and Analysis of Fish and Habitat
Relationships.Prepared for the APA.]"
RESPONSE:
Please refer to the Responses to Comments 1.55 and 1.60.
COMMENT 1.68:
-
-
-
-
"Page E-2-172:(vii)Total Dissolved Solids,Conductivity,
Alkalinity,Significant Ions and Metals:Please refer to
our comments on pages E-2-34 and E-2-96."
RESPONSE:
Please refer to the Responses to Comments I.21 and 1.41.
COMMENT 1.69:
"Page E-2-186:6.3 Mitigation-Watana Impoundment:Paragraph
4:The potential for,and anticipated extent of,'aggradation
of the Chulitna-Susitna confluence must be better defined,
along with many other parameters we have identified,prior
to discussions of mitigation needs at this site."
RESPONSE:
Please refer to the Responses to Comments B.14 and C.38
concerning potential aggradation at the Susitna-Chulitna
confluence area.
A reasonable discussio~of mitigation measures and an
estimate of the magnitude of those measures should not be
precluded where existing studies are not as precise or exact
as could be achieved through additional years of data
collection and study.The use of judgment along with
conservative estimates of impacts may be all that is
required to determine whether a potential impact exists and
whether a practical measure can be taken to mitigate for
that impact if,in fact,it occurs.Using this reasoning,
one can make conservative estimates of the costs of
~=_Wlll.__~_'-----,---------------
RESPONSE TO COMMENT I.69 (cont.):
mitigation measures and determine the effects on project
feasibility from environmental,engineering and economic
viewpoints.A more thorough discussion of this point is
contained in the Response to Comment C.31.
COMMENT 1.70:
"Chapter 3 generally fails to quantify the existing
resources,quantify the potential impacts,and provide
specific mitigation measures to deal with identified,
quantified,adverse impacts."
RESPONSE:
Exhibit E of the FERC License Application contained all data
on fish,wildlife and botanic resources that was available
in the project area at the time of preparation of the
License Application (see Responses to Comments C.63,C.64,
C.78,C.80 and C.89).Extensive quantitative data is
provided throughout the Exhibit.For example,the Botanical
Resources Section includes estimates of the number of acres
within various vegetation types based on vegetation mapping,
and estimates of the amount of each type that will be lost
to each project action.Baseline wildlife descriptions
present detailed quantitative data obtained during
project-related studies,as well as from relevant studies
outside the project area.The impact assessments also
provide considerable quantification.Exhibit E includes
over 200 tables and figures presenting detailed quantitative
data on botanical and wildlife resources.Quantitative
results from more recent field work have been and will
continue to be provided as they are received from the Alaska
Department of Fish and Game,University of Alaska,and other
contractors.
Refinement of proposed mitigation measures is continuing.
Additional documentation of the feasibility and probable
effectiveness of proposed wildlife and botanical mitigation
measures will be provided in a Mitigation Plan Update Report
in May 1984.This plan will include data presented in an
Impact Assessment Update and Refinement Report to be
prepared in April 1984.
Additional quantification and refinement of information on
fisheries resources has continued since submission of the
License Application.This information is available in
reports by the ADF&G (annual reports for the 1983 field
season),the Arctic Environmental Information and Data
~,
-
,....
1"'"'
-
,-
-
-
RESPONSE TO COMMENT I.70 (cont.):
Center (AEIDC)and other contractors.The ADF&G is in the
process of analyzing data and completing reports on the 1983
field season.These will be available in the spring of
1984.Information from these reports will be used by the
AEIDC in continuation of the documentation of impacts due
primarily to flow changes expected with the Project.The
results of these analyses are expected to be completed in
the summer of 1984.
The Power Authority anticipates that the DEIS will
incorporate available studies and will analyze significant
areas of uncertainty.
COMMENT I.71:
"Through consultation,the FWS can advise the applicant as
to the breadth of our responsibilities.In the area of
botanical resources,recent budget cutbacks have precluded
in depth analysis of existing data."
RESPONSE:
The Alaska Power Authority and its consultants are in
frequent contact with the USFWS and other federal and state
agencies.The Power Authority anticipates that the DEIS
will reasonably analyze existing data and will incorporate
data analyses prepared by the Power Authority and others.
COMMENT I.7'2::
"ProposE;d mitigation measures should have proven success in
Alaska,or in a similar environment.If proposals are not
proven,they should be demonstrated effective in the project
area.For example,hatchery propagation of grayling needs
to be demonstrated as an effective mitigation option since
previous grayling hatchery programs have not been
particularly successful in Alaska.Likewise,the proposed
slough modifications are unproven and should be demonstrated
effective in the Susitna River system.Proposed vegetation
manipulations have not been tested.The viability of
providing alternative raptor nest sites in presently
unoccupied areas has not been proven.The legality of such
measures to mitigate for bald eagle nests is untested."
RESPONSE TO COMMENT 1.72:
The mitigation measures or proposed plans presented by the
Power Authority in the FERC License Application are expected
to have a high degree of success.The statement that the
proposed slough modifications are unproven is not correct.
Numerous such modifications have been made throughout the
Pacific Northwest,Canada and Alaska and have been
successful.The reader is referred to the Response to
Comment B.9 for further details.References for many of
these successful modifications and techniques were provided
in the License Application (Chapter 3,Section 2.4).
Demonstration of slough modifications on the Susitna River
is not currently planned.The reasons for this are:
~,
1.Slough·modification is an existing technique (as
mentioned)that has had proven success.Therefore,it
is anticipated that similar success will occur on the
Susitna.
2.The costs involved in performing a demonstration
project are significant.
3.The slough modifications proposed in the License
Application are designed to alleviate potential impacts
on existing productive sloughs that occur as a result
of with-project conditions.Those conditions are not
presently available.Therefore,the Power Authority
has and will continue to develop information to predict
with-project conditions.The Power Authority firmly
believes that the plan (including alternatives)
presented will insure that the existing resources can
be protected or that alternative measures can be
implemented to insure a viable resource.
The Power Authority anticipates that the DEIS will discuss
the adequacy of proposed mitigation plans.
COMMENT 1.73:
"Fishery Resources of the Susitna River Drainage:
liThe current problems with the water quality computer
modeling efforts invalidates much of the fisheries
discussions.For example,if we lack a valid river
-
-I
-
-
COMMENT I.73 (cont.):
temperature model and/or ice process model,we cannot
confidently discuss potential impacts nor discuss viable
mitigation for these concerns."
RESPONSE:
Please refer to the Response to Comment B.6 for a discussion
of the models in use and their validity.
COMMENT I.74:
"Fishery Resources of the Susitna River Drainage:
"We continue to lack specificity on the mitigation
proposals.Mechanical manipulation of sloughs is being
proposed.This section should describe specifically being
proposed and which sloughs,side channels,and mainstem
reaches are proposed for alteration.There is no indication
as to the overall effectiveness of such measures."
RESPONSE:
The mitigation plan presented in the FERC License
Application does provide sufficient specificity to elicit
more than just general comments from the resource agencies.
The Power Authority has clearly presented a plan that
employs proven measures and is designed to be highly
effective in maintaining the existing resources or ensuring
that alternative measures can be implemented to insure a
viable resource.Ongoing studies are designed to refine
existing information in order that final detailed designs
for mitigative measures can be developed.The final
selection and design of mitigation measures will be derived
in consultation with the resource agencies.
See the Responses to Comments B.9 and I.72 for additional
discussion.
~~-~---------
-
COMMENT I.75:
"Fishery Resources of the Susitna River Drainage:
"The significance of the reach below the Chulitna River
confluence should be determined.At present,the number of
fish using this lower reach,other than for migration,is
unknown.We do not believe the fishery impacts will cease
at the Chulitna River (please refer to our comments on page
E-3-100).Studies should be undertaken to examine the
resources of this lower reach and to examine potential
impacts and determine mitigation needs.II
RESPONSE:
It is incorrect to state that little is known about the
fishery resources downstream of Talkeetna.Considerable
data are available in the AD'&G basic data reports for the
1981 and 1982 field seasons and in the ADF&G 1983 synopsis
report.All of these documents have been transmitted to the
FERC for use in developing the Draft Environmental Impact
Statement.Some of this information has been summarized in
the Responses to Comments B.8,I.98 and I.99.Fish habitat,
resident fish and anadromous fish studies have also provided
information on fish resources in the lower river.Refer to
ADF&G's 1978 Preliminary Environmental Assessment of
Hydroelectric Development on the Susitna River.The ADF&G
FY 1984 Plan of Study also provides information on the
planned aquatic studies program.
REFERENCES
ADF&G,Preliminary Environmental Assessment of Hydroelectric
Development on the Susitna River (1978).
ADF&G,Summary of Preliminary Plans for FY 1984 Aquatic
Studies Program Activities by Habitat Type and River Mile.
COMMENT I.76:
IIBotanical Resources
IIThis section has been considerably improved over the
November 15,1982 draft license application.We appreciate
the incorporation of our comments on the draft,most notably
with regard to baseline sections.1I
RESPONSE TO COMMENT 1.76:
Comment noted.
COMMENT 1.77:
"Botanical Resources
"Although the impacts section now identifies the full range
of vegetation impact issues,there is no estimate of the
size of areas which may be potentially affected by changes
in vegetation cover.Refinement of the vegetation map to
better relate it to wildlife habitat is necessary before the
impacts analysis can be completed.Information is then
needed on the tradeoffs relative to fish,wildlife,and
botanical impacts,as well as cost and design considerations
in the siting of project support facilities,roads,and
transmission lines."
RESPONSE:
Quantification of areas in which vegetation cover will be
lost or significantly altered is found throughout the FERC
License Application Botanical Resources text and tables.
Areas to be affected by changes in vegetation cover as a
result of facility construction and operation are quantified
in Exhibit E,on FERC License Application pages E-3-276
through E-3-278.Other areas will be subject to changes of
vegetation cover as a result of dynamic processes occurring
along roads,the impoundment areas,and the downstream
floodplain.Further attention is being given to the
quantification of the latter areas during impact assessment
refinement.
COMMENT 1.78 :
"Botanical Resources
"Three other concerns with the impacts section are:
(I)Incorrect assessment of wetlands (see comments on
Section 3.2.3,3.3);
(2)Incompatibility of vegetation typing within the
different transmission corridor segments (see
comments on Section 3.2.2{e),and 3.3);and
(3)Calculation errors in summing areas of each
vegetation type affected by the transmission
corridor (see comments on Table E.3.86)."
~,
,~
-
RESPONSE TO COMMENT 1.78:
This Comment references concerns which are more specifically
stated elsewhere in the material provided by the Department
of Interior.For specific discussion of these aspects,
refer to the appropriate responses as follows:
1.Wetlands--see the Response to Comment 1.330;
2.Vegetation typing--see the Response to Comment 1.327;
and
3.Tables E.3.86--see the Response to Comment 1.419.
COMMENT 1.79:
"Botanical Resources
liThe Mitigation Plan is considerably improved over the draft
license application;however,it is still incomplete and too
general.Implementation,construction,and operation
schedules are not clear for many recommended mitigation
measures (e.g.land acquisition and management).
Incorporation of recommended mitigation measures into
project plans is uncertain (e.g.construction techniques,
limitations on spoil areas,etc.).Neither replacement
lands nor habitat manipulations have been identified as to
suitable size,location or type.Moreover,replacement
lands and habitat manipulations cannot be realistically
identified until:
(1)Moose carrying capacity as well as associated
browse,and vegetation mapping studies are
completed;
(2)Appropriate wetlands interpretations are made;
(3)Possible mitigation lands are identified,their
potential mitigation benefits calculated,and
their availability determined."
RESPONSE:
The Power Authority continues to update and refine its
mitigation planning based upon more complete data and
continuing analysis.The mitigation plans presented in the
FERC License Application will undergo considerable
refinement before being finalized.
RESPONSE TO COMMENT I.79 (cont.):
The Power Authority also anticipates that the DEIS will
identify reasonable mitigaton options with appropriate
specificity.
COMMENT I.80:
"Botanical Resources
"Numerous general references are made to browse habitat
improvement techniques,land acquisition for habitat
management,and increasing browse by clearing or prescribed
burning of forests.However,specific information on the
potential benefits,time-frames,and suitable vegetation
cover types for controlled burning,clearing,and crushing
are not provided.The applicant had indicated that such
information would be included in Section 3.4.2 in response
to our original comments (Chapter 11,W-3-183)."
RESPONSE:
Because there is a considerable amount of published and
unpublished information on habitat enhancement methods
applicable to the Susitna River Basin that has not been
reviewed and synthesized,it was decided that review should
be conducted.This review of habitat enhancement methods
has been initiated and a report is scheduled to be available
in April 1984.A study has also been conducted over the
past several months to identify candidate lands for moose
habitat enhancement based on criteria developed with and
data collected by the Alaska Department of Fish &Game.The
Alaska Power Authority has also been working closely with
the Alaska Department of Natural Resources'Division of Land
and Water Management and jointly have identified
approximately 500,000 acres of candidate land.This
candidate Mitigation Lands Report will be available in
February 1984.These two documents will be used to refine
mitigation planning,the status of which will be presented
in a Mitigation Plan Refinement Report scheduled to be
available in late May 1984.
COMMENT I.81:
"Botanical Resources
"We believe that mitigation agreements should be worked out
with applicable landowners and incorporated into project
licensing.Otherwise,there is no guarantee that necessary
~',
~:
-
-
--
COMMENT 1.81 (cont.):
management polices (e.g.restrictions on use of project
access roads and off-road or all terrain vehicles,habitat
manipulations,control of other uses,etc.)will be adopted.
Our main concern with the Mitigation Plan stem from its
development within a short time period which allowed no
agency consultation before the formal license review.There
is need for joint efforts by the resource agencies and
principle study investigators,in conjunction with the
applicant's consultants,to:(1)clarify issues;(2)analyze
mitigation options;(3)agree on remaining data gaps and how
to fill them;and (4)modify this proposal into a mutually
acceptable,effective Mitigation Plan.Such a procedure and
useful dialogues among the different resource study groups
were initiated during the August 1982 Adaptive Environmental
Assessment (AEA)workshop and February 28 -March 2,1983
follow-up modeling session.Much of the progress made then
relative to identifying data gaps has since been lost due to
delays and budget cuts."
RESPONSE:
Please refer to the Responses to Comments I.301B and 1.494.
In addition,please refer to the Response to Comments A.10,
B.42,F.1,F.6 and F.28.
FERC License Application Chapter 11,Volumes lOA and lOB
document the extensive consultation and coordination which
dates back to before 1980 between the Power Authority and
other agencies.Even earlier consultation is documented in
the Final Environmental Impact Statement prepared by the
U.S.Army Corps of Engineers for their Susitna Hydroelectric
Project (1977).Consultation since the distribution of the
Draft FERC License Application is summarized below.
Federal,state and local agency personnel including J.Hall,
L.Corin,G.Stackhouse and A.Rappoport from the USFWS
participated in a series of workshops from November 29,1982
through December 2,1982.The Draft Exhibit E to the
License Application,mailed to agencies on November 15,1982
was reviewed in detail by its authors at this workshop.
This provided an early opportunity for agency review of
mitigation plans.Informal comments received during the
workshop and the formal agency review comments (see Chapter
11,Volume lOB of the License Application)were used in
refining the Mitigation Plan presented in the Application
submitted to the FERC on February 28,1983.
On March 3,1983,preview copies of the 8000 page FERC
License Application were distributed to interested agencies.
RESPONSE TO COMMENT 1.81 (cont.):
The USFWS initially received two,and then a third copy was
provided to facilitate review by their Western Alaska
Ecological Services office.Formal acceptance of the
License Application was delayed until July 12,1983 and
agencies formally received additional review copies in early
August.
Workshops reviewing FY 84 Plan studies were held in July
1983 in the following areas:Aquatic Biology,July 18;
Socioeconomic,July 19;Terrestrial,July 20;and
Archaeology,July 22,1983.Federal,state and local
agencies were invited to attend and received copies of the
plans of study.
In September 1983,agencies were invited to see the project
area and review field programs with the investigators.
NMFS,DNR,DEC and FWS (Mr.G.Stackhouse)participated in
these trips on October 5 and 6,1983.
Concurrent with meetings,workshops and field trips,the
Power Authority has continually distributed to resource
agencies technical reports on various topics.For example,
during the 1983 calendar year,the following reports were
provided to various agencies:
ADF&G
ADF&G
AEIDC
Game Reports for 1982-83
Data Reports,Habitat
Synthesis Report,Winter
Program Report
Temperature and Stage Reports
With respect to the need for cooperative efforts between the
resource agencies and principle study investigators to
develop a mutually acceptable,effective Mitigation Plan,
please refer to Response to Comment F.l and to the
description of the Susitna Settlement Process.
REFERENCES
U.S.Army Corps of Engineers,Office of the Chief Engineer,
Final Environmental Impact Statement,Hydroelectric Power
Development,Upper Susitna River Basin,South-central
Railbelt Area,Alaska (January 1977t.~,
-
COMMENT 1.82:
"Botanical Resources
"We remain concerned that the cumulative impacts of both
reservoir sites,borrow and spoil sites,access roads,
transmission corridors and potential indirect vegetation
losses are not addressed in accordance with our comments on
the draft (Chapter 11,W-3-114 and W-3-149)."
RESPONSE:
The effects of cumulative project-induced impacts on
wildlife are considered in the Impact Summary and Mitigation
Plan Sections of FERC License Application,Exhibit E,
Chapter 3 (Sections 4.3.5 and 4.4 respectively).Section
4.3.5 addresses the cumulative impacts of the entire project
on populations,species and communities.Cumulative impacts
on wildlife are also considered in the mitigation options
presented in Section 4.4.Throughout the remainder of the
text,specifically identified project effects are discussed
individually in order to facilitate accurate assessment of
each impact mechanism for each species or group.Without
prior consideration and quantification of individual impact
mechanisms where feasible,subsequent assessment of
cumulative impacts of the entire project cannot be
accomplished.The ongoing refinement of impact assessment
and mitigation planning is advancing our predictive
capability with respect to cumulative effects.Results of
this refinement process will be presented in the Impact
Assessment Update and Refinement Report to be completed in
April 1984.
COMMENT 1.83:
"Wildlife Resources
"A concern that we have with the discussion of impacts is
the repeated inference that wildlife will generally move to
adjacent areas as project area habitats are altered or
destroyed.Little is known of adjacent habitat values and
whether those habitats are already fully utilized or even
suitable for the species of interest are minimal.A further
problem is that no source is provided for many of the
conclusions presented here."
RESPONSE TO COMMENT I.83:
The Power Authority disagrees that Section 4.3 of Exhibit E
contains "the repeated in-ference that wildlife will
generally move to adjacent areas as project area habitats
are altered or destroyed."Our re-reading of the wildlife
impact discussion indicates no such simplistic inference;
such a conclusion on the part of the reader was certainly
not intended by the authors.
In the discussions of impacts to moose presented in FERC
License Application Chapter 3,Sections 4.3.1(a)and
4.3.2(a),31 impact mechanisms are specifically identified.
FERC License Application page E-3-397,paragraph 2,states
that
"The direct impacts that will most severely affect
moose populations in the middle Susitna basin are,in
order of decreasing severity:permanent loss of
habitat,blockage of seasonal migration routes,
disturbance by machines and humans,hazards associated
with the drawdown zone'and alteration of habitat.
Moose in the lower basin will be affected mostly by
alteration of habitat."
FERC License Application page E-3-398,paragraph 3,states
"There is no question that moose will be affected by
this loss of habitat:browse availability will be
reduced;winter range,calving areas and breeding areas
will be lost;movements may be altered as a result of
behavioral or physical barriers;animals will be more
vulnerable to predation and hunting (as a result of the
loss of cover);and repeated human and mechanical
disturbances may preclude use of some areas by moose .-"
These introductory statements and subsequent,more detailed
supporting discussions clearly demonstrate that habitat
destruction and alteration,along with blockage of movement,
are considered to be the most severe impact mechanisms that
will affect moose in the middle and lower Susitna Basins.
There is no indication in the moose impact discussions that
individual animals will merely relocate from areas of
habitat loss to surrounding lands,where they will continue
to survive as before.The impact discussions place great
emphasis on the importance of elevation differences and
terrain complexity in limiting the occurrence of suitable
habitat within and around the project area.The importance
~\
~r,
-
.-
....
RESPONSE TO COMMENT I.83 (cont.):
of winter habitat as a population-limiting factor,and the
dependence of winter habitat availability on elevation,
slope and snow depth,are explained to be especially
important in this regard.The impoundment areas in
particular are shown to provide a major source of winter
habitat which will be unavailable following clearing and
flooding.For example,FERC License Application page
E-3-400,paragraph 2,states
"Because low elevation riparian shrub,deciduous
forest,coniferous forest and muskeg habitats will not
be available in areas adjacent to the impoundment,the
removal of these habitats by initial clearing
activities and later flooding will deprive moose of a
large area of high quality winter range.Assuming that
bottomland browse resources throughout the middle
Susitna basin are fully utilized by moose in severe
winters,clearing and flooding of the impoundment will
force moose to depend on and likely over-utilize the
remaining winter range.Moose which never use the
impoundment area will also be affected by
over-utilization of these adjacent areas.Increased
mortality would be expected caused by starvation and
increased predation,whereas natality may decrease
because of the poor physical condition of the moose."
The reviewer states "Little is known of adjacent habitat
values and (data on)whether those habitats are already
fully utilized or even suitable for the species of interest
are minimal.II Again,this implies an expectation on the
part of the authors that individual animals will simply
relocate to surrounding areas about which little is known
from the standpoint of habitat suitability of'utilization.
Exhibit E states no such expectation and provides
substantive information on habitat requirements and area
limitations for the wildlife species discussed.For
example,the impact assessment for moose is based on
state-of-the-art modeling for carrying capacity and
population dynamics,as explained in FERC License
Application Section 4.3.1(a)(iii),pages E-3-412 through
E-3-414,and in the Response to Comment F.42.A pilot
browse study was conducted during the summer of 1983 to test
alternative methods for quantification of current annual
growth by height,density,dry weight,stem diameter and
other parameters.A report on this study will be available
in February 1984.
Although the above examples discuss moose,we are not aware
of other places in Exhibit E where it is indicated that
RESPONSE TO COMMENT I.83 (cont.):
other wildlife species will simply redistribute themselves
without detriment during and after project construction.
Nor are we aware of ,places where Exhibit E fails to discuss
current,area-specific information on habitat utilization.
For example,distribution and movement patterns,habitat use
and population characteristics of caribou in and around the
project area are discussed in FERC License Application
Section 4.2.l(b),pages E-3-3l8 through E-3-32S.FERC
License Application Section 4.3.3(b),pages E-3-479 through
E-3-482,discusses probable caribou impacts of the access
route from the Denali Highway.This discussion opens by
stating "The access road between the Denali Highway and the
two damsites is likely to have a substantial effect on
caribou movements."The ensuing discussion cites numerous
studies on individual and population-level responses of
caribou to human structures and activities~The discussion
concludes that,
"The Susitna-Nenana subherd is resident in the access
road area and,although the rate of exchange of
individuals with the main herd is unknown,the presence
of the Watana impoundment in conjunction with heavy
hunting pressure will probably result in a substantial
decrease in this subherd."
In the case of the black bear,Exhibit E clearly states
that,
"After filling,it is unlikely that a viable resident
black bear population will exist upstream from Watana
Creek.Transient bears may use areas adjacent to the
impoundment,and a few black bears may reside there
year-round.However,the lack of denning areas and
adequate forest stands near the remaining food supplies
will severely limit the resident population"(FERC
License Application Section 4.3.l(e)(ii),pages E-3-428
and E-3-429).
In the Impact Summary (FERC License Application Section
4.3.S(a),pages E-3-S02 and E-3-S03),this conclusion is
reiterated:
"Black bears will be severely affected by the project,
primarily as a result of inundation of denning and
feeding habitat upstream from Tsusena Creek.The
Watana reservoir will inundate approximately 69 percent
of the denning habitat occurring in that area (black
bears are restricted to the band of forest along the
river),whereas about 6 percent of the denning habitat
,~
~,
-
-
-
.-
RESPONSE TO COMMENT I.83 (cont.):
in the Devil Canyon reservoir vicinity will be lost.
Additional denning areas will be impacted by road and
transmission line construction.The resident
population of about 30-50 bears between the Tyone River
and Tsusena Creek will probably be eliminated.1I
The summary concludes:
IICumulative impacts of mortality from hunting,
increased encounters with brown bears,and bear/human
conflicts,in concert with loss of denning and feeding
habitats due to facilities and disturbance,will
greatly reduce the black bear population in the middle.
basin."
Again,there is no indication that bears will relocate to
adjacent areas;the fact that they are largely confined to a
narrow band of limiting habitat which will be lost as a
result of impoundment is clearly stated.It is known,and
stated,that habitat in neighboring areas is unsuitable.
Although the above examples apply to large mammals with
relatively low population densities,simila~treatment is
given to other species with greater population densities.
Unlike most mammals,birds are highly mobile and may
disperse great distances should disturbances or habitat loss
affect traditional use areas.For individual birds directly
affected by impoundment filling,dispersal to other suitable
habitats is highly probable.Incorporation of these
directly affected birds into surrounding bird populations is
likely for most species.In far northern regions,the
winter season represents the time of greatest stress on
resident birds.At this time,food is much more limited
than in summer and many resident woodpeckers and passerines
(e.g.,chickadees,woodpeckers)maintain enlarged feeding
territories to compensate for this paucity of food (Conner
1981).For these 10-12 species,individuals directly
displaced by habitat losses would likely establish new
breeding territories in summer;but if winter populations
are presently saturated,some absolute decreases in area
populations proportional to the amount of habitat loss could
occur within several years.For the remaining migratory
birds (35 species)or those that wander erratically in
winter (10 species),displacement to other suitable breeding
habitats will probably be the greatest level of impact
incurred.The Susitna Hydroelectric Project lies mostly
within the boreal forest zone,probably the most extensive,
relatively uniform avian habitat in North America.Many
migrant passerines breeding in this zone winter in the
'WIh J
RESPONSE TO COMMENT 1.83 (cont.):
tropical regions of Central America and northern South
America (A.O.U.1983).Here they compete with large
populations of resident birds in a habitat much more limited
in size than the boreal forest zone.Population regulation
through competition for food and space,if important as a
limiting factor to these passerine populations,probably
occurs at this season.Therefore it appears unlikely that
populations of these species are saturated on the expansive
breeding grounds,where absolute losses of habitat would be
less important than on the more crowded wintering grounds.
Therefore,"changes in the distribution and relative
abundance of species in the areal!will occur,with probably
little impact to some species (migrants),but some local
population declines for other species (residents).
REFERENCES
Conner,R.N.,Seasonal Changes in Woodpecker Foraging
Patterns,Auk 98(3):562-570 (1983).
American Ornithologists'Union (A.O.D.),Check-list of North
American Birds (6th Ed.)(1983).
COMMENT 1.84:
"Wildlife Resources
The majority of recommended compensation measures are
generally insignificant and unsubstantiated.For example:
increases in ungulates through browse improvement would
compensate for losses to their predators (bears and wolves);
carrion from increased road mortality and impoundment
hazards would compensate for wolverine habitat losses;
salmon benefitting through slough modifications would
compensate for decreases in other bear foods;flow
regulation resulting in downstream habitat improvement
compensates for upstream losses of moose and beaver
habitats;and general habitat improvements for larger
species would compensate for small birds and small mammal
losses."
RESPONSE:
The examples provided by the reviewer are not representative
of the full range of mitigation measures presented in the 23
mitigation plans for wildlife (FERC License Application
~l
,.."
-
-
.-
.....
RESPONSE TO COMMENT 1.84 (cont.):
Exhibit E,Chapter 3,Section 4.4.2(b),pages E-3-525
through E-3-540).Indeed,the examples cited are not really
compensation measures at all.Rather,they are probable
compensating factors likely to occur without deliberate,
species-specific intervention.Because they may affect the
total picture of cumulative impacts on certain species,
these factors should be taken into account and are noted for
that reason .
COMMENT 1.85:
"Page E-3-24:-Incubation and Emergence:Based upon their
apparent inability to distinguish upper Susitna River
sockeye salmon stocks from Talkeetna or Chulitna River
drainage stocks,Bernard et ale (1983 3F-l/concluded that
fry do not rear above Curry Station (-River Mile (RM)120.5).
The outmigration data from 1982 appears to support this
hypothesis.However,outmigration may have been
substantially complete when the outmigration trap was
installed (June 18).Growth exhibited by juveniles
collected in the trap throughout the summer·and the
observations of outmigrants during the spring of 1983 at
slough #11 indicated important sockeye salmon rearing
habitat may be found in the upper SusitnaRiver.3F-2/
Further investigation appears warranted in regard to sockeye
salmon rearing."
"3F-l/Bernard,D.R.,et al.1983.Comparison of Scale
Patterns from Sockeye Salmon Sampled from Different Rivers
within the Susitna River Watershed in 1982.ADF&G.Div of
Com.Fish."
"3F-2/ADF&G.1983.Synopsis of the 1982 Aquatic Studies
and Analysis of Fish and Habitat Relationships.Prepared
for the APA.ll
RESPONSE:
The document (ADF&G,1983 Synopsis Report)referenced by the
commentor does not include data collected in 1983.
Additional studies by the Alaska Department of Fish and Game
were initiated in 1983 to investigate this issue.The
--_._---_._._--------------------------------
RESPONSE TO COMMENT I.85 (cont.):
report on initial results should be available in late spring
1984.See Response to Comment I.95 for additional details.
REFERENCES
ADF&G,Susitna Hydro Aquatic Studies,Phase II Basic Data
Reports for 1982,5 Volumes (1983),previously submitted to
the FERC on October 31,1983.
Synopsis of the 1982 Aquatic Studies and Analysis of
Fish and Habitat Relationship (1983).
COMMENT I.86:
"Page E-3-32:Juvenile Behavior:Juvenile chum salmon are
generally thought to outmigrate quite soon after emerging.
Dat~collected by ADF&G in 1982 ~/indicate chum salmon
juveniles spend up to three months in the Susitna River.
This rearing period may be important since the Susitna River
estuary is very turbid and may not provide adequate rearing
habitat.The density patterns observed by ADF&G suggests
juvenile chums prefer lower velocity areas and are
associated with backwater areas near the mouths of sloughs
and clear water tributaries.3F-4/The report should be
expanded to include a discussion of chum salmon rearing.
The implications of the ADF&G finding should be discussed in
the analysis of post-proj ect impacts.II
l'3F-3/See Footnote 3F-2.[Footnote 3F-2/ADF&G.1983.
Synopsis of the 1982 Aquatic Studies and-Analysis of Fish
and Habitat Relationships.Prepared for the APA.
"3F-i/See Footnote 3F-2,supra."
RESPONSE:
The results of Alaska Department of Fish and Game studies
have shown that chum may spend as much as three months in
freshwater,prior to outmigrating.The Syno~sis Report
(ADF&G 1983)referenced by the U.S.Fish and Wildlife
Service is only a portion of the information currently
available on rearing habitats in the Susitna River.
Extensive information is also available in:
~,
~I
RESPONSE TO COMMENT I.86 (cont.):....
Alaska Department of Fish and Game,Susitna Hydro
Aquatic Studies Phase II Basic Data Report,Volume 3,
(1983)Resident and Juvenile Anadromous Fish Studies on
the Susitna River below Devil Canyon,1982,Parts I and
II plus appendices.
Alaska Department of Fish and Game,Subtask 7.10,
Phase I Final Draft Report Juvenile Anadromous Fish
Study on the Lower Susitna River (1982),ADF&G/SuHydro,
1981.
Alaska Department of Fish and Game,Preliminary
Environmental Assessment of Hydroelectric Development
on the Susitna River (1978),prepared for the U.S.Fish
and Wildlife Service.
,-
\~
.....
REFERENCES
ADF&G,Susitna Hydro Aquatic Studies,Phase II Basic Data
Reports for 1982,5 Volumes (1983),previously submitted to
the FERC on October 31,1983.
Synopsis of the 1982 Aquatic Studies and Analysis of
Fish and Habitat Relationship (1983).
COMMENT I.87:
"Page E-3-41 (v)Burbot:The ADF&G Synopsis Report l!:=.2./
states that burbot habitat shows a strong correlation with
turbidity.These findings should be discussed in light of
the post-project implications on turbidity."
"3F-S/See Footnote 3F-2.[Footnote 3F-2/ADF&G.1983.
Synopsis of the 1982 Aquatic Studies and-Analysis of Fish
and Habitat Relationships.Prepared for the APA.]"
RESPONSE:
Many fish species which are adapted to turbid waters are
probably also adapted to low light intensities.The burbot
is found to be active in conditions of low light
intensities,but not necessarily high turbidity conditions,
in many waters of North America (Scott and Crossman 1973).
The burbot is active in low light conditions and even shows
--_~~_'----,m ,_
RESPONSE TO COMMENT 1.87 (cont.):
an inversion of circadian rhythm patterns -becoming active
by day -during the long diurnal periods of winter darkness
near the Arctic Circle (Schwassermann 1980).Therefore,it
is unclear if the correlation reported in the ADF&G 1983
Synopsis Report is directly related to turbidity per se,or
to the decreased light associated with turbid conditions.
Based on the above-cited references,the latter would seem
to be the case.
Since turbidities in the mainstem Susitna will be decreased
during the summer months,it may be expected that,at least
above Talkeetna,light penetration may be somewhat improved.
Below Talkeetna,the influence of the Chulitna and Talkeetna
Rivers may significantly reduce increased light penetration.
In ice-covered reaches of the river,winter increases in
turbidity may not significantly decrease light compared to
the decreases from ice and snow cover.
The effects of changed light intensities on the ecology of
Susitna River burbot are presently unknown.
REFERENCES
Scott,W.B.and E.J.Crossman,Freshwater Fishes of
Canada,Bulletin 184,Fisheries Research Board of Canada,
Ottawa (1983).
Schwasser.mann,H.0.,Biological Rhythms:Their Adaptive
Significance,in Environmental Physiology of Fishes,
M.A.Ali,ed.(1980).
COMMENT 1.88:
Page E-3-42:(vi)Round Whitefish:The ADF&G data indicate
that significant numbers of round whitefish remain in the
mainstem of the Susitna River.They are associated with the
mouths of tributaries and turbidity mixing zones of clear
water sloughs.3F-6/"
"3F-6/See Footnote 3F-2.[Footnote 3F-2/ADF&G.1983.
Synopsis of the 1982 Aquatic Studies and Analysis of Fish
and Habitat Relationships.Prepared for the APA.]"
-
-
~,
RESPONSE TO COMMENT I.88:
The FERC License Application states that "The presence of
whitefish near the mouths of tributary streams in the March
to May period after none had been caught in the same
locations between November-February,indicates a general
pattern of movement into the various tributaries in the
spring (ADF&G 1981e)."
Further studies by ADF&G (1983)show that,in addition to
the tributaries,round whitefish are associated with the
mouths of tributaries.They also state that 1I •••round
whitefish •••were all more likely to be found in the mainstem
in spring and fall than summer.These species (including
round whitefish)apparently use tributaries and sloughs in
the summer,the mainstem in the spring and fall during
migrations,and the mainstem in winter as over-wintering
habitat."
Accordingly,the License Application stated that,in
general,the association of round whitefish with tributary
mouths is associated with their movement into the various
tributaries.
REFERENCES
ADF&G,Susitna Hydro Aquatic Studies,Phase II Basic Data
Reports for 1982,5 Volumes (1983),previously submitted to
the FERC on October 31,1983.
Synopsis of the 1982 Aquatic Studies and Analysis of
Fish and Habitat Relationship,pages G-20 and G-21
(1983).
Alaska Department of Fish and Game,Susitna Hydro Aquatic
Studies Phase I Final Draft Report,Resident Fish
Investigation on the Lower Susitna River,(1981e).
COMMENT I.89:
"Page E-3-62:(i)Mainstem and Side Channels:We suspect
the Susitna-Chulitna confluence area is important to the
anadromous fisheries for rearing and milling.We suspect
chinook,coho,sockeye,and chum rearing and/or
overwintering may occur here.The importance of the
confluence area to the fisheries of the Chulitna and the
COMMENT 1.89 (cont.):
Talkeetna Rivers are not known since fishery runs into these
two river systems were not included in the ADF&G studies.
Post-project winter flows would be approximately four times
greater than pre-project flows;winter turbidity would be
noticeably higher (affecting feeding and predator-prey
relationships);aggradation is probable;and temperature and
ice processes would probably be dramatically changed from
pre-project conditions.We recommend that the value of this
area be evaluated and the post-project impacts assessed."
RESPONSE:
Based on the data presently available,some locations within
the confluence area have been shown to be utilized by
juvenile salmon for overwintering and rearing.Most notably
are Rabideaux Slough,Sunshine Slough and Birch Creek
Slough.It is important to recognize that in the confluence
area,the river is a highly unstable braided river reach.
Year to year differences in available habitat are great.
See Responses to Comments 1.99 and B.S.
We assume that the suspicion expressed by the commentor is
based mainly on circumstantial evidence.Adult salmon which
enter the confluence area spawn primarily in the Chulitna
and Talkeetna river basins.Outmigrating juveniles from the
Chulitna and Talkeetna and upper Susitna drainage certainly
must pass through this reach and may on occasion result in
high concentrations of juveniles in the area.Some juvenile
rearing habitats have been evaluated in the reach as cited
above.
It should be noted that under with-project conditions during
the winter,the increased discharge from the Susitna River
.could quite conceivably enhance overwintering habitat in the
confluence area.The increased discharge from the Susitna
River will create larger breakwater zones in the mouths of
the Talkeetna and Chulitna Rivers which under natural
conditions are either nonexistant or are limited in extent.
Winter turbidity effects on juvenile overwintering habitats
and predatory-prey relationships are not anticipated to be
significant.Increased turbidity may provide additional
cover for juvenile salmon thereby enhancing survivorship.
Anticipated temperature changes and ice process changes
could result in an enhancement of the overwintering
habitats.
Aggradation of bedload and suspended sediments in the
confluence area will occur primarily during the summer,
openwater period.
~I
COMMENT r.90 :
"Page E-3-62:Salmon:The importance of the reach between
the Yentna River and the Susitna River above the Chulitna
and Talkeetna Rivers to anadromous fisheries is presently
unknown.The Yentna River Station allows ADF&G to separate
out the Yentna River run from the Susitna River run upstream
from this point.Lack of stations on the Chulitna and
Talkeetna Rivers prevents determining the importance of
these two river systems to the overall Susitna River run.
We recommend that stations be established on the Chulitna
and Talkeetna Rivers."
RESPONSE:
The Power Authority does not agree with the recommendation
to establish monitoring stations on the Talkeetna and
Chulitna Rivers.The importance of these two rivers for
salmon spawning is not questioned.Approximately 90 percent
of the salmon escapement past the Sunshine Station enter
either the Chulitna or Talkeetna Rivers.However,since the
project will not affect either of these rivers,it is
sufficient to obtain a composite estimate of the salmon
escapement to the rivers.
COMMENT r.91:
"Page E-3-80:(ii)Construction and Operation of Watana
Camp,Village and Airstrip:Paragraph 1:Justification for
separating the construction camp,construction village and
permanent townsite should be provided.Combining these
developments would help to minimize adverse impacts,
particularly to botanical and wildlife resources but also to
aquatic resources.We suggest that serious consideration be
given to combining these facilities."
RESPONSE:
The Watana Construction Camp will be a self-sufficient
installation for housing project construction personnel who
are on single status.The Construction Village will
likewise be a self-sufficient installation for housing
construction-related personnel and their dependents.The
overriding criteria for separating these two installations
is the mitigation of sociological and psychological factors.
Adherence to this criterion becomes more important when the
construction site is located remote from urban areas and in
zones of hostile climatic conditions.
---------";"'-_.._-----------------------~------------------
RESPONSE TO COMMENT I.91 (cont.):
The Construction Village and Permanent Village are
contiguous.The latter will provide housing for personnel
involved in the operation of the Project and their
dependents.The Permanent Village will conceptually be the
same as other rural hamlets in Alaska.The Construction
Village will have a useful life consistent with the
construction period,whereas the Permanent Village will
exist as long as the Project is in operation.The
development of the Construction Camp and Village will be one
of the first construction activities.The Permanent Village
will not be constructed until the project is nearing
completion and the need is established for operating
personnel orientation and training.At this time,housing
for both construction personnel and their dependents,as
well as operating personnel and their dependents,will be
necessary.It is conceivable that some facilities of a
permanent nature may be constructed in the Construction
Village for later utilization in the Permanent Village.
This possibility will be studied in detail during the design
phase of the project development.
COMMENT I.92:
IIPage E-3-80:(ii)Construction and Operation of Watana
Camp,Village and Airstrips:Last Paragraph:We understand
that current plans call for expanding the 2500-foot
temporary airstrip to 6000 feet in length rather than
constructing two airstrips.3F-7/We concur with this
proposal.II --
113F-7/See Footnote 3F-2.[Footnote 3F-2/ADF&G.1983.
Synopsis of the 1982 Aquatic Studies and Analysis of Fish
and Habitat Relationships.Prepared for the APA.]"
RESPONSE:
Reference is made to the Draft Report,Watana Airstrip
Feasibility Study -Phase 1 Report to the Alaska Power
Authority dated September 1983.
In this report,the feasibility and cost/benefits were
analyzed for the construction of a temporary airstrip at the
existing Watana Camp during the later part of 1983.
The temporary strip proposed and emphasized in the report is
2,500 feet in length with the possibility of extension to
RESPONSE TO COMMENT I.92 (cont.):
4,000 and 6,000 feet at a later date if conditions warrant.
No commitments for expansion were made in the report.
On July 5,1983,an application for permit was filed with
the Department of the Army,Alaska District Corps of
Engineers for placement of fill in wetlands to construct the
2,500-foot long temporary airstrip.On November 9,1983,an
Army permit,File No.071-0YD-4-830374 was issued,and can
be found in the Reference Volume of this response document.
Although the proposed 2,SOO-foot long airstrip is expandable
to 6,000 feet,no plans have been made to do so.Therefore,
the last paragraph of Section (ii)on FERC License
Application page E-3-80 is correct as is under present
conditions.
REFERENCES
Alaska Power Authority,Susitna Hydroelectric Project Watana
Airstrip Feasibility Study Phase 1,Task 39,Draft Report,
pages 8,19-20,Figure 1,Appendix E (September 1983).
U.S.Army Corps of Engineers,Alaska District Corps of
Engineers,Letter to Alaska Power Authority transmitting
permit November 9,1983).
U.S.Army Corps of Engineers,Permit Enabling Alaska Power
Authority to Discharge Dredged or Fill Material,Application
No.071-0YD-4-830374 (November 9,1983).
COMMENT I.93:
"Page E-3-84 to 86:Mainstem Habitats:We believe that the
knowledge of potential post-project water quality impacts is
inadequate.Please refer to our comments on Chapter 2,
pages E-2-19,E-2-34, E-2-69,and E-2-96.Post-project
reservoir fisheries should be re-examined after the
reservoirs'water quality parameters are assessed.II
RESPONSE:
Please refer to the Responses to Comments I.21,I.34 and
I.41.
----~-----~-_._-------------------------------------
COMMENT 1.94:
"Page E-3-96:Slough Habitats:Paragraph 4:According to
the ADF&G Synopsis Report 3F-8/,unrestricted access to
slough #9 does not occur until the mainstem discharges at
Gold Creek exceeds 20,000 cubic feet per second (cfs).
Acute access problems occur at flows less than 18,000 cfs.
The applicant should revise the discussion to reflect the
more current ADF&G assessment.
"Nine-sloughs were examined by ADF&G 3F-9/;Whiskers Creek
Slough,and sloughs #6A,#8A,#9,#11~6B,#20,#21,and
#22.Five of the sloughs (#9,#16B,#20,#21,#22)show
acute access problems below 18,000 cfs,and unrestricted
access is not achieved until flows exceed 20,000 cfs to
26,400 cfs."
"3F-8/See Footnote 3F-2.[3F-2/ADF&G.1983.Synopsis of
the 1982 Aquatic Studies and Analysis of Fish and Habitat
Relationships.Prepared for the APA.]
"3F-2,/See Footnote 3F-2,supra."
RESPONSE:
Based on the conclusions reached by ADF&G in their Synopsis
Report,it is evident that the sloughs identified in this
Comment are candidates for modifying the mouths to provide
more suitable access conditions.The results presented
below in Table I.94.A in terms of the provision of mainstem
discharges to provide suitable access conditions must be
coupled with the relative importance of these sloughs to the
existing spawning populations.Table I.94.B provides a
summary of the estimated escapement of adult salmon to the
five sloughs (#9,#16B,#20,#21 and #22)observed in 1981,
1982 and 1983 and the proportion of slough spawning salmon
utilizing each slough as well as the proportion of the
estimated escapement of adult salmon to the upper river
(past the Curry Station)which utilize each slough for
spawning.Based on this analysis,it is evident that the
numbers of salmon implicated by the conclusions reached by
ADF&G are relatively small.
~,
~'
-
1 The use of the term "acuten implies a threshold mainstem discharge
below which adult salmon attempting to gain access may be subjected
to extensive physical stress,increased predation or prevention of
access to the spawning habitat.If mainstem discharge is maintained
at or below this level on a continuous basis,future use of the spawn-
ing area may be constrained.
2 1982 data only as even year runs dominate in the Susitna.
Data unavailable.
RESPONSE TO COMMENT 1.94 (cont.):
Table L94.B
Estimates of Escapement and Relative
Importance of Selected Sloughs
Chum Sockeye Pink
Pro- Pro-Pro-Pro-Pro-Pro-
portion portion portion portion portion portion
of Slough of Escape-of Slough of Escape-of Slough of Escape-
Escape-Spawning ment P2st Escape-Spawning ment P2st Escape-Spawning ment P2st
ment Salmon Curry ment Salmon Curry ment Salmon Curry
Slough Year Estimate (Percent)(Percent)Estimate (Percent)(Percent)Estimate (Percent)(Percent)
9 1981 368 8.2 2.8 18 0.8 0.6 O.0 0
1982 603 11.9 2.1 13 0.9 1.0 18 6.1 <..0.1
1983 430 14.6 2.0 0 0 0 0 0 0
16B 3 1981 5
0.5 0.1 0 0 0 0 0 0
1982 0 0 0 0 0 0 0 0 0
1983 0 0 0 0 0 0 0 0
0
20 1981 24 0.5 0.2 0 0 0 0 0 0
1982 28 0.5 0.1 0 0 0 75 25.2 0.1
1983 103 3.5 0.5 0 0 0 0 0 0
21 1981 657 14.6 5.0 63 2.9 2.3 0 0 0
1982 1,737 34.4 5.9 87 5.9 6.7 9 3.0 <.0.1
1983 481 16.3 2.3 294 27.8 15.5 0 0 0
22 1981 0 0 0 0 0
0 0 0
0
1982 0 0 0 0 0 0 0 0 0
1983 105 3.5 0.5 0 0 0 0 0 0
li J J I ":1\!1 ,j,~~I ~1 ~~~'~I g",-,~
i Ii 1 1 1 ,I I •I J f I f')
RESPONSE TO COMMENT 1.94 (cont.):
Table I.94.B (cont.)
1
2
3
Extracted from ADF&G 1983 Phase II Adult Anadromous Investigations Draft Report,December 1983.,Pre-
pared for the Alaska Power Authority,Anchorage,Alaska.
Estimated escapement past Curry are:for Chum 13,100 in 1981,29,400 in 1982 and 21,100 in 1983;for
Sockeye 2,800 in 1981,1,300 in 1982 and 1,900 in 1983;for Pink 1,000 in 1981,58,000 in 1982 and
5,500 in 1983.
Sloughs 16 and 16B are closely associated with each other.The ADF&G Anadromous Adult Reports do not
segregate these two sloughs.
COMMENT 1.95:
"Page E-3-97:Slough Habitats:Paragraph 5:Please refer
to our comments on page E-3-24.The conclusion that the
Susitna River sockeye salmon upstream of the Talkeetna River
are strays from the Chulitna and Talkeetna Rivers stocks is
presently unsubstantiated."
RESPONSE:
In comparing scale patterns from different sockeye salmon
stocks in the Susitna River,Bernard et ale (1983,page 22)
concluded that:
"Most probably adult sockeye salmon passing Curry
Station are strays from the Chulitna and Talkeetna
Rivers and are not a separate stock.Most of thes
(sic)fish spawn in sloughs above Curry Station,and
their fry either move down to the Lower Susitna River
to overwinter and/or die."
REFERENCES
ADF&G,Susitna Hydro Aquatic Studies,Phase II Basic Data
Reports for 1982,5 Volumes (1983),previously submitted to
the FERC on October 31,1983.
Bernard,D.R.,G.Oliver,W.Goshert and B.Cross,
Comparison of Scale Patterns From Sockeye Salmon
Sampled From Different Stocks in the Susitna River in
1982,Appendix 2-H to:Susitna Hydro Aquatic Studies
Phase II Final Report,Volume 2,Adult Anadromous Fish
Studies,1982 (1983).
COMMENT 1.96:
"Page E-3-97 to 98:Slough Habitats:Paragraph 6:The
relationship between mainstem flows and slough upwelling
should be further examined (see paragraph 3 of this section
and our comments on Chapter 2,page E-2-98)."
RESPONSE:
Please refer to the Responses to Comments B.18 and B.19 for
additional information on the relationship between mainstem
flows and slough upwelling.Also refer to the specific
-
-
RESPONSE TO COMMENT I.96 (cont.):
Responses to Comments C.32,L 22 and I.42.
COMMENT I.97:
"Page E-3-98:Slough Habitats:Paragraph 7:Please refer
to our comments on Chapter 2,page E-2-44,and the recently
completed salmon incubation study.3F-IO/It is
unfortunate that the incubation study was not continued
through smolt stages.Pre-versus post-project temperature
changes could result in significant differences in
outmigration timing and/or survival.We recommend that the
study be re-initiated to determine timing and survival
through smolting.1I
"3F-IO/Wangaard,D.S.and C.V.Burger.1983.Effects of
Various Temperature Regimes on the Incubation of Susitna
River Chum and Sockeye Salmon.U.S.FWS.Prepared for the
APA."
RESPONSE:
The study by Wangaard and Burger (1983)of the U.S.Fish and
Wildlife Service (USFWS)contributed significantly to the
understanding of the relationships between various
temperature regimes and the incubation of Susitna River chum
and sockeye salmon.The recommendation by the USFWS that
the study be re-initiated to determine timing and survival
through smolting has been evaluated by the Power Authority.
At this time,however,the Power Authority does not believe
that this study is necessary.The reasons for this are:
1.The USFWS has proposed that survival through smolting
(particularly for chum salmon)be tested via salt water
challenge tests.These laboratory tests are very
useful in certain situations.A typical application of
this test is to determine the "readiness"of
hatchery-reared salmon to adapt to sea water in order
that they may be released at an optimum time.
~-
2.A second application of this test is to determine the
viability of smolts following exposure to various
stresses (e.g.,seawater challenge tests can be used to
test smolt viability following exposure to toxic
chemicals).Such tests are valuable to understanding
the mechanisms and results of stresses,or in this
case,various rearing temperatures.
--.--w---------__._
RESPONSE TO COMMENT I.97 (cont.):
3.
However,these are laboratory tests in a controlled
environment that eliminates much of the natural
variation that occurs in the actual field situation.
As such,extreme caution must be used in extrapolating
the results of such tests to the field situation.For
example,a laboratory test for smolt viability would
probably involve the following:collection of eggs in
the field from a limited number of sites~incubation in
a laboratory situation;rearing on artificial diet;and
then testing of selected fish over time by exposing
them directly to salt water.From this,the
relationships among temperature,temperature units,
timing of outmigration and smolt viability would be
examined.Success of rearing the fish from egg to yolk
absorption size under laboratory conditions could range
as high as 90%or better.In the natural environment,
this value would be below 50%and probably closer to
10%.Also,in the natural environment,there is a wide
range of variation within the juvenile fish population
because they originate from numerous sites (various
sloughs,side channels and tributaries spread out over
a large area),are reared under a wide variety of
conditions (e.g.,temperature,flow,substrate,etc.),
have a wide range of distances to outmigrate to sea
water,and show a considerable variation in the time
they spend in fresh water (e.g.,ADF&G (1983)has found
a major portion of the juvenile chums outmigrate from
the Talkeetna to Devil Canyon reach by mid-June,but
some may remain in this reach and rear for up to 3
months).Upon reaching sea water,the juveniles are
not directly exposed to sea water but may instead move
between areas of varying salinity,if necessary.This
is particularly true for juveniles that outmigrate
through Cook Inlet where large areas of varying
salinity are available.For these reasons,it would
not be scientifically valid to directly extrapolate the
laboratory results to the field situation.
The Power Authority has funded extensive studies to
determine timing,incubation rates and rearing periods
for churn salmon (and other species)in the field
situation.These studies,primarily by the Alaska
Department of Fish and Game,have been ongoing for
several years (see Response to Comment I.23)•The
results from these studies,those of Wangaard and
Burger (1983)and the extensive li~erature on th~s
subject are adequate to understand~ng the potent~al
~l
""'"
:~
RESPONSE TO COMMENT 1.97 (cont.):
impacts from temperature on incubating and rearing chum
and other salmon.
REFERENCES
ADF&G,Susitna Hydro Aquatic Studies,Phase LI Basic Data
Reports for 1982,5 Volumes (1983),previously submitted to
the FERC on October 31,1983.
-
-
-
.-
Synopsis of the 1982 Aquatic Studies and Analysis of
Fish and Habitat Relationship (1983).
Wangaard,D.B.and C.V.Burger,Effects of Various
Temperature Regimes on the Incubation of Susitna River Chum
and Sockeye Salmon,u.S.Fish and Wildlife Service (1983),
previously submitted to the FERC on November 29,1983.
COMMENT 1.98:
"Page E-3-100:(iii)Cook Inlet to Talkeetna:It is stated
that the Chulitna River contribution is 39%and the
Talkeetna River contribution is 18%.We assume the upper
Susitna River contribution is the remaining 43%.Lacking
hydrological,modeling and biological data to the contrary,
it could be assumed that greater impacts would occur
upstream of the mouths of Talkeetna and Chulitna Rivers than
to downstream.
"However,given that our understanding of the fishery use in
the lower reach is a magnitude below that for the upper
Susitna River,and the river is broad and relatively
shallow,we would not dismiss significant project-related
impacts in this reach.Although we do not know the level of
fishery use in this reach,we suspect this reach contains
important spawning and rearing habitat.
"In a report prepared for the APA,the Arctic Environmental
Information and Data Center (AEIDC)3F-11j concluded,'The
effort to delineate river reaches where post-project flows
differ significantly from natural flows has been
unsuccessful.The purpose of this effort was to limit the
area where flow-related impacts (other than water quality
issues)need to be considered.Being unable to establish
these limits,it appears necessary to include the entire
length of river when considering aquatic habitat effects.'
-,-----~----------------------------------
&4
COMMENT 1.98 (cont.):
"It appears that an aquatic studies program is necessary to
examine post-project impacts downstream of the Chulitna
River.We request the applicant provide the FWS with a copy
of the downstream studies program proposed to be undertaken
in 1984 by APA."
"3F-11/AEIDC.1983.Examination of Discharge and
Temperature Changes due to the Proposed Susitna
Hydroelectric Project.Prepared for the APA."
RESPONSE:
The relative contribution of water from the Upper Susitna,
Chulitna and Talkeetna Rivers is correct for the Sunshine
USGS gaging station.These three rivers combined contribute
approximately one-half of the total discharge of the Susitna
River at the Sunshine Station USGS gaging station near the
mouth of the river.
Considerable information pertaining to the Lower River has
been presented in the ADF&G data reports collected in the
1981 and 1982 field seasons.Much of this information is
included in Exhibit E of the License Application.Further
information pertaining to the Lower River is presented in
the ADF&G 1982 Phase II Synopsis Report.
Additional studies are currently being conducted to describe
the response of water surface areas of various habitat types
to various mainstem discharges.These studies are being
used to further refine the analysis presented in the License
Application and to develop a plan of study to further refine
the impact analysis of the Lower River.Once plans for the
additional studies are outlined,the plan will be discussed
with the appropriate resource agencies.
COMMENT 1.99:
"Page E-3-101:Mainstem Habitats:Paragraph 1:We believe
that the information on fish use downstream of the Chulitna
River is due to the very limited data gathering efforts
expended in this reach rather than limited fish use.Please
refer to our comments on page E-3-100,immediately above,
and on Chapter 2,page E-2-60."
,~
,~
RESPONSE TO COMMENT I.99:
The Power Authority does not agree that there has been a
limited gathering effort expended on the reach of the
Susitna River downstream of the Chulitna River confluence.
Considerable effort has been expended to describe the
spawning characteristics of eulachon and habitats through
the reach have been sampled for adult and juvenile salmon as
well as other anadromous and resident fish species.
Escapement index counts have been made in most of the
tributaries to the Susitna downstream of Talkeetna as well
as in the Talkeetna River and Chulitna River drainages
(ADF&G 1981,1983a,1983b).Quantitative habitat
relationships for juvenile salmon have been developed for
four side slough habitats downstream of Talkeetna (ADF&G
1983c).Hydraulic and ice processes studies have been
conducted and are continuing at the present time.As
discussed in the Response to Comment B.8,considerable
information has been collected regarding fishery habitats
downstream of Talkeetna.ADF&G has collected information on
escapement of adult salmon,resident species,utilization of
habitats,juvenile salmon rearing habitats and eulachon
spawning habitats (ADF&G 1981,1983a,1983b,1983c,1983d).
An index to the data collected in 1982 (ADF&G 1983a,1983b)
is also available (ADF&G,1983e).Results of investigations
of the fishery habitats downstream of Talkeetna prior to the
present study are presented by Riis and Friese (1978).
The Power Authority anticipates that the DEIS will summarize
and incorporate all such available data.
REFERENCES
ADF&G,Susitna Hydro Aquatic Studies,Subtask 7.10 -Phase I
Final Draft Report,Aquatic Habitat and Instream Flow
Project (1981).
ADF&G,Susitna Hydro Aquatic Studies Draft Phase II Data
Report -Winter Aquatic Studies,October 1982-May 1983
(1983),previously submitted to the FERC on October 31,
1983.
RESPONSE TO COMMENT I.99 (cant.):
ADF&G,Susitna Hydro Aquatic Studies,Phase II Basic Data
Reports for 1982,5 Volumes (1983),previously submitted to
the FERC on October 31,1983.
Synopsis of the 1982 Aquatic Studies and Analysis of
Fish and Habitat Relationship (1983).
Volume 2,Adult Anadromous Fish Studies (1983).
ADF&G,Susitna Hydro Aquatic Studies,Phase II Basic Data
Reports,Index of Data and Analyses (1983).
Riis,J.C.and N.V.Friese,Fisheries and Habitat
Investigations of the Susitna River - A Preliminary Study of
Potential Impacts of the Devil Canyon and Watana
Hydroelectric Projects (1978).
~I
.-.
~,
-
......
J~
.....
COMMENT L100:
"Page E~3-101:Mainstem Habitats:Paragraph 2:Regarding
water temperature changes,we have commented throughout
Chapter 2.Please refer to our comments on pages E-2-60,
E-2-62,E-2-87,E-2-88,E-2-119,E-2-123,E-2-124.To
summarize,due to insufficient data and the recent changes
in computer temperature models we believe that the
predictions in the applicati,.onare inadequately supported •
Identifiable temperature changes are predicted by AEIDC
below the Chulitna River confluence.3F-12/"
"3F-12/See Footnote 3F-1l.[Footnote 3F-11/AEIDC.1983.
Examination of Discharge and Temperature Changes due to the
Proposed Susitna Hydroelectric Project.Prepared for the
APA.]"
RESPONSE:
Please refer to the Responses to Comments 1.28,1.30,1.37,
1.38,1.39,1.48,1.51 and 1.56.
Please refer to the Responses to Comments B.16,B.23 and
B.38 for discussions of the temperatures downstream of the
Susitna-Chulitna confluence.Please refer to the Response
to Comment B.6 for a discussion of the current temperature
studies.Please refer to the Responses to Comments B.8 and
C.39 through C.41 on Lower River Studies and Lower River.
COMMENT L 101 :
"Further analysis should be made of potential aggredation at
the Chulitna River confluence (see our comments on
Chapter 2,page E-2-84),and of sediment transport and
bedload movement (see our comments on Chapter 2,
page E-2-164)."
RESPONSE:
Please refer to the Responses to Comments 1.36,1.61,B.14
and C.38 for discussions of the results of current
sedimentation studies.A draft report on the suspended
sediment and bedload transport characteristics of the
------,-------'------------------~----
RESPONSE TO COMMENT I.101 (cont.):
Susitna River near the Chulitna River confluence is
available.This report will be finalized by March 1984.
REFERENCES
Harza-Ebasco,Susitna Hydroelectric Project Reservoir and
River Sedimentation,Draft Report (1983).
COMMENT I.102 :
"Page E-3-l01:Mainstem Habitats:Paragraph 3:Reduction in
the occurrence of the l-in-2 year flood event so that it
becomes a 1-in-5 or 1-in-lO year event could result in
dramatic changes in habitats of particular importance,such
as sloughs.Information from the ADF&G Aquatics Studies
Program from the last two flow years may provide valuable
insight.For instance,observations of successional
processes and beaver activities should provide indications
of post-project impacts due to decreased flows and flood
events."
RESPONSE:
Th~reference page refers to mainstem habitats in the lower
river (Talkeetna to Cook Inlet).The small reduction in the
number and magnitude of peak flows is not expected to result
in dramatic changes.For example,high turbid flows in the
lower Susitna River may still inhibit fish passage at times
as well as limit benthic production.It is expected,
however,that reduction will result in some potential
changes.The Alaska Department of Fish and Game Aquatic
Studies Program has primarily concentrated on the river
reach between Talkeetna and Devil Canyon.Some of this
information may provide insight to impacts on the lower
river.For example,if the frequency of an overtopping of
particular slough was decreased,the slough habitat would
tend to become more stable and its value as habitat may
actually increase.Groundwater would then be the primary
contributor to the slough's discharge,although local runoff
could at certain times,be quite significant.To better
refine the impact predictions for the lower river,the Power
Authority is currently studying,in a step-wise manner,the
changes that are expected to occur.These studies first
involved a statistical analysis of the significance of flow
changes as a result of the Project.A final report on these
analyses will be available in the very near future.(The
-
~,
,~
-
-
-
-
RESPONSE TO COMMENT 1.102 (cont.):
Department of Interior apparently has a draft of this
document.)The second step in this study has two tasks.
One task was to review the existing information in the
literature and from field studies to determine what
information is available.The second task was to perform
field studies to determine how the lower river changes
physically over a range of natural existing flows.This
second task has included aerial photography and ground
reconnaissance.A report on these studies will be
tentatively available in the spring of 1984.Comments from
the various resource agencies will be elicited in response
to this report.
The successional processes and beaver activities are of
interest and will continue to be considered in the
refinement of impact predictions.
COMMENT 1.103:
"Page E-3-106:(i)Reservoir Habitats:Please refer to our
comments on Chapter 2,pages E-2-69,and E-2-96.We believe
the issues of reservoir turbidity and suspended sediment in
discontinuous permafrost·need further investigation."
RESPONSE:
Refer to the Responses to Comments 1.34 and 1.41.
COMMENT 1.104:
"Page 114:Winter/Ice Season:Paragraph 7:According to the
ADF&G Synopsis Report 3F-13/,chum salmon may rear in the
Susitna River for up to three months rather than just the
one month indicated in this section.The significance of
this information is that it may indicate the Susitna River
estuary,being very turbid,does not provide good rearing
habitat.The dependance of churn salmon on the Susitna River
environments,thus,may be much greater than first thought.
liThe incubation study conducted by the FWS showed the timing
of churn and sockeye salmon development to yolk absorption in
4°C water compared to the slough #8A temperature regime to
be nearly identical.We recommend the studies be continued,
COMMENT I.I04 (cont.):
comparing chum smolt development with anticipated
post-project to pre-project temperature conditions."
"3F-13/See Footnote 3F-2.[3F-2/ADF&G.1983.Synopsis
of the 1982 Aquatic Studies and Analysis of Fish and Habitat
Relationships.Prepared for the APA.]"
RESPONSE:
The Alaska Department of Fish and Game did find that some
juvenile chums may spend as much as three months in fresh
water prior to outmigrating.
The significance of this information does not necessarily
indicate that the Susitna River estuary,being very turbid,
does not provide good rearing habitat.This is only one
hypothesis of many that could explain freshwater rearing.
Turbid conditions are also found for prolonged periods in
the mainstem Susitna and side channels.They are also found
at times in sloughs when they are overtopped.Rearing chums
are found in all of these habitats.
The recommendation that the u.S.Fish and Wildlife Service
continue studies on chum salmon development under various
temperatures is discussed in the Response to the Comment
I.97..
COMMENT LI0S:
"Page 114:Winter/Ice Season:Paragraph 8:It is stated
that gas supersaturation would not be a problem because of
the use of cone valves in the spilling design.According to
Chapter 2,the cone valves would be frequently used,
particularly in the early years of project operation.One
of the conclusions of Acres American in their design of cone
valves 3F-14/is that:lIn view o~the nature of analyses
and lack of precedence for the proposed valves arrangement,
it is recommended that a physical model study be carried out
to confirm the performance of the valves.I"
113F-1:..1.1 Krishnan,G.September 13,1982.Gas Concentration
and Temperature of Spill Discharge Below Watana and Devil
Canyon Dams.Acres American.Prepared for the APA.II
~,
-
-
"""
--
RESPONSE TO COMMENT I.10S:
The Power Authority's consultants are of the opinion that
small-scale physical model tests of the cone valves would
not provide accurate information regarding dissolved gas
concentrations downstream of the cone valves.Air
entrainment and energy dissipation in the jet ~ssuing from
the valve are dependent on the turbulence in the jet as
measured by the Reynolds number (Falvey 1980).In
small-scale models the turbulent intensity is not similar to
prototype conditions and surface tension also affects
performance (de S.Pinto 1982).Therefore,it is not likely
that dissolved gas saturation would be accurately simulated
in a small-scale model.
A more accurate estimate of the dissolved gas concentration
downstream of the cone valves would be possible by testing
existing,similar full-scale installations.Such a test was
run by Ecological Analysts,Inc.for Milo Bell and is
referenced in the memorandum from Krishnan to Hayden cited
in the Comment.As indicated in the FERC License
Application,the dissolved gas concentration downstream of
the valves was within acceptable limits.Additionally,
please refer to the Response to Comment B.34.
REFERENCES
Falvey,Henry J.,Air-Water Flow in Hydraulic Structures,
Free Falling Water Jets,u.S.Department of the Interior,
Water and Power Resources Service (now Bureau of
Reclamation),Denver,CO (December 1983).
de S.Pinto,N.L.,S.H.Neidert and J.J.Ota,Water Power
and Dam Construction,Aeration at High Velocity and Flows
(February -March 1982).
COMMENT I.106:
npage E-3-124:(iii)Operation Impacts:Last Paragraph:
Please refer to our comments on pages E-3-100 and E-3-101.n
RESPONSE:
Please refer to Responses to Comments I.98,I.99 and B.8.
COMMENT 1.107:
"Page E-3-131:Mainstem Habitats:Paragraph 3:The
discussion on the ice front with both dams operating is
inconsistent with the discussion on ice formation in
Chapter 2,page E-2-169.Neither explanation appears to
reflect current modeling of post-project conditions.Please
refer to our comments on the reservoir,river,and ice
modeling efforts in Chapter 2 (page E-2-124)."
RESPONSE:
Please refer to the Response to Comment B.40 for a
correction of the discrepancy.See al~o Response to Comment
B.6.
COMMENT I.108 :
"Page E-3-136:In-Stream Activity:Use of heavy equipment
could also result in destruction of stream banks."
RESPONSE:
The construction I1heavy equipment"referred to as entering
water bodies are the road crossings of water bodies that are
under construction.Where this necessarily must occur,
construction specifications will require the contractor to
repair the area damaged by his equipment to a
pre-established criteria.
COMMENT 1.109:
"Page E-3-136:Erosion:Access to upstream habitat could
also be limited."
RESPONSE:
Increased runoff and turbidity alone would not be expected
to limit upstream migration.Access to upstream habitat.is
not expected to be limited unless the erosion results in a
physical blockage to upstream migration (e.g.,a slide
occurs).The Power Authority anticipates that the DEIS will
reasonably discuss project-related physical blockage.
-
-
-
..,..
-
COMMENT 1.110 :
"Page E-3-136:Fill Placement:The severity of fill
placement impacts would also be related to timing.Streams
used by grayling in summer may be dry in winter.
"Sheetflow discharge,when concentrated through culverts,
may tear the vegetative mat and result in thermokarst in
permafrost areas."
RESPONSE:
Comment noted.
At some ice-rich sites in Alaska,particularly along the
Dalton Highway,an inadequate number of culverts resulted in
concentrated sheet flow and serious downslope thermal
erosion.This problem will be minimized through
identification of potential problem areas and installation
of a sufficient number of culverts so that no single culvert
drains a large area.Minimum specifications will be
determined during detailed design and these will be
incorporated into the Erosion Control Plan along with
procedures for monitoring the effectiveness of culverts.
COMMENT I.111:
"Page E-3-136:Changes in Water Quality:Road maintenance
activities,such as blading and clearing of berms,could
lead to erosion~Runoff from these areas would adversely
impact water quality and could fill in culverts and drainage
ditches."
RESPONSE:
The Power Authority has described mitigation measures for
erosion control (see pages E-3-154 and E-3-155 of the FERC
License Application).These measures are designed to avoid
or minimize the potential impacts described and will be part
of the routine maintenance of the access road.The erosion
control plan will further address these matters •
COMMENT 1.112:
"Page E-3-l39:Changes in Water Quality:Fuel should be
banned within 100 feet of a flowing water course.
liTo facilitate cleanup,the project oil spill plan should
contain project area maps with all water drainages,
direction of flows,and sites and access points identified
where cleanup actions could be initiated.1I
RESPONSE:
Fuel facility siting for the project will incorporate good
engineering practices and address Federal and State
recommendations for the lOa-foot setback from a flowing
water course,along with the topography of an area,drainage
patterns,etc.The SPCC Plan will be reviewed by ADEC,EPA
and other appropriate agencies to ensure that facility
planning is in accord with agency requirements for the
protection of State water quality.The fuel ban proposed by
the commentor is not necessary for effective spill
prevention control and countermeasure efforts.
The SPCC Plan will address responses to potential spill
scenarios,i.e.,flowing water,wetlands,lakes,drainage
patterns,etc.Project topographic maps will be used to
formulate general approaches by project personnel in the
event of a spill.Spill responses will be incorporated in
the Project plan as well as implemented through personnel
training at intervals frequent enough to assure adequate
understanding of the SPCC Plan.The Plan will identify
critical areas for spill response,but cannot identify all
areas where cleanup actions could be initiated.Providing a
map for major storage areas is feasible and could be
available with the SPCC Plan.
COMMENT 1.113 :
IIPa e E-3-l42:Alteration of Waterbodies:Para ra hs 1 and
8:It is state,tpermanent roads may be bui t to provide
all-season access.'The discussion in these sections should
be limited to the proposed project development.This would
consist of access to the transmission line corridor via
trails from existing access routes at intermittent points
along the corridor.A more detailed description of the
transmission line access proposal is found on page A-4-6.
-
~,
-
COMMENT 1.113 (cont.):
"If the towers are to be set in concrete,excavations will
be required and provisions for pumping of silty water
needed."
RESPONSE:
The preferred mode of access to the transmission line is
that described on FERC License Application page A-4-6.
However,there is a possibility that some form of permanent
road to the ROW may have to be constructed.The refinement
of transmission access will continue as the Project
continues through the detailed design phase.
Any pumping or discharging of waters,silty or otherwise,
will be conducted in accordance with state and/or federal
permits related to these activities.
COMMENT Ie 114 :
"Page E-3-144:Alterations of Waterbodies:Paragraph 6:Use
of ramps rather than bank cuts would help to minimize
impacts to the aquatic habitats."
RESPONSE:
In general,stream crossings of construction equipment are
effected where the terrain or banks of the water bodies are
adequate for equipment movement.Construction
specifications will require the contractor to file an
equipment movement plan in order to obtain the necessary
permits from state,federal and,for some areas,native
agencies.
COMMENT 1.115:
"Page E-3-144 to 145:Alterations of Waterbodies:Last
Paragraph:We recommend that dredging,if required,be
timed so that it does not occur during periods of salmon
spawning."
RESPONSE:
This Comment refers to the laying of cable under the Knik
Arm of Cook Inlet.
RESPONSE TO COMMENT 1.115 (cont.):
The operation of excavating trenches,laying of submarine
cable and backfilling has advanced in sophistication in
recent years.Equipment is now available to do the above in
one continuous operation;thereby the disturbance to the
channel bed is restricted to a small area at any point in
time.This disturbance of placing bed material into
suspension is localized to the area of excavating and
backfilling at the time of the operation.This area at any
point in time is a very small percent of the channel width
and consequently the material placed in suspension,although
concentrated at the area in question,would have a minute,
insignificant effect on the body of water as a whole.
The removal and replacement of materials for trench
excavation is not expected to have any significant impact
because of the existing high turbidity and the extensive
mixing that occurs due to the extreme tidal fluctuation.
Any effects should be short-term and,therefore,would
probably not be detectable.
In conclusion,although the construction contractor could
possibly schedule this work to avoid the migrations of
August and the first part of September,the water quality
would show no overall measurable improvement by this action
and the area of disturbance would at all times be very
limited.
COMMENT 1.116 :
"Page E-3-145:Changes in Water Quality:What is considered
long-term should be defined.For example,a 24 hour
increase in sediment and turbidity could result in an
identifiable delay in grayling spawning."
RESPONSE:
Construction activities associated with transmission line
stream crossings are expected to result in increased
suspended sediment concentration.The duration of the
periods of increased suspended sediment concentrations is
expected to be on the order of a few hours,or fractions of
a day,and should not significantly interfere with grayling
spawning activities.
~i
-
~.
COMMENT 1.11 7:
-
"Page E-3-l48:2.4.1 Selection of Project Evaluation
Species:We recommend rainbow trout,Dolly Varden,and
burbot be included as evaluation species by the applicant,
since these species meet the criteria established in this
section.For additional justification please ~efer to our
January 24,1983 letter.1I
RESPONSE:
The criteria that the Power Authority used to select species
for evaluation were:
1.High human use value;
2.Dominance in the ecosystem;and
3.Sensitivity to project impacts.
Species with high regional visibility and commercial,sport,
subsistence or aesthetic value were given priority (see page
E-3-l48 of the FERC License Application).Since the
evaluation species play a dominant role in the ecosystem,
they may serve as indicator species.By maintaining
critical habitats for evaluation species,many of the
potential impacts on less sensitive species or species with
a lower evaluation priority will be mitigated.
Although rainbow trout,Dolly Varden and burbot are
recognized as important species,they do not meet all of the
criteria with a ranking as high as the species selected for
evaluation.The U.S.Fish and Wildlife Service (USFWS)
similarly ranks these species in a lower resource category
than the evaluation species (see License Application,.
Chapter 11,letter from USFWS to the Power Authority dated
January 24,1983).Furthermore,the exclusion of these
three species as evaluation species has not precluded
intensive studies on them,as warranted.These species,and
other fish species (such as round white fish,longnose
suckers,etc.)have been studied extensively in conjunction
with studies on the evaluation species.They have also been
studied specifically.Examples of such specific studies
include extensive radio-tagging of rainbow trout to
determine migratory movements and studies to determine
spawning behavior of burbot (ADF&G 1983).Studies on Dolly
Varden have been limited,primarily because the numbers
found have been extremely low in spite of intensive sampling
efforts over the last two field seasons.They are caught by
~"'iWlIl'llIiIlil~~'----_
RESPONSE TO COMMENT 1.117 (cont.):
sport fishermen,primarily at clear water tributary mouths
downstream of Talkeetna and in the Talkeetna River.These
areas are outside the area where the most pronounced
project-related impacts are anticipated and thus are outside
of the most intensive study area for the Project.
REFERENCES
ADF&G,Susitna Hydro Aquatic Studies,Phase II Basic Data
Reports for 1982,5 Volumes (1983),previously submitted to
the FERC on October 31,1983.
Volume 3,Resident and Juvenile Anadromous Fish Studies
on the Susitna River Below Devil Canyon (1983).
Alaska Power Authority,Susitna Hydroelectric Project FERC
License Application Project No.7114-000 (1983)Volume IDA.
U.S.Fish and Wildlife Service Letter (January 24,1983),
previously submitted to the FERC on July 11,1983.
COMMENT 1.118 :
"Page E-3-149:2.4.2 Selection of Project Evaluation
Species:Paragraph 6:Please refer to our comments on pages
E-3-24 and E-3-100 to 102."
RESPONSE:
Please refer to Responses to Comments 1.85,1.99 and 1.117.
COMMENT 1.119:
"Page E-3-150:2.4.3 Mitigation of Construction Impacts Upon
Fish and Aquatic Habitats:We have not received the design
criteria manuals.3F-15/Both manuals should be provided to
resource agencies for a minimum of 30 days for review and
approval.The manuals should then be incorporated into the
license as binding articles.
"We support the establishment of a monitoring program funded
by the project,and a board of representatives from
appropriate State,Federal,and having the authority to
recommend project modifications to assure that mitigation is
effective.The procedure by which this would occur should
be incorporated into the license as an article.
COMMENT I.119 (cont.):
"Costs would be incurred for the mitigation identified.We
recommend specifications pertaining to environmental
protection contain provision for payment at rates similar to
that payable for regularly scheduled production work.When
the licensee's contract goes out to bid,those competing for
the contract should be aware of monies specified for
environmental protection tasks."
"3F-15/Personal communication on September 30,1983 with
Thomas J.Arminski,APA Deputy Project Manager,Susitna
Hydroelectric Project."
RESPONSE:
-
A.
B.
The Power Authority anticipates that the Design
Criteria Manual can be reviewed and commented upon by
agencies.
The Power Authority also intends to have a Construction
Practices Manual prepared prior to any construction
activity.This manual would be the joint product of
the Design Consultant and a yet-to-be-selected
Construction Manager.Current planning envisions
engaging a Construction Manager in FY 86 (at least a
year prior to construction activities).It is
anticipated that resource agencies will have the
opportunity to review and comment on the Construction
Practices Manual,and that construction specifications
would include by reference both the design criteria and
the Construction Practices Manual.
The Power Authority reported to the FERC the USFWS
recommendation for full financial funding of monitoring
programs (FERC License Application page E-3-548).As
stated elsewhere (see Response to Comment I.147),the
Power Authority anticipates the organization and
operation of an interagency monitoring team but feels
the appropriate role for the team is that of adviser.
As for all other projects of which the Power Authority
is aware,the Power Authority plans to directly
contract for required monitoring and mitigation
activities,including these costs,in construction or
operation budgets as appropriate.The Power Authority
may not delegate its statutory and regulatory
responsibilities to other agencies or groups of
agencies.The Power Authority has not proposed to fund
state and federal agencies to perform their normal
RESPONSE TO COMMENT I.119 (cont.):
regulatory functions.The resource agencies will be
able to review and comment on the DEIS and the FEIS and
will probably participate in the development of license
stipulations.We do not anticipate,however,that once
the Project gets underway resource agencies may
casually "recommend project modifications to assure
that mitigation is effective."The license and/or
memoranda-of-understanding may prescribe appropriate
mechanisms for modifying mitigation or monitoring
programs.
C.The Design Criteria Manual,the Construction Practices
Manual and,as required,contract specifications will
define performance standards and facilities
specifications for the protection of environmental
resources that bidders must incorporate into their
bids.The Power Authority,its agents and the
regulatory agencies will appropriately monitor to
assure compliance and,if necessary,to effect
corrective measures.
COMMENT 1.120 :
"Page E-3-152:(ii)Mitigation:Beaver control measures
related to fish passage should be controlled by ADF&G."
RESPONSE:
The Power Authority will coordinate with the various state
and federal agencies concerning beaver control measures
related to fish passage.We will conform to all state and
Federal laws concerning beaver control;specifically we are
cooperating with the Alaska Department of Fish and Game
under Title 16 of the Alaska State Statutes.
The issue of beaver control illustrates the potential for
interactions which need to be addressed by resource
managers.Should sloughs be managed for beaver habitat or
for fishery purposes?The Power Authority's intent,as
outlined in the Application,has been to manage for the
fishery resource in the more productive sloughs and to allow
the natural course of events to continue in the less
productive sloughs.This approach may be modified as the
mitigation details are refined and agencies determine their
management goals.
.-.
-
-
COMMENT L121:
"Page E-3-152:Presence or Absence of Fish/Fish Habitats:
Provisions should be included in the mitigation plan for
modifications if fish are discovered upstream at a later
date."
RESPONSE:
The referenced statement in the FERC License Application
states:
"Streams having documented fish or fish habitat at or
upstream from the road crossing will be designed to
pass fish.Only those streams without fish or fish
habitat at,or upstream from,the road crossing will be
designed solely on the basis of hydrologic and
hydraulic criteria."
This statement does encompass the provision for
modifications if fish are discovered upstream at a later
date,primarily under the provision that if fish habitat
exists at or upstream from the crossing,the crossing will
be designed to pass fish.Fish passage will be maintained.
In the unlikely event that a stream is designated as not
having viable fish habitat (a designation process will be
performed in consultation with the resource agencies),but
later it is found to have fish present that require passage,
modifications will be made to the crossing to allow for this
passage.
Modification of bridges is not expected because it is
unlikely that bridges would prevent or impede fish passage.
COMMENT I.122:
"Page E-3-153:Flow Regime:All culverts should be armored
at both ends with rip-rap at the time of installation,or
flared-end culverts should be used."
RESPONSE:
Treatment of the hydraulic approaches to culverts is
dependent upon the velocity of the flow in the natural
channel and the composition of bed material at the culvert
entrance and outlets.The velocities should be such that
bed material is not scoured at the approaches.Scouring of
the bed material impacts water quality and could provoke
RESPONSE TO COMMENT 1.122 (cont.):
culvert failure with the passage of time.The Comment to
which this Response is directed is correct and is considered
good design practice.
COMMENT 1.123 :
"Page E-3-153:Methods of Installation:Intermittent water
courses should be surveyed in summer and staked for culvert
installations."
RESPONSE:
Where needed,culvert installations will be designed to
accommodate flows of both intermittent and continuous
flowing streams.
COMMENT 1.124 :
"Page E-3-154:(ii)Mitigation:Paragraph 1:Revegetation
measures should be undertaken immediately after surface
disturbance,or as soon as use ceases."
RESPONSE:
The Power Authority anticipates that the DEIS will discuss
the appropriate timing of revegetation mitigation measures
and the FERC License will include conditions regarding
revegetation.The Power Authority agrees that revegetation
measures designed to avoid or minimize erosion should be
undertaken promptly after the activities creating the
surface disturbance have ceased.Specifically,the Power
Authority anticipates that a final
Revegetation/Rehabilitation Plan for the Project will be
prepared by the Power authority during the detailed design
phase of Project development.The nature and timing of
revegetation measures will be established in this plan.See
also Response to Comment 1.425.Proposed
revegetation/rehabilitation measures are also discussed on
pages E-3-275 through E-3-281 of the License Application.
~l
~',
~,
-
.-
.....
COMMENT 1.125:
"Page E-3-155:(ii)Mitigation:Paragraph 4:The settling
ponds should be maintained by cleaning them out when
one-half of their original capacity is 10st.1I
RESPONSE:
Settling ponds are designed to provide sufficient retention
time to allow settling of suspended material,so that
prescribed ADEC water quality requirements are complied
with.Retention time is a function of the inflow into the
settling pond,therefore,stipulating a maintenance criteria
on the basis of usable volume is not reasonable.The
cleaning cycle should be based on water quality standard for
the effluent.Consequently,the construction contractor
will be required to monitor the ~ffluent periodically and
submit certified records to the Alaska Power Authority.
COMMENT 1.126:
~~~:::-::--r~~~~~~~~~~::'=';;:":"""'::'':;:'=:';:':;2;:.;~.::h:....=.l:The re ferences
erosion control
RESPONSE:
The Power Authority anticipates starting to prepare the
Erosion Control Plan as early as this summer,reflecting the
mitigation recommendations of the DE1S.A final Erosion
Control Plan for the Project will be prepared by the Power
Authority during the detailed design phase of Project
development.The plan will present detailed guidelines for
erosion control measures,including consideration of the
measures discussed in the cited references .
COMMENT 1.127:
"Page E-3-156:(ii)Mitigation:Paragraph 3:Stockpiling in
the floodplain may be preferable to moving the material
outside of the floodplain.This would depend upon the
timing and location of the intended activity.1I
RESPONSE TO COMMENT 1.127:
The Power Authority concurs that the use of stockpiled
material depends entirely on "the timing and location of the
intended activity."Although the final decision in this
regard will be made during the detailed design,stockpiling
of the majority of river channel excavated materials would
likely be adjacent to or in immediate proximity to the
borrow area.
COMMENT 1.128:
"Page E-3-156:The Spill
Preven ~on on (SPCC)should
be provided to the resource agencies for a minimum 30-day
review period and,following approval,be incorporated into
the license application.The SPCC should be a part of the
licensee's construction contract for the project."
RESPONSE:
SPCC Planning regulations are under the jurisdiction of the
EPA,40 C.F.R.§112 and ADEC,18 A.A.C.§75.Therefore,
the SPCC Plan should not be incorporated into the License.
To incorporate the SPCC Plan into the License would
duplicate EPA!ADEC responsibilities,would make FERC
responsible for a matter which it is not prepared to
administer and would needlessly,and perhaps dangerously,
restrict EPA!ADEC!APA abilities to respond quickly to spill
events.
~.\
The SPCC Plan should be
construction contractor
by the Power Authority.
I.425.
COMMENT 1.129:
developed in coordination with the
based on guidelines to be provided
See also the Response to Comment
"Page E-3-161:(ii)Measures to Avoid Impacts:Paragraph 2:
The project may affect all three of the factors mentioned,
rather than just mainstem stage.We suspect channel
geometry is related,in the side sloughs,to frequency a~d
severity of breaching of the slough's upstream berm.Th~s
process is directly related to mainstem stage,and in the
winter,location of the ice front.If the river does not
freeze,as is predicted for the river downstream from the
~\
..-
I~
COMMENT 1.129 (cont.):
dams for an unknown distance,then this major influence on
slough geometry and succession would be eliminated.
"The relationship between mainstem stage and slough flows
has been an assumed,yet unproven,assumption.Please refer
to our comments on page E-3-98 and on Chapter 2,
page E-2-98."
RESPONSE:
Please refer to the Response to Comment B.43 for a
discussion of the potential for impacts on channel geometry
and slough flow.Please refer to the Responses to Comments
B.18,B.19 and 1.22 on the relation between mainstem stage
and slough flow.Additionally,please refer to the specific
ResPQnse to Comment 1.97.
COMMENT 1.130:
"Page E-3-162:(ii)Measures to Minimize Impacts:In the
FWS letter on the Susitna hydroelectric project
pre-application 3F-16/,the ongoing AEIDC modeling efforts
were summarized.The FWS continues to support the AEIDC
modeling efforts.The AEIDC study should provide the basis
for determining project instream flow impacts and a
reasonable assessment of mitigation alternatives.II
"3F-16/See FWS letter dated January 14,1983 to
Eric-P.Yould,APA.Included in Chapter 11."
RESPONSE:
The Power Authority agrees that the AEIDC effort is an
important part of the ongoing analysis.
COMMENT 1.131:
"Page E-3-162:Winter Flow Regime (October-April):
Paragraph 2:It is unclear as to what project stage is
being discussed.The discussion appears to be restricted to
pre-Devil Canyon conditions,based upon the assumption that
the ice front would be upstream of Sherman RM 130.With
Devil Canyon operating,it was assumed that the ice front
would form between Talkeetna (RM 99)and Sherman (RM 130)
(see page E-3-134)or downstream of Talkeetna (see
Chapter 2,page E-2-169).Discussion should be provided as
COMMENT I.131 (cont.):
to:how the sloughs needing a protective berm were selected;
how it was established which sloughs would be overtopped
more frequently than once every five years;and how these
sloughs would be managed after Devil Canyon is operating.
liThe benefits of establishing maximum winter flows should be
discussed.If staging due to ice formation in the upper
Susitna River occurs only prior to the initiation of
operations at Devil Canyon,the overtopping of sloughs could
be controlled by maintaining flows below a maximum level.
Disturbance of the ten sloughs due to the construction of
protective berms may,therefore,be avoided.Flows to
cleanse the sloughs could also then be provided,if needed.
Again,it is premature to establish an instream flow regime
since the AEIDC study is not complete.
"Winter flows,downstream of the Chulitna River,are
expected to be up to 373%higher under post-project than
pre-project conditions.3F-17/The ice front would
probably form downstream from Talkeetna (Chapter 2,
page E-2-169)and be delayed for an indeterminent period of
time (Chapter 2,page E-2-170).Downstream from the
Chulitna River confluence,the Susitna River is broad and
relatively shallow.We consider this reach more susceptible
to impacts due to this channel geometry.Impacts and
mitigation needs in this lower reach should be included in
this section."
"3F-17/See Footnote 3F-1l.[Footnote 3F-11/AEIDC.1983.
Examination of Discharge and Temperature Changes due to the
Proposed Susitna Hydroelectric Project.Prepared for the
APA.]11
RESPONSE:
Please refer to the Response to Comment B.40 for a
correction of the discrepancy between pages E-3-134 and
E-2-169 of the License Application.Please refer to the
Response to Comment B.44 for a discussion of the selection
of the sloughs requiring berms for protection.Please note
also that the report referenced in the Comment has been
updated (AEIDC,January 1984).
The need for establishing maximum winter flows will be
examined.This examination will necessarily include
consideration of both the environmental and economic
ramifications.
..-
RESPONSE TO COMMENT 1.131 (cont.):
The intent of the protective berms is to exclude high flows
that overtop the upstream berms and to stabilize conditions
(flow,velocity,etc.)in the slough.The construction of
the berms is not expected to cause disturbances that will
negatively impact fish.The reasons for this are:
1.The construction would occur during periods when little
or no activity by salmon occurs in the slough;
-
2.
3.
The construction would be during low water periods
which would allow erosion control procedures to be more
readily applied;and
The berms are in the upstream end of the slough where
slough flows are small or non-existant (slough
discharge under non-Qvertopping conditions generally
increases in the downstream direction as additional
groundwater and tributary flow is contributed to the
slough flow).
Therefore,construction would occur primarily on dry land,
well upstream of the major spawning activity areas.
The period between completion of Watana Dam and completion
of Devil Canyon Dam will be on the order of 10 years.The
Power Authority does not feel that the productive sloughs
should be left vulnerable to overtopping for this extended
period of time.Also,even during operation of both dams,
there is a possibility that during extreme events
(e.g.,high flows from tributaries)overtopping could occur
if no berm was present.The intent of the berms is to
decrease the likelihood of such overtopping.As a
consequence,these are expected to positively benefit the
productivity of the sloughs.
Although overtopping of the sloughs may assist in removing
fine silt from the sloughs,observations have also shown
that deposition of silts can occur as a result of
Qvertopping (e.g.,on Slough 21).In the second instance,a
protective berm to exclude this silt could help to maintain
spawning habitat.
Data and analyses needed to determine potential impact has
been collected and mitigation procedures proposed to avoid
or minimize these impacts.The intent of the AEIDC studies
is to further refine the existing data by coupling it with
other studies (ice processes,reservoir modeling,etc.).
RESPONSE TO COMMENT I.131 (cont.):
The Power Authority agrees that it is premature to establish
a final flow regime at this time.However,the instream
flow regime proposed in the FERC License Application forms
the basis for a final flow regime for the Project,as
refined by the ongoing field studies and analyses described
in other responses and references herein.
Please refer to the Response to Comment B.6 for a
description of the ice process simulations and to the
Responses to Comments B.33 and 1.40 regarding the delay in
ice formation downstream from the Talkeetna River
confluence.Please refer to the Response to Comment F.13
regarding potential impacts in the lower river and to the
Responses to Comments B.8 and C.39 on the lower river.
The Power Authority anticipates that the DEIS will analyze a
reasonable range of flow regimes and their impacts.
REFERENCES
Arctic Environmental Information and Data Center (AEIDC),
Susitna Hydroelectric Project Aquatic Impact Assessment:
Effects of Project-Related Changes in Temperature,
Turbidity,and Stream Discharge on Upper Susitna Salmon
Resources During June Through September (January 1984),
previously submitted to the FERC on January 20,1984.
COMMENT I.132:
"Page E-3-163:Winter Flow Regime (October -April):
Paragraph 3:The process which led to the selection of the
ten sloughs should be fully described.The location of
slough B should be indicated.It is not shown on
Figures E.3.12 to E.3.17.
"With the construction of the protective berms,the ice
cover formed on the sloughs would not be flushed out in the
spring.Ice could remain in these protected sloughs well
into June.The impact of this phenomenon upon the fishery
should be included in this section along with a discussion
of mitigative measures for any potential impacts.Adverse
impacts may be related to changes in timing of outmigration,
early inmigration,and quality of rearing habitat."
~,
~,
-
.-
RESPONSE TO COMMENT I.132:
Please refer to the Response to Comment 1.50 on ice cover
induced staging and slough overtopping,1.53 on break-up ice
jamming effects on ice deposition at slough or tributary
mouths and 1.131 on winter flow regime including
consideration of ice-induced staging,protective berms,
maximum winter flows and impacts downstream of the
Chulitna-Susitna confluence.Also,please refer to the
Response to Comment B.44 on selection of sloughs for
protective berms.
Attached is a map showing the location of Slough B.It is
adjacent to Slough SA and between river miles 126 and 127.
The ten sloughs were selected on the basis that (1)they are
currently productive sloughs that support adult spawning;
and (2)initial studies have indicated that at the flows and
the predicted location of the ice front in the FERC License
Application,these sloughs will require an increase in the
height of the berms at the upstream end of these sloughs for
protection.
Any given slough would need a predicted overtopping
frequency of more than once every five years to be
protected.
As the flow release schedules are refined through additional
study and the negotiation process,the need for upstream
berms will be reexamined.
The purpose of the protective berms is to prevent
overtopping of the upstream end of the slough.This
prevents mainstem water from entering the slough.
Therefore,the discharge from the slough originates primarly
from groundwater during the ice-covered season.(With a
protective berm in place,additional flow to the slough can
originate from local sources such as runoff.)Because this
groundwater is warmer than O°C,the ice that may form is not
of the magnitude that is found in the mainstem (up to
several feet thick).Water would still be expected to flow
out of the slough and fish would be expected to outmigrate.
Under existing natural conditions,sloughs are frequently
not overtopped during spring.A prime ,example is Slough 11
which has not been overtopped in several years,yet it is
one of the most productive sloughs in the upper river.As a
result of observations of the processes occurring in the
natural system,it is not anticipated that mitigative
"--------~~"'..__••.,.,,..-.---------•m _
RESPONSE TO COMMENT 1.132 (cont.):
measures will be necessary.As with the entire slough
modification program part,however,the potential for this
impact will be included as part of the monitoring program.
~\
-j I J 1 J 1 j ~i 1
/iJ1 V~-9 ___
o 500
I I I
FEET
....,.......:,..,~.
•_.JJ4•••_.......;:,.':...~.,.....'I......~...t.:l:~.....'\.:,..~.,#I:•~:",".~~...,:~~,t·.·
--Sl/Sl r1\'4
E9
River mil.126
~
tv
(Jl
OJ
Appendix Figure 2-G-3.Slough B located at RM 126.3 approximately,Adult Anadromous fnvestigations.
Su Hydro Studies.1982.
COMMENT 1.133:
"Page E-3-165:Summer Flows:The term 'rectifying
measures'should be clarified,as should the manner in which
the listed sloughs were selected.According to the ADF&G
Synopsis Report 3F-18/,slough #11 (RM 135)has unrestricted
access at flows greater than 6,700 cfs while slough #9 has
an acute access problem with flows of less than 18,000 cfs.
We are unable to locate sloygh B and,apparently,sloughs
#8,#8A,#8B,#8C,Moose,A ,#9A,#9B,and #17 have not
been examined by ADF&G to determine whether an access
problem exists.3F-19/We assume that different measures
are proposed for the different sloughs.Since Table E.3.39
lists a specific number of sloughs which would receive a
particular rectification,we assume specific mitigation
plans for each slough are being proposed.We would like to
review any such plans along with an explanation of the
selection process and reasons as to why flow manipulations
could not be utilized to avoid and/or minimize the adverse
impacts.Also,it is unclear as to whether short-term
augmenting flows are being proposed or not."
"3F-18/See Footnote 3F-2.[Footnote 3F-2/ADF&G.1983.
Synopsis of the 1982 Aquatic Studies and Analysis of Fish
and Habitat Relationships.Prepared for the APA.J
"3F-1.2.1 See Footnote 3F-2,supra."
RESPONSE:
The term lI rec tifying measures II refers t·o the various habitat
modification options which may be implemented to mitigate
adverse effects o£project operation on habitats utilized by
various life stages of the fish.
In the FERC License Application,thirteen sloughs were
identified which provide spawning habitat for the majority
of the slough spawning salmon between Devil Canyon and
Talkeetna.In these thirteen sloughs,one or more habitat
modification options could be implemented as necessary.If
no modification is needed,none would be implemented.The
thirteen sloughs identified as possible sites for
implementation of mitigation options were selected on the
basis of the observed number of salmon presently utilizing
the sloughs.It was determined that if fifty or more salmon
were observed in a slough during the 1981 and/or 1982 study
periods (FERC License Application Table E.3.12),the slough
~.
--
,~
--
RESPONSE TO COMMENT 1.133 (cont.):
would be included as a potential site for habitat modifi-
cation.
As assumed by the commentor,different mitigation options
could be implemented at each of the sloughs.For example,
since unrestricted access conditions occur at Slough 11 when
mainstem discharge is 6,700 cfs or greater,no restructuring
of the mouth of Slough 11 is necessary.However,the
potential limitation to access indicated for Slough 9 at
flows of 18,000 cfs or less (see the Response to Comment
1.94)indicates that restructuring of the mouth of Slough 9
does have merit.
The specification of the number of sloughs to receive
specific restructuring methods as tabulated in FERC License
Application Table E.3.39 was based on the estimated numbers
of sites for which such modification might be warranted.
COMMENT 1.134:
"Page E-3-165:Access Mitigation:Eight sloughs are
indicated as needing restructured mouths.These sloughs
should be identified.
"In the third paragraph it is indicated that lowering the
slough mouths by 1.5 feet would provide unrestricted access.
Please refer to our comments on page E-3-163.It is not
specified which sloughs would undergo the proposed
modifications.We would expect lowering of all the sloughs
by the same amount would result in different
post-modification access conditions.We would like to
review the analysis which lead to the conclusion that the
decrease in elevation by the sepcified 1.5 feet would allow
unrestricted access to specified sloughs."
RESPONSE:
The number of sloughs which may need restructuring is eight.
These will be selected from the thirteen sloughs identified
in the FERC License Application on page E-3-165 or from
other sloughs in the reach between Devil Canyon and
Talkeetna.
The specification of 1.5 feet of depth for restructuring is
based on an estimate of how much might need to be removed
from a given slough.An idealized restructuring is
presented in the License Application on Figure E.3.28.
Depending upon the specific characteristics of a slough
RESPONSE TO COMMENT 1.134 (cont.):
selected for restructuring,the average depth of excavation
may be less than 1.5 feet.FERC License Application Figure
E.3.28 represents what will be done at a typical slough.
COMMENT 1.135:
"Page E-3-166:Access Mitigation:Last Paragraph:Sloughs
which would be restructured should be identified and the
specific proposals described.We are not cognizent of what
is being proposed in this section,or where it is being
proposed."
RESPONSE:
See the Responses to Comments B.9,1.133 and 1.134.
COMMENT 1.136:
"Page E-3-166:Spawning Habitat Mitigation:Please refer
to our comments on page E-3-98.
"The referenced ongoing aquatic studies should be
described."
RESPONSE:
The referenced ongoing studies are the same as those
described to the various resource agencies (including the
U.S.Fish and Wildlife Service)during the July 18,1983
workshop conducted by the Power Authority in Anchorage.An
update on the status of these studies is provided in th~
Response to Comment C.32.
COMMENT 1.137:
"Page E-3-167:Scarifying Side-Channels:This section
should identify the four side channels proposed to be
scarified.We are interested in the analysis of the
specific side channels,including timing,volume,and
duration of the proposed high-flow release,the maintenance
schedule proposed (if needed),the species (by life stage)
that are expected to benefit due to the proposed
modification for each side channel,and the number of each
species the specific side channels would be expected to
produce.11
-
.....
--
RESPONSE TO CO~~mNT 1.137:
See the Responses to Comments B.9 and 1.133.Hydraulic
information describing the physical character of the side
channels is currently being analyzed.Refinement of the
assessment of the effects of the Susitna Project on side
channel habitat and fish speqies will be completed during
the spring of 1984.
Use of side channels under natural conditions is limited
primarily to rearing juvenile salmon.It is anticipated
that under with-project conditions,additional spawning and
incubation habitats will become available.This will be an
enhancement of the side channel habitat type.
COMMENT 1.138:
"Page E-3-168:Slough Gravel Cleaning:The utility of a
high-flow release to cleanse sloughs should be discussed.
"The location of the mainstem spawning sites should be
provided and gravel sources identified.An analysis as to
which species are expected to benefit,and the anticipated
production should be provided."
RESPONSE:
Although periodic high flows may enable cleansing the
sloughs of accumulated sediments,several considerations may
preclude the desirability of utilizing this method.For
those sloughs at which the upstream berms have been
increased to protect them from overtopping during the
winter,it may not be possible to provide sufficient water
to overtop the berms.Also,if high flow is used to cleanse
the sloughs of accumulated sediments,the flows must be high
enough to substantially overtop the upstream berms.At
discharges which barely overtop the upstream berms,velo-
cities in the sloughs are not sufficient to scour the
sediments and in fact may cause accumulation of sediments in
the slough.
The Power Authority anticipates that the DEIS will
reasonably identify spawning sites and gravel sources •
..._----_._--------------------------------------
COMMENT I.139:
"Page E-3-170 to 171:(iii)Measures to Minimize Impacts:
Once the reservoir temperature model is reflects two years
of data,an examination of post-project temperature impacts
should be made.It is our understanding that the river
temperature model used in this application,HEATSIM,has
been replaced with SNTEMP (see our comments on Chapter 2,
pages E-2-123,E-2-167).
"In the last paragraph it is unclear whether the temperature
discussions are for Watana alone,or for both dams.
Temperature impacts are expected to change during the
filling and operation of Watana,the construction of Devil
Canyon,operation of the two dams under low and high power
needs,and operation during dry and wet years.The
potential benefits of a low level intake port in the Watana
dam should be discussed as a mitigation measure for adverse
temperature impacts during filling.1I
RESPONSE:
Please refer to the Responses to Comments I.51 and I.64 (DOl
Comments on FERC License Application pages E-2-123 and
E-2-167).Please refer to the Response to Comment B.6
regarding reservoir andinstream temperature modeling and
for a discussion of HEATSIM and SNTEMP.
The temperature discussions.in the last sentence of the
first paragraph of FERC License Application page E-3-171
(Measures to Avoid Impacts)refer to Watana operation (see
FERC License Application Figures E.2.180 and E.2.182).
Temperature impacts are expected to change during the
filling and operation of Watana and during the operation of
the two dams.The construction of Devil Canyon should have
minimal impact.During the second stage of filling Devil
Canyon,temperature impacts can also be expected.
Flow throughout the year is affected by low and high power
demand and project operation during wet and dry years.
Since the resultant project flows affect temperature,the
effects of wet and dry years and power demand on temperature
are currently being investigated.
The potential benefit of a "mid"level intake port in the
Watana Dam is being examined as a mitigation measure for
adverse temperature impacts during filling.Alternative
~,
~,
,~
.-
RESPONSE TO COMMENT 1.139 (cont.):
mitigation measures are also being considered.Please-refer
to the Response to Comment 1.8.
COMMENT 1.140:
"Page E-3-173:Grayling Propagation Technology:Last
Paragraph:We recommend that the viability of a grayling
propagation program be established prior to license issuance
since it is a major element of the proposed mitigation
program."
RESPONSE:
The Power Authority concurs that the viability of a grayling
propagation program be established.This has been proposed
by the Power Authority in the FERC License Application.The
Power Authority does not agree that such a program must be
established prior to license issuance.Nor does it feel
that issuance of a license should be contingent on the
results of such a program.
COMMENT 1.141:
"Page E-3-173:Hatchery Pro a ation of Gra lin or Other
Resident Species:Paragraphs 2 and 3:The lakes and or
streams to be stocked should be determined through
consultation and approval of the appropriate resource
agencies,and land owners or managers."
RESPONSE:
The Power Authority concurs with this statement as indicated
by statements on page E-3-l73 of the License Application.
The Power Authority intends to execute agreements with the
appropriate adjacent landowners and resource agencies to
effectuate appropriate stocking of the lakes.
COMMENT 1.142:
"Page E-3-174:Introduction of Rainbow Trout into Devil
Canyon Reservoir:The potential of the Devil Canyon
reservoir as fishery habitat should be re-examined in light
of our comments on Chapter 2,pages E-2-69,and E-2-96.11
-----------,,----....wcp:
RESPONSE TO COMMENT I.142:
The Power Authority does not presently anticipate a mercury
bioaccumulation problem associated with the Susitna
Hydroelectric Project reservoirs.
Please refer to the related Response to Comment I.41.
COMMENT 1.143 :
"Page E-3-l74:(ii)Measures to Avoid Impacts:The impacts
of greater than 1-in-50 year floods should be fully
evaluated,and mitigation proposed.Given the expected life
of the project,the potential for a flood event greater than
this project design is high.
"The referenced test of the Lake Comanche cone valves was
evaluated for the applicant by Acres American.3F-~/
Please refer to our comments on page E-3-ll4.
"Given the lack of a strong endorsement by the applicant's
consultant,the anticipated frequent use of the valves,and
the potential magnitude of supersaturation as a fisheries
problem,we recommend that the physical model study be
undertaken."
"3F-20/See Footnote 3F-14 [Footnote 3F-14/Kri~hnan,G.
September 13,1982.Gas Concentration ana-Temperature of
Spill Discharge Below Watana and Devil Canyon Dams.Acres
American.Prepared for the APA.]"
RESPONSE:
Please refer to the Responses to Comments I.60 and I.55 with
regard to the need for evaluation of formation and
dissipation of dissolved gas for floods having a recurrence
interval of greater than 50 years.
Please refer to the Response to Comment I.105 with regard to
a physical model study of the cone valves.
~,
.-
COMMENT I .144:
"PageE-3-176:(i)Mitigation of Access and Impoundment
Impacts:Paragraph 2:Final decisions on the distribution
of grayling should be made through consultation with,and
approval of the appropriate resource agencies and land
owners and/or managers.II
RESPONSE:
See Response to Comment I.141.
COMMENT I.145:
"Page E-3-1 77:The
mo e ~ng e or y ~s ~n an e ryon~c s age an could
not have been the basis of either the impacts analysis or
mitigation proposals in this section.The forthcoming AEIDC
report should demonstrate that their system of models is
functional.One of the initial findings of AEIDC's work is
that,contrary to the assumption of the mitigation plan,
project impacts do extend downstream of the Chulitna River.
3F-21/We recommend that the impact assessment include
effects downstream of the Chulitna River,and appropriate
mitigation for any adverse impacts identified."
"3F-21/See Footnote 3F-11 [Footnote 3F-11/AEIDC.1983.
Examination of Discharge and Temperature Changes due to the
Proposed Susitna Hydroelectric Project.Prepared for the
APA.]II
RESPONSE:
The analysis being performed by AEIDC using a system of
linked models has resulted in an evaluation of access
conditions to adult salmon spawning areas and juvenile
salmon rearing habitats.This analysis is presented in the
AEIDC report entitled "Susitna Hydroelectric Project Aquatic
Impact Assessment:Effects of Project-Related Changes in
Temperature,Turbidity,and Stream Discharge on Upper
Susitna Salmon Resources During June Through September II
RESPONSE TO COMMENT 1.145 (cont.):
(AEIDC,1983).A final version of this report has been
submitted to the FERC.
REFERENCES
Arctic Environmental Information and Data Center (AEIDC),
Susitna Hydroelectric Project Aquatic Impact Assessment:
Effects of Project-Related Changes in Temperature,Turbidity
and Stream Discharge on Upper Susitna Salmon Resources
During June Through September (January 1984),previously
submitted to the FERC on January 20,1984.
COMMENT 1.146:
"Page E-3-179:2.5.2 Construction Phase:The mitigation
planning related to pre-construction and construction
phases,should occur prior to license issuance."
RESPONSE:
The Power Authority anticipates that the DEIS will
reasonably describe necessary mitigation for
pre-construction and construction phases,including the
extensive mitigation planning which has occurred prior to
license issuance and any additional mitigation planning
which should occur after license issuance.
The FERC would not authorize any actions which might
permanently alter the project site prior to issuing a
license.The Power Authority might proceed on state or
private lands under state permitting authority,however,to
construct non-power project aspects of the development,such
as roads or fisheries.
COMMENT 1.147:
"Page E-3-180:2.6 Monitoring Studies:We agree that an
interagency mitigation monitoring team must be established
to ensure the proper and successful execution of the
mitigation plan and to determine its effectiveness.The
composition,funding,mandate,and authorities should be
specified as a license article.We look forward to the
anticipated discussions which will lead to establishing this
team ...
RESPONSE TO COMMENT 1.147:
The Power Authority anticipates that the organization and
operation of an appropriate monitoring team will be
determined when it becomes clear what mitigation monitoring
role the various agencies require to discharge their
responsibilities.
Please also refer to Response to Comment I.119B.
COMMENT 1.148:
"Page E-3-188:2.8.1 U.S.Fish and Wildlife Service:
Recommendat~on at nottom of Page:To ensure its
effectiveness as a mitigation measure,a slough modification
demonstration should be undertaken in the Susitna River.
The demonstration slough should display,prior to
modification,the anticipated post-project conditions for
sloughs for which mitigation is proposed.For example,the
slough selected for demonstration should be characterized by
inadequate access,silt accumulation,insufficient
groundwater flow,and limited spawning habitat.Preferably,
the demonstration slough should be a slough which does not
currently support spawning and/or rearing salmon."
RESPONSE:
See Responses to Comments B.9,1.133 and 1.134.
The Power Authority appreciates the suggestions made and
will consider them for inclusion in the ongoing mitigation
planning process.
COMMENT 1.149 :
"Page E-3-189:2.8.2 Alaska Department of Fish and Game:
Second Recommendation:The response states a report
analyzing instream flows and temperatures required to
maintain existing populations would be available after
June 30,1983.We request that the applicant provide the
FWS with a copy of the report."
RESPONSE TO COMMENT 1.149:
The referenced report,the AEIDC USusitna Hydroelectric
Project Aquatic Impact Assessment:Effects of
Project-Related Changes in Temperature,Turbidity,and
Stream Discharge on Upper Susitna Salmon Resources During
June through September,"was furnished to the FERC in
preliminary form on November 1,1983 and in final form on
January 20,1984.The Power Authority will make this report
available to the Department of the Interior.
llQID.1
,.
I
\
....
.-
-
COMMENT I.150 :
"PagesE-3-295 and E-3-296:4.1.3 -Species Contributing to
Recreation,Subsistence and Commerce:The section should be
expanded to reflect that not only birds,but many wildlife
species in the project area contribute to non-consumptive
forms of recreation.Incidential viewing of wildlife in
conjunction with other activities is an unquantifiable but
well documented value.These non-consumptive values,the
subsistence and commerce values and the ecological values
mentioned in the Introduction,Section 4.1,were all
considered in selecting evaluation species within the FWS
Mitigation Policy (46 F.R.No.15,January 23,1981)and
Resource Category determinations for this project (FWS
letter to Eric P.Yould,January 24,1983)."
RESPONSE:
The last sentence of the first paragraph of Section 4.1.3
(FERC License Application page E-3-295)should be modified
to read:"In theory,many wildlife species contribute to
non-consumptive forms of recreation such as bird-watching,
but the area is too remote to attract many people who corne
solely to view wildlife."A description of existing and
projected recreational uses of project area wildlife is
presented in Exhibit E,Chapter 7.Consumptive wildlife
values are discussed in ExhibitE,Chapter 5 •
COMMENT I.151 :
"Page E-3-304:-Cover Requirements:Paragraph 7:Proposed
remapping of vegetation to better reflect moose habitat
components should be described here.Please also refer to
our previous comments,Section 3.2.2(a).1l
RESPONSE:
The description of the program for remapping of vegetation
in the Susitna Project area is contained in PERC License
Applicat:ion,Exhibit E,page E-3-201.Refinements to the
scope of the mapping efforts are currently being made in
consultation with personnel from the Alaska Department of
Fish and Game and the u.S.Fish and Wildlife Service.
COMMENT 1.152:
IIPage E-3-305:Habitat Use in the Middle Susitna Basin:
Paragraph 1:The evaluation of moose use of different
vegetation types by month would be improved by considering
the comparative availability of these types and subareas
important to moose throughout the middle Susitna basin.
Vegetation mapping,including understory characteristics did
not occur in 1983 as had been indicated by the applicant in
response to our conunents on the draft license application
(Chapter 11,W-3-204).Once vegetation is retyped we
recommend that this and other baseline data be reevaluated.
The availability,of different vegetation types and
understory values of those types should be considered within
the constraints described on page E-3-304.11
RESPONSE:
A Pilot Browse study and a Phenology study were
accomplished.Both of these studies provide a valuable base
for scoping the vegetation mapping.See the Response to
Conunent 1.151.
COMMENT 1.153:
"Page 307:-Food Habits:Paragraph 3:While we support
attempts to quantify moose winter carrying capacity as a
first step in simulation modeling tjos sectopm sjpi ;d a;sp
jost [sic]references and reflect concurrence of principal
moose investigators.The assumptions included in Appendix
E.3.H should be validated.Please refer to our comments on
Section 4.3.1(a)(iii)and on the Mitigation Plan.1I
.RESPONSE:
The Power Authority has difficulty in fully understanding
the first part of this Comment due to the typographical
errors.The second part refers to FERC License Application
Appendix E3H.An updated version of the FY 1984 Terrestrial
Program Plan of Study for impact assessment and mitigation
plan refinement is presently being £inalized and will be
transmitted to the FERC within a few weeks.
-
-
-
-
-
.-
-
COMMENT I.154:
"Page E-3-310:•Lower Susitna Basin;Paragraph 2:The
applicant should confirm that all biotelemetry data
indicated here as being available in June 1983 is contained
in the ADF&G report provided to the FWS in September 1983.
3W-l/We have similarly assumed that other information to
be supplied in June 1983 is also in the September report
(e.g.,responses to our comments on the draft,Chapter 11,
W-3-209)."
"3W-1/Modafferi,Ronald D.April 1983.Susitna
Hydroelectric Project,Phase II Progress Report,Big Game
Studies.Volume II.Moose-Downstream.Submitted to the APA
by the ADF&G.
"Ballard,Warren B.,Jackson S.Whitman,Nancy G.
Tankersley,Lawrence D.Aumiller,and Pauline Hessing.
April 1983.Susitna Hydroelectric Project,Phase II
Progress Report,Big Game Studies.Volume III.Moose
Upstream.Submitted to the APA by the ADF&G."
RESPONSE:
The biotelemetry data reference on page E-3-310 of the FERC
License Application was a general reference to the data
contained in the annual reports produced by the Alaska
Department of Fish and Game (ADF&G)in 1983 for big game
studies.The reports identified in the Comment footnote by
Modafferi (1983)and Ballard,et ale (1983)contain the
subject data.These reports were transmitted to the FERC by
letter dated May 31,1983.The next series of ADF&G annual
reports,which will contain an additional year of
biotelemetry data,are scheduled to be available in
May 1984.
REFERENCES
ADF&G,Susitna Hydroelectric Project,Phase II Progress
Report -Big Game Studies (1983),previously submitted to
the FERC on May 31,1983.
Modafferi,R.D.,Volume II,Moose -Downstream (1983).
COMMENT I.155:
"Page E-3-315:•Mortality Factors:We reiterate our draft
application recommendation that this discussion include
hunting as a mortality factor.Although the applicant's
response indicated that the subject was covered in
Chapter 3,Section 5,we find no such section (Chapter 11,
W-3-216).Please also see our comments on Chapter 5,
Section 3.7.2.Treatment of hunting should be better
coordinated between Chapters 3 and 5,given the effect that
both recreational and subsistence hunting can have on
wildlife population size,structure,and distribution."
RESPONSE:
The following paragraph should be viewed as an addition to
FERC License Application Section 4.2.1(a)(iii)--Mortality
Factors (FERC License Application page E-3-317).
While brown bears and wolves are important predators of
moose and account for a significant percentage of natural
mortality,hunting mortality is also an important factor
affecting moose populations.Hunting,at least in recent
decades,has been highly regulated within the Susitna Basin.
In most years,take is restricted to bulls.A given rate of
hunting mortality probably has less effect on the population
size of moose than the same natural mortality rate due to
the bulls-only restriction.Since moose are polygynous,
taking of bulls usually does not directly affect subsequent
reproduction.Poaching mortality is less predictable and
may account for additional mortality of breeding animals.
COMMENT 1.156:
"Page E-3-325:(c)Dall Sheep:Paragraph 1:The
preliminary nature of information presented here should be
stated in view of ADF&G's proposal for intensive ground
observations and sheep studies which were conducted from
March through July,1983."
_.
.....
-
RESPONSE TO COMMENT 1.156:
The subject studies are described in detail on page E-3-524
of the FERC License Application under Continued Monitoring
and Study Needs.Preliminary results from these studies are
discussed in the Response to Comment A.11.Final results of
these studies are scheduled to be available by May 1984.
Please refer to the Response to Comment 1.189 for a
description of project area sheep studies conducted from
1980 through 1983.
COMMENT 1.157:
"Page E-3-327:(ii)Mineral Lick Use:Paragraph 1:The
Jay Creek mineral lick area should be better described and
defined by elevation range and special area."
RESPONSE:
See the Response to Comment A.11.
COMMENT I.158 :
"Page E-3-328:(ii)Mineral Lick Use:Paragraph 5:During
ADF&G's intensive 1983 summer studies,moose were not
observed using the lick itself (Nancy Tankersley,personal
communication).ADF&G now considers previous observations
of moose use to be incidental."
RESPONSE:
This is the Power Authority's current understanding as well.
COMMENT 1.159:
"Page E-3-328:(d)Brown Bear:Paragraph 1:Current study
delays and funding cutbacks are preventing collection of
COMMENT I.159 (cont.):
valuable information and may make later comparisons of
year-to-year variations difficult.3W-~/"
"3W-2/APA.September 8,1983.Appendices 2 and 3 to Agenda
Item-IV,Action Item No.1,FY 1983 Program Changes and
Their Impact on the FY 1984 Program and Current Proposed
FY 1984 Budget Allocations,Susitna Hydroelectric Project.
Prepared for the APA Board of Directors.11
RESPONSE:
The Power Authority continues to fund big game studies.
"Valuable information U probably referred to vegetation maps,
wetlands maps and big game censuses.All of these
activities are funded through FY84,and are funded in the
FY85 budget approved by the Board of Directors.Since
little location and census activity is performed during
summer and early fall,little information was lost before
these activities were fully funded by Board of Directors
action on supplementary budget requests in November 1983.
Pilot Browse,Phenology and ADF&G Game Reports will be
available in 1984.
COMMENT I.160 :
"Page E-3-331:Seasonal Movements:Paragraph 4:Given the
large home range sizes of brown bear ,documented on page
E-3-323 (last paragraph through page E-3-334,paragraph 1),
we do not believe that bear use of the Susitna River area
has been overestimated as indicated here._
"Page E-3-335:Home Ranges:Paragraph 5:Our proceeding
comments apply here."
RESPONSE:
The assessment of whether the estimates of bear use of the
Susitna River area represent underestimates or overestimates
is entirely dependent on the study area referred to.If one
refers to the study area for which the population of
radio-collared brown bears is representative,then the
estimates are probably underestimates due to the fact that
some bears'use of the area is missed because of monitoring
frequency.However,if one refers to t~e Middle Susitna
Basin (refer to FERC License Application Figure E.3.3.for
its boundaries),as was done in the cited paragraphs of the
~J
-
,..,
-
'"""
RESPONSE TO COMMENT 1.160 (cont.):
License Applicatio~,then the estimates are probably
overestimates because the sample of radio-collared animals
does not represent a random sample of bears within the
Middle Basin.In particular,the sample includes little
representation .from the Oshetna and Tyone River watersheds
which are part of the Middle Basin but are distant from the
Susitna River.
COMMENT 1.161 :
"Page E-3-337:(c)Black Bear:Paragraph 1:Funding
cutbacks and study delays are precluding necessary study
progress and will make later data analyses needlessly
difficult and incomplete."
RESPONSE:
Please refer to the Response to Comment 1.159.
COMMENT 1.162 :
"Page E-3-341:Food Habits:Para<Jraph 2:The applicants
should describe ongoing studies which address the importance
of ungulate prey to black bear (page 236;paragraph 1 of the
draft application)."
RESPONSE:
The ongoing big game studies are described in the ADF&G
Fiscal Year 1984 Plan of Study referenced in the Response to
Comment C.78.Pages 12 and 13 of that study describe the
studies of black and brown bears in the project area.
COMMENT 1.163:
"Page E-3-342:Home Ran<Je:Para<Jraph 2:It should be
clarified how overlaps in home ranges with the impoundment
area can be greater than 100%."
RESPONSE:
In the 1981 black bear and brown bear studies of Miller and
McAllister (1982),bear use of areas in the proximity of the
Susitna River was examined by comparing three concentric
zones:the Watana and Devil Canyon impoundments,a one-mile
zone surrounding each impoundment and a five-mile zone
RESPONSE TO COMMENT I.163 (cont.):
surrounding each impoundment.These zones are shown in the
attached figure excerpted from Miller and McAllister (1982).
Examination of the attached figure shows that a portion of
the two five-mile zones overlap in the area between the
Devil Canyon and Watana impoundments.Values over 100%
overlap were obtained when a large portion of a bear home
range occurred within this area.For further information
please refer to Miller and McAllister (1982).
REFERENCES
ADF&G,Susitna Hydroelectric Project,Phase I Final
Report-Big Game Studies (1982),previously submitted to the
FERC on May 31,1983.
Miller,S.D.and D.C.McAllister,Volume VI,Black
Bear and Brown Bear (1982).
~,
-
-
•....'"'..=•~
=.;.l,..a:I•..-{
~~-~
•<
C CJ
0 X
CIt "tl>-c::
0 =a.'"'~~-~
e ~
'l"+
co X..Ie=..0 e
~..0a.'"'-~
0
c:o
>-c:
1II
()
••
.•-c:
•G..e-~
•c:~~
oa.e
III-e --N•aJ
C 0"1
0 -'-'
"CIc:•
c
.2-
e
•~=
•~-e
o..-
•==-III
C
'ac:
1II..1II..c:g 1II:-1II
~
'a
III•0a.
0..a.-0
•c:
•..
0
~•
----g..
~
....
I
l
I""'"
I
-
COMMENT L164:
"Page E-3-342:Population Size:Funding cutbacks prevented
the 1983 spring recensusing of black bear."
RESPONSE:
The 1983 Spring recensusing of black bear was attempted but
curtailed because too few bears were being observed compared
with the number known to be present based on radio tracking.
COMMENT I.165:
"Page E-3-344:(f)Wolf:Funding cutbacks have curtailed
monitoring.Since May 1983 only 2 relocation flights have
been made for radio-collared wolves."
RESPONSE:
Please refer to the Response to Comment I.159.
COMMENT I.166:
"Page E-3-347:-Food Habits:Paragraph 6:Given the
habitat losses,disturbances,and other project impacts
discussed in Section 4.3,it would seem doubtful that the
caribou population will increase,thus benefitting wolves
and relieving some moose predator m.ortality as suggested
here."
RESPONSE:
This Comment refers to the "Baseline Description"section of
the FERC License Application which is intended to provide a
"without-project"description.Effects of the Project on
caribou are described in Section 4.3.This section
indicates that quantification of cumulative Project effects
on caribou is impossible (FERC License Application
page E-3-501).Therefore,although the Nelchina herd is
apparently increasing in size at present,the direction and
rate of change with the Project is not possible to predict.
Given the considerable historical variation in herd size and
the uncertainty regarding the significance of Project
impacts,it is certainly possible that the herd may continue
to increase under the "with-project ll scenario.Refer to the
Jakimchuk study already sent to the FERC,for the view that
I
-
-
-
-[
.....
RESPONSE TO COMMENT I.166 (cont.):
population size may be effectively independent of project
impacts.
REFERENCES
Jakimchuk,R.D.,Disturbance to Barrenground Caribou;A
Review of the Effects and Implications of Human Developments
and Activities (July 1980),previously submitted to the FERC
on May 31,1983.
COMMENT I.167 :
IIPage E-3-349:(g)Wolverine:As with other big game
species,funding cutbacks are interfering with needed data
collection.No funds have been available since spring of
1983 to track the six wolverine radio-collared for the
project.II
RESPONSE:
Please refer to the Response to Comment I.159.
COMMENT I.168:
IIPage E-3-354:(a)Beaver:There have been no further
beaver studies or model development since March 1983.
Additional data have not been provided as indicated in
response to our comments on the qraft license application
(Chapter 11,W-3-237).We are particularly disappointed
that the opportunity has been lost to verify and expand upon
1982 cache counts and to better evaluate beaver habitats and
populations which could be affected by the proposed
project."
RESPONSE:
An aerial beaver cache survey along the Susitna River was
conducted during the fall of 1983.The survey included a
complete count between Talkeetna and Portage Creek and a
general survey downstream of Talkeetna.Beaver
overwintering studies are scheduled to be conducted this
spring and further model development is also planned based
on field survey data and other inputs •
COMMENT 1.169 :
"Page E-3-356:(ii)Population Characteristics:At present
there is no reliable estimate of the beaver population below
Talkeetna (Phil Gipson,personal communication).Such an
estimate would serve as a baseline for evaluating upstream
habitat losses and downstream habitat improvement.Fall
cache counts,marking of those caches,and later spring
surveys to determine overwinter survival are necessary to
assess impacts.Surveys could help identify the movement
patterns of young animals and downstream habitats which may
be improved due to project construction.Coordination
between furbearer biologists and hydrologists to assess
icing conditions was not accomplished in spring,1983 as
agreed to at the February 28 -March 2,1983 follow-up ABA
workship.3W-3/1f
"3W-3/Everitt,Robert R.,Nicholas C.Sonntag,Gregory T.
Auble,James E.Roelle,and William Gazey.October 22,
1982.Susitna Hydroelectric Project Terrestrial Environ-
mental Workshop and Preliminary Simulation Model.LGL
Alaska,Anchorage and Fairbanks.
"Everitt,Robert R.,Nicholas C.Sonntag,Gregory T.Auble,
James E.Roelle,and William Gazey.April 27,1983.
Susitna Hydroelectric Project,Draft Report,Terrestrial
Environmental Mitigation Planning Simulation Model.ESSA
Ltd.,USFWS and LGL Alaska for Harza/EBASCO,Anchorage."
RESPONSE:
Please refer to the Responses to Comments 1.168 and 1.269.
COMMENT 1.170:
"Page E-3-357:(ii)Population Characteristics:Paragraph
3:The need for trapper surveys was agreed to at the
February 28 -March 2,1983 follow-up ABA workshop.3W-4/
Since no such work has been undertaken,we recommend that a
trapping survey be made of residents along the railroad,in
~.',
-
~.
-
.-
--
-
-
COMMENT 1.170 (cont.):
Talkeetna,in Cantwell,along the Denali Highway,and in the
Watana area.1I
"3W-4/See Footnote 3W-3.[Footnote 3W-3/Everitt,Robert
R.,Nicholas C.Sonntag,Gregory T.Aub1e~James E.Roelle,
and William Gazey.October 22,1982.Susitna Hydroelectric
Project Terrestrial Environmental Workshop and Preliminary
Simulation Model.LGL Alaska,Anchorage and Fairbanks.
IIEveritt,Robert R.,Nicholas C.Sonntag,Gregory T.Auble,
James E.Roelle,and William Gazey.April 27,1983.
Susitna Hydroelectric Project,Draft Report,Terrestrial
Environmental Mitigation Planning Simulation Model.ESSA
Ltd.,USFWS and LGL Alaska for Harza/EBASCO,Anchorage.]II
RESPONSE:
Recently completed household and business surveys of
Talkeetna,Trapper Creek and Cantwell residents will help
supplement the information on trapping presented in the FERC
License Application.The household survey included
questions on the number of persons in each household who
trap,where and how often they trap,what species they trap,
and the importance of trapping for recreation,food,income
and cultural pursuits.The business survey included
questions on the percent of gross annual revenues
attributable to trapping activities,what areas are
important to those activities and what species are trapped
as part of their business.The results of the surveys are
being tabulated,and a general report will be available in
March 1984.
COMMENT 1.1 71 :
IIPage E-3-357:(b)Muskrat:Sufficient water depth below
ice is a habitat requisite for muskrat as well as beaver.
Measurement of lake depths in the middle Susitna River basin
would allow assessment of which lakes are critical
overwintering areas.Shallower lakes where pushups may be
visible but muskrats do not successfully overwinter could
also be then identified (Phil Gipson,personal
communication).11
----,--._--,------"--------------------------------
RESPONSE TO COMMENT I.171:
The reviewer has not substantiated the need for the
requested additional information concerning lake depths in
the middle Susitna Basin.FERC License Application page
E-3-436 notes that:
"Of the 103 lakes surveyed for muskrat sign in spring
1980,17 occurred within borrow sites D or E or the
impoundment zone (Table E.3.154);only 5 of these lakes
have muskrat pushups (Gipson et ale 1982).A total of
13 pushups were observed on these 5 lakes but the
number of muskrats this represents is unknown (pushups
are temporary structures,and one muskrat can create
many of these during a winter).A likely estimate of
the number of muskrats to be lost as a result of this
habitat loss is 5 to 10 animals.Improved downstream
habitat will compensate for this loss."
Downstream habitat improvement for muskrat will occur as a
result of stabilization of water levels and greater winter
water depths in sloughs and side channels between Devil
Canyon and Talkeetna.Of the 103 lakes surveyed for muskrat
sign during spring 1980,only 16,or approximately 15%,
actually contained muskrat pushups (Gipson 1982).Of these
16 lakes,only 5 will be directly affected by project
construction and operation.It is unlikely that these 5
lakes provide "critical overwintering areas"for the muskrat
population of the middle Susitna Basin,and it is improbable
that their removal will produce population-level effects on
muskrat.Thus,establishing a"field program for the
measurement of lake depths in the middle Susitna River Basin
appears to be unnecessary and inappropriate.
REFERENCES
ADF&G,Susitna Hydroelectric Project,Subtask 7.11 -Phase I
Report,Environmental Studies,Furbearer Studies (1982).
Gipson,P.S.,S.W.Buskirk and T.W.Hobgood (April
1982)•
~'I
-
-
-
-
-
-
COMMENT I.172:
"PageE-3-358:(cl River Otter:Paragraph 2:We suggest
that furbearer and aquatic researchers determine whether
areas where otter tract concentrations were observed in
November 1980 correspond with grayling movements to
overwintering areas."
RESPONSE:
Studies by the Alaska Department of Fish and Game (1983)
have shown that grayling exhibit a fall outmigration from
tributaries to the mainstem.No grayling overwintering data
were collected in November 1980 to determine if otter track
concentrations correlate with grayling movements to
overwintering areas and the limited data collected since
then are not sufficient to perform this analysis.No plans
are being made to define overwintering areas to the extent
necessary to perform this correlation,primarily because of
the extreme difficulties in sampling fish during the winter
period and the limited data that are produced.Even if
grayling concentrations were found near otter track
concentrations,it would require an otter food habits study
to confirm that the otter were feeding on grayling and not
other fish which may overwinter in the same locations as
grayling.Finally,because otter tracks were observed at
46 percent of the 37 checkpoints visited along the Susitna
River and were fairly uniformly distributed among
checkpoints between the Indian and Oshetna Rivers (Gipson,
et al.1982),the effort required to determine whether or
not track concentrations correlate with grayling
concentrations does not appear to be justified.
REFERENCES
Alaska Department of Fish and Game,Susitna Hydro Aquatic
Studies Draft Phase II Data Report -Winter Aquatic Studies,
October 1982-May 1983 (1983),previously submitted to the
FERC on October 31,1983.
ADF&G,Susitna Hydroelectric Project,Subtask 7.11 -Phase I
Report,Environmental Studies,Furbearer Studies (1982).
Gipson,P.S.,S.W.Buskirk and T.W.Hobgood (April
1982)•
------,,_........_---------------------------------------
COMMENT 1.173:
"Page E-3-365:(h)Coyote:An addition to the information
provided here is an observation of a coyote feeding on
remains of a moose on ice in the Susitna River,about
7 miles downstream from the mouth of Portage Creek during
March,1983 (Phil Gipson,personal communication)."
RESPONSE:
This information is consistent with the coyote distribution
information provided in the cited section (License
Application page E-3-365).
COMMENT 1.174:
"Page E-3-369 (a)Raptors and Raven:Paragraph 1:Defini-
tions for raptor 'nesting locations'and 'nest sites'were
found in Section 4.3.1(n)(i),page E-3-443,paragraph 1:not
in Appendix 3.1 as indicated here.
liThe draft report stated '•••precise elevations of nests
and cliff-tops relative to maximum impoundment fill levels
are integral to a sound mitigation plan •••'(Chapter 11,
W-3-251).That information is essential to several of the
recommended mitigation plans (e.g.section 4.4.2(a)(9),and
(b)(10),(20),and [21]).The applicant should confirm that
these data were obtained,and by whom,and how the data will
be incorporated into the Mitigation Plans."
RESPONSE:
More precise elevational and horizontal measurements of
nesting locations and potential mitigation sites will be
made during early sununer of 1984 by an experienced raptor
biologist.This information will be used to develop a more
detailed raptor mitigation plan containing specific
implementation procedures for mitigation impacts at each
nesting location and for enhancing nesting habitat at
selected sites.
The most precise nest location information currently
available has been provided in Exhibit E,Chapter 3,Tables
E.3.127,E.3.127b,E.3.160,E.3.161 and E.3.162.As stated
in the footnote to Table E.3.161,
"Differences occur between elevations given here and
those reported by Kessel et al.(1982a)••••AII
~,
-
.....
-
.-
RESPONSE TO COMMENT 1.174 (cont.):
elevations have been reviewed and some revisions were
mader however,in some cases,estimates given here may
contain errors of as much as 30.5 m (100 ft.).All
elevations must be considered approximate (unless
otherwise noted)until the majority are rechecked with
the precision altimeter."
Elevations of the raptor nesting locations and nest sites
described in Tables E.3.160 and E.3.l6l are estimates made
from topographic maps with 100-ft.contour intervals .
.-.
-
COMMENT 1.175:
"Page E-3-385:(v)Middle Basin Bird Conununities:We
appreciate inclusion of Table E.3.139 and the expanded
discussion on avian habitat types and densities.Once the
proposed vegetation and wetland maps are completed,these
data should be reexamined for further understanding of
middle basin bird conununities and project impacts.1t
RESPONSE:
Results of vegetation mapping (see Response to
Conunent 1.151)can be used to refine impact assessments and
mi tigation plans.
COMMENT 1.176:
"Page E-3-396:4.3 Impacts:Paragraph 1:While we agree
that acceleration of secondary development in the Susitna
River basin is an indirect rather than direct project
impact,the potential for such development should be fully
assessed within the intent of NEPA (42 U.S.C.4321 et
seq.).11
RESPONSE:
Please see the Response to Comment F.71.To reiterate,the
potential for secondary development in the Susitna River
Basin is dependent upon action and circumstances that are
beyond the ability of the Power Authority to predict or
determine.The Power Authority is continuing to work on
land use planning and management policies with the Bureau of
Land Management,Alaska Department of Natural Resources,
Matanuska-Susitna Borough and the native corporations.
Collectively and individually,these entities will.have the
greater controllable influence on the ultimate development
of the Susitna River Basin.
The FERC License Application and supporting material have
addressed the potential for secondary development to the
extent possible,and have identified the uncertainty of such
development.
The Power Authority anticipates that the DEIS will
appropriately address reasonably foreseeable indirect
impacts,if any.
COMMENT I.177:
"Page E-3-396:4.3 Impacts Paragraph 2:Please refer to our
comments on Table E.3.144 regarding inconsistencies with
data presented elsewhere and to additional comments on the
species -specific impact tables.1I
RESPONSE:
This Comment cross-references other Comments and does not
raise an issue or question by itself.For specific
discussions of these other aspects,refer to the appropriate
Responses as follows:
1.Table E.3.144--see Response to Comment I.305;and
2.Species-Specific Tables E.3.146 and E.3.168--see
Responses to Comments I.306 to I.312.
COMMENT I.178:
"Pages E-3-396 to E-3-397:Moose:The qualitative statements
which characterize this section confirm the need to
aggressively pursue development of the moose carrying
capacity model and completion of necessary background
studies.Please refer to our previous concerns with the
validity of these numbers (Section 4.2.1(a)[ii])."
RESPONSE:
Please refer to the Responses to Comments C.86 and I.153.
COMMENT I.179:
"Page E-3-396:(a)Moose:Paragraph 1:Details on specific
locations and the magnitude of benefits from the Watana
project should be provided here."
RESPONSE:
The cited paragraph is the introductory paragraph of the
moose impact section,and,therefore,the Power Authority
does not agree that details and specifics of benefits should
be provided there.Discussion of the potential benefits of
the Watana project to moose are provided in FERC License
Application pages E-3-407 and E-3-466 relative to downstream
habitat.
~,
i~
.-
",...
-
COMMENT 1.180:
"Page E-3-405:-Permanent Loss of Habitat:Paragraph 1:In
addition to describing how increased moose densities could
cause a decline in habitat quality adjacent to project
impact areas,consideration should be given to existing
utilization of those areas by moose and whether displaced
moose could ultimately survive.1I
RESPONSE.:
Please refer to Mitigation Plan No.8,FERC License
Application page E-3-530 for an explanation of contingency
plans for directly displaced moose should surrounding browse
availability be determined to be too low for increased
numbers of moose.
COMMENT 1.181:
"Page E-3-406:-Upper Susitna Basin:Please refer to our
previous comments on altered habitats,including needed
quantification of these areas (Section 3.3.1(a)(ii)and
(iii),(b)(ii),(iii),and [iv).We are concerned that due
to decreased funding,plant phenology data obtained in 1983
may not be analyzed.These data and analyses are essential
to assess implications of the reservoir impoundment and
potential values of proposed habitat improvements.See our
comments on Section 3.3.1 (b)(iv)."
RESPONSE:
The plant phenology data obtained in 1983 are currently
being analyzed,and a final report containing the data and a
discussion of results is scheduled to be completed in early
May 1984.These data will be utilized in the continuing
review and analyses of impacts and mitigation measures.
For more information specific to the referenced sections in
this Comment,please refer to the Responses to
Comments 1.338 to 1.340 and 1.345 to 1.352.
COMMENT 1.182:
"Page E-3-409:-Blockage of Movements:To better
understand potential movement blockages,we recommend that
concentration areas and timing of moose crossings of the
COMMENT l.182 (cont.):
Susitna River be analyzed relative to slopes in the drawdown
zone.If
RESPONSE:
The commentor has not indicated what the impact would be
that this analysis would address.
COMMENT l.183:
"Page E-3-410:-Blockage of Movements:Paragraph 2:As we
commented on Chapter 2,page E-2-90,the expected delay in
ice cover formation downstream from Talkeetna should be
re-evaluated and the results provided to allow better
quantification of the potential for interference with moose
movements."
RESPONSE:
Please refer to the Responses to Comments I.40 and B.6.
COMMENT I.184:
"Page E-3-410:Blockage of Movements:Paragraph 5:The
applicant should provide the schedule and scope for the
additional information."
RESPONSE:
The additional information discussed in this paragraph
refers to the ongoing upstream moose studies being conducted
by the Alaska Department of Fish and Game.The most recent
ADF&G annual report (Ballard,et ale 1983)was published
following publication of the FERC License Application and
transmitted to the FERC by letter dated May 31,1983.The
-
-
RESPONSE TO COMMENT 1.184 (cont.):
next ADF&G annual report will be available in April-May 1984
and will be transmitted to the FERC at that time.
REFERENCES
ADF&G,Susitna Hydroelectric Project,Phase II Progress
Report -Big Game'Studies (1983),previously submitted to
the FERC on May 31,1983.
Ballard,W.B.,J.S.Whitman,N.G.Tankersley,L.D.
Aumiller and P.Hessing,Volume III,Moose -Upstream
(1983)•
COMMENT 1.185:
Kpage E-3-411 -Mortality:Paragraph 1:The need to provide
baseline data on hunting demand and harvest was previously
identified,as was the need to coordinate consideration of
hunting between Chapter 3 and Chapter 5 (Section
4.2.1(a)[iii]).Whether hunting will remove displaced
animals and thus prevent overbrowsing of remaining habitats
will depend on the magnitude of that displacement and
regulation of hunting by the Alaska Board of Game.1I
RESPONSE:
Please refer to the Response to Comment 1.155.Dispersal of
moose directly displaced by impoundment filling would likely
lead to increased utilization of browse in the immediate
vicinity of the impoundment.Decisions as to whether these
moose would best be utilized by the hunting public,or
should be allowed to integrate into surrounding moose
populations,thereby potentially increasing those
populations above their carrying capacity,is the
responsibility of the Alaska Board of Game.Recommendations
provided in future mitigation plans,currently being
refined,will be closely coordinated with personnel from the
Alaska Department of Fish and Game •
.COMMENT 1.186:
"Page E-3-412:(iii)Quantification of Project Effects:We
support efforts to model moose carrying capacity and
subsequently simulate the cumulative effects of habitat
COMMENT 1.186 (cont.):
loss,habitat alteration,and various mortality factors.
This model will also allow a quantitative evaluation of the
habitat values of alternative replacement lands.It should
also be used to evaluate habitat values of alternative
habitat improvement methods,e.g.,burning,clearing,
crushing,etc.BUdget cutbacks and study delays are,
however,interfering with the timely completion of this
habitat quantification.Contrary to information presented
here and responses to our previous recommendations
concerning vegetation values (Chapter 11,W-3-203 and
W-3-204),the necessary vegetation mapping may not be
available until State fiscal year 1985."
RESPONSE:
Please refer to the Response to Comment 1.153.Also,please
note that although certain planned programs were not
conducted in 1983 due to budgetary limitations,final
simulation modeling results are still expected to be
available by early 1986 as stated in the FERC License
Application (page E-3-4l4).
COMMENT 1.187:
"Page E-3-414:(iii)Quantification of Project Effects:
Paragraph 6:The scope and timing of preliminary model
analyses to be available in 1983 should be described."
RESPONSE:
Please refer to the Response to Comment C.86.
COMMENT 1.188:
"Pages E-3-416B:(ii)Filling and Operation:paragraph 7:
Please refer to our previous comment on page E-3-409 that
slopes within the drawdown zone be analyzed relative to
wildlife crossings (Section 4.3.1(a)[ii]).We again
recommend modeling of reservoir ice formation and break-up
during filling as well as operation (see our comments on
Chapter 2,page E-2-88).The time of break-up has
significant implications with regard to potential crossings
by animals such as caribou."
~l
~I
mPJmj,
.....
RESPONSE TO COMMENT 1.188:
This Comment refers to previous specific Comments.Please
see the Responses to Comments 1.182 and 1.39 for Responses
to the first and second parts of this Comment,respectively.
COMMENT 1.189:
"Page E-3-417:(c)Dall Sheep:Sheep studies,particularly
in the Jay Creek mineral lick area,were not undertaken
until March through July,1983.Information presented here
should be qualified as preliminary.n
RESPONSE:
We disagree that sheep studies were not undertaken until
1983.Ballard,et ale (1982)presents the results of aerial
sheep surveys of the project area conducted during
summer 1980,winter 1981,spring 1981 and summer 1981 as
well as ground observations of the Jay Creek lick area
conducted in spring 1981.The spring-early summer 1981
aerial surveys included 33 aerial surveys of the Jay Creek
lick area.In addition,Tankersley (1983)presents the
results of aerial sheep surveys of the project area
conducted in winter 1982 and summer 1982,plus numerous
incidental aerial observations.Ground observations of the
Jay Creek lick area conducted during spring 1982 and aerial
composition counts in the Watana Hills sheep trend count
area for 10 years between 1950 and 1982 are also reported.
Please also see the Response to Comment 1.189.
REFERENCES
ADF&G,Susitna Hydroelectric Project,Phase I Final Report -
Big Game Studies (1982),previously submitted to the FERC on
May 31,1983.
Ballard,W.B.,J.H.Westlund,C.L.Gardner and
R.Tobey,Volume VIII,Dall Sheep (1982).
ADF&G,Susitna Hydroelectric Project,Phase II Progress
Report -Big Game Studies (1983),previously submitted to
the FERC on May 31,1983.
Tankersley,N.G.,Volume VIII,Dall Sheep (1983).
______.......-....o ~__------_
COMMENT 1.190:
"Page E-3-418:(i)Construction:Paragraph 2:Disturbance of
sheep at the Jay Creek mineral lick may be more immediate
than lick inundation.However,disturbance from
recreationists could extend through the project life.The
cumulative impacts should be evaluated."
RESPONSE:
During project construction,major ground activities will be
prohibited within one-half mile of the Jay Creek mineral
lick between April 15 and June 15.During and following
construction,the reservoir adjacent to the lick will be
closed to boat and float plane use within one-half mile of
the lick (see FERC License Application page E-3-532).It is
expected that these restrictions will reduce the potential
for disturbance impacts by recreationists to a low level,
probably less than the current potential for disturbance by
field study personnel.As project planning and Mitigation
Plan refinement continues,these restrictions will be
refined as necessary in cooperation with resource management
agencies.
COMMENT 1.191:
"Pages E-3-419 to E-3-420:(i)Construction:Paragraphs 2
through 4:The Jay Creek mineral lick area is apparently
more extensive than it was originally thought to be.
Additional downstream lick areas discovered during ADF&G's
recent work in the area would also be fully or partially
inundated (Nancy Tankersly,personal communication).While
erosive water action could cause exposure of additional
mineral soil,it will more likely cause loss of the steep
rocky cliffs resulting in added stress and exposure to
predators when sheep use the area.
"Given the apparent elevation range of the Jay Creek lick
area,it is uncertain that the lick was originally created
or is maintained by the water action along t~e creek.
liThe discussion should consider impacts from proposed
reservoir clearing activities and provide information on how
access for those activities is to be provided.Timber
clearing and associated access are further sources of
disturbance and could impact sheep use of the Jay Creek lick
area."
"'"",
RESPONSE TO COMMENT I.191:
""'"Please refer to the Response to Comment A.l1 for further
discussion on the complex of lick sites known as the Jay
Creek mineral lick,including the East Fork lick located
approximately 10 miles north of the reservoir.The Jay
Creek lick complex consists of many lick areas generally
above the Watana Reservoir elevation (usually
2,200-2,500 feet in elevation).The most popular area is a
large rocky bluff ranging from 2,000 to 2,550 feet in
elevation.At present,it does not appear likely that
erosive action of reservoir waters will cause loss of steep,
rocky cliff habitat.However,this possibility will be
investigated during future impact assessment refinement
efforts.
Please note that the text of the FERC License Application
does not say that the Jay Creek lick area was created or is
maintained by the water action along the creek as suggested
by the Comment.
Please refer to the Response to Comment I.190 regarding
access restrictions during project construction and
operation.
COMMENT I.192 :
"Page E-3-421:(i)Construction:Potential disturbance and
loss of habitat from borrow area activites should be
discus·sed.3W-S/"
--
"3W-5/Miller Sterling D.and Dennis C.McAllister.1982.
Susitna Hydroelectric Project.Phase I Final Report.Big
Game Studies.Volume VI,Black Bear and Brown Bear,
page 60.Submitted to the APA by the ADF&G."
RESPONSE:
Excavation of borrow areas required for construction of the
Watana dam and adjoining facilities (e.g.,cofferdams,
spillways and service roads connecting the camp,village and
powerhouse-dam complex)will remove habitat of brown and
black bears,influencing seasonal movements and preventing
foraging in locations now used by these species in spring
and late summer.During project construction,borrow area
___F01li_--""-'_'-
RESPONSE TO COMMENT 1.192 (cont.):
excavation activities will disturb individual bears
directly.
Borrow area E (see Exhibit E,Chapter 6,Figure E.6.13)is
in a brown bear spring foraging area (Miller and McAllister
1982).Approximately half of this site (by area)occupies a
first-level terrace on the north side of the active
floodplain of the Susitna River.This terrestrial habitat
area will pond during excavation and will be permanently
lost as a source of forage vegetation (see Exhibit E,
Chapter 3,Figure E.3.25).As noted by Miller and
McAllister (1982),"over the long run the habitat in this
area would likely be vacated by brown bears regardless of
the borrow area because of its proximity to the Watana dam
site and flooding by the Devil Canyon dam."
Excavation of three other borrow areas will displace brown
bears with home ranges overlapping these sites (Miller and
McAllister 1982).Borrow area D and quarry site Bare
located adjacent to the mouth of Deadman Creek immediately
west of the creek;the third site,borrow area H,is
approximately 0.25 miles south of Fog Creek (see Exhibit E,
Chapter 6,Figure E.6.13).
Borrow area D will have the greatest impact on black bears
(Miller and McAllister 1982).This site,in the tablelands
area west of Deadman Creek,is used by black bears foraging
for berries in late summer.Miller and McAllister (1982)
state:
"[1]n the late summer these tableland areas are used
both by local resident black bears as well as by bears
moving to these areas from downstream locations.The
plant ecology study (subtask 7.12)prepared by the
Agricultural Experiment Station,University of Alaska
indicates the size of Area D as 228 hectares of which
48%is low mixed shrub and 32%is birch shrub (Ope
cit.,Table 4,page 23).Bog blueberry (Vaccinium
uliginosum),crowberry (Empetrum nigram)(sic)and
Mt.cranberry (V.vitis-idaea)were especially common
in these shrub types according to this study.Borrow
area D encompasses 0.02%of the low mixed shrub type
found in the entire upper Basin and 0.22%of the birch
shrub type (op.cit.).From the perspective of a black
bear,however,these low percentages are misleading as
the proximity of these types to escape cover
(especially forests)governs their use by black bears.
Borrow area D encompasses a much higher percentage of
RESPONSE TO COMMENT I.192 (cont.):-
,....
.-
..-
these types which are also found in close proximity to
escape cover."
Miller and McAllister (1982)state that borrow areas Band H
and the north part of E are in forested areas where black
bears are resident,and that excavation of area H would
produce the greatest impact of these three sites on black
bears.
Several borrow and quarry sites were not considered as
primary sites for this project because of lengthy haul
distance to the damsite,adverse environmental impacts,
insufficient quantities and poor quality material.These
include B,C,F and H,as stated in page E.6.17 of the
License Application.
Potential impacts to brown bears resulting from borrow area
activities,including human disturbance and loss of habitat,
will be addressed in the impact assessment and mitigation
update report.This report will incorporate data from the
1983 and 1984 ADF&G reports.
REFERENCES
Acres American,Inc.,Susitna Hydroelectric Project,Subtask
7.12--Phase I Final Report,Environmental Studies,Plant
Ecology Studies (1982).
Miller,S.D.and D.C.McAllister,Alaska Power Authority,
Susitna Hydroelectric Project,Phase I Final Report,Big
Game Studies,Volume VI,Black Bear and Brown Bear (1982)•
COMMENT I.193:
"Page E-3-426:(ii)Filling and Operation:Paragraph 3:
While brown bears could physically cross the reservoir,they
would likely be inhibited by adjacent human activities.
3W-E.-/"
"3W-6/See Footnote 3W-5.[3W-S/Miller Sterling D.and
Dennis D.McAllister.1982.Susitna Hydroelectric Project .
Phase I Final Report.Big Game Studies.Volume VI,Black
Bear and Brown Bear,page 60.Submitted to the APA by the
ADF&G.]II
------_._......._--"--------------------------------------
RESPONSE TO COMMENT I.193:
It does not seem likely that adjacent human activities would
inhibit bear crossings along most of the reservoir length
since the only location along the 54-mile long reservoir
where human activities would consistently take place is
within a few miles of the dam.During the reservoir
clearing program,human activity will extend the length of
the reservoir.
COMMENT I.194:
"Page E-3-427:(i)Construction:Paragraph 3:According to
Figure E.3.37,borrow area E is more extensive than it was
originally thought to be and represents a significant source
of disturbance to the high density black beardenning in the
area (Sterling Miller,personal communication)."
.RESPONSE:
The size of borrow area E has not been changed;it is no
more extensive than was originally thought to be.Figure
E.3.37 does not accurately portray the borrow area because
it exaggerates its size.Figure E.6.13 in the License
Application and Figure 8.18 in the December 1982
Geotechnical Supplement more accurately define the maximum
boundaries of borrow area E.The impact of borrow area E
and other borrow areas on black bear denning habitat is
addressed on page E-3-427 of the License Application.
REFERENCES
Acres American,Inc.,Susitna Hydroelectric Project,1982
Supplement to the 1980-81 Geotechnical Report,Volume 1
(December 1982).
COMMENT I.195 :
"Page E-3-428:(i)Construction:Paragraph 4:The ADF&G
Phase II Annual Report (April 1983)shows the Watana
impoundment area to be more important to black bear denning
4
~,
COMMENT 1.195 (cont.):
than previously realized.Thirteen of 24 black bear dens
found within the project area will be flooded.3W-I/"
,...,.
"3W-7/Miller Sterling D.April 1983.
Project,Phase II Progress Report,Big
Volume VI.Black Bear and Brown Bear.
by the ADF&G."
RESPONSE:
Susitna Hydroelectric
Game Studies.
Submitted to the APA
r
The referenced report was provided to the FERC by letter
dated May 31,1983.It should be noted that,while the FERC
License/Application indicates that 69%of the black bear
denning habitat in the Watana impoundment vicinity will be
lost,the new data suggests that only 54%will be lost.
COMMENT 1.196 :
"Page E-3-431 to E-3-432:(f)Wolf:Last Paragraph:We
agree that wolves may temporary increase as a result of
increased availability of prey due to displacement adjacent
to the reservoir area.Those initial benefits may later
mean more significant impacts to wolves as hunters and
predators eliminate prey.II
RESPONSE:
The FERC License Application recognizes (pages E-3-431,
E-3-432 and E-3-503)that there may be a fluctuation
(temporary increase,then decrease)in wolf numbers
following reservoir clearing.
COMMENT 1.197:
"Page E-3-435:(ii)Filling and Operations:Paragraph 3:
Line 1:A more accurate statement would be that no beavers
are known to overwinter in the river reach between watana
and Devil Canyon (Phil Gipson,personal communication)."
RESPONSE:
The Power Authority agrees that this wording is more
accurate.
COMMENT L198:
"Page E-3-435 to E-3-436:(ii)Filling and Operation:
Paragraph 4:The value of sites occupied by beaver in the
winter depends on water stability.Thus,flow fluctuations
for even a few days could affect downstream beaver.Beaver
could be frozen out of their lodges and/or food caches if
water levels suddenly drop.Alternatively,their lodges and
food caches could be destroyed should sudden flow releases
cause ice movements or flooding out of beaver sites.The
potential for daily flow fluctuations in winter should be
described.
liAs we commented on Chapter 2,page E-2-90,the expected
delay in ice cover formation downstream from Talkeetna
should be described here and the implications.discussed in
regard to beaver habitat improvement proposals.We
recommend using hydrologic data in conjunction with revised
vegetation maps and with information on vegetation
succession to quantify downstream areas likely to be
affected under different flow regimes.Please refer to our
previous comments on the uncertainties in existing reservoir
temperature and icing models which make these conclusions on
downstream vegetation succession and icing processes
questionable (Section 3.3.1(b)[iiil).
tlAn explanation should be provided of when,how,and by
whom,'•••available hydrologic data will be used to
determine the most likely locations for enhancement [habitat
improvement]in downstream sections,as indicated in the
applicant's response to our previous comments on this
subject (Chapter 11,W-3-324).
"We question whether beaver habitat can be improved.Other
than to create stable but higher winter flows and deeper
water in some sloughs and side-channels for beaver use,
there may be other physical manipulations which could
improve beaver habitat.These would be to:(1)dig out
sloughs to increase their depth;(2)put in berms at
upstream channel openings to slow down flows;or (3)put a
dam at downstream channel mouths to deepen the water in the
channel.These are all drastic measures whose values have
not been proven in Alaska,and which potentially conflict
with management and mitigation plans for other species."
..
~\
"""
-
RESPONSE TO COMMENT 1.198:
The last paragraph of this Comment provides the key to the
entire discussion.The Comment indicates that probably the
best way to improve beaver habitat is lito create stable but
higher winter flows and deeper water in some sloughs and
side-channels for beaver use."This is exactly what the
Project will provide.Under natural (without-project)
conditions,average monthly winter flows at Gold Creek and
Sunshine are (FERC License Application Tables E.2.8 and
E.2.9):
Gold Creek Sunshine
November 2,577 cfs 6,028 cfs
December 1,807 cfs 4,267 cfs
January 1,474 cfs 3,565 cfs
February 1,249 cfs 2,999 cfs
March 1,124 cfs 2,681 cfs
April 1,362 cfs 3,226 cfs
Under with-project conditions,comparable average monthly
flows will be approximately (from FERC License Applicaton
Tables E.2.54 and E.2.56):
November 9,600 cfs 13,100 cfs
December 11,300 cfs 13,700 cfs
January 10,600 cfs 12,700 cf·s
February 10,200 cfs 11,900 cfs
March 9,300 cfs 10,800 cfs
April 8,100 cfs 10,000 cfs
The increased water depth which would result from these
project-induced increased winter flows would vary depending
on the physical cross-section characteristics of the given
site,but,at Gold Creek and Sunshine,the increases would
be approximately 4.5 and 1.6 feet,respectively.
Under base-loading,daily fluctuations will be held to a
minimum and limits will be negotiated with the resource
management agencies concerning both maximum daily variations
and hourly rate of change of discharge.Thus,with or
without ice cover,it is anticipated that habitat conditions
for beaver downstream from Gold Creek will be improved by
the Project.The delay in ice cover formation in this reach
of the river (see Response to Comment 1.40)will further
improve habitat conditions for beaver.Please see also the
Responses to Comments 1.346,1.542 and 1.552.
RESPONSE TO COMMENT 1.198 (cont.):
Proposed habitat improvement measures for beaver (see
Mitigation Plan No.19,page E-3-537)will also enhance
beaver (and other aquatic and semi-aquatic furbearers)
downstream.Further evaluation of project impacts and
refinement of mitigation measures for furbearers is being
conducted as part of ongoing impact assessment and
Mitigation Plan refinement efforts.Please refer to the
Responses to Comments I.29,1.40,1.168,and 1.310 for
further related discussion.
COMMENT 1.199:
"Page E-3-436:(j)Muskrat:Paragraph 1:The
effectiveness of proposed downstream improvements to muskrat
habitat should be demonstrated."
RESPONSE:
Muskrats are predicted to benefit from project alterations
in downstream areas in two ways:(1)The presence of
greater amounts of open water in winter in downstream river
sections after completion of the dams will allow muskrats to
overwinter (a critical period)in sections of the river
which were unavailable to them before (due to shallow water
and extensive ice cover),and (2)the enhancement of
downstream sloughs for beaver will secondarily benefit
muskrats.The creation of deep ponds by beaver damming
activities will also create overwintering habitat for
muskrats.This commensal relationship between beavers and
muskrats is well documented (Errington 1961,Larin 1961,
Curatolo,et ale 1981)and is expected to occur in the
Susitna Basin.
REFERENCES
Errington,P.L.,Muskrats and Marsh Management (1961).
Larin,B.A.,The Relation Between Muskrats and Beaver,
Referet.Zhur.Biol.,[1964 translation of Russian abstract]
(1964)•
Curatolo,J.A.,M.S.Boyce,M.A.Robus and R.H.Kacyon,
Aquatic Furbearer Habitat Survey-Final Report,Alaska
Biological Research,Fairbanks,Alaska (1981).
"""I
..i£4##4 '1#,