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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 II
ARLIS
Alaska Resources
Library 'informatIon Serv~ce~
Anchorage.Alaska
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COMMENT 1.200:
"Page E-3-436:(i)Muskrat:Paragraph 2:Because of the
above concern we question the certainty of the conclusion
that,IImproved downstream habitat will compensate for •.•
[the impoundment area]10SS.11I
RESPONSE:
Please refer to the Response to Comment I.199.Because of
the apparently low population of muskrat in either
impoundment zone,compensation of lost habitat due to
reservoir flooding should be easily achievable in downstream
reaches.Muskrat use of downstream sloughs to be enhanced
for beaver (see Mitigation Plan No.19,FERC License
Application page E-3-537)should provide most,if not all,
compensation.Muskrat use of impoundment shores
(particularly Devil Canyon,which has low annual water
fluctuations)is difficult to predict,although conversion
to use of bank dens along these shores could conceivably
occur,providing additional habitat for this species.
COMMENT I.201:
"Page E-3-436:(i)Muskrat:Paragraph 3:The potential
for negative impacts to muskrat from daily flow fluctuations
should be fully addressed."
RESPONSE:
As discussed in the Response to Comment 1.198,average
winter flows will be higher than normal under with-project
conditions and daily fluctuations will be limited so that
adverse effects on aquatic furbearers resulting from daily
fluctuations are expected to be minimal.However,further
evaluation of this impact mechanism is being conducted and
will be completed following finalization of the operational
flow regime including daily fluctuation limits.See also
the Responses to Comments I.198,I.346,I.542 and I.552.
COMMENT I.202:
"Page E-3-440:(1)Coyote and Red Fox:Paragraph 5:Red
fox habituation to human activity may be overemphasized.
The referenced studies were in areas protected from hunting
ARLIS
Alaska Resources
Library &,InfonnatlOn Services
Anchorage l Alaska
COMMENT I.202 (cont.):
and where vehicle use may be less frequent and at slower
speeds than it will be during project development
activities."
RESPONSE:
All studies referenced in this section (including Milke
1977,Tracy 1977 and Neuman and Merriam 1972)noted a lack
of disturbance reactions to many human activities on the
part of red foxes.As for any wildlife species,negative
reactions to humans will be more severe if hunting of that
species is allowed.If hunting is restricted in the area of
construction and intensive access during the project,then
reactions by red foxes would likely follow the scenarios
mentioned in the text.Should hunting be allowed,the
reactions may be stronger,but likely only toward known
human sources,such as people on foot,gunshots,etc.The
abundance of foxes in well-settled portions of North America
indicates this species is well adapted to coexist with human
disturbances,such as road traffic and other construction
activities.
REFERENCES
Milke,G.,Animal Feeding:Problems and Solutions,Joint
State/Federal Fish and Wildlife Advisory Team,Special
Report Noo 14 (1977).
Tracy,D.M.,Reactions of Wildlife to Human Activity Along
the Mt.McKinley National Park Road,Master's Thesis,
University of Alaska (1977).
Neumann,P.W.and H.G.Merriam,Ecological Effects of
Snowmobiles,Can.Field Nat.86:207-212 (1972).
COMMENT I.203:
"Pages E-3-441 to E-3-442:(m)Other Furbearers:
Paragraphs 4 and 5:.The difficulties with 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 dif-
ferences in trapability,the fact that a professional
trapper worked in that area the previous winter further
negates the validity of this estimate.We suggest that the
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COMMENT 1.203 (cont.):
trapper be contacted for further information on Watana area
marten populations."
RESPONSE:
Several trappers worked in the middle Sus~tria River Basin
during years of furbearer studies.The presence of several
trappers in this area represents the normal situation1
therefore marten populations in the basin during the years
of study were probably more representative of normal
population levels than would be calculations accounting for
trapper harvest levels.Thus,the model does predict the
loss of marten due to impoundments and other facilities1 but
does not,at present,predict potential loss of marten
populations that could be present given no trapping
mortality (an artificial situation).
COMMENT 1.204:
"Page E-3-442:(n)Raptors and Ravens:Section discussions
leave the unproven impression that raptors and ravens will
be displaced to downstream and adjacent areas.For example,.
on paqe445,paragraph 5,it is inferred that downstream
cliffs may increase in importance to golden eagles who lose
upstream cliff nesting~10cations1 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.
"Little consideration has been given to the relative habitat
values of these 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 meaning-
less to provide alternative nesting locations.Where
alternative 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
successfuly reestablished involved an existing site which
COMMENT 1.204 (cont.):
was restored,not establishment of a nest in an area
currently uninhabited~nd unsuitable for nesting by bald
eagles.The viability of such measures in Alaska or similar
environments must be shown before they can be found ac-
ceptable."
RESPONSE:
Our re-reading of Exhibit E,Chapter 3,Section 4.3.1(n),
(FERC License Application pages E-3-442 through E-3-454)
does not,in our judgment,"leave the unproven impression
that raptors and ravens will be displaced to downstream and
adjacent areas."The example cited on FERC License
Application pages E-3-445 and E-3-446 states:
"Cliff-nesting habitat for golden eagles will become
severely limited upstream from the Watana damsite once
the impoundment is full.Loss of cliffs upstream from
the Watana damsite may increase the importance of
clif"fs farther downstream in Devil Canyon,along Fog
Creek,Tsusena Creek and other streamS draining into
the Watana to Devil Canyon reach.However,airspace is
restricted in much of Devil Canyon,many of the cliff
areas appear to be exposed to higher levels of
moisture,and existing cliffs may lack suitable ledges
on which golden eagles could construct nests.
"Golden eagles often have several alternative nesting
locations,some perhaps 4-5 miles (6-8 km)apart
(McGhan 1968,Roseneau,et ale 1981),and thus the 6
nests lost to the project do not represent 6 pairs of
eagles.The middle Susitna River Basin population of
golden eagles will probably be reduced by 3-5 pairs as
a result of the construction and filling of the Watana
reservoir because of (1)losses of 38 percent of the
well-established golden eagle nest sites along the
river;(2)concomitant losses of most of the other
potential cliff nesting habitat upstream from the
Watana damsite;and (3)a suspected scarcity of
alternative nesting locations through much of the
remainder of the middle basin."
with regard to the question of loss of foraging habitat at
downstream locations,it is pointed out on FERC License
Application page E-3-438,paragraph 4,
"Most raptors are limited by availability of nesting
locations and nest sites,not food (Newton 1979).
Furthermore,raptor 'hunting habitat'and productive
RESPONSE TO COMMENT I.204 (cont.):
areas of prey habitat,including riparian zones and
wetlands are not necessarily equivalent."
The discussion of this point continues through FERC License
Application page E-3-449.The question of the validity of
concluding that cliff-and tree-nesting raptors will find
alternative nesting locations when displaced by project
construction and operation will receive more detailed
attention during impact assessment refinement.In the final
analysis,however,it will not be possible to prove in
advance that all raptors displaced from presently used
nesting locations will in fact successfully nest in other
locations near the project area or farther afield.
We disagree with the reviewer's comment that
"Where alternative 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."
Successful applications of the proposed raptor mitigation
methods are described and documented in FERC License
Application Appendix E3I,along with the descriptions of
specific techniques for their implementation.
The Power Authority anticipates that the DEIS will reasonbly
analyze these topics and will incorporate available studies.
REFERENCES
McGhan,J.,Ecology of the Golden Eagle,Auk.85:1-12 (1968).
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).
Newton,I.,Population Ecology of Raptors (1979).
COMMENT 1.205:
"Page E-3-443:-Nesting Habitat:Review of Appendix 3.1
shows that successful provision of artificial nest sites in
Alaska remains unproven and untried.While we agree that
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COMMENT I.205 (cont.):
lack of opportunity rather than lack of knowledge may be
limiting such applications,we believe 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 Alaskan raptors."
RESPONSE:
The Power Authority intends to implement a thoughtful,
carefully designed program to determine the efficacy of
proposed mitigative measures.From applications elsewhere,
documented in part in Appendix E3I to FERC License "
Application Exhibit E,there is every reason to expect that
the proposed measures will accomplish the successful
relocation of raptors to alternative nest sites.
The Power Authority appreciates the concern expressed with
regard to the availability of adequate foraging habitat.
However,we must re-emphasize that most raptors in most
regions are in fact primarily limited by occurrence and
availability of nesting locations,not by the availability
of foraging habitat.We refer the reader to FERC License
Application Exhibit E,Chapter 11,Appendix E11J,in which
this question is thoroughly reviewed (Response to USFWS
Comment W-3-461 on the November 1982 Draft License
Application).Also refer to the Response to Supplemental
Information Request 3W-4 (referenced in the Response to
Comment I.209).The further development of mitigative
proposals for raptors will be undertaken with the close
involvement of USFWS Region 7 raptor specialists.Review,
discussion and informed decisions will be made with the
participation of USFWS personnel at every step in the
further development of mitigation proposals for raptors.
It should be noted that mitigation measures for raptors need
not be proven effective in Alaska to be of potential value
to the Susitna Hydroelectric Project.If proposed
techniques have been documented to be effective for the same
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RESPONSE TO COMMENT 1.205 (cont.)
or similar species in similar habitats,they are worthy of
consideration,regardless of pol~tical boundaries.
The missing references for artificial nest examples 1,3 and
9 (FERC License Application Appendix E3I)are provided
below.
REFERENCES
Cugnasse,J.M.,Adoption drune aire artificielle par un
couple de faucons pelerins et note sur la maturite sexuelle
de la femelle,Nos.Oiseaux 35:238-242 (1980).
Dunstan,T.C.and M.Borth,Successful Reconstruction of
Active Bald Eagle Nest,Wilson Bull.82:236-327 (1970).
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,IntI.Council Bird Preserv.(1975).
[Please note that Dustan and Borth (1970)is included in the
references section of the FERC License Application (page
E-3-576).However,due to a typographical error,"Dustan"
is listed as "Dunshan."]
COMMENT 1.206:
r!page E-3-445:Paragraph 4 through Page E-3-447:Paragraph
1:As cited in the folowing 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,in-
cluding 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 appro-
priate FWS Regional Director under eagle permit regulations
(50 C.F.R.22)."Take r!is defined to include molest or
disturb.II
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RESPONSE TO COMMENT 1.206:
The information provided in this comment is provided in
detail on page E-3-451 of the FERC License Application.
Please refer to the Response to Comment 1.210 for further
information.
COMMENT 1.207:
"Page E-3-448:Paragraph 2 through Page E-3-451:Paragraph
1:Hunting and Perching Habitat:Supporting references
should be provided for this discussion.Only a brief
SUbjective assessment has been made of hunting and perching
habitat which would be available near artificially provided
nesting locations and nest sites.Nests without perches are
of limited value to bald eagles.Nesting habitat is useless
without sufficient sources of food."
RESPONSE:
This Comment concerning the discussion of hunting and
perching habitat is noted and appreciated.Additional
evaluation of these concerns will be conducted during the
refinement of impact assessments.Please refer to the
Responses to Comments 1.205 and 1.209.
COMMENT 1.208:
IIPage E-3-449:Hunting and Perching Habitat:Paragraph 6:
We question the validity of this discussion.Bald eagles
hunt very close to the nest site and probably always within
line of sight,especially during the early part of the
nesting season.1I
RESPONSE:
Paragraph 6 of Exhibit E,Chapter 3,Section 4.3.1{n)(i),
entitled lIHunting and Perching Habitat"(page E-3-449),
states that "[rn}ost raptors,especially the larger species,
have the capability to range relatively long distances from
their nesting locations to hunt.1I In response to our
statement,the reviewer singled out bald eagles,stating
"[b}ald eagles hunt very close to the nest site and probably
always within line of sight,especially during the early
part of the nesting season."The latter statement is
generally supported by several studies of nesting bald
e~gles.However,it should be recognized that:
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RESPONSE TO COMMENT 1.208 (cont.):
Bald eagles are opportunistic in their feeding habits.
They are capable of exploiting one of the widest arrays
of food sources of any raptor (including fish,birds,
mammals,carrion,and human refuse).
On the other hand,bald eagles have relatively specific
requirements for nest sites.In interior Alaska,
almost all bald eagles nest in balsam poplar or white
spruce trees that are large,mature,and often decadent
(cliff nests are rare).Conformation of the trees is
important;i.e.,spruce must have broad II bushy II upper
sections,and poplar must have properly configured
limbs and partially open canopies.
Suitable nesting locations are often limited in number
and widely scattered in interior Alaska.Trees of the
appropriate size and conformation are not common in the
Susitna River basin upstream of Talkeetna.
Suitable nesting locations are not always conveniently
located immediately adj acent to sources of prey.-
Furthermore,the distances and directions bald eagles
hunt from their nests are strongly tied 1:.0 the
distribution,abundance,availability,and"
vulnerability of prey in the local area.Therefore,
the sizes and shapes of hunting territories vary among
nesting pairs and ~mong nesting areas.
In addition,the morphology of eagles suggests that
they have the capability to range long distances from
their nests to hunt for food.The size and shape of
their wings (e.g.,long and broad with slotted wing
tips)in relation to body size,resulting in low
wing-loading,facilitate long distance movements.
We point out that our original statement in the FERC License
Application dealt with capability,not with the distances
within which eagles are most often able to obtain food.
Furthermore,an understanding of the eagles'(and other
raptors')capabilities to exploit their environment is an
important prerequisite when designing a sound mitigation
plan,especially if plans include manipulating nests.
Pertinent factors include capabilities to use a variety of
nesting habitats and nest structures,take a variety of
prey,or to fly long distances to obtain food.
It is true that the river valley in the middle basin where
four pairs of bald eagles nest will be inundated.Although
the river valley may presently afford some hunting habitat
RESPONSE TO COMMENT I.208 (cont.):
for these eagles,it probably does not provide the most
suitable foraging habitat in the region.The river waters
are turbid and swift,and anadromous fish,an important food
source,rarely penetrate upstream of Devil Canyon.As a
consequence,the bald eagles nesting here may not hunt
entirely within the river valley.Instead it is quite
possible that they use nearby wetlands where prey may be
more abundant (e.g.,Fog Lakes,Portage Creek Valley,
Stephan Lake area).However,suitable nesting locations are
almost non-existent in these areas;as a result of project
actions,the Power Authority anticipates establishing
compens~tory nest sites in areas of suitable hunting habitat
for the raptor species in question.
COMMENT I.209:
"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 Plan."
RESPONSE:
The sentence in question (FERC License Application page
E-3-450)states "Assuming waterfowl are never attracted to
the impoundment,and that fisheries never develop there,
surrounding habitat,including tributaries and waterbodies
near the impoundment zone,is likely to be adequate for
those eagles that remain after construction and filling of
the Watana reservoir."This statement formally addresses
only impacts which are likely to occur in the absence of
mitigative measures.It should be noted however that FERC
License Application page E-3-538 states,llA combination of
several of the enhancement measures described in
Appendix E3I will be used to provide artificial nesting
locations for bald eagles until at least four successful new
eagle nests have been established in the middle or upper
basin.As shown in Table E.3.l60,four known recently
active bald eagle nests will be inundated by the impoundment
areas,borrow areas or campsites if the project is
constructed as described in the License Application.Hence,
through mitigative measures and monitoring,the Power
Authority intends that at least four successful new bald
eagle nests be established after the loss of the existing
nest sites documented in Table E.3.l60.Because the
availability of nesting locations is usually more limiting
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RESPONSE TO COMMENT 1.209 (cont.):
than the prey base (see Technical Response to
Comment 1.204),it is likely that food and foraging habitat
will be adequate for the four nesting pairs of bald eagles
which are expected to occupy new nest sites following
construction and filling of the reservoirs.
For additional information concerning this and other
Comments pertinent to bald eagles,the reader is referred to
the Power Authority's Response to Supplemental Information
Request 3W-4.
REFERENCES
Alaska Power Authority,Response to FERC Supplemental
Information Request,3W-4 (1983),previously submitted to
the FERC on July 11,1983.
COMMENT 1.210:
"Page E-3-451:Paragraph 2 through Page E-3-454:Paragraph
1:(ii)Disturbance:The APA has initiated I consultation'
with the Alaska Regional Director of the FWS with regard to
the taking of eagle nests.The applicant's initial February
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 30,1983 responses included a copy of the
Bald Eagle Protection Act and appropriate 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 permit issued by the Secretary.
There are no provisions for issuing permits to take or move
bald eagles 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 (ii)Disturbance,paragraph 1,and in the Chapter 11
response (W-3-344,paragraph 1).
"In their letter to the FWS Regional Director and in the
Wildlife Resources section of the Exhibit E,the applicant
has explained no such scientifi~or 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
COMMENT I.210 (cont.):
case permit for the similar 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 with project construction.An additional bald
eagle nest and up to seven additional golden eagle nests
will be subject to disturbance from project access,
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 on
the draft application suggests that the Bald Eagle
Protection Act will be met by implementing the Mitigation
Plan:
'•.•in a manner that should satisfy taking of bald
eagle nests as part ofa scientific study to learn
about the effectiveness of several possible RESPONSE:
mitigation methods useful as evaluative and mitigation
tools should similar conflicts arise between this
species and other future developmental or industrial
projects'(Chapter II,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.".
RESPONSE:
The Alaska Power Authority has communicated with the Fish
and Wildlife Service Regional Director in Alaska several
times with regard to this matter.The Alaska Power
Authority fully recognizes its obligations under the Bald
Eagle Protection Act.The Power Authority will continue its
efforts to meet with the appropriate Fish and Wildlife
Service officials in that regard and to take all other
appropriate actions to comply with that Act.The Power
Authority anticipates obtaining the necessary permits
subject to a reasonable Mitigation Plan.
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COMMENT 1.211:
"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.11
RESPONSE:
Disturbance to eagle nests due to reservoir clearing
operations is discussed in the cited paragraphs.The
eventual fate of each of these nests is also discussed in
'these paragraphs.
COMMENT 1.212:
"Page E-3-46l:(9)Non-game (Small)Mammals:Paragraph 4:
The text should explain how the estimated 5%decrease in
northern red-backed vole numbers was derived."
RESPONSE:
This figure was derived from the estimate of 4.0 percent of
white spruce habitat plus a smaller amount (area of type too
small to be mapped)of balsam poplar (ll co ttonwood")habitat
lost to the Watana impoundment in relation to the percent
coverage of these types in the Susitna watershed upstream of
Gold Creek.As stated in the text,these are preferred
habitats of red-backed voles,therefore a decrease of up to
5 percent (4+%)in overall abundance of this species is
expected.
COMMENT 1.213:
"Page E-3-465:-Alteration of Habitat:Please see our
previous comments and references on altered habitats under
impacts from the Watana development (Section 4.3.l(a)[ii])."
RESPONSE:
Please refer to the Response to Comment 1.181.
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COMMENT 1.214:
"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[iJ).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)."
RESPONSE:
Further refinement and documentation of the impact
assessment for beaver is being developed.Please refer to
the Responses to Comments 1.168 and 1.198.
COMMENT 1.215:
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"Pages E-3-471 through E-3-474:
Please refer to our comments on
the potential for conflict with
Act.
(n)Raptors and Ravens:
Section 4.3.1(n)regarding
the Bald Eagle Protection
"Impacts of operating the Devil Canyon dam should be
described.II
RESPONSE:
Please refer to the Response to Comment 1.210.
COMMENT 1.216:
"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 earlier.Birds which remain 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."
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RESPONSE TO COMMENT I.216:
Rereading of this section of the FERC License Application
failed to reveal any inference made to attraction of
waterfowl earlier or later than normal migration patterns
already existing in the area due to open water.The
statement:."The open water area near each end of the
reservoir should benefit some early and later migrants when
other waterbodies are frozen"(FERC License Application
page E-3-474)refers to the fact that migrants during the
very early or late periods often encounter frozen lakes and
are forced to return to open water farther south,or land on
ice and risk predation by land predators.Presence of open
water in the Devil Canyon Reservoir will benefit these birds
by providing iimited areas of safe resting (and possibly
feeding)habitat until other areas become ice-free (spring)
or they continue migration (fall).If waterfowl were
attracted to this open water late in the fall,they would
only remain as long as food is available.Ice-free
overwintering areas of waterfowl in Prince William Sound or
Cook Inlet are well within one-day's flight time and are
probable normal migration stopover or overwintering
destinations for.many waterfowl in the Susitna Basin in any
event.
FERC License Application Section 4.3.2(0)states that the
relatively stable water level in this impoundment IIshould
allow for the development of some vegetation in the impound-
ment,although suitable shallow shoreline areas will be
somewhat limited"(FERC License Application page E-3-474).
This statement takes the predictive capability of future
food resource assessment as far as is currently practical.
The limited plant growth will provide some food for
waterfowl,but again,limited amounts (quantitative
assessment is not practical).The steep shorelines are not
conducive to shorebird use;therefore,little'usable habitat
would be generated.
COMMENT I.217:
"Page E-3-476:(0)Waterbirds:Paragraph 2:Data should be
provided to support the contention that 'distributional
shifts'would,occur and downstream habitats can support
additional waterbirds.1I
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RESPONSE TO COMMENT 1.217:
The term "distributional shifts"could be eliminated from
the referenced paragraph.It was meant to be interpreted
loosely as distributional changes in relative abundance,
which is already stated.The referenced section does not
state nor is not meant to imply that downstream habitats can
support additional waterbirds.However,as plant succession
is influenced by changes in the water regime,so will the
abundance of riparian species.
COMMENT 1.218:
"Page E-3-476:4.3.3 -Access Roads and Railway:~lease
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."
RESPONSE:-A description of the proposed access plan is contained in
FERC License Application Exhibit B,pages B-2-60 to B-2-76.
Please refer to the Responses to Comments A.I,A.3,F.7 and
1.384 for further discussion of the access plan and its ~
impacts.
COMMENT 1.219:
"Page E-3-477:(i)Mortality:Paragraph 2:While we agree
with the statement '•..carefully managed hunting may
effectively 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."
RESPONSE:
FERC License Application Exhibit E recognizes that the Power
Authority will not have legal jurisdiction over hunting and
trapping activities on public or private lands surrounding
.-
-
......
RESPONSE TO COMMENT 1.219 (cont.):
the Watana and Devil Canyon impoundments (see FERC License
Application pages E-3-5l9 and E-3-534).The Exhibit also
recognizes that the Board of Game may need to modify
regulations with regard to project impacts (see FERC License
Application pages E-3-5l9 and E-3-520).Please refer to the
Response to Comment F.52 for additional discussion of this
topic.
COMMENT 1.220:
"Page E-3-48l:(b)Caribou:Paragraph 7:We can find no
table E.3.l62 which includes estimates of vehicle traffic."
RESPONSE:
The paragraph in question contains a typographical error.
The appropriate table should be "Table E.3.l67:Total
Average Daily Traffic on Access Road and Denali Highway
During Peak Construction Year and Season."
COMMENT L 221:
"Page E-3-487:(h)Furbearers:Paragraph 1:First Sentance:
Lack of accurate wetlands maps precludes a full assessment
of project impacts."
RESPONSE:
Please refer to the Response to Comment 1.330.
COMMENT 1.222:
"Page E-3-487:(h)Furbearers:Paragraph 3:Potential use
of material sites along Deadman Creek conflicts with
assurances in the Botanical Resources section that use of
such areas will be avoided through use of side-borrow and
balanced cut-and-fill techniques for road development
(Section 3.4.2[i]).This apparent discrepancy should be
corrected."
RESPONSE:
The Botanical Resources Section (Section 3.4)does not make
assurances that material sites along Deadman Creek will be
avoided.Instead,on FERC License Application page E-3-265
--~-------,--------~-----
~i
RESPONSE TO COMMENT I.222 (cont.):
it states:liAs shown in Figure E.3.37,nine borrow areas
have been identifi~d along the Denali Highway-to-Watana
segment as far as MP 32.These will be excavated on a
contingency basis to support road construction in cases
where side-borrow material is not available in sufficient
quantities."The furbearer impact section (see FERC License
Application page E-3-487)reflects impacts in the absence of
mitigation.Thus,given mitigation,the impacts of borrow
areas from Deadman Creek on furbearers is essentially taken
care of.
COMMENT I.223:
"Page E-3-489:(i)Raptors and Ravens:Please refer to our
previous comments on Section 4.3.1(n)regarding requirements
of the Bald Eagle Protection Act."-
RESPONSE:
~I
Please refer to the Response to Comment 1.210.
COMMENT 1.224:~
"Page E-3-489:(i)Denali Highway to Watana Damsite:
Paragraph 3:Inconsistencies regarding which bald eagle -
nesting locations 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.'The same statement,without the identifying
loca~ion number,is repeated in Table E.3.159 under item
(1).It is unclear whether the nest identified in that
table is the same as the one previously described.
lI1n Table E.3 .160,it is said that nest BE-6,'•••may be -,
affected by the access corridor in Deadman Creek,'and
nesting location BE-8,'..•may be affected by the
construction of the railroad between Devil Canyon and Gold
Creek.'These statements appear to contradict earlier
descriptions in the Botanical Resources Mitigation Plan and
Figure E.3.81 that,'A balsam poplar stand near Deadman
Creek at access milepost 37.5 has been avoided by a
-
I~
..-
COMMENT I.224 (cont.):
one-half-mile route realignment to protect a bald eagle nest
in the stand'(page E-3-258,paragraph 2).While such road
realignment is also described in Wildlife Resources
Mitigation 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."
RESPONSE:
Bald eagle nest BE-6 referred to on PERC License Application
page E-3-489,is in fact the same bald eagle nest referred
to under item (1)of PERC License Application Table E.3.159.
The wildlife impact discussion referred to in the preceding
sentence describes impacts that will occur in the absence of
mitigative measures.As stated in the botanical resources
mitigation option analysis (PERC License Application page
E-3-258),"A balsam poplar stand near Deadman Creek at
access milepost 37.5 has been avoided by a one-half-mile
route realignment to protect a bald eagle nest in the stand
(Section 4.4,Figure E.3.81)."The nest referred to is
BE-6.FERC License Application Figure E.3.81 does indeed
show that the original access route has been moved to avoid
impacts to this bald eagle nest.The reference to nest BE-8
on FERC License Application page E-3-537 is a typographical
error.The nest referred to is BE-6 •
---------------------------;---
....
COMMENT 1.225:
"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 types (e.g.
Table E.3.86);and (3)inconsistent references to existence
of a 69kv,34 kv,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 maintenance access trails.Access
trails to the line should be limited to reaches between
major river crossings or topographical barriers.Locked
gates or other impassible barriers should be placed at
intersections of the maintenance access trails witfi public
roadways.Please refer to our proposed Biological
Stipulations,Attachment A,and Wetlands Construction
Methods,Attachment C for further recommendations.1I
RESPONSE:
Please refer to the Response to Comment 1.327 regarding a
cumulative assessment of potential vegetation impacts
associated with the transmission line.Please refer to
Responses to Comments 1.393 and A.7 regarding the
construction power source.During the detailed engineering
of the transmission line,appropriate agencies as well as
landowners and managers will be consulted in finalizing the
line route and access trails.Regarding access trails,
please refer to Responses to Comments A.I8,1.303,1.371 and
F.39.
COMMENT 1.226:
"Page E-3-493:4.3.4 -Transmission Lines:Paragraphs 2 andl:To minimize clearing requirements along the transmission
corridor,we recommend that the 25-foot maintenance access
trail be adjacent 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
COMMENT 1.226 (cont.):
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.
liThe referenced map of the transmission corridor
(Figure E.3.3?)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.II
RESPONSE:
Final routing of the access trail for the transmission line
will be determined by site specific data obtained through
field investigations during the detailed construction
planning for the line.It is anticipated that in areas of
tall vegetation and,where allowable,due to terrain condi-
tions,the access traiT will follow the pattern shown in the
attached Concept For Construction/Maintenance Access.
Anticipated clearing heights are described in FERC License
Application Exhibit E,Chapter 9,page E-9-48.Presently,
the schedule for maintaining vegetation height standards is
anticipated every ten years at a maximum.Final schedules
for maintenance of the right-of-way will be determined by
the operating contractor and will provide for flexibility
depending on identified circumstances.FERC License
Application Figure E.3.3?shows only the transmission line
route between Watana and Gold Creek (the immediate project
site).The complete transmission line route is referenced
in FERC License Application Exhibit G,Plates G.30 through
G.52.These maps are keyed to an overview index map shown
in Plate G.4.
REFERENCES
Alaska Power Authority,Susitna Transmission Concept For
Construction,Maintenance Access and Clearing -Two Single
Circuit Lines (January 1984).
~,
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-
I.".
TYPICAL CROSS SECTION
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.,-_-+__Tower areas kept clear of
tall vegetation to provide
access for maintenance.
Proposed access route
through tall vegetation
PLAN VIEW
,r---t---Feather and selectively thin
vegetation to reduce sheared-
edge effect.
,.I
,----+--Access utilizes cleared area
under lines to minimize need
for clearing center .
"~,.r~
}'"
"
-
--
APPENDIX I.226
SUSITNA TRANSMISSION
CONCEPT FOR CONSTRUCTION IMAINTENANCE ACCESS
AND CLEARING -TWO SINGLE CIRCUIT LINES
COMMENT 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 mimimum,restrictive time-frames should be set during
which construction of those segments would be allowed.This
section fails to indicate that the 'temporary effects'of
disturbances 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."
RESPONSE:
The reactions of animals to human disturbance along
corridors has received considerable attention in northern
areas (Geist 1963,Mathisen 1968,Kl~in 1971,Barry and
Spencer 1976,Tracy 1977,Roby 1978,etc.).As expected,
most wildlife species avoid areas of intense human activity,
but will usually relocate into these areas once the
disturbance has diminished.Several studies of ungulates,
for example,have noted an increase in ungulate numbers in
areas where human activities have purposefully or
inadvertently improved habitat for these species.For
example,Peek,et ale (1976)studied historical trends in
moose populations in northeastern Minnesota,and reported
that the marked increases in moose numbers that occurred
from 1925 to 1933 and from 1960 to 1970 followed periods of
sawtimber cutting and pulpwood harvesting,respectively.
The population appeared to have increased by 300%from 1960
to 1970 according to aerial survey results.The creation of
forest clearings and the retardation of forest succession by
bulldozed clearings,prescribed burning,thinning and
herbicide application are often used as management
techniques to increase the use of areas by moose,deer and
elk (Krefting 1941,Erickson,et ale 1961,Gysel 1961,
Spencer and Hakala 1964,Dills 1970,McCaffery,et ale 1974,
Euler 1975,Asherin 1976,Folliot,et ale 1977,Usher 1978).
Use of these newly created areas and subsequent ungulate
population increases could not have occurred if these
species-had failed to reutilize disturbed areas once human
~,
-
-
RESPONSE TO COMMENT 1.227 (cont.):
activities had ceased.Other examples,involving wildlife
of many species repsonding positively to habitat
manipulations also exist,but are far too numerous to
mention here.
Although a research program into wildlife use and population
densities present near the transmission corridor stretcing
from Fairbanks to Anchorage does not seem warranted at this
time,planning and route refinement for the corridor is a
continuing process and includes site reconnaissance and
interaction with wildlife regulatory agencies to ensure that
important wildlife habitats and use areas near the corridor
are protected.Included in this process is identification
and avoidance of particularly sensitive sites,such as
trumpeter swan and raptor nesting locations,ungulate
calving sites and bear denning sites.Generally low growth
rates of woody vegetation in northern latitudes allows
clearing activities to occur several years after the
previous cutting,a period of time sufficient for wildlife
-to reestablish use patterns in these corridors.Clearing
operations for project transmission line right-s-of-way are
presently anticipated to occur every ten years at a maximum.
Localized clearing associated with tower and line
maintenance or repair may be required more frequently.
Final schedules for vegetation maintenance of the
right-of-way are likely to vary along the corridor depending
on the type of vegetation encountered and its growth
characteristics.These schedules will be determined by the
operating contractor in consultation with appropriate
wildlife regulatory agencies.Much of the transmission
corridor has been sited away from roads and railways,
although out of necessity it must cross several
transportation corridors along its length.Methods for
controlling access along the transmission line will be
determined in consultation with appropriate agencies,land
owners and land managers during preparation of the
construction access and maintenance plan.
REFERENCES
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).
Barry,T.W.and R.Spencer,Wildlife Response to Oil and
Well Drilling,Can.Wildl.Servo Prog.Note No.67 (1976).
..---_._------------------------------_~--------
RESPONSE TO COMMENT I.227 (cont.):
Dills,G.G.,Effects of Prescribed Burning on Deer Browse,
J.Wildl.Manage,34:540-545 (1970).
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)•
Euler,D.,The Economic Impact of Prescribed Burning on
Moose Hunting,J.Environ.Manage.,3:1-5 (1975).
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).
Geist,V.,On the Behaviour of the North American Moose
(Alces alces andersoni Peterson 1950)in British Columbia,
Behav.,20:377-416 (1963).
Gysel,L.W.,Bulldozing to Produce Browse for Deer,
Michigan Agr.Exp.Sta.,Lansing,Quarterly Bull.,
No.43:722-731 (1961).
Klein,D.R.,The Reaction to Produce Browsing fo'r 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).
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 Pic10ram Pellets,Wildl.
Soc.Bull.,2:40-45 (1974).
Peek,J.M.,D.L.Urich and R.J.Mackie,Moose Habitat
Selection and Relationships to Forest Management in
Northeastern Minnesota,Wildl.Monogr.No.48 (1976).
Roby,D.D.,Behavioral Patterns of Barren-Ground Caribou of
the Central Arctic Herd Adjacent to the Trans-Alaska Oil
Pipeline,M.S.Thesis,Univ.of Alaska,Fairbanks (1978).
Spencer,D.L.and J.Hakala,Moose and Fire on the Kenai,
Proc.Ann.Tall Timbers Fire Ecol.Conf.3:10-33 (1964).
~I
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RESPONSE TO COMMENT 1.227 (cont.):
Tracy,D~M.,Reactions of Wildlife to Human Activity Along
Mount McKinley National Park Road,M.S.Thesis,Univ.of
Alaska,Fairbanks (1977).
Usher,R.G.,The Response of Moose and Woody Browse to
Clearing in the Boreal Mixed-Wood Zone of Alberta,M.Sc.
Thesis,Univ.of Calgary,Calgary,Alberta (1978).
COMMENT 1.228:
"Page E-3-495:(iii)Willow to Healy:Paragraph 1:The text
should indicate whether widening of the 1ntertie between
Willow and Healy will be immediately adjacent to the
existing line throughout that corridor."
RESPONSE:
Susitna transmission lines paralleling the 1ntertie route
will be locat~d adjacent to the 1ntertie line.Spacing
requirements between the 1ntertie and Susitna lines will be
similar to those shown in FERC License Application Figure
E.3.85 (Typical-Transmission Right-of-Way Cross Section).
Deviations from this spacing requirement may occur in
specific areas where site specific impacts or constraints
resulting from construction of the 1ntertie have been
identified.Such refinements in line routing will be
determined during the detailed construction planning for the
transmission line in consultation with the appropriate
landowners/managers and agencies.
COMMENT 1.229:
"Page E-3-496:(b)Furbearers:Paragraph 2:Please refer to
our previously described concerns with the marten model,
Section 4.2.l(m)."
RESPONSE:
Please refer to the Response to Comment 1.203.
COMMENT 1.230:
"Page E-3-497:(c)Birds:Paragraph 3:Reasons as to shy
the 34kv construction transmission line could not be built
to avoid the possibility of electrocution should be
----~---------------...
COMMENT I.230 (cont.):
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)."
RESPONSE:
A final decision regarding the size and routing of a
transmission line to provide construction power has not yet
been made.Please refer to the Response to Comment I.393.
In general,without mitigation,the potential of raptor
electrocution is greater on transmission lines 69 KV or
smaller due largely to closer phase spacing and grounding
practices.However,for the Susitna Project,if the lower
voltage line is selected to supply construction power,the
towers will be designed to conform to Rural Electrification
Administration (REA)guidelines and will incorporate other
standards (Olendorff 1981)for protecting raptors.Some of
these mitigative measures are shown in Figures E.3.119
through E.3.123 of Exhibit E of the License Application.
These mitigation measures are presented as Mitigation
Plan 22 on page E-3-539 of FERC License Application
Exhibit E.
REFERENCES
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).
COMMENT I.231:
"Page E-3-498:(c)Birds:Paragraph 7:Because of potential
disturbance to golden eagle and raven nesting locations
(GE-18,R-13,and R-21),we recommend that construction of
the transmission line between Watana dam and the Intertie
occur before March 1 and after May 10 (per Table E.3.128)if
those nests are inactive,or before March 1 and after the
interagency monitoring team confirms that the young have
fledged and left (in July for ravens and in September for
golden eagles)if the nests are active."
pm,
.....
.-.
RESPONSE TO COMMENT 1.231:
As stated on FERC License Application page E-3-533 and Table
E.3.168,major ground activity will be prohibited within 1/2
mile of active golden eagle nests between August 31 and
March 14.Nests will be assumed to be occupied until June 1
each year.~o specific restrictions have been adopted for
activities near common raven nesting locations,although
construction activities will be avoided,where possible,in
the vicinity of raven nests during sensitive periods.The
raptor nest protection criteria listed in FERC License
Application Table E.3.168 were developed for the proposed
Alaska Natural Gas Transportation System by raptor
biologists in Alaska and were modified for application to
the Susitna Basin based on known phenology of nests.
COMMENT 1.232:
"Page E-3-499:4.3.5 -Impact.Summary:Paragraph.1:
Criteria used to determine whether impacts on wildlife
populatons were,'•••of sufficient magnitude to influence
mitigation planning,'should be provided.We are concerned
that emphasis appears to be on impacts for which mitigation
measures can later be recommended.Uncertainties in
predicting project impacts on the basis of existing
information are evident here.The general and incomplete
nature of the resulting Mitigation Plan are due to these
uncertainties.".
RESPONSE:
Mitigation goals and planning criteria are discussed in the
FERC License Application Exhibit E,Chapter 3,Section 1.3
pages E-3-3 to E-3-6 and,in further detail at pages E-3-147
to E-3-190,E-3-250 to E-3-275 and E-3-508 to E-3-550.
Mitigation planning focused on programs that are associated
with significant species and for which practical mitigating
techniques exist or are likely to be developed in time for
application for this project.Additional studies are being
performed to refine the precision of impact analyses and
mitigation planning (see Responses to Comments A.10C,F.6,
F.27 and F.47).In particular,the systems of aquatic
models should provide increasing resolution on impact
assessment,mitigation and enhancement plans for fisheries.
The Power Authority anticipates that the DEIS will discuss
impact assessment uncertainties .
______•__u_.---,_
...-
COMMENT 1.233:
"Page E-3-499:4.3.5 -Impact Summary:Paragraph 2:We
previously commented on the need to integrate discussions of
hunting with those in the Socioeconomic and Recreation
Chapters of the Exhibit E.Hunting demand and harvest data
p~esented throughout Section 4.3 are minimal and not
up-to-date.The location of the section on
socioeconomic/wildlife relationships,which has apparently
been added to Chapter 3 in response tc our comment
(Chapter 11,W-3-424),should be noted."
RESPONSE:
Please refer to the Responses to Comments 1.155 and 1.185
and Section 4.4.1(b)Mortality Factors (i)Hunting and
Trapping (FERC License Application Exhibit E,Chapter 3),
which contains the detailed discussion of hunting and
socioeconomic concerns related to alteration in human use
patterns in the area,as requested from the Draft
Application.
COMMENT 1.234:
"Page E-3-499:(a)Big Game:Paragraph 2:The preliminary
estimate of 300 moose which winter in the Watana impoundment
should be indicted here~also 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,personal communication)."
RESPONSE:
This estimate should be identified as "preliminary"as the
commentor suggests.Please refer to the Reponses to
Comments F.30 and 1.153 for responses to the remainder of
this comment.
COMMENT 1.235:
"Page E-3-500:Paragraph 2:Estimated moose losses to other
project facilities 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,
over time,should be quantified."
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RESPONSE TO COMMENT 1.235:
See the Responses to Comments 1.306, 1.336,1.344 and 1.492.
COMMENT 1.236:
"Page E-3-500:Paragraph 3:Although it may not be possible
to .accurately predict downstream habitat 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 mitigation."
RESPONSE:
Please refer to the Responses to Comments C.87,1.326,
1.346,1.542 and 1.552.
COMMENT 1.237:
"Page E-3-500:Paragraph 4:Whether alternative areas can
support displaced moose or whether those moose will alter
their movements in response to specific habitat alterations
is unknown throughout the project area."
RESPONSE:
The most recent available information indicates that
approximately 1,900 to 2,600 moose have home ranges which
include any portion of the impoundment areas (and,by
inference,surrounding facility sites)(Ballard,et ale
1983).Although individual moose will undoubtedly alter
their movements to avoid the impoundment areas and other
project facilities,and will probably use the transmission
corridors as browse sources and as movement corridors,these
alterations in movement are not expected to produce changes
in the size or productivity of the 1,900-to-2,600-moose
population in question.Moose populations through which the
entire transmission system passes will cumulatively total
far more than 2,600 individuals,and population-level
impacts to these moose will be even less likely to occur.
Avoidance behavior due to construction-related disturbances
is also not expected to produce a detectable
population-level impact on moose.Such short-term
disturbances will probably result in"temporary avoidance by
moose of areas of concentrated human activity,especially in
~~--"._------------~----,-------------------------
RESPONSE TO COMMENT 1.237 (cont.):
the immediate vicinity of the Watana and Devil Canyon dam
construction sites.
As stated in the discussion preceding the paragraph
questioned by t~e reviewer,II [m]oose will be most severely
affected by habitat loss caused by inundation of spring and
winter range ll (Exhibit E,Chapter 3,page E-3-499).The
entire moose impact assessment presented in the License
Application supports this point.Alterations in the
movements of individual animals to avoid facilities and
human activities will have a negligible effect compared to
that of habitat loss.
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 1.238:
"Page E-3-502:Paragraph 1:We concur with the ADF&G's
concern."
RESPONSE:
The Power Authority also shares this concern.Impacts to
current or higher population levels,as summarized on FERC
License Application page E-3-501,may reduce management
options,as noted on FERC License Application page E-3-502.
COMMENT 1.239:
IIPage £-3-502:Paragraph 2:Loss of escape cover and
disturbance from reservoir clearing activities in the
vicinity of the Jay Creek mineral lick area should be
discussed.II
;ax;;
.,..
RESPONSE TO COMMENT 1.239:
Please refer to the Responses to Comments 1.191 and A.ll.
COMMENT 1.240:
"Page E-3-S02: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."
RESPONSE:
No project construction activities are proposed for the
Prairie Creek area.A potential recreational development
(trails,campsites,dock)is included at Stephan Lake
(approximately five miles away)in Phase 5 (last)of the
Recreational Development Plan (License Application page
E-7-108,109).Facilities will be developed there only if
demand requires and if their development will not result in
unacceptable adverse effects.
CO~ENT I.241:
"Page E-3-S04:(b)Furbearers:Paragraph 1:and
Page E-3-50S:Paragraph 2:Please refer to our comments on
Section 4.3.1 (i)[ii].n
RESPONSE:
Please refer to the Responses to Comments l.198, l.199,
1.200 and 1.201.
COMMENT 1.242:
"PageE-3-504:Paragraph 3:Work on the beaver habitat
model has been at a standstill since the February 28-
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 model will be
developed."
~-----"-----_..,_._-"-,_.----------,~---_.__._------------"---_.-------
RESPONSE TO COMMENT 1.242:
Please refer to the Response to Comment 1.168.
COMMENT 1.243:
"Page E-3-506:Paragraph 1:Th~quantification of ~arten
losses provided here (also see Section 4.3.l[m])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."-
RESPONSE:
The text on FERC License Application page E-3-471,
Section 4.3.2(m)should be corrected to read "Habitat for
approximately 21 marten will be lost to the impoundment and
construction sites,borrow sites,etc.1I Likewise,FERC
License Application Table E.3.157 should also be corrected
to read "Approximately 21 marten will be lost to D.C.
impoundment."These corrections will then make these
sections consistent with the estimate of marten lost due to
habitat removal by the Devil Canyon·impoundment and
facilities as summarized on FERC License Application
page E-3-506.The estimate of 21 marten was derived by
using the estimate of forest habitat loss in the Devil
Canyon area given in FERC License Application Table E.3.84,
and the estimate of marten population density in the Susitna
Basin from License Application Section 4.3.1(m),in the
following equation:
Forest habitat lost x population density =No.of
marten affected
(2,499 ha)x (0.0085/ha)
COMMENT 1.244:
=21 marten
"Pages E-3-506 through E-3-507 (c)Birds and Non-game
Mammals:Taking of bald and golden eagles is generally
prohibited under the Bald Eagle Protection Act (see
Section 4.3.1[nJ)."
-
RESPONSE TO COMMENT 1.244:
Please refer to the Response to Comment 1.210.The Power
Authority's letters as early as February 1983 to the USFWS
note this and requested assistance in determining a
solution.
COm-lENT 1.24 S:
"Page E-3-S08:4.4 -Mitigation Plan:This is a good first
step in developing a comprehensive plan for mitigating
project impacts.Presentation of the plan in the license
application is the first opportunity 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
recommendations on Section 3.4 are thus applicable to
Section,4.4;e.g.,facility siting,reclamation,access
regulation,habitat acquisition and improvement,etc.
Please also refer to Attachments A through C."
RESPONSE:
On page E-3-S08,the FERC License Application states that as
additional information from "continuing studies becomes
available,certain concepts contained in this mitigation
plan will be refined to specity the number,location,and
design of mitigation features."Mitigation plan refinement
is an ongoing process that involves incorporation of field
study and modeling results,as well as consultation with
resource agencies.Agency consultation is being conducted
through monthly meetings involving key terrestrial study
team members,including representatives from the u.S.Fish
and Wildlife Service and Alaska Department of Fish and Game.
In addition,numerous technical meetings on specific topics
related to impact assessment and mitigation plan refinement
are taking place which involve agency personnel.A mitiga-
tion plan refinement report to include the most refined
version of the terrestrial mitigation plan including
-----_._-_._-,--_._----
RESPONSE TO COMMENT 1.245 (cont.):
specific implementation procedures for many aspects,will be
available in late May 1984.
COMMENT 1.246:
"Page E-3-508:4.4 -Mitigation Plan:Paragraph 2:In
addition to the vegetation and wetlands mapping and
vegetation data analysis described previously (Sec-
tion 3.2.2),other required studies include:(1)moose food
habits and browse information necessary to complete the
moose carrying capacity model;(2)continued radio-tracking
of collared big game,including moose downstream and
recollaring of animals whose collars will soon become
nonfunctioning,(also see footnotes 3W-5 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 T,olOrk sessions
and larger interdisciplinary workshops to ensure that objec-
tives are coordinated,a common base of project assumptions
are used,and plans are complementary;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.).
"We recommend that the Environmental Guidelines included as
Appendix E.3.B to the Exhibit E '•..be incorporated by the
Alaska Power Authority,'(Chapter 11,W-3-437).We have
attached to our comments a more complete set of Biological
Stipulations.We recommend that Attachment A be
incorporated into the license and construction contracts."
"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."
:'3W-8/Hodafferi,Ronald D.March 1982.Susitna Hydro-
electric Project,Phase I Fina 1 Report,Big Game Studies.
Volume II.Moose-Downstream.Submitted to the APA by the
ADF&G."""
COMMENT 1.246 (cont.):
"Ballard,Warren B.,Craig L.Gardner,John H.Westland,and
James R.Dav.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.[Footnote 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.]
[Footnote 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.]"".
RESPONSE:
This Comment consists of many parts,most of which are indi-
vidually addressed in greater detail by other Comments.
Please refer to the appropriate Responses as follows:
Paragraph 1:.Comments
7.,testing of mitigation measures
-
-
.-
1.
2.
3.
4.
5.
6.
moose food habits,browse,
carrying capacity model
radio-tracking big game
beaver studies
marten studies
otter studies
species models
C.86,1.53
C.78
C.80,1.168
see below
1.172
see below
C.82,F.80,
F.61,1.2
RESPONSE TO COMMENT 1.246 (cont.):
Paragraph ~
Environmental Guidelines/
Biological Stipulations
Corrnnents
1.377
1.425-1.489
~,
~,
Regarding Item 4 under paragraph 1 of the Comment,addi-
tional marten studies are not currently planned.The
ecology of marten have been studied for 2-1/2 years in the
Project area (Buskirk 1983).The full results of these data
were not available during preparation of the FERC License
Application.As part of impact assessment refinement,
improved estimates of marten numbers affected by the Project
will be generated based on all available data.
Also,the Power Authority anticipates that the DEIS will
describe and incorporate existing studies of the topics
mentioned in this Comment.
REFERENCES
Buskirk,s.W.,The Ecology of Marten in Southcentral
Alaska,Ph.D.Thesis,Univ.of Alaska,Fairbanks (1983).
COMMENT 1.247:
"Page E-3-509:(al Reduction in Carrying Capacity:Our
previous comments.on minimizing disturbed areas,
consolidating features,and using mitigative construction
techniques apply here (see Section 3.4.2)."
RESPONSE:
Please refer to the specific Comments on the cited section,
FERC License Application pages E-3-252 to E-3-29l.
Specifically,see the Responses to Comments 1.381, 1.382,
and 1.389.
COMMENT 1.248:
"Page E-3-5l0:(i)Moose:Paragraph 1:Calculations of
losses in vegetated habitat should be corrected.An
additional 406 ha will be permanently lost to roads and
.....
-
CO~mENT 1.248 (cont.):
highways.Neither borrow sites nor spoil areas for road
construction were 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)."
RESPONSE:
As stated on FERC License Application page E-3-253,which
has been revised based on supplemental information,
approximately 447 hectares will be lost to project-related
roads,and an additional 14 hectares may be lost temporarily
through the construction of borrow areas in support of the
access routes.Because detailed mining plans have not been
prepared for borrow sites,and because spoil areas for road
construction have not yet been identified,it is not
possible to determine areas of specific habitat types which
will be affected by these facilities.During detailed
engineering design,geotechnical investigations will
determine more precisely the probable locations of borrow
sites and spoil areas to be designed following detailed
routine surveys.Because the precise locations and area
extents of these facilities have not yet been determined,
they cannot be included in the license application except in
a general way.As detailed engineering design"and
construction planning proceed,environmental specialists
working in the engineering design office will make more
precise determinations with respect to specific vegetation
types affected by these facilities.More importantly,these
environmental specialists will provide the necessary
information to insure that vegetation types of high value to
wildlife or of other special resource interest (i.e.,
wetlands)will be avoided as much as feasible by detailed
engineering design.See also the Response to Comment 1.235.
COMMENT 1.249:
IIPage E-3-510:(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."
RESPONSE:
As stated in FERC License Application Exhibit E,on page
E-3-526,
--'-----,-,~-~,
.'M
RESPONSE TO COMMENT 1.249 (cont.):
"Minimization of habitat loss to the transmission
corridor will be accomplished by selective clearing in
the corridor (Figure E.3.85),leaving small shrubs and
trees,and by leaving a 35-foot (10 rn)wide strip of
vegetation up to 10 feet (3 m)tall.Additional
rectification for habitat loss will be provided by
allowing vegetation to grow to a height of 10 feet
(3 rn)during operation.The transmission corridor
design is described more completely in Section 3.4.2.
This design will actually enhance habitat for moose and
other wildlife preferring vegetation types in early
successional stages."
-
.~
......
COMMENT I.250:
"Page E-3-5l0:(i)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 has foreclosed management options of the
Board."
RESPONSE:
Please refer to the Response to Comment I.219.
COMMENT I.251:
"Page E-3-5l1:(ii)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."
RESPONSE:
The Power Authority objects to the impact assessment for
caribou being characterized as "...given the unknown nature
of project impacts ••."The major uncertainty of the
analysis is related to the conjectural impact mechanisms
suggested by resource agencies and which the authors
acknowledge in their discussion.Direct project impacts on
caribou populations will probably be insignificant with
respect to habitat loss,minor with respect to the access
corridor,and minor with respect to crossing the reservoir
(Fancy,1983 and Jakimchuk,1980).
The Power Authority in a letter from Richard Fleming to
Chris Beck of the Department of Natural Resources dated 23
August 1983 suggested that if the Ne1china Special Use
District ever became a reality,the upper portions of the
reservoir and adjacent project lands could be managed in a
manner compatible with the goals of the Special Use
District.This and the other proposed management activities
RESPONSE TO COMMENT 1.251 (cont.):
should provide sufficient compensation for the commentor's .
conjectural impact to caribou.
REFERENCES
Alaska Power Authority,Letter from Richard Fleming to Chris
Beck,Department of Natural Resources (August 23,1983).
Fancy,Steven G.,Movements and Activity Budgets of Caribou
Near Oil Drilling Sites in the Sagavanirktok River
Floorplain,Alaska (June,1983).
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
PERC on May 31,1983.
COMMENT I.252:
"Page E-3-512:(iii)Dall Sheep:Lowering the Watana dam
height would minimize or avoid impacts to sheep.If the dam
were about 185 feet lower than now proposed,physical loss
of the Jay Creek mineral lick and escape cover would be
largely avoided and disturbance would be somewhat
minimized."
RESPONSE:
Please refer to the Response to Comment A.11 for further
discussion of the complex of lick sites known as the Jay
Creek mineral lick.
Regarding major changes in the Project such as lowering the
Watana Dam height by 185 feet,please see Responses to _
Comments B.1 -B.5 and F.39.
COMMENT I.253:
"Page E-3-513:(iv)Brown Bears:Paragraph 6:Cooperative
management agreements to mitigate potential impacts of
secondary development and access should be reached among the
APA,resource agencies,and private landowners and
incorporated into the project license.We recommend that -,
public access not be allowed on the project spur road across
the Watana dam.Such access prohibitions are necessary to
-
.-
-
-
COMMENT 1.253 (cont.):
prevent disturbance to bear concentrating on Prairie Creek .
during salmon runs.1I
RESPONSE:
Prairie Creek is located approximately 20 air miles
southwest of the Watana site.At the present,the only
access is by float plane to Lake Stephan.Project studies
have indicated a significant gathering of grizzly bear
feeding along the creek during the salmon runs up the creek .
A host of conjectural impacts on bear populations have been
proposed which related to the development of the surrounding
lands by the landowner (i.e.,native corporations).These
have been viewed as secondary project impacts.The impacts
relate primarily to increased human activity around Lake
Stephan and along Prairie Creek and to increased hunting
pressure.
At this time it is unclear how,or when,native corporations
will develop their lands.The actions of the native
corporations are the major determinant with respect to
possible adverse impacts to bear populations.
The Power Authority is in no position,nor does it have any
desire,to impede native development of native lands.In
fact,the intent of the Alaska Native Claims Settlement Act
was to provide a resource basis to support development of
the native community.The Power Authority does not assume
any burden related to conjectural impacts caused by nati~e
development of native land.Fish and Wildlife Resource
Agencies should address their concerns directly with the
native landowners and the land managing agencies.
COMMENT 1.254:
IIPage E-3-513:(v)Black Bears:Paragraph 2:Aligning
transmission corridors through tundra areas may not minimize
impacts to black bears,and may disturb brown bears;thus we
question the rational for this alignment."
RESPONSE:
As documented in Miller and McAllister (1982)and Miller
(1983),both bear species are wide ranging and utilize a
variety of tundra,shrubland and forest habitats.Thus,
from the standpoint of minimizing impacts to bears,the
value of one transmission corridor alignment over another is
difficult to demonstrate conclusively.The main reason for
RESPONSE TO COMMENT 1.254 (cont.):
aligning the transmission corridor between Watana and Devil
Canyon adjacent to the Watana to Devil Canyon access road is
to provide consolidation of the two facilities within a
common corridor,thus minimizing the zone of disturbance.
We believe that this approach in itself is of value in
minimizing impacts to both brown and black bears,and,in
fact,accommodates the Department of the Interior's
preferences as expressed in comments on the Draft License
Application (Department of Interior,National Park Service
letter on Draft License Application,January 14,1983,FERC
License Application,Volume lOB,Chapter 11,
Comment W-10-019)•
REFERENCES
~I
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).
ADF&G,Susitna Hydroelectric Project,Phase II Progress
Report -Big Game Studies (1983),previously submitted to
the FERC on'May 31,1983.
Miller,S.,Volume VI,Black and Brown Bear (1983).
COMMENT 1.255:
"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 impacts.it
RESPONSE:
In addition to the cited pages,these impacts are clearly
discussed on FERC License Application page E-3-S03 in the
Impact Summary Section (Section 4.3.5)and on FERC License
Application pages E-3-514 and E-3-518 of the Impact Issues
and Option Analysis Section (Section 4.4.1)under the
Mitigation Plan.
...
~,
-
.....
i~
,-
-
COMMENT I.256:
"Page E-3-514:(viii)Beavers and !4uskrat:and (ix)Mink and
Otter:.The APA should clarify the magnitude and certainty
for downstream habitat improvements (see our comments on
Section 4.3.1(i)(ii»."
RESPONSE:
Please refer to the Response to Comment I.198.
COMMENT I.257:
"Page E-3-515:(xl Marten:Please refer to our previous
comments on the preliminary nature of quantified of marten
losses (Section 4.3.1[m])."
RESPONSE:
Please see the Response to Comment I.203.
COMMENT I.258:
"Page E-3-515:(xi)Raptors and Raven:Paragraph 2:The
potential for the project to be in conflict with the Bald
Eagle Protection Act was previously detailed
(Section 4.3.1 In]) •"
RESPONSE:
Please refer to the Response to Comment I.210.
COMMENT I.259:
lIPage E-3-515:(xi)Raptors and Raven:Paragraphs 3 and 4:
While the total golden eagle population will not be greatly
affected,limited nesting habitat and sparse populations in
the interior make project impacts locally significant."
RESPONSE:
The intent of this Comment is unclear,as it echoes
statements made earlier in the FERC License Application.
Specifically,FERC License Application page E-3-444,
paragraph 2 states:
RESPONSE TO COMMENT I.259 (cont.):
"As a consequence,direct losses of cliff-nesting
locations in the middle basin as a result of
construction of the Susitna Hydroelectric project are
judged to be reasonably significant to the golden eagle
population inhabiting the Susitna River drainage."
Should the commentor be concerned that mitigation efforts
are not sufficient,mitigation for bald and golden eagles
remains one of the highest priorities of mitigation efforts
for affected wildlife.Considerable precedence has been
established for compensation of project effects by replacing
or moving nests or nest sites in other parts of North
America,and it is anticipated these techniques will work in
Alaska as well.
COMMENT I.260:
"Page E-3-51?through E-3-520:(i)Hunting and Trapping
Mortality:Please refer to Section 4.4.1 (a)[i])."
RESPONSE:
Please see the Responses to Comment I.219.
COMMENT I.261:
"Pages E-3-518 to E-3-519:(i)Hunting and Trapping
Mortality:Paragraph 5:We have previously commented on the
need to improve downstream sloughs for aquatic furbearers
(Section 4.3.1(i)[ii]).It is currently unknown which lakes
are deep enough to allow successful overwintering and
disperse:tl for beaver and muskrat."
RESPONSE:
Please see the Responses to Comments I.19B and I.l?1 for
responses to the first and second parts of this comment,
respectively.
COMMENT I.262:
"Page E-3-520 through E-3-522:(ii)Additional Mortality:
An environmental orientation program should be requisite at
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
~,
-
.....
""'"
-
COMMENT I.262 (cont.):
desirable for salmon yet beaver colonization may be
encouraged in ofher project areas."
RESPONSE:
As detailed project design,mitigation planning and execu-
tion and environmental monitoring continue,all of the
implications of proposed control measures will be
reevaluated and the most desirable solution identified
considering all aspects,not only the initiating problem
such as beaver in a culvert.Please refer to the Response
to Comment I.425.
COMMENT I.263:
IIPage 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.II
RESPONSE:
Mitigation planning is being made more detailed with respect
to specific protective activities to be undertaken prior to
and during project construction and operation.Efforts are
being made through meetings with representatives of the Game
Division,ADF&G,to plan optimally effective ways in which
adverse impacts to black bears and brown bears can be
avoided.In coordination with ADF&G,documented denning
locations are being identified on maps.Environmental
specialists using these maps and other resources will
provide direct input to engineering design products and
construction plans early in their preparation.Transmission
corridor routing,reservoir clearing,facility siting and
other components of engineering design and construction
planning,including scheduling of major construction
activities will be guided through regular consultation with
resource agencies.This consultation will include making
available preliminary design products and scheduling
documents for agency review,along with frequent discussions
__~.@ .a ...__~~__--_~...---,..._
RESPONSE TO COMMENT I.263 (cont.):
with agency representatives as the detailed design phase
progresses.
COMMENT I.264:
"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."
RESPONSE:
with proper mitigation measures,recreational activities
should have no adverse effect on Dall sheep using the Jay
Creek mineral lick area.As noted in the proposed
Mitigation Plan (FERC License Application page E-3-532),
ground activity and boat and floatplane use of the reservoir
would be prohibited within 1/2 mile of the mineral lick
between April 15 and June 15.These restriction dates are
subject to revisions,as indicated by Comment I.283 and its
Response,but the Mitigation Plan will prevent potentially
disturbing activities near the Jay Creek mineral lick during
the period of its use by sheep.
The proposed recreation plan would not lead to recreational
use patterns that would be likely to disturb the Jay Creek
area.The proposed facilities closest to Jay Creek are in
the Rosina Creek drainage,consisting of trails to Clarence
and Watana Lakes and undeveloped campsites at Watana Lake.
These two developments account for a total estimated visita-
tion potential of 857 visitor days per year,indicating low
intensity use.Access to these trails and lakes would be
either by floatplane or by boat.
Boat access could be from the west via the proposed Phase II
boat launch at Watana Dam or from the east via Lake Louise
or the Denali Highway bridge over the Susitna River.Rosina
Creek is more than 20 miles from Watana Dam;given this
distance and intervening recreation opportunities between
the locations,relatively few boaters would make this trip.
Those boaters who would reach Kosina Creek from Watana Dam
would turn into the creek drainage two miles west of the
confluence of Jay Creek and the reservoir,and therefore
would be unlikely to pass near the mineral lick.Boat
access from the east involves a much longer distance,
roughly 50 miles py water from the Denali Highway bridge to
Rosina Creek.While this route would cross the mouth of the
Jay Creek arm of the reservoir,boaters traveling down the
-
.....
I
-
RESPONSE TO COMMENT 1.264 (cont.):
reservoir to Kosina Creek would pass approximately two miles
to the south of the Jay Creek mineral lick.
COMMENT 1.265:
"Page E-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 implementing additional study and mitigation
needs.The length 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;(2)be fully supported by project funding;
and (3)be utilized to modify,delete,or add to the
Mitigation Plan in response to both information from ongoing
studies and needs which become apparent as project impacts
are realized.
"Another general reconunendation on the Mitigation Plan is
that consultation between the license applicant and resource
agencies include of working sessions with project design
engineers to fully incorporate wildlife mitigation plans."
"3W-9/See Footnote 3W-3.[Footnote 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
,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.]"
_.lIIF1
RESPONSE TO COMMENT I.265:
Please refer to the Response to Comment I.245 and also note
that mitigation plan refinement will include refinement of
monitoring plans including the mechanism for modifying
mitigation procedures based on feedback from the monitoring
program.We appreciate your recommendations regarding
monitoring.They will be considered during mitigation plan
refinement.Refer to Response I.119B.
COMMENT I.266:
"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.II
RESPONSE:
The frequency and timing of aerial photography for the
purpose of monitoring changes in vegetation cover in the
downstre~m floodplain will be reviewed and your recommenda-
tions considered during mitigation plan refinement efforts.
COMMENT I.267:
IIPage E-3-524:(3):Results of caribou monitoring may.
require further restrictions on access as recommended by the
interagency monitoring team.1I
RESPONSE:
No further restrictions on access would be needed unless
monitoring indicates unacceptable impacts.See also
Response I.119B.
COMMENT I.268:
IIPage E-3-524:(6):Surveys of active dens for brown bear,
black bear,wolf and fox dens should continue during
operation.II
-
-
RESPONSE TO COMMENT I.268:
As stated on FERC License-Application page E-3-S24,the
purpose of collecting information on the locations of active
dens is so that major ground and aerial activity during
construction can be controlled in order to minimize
distrubance impacts.The occurrence of major ground and
aerial activites will be minimal during operation.Please
refer to the Responses to Comments I.245 and 1.265 and note
that refinement of the monitoring plan is a continuing
process being carried out in consultation with resource
agencies.While occasional monitoring might be useful in
order to periodically assess bear populations,continuous
monitoring does not seem justified.
COMMENT I.269:
"Page E-3-525:(8):Downstream beaver surveys should extend
to the Yentna River to establish a baseline control for
assessing upstream losses and downstream habitat modifica-
tions (see Section 4.3.1[i])."
RESPONSE:
An aerial beaver cache survey along the Susitna River,
conducted during October 1983,extended from Cook Inlet to
Portage Creek.Preliminary results for that portion of the
survey between Talkeetna and Portage ~reek were referenced
in the Response to Comment C.80.
COMMENT I.270:
"Page E-3-525:(9):We concur with the need for annual
raptor nest surveys.Should surveys identify the presence
of the endangered peregine falcon,Section 7 consultation
should promptly be initiated with the FWS."
RESPONSE:
The PERC has already initiated Section 7 consultation
relative to the Susitna Project with the Department of the
Interior.
COMMENT 1.271:
"Page E-3-525:(10):If swan nesting is identified in areas
where there is possibility for disturbance,surveys should
continue through operation and maintenance."
RESPONSE:
The Power Authority agrees with your recommendation.
Mitigation Plan refinements will reflect this.
COMMENT 1.272:
"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 evaluated."
RESPONSE:
The Power Authority initiated work on the monitoring of
moose habitat enhancement efforts in 1982 by cooperatively
funding baseline studies to be used for monitoring the
effects of the proposed Alphabet Hills Burn.A review of
published and unpublished data regarding moose habitat
enhancement in South Central Alaska is presently under way.
A report presenting the results of this review is scheduled
to be available in late April 1984.
The need for supplemental surveys of annual big game numbers
and harvests in addition to those identified in Section
4.4.2(a)of the FERC License Application and those already
conducted for management purposes by the Alaska Department
of Fish and Game will be considered during efforts to refine
the monitoring plan.The Power Authority is funding ongoing
studies by ADF&G to monitor moose population in disturbed
areas adjacent to the lower river.
"""
COMMENT 1.273:
"Page E-3-525:(b)Mitigation Plans:Expected mitigation
benefits should be more adequately quantified.The
potential effectiveness of many recommendations is unknown."
RESPONSE:
Please refer to the Responses A.10C,C.82,F.9,F.44,F.45
and F.46.
COMMENT 1.274:
"Page E-3-525 to E-3-526:(1):Delaying reservoir clearing
a few years may aid a few individuals,but will have minimal
long-term affects on wildlife populations.Access as well
as schedules for clearing should be planned in consultation
with the resource management agencies.Clearing activity in
the Jay Creek mineral area should be restricted to the
period August 15 to May 1 to prevent disturbance to sheep
using the area.1I
RESPONSE:
Access and schedules for clearing of sensitive areas such as
the Jay Creek mineral lick are discussed on PERC License
Application page E-3-532.As project planning continues,
mitigation plan refinement will"continue in cooperation with
the resource management agencies.Precise clearing
schedules will be refined in this manner as stated at the
top of FERC License Application page E-3-526.
-
_.
-
COMMENT I.275:
"Pages E-3-526:(2):Please refer to our previous comments,
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 recommend that no borrow
activities occur in the portion of borrow site E at the
confluence of Tsusena Creek with the Susitna River."
RESPONSE:
During the feasibility study,it was perceived that,upon
the excavation of material in Borrow Site E,much of the
area would be below the Susitna project operation river
level (1,455 feet)and the Devil Canyon Reservoir level.At
the present time,the portion of Borrow Site E at the
confluence of Tsusena Creek and the Susitna River is
included within this area.
During detailed design,a more detailed description of
construction methods to be employed at Borrow Site E will be
developed.Excavation from this primary source of dam
embankment material will result in the area being inundated
by the river.Even if we were to exclude borrow operations
of the delta tributary area of the borrow site,subsequent
erosion due to the adjacent deep pool would eventually
degrade portions of the delta.
COMMENT I.276:
"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
E-3-275 through E-3-281."
RESPONSE:
Shrubs,herbs and saplings which provide forage for moose
characterize early successional plant communities on sites
where all original vegetation has been removed.\Species
such as black spruce grow slowly and are a minor component
of revegetated areas in early years.Surrounding vegetation
we~__·--~_
RESPONSE TO COMMENT I.276 (cont.):
does affect the seed rain and hence,·the species composition
and speed of revegetation.This is particularly true for
alder and birch which usually disperse seeds relatively
short distances compared with fireweed and willow which can
disperse for several miles.
Terrain features,vegetation patterns,and habitual
movements do affect moose and bear use of revegetated areas.
However,factors which are probably more important in
determining the value of revegetated areas for moose and
bear are the proximity of project facilities,roads and
human activity.Please refer to the Response to Comment
1.397.
COMMENT 1.277:
"Page E-3-525:(4):Anticipated forage gains from clearing
of the transmission corridor should be compared with
anticipated forage losses due to permanent project -\
facilities.Also see Section 3.4.2(a)(i),pages E-3-269
through E-3-274."
RESPONSE:
Forage gains expected to result from clearing of the
transmission corridors have not been estimated.Forage
increases will depend on successional stages which occur
following clearing of each vegetation type,and on the
cumulative area of each vegetation type cleared.Areas of
vegetation types to be crossed by the transmission corridors
have been quantified (Exhibit E,Chapter 3,Tables E.3.79,
E.3.80 and E.3.86).
It should be noted that the term "forage"is not specific,
and that forage value and availability depend on the
wildlife species under consideration.Forage loss for a
certain number of individuals of one species may constitute
a forage gain for a different number of individuals of
another species.'The tradeoff must therefore be extended
from comparing only 19cations of available forage,so that
it also includes a comparison of wildlife species
potentially utilizing the forage in question.
~\
..-
-
COMMENT I.278:
"Pages E-3-526 and E-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;page 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-2-121, E-2-123,
and E-2-124)."
RESPONSE:
As stated on FERC License Application pages E-3-526 and
E-3-527,habitat alteration which will occur downstream from
the Devil Canyon dam will be reduced through the use of
multi-level intake structures that will maintain river
temperatures as close to normal as possible.This will
minimize the open water reach and therefore will aid in
reducing vegetation frosting,and blockage of big game
movements by open water in winter,as stated in the License
Application.However,the impacts may still occur
especially in the open water downstream from Watana,but
they will be minimized to the extent possible.Thus the
cited statements are not inconsistent with the discussions
of blockage of movements by open water and frosting of
vegetation as found on FERC License Application
pages E-3-408 and E-3-435~The Power Authority awaits any
analysis that indicates that frosting of vegetation
represents a real problem for moose and not just a
conjectural impact mechanism.
For further discussion of the reservoir temperature and
river icing models,see the the Responses to Comments B.6,
B.31,B.32,B.33 and I.39.
COMMENT I.279:
"PageE-3-527 through E-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."
RESPONSE TO COMMENT 1.279:
The Power Authority is presently funding studies to identify
candidate mitigation lands and associated problems and to
review habitat enhancement techniques for these lands.
Reports providing the results of these studies are scheduled
to be available in February and April 1984,respectively.
Further site-specific evaluations of lands to be managed
will be conducted after specific mitigation lands are
identified.The base maps used to identify candidate
mitigation lands were developed by the Habitat Division of
the ADF&G .and identify areas as having high potential for
wildlife.See Response to Comment 1.301.
COMMENT 1.280:
"Page E-3-529:Paragraphs 3 and 4:Projected improvement of
bear habitat should be quantitively supported through
controlled burns and revegetation.It was stated earlier
that permanent 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."
RESPONSE:
Please refer to the Responses to Comments C.82 and F.52.
COMMENT 1.281:
"Page E-3-531:Paragraph (3):During 1983 field studies,
ADF&G found the Jay Creek mineral lick area to be larger
than they had previously believed.Thus,we recommend 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."
RESPONSE:
Please refer to the Responses to Comments 1.190,1.191 and
A.l!.
-
.-
COMMENT 1.282:
"Page E-3-531:Paragraph S:Restrictions on aircraft
activity near active fox dens should be established through
consultation with ADF&G."
RESPONSE:
The Power Authority agrees with this Comment.Current
restrictions will be incorporated into the Mitigation Plan
as appropriate.
COMMENT 1.283:
"Page E-3-532:Paragraph 4:Ground activity near _the Jay
Creek mineral lick should be prohibited between May 1 and
July 30."
RESPONSE:
Tentative ground activity restrictions near sensitive areas
are identified on FERC License Application pages E-3-532 and
E-3-533.As project planning and mitigation plan refinement
continue,these restrictions will be refined in cooperation
with resource management agencies .
COMMENT 1.284:
"Page E-3-532:Paragraph 5:The text should clearly
indicate that sensitive areas include brown bear and black
bear dens and the Jay Creek mineral lick area."
RESPONSE:
Because the cited page deals exclusively with sensitive
areas and because paragraphs 4 and 6 of that page deal
exclusively with restrictions for major ground activity near
the Jay Creek mineral lick and bear dens,respectively,and
because clearing activities are identified as a major ground
activity (at the top of the cited page),the Power Authority
believes that the Comment subject is clearly indicated in
the text of the FERC License Application.
COMMENT 1.285:
"Page··''E-3-532:Paragraph 8:
included here."
RESPONSE:
Active fox dens should be
The last paragraph on FERC License Application page E-3-532
should be amended to read:
"Ground activity will be prohibited within 1/4 mile of
known active wolf or fox dens or wolf rendezvous sites
between May 1 and July 31."
COMMENT 1.286:
"Page E-3-533:Paragraph 3:Final siting and scheduling of
construction and use of the Watana to Devil Canyon access
road near nesting location GE-18 should be decided in
consultation with the FWS to ensure compliance with the Bald
Eagle Protection Act."
RESPONSE:
The Alaska Power Authority intends to consult with the
U.S.Fish and Wildlife Service regarding specific mitigation
measures for each bald or golden eagle nesting location
potentially impacted by the Project.
COMMENT 1.287:
"Page E-3-533:Paragraph .4:Our previous comment on siting
in consultation with the FWS also holds for the railroad
alignment near nesting location BE-8."
RESPONSE:
Please see the Responses to Comments 1.224 and 1.286.
COMMENT 1.288:
"Page E-3-533:(11):In areas of permafrost,higher road
profiles may be required."
.-
,.....
-
-
R~SPONSE TO COMMENT I.288:
Access routing has been refined to avoid poorly drained as
well as potential frozen soils where possible.Alignment of
the 'access road along well-drained and non-frost susceptible
soils will be maximized to enable the use of side borrow
techniques in level terrain and balance cut-and-fill inside
hill cut areas.In areas where the alignment crosses frost
susceptible or frozen soils,the design of the road embank-
ment will be based on the localized conditions.Since the
site area is characterized by discontinuous,"warm"perma-
frost,the existing foundation conditions will determine
whether the ground is allowed to thaw and consolidate prior
to placement of the embankment fill or if the ground is to
be kept frozen after construction of the road embankment.
Prevention of permafrost degradation often requires an earth
embankment sometimes exceeding five feet in depth.Alterna-
tively,the thickness of the fill required can be reduced by
insulating the subgrade by·leaving the vegetation mat
undisturbed and/or a layer of rigid insulation can be placed
in the embankment.
For additional information,see the Response to Comment A.4.
COMMENT I.2a9:
"Page E-3-534:(12):We recommend that the APA consul:t with
resource agencies in reviewing options for reducing traffic
volume.If our recommendation to drop the proposed Denali
Highway to Watana access road is not adopted,·then we
recommend that the road not be maintained following project
construction.Rehabilitation of this link would inhibit
public access and thus minimize impacts to all species from
continued disturbance and habitat loss.Continued access
for project maintenance could be through the railway and
Devil Canyon to Watana Road.".
RESPONSE:
The Power Authority will contact Federal and state agencies
with land management,resource management and administrative
responsibility regarding options to reduce traffic volume on
the proposed access road from the Denali Highway to Watana.
Such consultation can be best accomplished when construction
plans are being formulated by the project's construction
manager.It should be pointed out,however,that road
access is required throughout construction of the Watana and
Devil Canyon projects,and is desirable during operations.
i'lil!l_~_''ilim_...'~•_
RESPONSE TO COMMENT 1.289 (cont.):
A review of access plans as related to the issue of public
access is provided below.
Current plans call for restricted access from Denali Highway
to the darn site during construction.Eliminating public
access during construction is preferred from a construction
standpoint.Such a policy prevents safety-related problems
which would arise if the public were allowed to travel
freely to the construction site.A restricted construction
access policy also provides environmental benefits by
minimizing impacts to all species and by preventing habitat
loss.
After construction of the Watana project,plans call for
construction of a road between Watana and Devil Canyon and
rail access to the Devil Canyon project during this period.
The Power Authority would continue to maintain the road from
the Denali Highway to Watana and from Watana to the Devil
Canyon project so that road access to Devil Canyon would
exist throughout that project's construction.Maintaining
road access provides flexibility for emergency or other
situations when rail access is not possible.
Refer to the Responses to Comments A.l and A.3 •
.COMMENT 1.290:
"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 critical as loss of
portions of the lick,exposing new mineral soil may be of
little value as mitigation (Nancy Tankersley,personal
communication)"
RESPONSE:
~i
!@Wi!,
It is unclear how "loss of escape cover"would occur.
Specific criteria will be established for determining
additional mitigation measures should be implemented.
will be incorporated into refined mitigation plans.
COMMENT 1.291:
when
These
"Pages E-3-534 through E-3-525:(14):Mitigation of project
impacts through regulation of hunting will occur
independently of project activities.When such regulation
COMMENT 1.291 (cont.):
is determined necessary by the Alaska Board of Game,it will
be at the expense of other managewment options (see
Section 4.4.1(a)(i])."
RESPONSE:
Please refer to the Response to Comment 1.219.
COMMENT 1.292:
"Page E-3-535:(15):Environmental briefings should also be
developed for workers'families who will be residing in the
construction village."
RESPONSE:
Environmental briefing programs will be conducted with site
authorizations for appropriate project personnel •
.-
COMMENT 1.293:
-
"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 4.4.1(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 areas where it will be lost."
RESPONSE:
The FERC License Application does not state or imply "that
downstream slough modification will effectively compensate
for upstream impacts to salmon and bear."The section
referred to by the reviewer (FERC License Application
Exhibit E,Chapter 3,Section 4.4.1(a)(iv»states:
IIA reduction in salmon spawning between Po;rtage Creek
and Talkeetna has been identified as a possible factor
which would reduce carrying capacity for brown bear.
This impact will be avoided through maintenance for
downsteeam sloughs for salmon spawning (see Section
2.4.4[a]).11
----------------------.....,-~------
RESPONSE TO COMMENT I.293 (cont.):
It'was the intention of the authors to point out that
sloughs and side channels Qetween Devil Canyon and Talkeetna
appear to be important feeding areas for brown bears and
black bears.As stated in FERC License Application
Exhibit E,Chapter 3,Section 4.3.1(d)(ii),page E-3-426,
"Indirect impacts on brown bears downstream from Watana
will result from reduced populations of moose and
salmon and from increased hunting along the
transmission corridor.Moose,bear and salmon studies
are being conducted downstream from Watana in an
attempt to quantify project impacts.The carrying
capacity of the areas adjacent to the river will
decrease if salmon and moose populations are
substantially reduced."
As discussed further on FERC License Application page
E-3-429,
"Downstream effects of the Watana development on black
bears are likely to be much less severe.Impacts on
salmon spawning areas,aircraft disturbance and
increased hunting will probably have the greatest
effect on the population.The expected successional
changes in vegetation are not likely to have a notice-
able effect on the population,nor will any open water
areas dUEing winter,since bears will be in dens at
that time.The importance of salmon to downstream
bears is unknown,but several bears from the middle
basin moved downstream to feed on salmon during a berry
crop failure,and bears are commonly seen along
spawning sloughs in late summer (ADF&G 1982e).Twenty
percent of the salmon radio-tagged during studies
downstream were eaten by bears (Miller 1982 Personal
communication).However,bear scats found along salmon
streams comprise mostly berries,and thus the
importance of salmon to these bears is uncertain.Bear
studies downstream from Devil Canyon will be
intensified in 1983,and consequently,the food habits
of downstream bears will be better defined at that
time."
The 1983 data referred to here will be available in April
1984.For more detailed discussion of food habits of
downstream black bears,including a review of the question
of salmon importance vs.berry importance in the black bear
diet,see Miller (1983),Chapter 3,pages 39-48.
~,
.~
.-
RESPONSE TO COMMENT I.293 (cont.):
Because upstream access by inmigrating salmon is largely
restricted upstream of Portage Creek,it seems likely that
impacts on brown bears and black .bears resulting from
decreased salmon availability in the Susitna River would
only occur downstream from Devil Canyon.As stated above,
studies of the downstream area are continuing in an attempt
to quantify the importance of salmon available in sloughs
and side channels of this reach to"the brown bear and black
bear diets.If salmon are indeed important to bears along
the reach between Devil Canyon and Talkeetna,and if project
implementation is likely to decrease salmon availability in
this reach,then mitigative measures proposed to rectify or
compensate for this reduction become important as mitigative
measures to offset impacts to brown bears and black bears.
On FERC License Application pages E-3-l64 and E-3-l65 of
Exhibit E,it is stated that:
I1Impacts to salmon spawning areas will occur if
mitigation measures are not employed in coordination
with the proposed project flows (or the alternative
regime of short-term augmented flows).The
rectification methods selected are (1)to maintain
access to the sloughs;and (2)to ensure suitable
spawning and incubation habitat by physically modifying
sloughs,to maximize use of reduced filling and
operational summer flows.The following habitat
enhancement measures will be applied either singly or
in combination on sloughs,depending on the type of
impact that limits salmon production.These methods,
especially if used in combination with short-term
augmented flows during the spawning season,will
maintain salmon productivity in sloughs."
This section goes on to present a variety of mitigative
measures designed to maintain use of these sloughs by
spawning salmon.The referenced statement on FERC License
Application page E-3-536,that "Decreased availability of
salmon to bears will be completely compensated for by
enhancement of 13 sloughs between Devil Canyon and the
confluence of the Chulitna and Talkeetna Rivers"is
substantiated and supported by proposed fisheries mitigation
measures.
We agree that further quantification of expected changes in
vegetation at rehabilitated facility sites will be necessary
before a precise assessment can be made of the probable
value of the revegetated sites to wildlife.Attention will
be given to this question during impact assessment
refinement.However,it should be noted that changes in
-------,---------"---~------------
\.
RESPONSE TO COMMENT 1.293 (cont.):
facility siting may occur during the detailed engineering
design phase,and that more detailed con~ideration will be
given to the development of a comprehensive restoration plan
at that time (FERC License Application pages E-3-279 through
E-3-281).As detailed engineering design proceeds,a more
precise picture of the probable value of rehabilitated areas
to wildlife will evolve.
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).
ADF&G,Susitna Hydroelectric Project,Phase II Progress
Report -Big Game Studies (1983),previously submitted to
the FERC on May 31,1983.
Miller,S.,Volume VI,Black and Brown Bear (1983).
COMMENT 1.294:
IlPage E-3-356:(17):Please refer to our previous comments
on access road borrow areas (Section 3.4.2(a)[i])."
RESPONSE:
It appears that the page number listed above,FERC License
Application page E-3-356,should be E-3-256.For an answer
to that Comment,please see the Response to Comment 1.386.
COMMENT 1.295:
"Page E-3-537:(18):Development of the beaver model will
not,'•••mitigate for residual impacts on furbearers.'Use
of the model will provide information for developing and
implementing mitigative flow releases or other habitat
manipulations.II
~-
RESPONSE TO COMMENT I.295:
It is the Power Authority's opinion that the development of
state-of-the-art predictive models,that will have
application for studying or assessing impacts to other
populations,will have at least some inherent mitigation
value.
COMMENT I.296:
"Page E-3-527:(19l:Please refer to our previous comments
on the unproven nature of slough modification for beaver
(Section 4.3.1(i)[ii]).The text should indicate which
sloughs are to be managed for beaver and which for salmon
and then define exactly what is meant by '...slough
enhancement measures.'Existing beaver populations in all
sloughs should be assessed.Coordination betweeen 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.1I
RESPONSE:
Please refer to the Response to Comment I.198.We agree
that coordination between aquatic and furbearer
investigators should take place and will ensure that it will
take place during mitigation plan refinement.
COMMENT I.297:
"Pages E-3-537 through E-3-539:(20)and (21):Please refer
to Section 4.3.1(n).11
RESPONSE:
Please refer to the Response to Comment I.210.
COMMENT I.298:
"Pages E-3-540 through £·-3-544:(cl Residual Impacts:While
this section generally identifies additional mitigation
needs,it lacks any procedures or mechanisms for
implementing mitigation measures.There is no
quantification to statements that most impacts will be
mitigated -primarily though increasing moose browse.The
---------'""--------~.
COMMENT 1.298 (cont.):
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 mitigation plan on
increasing moose browse.The benefits of such measures will
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 Mitigation Plan are aimed
primarily 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-of-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 FWS's Mitigation
Policy (see Section 4.1.3)."
RESPONSE:
Please refer to the Responses to Comments C.82,C.88,F.SO,
F.Sl and F.S2 for discussions of issues raised in this
Comment.In addition,because impact assessment and
Mitigation Plan refinement are continuing processes,the
specific Comments expressed here will be considered during
future refinement efforts~
Please note that the u.S.Fish and Wildlife Service project
area Resource Category Determination was not received by the
Power Authority in time for it to be addressed by the
Mitigation Plan presented in the FERC License Application
(see FERC License Application,Volume lOA,Chapter 11,
Appendix EllE,FWS letter to APA dated January 1983 and APA
response letter to FWS dated February 1983).
COMMENT 1.299:
"Page E-3-54l:(iv)Brown Bears:The losses of food
resources are viewed as the most significant project impact.
3W-IO/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
QIiiibSW U
~I
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COMMENT 1.299 (cont.):
potentially negative nature of project impacts (see
Section 4.4.1(a)(ii),page E-3-S11,and
Section 4.4.2 (b)(16),paragraph 2,page E-3-S36).II
"3W-IO/See Footnote 3W-S.[Footnote 3W-S/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.]II
RESPONSE:
The Power Authority does not believe that losses of food
resources will constitute the most significant potential
impact of the Susitna Hydroelectric Project on brown bears.
As discussed on FERC License Application pages E-3-420
through E-3-426,loss of spring feeding areas and direct
mortality resulting from bear/human interactions and in-
creased hunting pressure will constitute the most severe
impacts to brown bears in the project area.For example,it
is stated on FERC License Application page E-3-421 that:
liThe two major impacts of the project on brown bears
during the construction phase will be the loss of
spring feeding areas during and after clearing,and
direct mortality of bears resulting from bear/human
conflicts at camps,construction sites and bear
concentration areas.Unregulated hunting by
construction workers would also have a major impact on
brown bears during this period."
The point raised QY the reviewer is extensively discussed in
this section.For example,on FERC License Application page
E-3-423 it is stated that:
"Brown bears have one of the lowest reproductive rates
of any land mammal in North America (Bunnel and Tait
1978)..This,coupled with the low densities of brown
bears in most parts of their range,makes the impact of
sustained high levels of mortality particularly severe
(Craighead et al.1974)."
It is further pointed out on FERC License Application page
E-3-423 that:
"Human activities related to the Trans-Alaska pipeline
project (TAPS)resulted in a minimum of 11 brown bear
--..__._._._--~._-~~--_...._.--,---------------"-~--------_._------------
RESPONSE TO COMMENT I.299 (cont.):
and 30 black bear deaths (JFWAT files).·One of the
most serious problems encountered during TAPS
construction resulted from the attraction of bears to
areas of human activity."
On FERC License Application page E-3-425,it is stated that:
liThe loss of habitat as a result of the impoundment
clearing and filling and the partial avoidance of
project facilities will have the greatest impact on
brown bears during the filling and operation phases.
Indirect effects of decreased moose populations and
increased hunting by people will also have measurable
effects on brown bears.There is also some potential
for the impoundment to interfere with bear movements,
particularly during the spring."
The point here is that during project operation,when
construction personnel and activities are no longer present,
loss of habitat is likely to become a more important adverse
factor in regulating population size and productivity of
brown bears in the project area.On balance,it can be
concluded that both habitat loss and direct mortality
resulting from bear/human interaction (including increased
hunting pressure)will produce significant impacts on brown
bears in the project area.
We concur that it has not been conclusively demonstrated
that burning increases berry production in Interior or
South-Central Alaska.However,as cited on FERC License
Application page E-3-527,the recent study by Friedman
(1981)in Interior Alaska did demonstrate increased berry
production following burning.The efficacy of various
measures to increase browse and berry production in northern
regions is currently being reviewed during mitigation plan
refinement.
We agree that reductions in populations of brown bears would
not necessarily improve recruitment to caribou populations
within the project area.The evidence on this point is far
more conclusive with regard to moose (e.g.,Ballard,et ale
1981).Of course,it is not clear that reductions in
predation by bears would necessarily increase the
f5i$;',
~I
....
RESPONSE TO COMMENT I.299 (~ont.):
recruitment rate to moose populations to an extent
sufficient to offset other advers~impacts.
REFERENCES
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).
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).
ADF&G,Susitna Hydroelectric Project,Phase I Final Report -
Big Game Studies (1982),previously submitted to the FERC on
~lay 31,1983.
Miller,S.D.and D.C.McAllister,Volume VI,Black
Bear and Brown Bear (1982).
-------...;,.....---_.
..-,
-
COMMENT I.300:
"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."
RESPONSE:
For several raptor species (e.g.,golden eagles,
rough-legged hawk,gyrfalcon),foraging areas are largely in
higher elevation habitats that will not be flooded by the
impoundments and will not receive extensive human
disturbance.For these species,mitigation bf nest site
losses by establishment of new nest sites (and possibly
moving of some nests)will probably wholly compensate for
project impacts.Disturbance of nesting raptors remains the
major concern during project construction and operation,
although efforts at minimizing human disturbance to raptors
along the Trans-Alaska Pipeline System have proved
successful in recent years,and similar efforts are planned
for the Susitna Hydroelectric Project.
As stated in FERC License Application Exhibit E,Appendix
E3I,"raptors are one of the few groups of birds that are
limited by availability of nesting locations and nest sites
in most regions,rather than food .•••"Foraging areas for
bald eagles,goshawks and some other smaller raptors would
likely be available after project completion (see FERC
License Application pages E-3-442 through E-3-454),provided
nesting locations are established·to mitigate for nests lost
due to flooding.While cumulative impacts may cause
displacement of some raptor species,attempts at nest site
enhancement outside of the impoundment zones should
compensate for most losses,particularly for bald eagles
which have historically responded favorably to artificial
nesting sites (see FERC License Application Exhibit E,
Appendix E3I).
COMMENT I.301:
"Pages E-3-544 through E-3-545:Cost Analysis and
Scheduling:To provide for unforseen contingencies,we
recommend that a trust fund be established at the start of
license construction.Unspent monies would revert to the
project sponsor at the end of the license period.
COMMENT 1.301 (cont.):
lilt should not be assumed that appropriate habitat
management lands will be available through the State or
Federal government.The applicant should initiate'
discussions with resource and land management agencies as
soon as possible to identify potential management lands.1I
RESPONSE:
A.
B.
The Power Authority does not anticipate establishing
any special trust funds.The commentor is apparently
concerned about the solvency of the applicant.Such a
concern is inappropriate in this case since the
applicant is the State of Alaska.
The Comment also reflects a concern that the applicant
would not commit sufficient resources to mitigation
measures or environmental enhancement.This concern is
also misplaced.As a state agency,the Power Authority
has a duty to act in the overall public interest of the
state's citizens.This would necessitate due concern
for the environmental,as well as power,benefits of
the Susitna River.Also,the cost of environmental
programs will be determined in the same manner as any
other cost and included in either construction or
operating costs.These costs are viewed as a normal
part of project costs.
The Power Authority has determined that more than
sufficient habitat-management lands in state ownership
are available.Proposed land use designations are
compatible with proposed management activities.See
the Responses to Comments A.17,1.80 and 1.279.
~,
COMMENT 1.302:
"Page E-3-548:While we support monitoring,as well as
plans to consult with the resource agencies,we believe that
an interagency team should be established to oversee
monitoring with some follow-up through project operation and
maintenance.II
RESPONSE:
See the Responses to Comments I.119B and 1.147.
-
,JllS'lIISil
.....
COMMENT I.303:
"Pages E-3-549 through E-3-550:Transmission Corridor
Recommendations:Access could be beter controlled by signs,
zoning (to prohibit off-road vehicle use),monitoring,and
enforcing of fines."
RESPONSE:
Allowing or restricting public use of transmission corridors
will be determined by a number of factors,such as:mode of
use,(motorized or pedestrian),conditions of granting the
right-of-way,preference of adjacent landowners,
environmental considerations and public interest.
Methods for controlling access along the transmission line
and establishment of monitoring and enforcement procedures
will be examined and their effectiveness will be determined.
Actual locations in which access should be restricted will
also be identified.
Issues regarding access will be addressed as the necessary
implementing agreements are procured.Various approaches
for restricting access and managing public use of areas will
be developed in consultation with appropriate agencies,
landowners and land managers.These will be identified in
the construction access plan developed for the transmission
line.
COMMENT I.304:
"Table E.3.87:Problems with the comparison of aerial
habitat with ViereQk and Dyrness 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 the table title."
RESPONSE:
Table E.3.87:Problems with correlation of aerial habitat
with Viereck and Dyrness vegetation classifications are
noted in the text where this table is cited (on FERC License
Application,page E-3-304)and do not need to be renoted
here •
RESPONSE TO COMMENT 1.304 (cont.):
Table E.3.92:Qualifications regarding these data are
discussed in the text (on FERC License Application,
pages E-3-318 through E-3-321)and Appendix EH of the FERC
License Application,both of which are referred to in the
table for an explanation of the methods used.
COMMENT 1.305:
"Table E.3.l44:This table is a useful,preliminary
assessment of overall project impacts.However,we have
identified the following errors:
"1.Permanent Habitat Loss:
"According 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 applicant should clarify how
borrow sites included here correlate with figures given in
Table E.3.85 and the discussion in the text which states
that use of borrow 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
inconsistent with the70ha village (8ha of which is a lake)
listed in Table E.3.83.We find no description in the text
or drawing in Plates F70 or F7l of a 9 ha airstrip for the
Devil Canyon development..
"2.Habitat 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 village and temporary camp given here do not agree
with figures given in Table E.3.84.The 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 E.3.80.
"Potential alterations in ice staging,scouring,etc.are
further impact mechanisms which will result from hydrologic
alterations.
"3.Barriers,Impediments,or Hazards to Movement:
"The permanency of these features should be mentioned.
-
-
-
COMMENT 1.305 (cont.):
"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."
RESPONSE:
Many of the inconsistencies and errors in the referenced
tables and text,as well as other errors,were corrected and
presented in the Response to Supplemental Information
Request 3B-7 (see Reference 1.370.1 in the February IS,1984
A~A Response Document,Reference Volume).Additional
inconsistencies and errors,some of which were pointed out
in this Comment and some of which were subsequently
discovered,have also been corrected~These corrections are
shown in Reference 1.370.2 in the February 15,1984 APA
Response Document,Reference Volume.These additional
revisions are primarily due to corrections in the
right-of-way requirements for several transmission line
segments.Other revisions were required due to mathematical
errors and oversights in Table E.3.144.Specific Responses
to this Comment follow:
1.Permanent Habitat Loss
A.
B.
Table E.3.83 and the first page of Table E.3.144
have been revised and are included in
Reference 1.370.2 (see February 15,1984 APA
Response Document,Reference Volume).As stated
in ..both revised tables,-the Watana Impoundment
Area is 14,691 ha.
For a discussion of the area calculated for the
Access Corridor and borrow areas,please refer to
the FERC License Application,page E-3-255 and
E-3-256.As stated in the License Application,
borrow areas which may be required for access road
construction will be sited immediately adjacent to
the route.As shown in Figure E.3.37,14 borrow
areas have been identified along the access route
from the Denali Highway to Devil Canyon.Access
routing has been refined to emphasize well-drained
soils which will allow maximum use of side-borrow
techniques in level terrain and balanced
RESPONSE TO COMMENT 1.305 (cont.):
cut-and-fill in sidehill cut areas
(Figure E.3.83).Therefore,the borrow areas
shown in Figure E.3.37 are not expected to be
fully excavated,as they will be used only to
augment material requirements where side-borrow or
balanced cut-and-fill techniques cannot be fully
utilized.In general,it is expected that each
site will be excavated at most to a depth of
8-feet (2.5m)and will range in area from less than 10
to no more than 20 acres (4 to 8 ha).
.'W!!1'l
C.
D.
E.
It is not clear what the reviewer's confusion is
concerning borrow site figures given in
Table E.3.144 and E.3.85,as the figures appear to
be consistent with the original tables in the
License Application.The figures given for the
Access Corridor include borrow sites for access in
both tables.However,these figures have since.
been revised based on supplemental information and
are now incorrect.The correct figures are
included in revised Tables E.3.144 and E.3.85
included in Reference I.370.2 (see February 15,
1984 APA Response Document,Reference Volume).
The clearing widths assumed are conservative
enough to include areas required for borrow.
The correct figures for a permanent and temporary
village can be found in revised Table E.3.144 and
page E.3.253,which are included as Reference
I.370.2 (see February 15,1984 APA Response Docu-
ment,Reference Volume).Revised Tables E.3.83
and E.3.84 break out the total figures as given in
revised page E.3.253 for the permanent and tempor-
ary villages and camps for Watana and Devil
Canyon,respectively.
As stated in the License Application in Volume GA,
Exhibit E,Chapter 3,page E.3.127,no airstrip
will be built;air access will be via the
permanent runway at Watana.Table E.3.l44 has
been corrected to reflect this.
-
-
2.Habitat Alteration and Temporary Habitat Loss
A.The figures given for impoundment clearing,
temporary village and temporary camp in revised
Table E.3.144 are consistent with the figures
-
RESPONSE TO COMMENT I.305 (cont.):
given in revised Tables E.3.83 and
E.3.84,included in Reference I.370.2
(see February 15,1984 APA Response
Document,Reference Volume)•
-
B.
C.
The figures given for the Transmission Corridor in
revised Table E.3.l44 are consistent with those
figures sited 'in Table E.3.80,which has been
revised and is included in Reference I.370.2 (see
February 15,1984 APA Response Document,Reference
Volume).As stated in revised Table E.3.80,the
Devil Canyon to Gold Creek segment will alter a
total of 202.9 ha,which is broken out into
194.4 ha and an additional 83.5 ha in revised
Table E.3.144.These figures are based on a cor-
ridor width of 300 feet and 210 feet,respective-
ly.
Impact mechanisms,including changes in ice
scouring,ice staging,and spring and summer
floods will affect the abundance of early
vegetational succession,such as riparian
vegetation types.This was intended to be
included in Item 4 of Table E.3.144.
3.We agree;all features listed in Table E.3.144 are
permanent features.
-.4.Construction activities will begin in approximately
1985,which is the time that increases in impacts and
increases in human access will occur.
-
-
.....
-
COMMENT I.306:
"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."
RESPONSE:
Proportionate losses of vegetation-cover type areas
expressed as percentages of arbitrarily defined geographical
areas are one possible measure of significance from a
----------------------------~._-------------
RESPONSE TO COMMENT I.306 (cont.):
biological standpoint.Please see the Response to Comment
F.45.
COMMENT I.307:
"Table E.3.148:Anticipated and Hypothesized Impacts to Dall
Sheep:(2)and (3):Borrow areas and roads in the vicinity
of Tsusena Creek are an additional potential impact.
"(5):Floatplane landings and on-ground disturbance from
recreational hikers and campers are an additional
recreational disturbance tb be considered."
RESPONSE:
Based on the data published to date (Ballard,et al.1982,
Tankersley 1983),it does not appear that borrow areas or
access roads will impact the movements or habitat of the
Portage-Tsusena Creek sheep population.Float plane
landings and on-ground disturbance from recreational hikers
and campers are sources of recreational disturbance which
could be listed separately,although they are implied by the
present descriptions of disturbance from air traffic and
boats,which are the two modes of access by recreationists
to the Jay Creek area.
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.B.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).
'~
-
-
COMNENT I.308:
IITableE.3.149:Anticipated and Hypothesized Impacts to
Brown Bear:(3):Roads have been found to affect movement
of bears and could inhibit crossings.3W-9/
11(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 area.1I
"3W-9/See Footnote 3W-3.[Footnote 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.]"
RESPONSE:
The Power Authority agrees with the reviewer1s comments that
roads,construction activities and the impoundment areas
themselves may affect bear movements.These impact mecha-
nisms are discussed on FERC License Application pages
E-3-420 through E-3-429,E-3-483 and E-3-484,as well as
other places in the FERC License Application.
COMMENT I.309:
"Table E.3.150:Anticipated and Hypothesized Impacts to
Black Bear:Please refer to our comments under Table
E.3.146 about misleading 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.
COMMENT I.309 (cont.):
Moreover,the even more limited areas of deciduous forest
may be the sites most preferred by black bears.3W-10/"
"3W-IO/See Footnote 3W-5.[Footnote 3W-S/.l-iiller
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.]II
RESPONSE:
Please refer to the Responses to Comments F.45.
COMMENT I.3l0:
-
"Table E.3.153:Anticipated and Hypothesized Impacts to
Aquatic Furbearers (beaver and muskrat):(1):The text ~~
should indicate the source for numbers of muskrats estimated
in the impoundment area.
"(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 quantified nor spacially identified in coordination
with fish mitigation plans."
~SPONSE:
1.
2.
As indicated in FERC License Application Section
4.3.1(j),paragraph 2,the number of muskrat affected
by the Watana impoundment was extrapolated from aerial
survey data of muskrat pushups (lodges)in the
impoundment zone by Gipson et ale (1982).As stated in
the text,numbers of muskrats per pushup may be
variable.Therefore a range (5-10 muskrats affected)
is given to adjust for this variability.
Please refer to the Response to Comment I.171 for a
response to the first part of this Comment.Because
several beneficial impacts may accrue to beaver and
muskrat due to the project,enhancement of habitat for
negatively affected fish populations would likely take
higher precedence.Mitigation plans for both groups
~,
RESPONSE TO COl1MENT 1.310 (cont.):
will be coordinated as mitigation refinement efforts
supported by the Alaska Power Authority continue.
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)
COMMENT 1.311:
"Table E.3.157:Anticipated and Hypothesized Impacts to
Marten,Weasel,and Lynx:(1)and (2):Please refer to our
previous comments on problems in quantifying marten losses
(Section 4.3.1[m]).Figures 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 commented on Table E.3.150,
figures for proportions of conifer forest to be lost are
misleading."
RESPONSE:
Please refer to the Responses to Comments 1.203 and 1.243
concerning problems in quantifying marten losses.
Figures for area of forest habitat to be reclaimed (listed
under (2)Habitat Alteration and Temporary Habitat Loss)in
FERC License Application Table E.3.157 are incorrect,and
should read as follows:
Watana:
,.".
o
o
980 ha of total forest.This includes 770 ha of spruce
forests,67 ha of closed conifer-deciduous,5 ha of
closed birch and 138 ha of open conifer-deciduous.
Devil Canyon:.
194 ha of total forest.This includes 11 ha of spruce
forests and 183 ha of closed conifer-deciduous.
,......-----~-------~------
COMMENT 1.312:
IITable E.3.159:Anticipated and Hypothesized Impacts to
Raptors and Ravens:(1):The text should indicate whether
destruction of the bald eagle nest in Deadman Creek will be
avoided by access road rerouting shown in Figure E.3.812.
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 considering the length of
time those areas would have been out of production during
construction.II
RESPONSE:
1.
2.
Please refer to the Response to Comment 1.224.The
Golden Eagle nesting location at Borrow Area E may not
be destroyed,depending on the final configuration of
this borrow site.Provision of an alternate nesting
site should be attempted in any case,should
disturbance due to borrow site activities cause
abandonment of the nesting location.The text of FERC
License Application Table E.3.159(2)should be
corrected to read:IIA Golden Eagle nesting location
may be destroyed by Borrow Area E.1t
This benefit (increased availability of small mammal
prey)will occur,although maximum benefits will not
accrue until several years following construction.
Some use of reclaimed lands by small mammals will
probably occur even during the year of reclamation,
because annual plants,the first groups to recolonize
the site,are favored forage of many small rodent
species.
~I
COMMENT 1.313:
"Tables E.J.1?1 through E.3.1?5:Estimated l-'litigation Costs:
Costs for follow-up monitoring to evaluate the effectiveness
of the recommended programs should be included.Provisions
for funding additional measures,should initial mitigation
prove ineffective,should also be included."
RESPONSE:
Detailed cost estimates for the mitigation and monitoring
programs described in FERC License Application Exhibit E,
~,
-
-
RESPONSE TO CO~rnNT 1.313 (cont.):
Chapter 3,Sections 3.4 and 4.4 will be developed during
mitigation plan refinement.A general estimate of
monitoring costs is included in the project capital costs
presented in FERC License Application Exhibit D.The
mitigation plan refinement program will include provisions
for the funding of additional measures which may be
determined to be required as a result of information gained
during monitoring.
COMMENT 1.314:
"Table E.3.178:Wildlife Mitigation Summary:Estimated
costs for Monitoring Study 2 and Mitigation Plans 6 and 21
should be included in project capital costs,as should costs
of any other mitigation necessary because of the project."
RESPONSE:
The reviewer's Comment has been noted.Please refer to the
Response to Comment 1.313.
COMMENT 1.315:
"Page E-3-191:3.1 -Introduction:Paragraph 1:It is our
understanding the downstream study area extended only to the
Deshka River,not all the way to Cook Inlet.3B-1/"
"3B-1/McKendrick,J.W.Collins,D.Helm,J.McMullen and
J.Koranda.1982.Susitna Hydroelectric Project,Phase 1
Final Report,Environmental Studies,c Subtask 7.12:Plant
Ecology Studies.University of Alaska Agricultural
Experiment Station,Palmer.Prepared for the APA."
RESPONSE:
The Power Authority assumes this Comment refers to
Paragraph 2 of the referenced FERC License Application
Introduction rather than Paragraph 1 as indicated.
Paragraph 1 does not refer to a study area.The study area
described in Paragraph 2,which included "a corridor
extending approximately 1 mile (1.6 km)to each side of the
downstream floodplain between Gold Creek and Cook Inlet,"
represents the general study area "designated for botanical
resources and wildlife of the Susitna Hydroelectric
Ml ' 4
RESPONSE TO COMMENT 1.315 (cont.):
Project.It This study area is addressed in FERC License
Application Sections 3 and 4.The reference is not intended
to represent the study area used by a specific study (i.e.,
McKendrick,et ale (1982)as cited in this Comment).
COMMENT 1.316:
"Page E-3-193:(a)General:Last Paragraph:Floristic
surveys were not comple"ted in 1983 as described here and
under (c)Summary,page E-3-198.A current schedule of when
the surveys will be conducted,and when the information will
be distributed,should be provided by the applicant.1t
RESPONSE:
The Power Authority anticipates that the DEIS will evaluate
the adequacy of the existing floristic data base.However,
as indicated by the USFWS in Comment 1.318,it is felt that
the likelihood of finding threatened or endangered plant
species in the transmission corridors is very low.
COMMENT 1.317:
"Page E-3-195:3.1.3 -Contribution to Wildlife,Recreation,
Subsistence,and Commerce:More specific information on
different wildlife species'uses of various vegetation
communities throughout the project area should be included
in this section."
RESPONSE:
Specific information on wildlife uses of the various
vegetation types that occur within the project area is
presented in FERC License Application Exhibit E,Chapter 3,
Section 4 (Wildlife).See also Responses to Comments C.83,
C.84, C.96,F.41,F.44 and F.45.
COMMENT 1.318:
"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 species.Although the
-
I~
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~,
COMMENT 1.318 (cont.):
proposed surveys for candidate endangered plants were not
done in 1983,it is felt that the likelihood of finding
these species in those areas is very low."
RESPONSE:
Thirty-three plant taxa are presently under review as
candidate threatened or endangered species as compared to
the 37 that were listed in the cited 1980 report.The Power
Authority appreciates this updated information and agrees
that the probability of any candidate threatened or
endangered plant species occurring along the
Healy-to-Fairbanks and Willow-to-Anchorage transmission
corridors is very low.
COMMENT 1.319:
"Page E-3-196:(a)Watana and Gold Creek Watersheds:The
word "candidate"should be added before "endangered plant
taxa"in the last sentence on the page."
RESPONSE:
We agree.
COMMENT 1.320:
"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
comments on all of Section 3.2.2 (e)and Tables E.3.79 and
E.3.86.Please see our more detailed comments under
Wetlands,Section 3.2.3,regarding the inaccuracies of
typing wetlands solely from a vegetation-type map.1I
RESPONSE:
As stated on page E-3-191 of the FERC License Applicaton,
vegetation was mapped in "corridors approximately 5 miles
(8km)in width encompassing the transmission routes from
Healy to Fairbanks and Willow to Anchorage."Results of
these studies are shown in Tables E.3.77 and E.3.78 of the
PERC License Application respectively.
_____,~__.._=--------'---~_G~-~-.-.=="'F'f,..,,..------
RESPONSE TO COMMENT 1.320 (cont.):
The second half of the Comment references other Comments on
Chapter 3 of the FERC License Application.For specific
RESPONSE TO COMMENT 1.320 (cont.):
discussions of these aspects,please refer to the following
Responses:
Section 3.2.2(e)
Table E.3.79
Table E.3.86
Section 3.2.3
See Response to Comment 1.327
See Response to Comments 1.415 &
1.370
See Response to Comments 1.419 &
1.370
See Response to Comment 1.330
COMMENT 1.321:
"Page E-3-199:Cal Methods:Paragraph 3:The 1982 browse
inventory,plant phenology,and Alphabet Hills pre-burn
inventory and assessment studies should be briefly
described."
RESPONSE:
The cited studies are described in a report by Steigers,et
ale (1983).This report is referenced below.
REFERENCES
ADF&G,Susitna Hydroelectric Project,Subta~k 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 (1982).
COMMENT 1.322:
"Page E-3-201:Ca)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
.-
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COMMENT 1.322 (cont.):
forests and Level IV for other types.3B-2/Wetlands should
be mapped directly from aerial photographs,and incorporate
soils and drainage characteristics,according to Cowardin et
al.(please also see our Comments on Section 3.2.3).3B-3/.
The application should be updated to include current 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 CO~~ENT
I .322 (cont • ) :
considerations.The preliminary mapping scheduled for
completion by June 30,1983 was not accomplished.1I
113B-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
Vegetation:77 pp.1I
113B-3/Cowardin,L.r-L,V.Carter,F.C.Golet and E.T.Laroe.
1979:Classification of Wetlands and Deep Water Habitats of
the United States.Publication FWS/OBS-79-31.U.S.FWS.l1
RESPONSE:
We acknowledge Department of Interior support for Power
Authority activities to map vegetation and wetlands.The
technical recommendations for mapping have been noted.
The Power Authority anticipates that the DEIS will
reasonably analyze vegetation and wetlands and will
incorporate prior studies of vegetation and wetlands.
COMMENT 1.323:
"Page E-3-204:(b)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 planning efforts."
_.-..--.-._.~_~m==_..__,.-...,-W"4I'i""""'="_.F_----_
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RESPONSE TO COMMENT 1.323:
The requested information is provided in the Wildlife
Baseline and Impact Discussions (FERC License Application
pages E-3-296 through E-3-S08).As stated in Section 3.1
(FERC License Application page E-3-191),
"[T]he primary importance of botanical resources within
the project area is their key role as components of
wildlife habitat.The following discussions have been
coordinated closely with baseline descriptions,impact
assessments,and mitigative measures presented in
Section 4 (Wildlife),and formed an important basis for
that section."
~,
Thus the Botanical Resources,Baseline Impact and Mitigation
sections were written to prepare the reader for the
discussions of species habitat relationships which follow in
the Wildlife discussions.However,the Botanical Resources -
section discusses botanical resources in themselves and not
as wildlife habitat.
COMMENT 1.324:
"Page E-3-21l:(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."
RESPONSE:
~,
Please refer to the Response to Comment 1.323.In FERC
License Application Exhibit E,Chapter 3,Section 4,
vegetation types are extensively discu~sed in relation to
the wildlife species which utilize them.The plant species
discussed on FERC License Application pages E-3-21l and
E-3-2l2,and shown in Table E.3.70,are all associated with
a single wetland class:lakes and ponds.In the USFWS
wetland classification system of Cowardin,et ale (1979),
lakes and ponds of the project area comprise lacustrine and
palustrine wetlands.Wetlands are discussed in greater
-
...
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RESPONSE TO CO~mENT 1.324 (cont.):
detail on FERC License Application pages E-3-220 through
E-3-222.
REFERENCES
Cowardin,L.M.,V.Carter,F.C.Golet and E.T.LaRoe,
Classification of Wetlands and Deep Water Habitats of the
United States,Office of Biological Services,U.S.Fish and
Wildlife Service,Publication FWS/OBS-79-31 (1979).
-
COMMENT 1.325:
"Page E-3-214:(c)Devil Canyon to Talkeetna:A comparison
should be made of:(1)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."
RESPONSE:
--
..-
I
In response to the first part of the Comment,a table
providing a comparison between lower Susitna River
successional stages and the Viereck and Dyrness (1980)
vegetation classification system (which was used to classify
the upper and middle Susitna River Basins)is attached.
In response to the second part of the Comment,the following
discussion is provided:
Wetlands have been mapped along much of the lower Susitna
River by the u.s.Fish &Wildlife Service under the National
Wetlands'Industry using the Cowardin,et al.(1979)system •
On these maps,riparian areas dominated by alder and willow
are classified as palustrine forested wetlands depending on
plant height.About two-thirds or more of the vegetated
floodplain represents riparian wetland vegetation given that
spruce-birch,which is most likely not wetland,covers about
one-third or less of the vegetated floodplain (see FERC
License Application page E-3-216).
......,---_....,.....__.__...--~------------~-------------
RESPONSE TO COMMENT 1.325 (cont.):
COMPARISON OF LOWER SUSITNA RIVER
SUCCESSIONAL STAGES WITH THE
VIERECK &DYRNESS(l980)VEGETATION
CLASSIFICATION SYSTEM
Viereck and Dyrness (1980)*Classification
Lower River Successional Stage
(1)Early Successional Stands
-young willow,alder,
balsam poplar saplings
(2)Mid-Successional Stands
-mature willow,
mature alder,
young balsam poplar trees
(3)Late Successional Stands
-mature balsam poplar trees,
white spruce,paper birch
Level III
Closed tall shrub
Open tall shrub
Closed tall shrub
Open tall shrub
Closed deciduous
forest
Closed deciduous
forest
Closed mixed con-
ifer and deciduous
forest
Level IV
willow
alder-willow
willow
alder-willow
willow
alder
alder-willow
willow
alder-willow
balsam poplar
balsam poplar
spruce-birch
poplar-spruce
~,
*Viereck,L.A.,and C.T.Dyrness,A Preliminary System For
Vegetation of Alaska (1980),U.S.Forest Service Pacific Northwest
Forest &Range Experiment Station,Gen.Tech.Rep.FNW-106.
REFERENCES
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).
Viereck,L.A.and C.T.Dyrness,A Preliminary
Classification System for Vegetation of Alaska (1980).
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COMMENT 1.326:
"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.2.49 in
Chapter 2 documents an expected doubling of mean flows at
the Susitna Station (RM 26.0)from December through March
with project operation)."
RESPONSE:
As stated on FERC License Application page E-3-191,unless
cited otherwise,descriptions of vegetation are taken from
McKendrick,et al.(1982).In the report ~ited,these
investigators noted that,judging from average age and
successional stage of riparian vegetation,islands and river
bars downstream from Talkeetna were apparently more stable
than those between Talkeetna and Devil Canyon.Although it
was not greatly emphasized,this point was attributed to the
probable greater severity of ice jam damage and flooding in
the narrower floodplain upstream from Talkeetna.
Considerable discussion of riparian succession along the
downstream floodplain occurred during the Susitna
Hydroelectric Project Terrestrial Environmental Workshop
held in February and March 1983.Geomorphological cross
sections already prepared could be used for long-term
monitoring of vegetation changes along the downstream
floodplain.
REFERENCES
ADF&G,Susitna Hydroelectric Project,Phase I Final Report,
Environmental Studies,Subtask 7.12:Plant Ecology Studies
(1982)•
McKendrick,J.,W.Collins,D.Helms,J.McMullen and
J.Koranda report (1982).
COMMENT 1.327:
~Page E-3-2.7:(e)Transmission Corridors:The applicant's
response to our comments 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 Levell of Verreck et al.(Chapter 11,W-3-112).
Different map scales and corridor widths prevent a
comparison or cumulative assessment of vegetation types to
be impacted by the four transmission corridor segments.
"(We have previously commented 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.
You1d,APA)."
RESPONSE:
Vegetation types occurring within the Watana-to-Go1d Creek,
Healy-to-Fairbanks,and Wil10w-to-Anchorage transmission
·corridors cannot be correlated with vegetation types mapped
within the Intertie transmission corridor beyond Level I or
II of Viereck,et a1.(1982).While it would be preferable
to map all corridor segments in accordance with the same
vegetation classification system,we do not believe that
this is necessary to allow cumulative impact assessment.
REFERENCES
Viereck,L.A.,T.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).
COMMENT I.328:
"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 ale This
would allow an assessment of cumulative transmission line
impacts and mitigation needs."
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RESPONSE TO COMMENT 1.328:
Please refer to the Response to Comment 1.327.Vegetation
maps of the intertie corridor,presented at a scale of
1:250,000 in a Commonwealth Associates,Inc.(1982)report,
were adapted from a map previously prepared by the Joint
Federal-State Land Use Planning Commission for Alaska
(1973).These maps are presented in the Commonwealth
Associates report in Figures 14a-d on pages 101-108.Those
figures note that additional sources for the vegetation
mapping were 1"=3000'color infrared U-2 photographs taken
in 1977 by NASA (unreferenced)and field investigations made
by Commonwealth Associates in 1981.
REFERENCES
Commonwealth Associates,Inc.,Environmental Assessment
Report,Anchorage-Fairbanks Transmission Intertie (1982).
Joint Federal-State Land Use Planning Commission for Alaska,
Major Ecosystems of Alaska,Map (1973),previously submitted
to the FERC on July 11,1983.
COMMENT 1.329:
"Page E-3-220:(iv)Darns to 1ntertie:Figures E.3.39 and
E.3.40,showing vegetation types crossed by this
transmission corridor segment and other project facilities,
are unreadable due to reduction for publication."
RESPONSE:
FERC License Application Figures E.3.39 and E.3.40 were
transmitted to the FERC at their original size (30"X 36")
as Supplemental Attachments 10-14-1 and 10-14-2 in the
July 11,1983 filing of supplemental information request
responses.Interested parties may obtain at cost full size
copies of these figures by requesting them from the Alaska
Power Authority.
COMMENT 1.330:
"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 E.3.70 were stereoscopically
----_._--.--------------
COMMENT 1.330 (cont.):
examined.The FWS found wetland and non-wetland areas were
inaccurately distinguished.Large areas of upland are
included in the map units 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 involves 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.Wetland
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 ale
(1979)system 3B-4/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 recommend 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.n
"3B-4/See Footnote 3B-3.[Footnote 3B-3/Cowardin,L.M.,
V.Carter,F.C.Golet and E.T.LaRoe.1979.Classification
of Wetlands and Deep Water Habitats of the United States.
Publication FWS/OBS-79-31.u.S.FWS.]
"Office of Environment,Office of the Federal Inspector.
1981.Revegetation Philosophy for the Proposed Gasline.
June 26,1981.Anchorage,Alaska.3 page mimeo.
"Kubanis,S.A.1982.Revegetation 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.n
RESPONSE:
The FERC License Application recognized the extent of the
available wetland maps (see pages E-3-222,E-3-223,E-3-224
and E-3-245).The Power Authority anticipates that the DEIS
will analyze the adequacy of existing maps and will describe
affected wetlands in reasonable detail..
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i...•
COMMENT 1.331:
"Page 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
clarification.It implies that wetland types that do not
have standing water,but nevertheless exhibit saturated soil
conditions .throughout the growing season,are not addressed
in the discussions.These saturated wetlands include many
of the bog,floating-mat,and muskeg type wetlands in the
project area.Since some of these types are of concern to
the FWS,and since the U.S.Army Corps of Engineers (CE)
extends permit authority to many of these wetlands,they
should be included in mitigation and impact discussions.1I
RESPONSE:
The portion of the text cited is not meant to imply that
wetland types that do not have standing water,but
nevertheless exhibit saturated soil conditions,are not
addressed in the discussions.The sentence in question
(FERC License Application page E-3-221,Paragraph 4)should
be amended to read as follows:
"In discussions of impacts and mitigation involving
wetlands in general,the term is used to denote.areas
at least partly characterized by hydrophylic vegetation
and the presence of standing water or sheet flows."
It should be noted that in the two paragraphs immediately
preceding the sentence in question,wetlands are
specifically defined both from the standpoint of Cowardin,
et al.(1979)and U.S.Army Corps of Engineers regulations
promulgated under Section 404 of the Clean Water Act
(33 C.F.R.§§320-330).Bog or muskeg type wetlands
referred to by the reviewer are included in the discussions
and mapping of wetlands contained in FERC License
Application Exhibit E (Chapter 3,Section 3.2.3i
Figures E.3.45 through E.3.47 and E.3.66 through E.3.73).
REFERENCES
Cowardin,L.Mo,V.Carter,F.C.Golet,E.r.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).
-----------------,..-__._----------~-,-----~----
COMMENT 1.332:
"Pages E-3-221 and 222:3.2.3:(a)Methods:Table E.3.81
attempts to display Viereck and Dyrness (1980)types which
are interchangeable with Cowardin et ale (1979)system
wetland types.The table points out several major problems.
Enough information is presented in most of the Viereck and
Dyrness (1980)vegetation types to allow for more detailed
classification in the Cowardin et ale (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 scrub-shrub,not just
Palustrine scrub-shrub.In addition,field data gathered
during the initial vegetation mapping phase probably could
provide enough information to add water regime modifiers to
some of the Cowardin et ale (1979)wetland types.Open
black spruce in wetland situations 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 Dyrness (1980)vegetation types that
appear in Table E.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 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,'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 (1980)vegetation types has to be
done on the original aerial photography that was used to map
the vegetation.Preferably this should 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
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COMMENT I.332 (cont.):
polygons containing the modifying code would be transferred.
The Viereck and Dyrness (1980)classification would then be
converted to the appropriate wetland classification.1I
RESPONSE:
The Power Authority concurs with the reviewer's Cowment that
enough information is presented in most of the Viereck and
Dyrness (1980)vegetation types to allow for more detailed
classification in the Cowardin,et ale (1979)wetland
categories.However,at the time the vegetation mapping was
prepared,correlation was made to the level of detail shown
in FERC License Application Table E.3.81.On FERC License
Application page E-3-222,it is also stated that:
IIBecause the system of Cowardin et ale (1979)requires
additional data on hydric soils and periodic ambient
water conditions to characterize wetlands completely,
the mapping is liberal and indicates areas which
potentially qualify as wetlands under that system.
Portions of these areas may be eliminated by further
considerations of soil and water conditions."
REFERENCES
Viereck,L.A.,T.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).
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).
COMMENT I.333:
IIPage E-3-222:(a)Methods:Paragraph 3:The application
states that 'Because the system of Cowardin et ale (1979)
requires additional data on hydric soils and periodic
ambient water conditions to characterize wetlands
completely,the mapping is liberal and indicates areas which
potentially qualify as wetlands under than system.'This
implies that detailed soil and water permanancy data need to
be available if wetlands are to be mapped accurately using
the Cowardin et ale (1979).
COMMENT I.333 (cont.):
"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 ale (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 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 photo interpreter 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 recommends
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 ale (1979)system.Costs and time involved to perform
either method would be approximately the same.
"The FWS does not agree with the baseline report conclusion
that detailed wetland maps in the project area would be
extremely difficult to produce using standard
photointerpretation techniques.The primary reason for this
difficulty,according to the report,is the conclusion that
'wetlands are highly integrated with non-wetlands,'and
plant species composition in wet and non-wetland is similar,
differing only in the quantities of individuals.Analysis
of the high altitude aerial photography covering the project
area by FWS personnel indicates that detailed wetland maps
can be produced,and the wetlands can be accurately
classified to the subclass and water regime levels of the
Cowardin et ale (1979)classification system.Although
there are some wetland types that will initially be
difficult to distinguish from adjacent upland areas,a
moderate amount of ground truthing can provide the
photointerpreters with enough information to draw the
~,
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I
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COMMENT 1.333 (cont.):
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 could be displayed if the
wetland maps were produced at a scale of.1:63,360.
"We suggest that site-specific field confirmation of
wetlands 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.Support and preliminary
plans for such agency coordination were established at the
December 2,1982 wetlands meeting (please refer to notes
from APA's license application workshop included as
Appendix EIl.H to Chapter 11)."
RESPONSE:
Please refer to the Response to Comment 1.330.Also,the
Power Authority anticipate~that the DEIS will reasonably
analyze wetlands in the Project area.
COMMENT 1.334:
"Page E-3-223:(b)General Description:Discussion should
be provided on successional patterns and fire predominance
in wetland types.
"We question the wetlarids classification of mapped
vegetation types without use of other factors or field
verification.Please refer to our two previous comments."
RESPONSE:
Succession in riparian wetlands is discussed in
pages E-3-2l4 through E-3-2l7 of the License Application.
Palustrine ferested and palustrine shrub-scrub wetlands,
including sphagnum bogs,are subject to wildfire.Even
sedge-grass wetlands may burn when conditions are dry
enough.Large areas of all types of wetlands were burned in
the recent fire in Minto Lakes area west of Fairbanks;fires
ignited in wetlands in the Tanana Flats near Fairbanks
ignited peat in the wetlands and have smouldered for several
years;and during the very dry summer in 1977 wetland
tussock tundra on the North Slope burned.Wetlands
RESPONSE TO COMMENT 1&334 (cont&):
vegetation generally regenerates rapidly,with resprouting
of herbs and shrubs.
Please refer to the Responses to Comments 1.330 and 1.332.
Further analysis of wetland dynamics and impacts is b~ing
conducted during impact assessment refinement.
COMMENT 1.335:
"Page E-3-223:(b)General Description:Paragraph 2:It
should be indicated on wetland maps (Figures E.3.45 through
E.3.47,and E.3.66 through E.3.73)that the areas depicted
are potential wetlands."
RESPONSE:
The Power Authority agrees that these maps should have been
labelled as potential wetlands'maps.
COMMENT 1.336:
"Page E-3-225:(a)Construction:Other than the direct
vegetation losses due 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,·mel ting,etc.Several of those impacts can and
should be analyzed based on information in Chapter 6,
Geological and Soils Resources,and Figures E.6.3D through
E.6.45."
RESPONSE:
The area potentially affected by each type of slope failure
for each reservoir was estimated based on the information
presented in Chapter 6 of the FERC License Application
including Figures E.6.22 through E.6.45.This information
was provided in response to FERC Supplemental Information
Request 6-7.A breakdown and distribution of each slope
condition along both reservoirs is presented in Tables 3 and
4 of Supplemental Information Response 6-7.The estimates
include all areas potentially affected above the minimum
reservoir level and represent a worst case conditione A
worst case estimate of the area above the maximum reservoir
level (2,000 ft.)that would potentially be affected is
provided by the third column of Table 3 for Watana.The sum
"'"
~,
I~
RESPONSE TO COMMENT I.336 (cont.):
of the areas in this column is 851.3 hectares.In the case
of Devil Canyon,as indicated in Table 4,the area above the
maximum reservoir level that is susceptible to slope
instability is minimal due to the minimal fluctuation of the
reservoir level and a drawdown zone which is primarily in
contact with bedrock and/or low angle slopes.
"For a more detailed discussion of slope stability as i~
relates to the Watana and Devil Canyon reservoirs,see the
1980-1981 Geotechnical Report by Acres American,Volume 2,
Appendix K-Reservoir Slope Stability.See the Response to
Comment I.361 for further discussion of erosion and soil
losses following clearing.
As indicated on page E-3-285 of the License Application,
precise areal extents and elevation ranges of slope
stability effects cannot be reliably quantified in advance.
Supplemental Information Response 6-7 provides worst case
estimates and "reasonable estimates"of areas susceptible to
different erosion proceSses.Worst case or "reasonable
estimates"of the area of each vegetation type that occupies
location susceptible to each erosion type are also possible,
but these estimates would be even less precise than the
totals,and predictions of the changes in"vegetation cover
that would potentially occur in each situation would require
even further simplifying assumptions,making the value of
this analysis questionable.Nevertheless,methods for
deriving useful estimates of the areas impacted by erosional
processes (including those resulting from permafrost
thawing)will be considered during impact assessment
refinement efforts.
REFERENCES
Acres American,Inc.,Susitna Hydroelectric Project,
Task 2 -Survey and Site Facilities,Subtask 2.15 -Slope
Stability and Erosion Studies Closeout Report,Final Draft
(1982).
Acres American,Inc.,Geotechnical Report,Volume 2,
Appendix K -Reservoir Slope Stability (1980-1981).
Alaska Power Authority,Response to FERC Supplemental
Information Request 6-7 (1983),previously submitted to the
FERC on JUly 11,1983.
-,--_._--------------"------------
COMMENT I.337:
"Page E-3-225:(i)Vegetation removal:Paragraph 1:We
concur with intentions to confine spoil deposition to areas
within the impoundment or areas already disturbed.We
siggest that the potential size and locations of spoil areas
be mapped and quantified in the discussion and accompanying
tables."
RESPONSE:
Wherever practical,excess spoil will be deposited in the
defined areas within the impoundment or areas already
disturbed in accordance with criteria established by the
Power Authority and the Design Consultants in project
memoranda.These requirements will be stipulated in the
Project Construction Specifications that the contractors
will bid·on and the Erosion &Sediment Control Plan that
will be submitted by the construction contractor prior to
implementing his activities.All spoil disposal sites will
be identified and mapped during the detailed design phase of
project development.
COMMENT I.338:
"Page E-3-226 (ii)Vegetation Loss by Erosion:We recorrnnend
quantifying the permafrost and unstable slope areas mapped
in Chapter 6,Figures E.6.3D through E.6.45,by vegetation
type.Overlay maps of a readable size are necessary to
fully assess botanical 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."
RESPONSE:
Please refer to the Response to Comment I.336 concerning
quantification of vegetated areas potentially affected by
unstable slopes due to several causes including permafrost
thawing adjacent to the reservoir.
COMMENT I.339:
"Page E-3-226:(iii)Vegetation Damage by Wind and Dust:
Paragraph 1:We find it difficult to quantify the miles of
shoreline and the nearby area where blowdown of trees may
-
I~
COMMENT 1.339 (cont.):
occur.Tree blowdown 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."
RESPONSE:
The Power Authority also finds it difficult to quantify
areas where blowdown of trees may occur as a result of the
Project.
COMMENT 1.340:
"Page E-3-226:(iii)Vegetation Damage by Wind and Dust:
Paragraph 2:As above,we suggest that:(1)quantification
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 (3)correlation be made
with wildlife uses in those areas.".
RESPONSE:
Our current assessment indicates that reservoir clearing and
borrow pit development will not create significant dust
impacts outside of areas to be disturbed.Areas most likely
to be affected by dust accumulation are those areas within a
band SOm wide on each side of project roads (CRREL 1980).
Additional attention will be given to the evaluation of
vegetation impacts due to dust accumulations during impact
assessment refinement.
REFERENCES
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).
COMMENT I.341:
"Page E-3-227:(vii)Effects of Increased Fires:We concur
with this description and note that fires occuring near
populated areas will likely be repressed.Thus,the
potential for using prescribed burns to stimulate natural
successional patterns may be reduced."
_._w -----
Techni~ues in Arctic and
the Federal Inspector,
System,Office of
Anchorage,Alaska.
RESPONSE TO COMMENT 1.341:
Comment noted.
COMMENT 1.342:
"Page E-3-228 (b):Filling and Operation:Another impact
which should be fully assessed is the potential for
increases in fish mercury levels.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 3B-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."
"3B-4/See Footnote 3B-3.[Footnote 3B-3/Cowardin,L.M.,
V:-carter,F.C.Golet and E.T.LaRoe.1979.Classification
of Wetlands and Deep Water Habitats of the United States.
Publication FWS/OBS-79-31.u.S.FWS.
"Office of Environment,Office of the Federal Inspector.
1981 ..Revegetation Philosophy for the Proposed Gasline.
June 26,1981.Anchorage,Alaska.3 page mimeo.
"Kubanis,S.A.1982.Revegetation
Subarctic Environments.Office of
Alaska Natural Gas Transportation
Environment,Biological Programs.
40 pp.]"
RESPONSE:
Refer to the Response to Comment 1.41.
COMMENT 1.343:
"Page E-3-228:(i)Vegetation Succession Following Removal:
Natural plant succession may also be inhibited or precluded
following disturbance unless topsoil is restored and steps
taken to minimize erosion,changes in area drainage,etc.
fI1i'(lt:i,
~-
&w_
COMMENT I.343 (cont.):
"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 discussi6n has not bee~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."
RESPONSE:
The importance of topsoil replacement,erosion control and
drainage are recognized and discussed in the Mitigation Plan
(Section 3.4 of FERC License Application Exhibit E),which
is based in part on the restoration plans,analyses and
stipulations for the Alaska Natural Gas Transportation
System.Use of the construction methods recommended in the
FERC License Application for mitigating impacts to wetlands
will minimize removal of wetland vegetation except for any
gravel fill.In general,wet areas usually vegetate more
rapidly than drier areas.If wetland vegetation is removed
and/or the organic layer is compressed,the disturbed area
usually becomes wetter and may pond,and species composition
of vegetation may shift.For example,vehicle tracks in
Alaskan shrub wetlands often regenerate to sedges.Further
evaluation of wetland succession will be conducted during
impact assessment refinement.
COMMENT I.344:.
"Page 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-3-226)."
"_._-,..._---------------....-------------------.........-
RESPONSE TO COMMENT 1.344:
Impacts related to permafrost thawing will be related to
development of project features such as the dams,camps,
villages,borrow areas and access roads.Permafrost-related
impact areas associated with these features are included in
the areas tabulated for vegetation losses in Chapter 3 of
the License Application.Permafrost mapping is not
available for the project area in general and the reason for
quantifying the area of each vegetation type underlain by
permafrost outside of those areas affected by project
features is unclear.Further geotechnical studies during
detailed design will enable the identification of areas
where special construction methods will need to be used to
minimize permafrost degradation.
To the extent to which areal data on permafrost coverage of
the project area are available,they will be evaluated along
with vegetation data and the locations of project features.
Quantification of vegetation losses will be carried to the
extent feasible during impact asessment refinement efforts.
COMMENT 1.345:
"Page E-3-230:(ii)Effects of Erosion and Deposition:
Paragraph 2:Unstable slopes and permafrost areas are
mapped in Chapter 6.However,because there is no
interpretive description correlating those areas to
vegetation cover types,it is difficult to analyze potential
wildli fe impacts.We recomlnend such an analysis."
RESPONSE:
In order to assess "potential wildlife impacts,"the Power
Authority needs to know what kind of impact mechanisms are
being referred to by the comrnentor.
COMMENT 1.346:
"Page E-3-231 through E-3-235:(iii)Effects of Regulated
Flows:This discussion generally neglects consideration of
the potential range and frequency of daily flow fluctuations
in response to peak power needs.
"Several other potential project impacts relative to altered
downstream flows have not yet been clarified,particularly
wi th regard to wetlands and floodplains..These include
~,
.~
.....
COMMENT 1.346 (cont.):
impacts to floodplian areas which:(1)are now sUbject to
annual #5-year,10-year,etc.flooding,and (2)will become
exempt from flooding with project construction.Given'the
successional information depicted in Figure E.3.78 and
revised ,vegetation maps,it should be possible to quantify
expected changes in vegetation,over time,for a variety of
flow regimes.Such information is necessary to fully
determine project impacts to wildlife and to make mitigation
recommendations.
"We appreciate the thorough qualitative discussion of
project impacts throughout this section.Once the
recommended vegetation remapping is undertaken and analyzed
in conjunction with hydrologic information,the information
included here should be the basis for examining positive
and/or negative impacts to wildlife of potential vegetation
changes,over the life of the project.We recommend
quantifying the maximum and minimum areas which may become
available for the establishment of vegetation under
alternative icing scenarios."
RESPONSE:
The Department of the Interior and other agencies have
commented to the FERC regarding possible flow regimes,
project operation alternatives and their impacts {see
Comments B.2,B.3,B.4, B.5,B.?,B.64,B.65,C.8?,F.2,
F.3,F.10,F.II,F.25,F.39,1.5,1.24,1.25, 1.29,1.131,
1.133,1.149, 1.198, 1.201,1.236,1.558,1.560 and 1.562,
and the associated Power Authority Responses;see also FERC
License Application {pages E-2-104,E-2-55 to E-2-62 (Case C
target minimum flows»•
As indicated in the Responses to Comments'B.65,F.11 and
F.25,liThe Power Authority anticipates that the DEIS and
FEIS will analyze a full reasonable range of alternative
operating scenarios."These alternative operating scenarios
and their associated flow regimes could include base-load
operation,an alternative already identified and analyzed in
the FERC License Application,and also a range of
load-following scenarios with hourly flow variations.The
Power Authority has developed additional data and methods
which FERC may utilize in its analysis of load-following
alternatives,to the extent FERC deems any load-following
operational scenario to be a reasonable alternative.The
Power Authority has identified a load-following case and has
analyzed the resulting stage fluctuations in the Susitna
____w."""''1''''''--'.--------
--
RESPONSE TO COMMENT I.346 (cont.):
River downstream from the Project.A report documenting
this analysis,illustrating appropriate methods of analyzing
such alternatives,is referenced below and appended as a
reference to this Response Document.This load-following
hypothetical case may be characterized as "extreme,"but
remains within the flow constraint of the Case C scenario.
This analysis was made to determine if,downstream of the
Project,significant attenuation of the fluctuating water
levels resulting from load-following operation would occur.
The Power Authority does not currently believe that the flow
release patterns in this report would be jUdged by many
agencies to be an environmentally reasonable alternative.
Neither is it necessarily thought that these patterns
represent the optimum economic use of the resource.It may
be of value in that it represents an environmentally extreme
case;however,the FERC may not deem this case a
"reasonable"alternative for its analysis.A second report
which will document stage fluctuations for a more moderate
case of discharge variations is anticipated in late March
1984.
We anticipate that the FERC will identify reasonable
alternatives and analyze the environmental impacts of such
modes of operation in preparing DElS and FEIS.To the
extent such alternatives are load-following,such an
environmental analysis would include consideration of
aquatic habitat effects of the rnximum and seasonal mean
changes in discharge occurring on a daily basis as well as
the rates of change.Both rate of change and absolute
change associated with alternative load-following modes of
operation can be compared to natural existing conditions in
the river.
A few examples of the natural range of the daily discharge
variation is given in the Table below,taken from daily
average discharge records at Gold Creek and two other
locations at which rating curves are available.Rates of
change under existing conditions can only be indirectly
deduced from this table,but should be directly available
from USGS gaging records.Please see also the Responses to
Comments 1.542 and 1.552,as well as the Responses to
Comments B.7,B.64,B.65,C.87 and F.39.
2M.4
"""
~I
-
RESPONSE TO COMMENT 1.346 (cont.):
TABLE I
Daily Changes in Discharges
and Associated Changes
in Wa~er Surface Elevation.
Change Change Change in Change in
Avg.From in Stage Stage at Stage at
Date Daily Prevo at Gold LR X 28 LR X 35
Discharge Day Creek
(cfs)(cfs)(ft) (ft)(ft)
08/31/82 16,000 +3,000 +0.6 +1.0 +0.8
06/08/82 30,000 +4,000 +0.5 +0.4 +0.5
08/02/81 54,000 +20,000 +3.2
08/21/81 43,100 +8,000 +0.8
05/07/81 13,600 +3,600 +1.1 +1.1 +1.1
05/09/81 30,000 +9,000 +1~3 +1.2
09/15/80 21,600 +9,600 +1.8 +2.1 +2.1
09/14/80 12,000 +2,400 +0.6 +0.8
07/02/80 33,800 -8,600 -0.9
09/01/79 12,100 -2,000 -0.5 -0.6
09/22/83 13,600 +3,000 +1.0 +1.0
09/23/83 17,500 +3,900
Note:September 22,1983 discharge increased from
approximately 12,000 cfs to approximately 15,000
cfs during a one-day period.Discharge was
13,000 cfs at 0730 hours;approximately 15,000 cfs
at 1800 hours.
REFERENCES
Harza-Ebasco,Susitna Hydroelectric Project River Stage
Fluctuation Resulting From Watana Operation (January 1984).
COMMENT 1.347:
"Page E-3-232:-Watana to Devil Canyon:Paragraph 4:We
appreciate the discussion of rime ice formation in response
to our previous comments (Chapter 11,W-3-125),but note
omission of Wood,et ale (1975)from the document's
reference list.An important concern with rime ice
COMMENT 1.347 (cont.):
formation would be potential impacts to birch adjacent to
the impoundment and winter use of those areas by moose.II
RESPONSE:
The authors of the text have not been able to locate the
reference to the effects of ice storms on oak forests
(listed as Wood,et ale 1975).Effects of ice formation on
moose are discussed in the Response to Comment 1.352.
COMMENT 1.348:
IIPage E-2-234:Talkeetna to Yentna River:The project is
expected to alter flows 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."
RESPONSE:
Please refer to the Responses to Comments B.33,1.40 and
1.54 with regard to simulation of ice processes in the Lower
River downstream of the Susitna-Chulitna confluence.Addi-
tionally,please refer to the Response to Comment C.42 on
ice scouring and vegetation removal in the reach between
Talkeetna and Devil Canyon.
The same considerations in the Response to Comment·C.42
apply to the Lower River with some modification.
Post-project stages during freeze-up are expected to be
higher than existing stages because of the higher freeze-up
discharge.Ice cover induced staging may be expected to be
similar to present conditions.However,the increased
stages during freeze-up do not in themselves lead to
increased bank scouring.Bank scouring and other changes to
river morphology occur primarily during break-up (License
Application page E-2-25 and R&M Consultants,Susitna River
Ice Studies 1980-1981,1981-1982 and 1982-1983).Freeze-up,
under natural conditions is a much more gradual controlled
phenomenon than break-up.No significant additional bank
scouring due to higher water levels during the freeze-up
period is expected.
Break-up jamming does not appear to have as significant an
influence on channel morphology downstream of the confluence
with the Chulitna as upstream.Observations by R&M during'
the winter of 1982-1983 indicated "The only significant ice
.....
RESPONSE TO COMMENT 1.348 (cant.):
jam observed below the Parks Highway Bridge occurred near
the confluence with Montana Creek."A jam was observed in
the same area as the 1980-1981 break-up.The lack of
significant ice jamming is characteristic of braided chan-
nels as noted by Gerard (1983).With the project in place,
the warmer releases from the reservoirs and the control of
spring floods in the reach upstream of the Chulitna conflu-
ence would tend to moderate the break-up jamming which now
occurs.This scour of banks and vegetation should be
reduced with Project.
REFERENCES
R&M Consultants,Inc.,SusitnaHydroelectric Project,
Susitna River Ice Studies.
Ice Observations 1980-1981,1981-1982 (l982),
previously submitted to the FERC on July 11,1983.
Ice Observations 1982-1983 (in preparation).
Gerard,L.,Notes on Ice Jams,for Ice Engineering in Rivers
and Lakes,University of Wisconsin,Madison (19B3).
COMMENT 1.349:
"Page E-3-235:"Yentna River to Cook Inlet:We axe
concerned that minimal downstream impacts have been assumed
even though a doubling in mean winter flows has been
predicted at Susitna Station (RM 26)(Chapter 2,Figure
E.2.49);and ice staging and break-up impacts are unknown."
RESPONSE:
Please refer to the Response to Comment 1.348 on winter flow
regime downstream of the Chulitna-Susitna confluence.The
same considerations apply to the reach downstream of the
Yentna-Susitna confluence.However,the influences of
warmer temperatures released from the reservoirs and spring
flood regulation on break-up would be minimal dOvlnstream of
the Yentna confluence.This would be due to the large quan-
tity of tributary inflow in the Lower River (i.e.,Chulitna,
Talkeetna and Yentna Rivers)•
I~
COMMENT I.350:
"Page E-3-236:(iv)Climatic Changes and Effects on
Vegetation:The areas in which vegetation changes will
occur must be known to fully assess implications to wildlife
habitats."
RESPONSE:
Quantification of areas in which vegetation changes
resulting from climatic changes will occur is difficult at
best and may be beyond the state-of-the-art.Methods of
estimating these areas will be considered and quantification
will be carried to the extent feasible during impact
assessment refinement efforts.
COMMENT I.351:
"Page E-3-236:(iv)Climatic Changes and Effects on
Vesetation:Parasraph 2:Although phenology studies were
undertaken in spring,1983 to obtain data for better
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."
RESPONSE:
The Power Authority anticipates that the DEIS will
reasonably address phenological effects.
COMMENT I.352 :
"Page E-3-236:(iv)Climatic Changes and'Effects on
Vegetation:Paragraph 5:As with the discussion on
temperature changes adjacent to the reservoir,the
importance of fog banks and resultant ice formation relates
to plant species,time of year,and wildlife uses which will·
be affected.In addition to providing such information,we
recommend describing the period when area temperatures may
be below -9.4°P and stearn fog creation is likely."
RESPONSE TO COMMENT I.352:
Many Alaskan rivers have open water areas which produce fog
throughout the winter.The ice crystals observed on
vegetation in these areas,although large,are not dense and
probably less likely to break twigs than a heavy snowfall.
At a thermal springs area on the North Slope up to 90%of
the available twigs adjacent to the water were browsed by
moose (Masters,et ale in press).The ice crystals may be
removed by wind and are not necessarily present all winter.
REFERENCES
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).
COMMENT I.353:
"Page E-3-237:(v)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
commnents on Sections 3.3.3 and 3.4.2(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 in
Chapter 11)."
RESPONSE:
""",
This Comment is noted and appreciated.Please refer to the
Responses to Comments 1.364 and 1.384.~
COMMENT I.354:
"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 increase."
RESPONSE:
After resprouting following fire,blueberries produce larger
crops of berries (Hall and Aalders 1979).Raspberries
(Rubusidaeus)and currants (Ribes glandulosum),which
Pitt
RESPONSE TO COMMENT 1.354 (cont.):-germinate from buried seed following fire,also produce
large berry crops in the early successional stages and
disappear from the mature forest (Densmore 1979).
REFERENCES
Densmore,R.V.,Aspects of the Seed Ecology of Woody Plants
of Alaskan Tiaga and Tundra,Ph.D.Thesis,Duke University,
North Carolina (1978).
Hall,I.V.and L.E.Aalders,Lowbush Blueberry Production
and Management,in:Lowbush Blueberry Production (1979).
COMMENT 1.355:
."Page E-3-240:(a)Construction:There is no
quant~fication 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.85.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."
RESPONSE:
Please refer to the Responses to Comments 1.248,1.305,
1.336, 1.338,1.344 and 1.345.
COMMENT 1.356:
"Page E-3-240:(i)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
development 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
confirm optimum siting of camp,village,and borrow areas."
~------'-~'--------------------------------
RESPONSE TO COMMENT 1.356 (cont.):
Rehabilitation plans for disturbed sites are conceptually
described in the FERC License Application on pages E-3-275
through E-3-281 of the Mitigation Plan.As stated on
page E-3-279 "preparation of a comprehensive restoration
plan for the Susitna project has been designated as a task
for the detailed engineering design phase."Please refer to
the Responses to Comments 1.77,1.330 and 1.381 fqr
responses to the last sentence of this Comment.
COMMENT 1.357:
"Page E-3-240:(ii)Vegetation Loss by Erosion: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])."
RESPONSE:
Please refer to the Responses to Comments 1.336 and 1.344.
COMMENT 1.358:
"Page E-3-241:(iv)Effects of Altered Drainage:Please see
our comments on Table E.3.82 regarding the likely
overestimation of wetlands as described here."
RESPONSE:
Please refer to the Response to Comment 1.417 regarding FERC
License Application Table E.3.82.
COMMENT 1.359:
"Page E-3-241:(b)Filling and Operation:Please refer to
our previous comments and study recommendations on the
potential for soil/vegetation/reservoir interactions which -
result in increased mercury levels in fish (Section 3.3.1(b)
and in Chapter 2,Section 4.1.1(e}[vii]."
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-
--
RESPONSE TO COMMENT I.359 (cont.):
Please see the Responses to Comments 1.41 and I.342.
COMMENT 1.360:
"Page E-3-242:Filling and Operation:Paragraph 3:We find
no delineation of the large landslide at RM 175 on Figure
E.3.3.as referenced here."
RESPONSE:
The figure reference for the old landslide at River Mile 175
should be:FERC License Application Exhibit E,Chapter 6,
Figures E.6.27.A copy of that Figure is attached.
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COMMENT 1.361 :
"Page E-3-242:(ii)Erosion and Deposition:This statement
is inconsistent with the previous discussion of erosion,
Section 3.3.2(a)(ii),the proceeding paragraph which assumes
some soil losses following clearing [Section 3.3.2(b)(i)],
the des~ription of the large landslide at RM 175,and the
steep area topography."
RESPONSE:
As stated on FERC License Application page E-3-242,"due to
the geologic character of the Devil Canyon region,erosional
and depositional changes affecting vegetation will be
minimal following filling of the reservoir."Because of the
narrow,steep configuration of Devil Canyon,vegetation
losses will be substantially less than the Watana Reservoir.
On cleared,unsubmerged lands,vegetational succession
patterns will occur and a much greater mosaic of vegetation
types may develop.Clearing along the periphery of the
reservoir may facilitate erosion,which in turn may result
in vegetation loss,but this will generally be within the
drawdown zone.The old,large landslide at RM 175 could
move after filling and as a consequence,it could cause a
loss of mid-and late-successional vegetation.To
summarize,a potential for vegetation loss may exist if
either a landslide or erosion of areas cleared for the
reservoir occurs.Therefore,in a relative sense,the
potential for vegetation loss is considered minimal in the
areas adjacent to the reservoir.
COMMENT 1.362:
"pageE-3-242:(iii)Effects of Regulated Flows:Frost
build-up on vegetation adjacent to the reservoir could
result in a significant changes in vegetation.Wildlife
would subsequently be affected,as we commented under
Section 3.3.1 (b)(iii).Please also see comments there
regarding the need to quantify the range of areas which may
become available for successional vegetation development."
RESPONSE:
The effects of frost on vegetation are discussed in the
Response to Comment 1.362.
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COMMENT I.363:
.....
"Page E-3-243:Ca)Construction:Additional impacts from
access road construction and use include thawing of adjacent
permafrost and associated drainage and vegetation changes."
RESPONSE:
Where it is necessary for the access road between Devil
Canyon and Watana to cross permafrost areas,appropriate
construction techniques will be utilized to minimize
thawing,provide cross drainage,prevent impoundment of
water and avoid concentration of sheet flow.These
techniques will be addressed in the Project Design Criteria
Manual and Erosion Control Plan.Thawing and slumping at
the toe of the road may occur in some areas after several
years,and produce wet areas and a shift in vegetation
immediately adjacent to the road.
COMMENT I.364:
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-
"Page E-3-244:Cb)Operation:Use and management of access
routes in addition to those required for project
construction will determine tlie magnitude of impacts to area
fish,wildlife,and socioeconomics."
RESPONSE:
In general,access-related environmental impacts fall into
two categories.First,there are the direct impacts
resulting from construction of the access facilities
themselves and the indirect impacts resulting from
activities of workers involved in construction of the roads
and other project facilities.The second category of
impacts includes those impacts which would result from
increased human activity due to improved access to the
project area.Because construction worker activity and
other construction impacts can be limited through management
practices,the second category of impact is the one for
which there is potentially the greatest variability in
environmental impact.Moreover,because the direct
construction-related impacts can be controlled through
project design and management practices,the issue of access
facilities for nonproject needs becomes the determining
factor in assessing overall project-related environmental
impacts.Therefore,the use and management of access roads,
in addition to those required for project construction,will
have a major influence in determining environmental impacts.
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RESPONSE TO COMMENT 1.364 (cont.):
Recognizing this fact,the Power Authority is committed to
working with the resource agencies in formulating access
policies.Please refer to the Response to Comment 1.289 for -
additional discussion of this matter.See also the
Responses to Comments A.1, A.3.and F.7.
The Power Authority anticipates that the OEIS will analyze
such factors in connection with reasonable access
alternatives.
~-
COMMENT 1.365:
"Page E-3-244:Cal Construction:Paragraph 1:In addition
to the botanical impact analysis of individual transmission
line segments described here and in Tables E.3.79,E.3.80
and E.3.86,we recommend 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]).
"Please also note apparent calculation errors in Table
E.3.86 which double the estimate of total areas to be
impacted by the Healy-to-Fairbanks and Willow-to-Cook Inlet
transmission corridors.Subtotaled areas of forest,tundra,
shrubland,and unvegetated cover types crossed appear to
have been added to the individual sixteen forest,three
tundra,four shrubland,and two unvegetated types in
arriving at an overall total.
"Reference should be made to our comments on Table E.3.86
regarding potential inaccuracies in recalulation of
transmission line right-of-way widths from 400 to 300 feet."
RESPONSE:
Please refer to the Response to Comment 1.327 for the
response to the first part of this Comment.
FERC License Application Table E.3.86 was revised to
eliminate calculation errors due to double counting of
forest,shrub,tundra and unvegetated cover types and this ~"
revision was included in the Response to Supplemental
Information Request 3B-7 (see February 15,1984 APA Response
Document,Reference Volume,Reference 1.370.1).
Recalculation of transmission line impac~s on the basis of
the 300-foot right-of-way width used in FERC License
RESPONSE TO COMMENT I.365 (cont.):
Application Table E.3.86 was by a straight-line proportion,
which results in an accurate adjustment.However,the Power
Authority has noted that the Willow-to-Cook Inlet portion of
this Table should assume ultimate development of three
circuits requiring a 400-£oot right-of-way (see FERC License
Application Exhibit G,plates G30-G34).Therefore,the
Tab~e has been revised appropriately and is included in
Reference I.370.2 (see February 15,1984 APA Response
Document,Reference Volume).
COMMENT I.366:
"Page E-3-244:(a)Construction:Paragraph 2:Please
explain whether vegetation impacts were recalculated where
the currently proposed route extends outside the corridor in
which vegetation was originally mapped (e.g.,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.lI
.
.....
RESPONSE:
Vegetation impacts have been accounted for in both the
mapped and unmapped portion of the corridor.As stated in
the second footnote of Revised Table E.3.86 (see revision
referenced in the Response to Comment I.370),for the
purpose of calculation of total acreages it was assumed that
vegetation types along the unmapped portion of the route
were representative of the vegetation types that occur along
the mapped portion of the corridor.
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COP..MENT I.367:
"Page 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,'except at areas such as major river
crossings and deep ravines where an access strip would not
be utilized for the movement of equipment and materials.'
Please clarify whether low shrub and tundra types will be
cleared within the access strip and the anticipated schedule
for maintaining that access.
IIWe recommend that the applicant consult with the CE,FWS
and ADF&G in siting of the proposed access strip to ensure
_~._~--------F"-
COMMENT 1.367 (cont.):
that potential adverse impacts to wetlands and fish streams
are avoided.
WDuring planning for the 1ntertie,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 distrubances,and
potential off-road vehicle (ORV)lise.However,pressure
from the public utilities,who will eventually take over
operation of the 1ntertie,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.w
RESPONSE:
The 25-foot wide access strip parallel to the transmission
line will be developed to the minimum standard necessary to
allow for flat-tread,balloon tire vehicles to carry
equipment to sites for construction.
Tundra vegetation will not be cleared.Low shrubs will not
be cleared unless they are so tall and dense that access is
restricted.
Schedules for access strip maintenance will be the same as
for general maintenance of the right-of-way.Presently,
clearing for the right-of-way is anticipated every ten years
at a maximum.Localized clearing associated with tower line
maintenance or repair may be required periodically.Final
schedules for maintenance of the right-of-way will be
determined by the operating contractor and actual field
conditions after the transmission line is constructed.
During the detailed engineering phase and subsequent
development of transmission line construction drawings and
specifications,final siting of the line,including the
access strip,will be located in consultation with
appropriate agencies.This location will be identified in
the construction access plan prepared for the transmission
line.
Regarding the use of helicopter construction,please refer
to the Responses to Comments 1.387 and F.39.Also refer to
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RESPONSE TO COMMENT 1.367 (cont.):
Supplemental Responsp.s 3-B-15 and 3-B-16,which were filed
with the FERC on July 11,1983.
REFERENCES
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.
COMMENT 1.368:
"Page E-3-245:3.3.5 -Impacts to Wetlands:The application
states that the estimates of wetland acreage to be impacted
by the proposed project'are extremely liberal and all
values should be considered preliminary.'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
Se9t~m3.2.3 -Wetlands)•Thus,we recommend that impacts
from access and transmission corridors not be assessed by
applying the applicant's current wetlands classification by
vegetation type system."
RESPONSE:
The Power Authority recognizes the concerns regarding the
evaluation of wetlands.See the Response to Comment 1.330.
COMMENT 1.369:
"Page E-3-246:3.3.6 -Prioritization of Impact Issues:In
order to quantify project impacts over the life of the
project,further details are needed on the anticipated
length of time for each impact discussed here.II
RESPONSE:
Most of the impacts discussed in the referenced section will
occur for the life of the Project.The date of initiation
and/or duration of many impact mechanisms is presenfed in
Table E.3.144 of the FERC License Application,and the
duration of many project impacts are presented along with
their descriptions in Section 3.3.As impact assessment
------------------
RESPONSE TO COMMENT 1.369 (cont.):
refinement proceeds,improved and more complete p.stimates of
the duration of impacts will be possible.
COMMENT 1.370:
"Page E-3-246:(a)Direct Loss of Veqetation: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."
RESPONSE:
The referenced text,as well as many.other inconsistencies
between the text and tables,were revised and presented in
the Response to Supplemental Information Request 3B-7 (see
February 15,1984 APA Response Document,Reference Volume,
Reference 1.370.1).Many of these have subsequently been
revised and are included in Reference 1.370.2 (see
February 15,1984 APA Response Document,Reference Volume).
The subsequent revisions are primarily due to corrections in
the right-of-way requirements for several transmission line
segments.The corrected right-of-way requirements for each
segment are noted in footnotes for each table.The Response
to Comment 1.305 discusses corrections to Table E.3.144 and
other revisions which are all included in Reference 1.370.2
(see February 15,1984 APA Response Document,Reference
Volume)for simplicity.
COMMENT 1.371:
"Page E-3-247:(iv)Transmission Corridors:Please refer to
our previous comments under Section 3.3.4(a)and Table
E.3.86 on apparent errors in the ·calculation of transmission
line impacts.Inconsistencies between the description of
access trails in Exhibit A,Sections 4.2{d),
Section 3.3.4(b),and the applicant's response to our
question on the draft license application that,
'Transmission corridor design has been revised and no longer
incorporates longitudinal access strip'(Chapter 11,
W-3-152),should be removed."
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RESPONSE TO CO~~lENT I.371:
Errors in the calculation of vegetation impacts resulting
from transmission line construction have been noted and
corrected.Please refer to the Response to Comment I.369
and Reference I.370.2 (February 15,1984 APA Response
Document,Reference Volume).Clarification on the intent ·of
longitudinal access is as follows:
o Longitudinal access will be necessary for right-of-way
and tower/line maintenance.
o
o
A "strip"in the sense of a constructed road requiring
stripping of topsoil,gravel surfacing or cuts and
fills will not be developed.
Within the right-of-way,only vegetation that would
impede access by 4-wheel maintenance vehicles would be
removed.Siting of the access route will be done with
field verification and in consultation with appropriate
agencies to ensure that impacts are minimized.Please
refer to the Response to Comment I.226 for further
clarification on this topic.
o Though the d~~elopment of longitudinal access will be
restricted to removal of vegetation and stumps in
areas,a trail is still likely to develop.Reasons for
this are:
1.The route will receive repeated construction use
which will tend to impact soils and limit
vegetation growth within the access relative to
other areas within the ROW,and
2.Over time,vegetation in the right-of-way will
grow beyond height limits and need to be cut;the
vegetation within the access route will tend to be
cut lower in order to provide unimpeded access
further emphasizing demarcation of a trail.
.....
COMMENT I.372:
"Page E-3-248:(b)Indirect Loss of Vegetation:The
cumulative impacts of project features described under the
previous section and here should be considered.Many
identified losses will be in riparian habitat important to
wildlife species."
RESPONSE TO COMMENT I.372:
Discussion of indirect losses due to erosion and other
factors is contained in Responses dealing directly with
these factors (see,for example,the Responses to Comments
I.336 and I.344).
COMMENT I.373:
IIPage E-3-249:ecl (i)Downstream Floodplain:Please refer
to our previous comments (Section 3.3.1(b)(iii)on the
uncertainties underlying current downstream analyses,
particularly downstream of Talkeetna.We again recommend
quantification of potential vegetation changes over the life _
of the project for a variety of possible flow and ice
scouring scenarios.1I
RESPONSE:
Please refer to the Re~ponses to Comments I.54 and I.346.
In addition,information on hypothetical dam break scenarios
is also available (R&M Consultants,1982).-
REFERENCES
R&M Consultants,Hypothetical Dam Break Analysis for Acres
American,Inc.(March 1983).
COMMENT 1.374 :
IIPage E-3-251:(a)Item 3:Where information for
determining the extent to which mitigation will be achieved
is unavailable,requisite studies,including monitoring,
should be outlined and their implementation assured.1I
RESPONSE:
The Power Authority agrees that monitoring to determine the
extent to which mitigation is achieved should be conducted
where this information is not already available.Refined
mitigation plans will incorporate specific monitoring
programs for botanical resources which are necessary in
addition to those already defined for wildlife (see FERC
License Application Section 4.4.2(a».
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COM1'1ENT 1.375:
"Pace E-3-251:Item 8:We are concerned that illustrations
of ~itigative design 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."
RESPONSE:
This suggestion regarding the inclusion of more
illustratio~s and location maps of mitigative design
features will be carried out in more refined versions of the
Mitigation Plan,especially as detailed engineering design
proceeds.Please refer to the Response to Comment 1.378 for
additional discussion regarding the side borrow technique.
COMH.ENT 1.376:
"Page E-3-251:(b):The FWS supports funding and
implementation of mitigation concurrently with projec:::t
planning and construction.We are concerned that outlined
mitigation studies are generally limited to planning studies
with some follow-up monitoring (Table E-3-177).Provisions
are lacking for implementing measures that will be
recommended through these study efforts.Please also see
our comments on Table E.3.177."
RESPONSE:
The Mitigation Plan presented in FERC License Application
Section 3.4 is specific where detailed design and
construction planning have proceeded sufficiently and
conceptual where they have not.As stated on FERC License
Application page E-3-252,"as engineering design and
construction planning proceed,features of this mitigation
plan will be correspondingly refined with respect to
specific locations,procedures and costs."The Power
Authority cannot locate the referenced comments on FERC
License Application Table E.3.l77.
COMMENT 1.377:
"Page E-3-252:Paragraph 1 to 4:We recommend that the
Biological Stipulations included with our comments as
Attachment A be made conditions of the FERC-license and
incorporated in any project contracts and bid specifi-
cations.
"With the exception of wetlands mitigation planning,we
concur with the mitigation objectives and framework outlined
here.As stated previously in Sections 3.2.3 and 3.3.5,
inadequate identification of wetlands means that higher
priority mitigation options to avoid and minimize impacts
may now be more difficult to incorporate in project
planning.
"We believe that a mechanism and r~sponsible parties should
be identified for ensuring that,'features of this
mitigation plan will be correspondingly refined with respect
to specific locations,procedures,and costs'as project
design and planning proceeds."
RESPONSE:
/m".
A.
B.
The Power Authority does not concur with the DOl
recommendation that all Biological Stipulations
included in 001 Attachment A be made conditions of the
FERC License.It is the Power Authority's opinion that
many of these conditions,or similar conditions,will
be stipulated in state,Federal and local permits
required fo.r construction and operation of the Project.
That being the case,it is unnecessary that they become
FERC License conditions.
Also,many of the proposed stipulations are either
contradictory or untenable.
See also Response to Comment 1.425.
The Power Authority believes that several formal
mechanisms already exist which may result in the
refinement of the Mitigation Plan.These mechanisms
are described below:
Application Process
Agency and public comments addressing the Mitigation
Plan in the License Application may be used to refine
the Mitigation Plan.
~"
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RESPONSE TO COMMENT 1.377 (cont.):
NEPA Process
The Draft EIS will provide for agency and public
comment on project features and alternatives as well as
mitigation proposed for each.The Power Authority may
use those comments to further refine its Mitigation
Plan.
Settlement Process
The Power Authority has embarked upon an ambitious
settlement process the main emphasis of which is to
coordinate with agencies,local governments and
intervenors and arrive at a mutually agreeable
Mitigation Plan (see Response to Comment I.81l.
PERC Hearing Process
If the NEPA process and the Settlement Process do not
result in a mutually acceptable Mitigation Plan,the
PERC may order hearings to address this issue.It is
the Power Authority's intention,however,to avoid
hearings to the maximum extent possible •
COMMENT 1.378:
"Page E-3-252:.(a)Direct Loss of Vegetation:We question
the estimated area for access borrow areas.According to
the following Section,(i),(page E-3-265,paragraphs 2 and
4)borrow needs could run from 90 to 180 acres the Denali
Highway-to-Watana road segment and from 50 to 100 acres for
the road between the Watana and Devil Canyon Dams.
Potential 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)."
RESPONSE:
The preliminary inve;:;tigati.ons performed in siting the
access roads to both Watana and Devil Canyon and the
railhead-railway for Devil Canyon established potential
borrow sites to be used in case sufficient material from
side borrow was not available.The definition of these
sites was to indicate the potential resources available
along the access routes.'I'he upper limit on borrow areas
indicated in the Comment does not reflect the area that will
RESPONSE TO COMMENT I.378 (cont.):
be required.Similarly,the lower limit would also indicate
that each of the borrow sites identified would be utilized,
which mayor may not be the case.Optimum access siting
requires a balance between the length of access (volume of
material moved and placed)and the material haul lengths.
The siting of an access maximizing the utilization of
material adjacent to the access can justify an increased
length and still be the most economical alternative.In
FERC License Application Figure E.3.37 potential borrow
sites are indicated along the alignments for the Watana
access road,the Devil Canyon access road and the railhead-
railway for Devil Canyon.The area requirements in hectares
for these three accesses including borrow sites are
presented in FERC License Application Table E.3.~44 (see
revised Table E.3.144 referenced in the Response to
Comment 1.370).Site material not suitable for use in
access construction will be stockpiled until the borrow
operation is advanced well enough at the site so that the
spoil material can be placed in the used borrow area.This
spoil material will be shaped and graded so as not to affect
drainage and impact runoff water quality.
Borrow for construction camps and villages will be minimal,
the permanent village requirements principally for
landscaping can be obtained from borrow area D and quarry
site B.Spoil from the construction ca~ps that cannot be
incorporated in grading or landscaping can be spoiled in
designated areas that lie within the impoundment zone.Two
specific areas are designated on each of FERC License
Application Exhibits F 35 and F 71.
COMMENT 1.379:
"Pages E-3-254 through E-3-275:(i)Minimization:The
discussion is limited by the:(1)inadequacy of wetlands
mapping (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."
RESPONSE:
The Power Authority anticipates that the DEIS will reason-
ably describe wetlands in the project area,classify vege-
tation as necessary and assess various mitigation options
and that the DE1S will summarize and incorporate prior
studies of these topics.
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COMMENT 1.380 (underlined text):
"Page E-3-254 Last Paragraph through Page E-3-256:Paragraph
~:We recommend that the £:roposed temporary airstrip be
sited so ~it ~later ?e expanded to become the
permanent airstrip.This suggestion is compatible with the
applicant's recent request ~o fund ~2500-foot temporary
airfield at the Watana base camp which would subsequently be
expanded to the 6000-foot airfield necessary during project
construction 3B-5/.
"We also recommend consolidation of the Watana constuction
camp,village,and townsite.We note these facilities
(Exhibit F,Plate F35)are spread out com pared to the Devil
Canyon camp and village (Exibit F,Plate F70).We also note
theWatana 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,village,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
equipment and materials is preferable to prevent impacts in
biologically sensitive areas.Please refer to our previous
comments on access for line maintenance,Section 3.3.4(b)."
"3B-5/Construction of Temporary Airfield at Watana.
Appendix 4 to Agenda Item IV,Action Item NO.1,prepared
for the APA Board of Directors."
.RESPONSE:
Refer to the Response to Comment 1.92.
COMMENT 1.381 (underlined text):
"Page E-3-254 Last Paragraph through Page E-3-256:Paragraph
~:We recommend that the proposed temporary airstrip be
sited so that it can later be expanded to become the
permanent airstrip.This suggestion is compatible with the
applicant's recent request to fund a 2500-foot temporary
airfield at the Watana base camp which would subsequently be
expanded to the 6000-foot airfield necessary during project
construction 3B-5/.
"We also recommend consolidation of the Watana constuction
camp~llage,and townsite.We note these facilities
(Exhibit F,Plate F35)are spread out compared to the Devil
Canyon camp and village (Exibit F,Plate F70).We also note
the Watana facilities ~close to the environmentally
sensitive Deadman Creek~.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,village,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
equipment and materials is preferable to prevent impacts in
biologically sensitive areas.Please refer to our previous
comments on access for line maintenance,Section 3.3.4(b)."
"3B-5/Construction of Temporary Airfield at Watana.
Appendix 4 to Agenda Item IV,Action Item No.1,prepared
for the APA Board of Directors.II
RESPONSE:
Refer to Response to Comment r.91 relative to combining the
Construction Camp,Village and Permanent Village.During
final layout of facilities,impacts on wetlands will be
..
~,
,..",
~i
RESPONSE TO COMMENT 1.381 (cont.):
minimized to the extent practical.
COMMENT I.382 (underlined tE~xt):
"Page E-3-254 Last Paragraph through Page E-3-256:Para~raph
2:We recommend that the proposed temporary airstrip be
iited so that it can later be expanded to become the
permanent airstrip.This suggestion is compatible with the
applicant's recent request to fund a 2500-foot temporary
airfield at the Watana base camp which would subsequently be
expanded to the 6000-foot airfield necessary during project
construction 3B-5/.
"We also recommend consolidation of the Watana constuction
camp,village,and townsite.~'le note these facilities
(Exhibit F,Plate 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,~:!Tsusena Creek should be
explained.As ~commented on the draft license
application,we have not had input into the decisions
regarding the ~,administration £E siting of the
construction camp,village,and townsite (Chapter 11,
W-3-046).We concur with the concept of common corridor
routing for the Watana-to-GoldGreek access ~transmission
corridors although the map .scale represented in Figures
E.3.39 and E.3.40 makes it difficult to evaluate those
Eroject~atures.Consultation with resource agencies
during the on-ground Elanni~of detailed Eroject design may
indicate areas where winter movement of construction
equiEment and materials is preferable to Erevent impacts in
biologically sensitive ~~.Please refer to ~Erevious
comments on access for line maintenance,Section 3.3.4(b)."
"3B-5/Construction of Temporary Airfield at Watana.
Appendix 4 to Agenda Item IV,Action Item No.1,prepared
for the APA Board of Directors."
,_--------,.-.-----......,..-,,...1""'---------.------------
RESPONSE TO COMMENT 1.382:
Please refer to the Responses to Comments 1.92 and 1.543
concerning airstrips.See the Responses to Comments 1.380
and 1.543 for Response to Comments on Construction Camp,
village and townsite.We also confirm that final siting of
these installations will take into consideration any
wetlands (see Response to Comment 1.330).The "circular
road system outlined in Exhibit F,Plate F35"is for moving
material excavated for project features to spoil areas and
moving materials excavated in borrow and quarry areas for
use in the project features.Given the scale of the
drawing,the alignment shown is schematic.Detailed design
will consider site specific topography and foundation
conditions in selecting an alignment that will minimize
environmental impacts during and after project construction
and meet design and safety standards established in the
design criteria and construction specifications.Please
refer to the Response to Comment 1.367 regarding access for
transmission line maintenance.
The scheduled use of these temporary construction roads can
be determined from the Watana Construction Schedule in FERC
License Application Exhibit C (Figure C.l).For example,
main dam excavation begins after mid-1986,fill operations
begin in mid-1987 and continue intermittently until late
1993.Emergency spillway work begins early in the second
quarter of 1991 and continues for approximately six months
with the same schedule repeated in 1992.
COMMENT 1.383:
"Page E-3-256:Paragraph 3:and Page E-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."
RESPONSE:
Comment noted.
-
~,
COMMENT 1.384:
"Paragraph 3 through Page E-3-258,and Pages E-3-260:
Paragraph 4 through 262:We reiterate our recOImnendation to
drop the Denali Highway-to-Watana access segment because of
big game resource values described here,as well as area
furbearer,raptor,and wetland values.Moreover,signifi-
cant secondary impacts of increased disturbance will result
from the increased access allowed by that route.Please
refer to our letters dated Augustl7,1982 and January 14,
1983 to Eric P.Yould,APA.Eliminating the Denali Highway-
to-Watana access road is the design change with the greatest
potential for mitigating access road impacts to wildlife."
RESPONSE:
The issues surrounding the selection of a preferred access
route are complex from an environmental perspective (see
Responses to Comments A.l,.A.3 and F.7).It is recognized
that the Denali route traverses a relatively inaccessible
area considered to be of a relatively high quality for
wildlife and other resources.From a purely wildlife
standpoint,impacts could be greater for the Denali plan
than for a plan involving access from the west.Impacts to
large raptors,furbearers,brown bear and caribou could be
higher under the Denali plan,while impacts to black bear
and moose would likely be higher under the other alternative
plans.Wetland impacts and the total amount of habitat lost
could also be higher under the Denali plan.Probably of
greatest concern from a wildlife standpoint,however,is .the
potential for increased accessibility to sensitive areas
from road traffic along the Denali access road.With
careful management and use restriction (see Responses to
Comments 1.289 and 1.364),it will be possible to reduce
nonconstruction-related secondary impacts.
Although wildlife-related impacts could be judged greater
with the Denali access plan,the Denali access plan is
preferred when all factors are considered.Thus,although
it is recognized that wildlife impacts could likely be
greater for the Denali plan,the other benefits of the
Denali alternative outweigh the disadvantages.
Reasons supporting the Denali access route include the fact
that the proposed Denali to Watana access road crosses fewer
major streams than other routes along the Susitna River,and
would not cross any anadromous fish streams.The Denali
route generally traverses flatter terrain,w~th better
drained soils than the other routes,and would be the least
------_.~---------------_._~----------
M,..
RESPONSE TO COMMENT 1.384 (cont.):
difficult to construct of the aternatives considered.These
conditions result in the Denali plan having a lower initial
cost,and its being favored from a construction standpoint.
The Denali plan provides the best access for support of
field forces since under the Denali plan the early stages of
project construction can be completed more readily.These
and many other factors were evaluated in several reports,
including the Access Recommendation Report (Acres American,
Inc.March 1983),which summarizes the major issues.
REFERENCES
Acres American,Inc.,Supplement to the Feasibility Report
(March 1983).
COMMENT 1.385:
"Page E-3-258:Paragraph 1:Although the Watana-to-Devil
Canyon transmission and access routes share a common cor-
ridor,it does not appear that they have adjacent or com-
bined 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.1I
RESPONSE:
Sharing or combining rights-of-way generally results in less
overall environmental impact and reduced construction nnd
operating costs.The viability of combining more of the
transmission and access road rights-of-way will be explored
as tower siting and route refinement take place during the
detailed engineering phase of the Project.At that time,
up-to-date aerial photography will be utilized in
conjunction with field investigation and construction 'site
drawings.However,transmission right-of-\-Jay generally is
point to point to minimize length.Road right-of-way must
take advantage of contours to maintain acceptable grade,
horizontal and vertical curves.
COMMENT 1.386:
IIPage E-3-256:Paragraphs 1 and 2 and Pages E-3-261 through
266:We concur with the objective of siting borrow areas
adjacent to the access road and with the recommended side-
~:
-
-
-
-
COMMENT I.386 (cont.):
borrow or balanced cut-and-fill techniques.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.
IIFor side-borrow construction,we recommend that the project
engineers work with interagj:mcy monitoring team in the
selection of temporary overburden and topsoil stockpile
iocations.Schedules should be provided for use and
reclamation of access borrmv 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 rel~stablishment of native species,
or seeding and possibly sprigging of willows in more
erodable areas,should be dletailed 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 included
as Attachment A and our comments on Section 3.4.2(a)(ii)
Rectification."
RESPONSE:
The adoption of certain construction practices,including
the sideborrow concept,can limit the impact of access road
construction.Since the development of large borrow areas
has the potential of disturbing more area than the access
roads themselves,special attention will be given to
designing the access road to take advantage of opportunities
to employ the sideborrow technique.In addition,Alaska
Power Authority intends to have its engineers work with
environmental scientists in selecting temporary overburden
and topsoil stockpile locations.Other suggestions in the
Comment will also be considered for incorporation into the
access road design and construction specifications.
It is the Power Authority's intention to identify more
potential borrow areas and stockpile sites than will
actually be needed,so that the contractors will have a
number of options for completing the access road
construction.Resource agencies will have an opportunity to
review design criteria and alignments.
COMMENT I.387:
"Page E-3-263:Paragraph 4:This section should explain how
the transmission corridor in the Jack Long Creek area will
be maintained since 'temporary'bridging of the creek will
be accomplished for construction.We recommend transporta-
tion of construction materials and equipment via helicopter
in this area to minimize potential disturbance,erosion,and
loss of fish and wildlife habitats.
"Please refer to Attachment C,for additional recommenda-
tions."
RESPONSE:
The transmission line right-of-way in the Jack Creek area
will be maintained by ground access.East of the Jack Creek
crossing,the transmission line right-of-way will be
maintained by access from the Devil Canyon access road.The
line and right-of-way west of the crossing will be
maintained via access along the Intertie route to the Gold
Creek substation.
It is the intention of the Power Authority that ground
access be used for construction and maintenance of the
transmission line (FERC License Application page E-3-271).
The many limitations of helicopter use (FERC License
Application page E-3-271)make it impractical to specify
helicopter use as the sole means of access except in very
limited locations where rugged terrain or severe
environmental impact make their use imperative.In
addition,being forced to depend solely on helicopters as
the means of transport for service restoration presents an
unnecessary risk in terms of delay and safety.
Prudent planning for maintenance and restoration of the
transmission line necessitates provisions for ground access
to the line.
COMMENT I.388:
"Pag.e E-3-264:Paragraph 1:We concur with realignments and
improved siting of the railhead facility to further minimize
project impacts to furbearers,eagles,and wetlandse The
discussion should include how such siting will minimize
disturbances to big game.Until additional assessment data
can be incorporated into moose,black bear,and brown bear
A,A
~\
~,
-
COMMENT I.388 (cont.):
models,it is not possible to compare habitat values of
alternative locations.
"Paragraph 3:A road crown of 2 to 3 feet above original
ground level may not provide an adequate thermal blanket in
areas of permafrost."
RESPONSE:
The railhead facility site,while necessary to be placed on
the south side of Jack Long Creek due to a beaver pond and
other wildlife concerns,is sited close to the construction
camp and village to reduce disturbance effects on
surrounding big game.It is also in fairly wet
forested habitats containing some black spruce--habitats not
highly productive for either browse species used by moose,
or spring forage or berry plants utilized by bears.
FERC License Application Figure E.3.83 contains a typical
cross-section of the side-borrow roadway.The feasibility
design as shown indicates a variable sub-base thickness.
The reference to a two-to-three-foot road crown on FERC
Licen'se Application page E-3-264 is a generality for
allowing the reader to compare a finished road section using
side borrow with the conventional roadway section.The
actual thickness of the roadway crown will be established
prior to completing the construction specifications by
design-related investigations of the sub-base material
conditions in the field including permafrost.
Roads susceptible to deterioration by permafrost usually lie
on silt-covered lower hillslopes or organic-rich soils in
lowlands which contain a high percentage of ice and ice
wedges.Thawing of such ground results in noticeable
differential subsidence.
Because permafrost containing large amounts of ice has not
been encountered along the proposed alignment,the roadway
is expected to be subjected to only that subsidence caused
by thawing of the so-called "warm"permafrost prevalent in
the area.Some slough and swale deposits may contain
segregated ice,but these deposits are restricted and easily
removable.For these reasons,the feasibility design using
two to three feet of road crown is considered to be
appropriate.See also Response to Comment A.4.
-------------------~------""""'I~--..,."I'--'-------~-----'------.-...-------
COMMENT 1.389:
"Page 266:Paragraph 3 through Page 268:We recommend that
resource agency concurrence be obtained during detailed
engineering design for final site selection and procedures
for spoil disposal.Spoil should be armored 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 pits.No spoil
should be placed upon snow,even for temporary disposal,and
overburden should not be pushed onto areas adjacent to
roadways which cross tundra vegetation.
"Additional recommendations for settling ponds,should they
be used in spoil disposal,follow:
1.Settling ponds should be sized for gravel pro-
cessing quantities,and fines.3B-6/.
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 stabilization.
"The length of time and potential areas to be covered by any
'temporary'spoils disposals should be designated."
"3B-6/u.S.Forest Service.Guidelines for Reducing
Sediment in Placer Mining Wastewater.No date,available
from Alaska Resources Library,Anchorage,Alaska.31 pp.1I
RESPONSE:
Spoil sites are to be located within the impoundment or
within the borrow pits themselves (see Plates F 34 and F 71
of FERC License Application).
During the detailed engineering design of spoil operations,
technical specifications will be developed and incorporated
into the earthwork contract packages concerning final spoil
site selection and procedures for spoil disposal.See the
Response .to Comment 1.425.
RESPONSE TO Cm.1MENT 1.389 (cont •) :
The contents of these specifications will comply with
Federal and State regulatory statutes and will include:
1.Classification of spoil materials;
2.Types of spoil sites (exterior to impoundment,interior
impoundment,permanent -temporary);
3.Pel;'mi t and code requir,ements;
4.Site preparation (stripping,grubbing,stockpiling
organics);
5.Grading and drainage (excavation,construction berms,
dikes);
6.
7.
Erosion control and spoil stabilization (slopes,
surface treatment);
Sedimentation control (settling ponds,treatment);
-.
8.Discharge requirements;
9.Quality control,sampling and testing procedures;and
10.Documentation.
By incorporating these specifications into all earthwork
contracts,continuing long-term earthwork operations will be
accomplished in compliance with appliqable regulations
through application of contract administration techniques
and quality control testing and inspection.
COMMENT 1.390:
"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.We recommend that all disposal be within
the impoundment area and that vegetation slash be burned to
preclude debris accumulations in water entrainment systems.fl
RESPONSE:
As stated on FERC License Application page E-3-253,
generally spoil will be deposited within the impoundments or
in the excavated borrow areas.Spoil disposal,siltation
RESPONSE TO COM.MENT 1.390 (cont.):
control and site rehabilitation will be addressed in detail
in the Project Erosion Control,Waste Management,
Revegetation/Rehabilitation Plans,to be developed by the
Power Authority and reviewed by the appropriate agencies.
COMMENT 1.391:
"Page E-3-268:Paragraph 3:Accurate wetlands maps should
be used .in geotechnical 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."
RESPONSE:
During detailed design,wetland maps at 1:63,360 of the
project area as well as site specific studies along portions
of the access road alignment will be completed prior to and
in conjunction with geotechnical exploration.All wetland
activities will comply with COE,ADEC and ADF&G regulations.
State-of-the-art practices in ice-rich soils and ADOT road
design criteria will be used in the design and construction
of the access road.
Please also refer to the Response to Comment 1.147.In
addition,the Power Authority and the U.S.Fish and Wildlife
Service,Region Seven are currently negotiating an MOD that
will support a joint wetland mapping program.Draft wetland
maps are expected during the winter of 1984-85.
COMMENT 1.392:
"Page E-3-269:Para~raph 3:It is unclear what portion of
the Anchorage to Falrbanks transmission corridor to 'be
widened to accomodate an additional single-tower right-of-
way 190 feet (58 m)wide'has been included in the previous
vegetation assessment (Section 3.3.4(a)and Tables E.3.79,
E.3.80 and E.3.86).The statement that this alignment .'may
depart from the previously established corridor'substan-
tiates our previous concerns that by not evaluating the
Intertie as an integral part of the Susitna project,further
impacts could result from later needs to upgrade the line."
..-
RESPONSE TO COMMENT 1.392:
The additional single-tower right-of-way referenced in
paragraph 3,FERC License Application page E-3-269 of
Exhibit E,refers to the addition of the Devil Canyon
transmission line from Gold Creek to Anchorage.This
results in two lines existing between Gold Creek and Willow
(not including the 1ntertie)and three lines existing
between Willow and Cook Inlet (Knik Arm).FERC License
Application Tables E.3.79 and E.3.86 did not include a
calculation of the area of vegetation to be cleared for the
additional line to Anchorage associated with Devil Canyon.
These have been corrected and are referenced in the Response
to Comment 1.370.FERC License Application Table E.3.80
represents impacts associated with the transmission lines
between Watana and Gold Creek and is not relevant to the
Anchorage-to-Fairbanks corridor.
The statement that the alignment "may depart from the
previously established corridor in locations"was intended
to reflect the possibility that constraints identified.
during construction of the 1ntertie often may be avoided
through route refinement.Major corridor deviations are not
intended.Typical impacts associated with construction of
transmission lines,such as change 'of vegetation,will occur
when the later (Devil Canyon)line is constructed.However,
since it will be adjacent and parallel to the other Susitna
River and the 1ntertie line,the types,locations and
significance of impacts within this corridor can be anti-
cipated as a result of previous construction.
COMMENT 1.393:
"Page E-3-269:Paragraph 4:The referenced 69 kilovolt (kv)
service transmission line has not been previously mentioned
and appears inconsistent the statement that diesel
generators will be used to maintain the camp and village and
construction activities (Exhibit A,Section 1.13(d)(i),page
A-1-27).Please clarify the purpose of this line,proposed
right-of-way,height of utility poles,distance of the
centerline from the access road,and connections at the
Denali Highway end.According to the APA,three
alternatives are under consideration for supplying power
during project construction;(1)a 69kv service transmission
line from Cantwell along the Denali Highway-to-Watana access
route;(2)a transmission line from the Intertie near Gold
Creek along the railroad and access road which follow the
Susitna River;and (3)use of diesel generators (Thomas A.
_______'m_w =_q~,,..~_,_----""',-·.......,...,.·--__..i----------------------
COMMENT I.393 (cont.):
Arminski,APA Deputy Project Manager,personal communica-
tions of September 30,1983).The existence of those three
alternatives should be described in detail in the license
application.We recommend that alternative (3),diesel
generation,be used to avoid impacts of an additional
transmission line."
RESPONSE:
The type of power supplied for project construction and camp
purposes has not yet been finalized.Issues that will be
addressed in reaching a final decision include contractor
preference and flexibility,construction scheduling,power
availability and reserve from the Intertie,and agreements
with utilities to tap Intertie power.
The three alternatives referenced in the Response to
Comment I.393 are still under consideration.While a final
decision has not been made,a combination of diesel and
transmission line is considered most likely.Presently,the
preferred option for supplying transmission line power is
construction of a line from Gold Creek to Watana as shown in
Exhibit G of the License Application (reference Response to
Comment A.7).This line would be energized at 138 kVand
then stepped down to the necessary power requirement at the
construction site.Upon completion of Watana construction
the line would then be upgraded to 345 kV for incorporation
into the Susitna power system.
The 69 kV transmission line option,if selected,would run
from Cantwell along the Denali Highway to the access road,
and then parallel the access road to the construction site.
Placement of this line would be within the right-of-way of
the access road.Typical design characteristics for such a
line include the following:
~.',
~.
o
o
o
o
o
Tower Type
Height
Right-of-way
Proximity to access road -
Connection at Cantwell
Single Circuit wood pole
42-45 feet
Approximately 50 feet
Outside edge of drainage
swale ,
T~?nsformer at Cantwell
Substation
COMMENT I.394:
"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
producti9n 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 vegetation manipulations."
RESPONSE:
A.
B.
As mentioned in more detail elsewhere (I.425),the
Power Authority does not concur with the U.S.Fish and
Wildlife Service's recommendation that all biological
stipulations be adopted as articles of license or (as
presented)contract specifications.
The Power Authority will investigate the feasibility of
enhancing moose browse within the transmission line
right-of-way.If an enhancement program appears
warranted and is embarked upon,an appropriate
monitoring program will be initiated.Please refer to
the Response to Comment I.277 ..
COMMENT I.395:
"Page E-3-273:Paragraph 4:Potential policy conflicts
should be identified in conjunction with access road and
transmission line siting studies.Agreements with public
and private landowners which provide for the mitigation
determined 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 management policies will be adopted.The record
on negotiation settlement proceedings for the Terror Lake
hydroelective project now under construction by the ap-
plicant on Kodiak Island supports such careful planning."
---------.-----.'oor---.--------=
RESPONSE TO COMMENT 1.395:
The Power Authority is presently discussing policy issues
with agencies and landowners including issues dealing with
access and transmission lines.It is the Power Authority's
intent to continue consulting with resource management
agencies,land managers and owners to identify all relevant
issues and resolve conflictst if any.
As.required by FERC regulations,measures and facilities
recommended for mitigation by agencies have been described
in the FERC License Application.When feasible and neces-
sary,agreements with public and private landowners regard-
ing mitigation may be obtained prior to project licensing.
It is anticipated,however,that not all agreements regard-
ing mitigation will be confirmed prior to the license.
Refinements to mitigation plans are a continuous process
based on information received from ongoing studies,site
specific information gathered during field investigation and
information based on detailed design.All of these will
continue after granting of the FERC license.
In addition,given the length of time to completion of the
Project and the dynamic arena of Alaska land use planning,
it is prudent to reexamine policy issues and agreements
prior to,during and after construction.
The Power Authority anticipates that the FERC license issued
for this Project will include FERC's customary and appro-
priate conditions and will not include unnecessary condi-
tions.For example,any mitigation agreements may be
enforced in accordance with their terms and need not be
duplicatively and wastefully enforced through FERC license
conditions.
COMMENT 1.396:
"Page E-3-274:Paragraph 4 and Page E-3-275:Paragraph 1:
The text should explain:(1)inconsistencies between these
figures and those in Section 3.4.2(a);and (2)calculations
of areas where vegetation removal will be minimized."
RESPONSE:
Inconsistencies between figures on FERC License Application
pages E-3-274 and E-3-275,and calculations of areas where
vegetation removal will be minimized have been corrected in
~!
..,..
RESPONSE TO COMMENT I.396 (cont.):
Supplemental Information Request Response 3B-7 provided to
the FERC on July 11,1983.The revised tables and relevant
portions of the text that subsequently required modification
is included in Reference I.370.2 (see February 15,1984 APA
Response Document,Reference Volume).Additicmal
cross-sections to FERC License Application page E-3-252 have
been included in Reference I.370.2 as well.
COMMENT I.397:
"Pages E-3-275 through E-3-281 (ii)Rectification:A pre-
liminary assessment should be made of vegetation cover type
losses from the standpoint of how long each area will be
disturbed.As reclamation and revegetation take effect and
disturbance by construction activities decreases,some
habitat values would be expected to slowly increase.We
agree that predictions of how plant succession will proceed
on these lands over time are difficult to justify.However,
we suggest that the information presented here,coupled with
the successional information presented earlier
(Section 3.3.1(b)[i]and in Table E.3.144)will allow an
assessme.n~of the range of possible vegetation restoration
over time.The typical 10-year time frames within which
each area will be completely out of production must be
coupled with the up to 150 year time spans necessary for
revegetation in order to thoroughly assess project impacts.
Although these losses may be 'temporary,'they are signifi-
cant within the average life-spans of area wildlife.II
RESPONSE:
The statement in the FERC L,icense Application which
discusses the rate of revegetation and states that 150 years
may be required for revegetation refers to development of
mature plant communities on.harsh sites.The intervening
successional phases provide productive habitat.Additional
evaluation will be made during the Mitigation Plan
refinement.Assessments of the rate and direction of
revegetation can be made pa.rt of the site-specific
restoration plans.
COMMENT I.398:
"Page E-3-276:Construction Camp:The text should clarify
the double listing for dismantling and redraining the 78
acres involved here."
RESPONSE TO COMMENT I.398:
The FERC License Application text cites the rehabilitation
action as "dismantling"of the temporary facilities such as
the construction camp and "reclaiming"the area by preparing
the acreage for re-establishment of vegetation.It is
anticipated that the camp will be dismantled in phases and
therefore will likely occur over a two-year period.This is
why the 156 acres required for the construction camp is
split into two pqrts.
COMMENT 1.399:
~I,
"Page E-3-277:Borrow Area D:It appears that an additional _
70 acres should be listed under the excavation and reclama-
tion category for 1986."
RESPONSE:
Under Borrow Area D,on the listing of rehabilitated lands
at Watana,an additional 70 acres should be added under
excavation and reclaiming,for 1986.The revised list
should read as follows:
~,
I"'"'
!
-
COMMENT I.400:
"Pages E-3-279 to 280:(ii)Rectification:Refer to our
Attachment A,Biological St~ipulations,additional
references,and ongoing revegetation 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 site.
"We recommend that the resource agencies have the
opportunity to review and comment on the reclamation plans
at least one year prior to construction.The successful
implementation of reclamation plans would be facilitated by
limiting surface disturbances as the application has
indicated.
"An essential step to achiE!ving reclamation will be to
develop a monitoring program which assigns monitoring
responsibilitie~,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 impleme!TIting additional measures if
initial reclamation objectives are not achieved.
"The text should clarify the process by which 'slopes will
be serrated.'"
RESPONSE:
The Alaska Power Authority anticipates preparing a
Revegetation/Rehabilitation Manual that will describe
rehabilitation and revegetation methodologies.See also the
Response to Comment B.42.The basis for the practice
contained therein will be successful practices used on other
Alaskan projects.·Before the manual is adopted for project
use,it will undergo agency review.The practices contained
in this manual will be applied on a site-by-site basis with
the approval of a monitoring team.The monitoring team will
also assess the efficacy of these rehabilitation measures.
Refer to Response I.119B for additional information on the
monitoring team.
COID1ENT 1.401:
"Pages E-3-28l through E-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-3-28l,last paragraph.A mechanism for promptly
implementing results of the monitoring program is needed
here."
RESPONSE:
As described on FERC License Application pages E-3-6 and
E-3-282,the detailed monitoring plan will be developed
during the detailed engineering design and construction
planning phases of the Project.
The Power Authority anticipates that the DEIS will discuss
and incorporate results of prior monitoring and that the
DEIS may include reasonable and customary monitoring
programs as mitigation options.
COMMENT 1.402:
"Pages E-3-282 through E-3-285:(iv)Compensation:We
support the chosen option for compensation of vegetation
losses.The incremental habitat values gained from
selectively 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 habitat characteristics
also affect the wildlife habitat wildlife habitat values of
potential 'replacement lands'."
RESPONSE:
Comment noted.
9""';
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COlwf.MENT I.403 :
"Page E-3-283:Paragraph 4:and Page·E-3-285:Paragraph 2:
We certainly support the efforts of the ADF&G,the
University of Alaska,and the APA,in conjunction with the
FWS,to develop "a habitat-based model for moose carrying
capacity based on moose bioenergetic requirements and browse
nutritional value."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 modeling
work 3B-8/."
"3B-.~..1 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."
RESPONSE:
Funding levels are now adequate to complete all previously
planned studies by the ADF&G and the Power Authority's
contractors.
COMMENT I.404:
"Page E-3-284:Paragraph 2:We have encouraged the Bureau
of Land Management to widen the time-frame within which they
would undertake the prescribed burn at the Alphabet Hills
site.This would increase the possibility of obtaining
suitable weather,soils,etc.for burning.Specifically,we
recommend that a spring 1984 burn be undertaken.A spring
burn would facilitate an assessment of revegetation and
subsequent wildlife uses."
"....
RESPONSE:
Comment noted.
_______________-'--~,...F.----~------------••---
COMMENT 1.405:
"Page E-3-284:Paragraph 2:We support proposed vegetation
mapping and integregation of that mapping with modeling
efforts.
"Please note that periodic maintenance should be an integral
part of any enhancement programs."
RESPONSE:
"""
The Power Authority recognizes that there are operation and -
maintenance aspects and costs associated with enhancement
programs as indicated by the average annual cost elements
listed in FERC License Application Table E.3.l69.
COMMENT 1.406:
"Pages E-3-285 through E-3-289:(b)Indirect Loss of
Vegetation:While we appreciate efforts to describe areas
subject to erosion,blowdown and other vegetation losses,it
is impossible to fully assess replacement lands or
enhancement needs without some quantification of these
cumulative impacts.We suggest that impact 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-mile reach near the headwaters
of the Watana Reservoir."
RESPONSE:
Please refer to the Responses to Comments 1.336 and 1.344.
As stated in the former Response,quantification of these
impacts will receive continuing attention during impact
assessment refinement.However,it may be best to base
mitigation for the unpredictable losses due to the subject
impacts on objective monitoring data collected during
operation.
COMMENT 1.407:
"pageE-3-286:Paragraph 5:Please refer to our
Attachment A,Biological Stipulations,I.Environmental
Briefings,for further guidelines."
-
,~,
RESPONSE TO COMMENT I.407:
Please refer to the Response to COIIunent I.425.
COMHENT I.408:
IIPage E-2-289:Paragraph 2:We recommend that the APA
determine and pursue agreements on necessary regulatory
options in coordination with Federal and state resource
management agencies as well as private landowners."
RESPONSE:
Public access to and within the project boundary is the
subject of continuing study and assessment.Once a final
decision has been made regarding the extent and frequency of
public access,the Power Authority and agencies may enter
into appropriate agreements to control access (if required).
An access policy will be developed in consideration of the
concerns of adjacent private land owners,the Matanuska-
Susitna Borough,state and Federal resource agencies,the
Power Authority staff,its Board of Directors and
construction and operations managers.See Responses to
Comments A.3,A.6 and A.16.
COMMENT I.409:
"Pages E-3-289 through 291:(c)Alteration of Vegetation
Types:Wetlands mapping referred to in this section has not
been inititated (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),we
find no specific examples here of measures for minimizing
drainage alterations in wet sedge-grass tundra as referred
to on page E-3-259,paragraph 3.As previously mentioned,
we do,however,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:(1)the more detailed vegetation and
wetlands mapping efforts will have been completed and will
be available for use,and (2)resource agency concurrence
will be obtained."
____________-'-,.....,__+--_#"W'rF---~~----------------
RESPONSE TO COMMENT 1.409:
Please refer to the Response to Comment 1.330 for a
description of the wetland mapping.Mitigative siting and
construction techniques designed to minimize drainage
alterations are discussed or referenced in FERC License
Application Section 3.4.2(c).In addition,the text on FERC
License Application page E-3-290 states "Proper engineering
design and construction planning for wetland areas are
considered to be a top-priority component of the project
civil engineering program."The text on that page also
states that "coordination with the COE and USFWS will
continue so that incorporation of proper engineering design
to mitigate for potential drainage alterations is assured."
See also Response to Comment 1.425.
COMMENT 1.410:
"Page E-3-290 "Last Paragraph through Page E-3-291:
Paragraph 1:Reference to monitoring and "ongoing studies
of moose,raptors and other wildlife by the ADF&G and USFWS"
is confusing.While we heartily endorse post and
pre-construction monitoring and studies,and will continue
raptor and swan surveys within our funding constraints and
legislative responsibilities,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."
RESPONSE:"
The Alaska Power Authority is well aware of its respons-
ibilities for funding and implementing project impact
studies.We are beginning at this time the fifth year of
such studies,all of which are funded and implemented by the
Power Authority specifically to assess Susitna Hydroelectric
Project impacts.However,wherever impact assessment and
monitoring efforts can make use of ongoing studies being
funded by other sources,the Power Authority intends to make
maximum use of them.
COMMENT 1.411:
"Page E-3-291:Section 3.4.3 -Mitigation Summary:This
section lacks a comprehensive analysis of overall project
impacts,potential for achieving mitigation priorities and
-
I~
COMMENT 1.411 (cont.):
tradeoffs among mitigation options for various area
resources."-RESPONSE:
As explained on FERC License Application page E-3-251,the
information requested by the reviewer is provided in FERC
License Application Section 3.4.2,Option Analysis (pages
E-3-252 through E-3-291).As further noted on FERC License
Application page E-3-251,the mitigation summary (Section
3.4.3)is intended only to provide a brief listing of
mitigation measures already proposed for botanical resources
in FERC License Application Section 3.4.2.We believe that
the information provided in FERC License Application Section
3.4.2 amply provides the information requested by the
reviewer.
COMMENT 1.412:
IITable E.3.49:The taxa,Papaver alboroseum,was withdrawn
from consideration as a candidate threatened or endangered
species (FR 45,December 15,1980)."
RESPONSE:
The Power Authority appreciates the correction.
COMMENT 1.413:
"Table E.3.51:The text should indicate whether the mesic
sedge-grass classification here and in Table E.3.71 and
E.3.72 is the same as the sedge-grass classification in
Tables E.3.52,E.3.77 E.3.80 and E.3.83 through E.3.86."
RESPONSE:
Mesic sedge-grass tundra should be listed as sedge-grass
tundra.
COMMENT 1.414:
IITable E.3.71 and E.3.72:There is an apparent
inconsistency between the t,ext which says that 1 %of the
study area is open spruce and these tables which show nearly
______________.r-f--~-·------~-------·~.,..I,----------------------
,¥
COMMENT 1.414 (cont.):
8%of the Watana Watershed and over 2%of the Gold Creek
watershed to be open forests (Section 3.2.2(b)(i),
paragraph 1).11
RESPONSE:
The percentage of the Watana and Gold Creek watersheds
covered by open spruce forest is 8%and 2%,respectively,as
stated in Tables E.3.71 and E.3.72 of the FERC License
Application.The text (page E-3-206)was incorrect.
COMMENT 1.415:
IITable E.3.79:The vegetation classification is not
directly comparable to that used for other transmission line
segm~nts,Tables E.3.77, E.3.78,E.3.80 and E.3.86.11
RESPONSE:
Please refer to the Response to Commment 1.327.
COMMENT 1.416:
IITable E.3.3.81:Please refer tq our comments on the
inadequacy of this correlation,Section 3.2.3.11
RESPONSE:
Please refer to the Response to Comment 1.332.
COMMENT 1.417:
"Table E.3.82:Please refer to our comments on the
inaccuracies in wetland typing which make this table
meaningless,Sections 3.2.3 and 3.3.5."
RESPONSE:
As indicated in the Response to Comment 1.330,the FERC
License Application recognized the scope of the available
wetland maps (see pages E-3-222 through E-3-224),and also
indicated that new mapping would be conducted.Although the
numbers in FERC License Application Table E.3.82 represent
conservatively high figures for the areal extent of wetlands
affected by project facilities,they do represent
-
-
RESPONSE TO COMMENT I.417 (cont.):
preliminary estimates useful for comparison purposes and
environmental impact study.
COMMENT I.418:
"Tables E.3.83 and E.3.84:Potential spoil areas outside of
the impoundment or already disturbed areas should be
quantified here."
RESPONSE:
All spoil areas will be located within the impoundment or
the borrow pit from which the spoil was excavated.The only
area disturbed to date is in the immediate vicinity of the
Watana Camp already included in the tables.No
modifications to the tables are required.
COMMENT I.419:
"Table E.3.86:Please refer to our comments under
Section 3.3.4(a)regarding calculation errors which
apparently result in double counting'of forest,shrub,
tundra and unvegetated cover types.Mosaics of two or more
vegetation cover types may sometimes be 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 tables or discussions.Where
Table E.3.86 refers to an adjustment of right-of-way width,
there is no explanation of how that adjustment was made.It
appears that recalculation of transmission line impacts on
the basis of a 300-foot clearing width used in Table E3.86
as compared to the 400-foot clearing width used in
McKendrick et ale (1982)was by a straight proportion.3B-9/
As the line is finalized and assuming vegetation is remapped
in a manner more meaningful to wildlife,the affected
vegetation types should be recalculated.Quantification of
potential 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."
"3B-2..1 'See Footnote 3B-8.[Footnote 3B-.!U APA.September
8,1983.Appendices 2 and 3 to Agenda Item IV,Action
No.1,FY 1983 Program Changes and Their Impact on the FY
COMMENT I.419 (cont.):
1984 Program and Current Proposed FY 1984 Budget Allocations
Susitna Hydroelectric Project.Prepared for the APA Board
of Directors.]11
RESPONSE:
Please refer to the Response to Comment 1.365 concerning
Table E.3.86 and elimination of double counting and
adjustment of right-of-way width.As stated in the footnote
of revised Table E.3.86 (refer to the Response to
Comment 1.370),the Tanana Flats portion of the transmission
corridor is an area of extremely complex mosaics of vege-
tation types.As a result,various complexes were recog-
nized.
There are no current plans to remap the vegetation in the
transmission corridor from Healy to Fairbanks or Willow to
Cook Inlet.We believe that the 1:63,360 scale mapping
conducted to date along these segments is adequate for
assessing transmission line impacts.
The quantification of increased browse production along the
transmission line segments will be addressed during ongoing
impact assessment and mitigation plan refinement efforts.
COMMENT 1.420:
IIATTACHMENT C
..Recornmended Construction Methods for Mitigating Impacts to
Wetlands which cannot be Avoided by Project Development
liThe first step in outlining mitigation recommendations
pertinent to activities affecting wetlands is to define
'wetland.'This has been descriptively done in Chapter 3 of
Exhibit E.However,until the wetlands mapping proposed and
commented upon in Sections 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 permafrost,
construction activities may need to be further altered."
RESPONSE:
Please refer to the Response to Comment 1.330.
~,
COMMENT I.42l:
"ATTACHMENT C
"Recommended Construction Methods for Mitigating Impacts to
Wetlands which cannot be Avoided by Project Development
"The following is based on options outlined by the applicant
in the Supplemental Submittal to FERC,Volume IIA of III.
We are here providing further information and
recommendations.
"(A)Construction methods in wetlands:
....
Clearing and construction should be undertaken when the
group.d is frozen;access should be by ice roads.
Excavated spoil should not be wasted in wetlands.The
workpads and access roads should be constructed so as
to prevent thermal degradation while providing
structural integrity.
Slash disposal in wetlands should be prohibited.
Hand clearing should be utilized to avoid scalping or
removal of the vegetative mat.
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 wetlands and
waterbodies.
r~2.
3 .
4 .
.~
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."
-
RESPONSE:
These recommendations are a useful expansion of the recom-
mended construction methods for mitigating impacts to
wetlands already listed in FERC License Application
Section 3.4.They will be considered during development of
the Design Criteria Manual or during the Susitna Settlement
Process (see the Respon"ses to Comments I.424 and I.425).
-
-,-------..,.,------------~~_._._----------------_.-
COMMENT 1.422 :
"ATTACHMENT C
"Recommended-Construction Methods for Mitigating Impacts to
Wetlands which cannot be Avoided by Project Development
"The following is based on options outlined by the applicant
in the Supplemental Submittal to FERC,Volume IIA of III.
We are here providing further information and
recommendations.
"(B)Techniques for minimizing alterations to wetland
drainage patterns:
1.Hydrologic assessments 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,elevation~
of culvert inverts determined,and direction of water
flow noted and culvert size determined.
2.
3.
4 .
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 less)should
be designed to handle a five-year flood event and
permanent culverts (i.e.,to remain in use for more
than two years)should be designed to handle a 50-year
flood event.
Install culverts with sufficient camber to prevent
settlement.The camber may also be dependent upon fish
passage requirements.
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 pr€clude
thermokarst).
5.Install steampipes in culverts where icing is likely to
occur.The steamfitted uprights should be installed to
provide access in snow and ice conditions.Guide
,-~
,-
COMMENT 1.422 (cont.):
markers to the steam pipes will need to be able to
withstand.
RESPONSE:
See the Responses to Comments 1.424 and 1.425.
COMMENT 1.423:
"ATTACHMENT C
"Recommended Construction M,ethods for Mitigating Impacts to
Wetlands which cannot be Avoided by Project Development
liThe following is based on options outlined by the applicant
in the Supplemental Submittal to FERC,Volume IIA of III.
We are here providing further information and
recommendations.
II (C)Additional recommendations for mitigating impacts of
road construction on wetlands are:
1.Any placement of fills in a watercourse should be
perpendicular to the stream flow.
2.
3 •
Roads should be maintained in a crowned configuration
and maintenance activities should be accomplished so as
to prevent material be:ing pushed into drainages,
blocked culverts,or roadside berms along the driving
surface.
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."
,.,..
RESPONSE:
See the Responses to Comments 1.424 and 1.425.
COrA..MENT I.424 :
IIATTACHMENT C
IIRecommended Construction Methods for Z.1i tigating Impacts to
Wetlands which cannot be Avoided by Project Development
liThe following is based on options outlined by the applicant
in the Supplemental Submittal to FERC,Volume IIA of III.
We are here providing further information and
recommendations.
II (D)Case by case exemption to the above recommendations
may be granted by the interagency monitoring team.II
RESPONSE:
Wetlands construction activities are regulated and permitted
by the U.S.Army Corps of Engineers (CaE)pursuant to
Section 404,Clean Water Act,33 U.S.C.§1344.Any
modifications to the permitted activity must be submitted by
the CaE and exemptions cannot be granted by other agencies.
It would be duplicative,unnecessary,unauthorized and
perhaps dangerous for the interagency monitoring team to
exercise a portion of CaE's legislative authority.
"'"
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COMMENT I.425:
"ATTACHMENT A
"Biological Stipulations
"By incorporating the Environmental Guidelines of
Appendix E3.B,Chapter 3,Exhibit E of the draft Susitna
Hydroelectric Project Federal Energy Regulatory Commission
(FERC)License Application '",ith other stipulations
applicable to Alaska construction projects,a set of project
stipulations has been compiled.It is our recommendation
that these stipulations be incorporated into the FERC
license as a binding exhibit.They should then become part
of project contracting agreements.
II Preamble
IIImplementation of these stipulations are appropriate during
the construction,operation and maintenance,and termination
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,shall
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.II
RESPONSE:
The Power Authority is disa.ppointed that the DOl/Office of
the Secretary fails to understand or respect the Susitna
Settlement Process.The Power Authority strongly objects to
this attempt to avoid the Settlement Process by directly
proposing specific license conditions to the FERC.
Pursuant to the Settlement Process (see also Responses to
Comments B.59,F.l,F.6 and F.28),the development of
specific project stipulations should involve a concerted
effort by the Susitna ProjE!ct environmental and engineering
personnel,as well as state,Federal and local regulatory
agencies,to ensure that all comments are considered.Any
and all resulting stipulations should address broad-based
requirements to avoid precluding planning efforts and/or
RESPONSE TO COMMENT 1.425 (cont.):
conflicts with individual agency stipulations and
regulations ~and reduce the repetition of concerns
stipulated.
The Power Authority has scheduled the development of
environmental plans with reviews by appropriate agencies for
the following:Waste Management;Erosion Control;Fuel and
Hazardous Materials Management and Revegetation/
Rehabilitation.Design Criteria and Construction Practices
Manuals along with the Access Road Report,Transmission Line
Report and Camp/Village Siting Report will be prepared to
provide the vehicles for addressing many of the specific
items listed as DOl recommended Biological Stipulations.
The Power Authority also objects to the DOl/Office of the
Secretary's attempt to preempt the DEIS and FEIS NEPA
process.By apparently making its own decisions before the
NEPA process is complete,DOl/Office of the Secretary
blatantly fails to discharge its own duties under NEPA (see,
for example,40 C.F.R.§§1500.1(b)(obligation to ensure
environmental information is available "before decisions are
made"by federal agencies),1502.2(g)(EIS to serve as means
of assessing impacts rather than "justifying decisions
already made"),1502.5,1502.14 (DOl/Office of the
Secretary's decisions preclude other alternatives,which are
the "heart of the environmental impact statement lr ),1505.2
(DOl/Office of the Secretary fails to provide a record of
its decisions),1506.1(a)(2)(DOl/Office of the Secretary
decisions improperly "limit the choice of reasonable
alternatives")and 1506.10).The Power Authority urges the
FERC not to join or countenance these failures.
COMMENTS 1.426 -1.489:
Please refer to individual Biological Stipulations
identified as Comments 1.426-1.489 on pages 71-83 of
December 12,1983 Department of the Interior/Office of the
Secretary comment letter.
RESPONSE:
Reserved for Susitna·Settlement Process.See Response to
Comment 1.425.
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-
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COMMENT I.490:
lIAccess Roads
lIPage E-3-256 Side Borrow adjacent to or access balanced cut
and fill techniques will minimize certain impacts,however,
materials must 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.
"Page E-32-264 is two to three feet of road crown,enough in
areas of perrnafrost?lI
RESPONSE:
Please refer to Responses to Comments A.4 and I.288.
COMMENT I.491:
"Fish:We submit that the quality of the fisheries is
highly dependent on water use and quality.The Chapter 2
analysis has some deficiencies most notably a valid
temperature model and the lack of data on fish use
downstream of Chulitna River."
RESPONSE:
This comment is the same as Comment A.9 for which a response
has been prepared previously.See Response to Comment A.9.
COMMENT I.492-:
lIVegetation:Vegetation section lacked quantification of
areas which could be affected by changes in cover.A given
species may benefit by vegetation cover changes whereas
-other species may be adversely affected.The vegetation map
should be improved to better analyze moose and bear
habitat.11
RESPONSE:
Areas of vegetation to be affected by changes in cover as a
result of temporary facility construction,dismantling and
reclamation are quantified in Exhibit -E,Chapter 3,
Section 3.4.2 (a)(ii),pages E-3-276 through E-3-278.We
"F if'"""''''''"''
RESPONSE TO COMMENT I.492 (conte):
concur ~Yi th the Commentor's statement that II a given species
may benefit by vegetation cover changes whereas other
species may be adversely affected.1I This point is discussed
further in the Response to Comment I.277.
COMMENT I.493:
IIWildlife: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 mentioned.The dam will inundate Bald
Eagle and Golden Eagle nest sites,which is in violation of
the Bald Eagle Protection Act.1I
RESPONSE:
Please refer to the Responses to Comments A.11 on the Jay
Creek mineral lick and Comment I.210 on the Bald Eagle
Protection Act.
,.
COMMENT I.494:
"In summary,mitigation agreements should be arranged with
landowners prior to licensing and 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."
RESPONSE:
As mentioned elsewhere (see Responses 1.81 and I.301B),the
Power Authority or the State of Alaska,Department of
Natural Resources will,in all likelihood,have title to
project lands for facilities.During the construction
phase,some temporary construction facilities may be on
lands leased from adjacent landowners.
Mitigation lands that are not located on project lands will
probably be located on state lands.Management activities
will have to be arranged with the Department of Natural
Resources,the land manager.Thus,it is anticipated that
the Susitna Hydroelectric .Project license applicant (the
State)is also the landowner for most mitigation lands.An
Interagency Land Managment Transfer will probably be
executed between DNR and the Power Authority for project
~-
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-
RESPONSE TO COMMENT I.494 (cont.):
lands.A Memorandum of Agreement providing for joint
Management activities would probably be used for mitigation
lands.See also Responses I.BI and I.119B~
COMMENT I.495:
"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
60.6{d».We view these items as representing part of a
significant entity,whose components may lack individual
distinction (36 CFR 60.6(c)."
RESPONSE:
See the Responses to Comments A.2 and I.496 (below).
COMIvlENT I.496 :
"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 app:l;icant'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."
RESPONSE:
The Alaska Power Authority ·anticipates that a reasonable
cultural resources mitigation plan for the Project will
include provisions for surveys of the locations of all
project facilities (such as transmission lines and access
roads)whose exact locations have not been established at
the time of FERC license issuance and which have not'been
_,---...,..-------~-----I""•re =--..-----~------------
RESPONSE TO CO~~ENT 1.496 (cont.):
identified through archeological sensitivity modeling as
having a likelihood of containing cultural resources.All
cultural resources identified during archeological surveys
(both pre-and post-PERC license)will be evaluated in terms
of a relative significance framework,which consists of a
site classification system and a set of criteria against
which the ability of a particular site to contribute to the
solution of specific significant research questions can be
measured.The results of this evaluation will,in turn,be
used to determine whether total,partial or no data recovery
(e.g.,salvage excavation)will be necessary at those sites
whose destruction cannot otherwise be reasonably avoided by
project modifications or other means.
This approach has been informally reviewed with
representatives of the State Historic Preservation Office
and other agencies,and should satisfy all cultural resource
regulatory requirements for the Susitna Hydroelectric
Project.
See also the Response to Comment A.12.
COMMENT 1.497:
"CHAPTER 5.SOCIOECONOMIC IMPACTS
lIGeneral Comments
lIThis evaluation should include:(1)a widely accepted
projection of future population and economic growth
(increasing user groups)or,if there is substantial
uncertainty as to the validity of key assumptions (as we
believe there is),then a 'multiple scenario model should be
pursured examining at least high,medium,and low projects;
and (2)tradeoff analysis examining the competing mitigation
proposals for the different interests.Chapter 5 fails in
respect to both points."
RESPONSE:
Socioeconomic projections for the Susitna Project were
developed through the use of an integrated econometric
model.The estimated socioeconomic impacts,which were
presented in the FERC License Application,addressed the
~,
""l,
44R;;;;;g;;;;57 T
RESPONSE TO COMMENT I.497 (cont.):
residency and movement of Project construction and operation
personnel,adequacy of available housing,and impacts on
public services and facilities,fish and wildlife user
groups,and local government revenues and expenditures.
Harza-Ebasco conducted a workshop in July 1983 to facilitate
a broader understanding by interested agencies and the
general public of the analytical approach,assumptions and
methodologies used to forecast potential socioeconomic
impacts of the Project.Working Paper No.1 (Susitna
Hydroelectric Project Subtask 4.5 Socioeconomic Studies:
Projection Assumptions,Methodology,and Output Formats)
provided workshop participants with specific assumptions and
methodologies used to forecast potential impacts.The paper
addressed in detail the structure of the model,including
the economic-demographic,public facilities and services and
fiscal moduies and their linkage.
Since preparation of this publication,the baseline and
with-project projections have been revised in response to
changing economic conditions in Alaska,the Railbelt and the
Mat-Su Borough,and in light of new community-specific data.
Three scenarios for transporting construction workers to the
project site were used in updating the projections,
including the use of personal vehicles,buses and fixed-
wing aircraft.The revised proj ections,\'lhich will be
updated annually,will be available in February 1984.
A mitigation plan update,which will be prepared in early
1984,will delineate measures that can be implemented to
eliminate or reduce identified adverse socioeconomic
impacts.
REFERENCES
Frank Orth &Associates,Working Paper No.1,Susitna
Hydroelectric Project Subtask 4.5 Socioeconomic Studies:
Project Assumptions,Methodology and Output Formats (July,
1983)•
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COMMENT 1.498:
"Page E-5-6:(b)Population:The population projections
are outdated.Impact analyses and mitigation planning are
tied to population projections with and without the project.
We recommend that the population projections be updated."
RESPONSE:
The population projections have been revised to reflect data
collected in household,business and public sector surveys
in Talkeetna,Trapper Creek and Cantwell and from updated
secondary data,including revised projections made by the
Institute of Social and Economic Research based on refor-
mulated assumptions regarding anticipated economic activity
in Alaska,the Railbelt and the Mat-Su Borough.The
baseline and with-project projections will be available in
February 1984.
COMMENT 1.499:
npage E-5-6:.(b)Population:Paragraph 5:The Knik Arm
crossing should not be considered 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 comunities indicated.1I
RESPONSE:
The alternative corridors as well as a no action alternative
will be evaluated in the Alaska Department of Transportation
and Public Facilities'Draft Environmental Impact Statement,
which is expected to released in June 1984.According to
the current schedule,the Knik Arm crossing is expected to
be completed in 1990.
This information is in agreement with the assumption used in
the FERC License Application.
~-
~,
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C014MENT I.50~:
KPage E-5-24:lb)Population:Paragraph 2:We concur with
the underlying assumption that,in Alaska,population growth
is strongly associated with natural resource development
projects.An updated evaluation of the projects which are
expected to be developed should be provided in this
section."
RESPONSE:
The following table outlines other major potential
developments in or affecting the Railbelt region,and
presents their associated employment projections.These
projects constitute the base case exogenous employment
assumptions for the Institute of Social and Economic
Research's Man in the Arctic Program Economic Model which
was revised in May 1983.This information was subsequently
incorporated into the revised socioeconomic projections,
which will be available in February 1984.
TABLE 1
SUMMARY OF BASE CASE EXOGENOUS EMPLOYMENT ASSUMPTIONS
FOR MAP MODEL RAILBELT ECONOMIC STUDY
';.
".-,
-
Assumptions
Trans-Alaska Oil Pipeline
North Slope Petroleum
Development
Upper Cook Inlet Petroleum
Production
Tertiary Recovery of North
Slope Oil
Description
Operating employment remains
constant at 1,500 through
2010.
Construction employment
developing Prudhoe Bay and
Kuparuk fields peaks at 2,400
in 1983 and 1986.Operating
employment remains at 2,502
through 2010 for overall North
Slope production.
Employment declines gradually
beginning in 1983 so as to
reach 50 percent of the 1982
level (778)by 2010.
Tertiary oil recovery project
utilizing North Slope natural
gas occurs in early 1990s with
a peak annual employment of
2,000.
RESPONSE TO COMMENT 1.500 (cont.):
Table 1 (cont.)
SUMMARY OF BASE CASE EXOGENOUS EMPLOYMENT ASSUMPTIONS
FOR MAP MODEL RAILBELT ECONOMIC STUDY
Assumptions
OCS Exploration and
Development
Anchorage Oil Headquarters
Beluga Chulitna Coal
Production
Hydroelectric Projects
U.S.Borax Mine
Description
The current OCS five year
leasing schedule calls for
16 OCS lease sales subsequent
to October 1982,including the
Beaufort,Norton and
St.George sales,which have
already taken place (Sales 71,
57 and 70).Development is
assumed to occur only in the
Navarin Basin (1.14 billion
barrels of oil)and the
Beaufort Sea (6.1 billion
barrels of oil).All other
sales are assumed to result in
exploration employment only.
Several oil companies estab-
lish regional headquarters in
Alaska in mid-1980s.
Development of 4.4
million ton/year mine for
export beginning in 1994
provides total employment of
524.
Employment peaks at 725
in 1990 for construction of
several state-funded
hydroelectric projects around
the state.
The U.S.Borax mine
near Ketchikan is brought into
production with oper-ating
employment of 790 by 1988.
"'"",
-
RESPONSE TO COr-lMENT I.500 (cont.):
Table 1 (cont.)
SUMMARY OF BASE CASE EXOGENOUS EMPLOY~lENT ASSUMPTIONS
FOR MAP MODEL B~ILBELT ECONOMIC STUDY
.....
-
Assumptions
Greens Creek Mine
Red Dog Mine
Other Mining Activity
Agriculture
Forest and Lumber Products
Pulp Mills
Commercial Fishing-
Nonbottomfish
Description
Production from the Greens
Creek Mine on Admiralty Island
results in employ-ment of
315 people from from 1986
through 1996.
The Red Dog Mine in the
Western Brooks Range reaches
full production with operating
employ-ment of 448 by 1988.
Employment increases from
a 1982 level of 5,267 at one
percent annually.
Moderate state support
results in expansion of
agriculture to employment of
508 in 2000.
Employment expands to
over 3,200 by 1990 before
beginning to decline gradually
after 2000 to about '2,800 by
2010.
Employment declines at a
rate of one percent per year
after 1983.
Employment levels in fish-
ing and fish processing
remain constant at 6,323 and
7,123 respectively •
RESPONSE TO COMMENT I.500 (cont.):
Table 1 (cont.)
SUMMARY OF BASE CASE EXOGENOUS EMPLOYMENT ASSUMPTIONS
FOR MAP MODEL RAILBELT ECONOMIC STUDY
~I
~,
Assumptions
Commercial Fishing-
Bottomfish
Federal Military Employment
Federal Civilian Employment
Tourism Assumptions .
COMMENT I.501:
Description
The total U.S.bottomfish
catch expands at a con-
stant rate to allowable catch
in 2000,with Alaska resident
harvest-ing employment rising
to 733.Onshore proces-sing
capacity expands in the
Aleutians and Kodiak census
divisions to provide total
resident employment of 971 by
2000.
Employment remains con-
stant at 23,323.
Rises at 0.5 percent
annual rate from 17,900 in
1982 to 20,583 by 2010.
Number of visitors to
Alaska increases by 50,000 per
year from 680,000 in 1982 to
over 2 million by 2010.
~,
"Page E-5-27:3 -EVALUATION OF THE·IMPACT OF THE PROJECT:
The evaluation 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 project employs.We would
agree that establishing a number,or narrow range,for this
potential impact would be difficult.However,to ignore
this potentially overwhelming factor would render 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
Pipeline System and Terror Lake hydropower project.
-
CO~lENT I.501 (cont.):
"We recornrncend 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
sa.me time and in the area Cif more direct project-related
impacts to these resources.Activities such as trapping,
fishing,hunting,berry-gat.hering,and disruptive uses of
fish and wildlife habitats would be expected to increase,
possibly resulting in great.er regulation of consumptive fish
and wildlife uses."
RESPONSE:
2.As'indicated in the Response to Comment I.498,the
socioeconomic impact projections have been revised to
reflect updated baseline conditions.These projections
will be available in April 1984.
-(
-
1.
3 •
The effects of speculative inmigration on the economy
were not specifically addressed in the FERC License
Application.Because the Susitna Project could attract
job seekers who are not successful in obtaining work on
the Susitna Project,it is important to examine the
potential for speculat,ive inmigration and its potential
to increase job displacement,unemployment,and ser-
vices and facilities.
For additional information on this topic,please refer
to Response to Comment A.14.
The Power Authority generally agrees with the
assessment in paragraph 3 of this Comment.Options for
reducing impacts to fish and wildlife user groups are
discussed in the Response to Supplemental Information
Request 5-26.
REFERENCES
Alaska Power Authority,Response to FERC Supplemental
Information Request 5-26 (1983),previously submitted to the
FERC on July 11,1983.
___-,~~,_~:;a:o r__·w •---------------------
COMMENT 1.502:
"Page E-5-79:(a)Natu'ral Resource -Dependent Businesses:
We recommend that guides registered for Game Management Unit
(GMU)13 be surveyed to determine their reliance on GMU 13.
Since most of these guides are also registered for other (up
to three)GMU's it is difficult to determine,without a
survey,the present reliance of these guides on Gl1U 13 and
thus the potential impact of the project on this group."
RESPONSE:
In conjunction with the FY 1985 Social Science Program Work
Scope approved by the Power Authority Board of Directors,a
survey of project area guides is anticipated.The survey
should be useful in determining project impacts on guides
utilizing GMU 13.
COMMENT 1.503:
"Page E-5-80:(a)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 resources to be unknown.
"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."
RESPONSE:
The Power Authority anticipates refining information about
the project's potential impacts on fish and wildlife
resource users.Recently completed household and business
surveys of Talkeetna,Trapper Creek and Cantwell residents
will help supplement the information presented in the FERC
License Application.The household survey included ques-
tions 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 cultural pursuits.The business survey included ques-
tions on the percent of gross annual revenues attributable
to hunting,fishing and trapping activities;what areas are
important to those activities;and what species are hunted,
~I
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RESPONSE TO COMMENT I.503 (cont.):
fished and trapped as part of their business.The results
of the surveys,which will indicate the importance of the
project area to natural resources dependent businesses,are
being tabulated,and a summary report will be available in
March 1984.
COMMENT I.504:
"Page E-5-80:3.7-Local and Regional Impacts on Fi$h and
Wildlife Groups:Please rE~fer to the above comments and our
remarks on Chapters 2 and 3.11
RESPONSE:
Please refer to the Responses to Comments I.15 through
I.149.
COMMENT I.505:
IIPage E-5-96:(a)Methodol0:s.Y.:We consider'it premature to
conclude that impacts downstream of Talkeetna would be
'limited'to the extent that they can be dismissed.The
number of fish utilizing the reach downstream of Talkeetna
is much higher than the number using the reach between
Talkeetna and Devil Canyon.Thus,a smaller adverse impact,
resulting in a loss t6 a small percentage of this fishery
could mean a greater loss of fish.The examination also
appears to consider spawning access to sloughs between
Talkeetna and Devil Canyon to be the sole determinant 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 some
of these factors."
RESPONSE:
The Power Authority has conducted considerable study on the
fishery resources downstream of Talkeetna.These studies
are discussed in the Responses to Comments I.98,I.99 and
B.8.
The discussion of access conditions to spawning areas within
side sloughs is only part of the entire discussion of the
-_._...-......._------,----,-----------'-----
RESPONSE TO COMMENT 1.505 (cont.):
potential effects to fishery resource~in the Devil Canyon
to Talkeetna reach of the Susitna River.The Power
Authority does not agree that Exhibit E states or implies
that the sole determinant of fish losses hinges on access to
the sloughs.The Power Authority has clearly recognized,as
discussed in the FERC License Application,that spawning,
incubation and rearing habitats in the sloughs may be
affected because of reduction in groundwater upwelling,
changes in the ice processes,changes in the temperature
regimes and changes in the frequency of overtopping of the
upstream berms.As a result,many aspects of the mitigation
plan presented in the License Application are designed to
protect these habitats given the anticipated changes.
The referenced AEIDC report was prepared and distributed in
final form on January 20,1984 and does provide further
elucidation of the interaction of some factors and the
fishery resources.
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 1.506:
-
II Page E-5-98:(l)Specific Impacts:The discussion again
fails to recognize the potential impact to fisheries down-
stream 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 terms 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).n
RESPONSE:
Concerning potential impacts to fisheries downstream of
Talkeetna,please refer to the.Responses to Comments I.98,
1.99,I.5D5 and B.8.See also the ADF&G 1982 Stock
Separation Feasibility'Report.
Even without the project,it is still questionable if the
-
RESPONSE TO COMMENT I.506 (cont.):
upper river could be used for salmon because (1)the passage
facilities (i.e.,fishways)required for natural production
would not produce a favorable cost/benefit ratio,and
(2)the success of artificially introducing outmigrantsto
upstream areas would need field verification of some of the
report assumptions prior to development of a large-scale
program.Accordingly,the Power Authority believes that
future opportunitie's for en.hancement of salmon above Devil
Canyon are not favorable.If the ADF&G actively pursues any
upriver enhancement options;for salmon and demonstrates that
these options are viable,t.he implications will be examined
in relationship to project construction and operation
mitigation plans.
The scenarios developed in FERC License Application
Exhibit E,Chapter 5,conce:rning commercial fishing,assume
a 100 percent loss in salmon populations for analysis.The
Power Authority has described mitigation plans in FERC
License Application Chapter 3 tha.t are designed to avoid and
minimize such losses so as to maintain the existing
fisheries resources.There~fore,there is no expectation
that there will be a loss of either commercial fishing,
induced job creation,or fisheries resources.
REFERENCES
ADF&G,Su-Hydro Stock Separation Feasibility Report,Adult
Anadromous Fisheries (1982).
COt1MENT I.507:
"Page E-5-l00:(c)Non-Commercial Use -The Sport Fishery:
We recommend that this section provide an examination of
impacts for the resident fisheries of the impoundment zones.
"In conjunction with identifying potential impacts to the
sport fishery,impacts to the sports fisherman should be
evaluated.Efforts to evaluate these impacts,as stated
above,have been dropped (reference response W-5-020 in
Chapter 11).We recommend that these studies be reinstated.
The type of evaluation necessary should be discussed with
the appropriate resource agencies."
-----,......,........------
RESPONSE TO COMMENT 1.507:
Impacts to resident fisheries of the impoundment zone have
been addressed in Section 2.3 in Chapter 3,Exhibit E of the
FERC License Application.Mitigation plans to avoid or
minimize these losses are described in Section 2.4 in
Chapter 3.
The Power Authority anticipates refining the information
about the project's potential impacts on users of fishery
resources.The U.S.Forest Service has provided the Power
Authority with estimates of sport fishing values in Alaska
(Mehrkens,personal communication 1983).Recently completed
household and business surveys of Talkeetna,Trapper Creek
and Cantwell residents will help supplement the information
presented in the License Application.The household survey
included questions on the number of persons in each house-
hold who fish;where and how often they fish;what species
they fish;and the importance of fishing for recreation,
food,income and cultural pursuits.The business survey
included questions on the percent of gross annual revenues
attributable to fishing;what areas are important to those
activities;and what species are fished as part of their
business.The results of the surveys are being tabulated,
and a summary report will be available in March 1984.
REFERENCES
U.S.Forest Service,Joe Mehrkens,Regional Economist,
personal communication to Ellen Hall,Envirosphere
(December 12,1983).
COMMENT 1.508:
"Page E-5-100:Cd)Non-Commercial Use -Subsistence Fishing:
The impact of the project on subsistence fishery use has not
been evaluated.The importance of the Susitna River system
to subsistence,potential losses of subsistence resources,
and how mitigation proposals affect subsistence use should
be addressed.The data currently provided is not applicable
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 -
.....
-
CO~~ENT 1.508 (cont.):
use,clearly distinguishing between sport and subsistence
fishing.As we have previously stated (see Chapter 11,
response W-I0-038),additional references are a~ailable on
this subject.5-1/"
"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."
RESPONSE:
The Power Authority anticipates refining information about
the Project's potential impacts on fish and wildlife
resource users.As discussed above,the Forest Service ha~
provided the Power Authority with estimates of sport fishing
values in Alaska (Mehrkens,personal communication 1983).
Recently completed household surveys of Talkeetna,Trapper
Creek and Cantwell residents will help supplement the
information presented in the FERC License Application.The
household survey included questions on the number of persons
in each household who fish,species caught,the location and
frequency of fishing and the importance of fishing for
recreation,food and cultural pursuits.The questions on
the importance of fishing for recreation,food and cultural
pursuits were asked to differentiate between subsistence and
sports fishing.The results of the surveys will be
available in March 1984.
REFERENCES
u.S.Forest Service,Joe Mehrkens,Regional Economist,
personal communication to Ellen Hall,Envirosphere
(December 12,1983).
COMMENT 1.509:
"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 wildlife essential to the
livelihood and lifestyle of many AlaSkan residents should be
discussed and quantified here.
COMMENT I.S09 (cont.):
I1Quantification of impacts to game species (reference our
comments on Chapter 3 of the Exhibit E)and of the sub-
sistence use of those resources is inadequate.Analysis of
economic impacts to hunters,subsistence users,and as-
sociated businesses should occur after quantification of
wildlife impacts and formulation of mitigation proposals.II
EESPONSE:
The Power Authority anticipates refining information about
the Project's potential impacts on fish resource users.
Recently completed household surveys of Talkeetna,
Trapper Creek and Cantwell residents will help supplement
the information presented in the FERC License Application.
The household survey included questions on the number of
persons in each household who hunt,fish and trap;what
species they hunt,fish and trap;and the importance of
hunting,fishing and trapping foar recreation,food,income
and cultural pursuits.The results of the surveys are being
tabulated,and a general report will be available in March
1984.
COMMENT I.SI0:
"Page E-S-I02:(i)Guides and Guide Services:Please refer
to our-comments on page E-S-79."
RESPONSE:
Please refer to the Response to Comment I.S02.
COMMENT I.Sll:
I1Page E-S-I03:(i)Guides and Guide Services:Last
Paragraph on Page Through Page E-S-I04:The availability
and quality of guide services and current use of alternative
hunting areas should be discussed.These factors,together
with the remote nature of project and alternative hunting
areas,will determine the magnitude of project impacts on
area guiding and of secondary impacts on alternative areas.
The suggestion that guides and their clients can move to
other hunting areas is analogous to the suggestion that
wildlife may move to adjacent areas when their habitats are
altered or destroyed.
"Page E-S-104:(i)Guides and Guide Services:Paragraph 2
on page:The potential for blocking of caribou movements
remains unknown.Chapter 3,Sections 4.3.l(b)and 4.3.3(b»
~I
-~-
~-
COMMENT I.511 (cont.):
described possible significant decreases in caribou subherd
populations.Potential population losses will affect
hunting quality and should be acknowledged here."
RESPONSE:
As part of an ongoing moni t.oring plan,a questionnaire will
be mailed to each guide and follovTed up by telephone,if
necessary,in order to achieve an adequate response rate.
Data will be collected on services offered,the number and
residency of clients,use areas,reliance on the project
area,and the location and utilization of facilities such as
cabins and airstrips.The questionnaire will be
administered annually in order to monitor the potential
impacts on guides as construction begins.The purpose of
surveying guides is to refine the discussion on impacts to
guides that was presented in the License Application.
Results from the questionnaire will provide information
sufficient to determine the significance,if any,of those
impacts.Mitigation measures vlill be formulated to reduce
any identified adv~rse impacts and these will be addressed
in the updated mitigation plan.
While the hunt for caribou is presently limited by the
number of permits issued,the presence of the access road
may increase hunting pressure on a portion of the
Susitna-Nenana subherd.The main effects resulting from
hunting from the access road will be on the geographic
distribution of the harvest.In the long term,the local
success rate for hunting the Susitna-Nenana subherd may
decrease as a result of reductions in subherd populations.
The overall success rate for hunting the Nelchina herd,
however,is not expected to decrease significantly as the
number of hunters is controlled by permit.Please refer to
Jakimchuk (1980)for a review of possible impacts of roads
on caribou.
REFERENCES
Jakimchuk,R.D.,Disturbance to Barrenground Caribou;A
Review of the Effects and Implications of Human Developments
and Activities (July 1980),preyiously submitted to the PERC
on May 31,1983.
____..,.~-··~----------~--~'----,..,r--------------------
COMMENT 1.512:
~I
"Page E-5-104:Last Paragraph through Page E-5-105:(i)
Guides and Guide Services:The non-resident proportion of
guided hunts should be evaluated.Additional information
should be provided on the schedule and scope of suggested
user interviews."
RESPONSE:
See Responses to Comments 1.170,r.503,1.509,1.520 and
1.521.See also Responses to Comments F.59,F.60 and F.61.
COMMENT 1.513:
"Page E-5-107:(ii)Lodge Operators:Please refer to our
comments on the previous section.The quality,availa-
bility,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.
"The draft license application referred to ongoing studies
and planned interviews which were to address project impacts
on lodges (page E-5-75 of the draft).The applicant should
provide information on the status of those studies particu-
larly as they relate to evaluations of disturbance and use
of wildlife."
RESPONSE:
The Power Authority anticipates refining information about
the Project's potential impacts on wildlife resource users.
Recently completed household and business surveys of
Talkeetna,Trapper Creek and Cantwell residents will help
supplement the information presented in the FERC License
Application.The household survey included questions on the
number of persons in each household who hunt and trap,where
and how often they hunt and trap,what species they hunt and
trap and the importance of hunting and trapping for
recreation,food,income and cultural pursuits.The
business survey included questions on the percent of gross
annual revenues attributable to hunting and trapping
activities,what areas are important to those activities and
what species are hunted and trapped as part of their
-
.r-'
RESPONSE TO COMMENT I.513 {cont.):
business.The results of t:he surveys are being tabulated
and a general report will be available in March 1984.
CO~..MENT I.514 :
"Page E-5-108:The Hunter:The fact that harvest statis-
tics,other than for caribou,do not distinguish between
subsistence and recreationa.l taking of game is no reason to
omit a discussion or quanti.fied study into the subsistence
use of such resources.The!number of people dependent on
subsistence uses of fish and wildlife resources should be
estimated.Alternative use areas are generally not an
option for people who have homesteaded in remote or semi-
remote areas.
"Page E-5-109:The Hunter:Last Paragraph:An explanation
should be given for the large increase in subsistence
caribou permits alloted in 1982.Present and future manage-
ment 'plans and options should be discussed."
RESPONSE:
Recently completed household surveys of Talkeetna,Trapper
Creek,and Cantwell residents will help supplement the
information presented in the FERC License Application.The
household survey included questions on the number of persons
in each household who hunt and fish,where and how often
they hunt arid fish,what species they hunt and fish,and the
importance of hunting and fishing for recreation,food,and
cultural pursuits.
The number of subsistence caribou permits has been fluctu-
ating over the past several years.The number of·permits
increased in GMU 13 in 1982 based on several factors,
including slight increases or stabilization in the popu-
lation of the Nelchina herd,increased demand for subsis-
tence permits by local residents and changes in the criteria
for obtaining a subsistence permit.
The most current management plan for the Nelchina herd
(ADF&G 1976)calls for maintenance of the herd at about
RESPONSE TO COMMENT 1.514 (cant.):
20,000 adult animals through harvest of the annual
increment.
REFERENCES
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.
COMMENT 1.515:
"Page E-5-109:(ii)Resources and Use Patterns:The
discussion provides some quantification for the importance
of GMU 13 relative to state-wide game harvests.Quantifica-
tion 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."
RESPONSE:
It is anticipated that the project-related impacts to big
game harvests in GMU 13 would be insignificant relative to
statewide game harvests as the harvest in GMU 13 represents
only a relatively small proportion of statewide harvest and
project-related decreases in GMU 13 harvest are not expected
to be large.The analysis of impacts on big game species
and their consumptive users will be refined through ongoing
studies.If,based on these studies,the impacts to the
harvests are determined to be significant,then quantifi-
cation of the economic importance of consumptive wildlife
users will be completed.
COM1orlENT 1.516:
"Pages E-5-112 and 113:Supply and Demand for Hunting
Opportunity:Given 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 impact.s 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 [sic]present and future
~.
-
~,
--
COMMENT 1.516 (cont.):
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 difference mitigative proposals
which conflict among user grroups.11
RESPONSE:
Caribou populations and the impacts of the Project on
caribou are discussed in Chapter 3 of FERC License .
Application Exhibit E.Additional information is contained
in the 1982 ADF&G annual re:port which was supplied to the
FERC in May 1983.The annual reports for 1983 will be
provided in May 1984.New information on impacts to the
caribou herd and related harvest opportunities will be
evaluated as it is available and utilized in preparation of
the new Impact Assessment Update and Refinement Report,
which is expected in late A.pril.
REFERENCES
ADF&G,Susitna Hydroelectric Project,Phase I Final Report -
Big Game Studies (1982),previously submitted to the FERC on
l-lay 3 1,1 983 •
Pitcher,K.W.,Volume IV,Caribou (1982).
COMMENT 1.517:
"Page E-5-115:Transportation To and From Hunting Grounds:
Figures showing both present access points and proposed
project access should be correlated to current harvest
intensities."
RESPONSE:
Please refer to the Response to Comment 1.519.
COMMENT 1.518:
"Page E-5-115:Hunting Pressure:The discussion should
explain why hunting pressure in GMU 13 has generally de-
creased in the last decade while the Railbelt region popu-
lation has increased nearly 50%.The influence of changing
COMMENT 1.518 (cont.):
regulations,lifestyles of area residents,or quality of the
hunt on hunting pressure should be examined.Better under-
standing of the moose harvest issue would come from in-~
elusion of comparable demand,harvest,and population data
for GMU's 14 and 16,as well as GMU 13.11
RESPONSE:
As discussed on FERC License Application page E-5-116 and
shown in FERC License Application Table E.5.51,changes in
regulations controlling moose harvest in GMU 13 have had a
marked effect on numbers of moose taken,but has had
relatively little effect on the total number of hunters
utilizing the area.The 1971 hunting season was the last
year of either sex harvest in the area and 4881 hunters took
advantage of this opportunity to harvest 1,814 moose.Since
then,the number of hunters has ranged from 2,299 to 3,199
per year with harvests ranging from 557 to 863 moose per
year.FERC License Application page E-5-117 contains a
further discussion of the importance of regulations to both
the harvest and the number of hunters in an area.Further
discussion on regulation of moose harvest in GMU 13 and
project-related effects is contained in the Response to
Supplemental Information Request 5-23.See also Response to
Comment F.8.
REFERENCES
~,
Alaska Power Authority,Response to FERC Supplemental
Information Request 5-23 (1983),previously submitted to the
FERC on July 11,1983._
COMMENT 1.519:
"Page E-5-117:Importance of Regulations: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:
(I)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 recommenda-
tions to omit any project acqess from the Denali Highway,
and the importance of those recommendations as a wildlife
mitigation measure,we recommend the impacts on hunter
access and harvest distribution both with and without that
-
~!
,~
.-
I~
COMMENT 1.519 (cont.):
road corridor be evaluated.Additional consideration should
be given to impacts both with and without restrictions on
worker access and hunting.Again,regulation of such use
can be a significant mitigation measure.
"Other game species (black bear,brown bear,Dall sheep,
wolf,and wolverine)should be discussed.Harvest and (if
applicable)permit in format:ion should be provided,with
projected demand and access discussed.For example,bear
harvest data and statistical analysis is contained in ADF&G
annual reports.5-21 Harvest data on other species is
similarly available.5-31 }I.nnual hunter surveys for all big
game include questionson harvest locations.While the data
are not exact,they do indi.cate approximate take locations
relative to existing access,proposed access,and project
features.Such information should be evaluated and de-
scriptive maps provided for this section of the license
application.
"Future study plans for filing data gaps on these species
and incorporating those data into project planning should be
discussed."
"5-21 ADF&G.1982.Susitna Hydroelectric Project Phase I
Final Report,Big Game Studies,Volume VI,Black Bear and
Brown Bear.Prepared for A.PA.
"ADF&G.1983.Susitna Hydroelectric Project Phase II
Progress Report,Big Game Studies,Volume VI,Black Bear and
Brown Bear.Prepared for the APA.
"5-31 ADF&G.1982.Susitna Hydroelectric Project Phase I
Final Report,Big Game Studies,Vol.V,Wolf;Vol.VII,
Wolverine,and Vol.VIII,Dall Sheep.Prepared for the
APA."
RESPONSE:
Discussion of access-related impacts to hunters is provided
in the Response to Supplemental Information Request 5-23.
The Response to Supplemental Information Request 5-22 should
be referred to for an analysis of the resource and human use
-------~----,.....-._-~--------.,.,
RESPONSE TO COMMENT I.519 (cont.):
~,
patterns for species other than moose and caribou.Please
refer to the Response to Comment F.8.
REFERENCES
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.
COMMENT I.520:
"Page E-5-120:(a)Data Limitations:Studies necessary to
fill data gaps should be pursued by the applicant.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
involved agency representatives,principal investigators,
consultants,and the project sponsor."
RESPONSE:
The Power Authority anticipates refining information about
the Project's potential impacts on wildlife resource users.
Recently completed household and business surveys of
Talkeetna,Trapper Creek and Cantwell residents will help
supplement the information 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.
',,--_............._------_......_------_.............................,.;--------_......._----------
r~
COMMENT I.521:
"Page E-5-120 and 121:(b)Impacts of the Project:The
issue of future opportunities lost or gained as a result of
the project should be examined in determining project
impacts.Consideration should also be given to the number
of additional trappers the area could support under alterna-
tive access and management scenarios."
RESPONSE:
The significance of the potential effects of the Project on
trapping activities will be further refined through an
analysis of information obtained from surveys of fish and
wildlife resource users.
Recently completed household and business surveys of
Talkeetna,Trapper Creek and Cantwell residents will help
supplement the information 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
~eport will be available in March 1984.
COMMENT I.522:
I1Page E-S-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 values of sloughs 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 available as beaver habitat.Tradeoffs in mitigation
for one species over another should be clarified in terms 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."
RESPONSE TO CO~MENT 1.522:
~,
Tradeoff analysis between terrestrial and aquatic species,
in terms of the mitigation planning process,will proceed as
decisions are made as to the relative importance of the
habitat to each species and as the interference of one
species on another is described and the values of specific
habitats to the respective species are determined.The
completion of this analysis will be dependent upon
acceptance by the resource agencies of a prioritization of
the species in question.For example,at a given slough,
will the mitigation options implemented be ones which favor
salmon or beaver?Once these decisions are made,
appropriate mitigation options can be implemented.
By its nature,this process of prioritization and tradeoff
analysis is best accomplished as a part of the Project
Settlement Process.Meetings describing the Power
Authority's plans for accomplishing this Settlement Process
were held with the agencies listed below and the
finalizatiqn of a comprehensive Issues List is currently
underway.
Agency
Alaska Department of Natural Resources
Alaska Department of Environmental
Conservation
u.S.Bureau of Land Management
National Marine Fisheries Service
National Park Service
u.S.Fish and Wildlife Service
Alaska Department of Labor
Alaska Department of Community and
Regional Affairs
Alaska Department of Fish and Game
U.S.Environmental Protection Agency
COMMENT 1.523:
Date of Meeting
November 2,1983
November IS,1983
November 17,1983
November 18,1983
November 18,1983
November 22,1983
November 28,1983
December I,1983
December 15,1983
February 17,1984
~I
"Page E-S-124:(f)Fox:Please provide comparative _
information on the commercial value of the fox pelts as was
provided for other furbearers."
1""."
RESPONSE TO COMMENT I.523:
The value of fox pelts purchased from trappers in the
project area ranges from $10-$90 and averages $50-$60.
COMMENT I.524:
"Page E-5-125:4.2 Background and Approach:The last
sentence in the first paragraph should be clarified,ela-
borated on,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 proj ect funding,we:are unaware of additional
studies or information which will be provided during the
proposed licensing schedule."
RESPONSE:
The last sentence in the first paragraph of Section 4.2
-"Background and Approach"on FERC License Application
page E-5-125 should be eliminated.
The Power Authority anticipates refining information about
the Project's potential impacts on fish and wildlife
resource users.Recently completed household and business
surveys of Talkeetna,Trapper Creek and Cantwell residents
will help supplement the information presented in the FERC
License Application.The household survey included
questions on the number of persons in each household who
hunt,fish and trapr 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 cultural pursuits.The business survey
included questions on the percent of gross annual revenues
attributable to hunting,fishing and trapping activities;
what areas are important to those activities;and what
species are hunted,fished and trapped as part of their
business.The results of the surveys are being tabulated,
and a general report will be available in March 1984.The
household and business surveys will be conducted on an
annual basis.
-------.........,...,......-----------------------
COMMENT I.525:
"Page E-5-128:4.4.1 -Mitigation Measures That Would Help
Avoid Significant Adverse P:roject-Induced Impacts:The
proposals lack specificity 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.,responsi-
bility,participation,schedule,criteria for determining
'significant adverse impacts'and then modifying mitigation
measure,etc.Furthermore,supplemental information pro-
vided 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 appro-
priate 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."
RESPONSE:
An update of the socioeconomic mitigation plan is currently
undenl7ay and will be completed by mid-1984.This plan will
be based on revised socioeconomic projections (as discussed
in the Response to Comment I.498),and \'lill include three
scenarios depicting different commuting options.The plan
will be directed toward avoiding or minimizing project
impacts on two groups:residents in the project vicinity,
with emphasis placed on the Mat-Su Borough and the
communities of Talkeetna,Trapper Creek and Cantwell;and on
construction and operation workers residing at the
construction camp and permanent village.
For a description of the methods used to monitor and update
socioeconomic impact assessments,please,refer to the
Response to Comment 34 (Chapter 5)in the FERC's April 12,
------------~--~--~,------------_.~-----------
RESPONSE TO COMMENT I.525 (cont.):
1983 Request for Supplemental Information (filed with the
FERC on JUly 11,1983).Refer also to Response I.119B.
REFERENCES
Alaska Power Authority,Response to FERC Supplemental
Information Request,Comment 34 (April 12,1983),previously
submitted .to the FERC on July 11,1983.
COMMENT 1.526:
"Page E-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."-
RESPONSE:
The costs of mitigation programs,including socioeconomic
mitigation measures,have been estimated and are included in
overall project costs.The overall cost of mitigation is
approximately $32 million for the Watana dam and
approximately $5 million for the Devil Canyon darn.The
costs associated with socioeconomic mitigation measures have
not been estimated separately.
COMMENT 1.527:
"Page E-5-133:4.5.1 -Developing Impact Information:
Please refer to our comments on page E-5-125.No details
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.IIA of III,pages 5-29-3 and 5-34-3.
"Page E-5-134:4.5.1 -Developing Impact Information:
Paragraph 3:An outline and 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,
.....
-
-
COMMENT I.527 (cont.):
mitigation planning workshop,as well as earlier workshops
on resources modeling and project licensing."
RESPONSE:
Recently completed household and business surveys of
Talkeetna,Trapper Creek and Cantwell residents will help
supplement the information presented in the PERC License
Application.The household survey was designed to obtain
information on demographic characteristics,employment,
length of residence,characteristics of the housing stock,
satisfaction with public services and facilities and
hunting,fishing and trapping activities.The business
survey included questions on the types of products and/or
services provided,the volume of revenues,number of
employees,business expansion plans and revenues associated
with hunting,fishing and trapping.The results of the
survey are being tabulated,and a general report will be
available in March 1984.
COMMENT I.528:
"Page E-5-135:4.5.3 -Refining and Implementing Mitigation
Measures:Plese refer to our comments under Section 4.4.1
on the need to establish a monitoring panel and describe
responsibilities and crlteria for adjusting mitigation
measures."
RESPONSE:
Please refer to Responses to Comments I.119B and I.147.
COMMENT I.529:
"It appears that regional-statewide impacts or effects of
the project are understated since as the State's oil revenue
decreases,a high percentage of available capital and/or
financing may be concentrated on the project,at the expense
of other projects or progra.ms.Other regional energy
development may be adversely affected,as an example."
RESPONSE:
See Response to Comment A.13.
__a_=_",~_
COMMENT I.530:
liThe effects of in-migration on the economy are understated.
Migration may include individuals 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."
RESPONSE:
See Response to Comment A.14.
COMl-iENT I.531 :
"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."
RESPONSE:
See Response to Comment A.15.
COMMENT I.532:
"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 100%related or attributable to the hydro project
alone.II
RESPONSE:
See Response to Comment A.16.
COMMENT I.533:
"Access development,if exaggerated,will cause development
of the region in general,not only development of a power-
site.The effects of increased use and development,cannot
be underestimated in effect upon the existing resident human ~~
population and local living conditions."
-
'""...
RESPONSE TO COMMENT I.533:
See Response to Comment A.17.
COMMENT I.534:
"There is no mention of the impact of the impoundment on
Federal mi~ing claims located,for example,along Jay
Creek.II
RESPONSE:
See Response to Comment A.5.
COMMENT I.535:
"Section 2.1 -Regional geology,seismic geology,and
geologic conditions appear to be well written,accurate,and
concise.II
RESPONSE:
No response necessary.
COl>1MENT I.536 :
"Sections 2,5,8 and 3.7 -Borrow pits and quarry sites -
planning for eventual inundation of borrow 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.'f
RESPONSE:
The exact locations of borrow areas for construction of the
Denali access highway have not yet been determined.General
availability of free-draining materials potentially suitable
for borrow along the Denali access corridor can be identi-
fied by examination of terrain unit maps and engineering
soils data.The Alaska Pow'er Authority considers the task
of identifying borrow and stockpile areas as one requiring
engineering and environmental input.Therefore,the Power
4 .•
RESPONSE TO COMMENT I.536 (cont.):
Authority is committed to incorporating environmental
considerations into the design of its facilities in order to
help prevent and mitigate impacts.
COMMENT I.537:
"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."
RESPONSE:
See Response to Comment A.6.
COMMENT I.538:
"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."
RESPONSE:
See·Response to Comment A.7.
COMMENT 1.539:
"The transmission line rights-of-way may eventually be used
as access corridors for ORV or other unplanned uses."
RESPONSE:
See Response to Comment A.18 •
-
-
-
COMMENT 1.540:
"CHAPTER 10.ALTERNATIVE LOCATIONS,DESIGNS,AND ENERGY
SOURCES
"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 e~ent 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.II
RESPONSE:
An analysis of the delay of the Watana Project was not
presented in the FERC License Application (see Responses to
Comments B.3,C.30 and C.33).However,thermal and mixed
thermal/hydro alternatives,which could be implemented if
Susitna is not built,are analyzed.
If the implementation of the Susitna Project is delayed or
postponed,energy that could be displaced by Susitna would
have to be"s:upplied by thermal generation.If the delays
are short term,the installation of new alternative
generation is expected to hie at a minimum.At present,
Railbelt utility planning anticipates the completion qf the
Anchorage-Fairbanks Intertile and the installation of Power
Authority hydroelectric developments (i.e.,Bradley Lake and
Susitna).Short-term delays of the Susitna Project (Watana
Dam)could be accommodated by power and energy exchanges
over the Intertie,extending the useful life of existing
generation,and reducing reserve margins.
If long-term delays are experienced or if the Susitna
Project is never built,it is postulated that the Railbelt
generation system would dev1elop similar to the non-Susi tna
alternative or a mixture of gas-and coal-field generation.
The assumptions and variablles used in the other planning
models (MAP and RED)would not be affected by a delay of
Watana because the effects of the construction of Susitna or
the thermal alternative were not included in the analysis by
these models.
-......--.------."F'"-------------,-,-------------------
COMMENT I.541:
"CHApTER 10.ALTERNATIVE LOCATIONS,DESIGNS,AND ENERGY
SOURCES
"In the assessments provided on hydropower alternatives,the
proposed Susitna project and alternative basin developments
are not evaluated on an equitable basis.There are explana-
tions and tables (e.g.Tables E.10.6and 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 poten-
tials.Yet,since the strengths and weaknesses of Susitna
River proposals are not similarly included here,it is not
possible to directly compare the Susitna project 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:(1)big game,(2)anadromous fish,(3)
de facto wilderness,(4)cultural (subsistence),(5)recrea-
tion (existing),(6)restricted land use,and (7)access.
Moreover,combinations of hydropower alternatives or hydro-
power with other power sources which would provide equiva-
lent power are not contrasted directly with the Susitna
project."
RESPONSE:
It is not reasonable to directly compare the 1620 MW Susitna
Hydroelectric Project as described in the FERC License
Application with the alternative hydropower sites as shown
in FERC License Application Tables E.10.6 and E.10.7.As
shown in PERC License Application Table E.10.7,the
alternative sites have installed capacities ranging from
less than 25 MW to "greater than 100"MW.The size of the
reservoirs range from less than 5,000 acres to greater than
100,000 acres.In comparison,the combined Watana-Devil
Canyon developments will have an installed capacity of
1,620 MW and a combined reservoir area of 45,500 acres.To
be truly comparable,the net probable impact of a combina-
tion of alternatives with a total capacity comparable to
Susitna would have to be compared to the net impacts after
mitigation of the Susitna Project.
Nevertheless,in accordance with the wishes expressed in the
Department of Interior letter,information is provided below
in Table I.541.A so as to permit incorporation of the
Susitna Project into PERC License Application Tables E.I0.6
-
~l
-
-
-
RESPONSE TO COMMENT I.541 (cont.):
and E.I0.7.Information regarding the cumulative
environmental impacts of thermal generation,as compared to
Susitna,is presented in the Response to Comment I.569 .
..~"
RESPONSE TO COMMENT 1.541 (cont.):
Table I.541.A
SUSITNA PROJECT COMPARED TO NON-rUSITNA
HYDROELECTRIC ALTERNATIVES
Environmental
Component
Big Game
Sensitivity
Scaling
B
Comments
Moose,Caribou,Dall
Sheep and Black and
Brown Bear present.
Winter concentration
area for Moose.
~,
Agricultural Potential
Waterfowl,Raptors,
Endangered Species
Anadromous Fisheries
Wilderness
Consideration
Cultural,
Recreational
and Scientific
Features
Restricted Land Use
Access
D
B
B
B
C
D
B
None identified.
Active and inactive
nests to be affected:
Golden Eagle -8;
Bald Eagle -6;
Goshawk -2;
Gyrfalcon -1;
Common Raven -17.
None within reservoir
area;five species
present and spawning
in sloughs,side
channels and tri-
butaries downstream.
Area presently rela-
tively inaccessible.
Good to high quality
scenery.Natural
features (only one
of which is affected
by the Project).
Class VI boating
waters;archaeo-
logical sites found
following extensive
surveying.
State and Native claims.
Presently accessible
only from air.
-
.,..
-
RESPONSE TO COMMENT I.54!(cont.):
1 Non-Susitna alternatives as described in FERC License
Application Tables E.10.6 and E.10.7.
The results of expansion planning studies with thermal
generation,non-Susitna hydropower and Susitna Basin
hydropower which provide equivalent system power comparisons
are contained in the FERC License Application as filed
February 15,1983.
Side-by-side comparison of generation system mix and total
system present worth of costs of alternative plans is
presented in Table I.541.B and was prepared from the
following tabulations.
1.Non-Susitna Alternatives -FERC License Application
Exhibit D,Table D.17 -Results of Economic Analyses of
Alternative Generation Scenarios
2.Susitna Alternatives -FERC'License Application
Exhibit B,Table B.11 -Results of Economic Analyses of
Susitna Plans
The information presented below in Table I.541.B includes
the specified on-line dates for the various stages of the
plans,the OGP5 run index number,the total installed
capacity at the year 2010 by category,and the total system
present-worth cost in 1980.The present-worth cost was
evaluated for the period 1980 to 2040,i.e.,60 years.The
OGP5 model was run for the period 1980-2010;thereafter
steady-state conditions were assumed and the generation mix
and annual costs of 2010 were applied to the years 2011 to
2040.This extended period of time was necessary to ensure
that the hydroelectric options being studied,many of which
only come on-line around 2000,were operated for periods
approaching their economic lives and that their full impact
on the cost of the generation system were taken into
account.
The basic data used in the studies and a reference to their
location in the FERC Licensle Application follows:
.....
,1t'f'lW!"
1 •
2 •
Load forecast over a specifie'd period of time
(Exhibit B,Table B.71J .
Details of the existing generating system (Exhibit D,
Table D.14).
__________mOO-"I;i3_~'--------'-'-"""...-"------------------------
RESPCNSE TO CCMMENT 1.541 (cont.):
f 1 .j )1 1 J )1 I ..~1 J
RESPONSE TO CCM1ENT 1.541 (cant.):
Table I.541.B (cant.)
cumulative Total
Avg.Annual System Total
Hydroelec-Installed Capacity by Category in 2010 Installed System
C-eneration Scenario tric Ener~!~b CX:;P5Rtm Thermal Hydroelectric Capacity Cost in
Type Description Production )Id.No.Coal Gas Oil Existing Added in 2010 1980
(GWh)(MW) (MW)(MW)(MW)(MW)(MW)($million)
No Renewals Plus:lA03 500 576 30 144 778 2028 7088
Chakacharnna (500)-1933 1925
Keetna (100)-1996 2320
Snow (50),Cache (50),
Talkeetna-2 (50),
Strwidline (20)=2002 ":!ne::nJVVV
Thermal Plus No Renewals Plus:L8J9 300 426 0 144 1200 2070 5850
Susitna Basin Watana (400)-1993 2990
Hydroelectric Watana (400)-1996 3250
Devil Canyon (400)-2000 6070
No Renewals Plus:L607 200 651 30 144 1180 2205 6530
Watana (800)-1993 3250
Watana (50)and
Tunnel (330)-1996 5430
No Renewals Plus:L601 300 651 20 144 1200 2315 6370
High Devil Canyon
(400)-1993 2760
High Devil Canyon
(400)-1996 3400
Vee (400)-2000 4.910
(a)Prepared from data shown in Exhibit D,Table D.17 and Exhibit B,Table B.11.
(b)Based on data shown in Exhibit E,Table E.10.13 (also Exhibit D,Table D.16)for Non-Susitna Hydroelectric Alternatives
and Exhibit B,Tables B.9 and B.10 for Susitna Basin Hydroelectric Alternatives.
(c)[Footnote (c)is missing.]
RESPONSE TO COMMENT 1.541 (cont.):
3 .A list of future thermal generating sources with
associated annualized costs,installed capacities,fuel
consumption rates,etc.(FERC License Application
Exhibit B,Table B.14).Natural gas-fired generation
was modeled in OGP5 assuming a natural gas consumption
constraint identi£ied as No Renewals.Under the No
Renewals constraint all new gas-fired generation would
be restricted to not more than 1500 hours of annual
operation at design capacity and retired gas-fired
generation would not be reconstructed.
4.Annual fixed carrying charges and fuel prices and
escalation rates (FERC License Application Exhibit B,
Table B.13).
5.A specified hydroelectric development plan,i.e.,the
annualized costs,on-line dates,installed capacities,
and energy production capability of the various stages
of the plan.
Sa.Non-Susitna Hydroelectric Alternatives Development
Plans (FERC License Application Exhibit E,Table
E.10.12).
Costs (FERC License Application Exhibit E,Table
E.10.13,also Exhibit D,Table D.16).
5b.Susitna Basin Hydroelectric Alternatives
Development Plans (FERC License Application
Exhibit B,Tables B.9 and B.10).
Costs (FERC License Application Exhibit B,Tables B.9
and B .10)•
The following tables,contained in Volume IV-Candidate
Electric Energy Technologies for Future Application in
the Railbelt Region of Alaska of the Railbelt Alterna-
tives Study,summarize and compare technologies on
selected technical,economic and environmental
characteristics.
~I
~J
RESPONSE TO COMMENT 1.541 (cont.):
..-
-
Table No.
4.1
5.1
5.9
6.1
7.1
Title
Comparison o:f Baseload
Technologies on Selected
Characteristics • • .
Comparison of Cycling
Technologies on Selected
Characteristics • • • • •
Summary of More Favorable
Potential Intermediate
and Large-Scale Hydroelectric
Sites in the Railbelt Program
Comparison of Storage
Technologies on Selected
Characteristics . • • • .
Comparison of Fuel-Saver
Technologies on Selected
Characteristics •.• .
4.5
5.2
5.40
6.2
7.2
-
....
-
Volume IV is one of seventeen volumes that document the
Railbelt Alternatives Study.The study was submitted
to the FERC on July 11,1983,in the following report:
Battelle Pacific Northwest Laboratories,Railbelt
Electric Power Alternatives Study:Evaluation of
Railbelt Electric Energy Plans (1982),prepared for the
Office of the Governor,State of Alaska.
On the basis of the information presented here and in
Response to Comment 1.569,the Power Authority anticipates
RESPONSE TO COMMENT 1.541 (cont.):
that the DEIS will reasonably evaluate the alternatives to
the Susitna Project.
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 I,Evaluation of Railbelt Electric Energy Plans
(1982).
COMMENT 1.542:
"CHAPTER 10.ALTERNATIVE LOCATIONS,DESIGNS,AND ENERGY
SOURCES
"Previously,we recorrunended that further details on alterna-
tive power sources be provided.We reiterate that recom-
mendation here while agreeing that,in some cases,informa-
tion 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 disag~eement with our
recommendations to include fish,wildlife,social,and land
use assessments in comparisons among non-hydropower and
hydropower alternatives (e.g.comments W-10-024,W-10-027,
W-10-029, W-10-031,W-lO-032,W-10-034 and responses to
those corrunents included in Chapter 11,Exhibit E).It is
our view that without such information,the license ap-
plication 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.I0.16 and E.IO.19,as well as the overall summary
evaluation of those alternatives (Table E.I0.20)."
'------------------------_......_------_......_---------
.-
--
RESPONSE TO COMMENT I.542:
The Department of the Interior and other agencies have
commented to the FERC regarding possible flow regimes,
project operation alternatives and their impacts (see
Comments B.2,B.3,B.4,B.5,B.7,B.64,B.65,C.87,F.2,
F.3,F.lO,F.ll,F.25,F.39,I.5,I.24,I.25,I.29,I.13l,
I.133,I.149,I.198,I.20l,I.236, I.558,I.560 and I.562,
and the associated Power Authority Responses;see also FERC
License Application (pages :E-2-104,E-2-55 to E-2-62 (Case C
target minimum flows».
As indicated in the Respons,es to Comments B.65,F .11 and
F.25,"The Power Authority anticipates that the DEIS and
FEIS will analyze a full reasonable range of alternative
operating scenarios."These alternative operating scenarios
and their associated flow regimes could include base-load
operation,an alternative already identified and analyzed in
the FERC License Application,and also a range of
load-following scenarios with hourly flow variations.The
Power Authority has developed additional data and methods
which FERC may utilize in its analysis of load-following
al ternatives,to the extent FERC deems any load-follov.Jing
operational scenario to be a reasonable alternative.The
Power Authority has identified a load-following case and has
analyzed the resulting stage fluctuations ~n theSusitna
River downstream from the Project.A report documenting
this analysis,illustrating appropriate methods of analyzing
such alternatives,is referenced below and appended as a
reference to this Response Document.This load-following
hypothetical case may be characterized as "extreme,"but
remains within the flow constraint of the Case C scenario.
This analysis was made to determine if,downstream of the
Project,significant attenuation of the fluctuating water
levels resulting from load-following operation would occur.
The Power Authority does not currently believe that the flow
release patterns in this report would be judged by many
agencies to be an environmentally reasonable alternative.
Neither is it necessarily thought that these patterns
represent the optimum economic use of the resource.It may
be of value in that it represents an environmentally extreme
case;however,the FERC may not deem this case a
"reasonable"alternative for its analys~s.A second report
which will document stage,fluctuations for a more moderate
case of discharge variation~is anticipated in late March
1984.
We anticipate that the FERC will identify reasonable
alternatives and analyze the environmental impacts of such
,==__,---------,M-'----.pi---------'-0-------------
RESPONSE TO COMMENT l.542 (cont.):
modes of operation in preparing DElS and FElS.To the
extent such alternatives are load-following,such an
environmental analysis would include consideration of
aquatic habitat effects of the mximum and seasonal mean
changes in discharge occurring on a daily basis as well as
the rates of change.Both rate of change and absolute
change associated with alternative load-following modes of
operation can be compared to natural existing conditions in
the river.
A few examples of the natural range of the daily discharge
variation is given in the Table below,taken from daily
average discharge records at Gold Creek and two other
locations at which rating curves are available.Rates of
change under existing conditions can only be indirectly
deduced from this table,but should be directly available
from USGS gaging records.Please see also the Responses to
Comments l.346 and l.S52,as ~lell as the Responses to
Comments B.7,B.G4,B.GS,C.B7 and F.39.
~,
I~
RESPONSE TO COMMENT 1.542 (cont.):
,~
-
-
~rABLE I
Daily Changes in Discharges
and Associated Changes
in Water Surface Elevation
Date
08/31/82
06/08/82
08/02/81
08/21/81
05/07/81
05/09/81
09/15/80
09/14/80
07/02/80
09/01/79
09/22/83
09/23/83
Avg.
Daily
Discharge
(cfs)
16,000
30,000
54,000
43,100
13,600
30,000
21,600
12,000
33,800
12,100
13,600
17,500
Change
From
Prevo
Day
(cfs)
+3,000
+4,000
+20,000
+8,000
+3,600
+9,000
+9,600
+2,400
-8,600
-2,000
+3,000
+3,900
Change
in Stage
at Gold
Creek
(ft)
+0.6
+0.5
+3.2
+0.8
+1.1
+1.3
+1.8
+0.6
-0.9
-0.5
+1.0
Change in
Stage at
LR X 28
(ft)
+1.0
+0.4
+1.1
+1.2
+2.1
+0.8
-0.6
Change in
Stage at
LR X 35
(ft)
+0.8
+0.5
+1.1
+2.1
+1.0
Note:September 22,1983 discharge increased from
approximately 12,000 cfs to approximately 15,000
cfs during a one-day period.Discharge was
13,000 cfs at 0730 hours;approximately 15,000 cfs
at 1800 hours.
I"'"
l~.
Information on the comparative environmental implications of
the Susitna project,other hydro and non-hydropower
alternatives is presented in Chapter 10 of the License
Application and is supplemented by the Responses to
Comments 1.541,1.544 and 1.569.
------_._--~-"----------------------
RESPONSE TO COMMENT 1.542 (cont.):
On the basis of this information,the Power Authority
anticipates that the DEIS will reasonably evaluate the
alternatives.
REFERENCES
Harza-Ebasco,Susitna Hydroelectric Project River Stage
Fluctuation Resulting From Watana Operation (January 1984).
COMMENT Ie 543:
"CHAPTER 10.ALTERNATIVE LOCATIONS,DESIGNS,AND ENERGY
SOURCES
"Alternatives to the proposed construction camps,village
and permanent town should be addressed in this Chapter.
These construction facilities have large implications for
the fish and wildlife resources and users.At a minimum,
the alternative of combining the three Watana facilities
should be discussed.The alternative of a Prudhoe Bay type
camp should also be considered.In addition,project design
includes three airstrips (two at Watana,one at Devil
Canyon).The alternatives of consolidating two of the
airstrips,and all three of the strips,.should be discussed.
Construction facilities alternatives should be discussed in
terms of minimizing adverse impacts to fish and wildlife
resources and their use.Resource agencles have not been
consulted in regard to project facilities."
RESPONSE:
Refer to Response to Comment 1.91 relative to combining the
Construction Camp,Village and Permanent Village.
The reference to an alternative of.a "Prudhoe Bay type camp"
is assumed to mean the multi-story facilities built by two
of the petroleum ventures on the North Slope of Alaska.
Facilities of this type are permanent in nature,i.e.,they
require longer construction times and cannot be dismantled
for reuse,and are not acceptable for use in the Susitna
Construction Camp or Construction Village.Multi-story
facilities for the Permanent Village is one option to be
considered.The housing of the Permanent Village families
in multi-story facilities will produce sociological and
-
-
RESPONSE TO COMMENT I.543 (cont.):
psychological problems due t.o the close proximity of
families with a focus on the Project and limited possibil-
ities for diversification.Some inhabitants undoubtedly
will prefer the apartment-type dVlelling lifestyle of a town-
house facility and this could be a major feature in the
Permanent Village concept.Detailed solutions will mitigate
potential,sociopsychological and environmental problems
prior to the construction of the Construction Village to
ensure compatibility of concepts and use with the Permanent
Village.
with regard to the Comment on the airstrips,we refer you to
the Responses to Comments I.380,I.92 and the following
discussion.
Relative to the project design of "Three ll Airstrips (two at
Watana,one at Devil Canyon),reference is made to the
License Application Volume 6A,Exhibit E,Chapter 3,dated
February 1983,page E-3-127.No airstrip will be built at
the Devil Canyon site.Access and supply to devil Canyon
will be through the access road from Watana,or railhead to
Gold Creek.(License Application Volume 3,Exhibit F,dated
February 1983,Plates F 40,F 70 and F 71).
At the Watana site,two airstrips will be required.A
temporary strip (2500'long)has just been permitted for
construction as described in Response to Comment 1.92.This
strip will be designed to accommodate light aircraft for the
specific purpose of providing access and support to the
Watana camp during environmental and geotechnical site
investigations.At a later date,the strip may be extended
to 4000 feet or 6000 feet in length to support such
activities as camp expansion,equipment mobilizations and
construction activities on the access road.
Although the temporary airstrip is expandable to 6000 feet,
it cannot be considered as permanent since the majority of
the strip is located in Borrow Site D,close to the main
dam.During the construction of the main dam,the temporary
strip will be removed so that the borrow material closest to
the dam can be utilized~
If the temporary strip were made permanent,its location
would seriously impact borrow operations and availability of
material for the main dam central core.
Access to the airstrip and safety to flights and construc-
tion personnel during the borrow operations will take on
RESPONSE TO COMMENT I.543 (cont.):
significant proportions at this location.Conversely,if
the temporary strip were located at the site indicated in
the License Application,an extensive access road between
the airstrip and the now-existing camp would be required.
The associated land disturbance and costs for this alterna-
tive are not justifiable during the project licensing
process.
Thus,two separate strips are proposed to be constructed at
the Watana site.No strip will be constructed at the Devil
Canyon site.
COMMENT I.544:
"Page E-IO-l:1 -ALTERNATIVE HYDROELECTRIC SITES:We
recommend that all evaluation matrices include the project
as proposed and other Susitna River basin alternatives."
RESPONSE:
Information on project alternatives other than alternatives
on the Susitna River itself is provided in the Responses to
Comments I.541,I.542,I.569 and I.579.Basic information
on the physical characteristics of other Susitna River
alternatives and combinations thereof that have been studied
is contained in FERC License Application Tables B.9,B.10
and B.11 and in the Response,filed December 19,1983,to
Comment D,Section 10,No.1 of the November 3,1983 request
for information from the FERC.
The Feasibility Report (Acres 1982),the Development
Selection Report (Acres 1981)and the Corps of Engineers
1977 Final Environmental Impact Statement (COE 1977)for the
Project all consider the environmental implications of
alternative Susitna River developments.Twelve sites were
identified on the river upstream of Gold Creek.These are:
Gold Creek
Olson (Susitna II)
Devil Canyon
High Devil Canyon
Devil Creek
Watana
Susitna III
Vee
Maclaren
Denali
Butte Creek
Tyone
,~
-
-
r
.-
RESPONSE TO COlJl'..MENT I.544 (cont.):
Two basic screening criteria were initially used to evaluate
these sites,environmental considerations and alterna.tive
sites for essentially the same development.In the
environmental screening,thl=potential impact on the
environment of a reservoir located at each of the sites was
assessed and categorized as being relatively unacceptable,
significant or moderate.
Unacceptable Sites
Sites in this category were classified as unacceptable
because either their impact on the environment would be
extremely severe or there are obviously better alternatives
available.
The Gold Creek and Olson sites both fall into this category.
As salmon are known to migrate up Portage Creek,a
development at either of these sites would obstruct this
migration and inundate spawning grounds.
Development of the mid-reaches of the Tyone River would
result in the inundation of sensitive big game and waterfowl
areas,provide access to a large expanse of wilderness area
and contribute only a small amount of storage and energy to
any Susitna development.Since more acceptable alternatives
are obviously available,the Tyone site is also considered
unacceptable.
Sites With Significant Impact
Between Devil Canyon and the Oshetna River,the Susitna
River is confined to a-relatively steep river valley.
Upstream of the Oshetna River,the surrounding topography
flattens and any development in this area has the potential
of flooding large areas even for relatively low dams.
Although the Denali Highway is relatively close by,this
area is not as isolated as the Upper Tyone River Basin.It
is still very sensitive in terms of potential impact on big
game and waterfowl.The sites at Butte Creek,Denali,
Maclaren and,to a lesser extent,Vee fit into this
category.
Sites With Moderate Impact
Sites between Devil Canyon and the Oshetna River have a
lower potential environmental impact.These sites include
.the Devil Canyon,High Devil Canyon,Devil Creek,Watana and
Susitna sites and,to a lesser extent,the Vee site •
------,,---,--------,------------,--""'!"'"---------------------
RESPONSE TO COMr~ENT 1.544 (cont.):
Sites which are close to each other and can be regarded as
alternative dam locations can be treated as one site for
project definition study purposes.The two sites which fall
into this category are Devil Creek,which can be regarded as
an alternative to the High Devil Canyon site and Butte
Creek,which is an alternative to the Denali site--.---
On the basis of further comparisons discussed in Exhibits B
and E of the FERC License Application and in the cited
reports,the Watana-Devil Canyon Project was shown to be
preferable from environmental,engineering and cost
standpoints.
REFERENCES
Acres American,Inc.,Susitna Hydroelectric Project
Feasibility Report,Volume I Engineering and Economic
Aspects,Final Draft (1982),previously submitted to the
FERC on March 15,1982.
Acres American,Inc.,Susitna Hydroelectric Project,
Development Selection,Final Report (December 1981),
previously submitted to the FERC on March 15,1982.
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).
COMMENT 1.545:
"Page E-10-6:1.1.5 -Plan Formulation and Evaluation:The
tables referenced in this section should include the pro-
posed project and other Susitna River basin alternatives.
If the Susitna project proposal is superior to the various
alternatives,incorporating the proposal into the tables
would help to demonstrate this conclusion."
RESPONSE:
Please refer to the Responses to Comments 1.541,1.542,
1.544,1.569 and 1.579.
"w"
-
Jil'=Ill,
-
COMMENT I.546:
"Page E-10-7:1.2.1 -D~scription 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.1I
RESPONSE TO COMMENT I.546:
The Chakachamna studies contained in FERC License
Application Exhibit E,Chapter 10 were performed using an
installed capacity of 500 MW which was computed using a
plant factor of about 45 percent and estimated average
annual energy generation of 1,925 GWh.The Chakachamna
plant factor was based on similar plant factors considered
for the Susitna Basin development plans.It would not be
correct to change the installed capacity to 330 MW since the
expansion planning studies (OGP5)contained in FERC License
Application Exhibit E,Chapter 10 were based on 500 f1t~.
The 330 MW installation which was computed using a plant
factor of 45 percent and estimates average annual energy
generation of 1,301 GWh resulted from subsequent studies
which were submitted to the FERC on July 11,1983,in the
following reports:
1.Sechtel Civil and Minerals,Inc.,Chakachamna
Hydroelectric Report,Interim Report (1981),prepared
for Alaska Power Authority,submitted to the FERC on
July 11,1983.
2.Bechtel Civil and Mine:rals,Inc.•,Chakachamna
Hydroelectric Report (1983),prepared for Alaska Power
Authority,submitted t,o the FERCon July 11,1983.
COMMENT I.547:
"Page E-10-9:(d)Aquatic Ecology:Paragraph 2:The low
number of spawning salmon observed in the mainstem 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 metho-
dology is appropriate for the clear water tributaries but
not for the glacial flow mainstems and side-channels."
RESPONSE TO COMMENT I.547:
Comment noted.The data and description provided here are
taken from the Chakachamna Feasibility Report.
REFERENCES
Bechtel Civil and Minerals,Chakachamna Hydroelectric
Interim Feasibility Assessment Report (1983),previously
submitted to the FERC on July 11,1983.
COMMENT I.548:
"Page E-10-14:1.2.4 -Environmental Impacts of Selected
Alternatives:Paragraph 7:The tunnel alternatives are in
conjunction with a dam to raise the Chakachamna Lake level.
The impacts to the aquatic system could,potentially,be
lessened through the alternative of restricting the project
to the Chakachatna River system instead of diverting flows
to the McArthur River.Fish passage facilities have been
proposed by the Alaska Power Authority (APA)as a component
of the preferred Chakachamna project plan.1I
RESPONSE:
The Chakachamna Lake hydroelectric study for which the Power
Authority provided a reference in Comment I.546,evaluated
the merits of developing power potential by diversion of
water southeasterly to the McArthur River via a tunnel about
10-miles long,or easterly down the Chakachatna Valley
either by a tunnel about 12-miles long or by a darn and
tunnel development.
Aquatic system impacts would be limited to the Chakachatna
River with development restricted to that river system
whereas aquatic systems in both the Chakachatnaand McArthur
Rivers would be affected with the McArthur alternative.
However,the cost of energy from the Chakachatna Valley
development is estimated to be 25%higher than that for the
McArthur alternative and is close to the cost of alternative
coal-fired resources.Therefore,there was justification to
concentrate further studies on the McArthur River
alternatives.In addition,building on the lower slopes of
Mt.Spurr--an active volcano--was not deemed prudent in view
of the evidence of geologically recent debris flows.
-
~.
-~
-,
RESPONSE TO COMMENT 1.548 (cont.):
The recommended scheme,designated Alternative E,includes a
darn and provisions for fish passage at the Chakachamna Lake
outlet,an intake,10 miles of power tunnel,and a power
plant on the McArthur River.
COMMENT 1.549:
"Page E-I0-18:1.3.3-Formulation of Susitna Basins
Development Plans.:The subplans should be corrected to
indicate the current proposed Watana dam installed capacity
of 1020MW."
RESPONSE:
The Susitna Basin development studies contained in FERC
License Application Exhibit E,Chapter 10 (also Exhibit B,
Section l)were performed using installed capacities based
on a desired annual plant factor in the range of 50 to
60 percent~For Watana,capacity of 800 MW was used.For
Devil Canyon,thE~study used 400 MW.Subsequent,detailed
studies of Watana and Devil Canyon,contained in FERC
License Application Exhibit B,Section 2 -Alternative
Facility Design,Processes and Operations,led to refinement
and optimization of project designs including installed
capacity.These optimization studies demonstrated that the
optimal installed capacity for the Project would be 1020 MW
at Watana,and 600 MW at Devil Canyon.The results of the
optimization studies,however,were not used in the
comparison of alt:ernatives.It would not be correct to
change the installed capacity of the Watana and Devil Canyon
developments in FER~License Application Exhibit E,
Chapter 10 (also Exhibit B,Section 1),since expansion
planning studies (OGP5)were based on the installations
shown.
----,----_.-----------"--'"y-----------,-----------
-
COHMENT I.550:
"Page E-10-31:2.1.1 -Diversion/Emergency Release
Facilities:Paragraph 1:The Case C flolflS (minimum flows of
12,000 cfs)were not established as proposed'...to avoid
adverse affects on the Salmon [sic]fishery downstream.'
The Chapter 11,Exhibit E,'W-10-008 Response states that
avoidance flows (i.e.flows necessary to avoid adverse
effects on the salmon fishery downstream),'...would be
19,000 cfs in August.'According to the Alaska Department
of Fish and Game (ADF&G)Synopsis Report prepared for the
Susitna project,five of nine sloughs examined do not
achieve unrestricted access until flows exceed 20,000 cfs.
10-1/In additon,the applicant's letter,dated May 16,
1983,to the Regional Director,U.S.Fish and Wildlife
(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.Yould,APA)."
1110-1/ADF&G.1983.Synopsis of the 1982 Aquatic Studies
and Analysis of the Fish and Habitat Relationships.
Prepared for the APA."
RESPONSE:
The question raised in this Comment is discussed extensively
in the Response to Comment I.94.
COMMENT I.551:
IIPage E-10-32:2.1.3 -Power Intake and Water Passages:
Paragraph 2:The statement.is made that a multi-intake
structure would be used,".•.in order to control the down-
stream river temperatures within acceptable limits."Since
temperature changes are ine~vitable,it is important that
"acceptable limits"be established and agreed upon by
resource agencies.
"Page E-10-32:2.1.3 -Powe!r Intake and Water Passages:
Paragraph·3:Please referemce our comments on page E-10-31
concerning minimum flows."
RESPONSE TO COMMENT I.551:
The multi-level intakes have been incorporated into the
design of the Susitna Project to enable flexibility in
releasing water with a desired temperature.It is
necessary,however,to emphasize that it will only be
possible to release water with temperatures that are within
the range available in the reservoir.It is anticipated
that designation of "acceptable limits"for the control of
downstream temperature will be agreed to in conjunction with
the overall designation of an acceptable flow regime.
See also Responses to Comments B.16,B.22,B.23,B.29,B.31
and B.38 for discussions on downstream temperatures.
COMMENT I.552:
"page E-10-33:2.2.1 -Installed Capacity:Paragraph 1:It
is stated that the Devil Canyon facility would be operated,
"•..primarily as a base loaded plant •.."The circumstances
and anticipated operating regimes under which peaking
operations at the Devil Canyondam are envisioned need to be
explained.The potential impacts of peaking operations at
the Devil Canyon dam on the aquatic resources should be
<0discussed."
RESPONSE:
Deviation from base-load operation at Devil Canyon is
envisioned only to react to system generation needs under
emergency conditions.Under normal circumstances,
regulation of frequency and voltage and provision of
spinning reserve and reserve capacity would be accomplished
by Watana and thermal generating units.Therefore,
deviation from'base-Ioad operation at Devil Canyon would be
very infrequent.Even under emergency conditions
restrictions on discharge change are under consideration to
minimize potential impacts to aquatic resources.
The installed capacity at Devil Canyon has been selected as
the maximum capacity needed to utilize the available energy
from the 32 years of hydrologic flows used in the study,as
modified by operation rules of Watana Reservoir.In months
when plant capacity output corresponding to the total
estimated monthly energy available is less than the
installed capacity,the remaining increment of capacity
could be considered in part or in whole as reserve capacity
in the system depending upon ,the discharge required to
~,
f"""
-
RESPONSE TO COMMENT I.552 (cont.):
operate the reserve capacity and the restrictions on change
of discharge.In addition '1:.0 reserve for emergencies,Devil
Canyon would provide reserve for its own maintenance
outages.
The Department of the Interior and other agencies have
commented to the FERC regarding possible flow regimes,
project operation alternatives and their impacts (see
Comments B.2,B.3,B.4, B.5,B.7,B.64, B.65, C.87,F.2,
F.3,F.10,F.11,F.25,F.39,I.5,I.24,I.25, I.29,I.131,
I.133,I.149,I.198,I.201,I.236,I.558,I.560 and I.562,
and the associated Power Authority Responses;see also FERC
License Application (pagesE-2-104,E-2-55 to (Case C target
minimum flows».
As indicated in the Responses to Comments B.65,F.11 and
F.25,"The Power Authority anticipates that the DEIS and
FEIS will analyze a full reasonable range of alternative
operating scenarios."These alternative operating scenarios
and their associated flow regimes could include base-load
operation,an alternative already identified and analyzed in
the FERC License Application,and also a range of
load-following scenarios with hourly flow variations.The
Power Authority has developed additional data and methods
which FERC may utilize in its analysis of load-following
alternatives,to the exte~t FERC deems any load-following
operational scenario to be a reasonable alternative.The
Power Authority has identified a load-following case and has
analyzed the resulting stage fluctuations in the Susitna
River downstream from the Project.A report documenting
this analysis,illustrating appropriate methods of analyzing
such alternatives,is referenced below and appended as a
reference to this Response Do~ument.This load-following
hypothetical case may be characterized as "extreme,"but
remains within the flow constant of the Case C scenario.
This analysis was made to determine if,downstream of the
Project,significant attenuation of the fluctuating water
levels resulting from load--following operation would occur.
The Power Authority does not currently believe that the flow
release patterns in this report would be jUdged by many
agencies to be an environmE~ntally reasonable alternative.
Neither is it necessarily t~hought that these patterns
represent the optimum economic use of the resource.It may
be of value in that it represents an environmentally extreme
case;however,the FERC may not deem this case a "reason-
able"alternative for its analysis.A second report which
will document stage fluctuations for a more moderate case of
discharge variations is anticipated in late March 1984.We
anticipate that the FERC wi.ll identify reasonable
RESPONSE TO CO~~1ENT I.552 (cont.);
alternatives and analyze the environmental impacts of such
modes of operation in preparing DEIS and FEIS.To the
extent such alternatives are load-following,such an
environmental analysis would include consideration of
aquatic habitat effects of the mximum and seasonal mean
changes in discharge occurring on a daily basis as well as
the rates of change.Both rate of change and absolute
change associated with alternative load-following modes of
operation can be compared to natural existing conditions in
the river.
A few examples of the natural range of the daily discharge
variation is given in the Table below,taken from daily
average discharge records at Gold Creek and two other
locations at which rating curves are available.Rates of
change under existing conditions can only be indirectly
deduced from this table,but should be directly available
from USGS gaging records.Please see also the Responses to
Comments 1.346 and I.542,as well as the Responses to
Comments B.?,B.64,B.65,C.8?and F.39.
-
-
RESPONSE TO COMMENT I.552 (cont.):
'rABLE I
Daily Changes in Discharges
and Associated Changes
in Water Surface Elevation
.-
-
Date
08/31/82
06/08/82
08/02/81
08/21/81
05/07/81
05/09/81
09/15/80
09/14/80
07/02/80
09/01/79
09/22/83
09/23/83
Avg.
Daily
Discharge
(cfs)
16,000
30,000
54,000
43,100
13,600
30,000
21,600
12,000
33,800
12,100
13,600
17,500
Change
From
Prevo
Day
(cfs)
+3,000
+4,000
+20,000
+8,000
+3,600
+9,000
+9,600
+2,400
-8,600
-2,000
+3,000
+3,900
Change
in Stage
at Gold
Creek
(ft)
+0.6
+0.5
+3.2
+0.8
+1.1
+1.3
+1.8
+0.6
-0.9
-0.5
+1.0
Change in
Stage at
LR X 28
(ft)
+1.0
+0.4
+1.1
+1.2
+2.1
+0.8
-0.6
Change in
Stage at
LR X 35
(ft)
+0.8
+0.5
+1.1
+2.1
+1.0
Note:September 22,1983 discharge increased from
approximately 12,000 cfs to approximately 15,000
cfs during a one-day period.Discharge was
13,000 cfs at 0730 hours~approximately 15,000 cfs
at 1800 hours.
REFERENCES
Harza-Ebasco,Susitna Hydroelectric Project River Stage
Fluctuation'Resulting From Watana Operation (January 1984).
COMMENT I.553:
"Page E-10-34:2.3 -Access Alternatives:Please refer to
our letter dated August 17,1982 to Eric P.Yould,APA
(included in Chapte'r 11)for our comments and recommenda-
tions specific to access routing.With the elimination of
the Denali Highway to Watana roadway link,the FWS would
COMMENT 1.553 (cont.):
endorse the access routing corridors and mode.Timing of
access route construction is very important to avoiding or
minimizing adverse environmental impacts.1I
RESPONSE:
As indicated in the Responses to Comments 1.384,A.l and
A.3,the decision to select a particular access plan is
difficult,requiring the consideration of a complex set of
factors,and the analysis of a series of tradeoffs.The
Power Authority has elected to propose access from the
north,after weighing all the advantages and disadvantages
of the routes under study.Furth~r,the adoption of various
management and use restrictions controlling both the
project-related and public access impacts will limit the
extent of impacts expected.
Please refer to Mitigation Plan 10 on FERC License Applica-
tion pages E-3-531 through E-3-533 for a description of
restrictions to be followed regarding minimizing wildlife
impacts from aerial and ground disturbance.In the case of
mitigation of fish impact,please refer to FERC License
Application pages E-3-150 through E-3-160 for a discussion
of measures to mitigate impacts of construction on aquatic
habitat.Restrictions regarding timing of construction
activities will be reviewed and refined in consultation with
resource agencies prior to adoption in the final Mitigation
Plan.
From an engineering standpoint,timing is also critical,but
in a different context.Timing is important for project
engineering and construction because scheduling access
construction,as well as construction activities at the
project site itself,is very important.The"benefits of the
Denali access plan in this regard are significant compared
against other access alternatives.For example,adoption of
a rail-only access to the project gateway could cause
difficulty in equipment delivery,supply and personnel
movement,and such delays could significantly increase
project logistics cost.
COMMENT 1.554:
"Page E-I0-43:(v)Denali Highway to Watana:Paragraph 1:
Impacts to caribou would be largely avoided by eliminating
the Denali Highway-to-Watana access road.This would be
COMMENT 1.554 (cont.):
consistent with the APA Mitigation Policy,the recommenda-
tions of the resource agencies,and Access Plan Recommenda-
tion Report (August 1982)which states:
'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 immediate
detrimental impacts on the resident subherd and future
negative impacts on the main Nelchina herd although
these impacts cannot he quantified.'II
RESPONSE:
The Power Authority concurs that from a caribou conservation
viewpoint,the Denali access route'is less favorable than
proposed routes originating on the Alaska Railroad and Parks
Highway.However,the selection of an access route 'is a
many faceted issue with numerous tradeoffs.In this
instance,other factors (as discussed in the Responses to
Comments F.40,1.364 and 1.384)indicated that the preferred
routing,considering all factors,was from the Denali
Highway.
COMMENT 1.555:
IIPage E-I0-54:2.4 -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."
RESPONSE:
Responses to Comments in the January 5,1982 letter can be
referenced in the April 14,1982 letter from Mr.John
Lawrence to Mr.J.Morrison,Acting Assistant Regional
Director,USFWS.
COMHENT 1.556:
"Page E-10-83:2.4.11 -Conclusions:We concur with the
recommended transmission corridors."
.....
._--_._--_._------------------......,..,.---~----------------
RESPONSE TO COMMENT 1.556:
No response necessary.
COMMENT 1.557:
"Page E-IO-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
specific adverse environmental impacts are contained in the
Biological Stipulations provided in the FWS comments on
Chapter 3,Appendix E3B."
RESPONSE:
At the present time,the primary borrow and quarry sites are
A,D and E at the Watana site and G and K at Devil Canyon.
The other sites were not considered as primary borrow
because of lengthy haul distance to the dam sites,adverse
environmental impacts,insufficient quantities and poor
quality material.
Borrow and quarry sites will be utilized only if necessary
and,upon completion of the excava~ion operations,the sites
will be rehabilitated.
Of the above borrow and quarry sites,E and G are within the
impoundment areas or beneath the river,i.e.,material is
from the river bed and therefore will pose no visual impact.
The remaining sites,A,D and K,are necessary to supply the
required materials for the dam even though they are situated
on the upland surface.These areas adjacent to the dam
sites will be rehabilitated.See also the Responses to
Comments A.4,A.22,C.35 and 1.425.
COMMENT 1.558:
"Page E-10-105:3.1.-Project Operation and Flow
Selections:The effects of various reservoir releases on
fishery habitats between Talkeetna and the reservoir(s)is
currently insufficient for -recommending flow releases.The
relationship of mainstem and groundwater flows must be
understood.The interrelated effects of ice,sediments,
stream flow,and temperature changes which will accompany
construction,filling,and operation of the darn(s)must be
understood for predictive purposes.
-
"""
....
-
COMMENT 1.558 (cont.):
"The Arctic Environmental Information and Data Center
(AEIDC)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 profes-
sional judgement.The AEIDC study is intended to:1)
predict system-vlide stream :flow and temperature effects of
the dam(s),and 2)interprete the effects of such changes in
terms of aquatic habitats and fish populations.An AEIDC
report scheduled for comple"tion in October,1983,is ex-
pected to demonstrate how the model functions.If the model
proves satisfactory,and the appropriate level of baseline
information 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.11
RESPONSE:
The discussions in the FERC License Application that concern
flows as they relate to habitat were based on field studies
(primarily by the Alaska Department of Fish and Game and
other Power Authority contractors),available literature and
professional judgment based on experience.The field
studies were extensive,having encompassed several years of
data collection efforts..In addition,extensive studies,
designed to expand and refine the information collected in
earlier studies,have been made.The various resource
agencies have been appraised of these studies (e.g.,a
workshop on Susitna fisheries studies was held at the Power
Authority in July 1983 which described present and future
studies).The agencies are apparently aware of these
studies as reflected by the references made to these studies
in the Comments.All of this information from the various
studies will be considered in the Power Authority studies.
Therefore,the Power Authority believes that flow
discussions are not based on speculation.In addi.tion,the
flow descriptions provided in Chapter 10 of the License
Application Exhibit E are not intended to provide extensive
detail.These details are provided in Chapters 2 and 3 and
in the references cited for these chapters.Please see also
the Responses to Comments 1.346,1.542 and 1.552.
COMMENT 1.559:
"Page E-I0-I06:3.1.2 -Pre-project:The impacts of the
1969 water year (extreme drought)should be fUlly-addressed,
not dismissed.The effect of this naturally occurring event
&.i4¥Jj
COMMENT I.559 (cont.):
should be described in regard to project operations and how
biological resources would be affected.We recommend this
analysis continue through water year 1970,which was also
dryer than average."
RESPONSE:
The flow of water year 1969 was the lowest flow of record.
Because of its very low probability of occurrence,it was
replaced by a synthesized low flow of a 30-year return
period in the analyses presented in the FERC License
Application.
Recurrence of the water years 1969 and 1970 drought during
the life of the Project would be very rare if it ever
occurs.Potential impacts of the Project on the biological
resources would be favorable compared to the natural
conditions because the low flow would be augmented and the
duration of the extreme low flow would be reduced by the
Project.
COMMENT 1.560:
"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-evaluated by the applicant.We recommend that
the net benefits versus flows discussions utilize the
current economics evaluation."
RESPONSE:
The Power Authority disagrees with the conclusion that the
FERC License Application includes power demand forecasts,
alternative fuel costs and economic growth evaluations that
are high.
The estimates of power demand and fuel costs and the
economic evaluations contained in FERC License Application
Exhibits Band D were performed in the spring of 1983,and
reflect the Power Authority's most current data and
analyses.The studies are based on the reasoning,
methodology and experience of well-known forecasts,as
discussed in the Power Authority's Response to Comment 1.1.
.~,
-
.-
COMMENT 1.561:
"Page ·E-10-109:3.2.1 -Susitna River Fishery Impacts:
Please refer to our comments on page E-10-105."
RESPONSE:
Please refer to the Response to Comment 1.558.
COMMENT 1.562:
"Page E-10-110:3.3.4 -Riparian Vegetation and Wildlife
Habitat:The post-project instream flow regime has tre-
mendous 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.'II
RESPONSE:
The FERC License Application does not state that lithe regime
is unrelated to any of these factors."The correct
statement is "Riparian vege~tation is affected by one or more
of the following:floods,freeze-up and spring ice jams.
Minimum flow selection for the cases considered is unrelated
to any of these factors.Hence,riparian vegetation effects
were not considered in mini.mum project flow selection.1I
The minimum flows for the cases considered for the License
Application (Table E.2.34,Figure E.2.130)would not control
discharge from the reservoir during periods of spring or
summer floods,freeze-up or spring ice jams.Minimum flood
discharges for spring floods were considered (FERC License
Application page E-10-111),but because of the importance of
spring flood storage to project economics,were not
implemented.The impacts of minimum flow selection on
summer floods is also discUlssed on page E-10-111.Freeze-up
normally occurs between lat:e October and December vlhen
reservoir discharge is controlled by the demand for power.
Provisions of a minimum discharge greater than the power·
demand during this period would raise the water level and .
possibly adversely affect riparian vegetation as noted in
the Responses to Comments C.42 and 1.348.Spring ice jams
occur as a result of warming air temperatures,precipitation
in the form of rain,runoff:from the basin and resulting
increased stream flow.The Project will regulate these
spring floods.and should reduce the severity of ice j a,mming
RESPONSE TO COMMENT 1.562 (cont.):
(License Application page E-2-126).Please see also the
Responses to Comments 1.346,1.542 and 1.552.
In addition to floods,freeze-up and spring ice jams,
riparian vegetation is affected by riparian groundwater.
relationships,primarily groundwater levels.Reduced main-
stem flows during the summer with-project may result in a
reduction of groundwater levels near the stream,as
described in the License Application (page E-2-97).Farther
away from the river,the change will be less,since fluctua-
tion of groundwater levels in response to changes in river
stage is generally effectuated with distance from the river.
To adapt to somewhat lower groundwater levels,there may be
a change in plant species composition near the stream bank.
COMMENT 1.563:
"Page E-IO-111:3.3.4 -Riparian Vegetation and wildlife:
It is stated that,'••.it may be·d~sirable 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 this 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 the 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:
See Response to Comment 1.29.
COMMENT 1.564:
"Page E-10-112:3.5 -Maximum Drawdown Selection:This
section should be reexamined in light of the most recent
economic evaluation.
"The environmental impacts implications of water year 1969
alone,and in conjunction with water year 1970,should be
examined.This is a naturally occurring sequence and could
repeat during the life of the project."
~t_
~.
~'
.....
,....
RESPONSE TO COMMENT 1.564:
Maximum drawdown selection is based on the natural
streamflows of record,instream flow regime and power and
energy demand.In the reservoir operation studies being
undertaken to evaluate the effect of project operation on
the instream flow regime and biological resources,the flows
as recorded at the gaging stations are being used without
adjustment,as discussed in the Power Authority's Response
to Comment I.559.Selected flow regimes will form the basis
for flow regime settlement negotiations.
The estimates of power demand and the economic evaluations
contained in FERC License Application Exhibits Band D were
performed in the spring of 1983.The studies are discussed
in the Power Authority's Response to Comment I.l.Maximum
drawdown was selected under load forecasts of comparable
magnitude.
COMMENT 1.565:
"Page E-I0-115:4.1 -Coal -Fired Generation Alternative:
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 Railbelt
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 environ-
mental 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 interests.Preliminary
environmental and engineeri.ng 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 environmental 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
----------------~-----,-------------------
COMMENT 1.565 (cont.):
in their second year.Preliminary reports on the 19a2
studies are now available and should be incorporated into
the discussions.10/2/
"We note that the referenced economic and technical
feasibility analysis is included in Exhibit D,not Exhibit B
as stated here.Please also see our General Comments on
this Chapter's failure to directly compare non-hydropower
alternatives with the Susitna proposal,even to the general
extent that those comparisons are provided for other
hydropower alternatives.1I
"10-2/Environmental Research and Technology,Inc.April
19837 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.Environ-
mental Research and Technology,Inc.and OTT Water
Engineers,Inc.April 1983.1982 Data Report Aquatic
Biology,Diamond -Chuitna Project Baseline Studies.Fort
Collins,Colorado."
RESPONSE:
Based on economic and engineering analyses of the major coal
fields in Alaska,it appears that the state's coal
requirements could be satisfied by mining only the two
largest and least expensive coal fields:Beluga and Nenana.
The generalized environmental impacts caused by mining and
electrical generation of these two coal fields were
presented in Exhibit E of the FERC License Application!and
in the earlier Railbelt electrical alternatives study.The
environmental impacts of the remaining coal areas were not
investigated,because it appears unlikely that there will be
future economic incentives to develop those sites.
The site-specific environmental impacts caused by major
development of either the Beluga or Nenana would certainly
have to be investigated in~etail prior to their actual
development.An extensive NEPA environmental impact
statement would have to be prepared,comparing the
environmental impacts of the proposed coal field development
with the impacts of other alternatives.The April 1983
..
~I
~I
-
-
RESPONSE TO COMMENT 1.565 (cont.):
baseline studies referenced by the commentor would be useful
for preparation of that E1S.
1 Battelle Pacific Northwest Laboratories,Railbelt
Electric Power Alternatives Study (December 1982).
COMMENT 1.566:
"Page E-10-l16:4.1.1 (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."
RESPONSE:
We are aware of the referred-to vegetation and wetland
mapping,much of which has only recently become available.
Please note that the FERC L,icense Application,at the top of
page E-IO-119,notes the importance of the area's coastal
wetlands to birds as it states:"The coastal wetlands and
mud flats are heavily utilized by waterfowl,cranes,and
shorebirds,while the offshore waters and sea cliffs are
inhabited by sea birds such as gulls,pUffins,and murres."
COMMENT 1.567:
"Page E-IO-117:(ii)Fauna:Nests of trumpeter swan in the
Beluga and Susitna areas have been mapped and the location
data computerized.This information is readily available
from the F~qS for comparative analyses."
RESPONSE:
The Power Authority is aware of and has utilized this
information base.
COMN.ENT 1.568:
IIPage E-10-118:ecl Aquatic Ecosystem:Preliminary
quantitative baseline data are now available on Beluga area
resources.10-3/11
1110-31 See Footnote 10-2.[Footnote 10-21 Environmental
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.]II
RESPONSE:
The potential impacts of the Beluga coal field development
on the marine ecosystem in the Cook Inlet region were
discussed in Exhibit E of the FERC License Application.It
was concluded that the coal field development would result
in some reduction in anadromous fish production.The
detailed Cook Inlet baseline studies referenced by the
commentor should provide excellent background data for any
future NEPA environmental impact studies,which would be
required prior to the actual coal field development,if any.
COMMENT 1.569:
"Page E-10-120:4.1.2 -Environmental Impacts:with recent
acceptance of the Alaska Surface Coal Mining Control and
Reclamation Program by the Federal Office of Surface Mining,
a comprehensive 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 Air Act.
liTo fully'compare alternative power developments within the
NEPA process as described previously,a comparative discus-
sion on environmental impacts should be provided here.For
example,Susitna hydropower development will result in
significant and irreversible habitat losses,with primary
habitat impacts occurring within a concentrated time frame,
-
-
-
-
-
COMMENT 1.569 (cont.):
and a work force of several thousand individuals during the
first several years of proj,ect development.In comparison,
Beluga coal development would result in small but continual
annual habitat losses,potentially reversible habitat
impacts,and an initially smaller work force which \'oJ'ould
remain for the project life.Quantitative estimates of
these habitat impacts,work force needs,and transportation
requirements,should be provided and compared here for the
Beluga development,the incremental impacts of expanding the
Nenana coal mine,and the proposed Susitna project."
RESPONSE:
The Alaska Surface Coal Mining Control and Reclamation Act
was enacted in 1982,under Alaska Statutes,Title 41,
Chapter 45.This law was enacted in response to the federal
SMCRA,and placed the permitting and regulation of surface
mines under the jurisdiction of the Alaska Department of
Natural Resources (ADNR).The regulations and performance
standards of the Alaska program are designed to be
consistent with the federal surface mining guidelines under
the Department of the Interior.Point source discharges
from mining and power plant operations are still regulated
under the federal NPDES program.
In response to the commentor,paragraph 5 of page E-IO-120
of the FERC License Application does indeed refer to the
Clean Air Act.
The environmental impacts of the proposed Susitna
Hydroelectric Project,the Beluga coal mine/power plant,the
Nenana mine expansion/power plant,and various North Slope
natural gas transport/electrical generation options have
already been presented in earlier studies (1),(2)and (3).
A hydroelectric alternatives study was also conducted by the
u.S.Army Corps of Engineers.The impacts of these projects
on air quality,soils/geology,hydrology/water quality,
terrestrial ecology,aquatic ecology and socioeconomics are
compared in the attached Table 1.It should be noted that
--------~---.,...--"----------------,----,.---------------------
RESPONSE TO COMMENT I.569 (cont.):
the Susitna project represents 1620 MW of installed capacity
as compared with only 400 MW for each of the thermal
alternatives.
REFERENCES
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 II,Selection of Electric Energy Generation
Alternatives for Consideration in Railbelt Electric
Energy Plans (December 1982)
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).
-
1 1 J }J 1 J J 1 1 1 .~]
I RESPONSE TO COMMENT 1.569 (cont.):
Table 1
SUMMARY OF ENVIRONMENTAL IMPACTS CAUSED BY
ALASKA RAILBELT ELECTRIC POWER ALTERNATIVES
Parameter
Hydrology
and Water
Quality
Sus itna Hyd ro-
electri~rroject,
1620 MW a
Impoundment of the
Susitna River would
inundate approximately
86 miles of river
(plus associated
tributaries).The
reservoirs may alter
downstream tempera-
ture and flow regimes.
Between Devil Canyon
and Talkeetna,peak
summer water tempera-
tures are expected to
be decreased and mini-
mum winter tempera-
tures are expected to
increase.To avoid or
minimize temperature
changes,multi-level
Beluga Coal Field
and 400 MW Coal
Fired Generator
Strip mining could
interfere with ground-
water flows and degrade
water quality.Surface
water could be affected
by runoff from the mine j
coal pile,and other
constructed areas.
Groundwater could be
affected by acid mine
drainage and ash disposal
pond leachate.Long-term
changes in pH,turbidity,
and trace metals concentra-
tions are expected.Dis-
charges would be minimized
by compliance with SMCRA
and NPDES guidelines.The
power plant would require
Nenana Coal Field
Expansion with 400 MW
Coal Fired Generator
Because the Nenana mine
is already in operation,
the incremental impacts
of mine expansion may be
less than those for the
new Beluga mine.Long-
term impacts of the power
plant would be similar to
those caused by the Beluga
option.
North Slope to Fairbanks
Gas Line with 400 MW
Combined Cycle Generator
The gas fired power plant
would require roughly
2,200 gpm of fresh water
for boiler makeup and
miscellaneous uses.The
gas pipeline would cross
15 major streams and
and numerous small
streams.The buried,
chilled pipe could
disrupt both ground-
water and surface water
flows.Road cuts for
pipeline access could
cause disruption of
groundwater flows,and
also cause changes in
surface runoff and soil
erosion.
(a)Watana plus Devil Canyon Developments.
RESPONSE TO COMMENT 1.569 (cont.):
Table 1 (cont.)
SUMMARY OF ENVIRONMENTAL IMPACTS CAUSED BY
ALASKA RAILBELT ELECTRIC POWER ALTERNATIVES
Parameter
Susitna Hydro-
electrit ,roject,
1620 MW a
intakes will be provi-
ded in the dams which
allow for control of
downstream tempera-
tures.A more stable
flow regime is expected
downstream of the Pro-
ject with low winter
flows increased and high
summer flows (particu-
larly flood events)
decreased.Ice forma-
tion is expected to
decrease,particularly
between Talkeetna and
Devil Canyon.Sus-
pended sediment levels
between Talkeetna and
Devil Canyon will be
significantly reduced.
Turbidity levels will
be significantly
reduced in the summer
and slightly increased
during winter.Down-
s~ream of Talkeetna,
Beluga Coal Field
and 400 MW Coal
Fired Generator
roughly 4,000 gpm of fresh
water for boiler makeup and
miscellaneous uses.
Nenana Coal Field
Expansion with 400 MW
Coal Fired Generator
North Slope to Fairbanks
Gas Line with 400 MW
Combined Cycle Generator
J .~J I i l i j I ,t I i 1 .~I J
I ~I )~I ]I j 1 T i I i 1
RESPONSE TO COMMENT 1.569 (cont.):
Table 1 (cont.)
SUMMARY OF ENVIRONMENTAL IMPACTS CAUSED BY
ALASKA RAIL BELT ELECTRIC POWER ALTERNATIVES
Parameter
Terrestrial
Susitna Hydro-
electri~yroject,
1620 MW a
project impacts are
expected to be less
significant due to the
influence of flows from
the Chulitna and
T~l~oort~o p~'7opaLa~~__LL~~~~v_~~.
Construction of the
Susitna Hydroelectric
projects (Watana and
Devil Canyon dams and
reservoirs)will result
in the direct removal
of vegetation from an
area of approximately
42,000 acres covering
a range of elevations
from 900 to 2400 feet.
An additional 7300
acres of unvegetated
areas (mostly existing
river area)will be
inundated or developed.
84%of the vegetated
area to be cleared is
forest land.This
Beluga Coal Field
and 400 MW Coal
Fired Generator
Surface mining and power
plant operation would
create long-term impacts
on wildlife habitats.
For one mining scenario,
the ultimate pit bound-
aries cover roughly 8 sq.
miles and the support
facilities would cover
roughly 500 acres.Min-
ing pperations would con-
sume roughly 250 acres/yr.
of habitat.New roads
into the mine area would
cause substantial losses
in carrying capacity and
productivity in the
affected areas.
Nenana Coal Field
Expansion with 400 MW
Coal Fired Generator
The incremental impacts
of the Nenana mine expan-
sion would probably be
less than operation of
the new Beluga mine.
Impacts of the Nenana
power plant would be simi-
lar to those of the
Beluga plant.
North Slope to Fairbanks
Gas Line with 400 MW
Combined Cycle Generator
Pipeline construction
would require clearing
of a 50-ft.right-of-way.
Construction-related
impacts could intermit-
tently disrupt wildlife
habitats during the 3-
year construction period.
The pipeline compressor
stations and metering
facilities would require
roughly 100-150 acres of
land.The Fairbanks
generating station would
have a minimal impact on
wildlife.
RESPONSE TO COMMENT 1.569 (cant.):
Table 1 (cont.)
SUMMARY OF ENVIRONMENTAL IMPACTS CAUSED BY
ALASKA RAILBELT ELECTRIC POWER ALTERNATIVES
Parameter
Susitna Hydro-
electrit Jroject,
1620 MW a
represents 10%of the
forest land within
10 miles of the Susitna
River from Gold Creek
to the north of the
MacLaren River.
Removal of vegetation
and filling of the
reservoir will reduce
the carrying capacity
of the area for wild-
life.The presence
of the reservoirs and
the access roads will
potentially impact
movements of moose,
caribou and other big
game in the area.
New roads would add
access to this pre-
sently remote area.
The Project,including
access and transmission
routes.will disturb
Beluga Coal Field
and 400 MW Coal
Fired Generator
Nenana Coal Field
Expansion with 400 MW
Coal Fired Generator
North Slope to Fairbanks
Gas Line with 400 MW
Combined Cycle Generator
1 'E ~1 3 I .~~J 1 J J .~J i J 1 .~
J J ])1 J 1 ]-]I j
RESPONSE TO COMMENT 1.569 (cont.):
Table 1 (cont.).
SUMMARY OF ENVIRONMENTAL IMPACTS CAUSED BY
ALASKA RAILBELT ELECTRIC POWER ALTERNATIVES
Parameter
Susitna Hydro-
electri~Jroject,
1620 MW a
18 recently active
raptor and raven nests
and 16 or 17 inactive
nests.
Beluga Coal Field
and 400 MW Coal
Fired Generator
Nenana Coal Field
Expansion with 400 MW
Coal Fired Generator
North Slope to Fairbanks
Gas Line with 400 MW
Combined Cycle Generator
during dam construc-
tion:particles,1,300
tons/yr.;S02'300 tpy;
NO ,2,300 tpy.Long-
te~m emissions after
dam completion should
be minimal.Ambient
pollutant concentra-
tions should be well
below all applicable
standards.
Air Quality Ch __...._...r'Io"..'I'Yl
iJllV.L \.-\..~.Ll.Il .n.'ft\;~~-ir.nO~J.u.LO0 .....\J'.LLO Short-term emissions
would occur during power
plant construction.Long-
term power plant emissions:
particles,1,800 tpy;S02'
1,700 tpy.These emissions
would occur for the entire
power plant life.Ambient
S02 concentrations would be
higher than the short-term
concentrations for the
Susitna project,and could
violate state air quality
standards.
Emissions from the Nenana
power plant should be simi-
lar to those from the
Beluga plant.However,
'the Nenana site is located
in a Class I PSD area.The
air quality impacts of
power plant emissions on
the protected area would
be very significant,and
siting of any major power
plant to meet very strin-
gent PSD regulations would
be extremely difficult.
Short-term emissions would
occur during pipeline and
power plant construction.
Long-term power plant emis-
sions:'negligible particu-
lates and S02;approx.
5,300 tpy of NO.Negligible
emissions from ~ipeline com-
pressor stations.Ambient
pollutant concentrations
would exceed those for the
Susitna project.
Geology
and Soils
Dam construction,
reservoirs,borrow
sites and construc-
tion camps would
affect roughly 50,000
acres.Roughly 80-90
The Beluga mine and facili-
ties would cover roughly
9 sq.miles.Mining opera-
tions would impact roughly
250 acres/yr.Topography
in the mine area would be
The Nenana coa.l mine is
already operating,so
initial expansion would
probably cause less impact
than would startup opera-
tions of the new Beluga
The buried pipeline would
cause localized soil
impacts along the entire
right-of-way.Pipeline
compressor stations,gas
conditioning plants and
RESPONSE TO COMMENT 1.569 (cant.):
Table 1 (cont.)
SUMMARY OF ENVIRONMENTAL IMPACTS CAUSED BY
ALASKA RAILBELT ELECTRIC POWER ALTERNATIVES
Parameter
Aquatic
Ecosystem
Susitna Hydro-
electri~)roject,
1620 MW a
miles of new access
roads would be needed.
In the reservoir area,
existing Susitna River
and affected tributary
aquatic habitat will
change from free flow-
ing to a reservoir.
Aquatic resources char-
acteristic of a large
glacially-fed lake or
reservoir would
develop.Small lakes
within the inundation
zone would be simi-
larly changed.
Between Talkeetna and
Devil Canyon,flow
alteration is expected
to provide a more
stable regime and
aquatic habitat with
Beluga Coal Field
and 400 MW Coal
Fired Generator
permanently affected.The
power plant.coal storage,
and ash disposal facilities
would occupy roughly 75-
150 acres.
Some aquatic habitat would
be lost due to mining opera-
tions.In addition,in-
creased siltation,stream-
flow reductions,reduced
stream pH and increased
trace metal concentrations
could result from mine
drainage and power plant
effluent discharges.The
adverse water quality im-
pacts could reduce fish
populations in local
streams and interfere with
anadromous fish runs,poten-
tially reducing marine re-
sources in the Cook Inlet
region.
Nenana Coal Field
Expansion with 400 MW
Coal Fired Generator
mine.Long-term incre-
mental mining operations
would create impacts simi-
lar to those for the Beluga
project.The Nenana power
plant would create impacts
similar to those for the
Beluga plant.
Impacts of the Nenana mining
activities and power plant
operation could adversely
affect fish populations and
anadromous fish runs in
local streams.These
impacts would be similar to
those caused by the Beluga
operation.
North Slope to Fairbanks
Gas Line with 400 MW
Combined Cycle Generator
the power plant would
require roughly 150-200
total acres.
The gas pipeline would
cross numerous small
streams,as well as 15
major rivers and streams.
Considerable mitigative
measures would be required
to prevent stream blockage
due to pipeline freezing,
increased stream velocity
due to stream diversion,
changes in stream tempera-
ture caused by presence of
the chilled pipeline.and
prolonged stream freeze-
ups that could hinder fish
migrations.The Fairbanks
power plant would have
minimal impacts on the
aquatic ecosystem.
,~I ,),)J ~)),_J ~j ~I .1 ,J
J --I --1 1 -J J J J I -i I J B 1 I i
RESPONSE TO COMMENT 1.569 (cont.):
Table 1 (cont.)
SUMMARY OF ENVIRONMENTAL IMPACTS CAUSED BY
ALASKA RAILBELT ELECTRIC POWER ALTERNATIVES
Parameter
Susitna Hydro-
electrit ,roject,
1620 MW a
increased winter flows
and decreased high sum-
mer flows (particularly
floods).Access for
adult salmon to sloughs
is expected to be hind=
ered.However,access
is to be maintained by
mitigation measures.
Temperature regime
changes resulting from
reservoir releases may
alter timing of speci-
fic life stages of fish
such as time of spawn-
ing,incubation time
and rearing."Multi-
level intakes in the
dams are expected to
provide control of
downstream tempera-
tures so as to avoid
or minimize this
effect.Decrease in
Beluga Coal Field
and 400 MW Coal
Fired Generator
Nenana Coal Field
Expansion with 400 MW
Coal Fired Generator
North Slope to Fairbanks
Gas Line with 400 MW
Combined Cycle Generator
RESPONSE TO COMMENT 1.569 (cont.):
Table 1 (cont,.)
SUMMARY OF ENVIRONMENTAL IMPACTS CAUSED BY
ALASKA RAILBELT ELECTRIC POWER ALTERNATIVES
Parameter
Susitna Hydro-
electrit ,roject,
1620 MW a
downstream sediment
loads would be expec-
ted to increase ben-
thic habitat;however,
turbidity may minimize
light penetration and
productiVity.Down-
stream of Talkeetna.'
project impacts are
expected to be less
significant due to the
influence of flows
from the Chulitna and
Talkeetna Rivers.
Beluga Coal Field
and 400 MW Coal
Fired Generator
Nenana Coal Field
Expansion with 400 MW
Coal Fired Generator
North Slope to Fairbanks
Gas Line with 400 MW
Combined Cycle Generator
Socioeconomic Impacts on the Mat-Su
Borough should be
minor.because most
construction workers
will be housed at the
dam site.The total
expected population
increase during the
Watana construction is
4.700 persons.3.600
of which will live at
the full service town-
sites at Watana.
Construction and opera-
tion of the Beluga mine
and power plant could
have major socioeconomic
impacts.Construction
activities would create
an influx of over 500
workers into an area
with low population and
minimal infrastructure.
Even if a construction
camp were established.
the presence of the
The Nenana site is situated
near Fairbanks.Most of
the 500 person labor force
would probably originate
from and live in the Fair-
banks region.A severe
boom due to Nenana plant
construction and operation
would therefore be unlikely.
The overall socioeconomic
impacts of the facility
would probably be minimal.
Generator construction
should have a minimal
effect on the Fairbanks
region.The estimated
workforce for generator
construction is 200-400
persons.Most construc-
tion workers would come
from the Fairbanks labor
pool.lvlinimal additional
housing and services
would be needed.Facility
construction would create
E !I j .~J J I t )I ,J I ~I .1 I .1 "
I I 1 1 ]1 1 1 1 i J J 1 1 1
RESPONSE TO COMMENT 1.569 (cont.):
Table 1 (cont.)
SUMMARY OF ENVIRONMENTAL IMPACTS CAUSED BY
ALASKA RAILBELT ELECTRIC POWER ALTERNATIVES
Parameter
Susitna Hydro-
electrit )roject.
1620 MW a
Virtually all social
services for the 3.600
persons will be pro-
vided by the contrac-
tor.The remaining
1.100 persons are
expected to inmigrate
to the local towns of
Cantwell.Trapper
Creek and Talkeetna~
This relatively low
population influx would
increase the utilities
and services costs for
those towns by only a
few percent.The total
traffic flow on the
existing Parks and
Denali Highways will
increase by only 30-35
trucks per day plus
commuter vehicles.
Additional snow re-
moval and maintenance
will be required for
the Denali Highway.
Beluga Coal Field
and 400 MW Coal
Fired Generator
required access roads
and other facilities
would probably create
significant impacts.
Operation of the mine and
power plant would require
between 100-200 permanent
employees.most of which
would probably live near
the site.Considering
that the largest local
town.Tyonek.has a popu-
lation of less than 250.
the influx of permanent
workers would create major
socioeconomic impacts.
Nenana Coal Field
Expansion with 400 MW
Coal Fired Generator
North Slope to Fairbanks
Gas Line with 400 MW
Combined Cycle Generator
slight short-term increases
in Fairbanks'traffic flow.
Operation of the power
plant would provide addi-
tional tax revenues for
the region.For pipeline
construction.workers
could be housed in existing
campsites used for the
Trans-Alaska oil pipeline.
COMMENT I.570:
"Page E-10-122:Aquatic and Marine Ecosystems:We ap-
preciate inclusion of quantitative estimates on area fishery
resources and potential impacts to them.Similar estimates
for consumptive use and for Susitna area resources should
also be included."
RESPONSE:
Comment noted.
COMMENT I.571:
"page E-10-141:4.3.1 -Natural Gas:Since natural gas is
considered by many to be the best single energy source
alternative to the Susitna project 10-41 it is disconcerting
to see so minimal an effort expended examining this alterna-
tive.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 potential environ-
mental impacts nor is a tradeoff examination made of natural
gas and other alternatives."
"10-41 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 Alaska,15 pp.
"See Footnote 10-1.[Footnote 10-11 ADF&G.1983.Synopsis
of the 1982 Aquatic Studies and Analysis of the Fish and
Habitat Relationships.Prepared for the APA.]II
~,
RESPONSE TO COMMENT 1.571:
The Power Authority objects to the characterization of its
assessment as lIinadequate.n An economic and financial
assessment of natural gas as an alternate source of electric
power for the Railbelt is presented in Exhibit D.The
economic analysis presented in Exhibit D indicates that
natural gas is not an acceptable alternative to Susitna.
For a summary comparison of the environmental impacts of the
proposed Susitna proj ect,t'wo separate coal mining/power
plant options,and one North Slope natural gas
transmission/electric generation alternative,please refer
to the Response to Comment 1.569.
COMMENT 1.572:
IIPage E-10-143:4.3.4 -Environmental Considerations of
Non-Coal Thermal Sources:'We do not consider the potential
environmental impacts of burning natural gas to be the same
for diesel,oil,or coal.'We recommend that environmental
considerations be examined separately for each of these fuel
alternatives.Then they should be examined through a
tradeoff analysis which would include the proposed Susitna
project,within basin alternatives,hydropo\-ler projects
outside the Susitna basin,and non-hydropower alternatives
to the proposed Susitna project."
RESPONSE:
Both diesel oil and crude oil were eliminated as viable fuel
options because of economic considerations.Economic
analyses were presented in Exhibit D of the FERC License
Application.
For a summary of the environmental impacts of natural gas
and coal usage,please refer to the Response to
Comment 1.569.
COMMENT 1.573:
npage E-10-162:4.6.3 -Potential Application in the
Railbelt: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
~-_._.....,.---~~------
COMMENT I.573 (cont.):
potential geothermal development site within their jurisdic-
tion.The lease sale was undertaken because the site:1)
has high potential (until exploratory drilling occurs,the
viability of the site will be unknown);2)is located on
State land;and 3)is close to existing transmission lines
(Beluga Station).In addtion,it is located between the
Chakachatna River and the Beluga Coal fields,an area
already being explored for power development,and criss-
crossed by logging roads.It would also seem logical to
explore the possibility of a West Cook Inlet power genera-
tion 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 facilities."
RESPONSE:
As was discussed in Exhibit E of the FERC License
Application,geothermal energy is not expected to be an
electrical generating alternative to the Susitna project.
The advantages and disadvantages to the use of geothermal
energy were presented in Exhibit E.While the cow~entorrs
information on the Mt.Spurr geothermal site provides some
additional advantages for that site over other geothermal
areas,it is unlikely that the Mt.Spurr site would serve as
a major power source for the Railbelt.
COMMENT 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 environmental conse-
quences 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 Railbelt region does have a
fall back plan in the event that the Susitna project is not
licensed.We recommend that such planning be undertaken.1I
M4
-
....
.-
RESPONSE TO CO~ll4ENT I.574:
The specific sequence of electrical power projects that
would be constructed by private and public organizations
would depend on many economic considerations.Please refer
to Exhibit D of the FERC License Application for economic
evaluations of alternative hydroelectric and geothermal
power facilities that would have to be constructed if the
Susitna.FERC license were denied.See also the Power
Authori ty Response to Comme:nt I.540 •
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".'"
COMMENT r.575:
"The total proposed access plan is duly influenced by the
preferences of private landowners in the Susitna project
area.However,the more complete the project area is
opened,the more significan-t attendant impacts on natural
values and resources of the area will-result."
RESPONSE:
See Response to Comment A.3.
COMMENT I.576:
"It is indicated that bridges are preferred (to culverts)
but specific locations or limits of use are not specified."
RESPONSE:
See Response to Comment A.S.
COMMENT I.577:
""The transmission corridors are acceptable if state of the
art siting and construction practices are employed."
RESPONSE:
See Response to CommentA.19.
COMMENT I.578:
"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."
RESPONSE:
See Response to Comment A.20.
COMMENT 1.579:
npOWER SITE CONSIDERATIONS
"From the standpoint of resource utilization we note
potential flaws with the plan formulation 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 darn at Watana 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
regulated 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,rela-
tively 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 fuT!
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 •.
-
COMMENT 1.579 (cont.):
"Further cost reduction may be possible by utilizing either
a rockfill or thin arch dam at Watana after the height
reduction brings the dam back within the natural canyon.
liThe 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 Denali was a physically
suitable damsite.Even if considerable foundation work is
required,it would appear that this.key damsite should not
be abandoned ~ithout a thorough investigation.It offers
the only low-cost storage in the Upper Susitna Basin.
"Full system development offers the advantage of staging
whereas the applicant's proposal does not.Its proposal is
saddled with the enormous initial costs required for the
first stage which would be the high Watana Dam.In
contrast,Denali,MacLaren and Vee,along with all
transmission faciliites,could all be built for half the
cost of Watana."
RESPONSE:
The Power Authority believes that the plan formulation and
selection methodology used for alternative site
considerations is reasonable and that the evaluation is
adequate.
The planning principle espoused by DOl is indeed valid,that
is to say 1I •••va lid comparisons can only be made if the type
of dam that best suits the particular site is used for
evaluation."This is recognized by the Power Authority;
however,the use of rockfill dams for comparative studies
should not significantly affect the choices for project
development for the following reasons:
1.Where foundation data were not available,it was
considered prudent to use fill dams rather than
concrete dams because fill dams can accommodate weaker
foundations.The regional geology interpreted in light
RESPONSE TO COMMENT I.579 (cont.)
of'the serious foundation problems at some of the sites
where there had been a degree of foundation exploration
(Devil Canyon,Denali,Vee and Watana)did not justify
optimism concerning foundations at the remaining sites.
Indication of (a)no substantial rock in the foundation
(Denali),(b)deep weathering,drift and talus on the
abutments (Vee)or (c)deep relict channels near the
Susitna River (Vee,Watana and Devil Canyon)were not
conducive to high expectations at sites that had not
been drilled (MacLaren,Susitna III and High Devil
Canyon).Reference Appendix D,Table D.2 -
Geotechnical Design Considerations contained in the
following two-volume report:Acres American Incor-
porated,Susitna Hydroelectric Project,Development
Selection Report (December 1981),prepared for the
Alaska Power Authority.
The premise that the comparison of individual sites cannot
be used when evaluating the potential of a river system is
not universally true,but can be accepted on a limited basis
for the Susitna Basin.However,this comment is something
of a puzzle since the underlying studies contain both
comparisons of systems and sites.For example,FERC License
Application Exhibit B,Table B.5 clearly demonstrates the
2.
3.
The later comparison of costs of rockfill dams to
concrete dams at Watana and Devil Canyon tended to
demonstrate that the choice of rockfill over concrete
dams did not affect the evaluation of project devel-
opment sites in any event.Comparison of cost of a
rockfill dam with a concrete dam at the Watana site
indicated that the concrete would not produce any
significant cost savings.A similar analysis of the
Devil Canyon site showed that the rockfill darn did not
offer significant cost savings in relation to a thin
arch darn.Reference Appendix H,pages H-5 and H-4,
respectively,of the above-referenced Development
Selection Report.
The II roc kfill"assumption was extended to consider
earth/rockfill with a flattening of embankment slopes
(and increase in volume of fill although the incre-
mental fill costs less per unit of volume than the
average cost of rockfill)where the foundation was
known (Denali)or suspected (MacLaren)to be weak.
Reference Appendix D,Table D.2,of Development
Selection Report.At these sites,the layout most
appropriate to the foundation conditions,i.e.,
earth/rockfill,was used.
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RESPONSE TO COMMENT 1.579 (cont.):
results of comparisons of systems as well as individual
sites.
During the site screening studies four basic criteria were
used;these included environmental,alternative sites,costs
and energy contribution.Individual sites were eliminated
as being unacceptable for environmental reasons or for being
the least promising of two mutually exclusive alternatives
as shown below (see also the Response to Comment 1.544).
Unacceptable
Gold Creek
Olson
Tyone
Excluded By More Favorable Alternatives
.Devil Creek/High Devil Canyon
Butte Creek/Denali
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A screening model was used with data on the Devil Canyon,
High Devil Canyon,Watana,Susitna III and Vee as power
sites and MacLaren and Denali as sites for river regulation.
Both MacLaren and Denali were eliminated,in the process of
program operation,because they did not contribute enough to
energy generation,in comparison to their cost,to be
justified.Reference Appendix E,Paragraphs E.3 (page E-3)
and E.5 (page E-5),Development Selection Report.
The screening studies did in fact test the cost aspects of
different arrangements of the sites with different sizes of
dams (License Application Exhibit B,Table B.5).However,
power generation at Denali was never included.This
increment to the Susitna Basin development is not precluded
by the proposed project.This is only partly pertinent
since it was shown that an increment of generation at Denali
is much more costly than a unit of generation at the Susitna
Project.
There is also a point made that additionai head
(1,550 feet vs.1,300 feet)could be derived by including
Vee (or Susitna III).For the given demands,the screening
studies determined the most economical solution was Watana
and Devil Canyon when compared to a development with Vee.
The add~tional head is not justified.
The data provided from the Bureau of Reclamation drilling
indicates that Denali has relatively unsuitable foundations.
Reference Appendix D,Table D.2,Development Selection
Report.However,Denali was excluded from the Susitna
Project on the basis of the economic evaluation.This
conclusion does not preclude or even prejudice its eventual
development.Denali also is known to be very objectionable
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RESPONSE TO COMMENT I.579 (cont.):
environmentally because of its effects on caribou feeding
grounds and migration routes (see also,the Response to
Comment I.544).
The Power Authority's study incorporates the following
preliminary data regarding costs of Denali,MacLaren and Vee
as contrasted to Watana.
~l
Investment
Deve1op-per Annual ~
ment Cost
10 6 Dam Height Annual Energy KWh
1980 $ x feet GWh/yr $
~
Watana 1,860 880 3,250 0.57
Vee 1,060 610 1,370 0.77
MacLaren 530 185 180 2.94
Denali 480 230 245 1.96
MacLaren and Denali would provide downstream storage bene-
fits at Vee.Denali plus Vee,with Denali contributing
600 GWh annually to Vee,would provide 2,215 GWh annually
for $1,540 million or $0.70 per annual kilowatt hour.The
cost of energy from the combination exceeds the cost of
energy from Watana.
A study of combinations of sites shows the following:
Investment
per
Sites Cost
10 6 Annual Energy Annual KWh
1980 $x GWh/yr $
Watana plus
Devil Canyon 2,860 6,230 0.46
High Devil Canyon
plus Vee 2,560 4,910 0.52
Devil Canyon
plus Watana
680 ft plus Vee 3,260 5,290 0.61
Devil Canyon
plus Watana
680 ft plus Denali 2,680 4,165 0.64
The investment cost of Watana is indeed greater than most of
the alternatives but its power generation is more than
correspondingly greater.The features of the three
alternative development sites are not additive in that
backwater from Vee will interfere vJi th the MacLaren site
~
I
RESPONSE TO COMMENT I.579 (cont.):
once the 'height of the dam at Vee exceeds 405 feet.This
summary analysis,while con.taining approximations,is a
comparative illustration of costs and functions of the
alternatives.The much more comprehensive screening
analysis of the plan selection studies addressed the
question of this and other alternatives before indicating
the preference for proposed Project.
REFERENCES
Acres American,Inc.,Susitna Hydroelectric Project,
Development Selection,Fina.l Report (December 1981),
previously submitted to the:FERC on March 15,1982.
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