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HomeMy WebLinkAboutAPA2962--------.-----------·--·----·-·-. ·-----·--· ·--- . REVISED DRAFT . . ENVIRONMENTAL lMPACT STATEMENT lfydroelectric Power Development 182 UPPER SUSITNA RIVER BASIN SOUTHC~NTRAL RAILBELT AREA ALASKA OFFICE OF THE CHIEF OF ENGINEERS ) DEPARTMENT OF THE ARMY WASHINGTON, D.C. 20314 DECEMBER', 1975 / Hydroelectric Power Development, Upper Susitna River Basin (Southcentral Railbelt Area, Alaska} TK ·1465' .s~ A~3 (\_0 • 4fJ lf 0 (X} ~evised Draft Environmental Statement S ta te~.;ent ( ) Final Environmental Responsible Office: Alaska District, Corps of Engineers Colonel Charles A. Debelius, District Engineer P.O. Box 7002, Anchorage, Alaska 99510 Telephone (907} 753-3128 1. Name of Action: ( } Administrative ( X } Leg i s 1 a t i v e 2. D_~scription of Action: The recommended plan is to construct dams on the upper Susitna River at Watana and Devil Canyon, powerplants, elec- tric transmission facilities to the Railbelt load centers, access roads, and permanent operating and recreational facilities. Since the current study is in the feasibility stage, impacts are not exhaustively evaluated. If the project is authorized and funded for detailed preconstruction studies, the environmental, social, economic, and engineering aspects of the project will be studied at greater depth and length prior to a recommendation to Congress for advancement to final project design and construction phase. 3 a. Environmental Impact~: The two-dam system would inundate some 50,500 acres extending 84 miles upstream from Devil Canyon Dam. Nine miles of a total 11-mile reach of white water would be inundated in Devil Canyon. Transmission lines would total 364 miles in length, corridors would average 186-210 feet in width, and require about 8,200 acres of right-of-way, of which about 6,100 acres would require veg- etative clearing. The project would utilize a renewable resource to produce projected power needs of the Railbelt area equivalent to the annual consumption of 15 million barrels of oil. Heat and noise and air pollution problems associated with most alternative energy production sources would be prevented. Stream flows for some distance below Devil Canyon would carry significantly reduced sediment loads during the summer months. Recreational opportunity would be increased by access roads and creation of project-related recreational facilities. b. Adverse Environmental Effects: The following adverse impacts would result from project implementation: impairment of visual quality resulting from access roads, dams, and transmission lines; loss of vegetation and habitat due to inundation and road construction; creation of public access resulting in increased pressure on wildlife and need for intensified game management and fire prevention pra~i!t Alaska Resources Library & Information Services Anchorage, Alaska increased turbidity of Susitna River downstream from Devil Canyon Dam during winter months; prevention of future mineral extraction from inundated land and limitations of options for uses of lands affected by the transmission corridors; direct impact on moose through some re- duction of existing habitat; possible inhibition of movement of caribou which cross the reservoir between calving and summer ranges; temporary degradation of air, water, and vegetation as a result of slash and debris disposal; inundation of one historical site and any archaeo- logical sites which might be discovered within the reservoir pools• social impacts related to seasonality of construction work and demands upon services of small communities located in the vicinity of construction activity. 4. Alternatives: Construct no additional electrical generating facili- ties, construct other Susitna hydroelectric alternatives, construct other Southcentral Railbelt hydroelectric facilities, develop other alternative energy generating facilities using resources such as coal, oil, and natural gas, nuclear power, geothermal, solar, or other alter- native power generating resources. 5.a. Comments Received (District Review): United States Department of the Interior Alaska Power Administration Geological Survey--Reston, Virginia Fish and Wildlife Service Bureau of Outdoor Recreation--Seattle, Washington National Park Service--Anchorage, Alaska National Park Service--Seattle, Washington Bureau of Indian Affairs--Juneau, Alaska Bureau of Land Management--Anchorage, Alaska United States Department of Commerce United States Environmental Protection Agency Departm~nt of the Army U.S. Army Cold Regions Research and Engineering Laboratory--Hanover, NH Department of Transportation Coast Guard--Seattle, Washington Federal Aviation Administration--Anchorage, Alaska Federal Highway Administration--Portland, Oregon Department of Housing and Urban Development--Seattle, Washington State of Alaska--Office of the Governor Greater Anchorage Chamber of Commerce Office of the Mayor--Anchorage, Alaska Sierra Club Alaska Conservation Society--College, Alaska Alaska Conservation Society--Anchorage, Alaska Knik Kanoers and Kayakers, Inc.--Anchorage, Alaska Cook Inlet Region, Inc.--Anchorage, Alaska Sea Airmotive, Inc.--Anchorage, Alaska Orah Dee Clark Jr. High, Seventh Grade, Sixth Period Class Private Citizens 6. b. Comments Requested (Departmental Review): United States Department of the Interior United States Department of Agriculture United States Department of Commerce United States Environmenta1 Protection Agency Federal Energy Administration United States Department of Transportation Federal Power Commission United States Department of Housing and Urban Development United States Department of Health, Education and Welfare Office of the Governor of Alaska--State Clearinghouse 6. Draft Statement to CEQ 3 October 1975. Revised Draft Statement to CEQ __________ __ (' •' '- ¥ ... _ -... _ ..... _ -. -··· . ... ' . ' ' ---. DBVIL 0ANYON WA/ANA \. \ ! \·., .· ..... UPPER SUSITNA RIVER BASIN PERSPECT IVE LOOKING NORTHEAST Looking downstream on Susitna River at Devil Canyon damsite. Dam would be locate d near bottom of photo. Vegetation is mostly white spruce. Paragraph 2.03.3 2. 03. 3. 1 2.03.3.2 2.03.3.3 2.03.3.4 2.03.4 2. 03. 4. 1 2.03.4.2 2-.03. 4. 3 2.03.4.4 2.03.4.5 2.03.4.6 2.03.5 2.03.6 2.04 3.0 3. 01 3.02 3. 03 4.0 4. 01 4.02 4.03 4.04 4.05 4.06 4.07 4.08 4.09 4.10 4.11 4.12 4.13 4.14 4.15 4.16 4.17 4.18 4. 18.1 Table of Contents (Cont'd) Transportation 36 Rail 36 Roads 36 Air 36 Other Forms of Transportation 36 Recreation 37 Access 37 Hunting 37 Fishing 38 Boating 38 Camping 38 Other Outdoor Recreational Activities 38 Historical Resources 39 Archaeological Resources 39 Energy Needs 40 Relationship of the Proposed Action to Land Use Plans 43 Present Land Status 43 Alaska Native Claims Settlement Act 43 Utility Corridors 44 Environmental Impacts of the Proposed Action 45 Hydrology and Water Quality 45 Fish 48 Wildlife 52 Recreation 54 Historical Resources 55 Archaeological Resources 58 Vegetation 58 Mining 60 Agriculture 60 Roads 60 Construction Activities 61 Workers' Facilities 61 Esthetics 62 Earthquakes 63 Sedimentation 64 Climatic Conditions 64 Air Pollution 65 Social 65 Population 65 i i Paragraph 8.0 8.01 8.02 8.03 8.04 8. 04.1 8.04.2 8.04.3 8.04.4 9.0 9. 01 9.02 No. I II No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Table of Contents (Cont'd) Irreversible or Irretrievable Commitments of Resources in the Proposed Action C~anges ~n Land Use Destruction of Archaeological or Historical Sites Change in River Use Construction Activities Fuel Requirements Manpow1er Materi i:i 1 Land Coordination with Other Agencie• Genera 1 i ·-' Public Participation Program Selected Bibliography Economic Data Comments and Responses Proposed Transmission Line Corridor (Photos Courtesy, Alaska Power Administration) TABLES Title --- Flows Data on the Proposed Project and Selected Susitna Alternatives LIST OF FIGURES Title The Railbelt Upper Susitna River Basin Location Map Transmission System Layout Upper Susitna River Basin Geology of the Railbelt Area Wildlife--Waterfowl Habitat Wildlife--Caribou and Bison Wildlife--Moose, Dall Sheep, Brown Bear Projected Energy Demand Proposed Recreation Plan Coal and Geothermal Areas Oil and Gas Potential Southcentral Key Hydroelectric Alternatives Alternative Transmission Corridors Potential Mineral Development Areas iv 99 99 99 99 100 100 lOO 100 100 101 101 101 103 106 107 Page 45 86 Page 2 5 8 11 16 22 24 26 42 56 73 76 81 89 98 i ! 1.0 PROJECT DESCRIPTION 1.01 Purpose and Authority. The utilization of renewable resources to produce electrical energy for domestic and industrial uses has become a primary concern in today•s energy crisis. The consumption of non- renewable sources of energy such as petroleum and natural gas has now reached a critical point where conservation of domestic sources must be considered. With the forecast increase in development for Alaska and corresponding increase in demand for electric power, the Committee on Public Works of the U.S. Senate, at the request of local interests, adopted a resolution on 18 January 1972, requesting a study for the provision of power to the Southcentral Railbelt area of Alaska. The resolution is quoted as follows: That the Board of Engineers for Rivers and Harbors created under the provisions of Section 3 of the River and Harbor Act approved June 13, 1902, be, and is hereby, requested to review the reports of the Chief of Engineers on: Cook Inlet and Tributaries, Alaska, published as House Document Numbered 34, Eighty-fifth Congress; Copper River and Gulf Coast, Alaska, published as House Document Numbered 182, Eighty-third Congress; Tanana River Basin, Alaska, published as House Document Numbered 137, Eighty-fourth Congress; Yukon and Kuskokwim River Basins, Alaska, published as House Docume~t Numbered 218, Eighty-eighth Congress; and, other pertinent reports, with a view to determining whether any modifications of the recom- mendations contained therein are advisable at the present time, with particular reference to the Susitna River hydroelectric power development system, including the Devil Canyon Project and any competitive alternatives thereto, for the provision of power to the Southcentral Railbelt area of Alaska. 1.02 ~cope of the Study. The Southcentral Rail belt area is that portion of the Yukon and southcentral subregions which extends from Cook Inlet and the Gulf of Alaska on the south to the southern slopes of the Brooks Range on the north, a distance of about 500 miles. This area, containing about 75 percent of Alaska•s population, is served by the Alaska Railroad and is commonly referred to as the .. Railbea•• (see Figure 1). Major power resources, both hydroelectric and fossil fuels, and the greatest power demands are in this region. ) THE RAILBELT · ) M I LE.S so 100 The proposed action discussed in this draft environmental impact statement is a two-dam system located in the Upper Susitna River Basin, which will provide hydroelectric power to the Southcentral Railbelt region in Alaska. 1.03 Description of Action. The recommended plan consists of construc- tion of dams and powerplants on the upper Susitna River at Watana and Devil Canyon, afid electric transmission facilities to the Railbelt load centers, access roads, permanent operating faci1ities, and other project- related features. A subsidiary purpose in the construction of the electric trans- mission line will be the 1nterconnection of the two largest electric power distribution grids 1n the State of Alaska, which will result in increased reliability of service and lower cost of power generation. The proposed plan for the Watana site (Figure 2) would include the construction of an earthfill dam with a structural height of 810 feet at river mile 165 on the Susitna River. The reservoir at normal full pool would have an elevation of 2,200 feet and a crest elevation of 2,210 feet, have a surface area of approximately 43,000 acres, and would extend about 54 river miles upstream from the damsite to about 4 miles above the confluence of the Oshetna River with the Susitna. The generating facilities at Watana would include three Francis reaction turbines with a capacity of 264 MW (megawatts) per unit and a maximum unit hydraulic capacity of 7,770 cfs (cubic feet per second). The firm annual production of electrical power at Watana would be 3.1 billion kilowatt-hours. Development of the Devil Canyon site includes the construction of a concrete, thin-arch dam with a maximum structural height of 635 feet and with a crest elevation of 1,455 feet. The dam would be located at river mile 134 on the Susitna River. Devil Canyon reservoir would have a water surface area of about 7,550 acres at the normal full pool elevation of 1,450 feet. The reservoir would extend about 28 river miles upstream to a point near the Watana damsite, and would be confined within the narrow Susitna River canyon. The generating facilities at Devil Canyon would include four Francis reaction turbines with a capacity of 194 MW per unit and a maximum unit hydraulic capacity of 6,250 cfs. The firm annual energy provided at Devil Canyon would be 3.0 billion kilowatt-hours. A total of 6.1 billion kilowatt-hours of firm annual energy would be produced by the combined Devil Canyon-Watana system. Secondary annual average energy production from this two-dam system includes an 3 Looking upstream toward Watana damsite. Tsuena Creek in left center of photo. Da~site just beyond the visible section of river. FIGURE 2 5 UPPER SUSITNA BASIN LO CAT I 0 N MAP SCALE 0 50 lOOM lito add iti onal 0.8 billion kilowatt-hours per year . The 6.9 billion kilo- wa t ts of firm and secondary annual energy wou ld be the energy equivalent of a bout 15 mi ll i on barrels of oil per year, or abou t 112 billion cubic feet of natural gas per year, or about 1.5 billion barrels of oil over a 100-year project-life period. Most of the generated electrical power would be ut ili zed i n the Fairbanks -Tct nana Valley and the Anchorage-Kenai Peni nsu l a a reas . The proposed transmission system would consist of two 198-mi l e, 230 kv single c ircuit lines from Devil Canyon to Fairba nks (call ed the Nenana corrido r), and two 136-m ile . 345 kv s ing l e c frcui t li nes from Dev il Canyon to the Anchorage area (ca 1l ed the Susi tna corridor ). Bot h l i nes wo uld generally pa ral l el the Alas ka Railroad , Power wou l d be c arr i ed f rom Wata na to Dev il Canyon via two s i ngle c ircuit 230 kv tra nsmis s ion li nes, a distance of 30 miles. Total l ength of the transmiss i on lines wou l d be 364 miles. The genera l l ocations of the transmiss i on l ines are shown on Fig ure 3 . Transmission l i ne corridors wou ld require a ri gh t- of-way of approximately 186-210 feet in width tota l ing slightly more than 8,200 acres of which about 6,100 acres would requi re clearing. Towers would be either steel or aluminum and of free-stand i ng or guyed type. dependi ng upon fi nal design and local conditions. Access to the Devil Canyon and Watana sites would be determined by siting studies that would include consideration of the environmental impacts for roads and transmission lines. Preliminary studies indicatE' an access road approximately 64 miles in length would connect the Watana site wi th the Parks Highway via Devil Canyon. A factor considered in loca ti on and design of access roads would be their subsequent use for publf c recreational purposes. Project-oriented recreational facilities would include visitor centers at the dams, boat launching ramps, campgrounds, picnic areas, and tra i l systems. Some of these facilities would be developed i n cooperation wi th Federal, State or private owners of L:·1d adjacent to the project. Housing would also be provided for operations personne l. The total first costs of the proposed hydroelectric project ba sed on Jctnuary 1975 prices are estimated at $1.52 billion, including the transmission system. Overall, Devil Canyon costs are estimated at $432,000,000, and Watana at $1,088,000,000. Watana Dam would be con- structed first and Watana's costs would include the total cost of the transmission system. The benefit-to-cost ratio compared to the coal alternative at 6-1/8 percent interest rate and 100-year project life is 1.4 using Federal financ i ng. 6 Detailed power and economics, hydrology, project description and costs, foundation and materials, transmission line, and recreational information are available at the Alaska District, Corps of Engineers office in Anchorage, Alaska. Various studies, reports, and articles provided background data and information for this Environmental Impact Statement. (See Selected BiblioBraphy.) This environmental impact statement discusses the known and sus- pected impacts of the proposed project. Since the study is currently in the feasibility stage, the EIS does not include a detailed and exhausti· 2 evaluation of project impacts, many of which cannot be fully ascertained prior to congressional consideration for project authorization and funding of detailed environmental and engineering studies. The Water Resources Development Act of 1974, Public L~w 93-251, sets forth a two- stage post-authorization pre-construction planning process prior to Congressional authorization for construction. If the project is author- ized, and funded for pre-construction planning, the process requires the Corps of Engineers to report their findings for congressional approval before advancing to final project design and construction. During this interim period, additional studies will be undertaken to further assess environmental impacts of the project. The EIS will be updated and refined during this phase to reflect the changed conditions which nor- mally prevail several years later when planning and design studies are undertaken, and to more fully address impacts on those resources for which detailed information is presently limited. Since the updated and revised EIS w.ill again be fully coordinated with all reviewing entities, Congress will be fully apprised of the latest thinking and the fullest possible consideration of environmental impacts prior to authorizing advancement to final project design and construction stages. Meanwhile, general environmental studies are continuing. Inventory and evaluation studies of fish and wildlife resources affected by the project are being conducted by the Alaska Department of Fish and Game, U.S. Fish and Wildlife Service, and National Marine Fisheries Service. As these ongoing studies identify specific areas of concern, they will be selected for more intensive investigation during detailed design studies, should Congress authorize advancement to that stage. Examples of problems expected to be addressed during the detailed design study phase include identification of significant adverse impacts to important fish and wildlife species, and specific actions which should be taken to prevent, ameliorate, or mitigate these impacts. Intensive archaeological surveys will be conducted throughout the proposed project sites and transmission corridors during the pre- construction planning stage, in cooperation with the National Park Service. 7 FIGURE 3 8 UPPER SUSITNA RIVER PROJECT NSM ISS ION SYSTEM LAYOUT SCALE 0 50 100 Mi les ( APA-1975 2.0 ENVIRONMENTAL SETTING WITHOUT THE PROJECT 2.01 Physical Characteristics 2.01. 1 Description of the Area. The Susitna River, with an overall drainage area of about 19,400 square miles, is the largest stream discharging into Cook Inlet. The Susitna River basin is bordered on the south by the waters of Cook Inlet and the Talkeetna Mountains, on the east by the Copper River plateau and the Talkeetna Mountains, and on the west and north by the towering mountains of the Alaska Range. The upper Susitna River upstream from the proposed Devil Canyon damsite drains an area of approximately 5,810 square miles (see Figure 2). Three glaciers flow down the southern flanks of the Alaska Range near 13,832-foot Mount Hayes to form the three forks of the upper Susitna River. These forks join to flow southward for about 50 miles through a network of channels over a wide gravel flood plain composed of the coarse debris discharged by the retreating glaciers. The cold, swift, silt-laden river then curves toward the west where it winds through a single deep channel. some 130 miles through uninhabited country, until it reaches the Alaska Railroad at the small settlement of Gold Creek. After the Susitna escapes the confinement of Devil Canyon, the river's gradient flattens. The river then turns south past Gold Creek, where it flows for about 120 miles through a broad silt and gravel- filled val)ey into Cook Inlet near Anchorage, almost 300 miles from its source. Principal tributaries of the lower Susitna basin also originate in the glaciers of the surrounding mountain ranges. These streams are generally turbulent in the upper reaches and slower flowing in the lower regions. Most of the larger tributaries carry heavy loads of glacial silt during the warmer summer months. The Yentna River, one of the Susitna's largest tributaries, begins in the high glaciers of the Alaska Range, flows in a general south- easterly direction for approximately 95 miles and enters the Susitna 24 miles upstream from its mouth. The Talkeetna River originates in the Talkeetna Mountains on the southeastern part of the ba.sin, flows in a westerly direction, and discharges into the Susitna River 80 miles upstream from Cook Inlet and just north of the community of Talkeetna. The Chulitna River heads on the southern slopes of Mount McKinley, the highest point in North America, with an elevation of 20,320 feet. The river flows in a southerly direction, joining the Susitna River near Talkeetna. 9 Susitna Glacier on Susitna River drainage. Glacier melt in summer months contributes to hi~h sediment in the river. SCAlE a 5 ' \ I I .\ ....... .~'"') ~ ('-1/'v ) / UPPER SUSITNA RIVER BASIN ALASKA Of'TR1CT, CO~ OF EHGH<EE~1 """""'-' ... lUUA 197!1 The principal tributaries of the upper Susitna basin are the silt- laden Maclaren, the less turbid Oshetna, and the clear-flowing Tyone {Figure 4). Numerous other smaller tributaries generally run clear. Streamflow in the Susitna River basin fs characterized by a high rate of discharge from May through September and by low flows from October through April. Much of the Upper Susitna River Basin is underlain by discontinuous penmafrost. Permafrost is defined as a thickness of soil, or other surficial deposit, or of bedrock beneath the ground surface in wh1c11 a temperature below 320f has existed continuously for two years or more. Such permanently frozen ground is found-throughout much of Alaska. The area above and below t~e Maclaren River junction with the Susitna is generally underlain by thin to moderately thick penmafrost. Maximum depth to the base of permafrost fn this area is about 600 feet. Around the larger water bodies, such as lakes, permafrost is generally absent. In some areas of the lower section of the upper Susitna basin. permafrost is not present. Additional data is required before permafrost areas can be specifically identified upstream from Devil Canyon. Because of the length of the proposed transmission system. and the diversity of terrain and ecosystems bisected by a corridor extending from Anchorage to Fairbanks. the system is divided into six major segments which lend themselves to discussion in terms of generally similar ecologica1 characte~istics. The route extending south from Watana Dam to Point MacKenzie is referred to as the Susitna Corridor. The route north from Gold Creek to Ester is called the Nenana Corridor (both corridors share the line from Watana to Gold Creek). The corridor for most of its length generally parallels the Alaska Railroad. The Susitna Corridor is subdivided into three major segments; (a) Point MacKenzie north to Talkeetna, a distance of 84 miles; (b) Talkeetna to Gold Creek, 38 miles; and (c) Gold Creek to Watana, 44 miles. The Nenana Corridor is also divided into three segments (continuing north): (a) Gold Creek to Cantwell. 62 miles; {b) Cantwell to Healy, 39 miles; and (c) Healy to Ester, 97 miles. These locations are shown on Figure 3. Relevant physical and ecological features of individual transmission line segments are described in the following paragraphs. 2.01.2 River Characteristics. The upper Susitna River is a scenic. free-flowing river with very few signs of man's presence. The extreme upper and lower reaches of the Susitna occupy broad, glacially scoured valleys. However. the middle section of the river , between the Denali Highway and Gold Creek, occupies a stream-cut valley with extremely violent rapids in Devil Canyon. 12 -------------------- Confluence of the Tvone and Susitna Rivers several miles above the upper reaches of the proposed Watana reservoir. The Susitna, the Bremner in the southcentral region, and the Alsek in the southeast are the three major whitewater rivers in Alaska. Portions of all three are Class VI {on a scale of I to VI) boating rivers, at the upper limit of navigability, and cannot be attempted without risk of life. Few kayakers have completed the difficult 11-mile run through Devil Canyon. The Susitna was one of the Alaskan rivers recommended for detailed study as possible additions to the National Wild and Scenic Rivers System in 1973, but was not one of the 20 rivers recommended for inclu- sion in the system by the Secretary of the Interior in 1974. The Susitna River has not yet been studied as recommended. About 86 percent of the total annual flow of the upper Susitna occurs from May through September, with the mean daily average flow from late May through late August in the range of 20,000 to 32,000 cubic feet per second. In the November through April period, the mean average daily flow of the river is in the range of 1,000 to 2,500 cubic feet per second. On 7 June 1964, the recording station at Gold Creek measured a flow slightly in excess of 90,000 cubic feet per second, which was the highest flow recorded for the upper Susitna River since recording started in 1950. High summer discharges are caused by snowmelt, rainfall, and glacial melt. The main streams carry a heavy load of glacial silt during the high runoff periods. During the winter when low temperatures retard water flows, streams run relatively silt-free. 2.01.3 Cook Inlet. All of the major water courses which flow into Cook Inlet either orig1nate from glaciers or flow through erosive soils; either type of stream carries a high suspended-solids load. The natural high flow period in streams tributary to Cook Inlet occurs during the summer months of May to September, th~ main period when sediment is transported to the Inlet. Freshwater runoff into the upper Inlet is an important source of nutrients and sediments. Large quantities of nitrate, silicate, and surface-suspended sediment with particulate organic carbon enter the Inlet with fresh water. Concentrations are especially high in the initial runoff each spring and summer. These additions decrease in concentration down the Inlet upon subsequent mixing with saline oceanic water and with tidal action. The large input of fresh water dilutes and tends to reduce salinity and phosphate concentration around river mouths and in the upper reaches of Cook Inlet. 2.01.4 Geology/Topography. 2.01.4. 1 General. The Railbelt area is characterized by three lowland areas separated by three major mountain areas. To the north is the 14 Tanana-Kuskokwim Lowland, which is delineated by the Alaska Range to the south. The Susitna Lowland is to the southwest, bounded to the north by the Alaska Range, and to the east by the Talkeetna and Chugach Mountains. The Copper River Lowland in the east is bounded on the north by the Alaska Range, and the west by the Talkeetna Mountains. Each basin is underlain by quaternary rocks surfaced with glacial debris, alluvium, and eolian deposits. The mountains are primarily metamorphic and sedi- mentary rocks of the Mesozoic, with several areas of intrusive granitic rocks in the Talkeetna Mountains and the Alaska Range, and Mesozo·c volcanic rocks in the Talkeetna Mountains. Figure 5 delineates the major features. 2.01.4.2 Susitna Basin. The Alaska Range to the west and north and the Talkeetna Mountains to the east make up the high perimeter of the Lower Susitna River Basin. The Alaska Range is made up of Paleozoic and Mesozoic sediments, some of which have been metamorphosed in varying degrees and intruded by granitic masses. The Talkeetna Mountain Range, with peaks up to 8,850 feet, is made up of a granitic batholith rimmed on the Susitna basin side by graywackes, argellites, and phyllites. Much of the interior portion of the basin is fluvial-glacial overburden deposits. Glaciers, in turn, carved the broad U-shaped valleys. Glacial overburden covers the bedrock, which is composed mainly of shale and sandstone with interbedded coals, Paleozoic and Mesozoic sediments, and lava flows. The Upper Susitna River Basin is predominantly mountainous, bordered on the west and south by the Talkeetna Mountains, on the north by the summits of the Alaska Range, and on the south and east by the flat Copper River plateau. Valleys are floored with a thick fill of glacial moraines and gravels. 2.01.4.3 Transmission Line Corridor. Beginning at sea level at Point MacKenzie, the transmission line corridor rises to an elevation of 500 feet at Talkeetna. The corridor traverses a wide river valley with rolling terrain east of the Susitna River and extremely flat land to the west. The valley flattens and widens to the south, is poorly drained, and has many bogs and lakes. From Talkeetna to Gold Creek, the corridor follows a moderately narrow valley floor narrowing toward the northern end. Maximum elevation is 900 feet. The corridor from Gold Creek to Watana rises to an elevation of about 2300 feet on the plateau south of Devil Canyon before descending to the Watana damsite. 15 , 1-1 Ci) 0'1~ rn LEGEND SEDIMENTARY AND li!ETAli!ORPHIC ROCKS QUATERNARY Surficial deposits, alluvium , glacial debris , eolian sand and silt TERTIARY S andstone, conglomerate , shale, mudstone; n o nm arine and marine MESOZOIC Sandstone and shale ; marine and nonmarine; includes some metamorphic rocks PALEOZOIC fu'\0 PRECAli!BRIAl\i San dstone , shale , limestone; mostly marin e; i ncludes some ear ly Mesozoic rocks PALEOZOIC fu"'D PRECAli!BRIAN Metamorphic rock s : schist , gneiss, etc .; mainly Paleozoic IGNEOUS ROCKS CJ1 I <: !\ A I Quaternary and T '"rtiary volcanic roc ks Mesozoic intrusive rocks; mainly granitic Paleozoic volcanic rocks ~~ ",;."'t> :1 Paleozoic i ntrusive rocks; granitic and ultramafic ~-------- Fault (Dashed where in fe rred) Source: U.S.G .S. APA-1 975 GEOLOGY OF THE RAILBELT AREA -~LE ---, - Between Gold Creek and Cantwell, the corridor rises to a 2400-foot elevation. It traverses a wide valley with moderately incised rivers in the south, becoming a very wide depression in Broad Pass with rolling valley bottom continuing to the northeast. · From Cantwell, elevation 2200 feet, the Nenana River valley narrows to the north into a series of tight canyons separated by the wide valley of Yanert Fork. The corridor emerges from the canyon into a wide rolling plain south of Healy, with stream terraces adjacent to the Nenana River. The corridor is bisected by the Denali Fault at Wi;rdy Creek. Elevation at Healy is 1400 feet, dropping to 350 feet at Nenana, and rising again to 1500 feet in the Goldstream Hills southwest of Ester. 2.01.4.4 Seismic Areas. The southcentral area of Alaska is one of the world's most active seismic zones. In this century, 9 Alaskan earth- quakes have equalled or exceeded a magnitude of 8.0 on the Richter Scale, and more than 60 quakes have exceeded a magnitude of 7.0. Several major and minor fault systems either border or cross the Susitna River basin. The March 1964 Alaska earthquake, with a magnitude of 8.4, which struck southcentral Alaska, was one of the strongest earthquakes ever recorded. A total of 115 lives were lost, 98 by quake-associated tsunami (seismic sea waves). The Richter scale is a logarithmic scale where a 7.0 earthquake would be ten times stronger than a 6.0 quake and an 8.0 quake would have one hundred times the intensity of a 6.0 earth- quake. Much of southcentral Alaska falls within seismic zone 4 (on a scale of 0 to 4) where structural damage caused by earthquakes is generally the greatest. This area of Alaska and the adjoining Aleutian chain are just part of the vast, almost continuous seismically and volcanically active belt that circumscribes the entire Pacific Ocean Basin. 2.01.4.5 Minerals. Most of the Susitna basin above Devil Canyon is considered to be highly favorable for deposits of copper or molybdenum and for contact or vein deposits of gold and silver. One known deposit of copper of near-commercial size and grade is near Denali. Also, the Valdez Creek gold placer district, from which there has been some pro- duction, is within the proposed project watershed. Though a number of mineral occurrences are known and the area is considered favorable for discovery of additional deposits, much of the drainage basin has never been geologically mapped. Thus, geologically, the basin constitutes one of the least known areas in the State except for a few areas in the vicinity of Denali where some geologic mapping has been done. Geologic information for the project area is not detailed enough to assess mineral resource potential within the proposed reservoir impoundment a rea s. l 7 The Alaska State Department of Natural Resources states that there are "active" and "non-active" mining claims in the upper Susitna River drainage area between Devil Canyon and the Oshetna River. Many of these claims are in upper Watana Creek above the maximum reservoir pool elevation, and in the surrounding drainage areas where copper activity is moderately extensive. 2.01.5 Climate. The Susitna basin has a diversified climate . The latitude of the region gives it long winters and short summers~ with great variation in the length of daylight between w1nter and summer. The lower Susitna basin owes its relatively moderate clima te to the warm waters of the Pacific on the south, the barrier effect of the Alas ka Range on the west and north, and the Talkeetna Range on the east. The summers are characterized by moderate temperatures, cloudy days, and gentle rains. The winters are cold and the snowfall 1s fairly heavy. At Talkeetna, at an elevation of 345 feet, which is representative of the lower basin, the normal summer temperature ranges between 440 and 680F, with winter temperatures ranging between oo and 40oF. The extreme temperature range is between -48° and 9loF. The average annual precipi- tation is about 29 inches, including about 102 inches of snowfall. The upper Susitna basin, separated from the lower basin by mountains, has a somewnat colder climate and an average overall annual precipi- tation rate of approximately 30 inches. The climate of the transmission line corridor from Devil Canyon to Point MacKenzie is transitional, with mild, wet conditions prevailing toward the southern end of the segment. The northern corridor has extremely variable climate related to differences in elevation. From Gold Creek to Cantwell, the annual temperature averages 25.9°F and annual precipitation 21.85 inches. From Cantwell to Healy, the annual temperature is 27.7°F and annual precipitation 14.5 inches. High winds are reported in this segment. North from Cantwell, the climate is typical of the interior, with an average temperature of 26.4°F and annual precipitation 11.34 inches. 2.02 Biological Characteristics. 2.02.1 Fish. 2.02. 1.1 Anadromous Fish. Fish inhabiting the Susitna basin are divided into two major groups: resident and anadromous. The anadromous fish spends a portion of its life cycle in salt water, returning to the freshwater streams to spawn. In this group are included five species of Pacific salmon: sockeye (red); coho (silver); chinook (king); pink (humpback); and chum (dog) salmon. Juvenile salmon of several of these spend several years in fresh water before migrating to sea. All five species of salmon die soon after spawning. Dolly Varden, a char, is widely distributed in the streams of Cook Inlet and is present in the Lower Susitna River Basin with both anadromous and resident populations. 18 Smelt runs are known to occur in the Susitna River as far upstream as the Deshka River about 40 miles from Cook Inlet. Salmon are found to spawn in varying numbers in some of the sloughs and tributaries of the Susitna River below Devil Canyon. Salmon surveys and inventories of the lower Susitna River and its tributaries have been made over a number of years, resulting in considerable distribution data; ~awever, population studies and additional resou~ce studies are needec.. The surveys indicate that salmon are unab·:.:: to ascend the turbulent Devil Canyon, and, thus, are prevented from migrating into the Upper Susitna River Basin. The 14 million pounds of commercial salmon caught in Cook Inlet during 1973 comprised about 10 percent of the 136.5 million pounds of salmon harvested in Alaska during the year. Chum, red, and pink salmon totaled about 94 percent of the salmon catch for ~ook Inlet during 1973. 1973 Catch and Production--Commercial Fisheries Statistics--Leaflet #26, State of Alaska Department o Fish and Game . The 1973 commercial catch figures do not approach the maximum sustained yields for Cook Inlet, but do present the latest available commercial catch information, and except for chinook salmon are rep- resentative of the last several years of commercial salmon fishing. Sport and subsistence fishing for salmon in Cook Inlet and in the Susitna basin are also important considerations. According to the Alaska Department of Fish and Game, a s~gnificant percentage of the Cook Inlet salmon run migrates into the Susitna River Basin. Although all salmon stocks are important, data from earlier 1950 and 1960 fish and wildlife reports added to the latest 1974-75 studies indicate that only a small percentage of the Susitna Basin salmon migrate into the 50-mile section of the Susitna River between the pro- posed Devil Canyon damsite and the confluence of the Chulitna River to spawn in the river's clearwater sloughs and tributaries. Further studies should determine more specific information on salmon numbers and habitat impacts. A 1974 assessment study, by the Alaska Department of Fish and Game, of anadromous fish populations in the Susitna River watershed estimated 24,000 chum, 5,200 pink, 1,000 red, and between 4,000 and 9,000 coho salmon migrated up the Susitna River above the river's rJn- fluence with the Chulitna River during the 7-week study period from 23 July through 11 September when most of the salmon were migrating up the river. The report indicated that chinook salmon were also present. According to the 1974 assessment by the Alaska Department of Fish and Game, a minimum of 1,036 pink, 2,753 chum, 307 coho, and 104 sockeye, and an undetermined number of chinook salmon spawned during the August and September spawning period in the streams and sloughs of the Susitna River between the Chulitna River tributary and Portage Creek as deter- minea from peak slough and stream index escapement counts. The assess- ment also indicated that a portion of the pink salmon spawn in the study area may have been destroyed by a late August-early September flood. 19 Chinook (King Salmon). The king salmon spends from one to three years in fresh water before migrating to sea. It is not unusual for this species to attain a weight of over 40 pounds. The maximum age is 8 years. In 1973, over 5,000 kings were caught in Cook Inlet; the total commercial catch comprised about 1.5 percent of the total weight of salmon caught in this area. The 1973 catch figures for king salmon were very low when compared to the average yearly catch for this species. Sockeye Salmon (Red~. The sockeye salmon averages between 6 and 8 pounds~ with a range of rom 2 to 12 pounds. This species spends from 1 to 3 years 1n a river system in which there are connecting 1akes. The maximum age attained by this salmon is 7 years, but most return to spawn at 4 or 5 years of age. The landlocked variety of this species is called a kokanee and usually attains a length of from 12 to 15 inches. In 1973, almost 700,000 sockeyes were caught in Cook Inlet, with a total weight of over 5 million pounds, or 37.0 percent of the total weight of the Cook Inlet commercial salmon catch. About 14.5 percent of the sockeye salmon catch in Alaska occurred in Cook Inlet. Coho Salmon {Silver). The coho or silver salmon spends from 1 to 2 years in fresh water and returns from the ocean to spawn at 3 or 4 years of age. Mature coho average about 10 pounds; some reach weights of over 30 pounds. The 106,000 cohos caught in Cook Inlet during 1973 weighed just over 648,000 pounds and comprised about 4.5 percent of the total commercial salmon catch for the area. Pink Salmon The pink salmon migrates to sea immediate1y after hatching an to spawn at 2 years of age. The average weight of a mature pink is 3 to 4 pounds, with some p1nks weighing up to 10 pounds. The 624,000 pink salmon caught in Cook Inlet during 1973 weighed over 2,260,000 pounds and comprised about 16.2 percent of the total weight of the commercial salmon catch in the area. Historically, odd-year catches of pink salmon are poor. Even-numbered year catches average about 2 million pinks. Chum (Dog Salmon). Chum salmon attain weights of up to 30 pounds, with an average mature weight of 8 to 9 pounds. This species migrates to sea immediately after hatching and matures between 3 and 6 years of age. The 742,000 chums caught in Cook Inlet during 1973 weighed almost 5,800,000 pounds and made up over 41.0 percent of the total commercial salmon catch for the area, the largest percentage of any of the 5 species of Pacific salmon. About 12.5 percent of the 1973 Alaskan chum salmon catch occurred in Cook Inlet. Salmon eggs hatch in late winter or early spring following the summer and fall spawning periods. The eggs incubate in gravelly stream- beds and cannot tolerate high levels of siltation or low flows that dewater the streambeds during the incubation or alevin (pre-emergent} stages. Low fiows, especially critical during the winter months, can dewater many of the spring-fed freshwater sloughs that are available to spawning salmon (see Table 1, page 45.) 20 2.02.1.2 Resident Fish. Grayling, rainbow trout, lake trout, Dolly Varden. whitefish, sucker, sculpin, and burbot (ling) comprise the principal resident fish population of the Susitna River basin. Although distribution studies have been made in the past, the magnitude of resident fish populations in the Susitna drainage is largely unknown. During the warmer months of the year, when the Susitna River is silt laden, sport fishing is limited to clearwater tributaries and to areas ·n the main Susitna River near the mouths of these tributari ::,, Resident fish, especi a 11y grayling, apparently inhabit tl.e mouths of some of the clean.,ater streams on the Susitnc:. River between Devil Canyon and the Oshetna River; however, most of the tributaries are too steep to support significant fish populations. Some of the upper s~ctio~~ of these clearwater tributaries, such as Deadman Creek, support grayling populations. Lake trout are also prominent in many of the terrace a~d upland lakes of the area. 2.02.2 Birds. 2.02.2. 1 Waterfowl. The east-west stretch of the Susitna River between the Tyone River and Gold Creek is a major flyway for waterfowl. The majority of the waterfowl nesting areas in the Upper Susitna River Basin are on the nearby lakes of the Copper River Lowland region, on the Tyone River and surrounding drainage areas, and on the ponds and lakes of the wide flood plain in the Denali area. The Upper Susitna River Basin has a moderate amount of use by waterfowl when compared with the Lower Susitna River Basin. The 'lower basin has a substantially greater amount of waterfowl habitat, and a greater number and variety of waterfowl seasonally use the thousan(~ of lakes and ponds in this area to nest and to raise their yo~ng. Lor ~ numbers of migrant birds also use the Susitna River basin for feeding and resting during spring and fall flights to and from Alaska's interior and north slope. Distribution and density of waterfowl habitat within the Railbelt area is shown on Figure 6. 2.02.2.2 Ra~tors. Raptors, including golden eagles, bald eaoles, a~d various spec1es of hawks, owls, and falcons, occur throughout the ent·r~ Susitna River basin but in smaller numbers in the river canyon betweer1 Portage Creek and the Oshetna River. A June 1974 survey of cliff- nesting raptors conducted by the U.S. Fish and Wildlife Service, deter- mined that the population densities of these birds between Devil Canyon and the Oshetna River are low and that no endangered species of per- egrine falcons, American or arctic, appear to nest along the upper Susitna River. Peregrines have occasionally been sighted within the area of the upper Susitna basin and along migration routes through the Broad Pass area of the upper Chulitna River. 21 .. High Den sit y lliiiiiJ] Medium Density ITJIIl Low Density Source• Joint Federoi-Stote Lon Use Plonnln Q Commission WILDLIFE WATERFOWL HABITAT I ~~------~~~--------------------------------o~-----~------~---~~c;~:--~---------~~~~~o~:~i re~•--~· ~ A.P.A.-JULY 19 75 FIGURE 6 22 On the basis of the 1974 U.S. Fish and Wildlife Service findings, other raptor populations in the canyon area of the upper Susitna River were determined to be minor, although minimal data were acquired on the tree-nesting raptors. Several nesting pairs of bald eagles and gyr- falcons were observed in or near the canyons of this area, and golden eagles frequently occupied upland cliffs in the vicinity of Coal Creek. Substantial populations of ravens were found in reaches of the Susitna River above Gold Creek. The nests of this large bird are often used by raptors, including peregrines and gyrfa1cons. However, there was no evidence that the nests observed were be·i ng used by rap tor-s. 2.02.2.3 Other Birds. Unknown numbers of game birds, such as spruce grouse and willow ptarmigan, inhabit the Upper Susitna River Basin. Some incidental game bird hunting takes place along the Denali Highway, but such hunting pressures are practically nonexistent in most of the area. Various other species of birds including songbirds, shorebirds, and other small birds are found throughout the Upper Susitna River Basin in varying numbers. 2.02.3 Mammals. 2.02.3. l Caribou. One of the most significant wildlife resources of the Upper Susitna River Basin is the wide-ranging Nelchina caribou herd. This herd, a major recreational and subsistence resource in the south- central region, declined from a population high of about 71,000 in 1962 to a low of between 6,500 and 8,100 animals in 1972. This spectacular decline has been attributed to various factors, including migration to other areas, bad weather, predation, and overhunting. Motorized all- terrain vehicle access to the backcountry has improved hunting success even in the face of a rapidly declining caribou population. Segments of the Nelchina herd periodically range throughout much of the Upper Susitna River Basin (see Figure 7). The major calving area for the herd is on the northeast slopes of the Talkeetna Mountains on the upper reaches of the Kosina Creek, Oshetna River, and L~~tle Nelchina River drainages. Calving generally takes place between mid-May and mid- June. Except for intermittent seasonal migration routes across the Susitna River in areas upstream from Tsusena Creek, caribou are not resident to the main Susitna River canyon between Devil Canyon and the Oshetna River. Caribou depend upon climax range, especially for winter forage; any alteration of the vegetation, especially of sedges and lichens, has a detrimental impact upon their distribution and numbers. A trait of the Nelchina herd is an almost constant change of winter ranges, a phenomenon that has undoubtedly characterized Alaska's caribou populations for centuries. 23 0 ~Caribou Win1e; Range EI?J Caribou Summer Range FIGURE 7 24 WILDLIFE CARIBOU AND BISON I ~----~LE __ 2 a · ----~ rOO Mile' A.P.A . -JULY 1975 J ...... ·.,.- The Alaska Department of Fish and Game considers the Nelchina herd to be one of the State 1 s most important caribou populations. Several thousand hunters from Anchorage and Fairbanks participate in the annual hunting of this species. Additional thousands of non-hunting recrea- tionists view the migrations of caribou as they cross the State's major highways. In addition, the herd provides sustenance to predators and scavengers such as wolves, grizzly bears, black bears, wolverines, lynx, and various species of birds. CariboJ are essentially limited in distribution within lhe trans- mission Lne system to the 136-mile segment extending north from Cantwell. In the mountainous area between Cantwell and Healy, they concentrate south of canyons. They are found in concentrations on the west bank of the Nenana River north of HeJly and south of Clear Air Force Base. 2.02.3.2 Moose. Moose range throughout much of the Upper Susitna River Basin (Figure 8). Wide fluctuations of populations have occurred over the years. A 1973 Alaska Department of Fish and Game fall aerial count resulted in sighting of approximately l ,800 moose in the upper Susitna River drainage. Numbers of moose in the southcentral region of Alaska have been reduced in recent years due mainly to weather conditions, h~~ting pressures, wolf predation, unbalanced age-sex ratios, and elir.l- nation of habitat. Much of the Upper Susitna River Basin is at or above ti111berline, resulting in large amounts of 11 edge 11 at timberline which produce con- s-iderable quantities of willow, an important winter forage :··Jr moose. Successional vegetation changes following fire also contribute heavily to areas favoring moose habitat. Limited numbers of moose inhabit the Susitna River bottom b,~theen Oevi l Canyon and the Oshetna River, because of a restricted ar10unt of suitable habitat. However, the available habitat provides critical winter range for moose that do utilize this area. Moose inhabit the entire length of the transmission line corridor but are more abundant in the lower valleys. In mountainous terrain, they are more commonly found in more open parts of canyons. 2.02.3.3 Grizzly/Brown Bears. Grizzlies, also referred to ~s brown bears in Alaska, are common throughout the Susitna River drainage and are fairly numerous in the upper Susitna despite the absence of salmon. Alpine and subalpine zones are the habitats most frequently used by grizzlies, although the more timbered areas are seasonally important. Denning begins in October, and all bears are in dens by mid-November (see Figure 8). Bears usually reappear during May, depending on weather conditions. Important spring foods include grasses, sedges, horsetails, other herbaceous plants, and carrion when available. On occasion, 25 MAP ~B rown/Grizzly Bear Denning Areas 1::/: l Moose Concentration WILDLIFE MOOSE, DALL SHEEP, BROWN BEAR FIGURE 8 26 0 50 2 IO OMi le • A.P.A .-JULY 1975 ) moose or caribou calves are taken. Berries--lowbush and highbush cranberries, blueberries, and bearberries--provide major summer food supplements. A prime consideration for grizzly bears is to minimize direct conflict with humans as the grizzly is adversely affected by contact with man. Hunting for grizzly bears in this area often occurs incidentally to other hunting during the short fall open season. Within the transmission line corridor, most grizzly bears ~re limited in distribution to the higher areas, primarily between Cantwell and Healy although they are found throughout this part of Alaska. 2.02.3.4 Black Bears. The Upper Susitna River Basin supports fair black bear densities. The larger populations are in semi-open forested areas with readily accessible alpine-subalpine berry crops. River bottoms, lake shores, and marshy lowlands are favorite spring black bear areas. Black bears generally eat many of the same types of food as ar0 eaten by grizzlies. Denning habits are also somewhat similar to the grizzly bear 1 s. Natural fires generally benefit black bears, especially when dense mature spruce stands are burned. Most other land uses do not seriously affect bear numbers in this area, and black bears are not as adversely affected by contact with man as are grizzlies. Black bears are found in forested areas throughout the length of the transmission line corridor. 2.02.3.5 Dall Sheep. These sheep are present in many areas of the Alaska Range, Talkeetna Mountains, and in the higher elevations of the Susitna River basin (Figure 8). The greatest concentrations of Dall sheep in the Susitna basin occur in the southern portions of the Tal- keetnas; herds become scattered on the northern portion of the range, where parts of the mountains are uninhabited by sheep. Dall sheep are also found in the Watana Hills. Because of the relatively gentle nature of much of the Talkeetna Mountains and Watana Hills, predation in this area has more effect on sheep numbers than in more rugged habitats. Sheep have always furnished some of the diet of wolves and other carni- vores in this area. Within the transmission line corridor, Dall sheep are essentially limited to the mountainous area between Cantwell and Healy. Hunting pressure for rams is fairly heavy due to relatively good access from highways, by air, and by ATVs (all-terrain vehicles). Nevertheless, as is true elsewhere in the State, ram-only hunting seems to have little effect on overall numbers. Sheep populations are almost entirely controlled by natural factors such as habitat, weather condi- tions, predation, and disease. Conflicts between man 1 s activities and 27 critical sheep habitat, such as lambing or wintering areas, can adversely impact Dall sheep populations. 2.02.3.6 Mountain Goats. Goats occur in low numbers in various areas of the Talkeetna Mountains and in the Watana Hills area, and do not provide a significant amount of hunting in the upper Susitna basin. The goats generally inhabit rougher terrain than do Dall sheep, and are thus less susceptible to man•s activities. 2.02.3.7 Wolves. Wolves occur throughout most of the Upper Susitna River Basin. Populations are subject to rapid fluctuations, and esti- mates should be viewed with extreme caution. Wolf numbers have been estimated from a low of 13 in 1943, after predator control efforts, to a high of 400 to 450 in 1965. Currently an estimated 300 wolves populate the area encompassing the upper Susitna, the Talkeetna Mountains, and the upper Copper River drainage area. The wolf has been removed from predator classification and is now classified as a game animal in Alaska. Alaska Department of Fish and Game n~nagement studies concluded that, from 1957 to 1967, wo1f predation neither adversely affected other game populdtions, nor reduced hunting success for sportsmen. However, absolute conclusions were uncertain since moose and caribou populations may have reached their highs during this period. The study proved that wolves and men can often coexist while competing for game animals, but that at times man must accept reduction of available game by wolves. 2.02.3.8 Wolverines. This area of Alaska has consistently produced more wolverines than any other area of comparable size in the State. Wolverines are seen regularly throughout the area, and it is not unusual for a hunter returning to a kill site to find a wolverine feeding on his moose or caribou. Wolverines have withstood human encroachment and trapping without any noticeable reduction in numbers or range. 2.02.3.9 Other Mammals. Fur animal species of the upper Susitna in addition to wolf and wolverine include beaver, muskrat, otter, mink, Canada lynx, fox, marten, and weasel. Found in varying populations throughout much of the Upper Susitna River Basin and transmission corridor, each of these species has its own unique habitat requirements. However, except for a limited number of beaver, the river canyon area between Devil Canyon and the mouth of the Oshetna River is not con- sidered good quality fur animal habitat for most of these species. Other mammals found in this area include coyotes, snowshoe hares, ground squirrels, tree squirrels, pikas, marmots, and several species of voles, shrews, and mice. As with other animals, the populations of the various species vary as adverse or beneficial factors are encountered. 28 ) Susitna River between Watana and Vee darnsites. Heavier vegetation, in this case upland spruce- hardwood forest, is .limited to the valley slopes, the vegetative biome on the upper plateaus is generally moist tundra, muskeg, and alpine tundra. 29 2.02.4 Threatened Wildlife of the United States. The only species in the U.S. Fish and Wildlife Services publication, Threatened Wildlife of the United States, that might be resident in or migrate through the Upper Susitna River Basin are the two subspecies of the peregrine falcon: Falco peregrines anatum (American) and Falco peregrines tundrius (arctic). Although no peregrines appear to be nesting along the upper Susitna River at present, there have been occasional sightings within the area and along known migration routes for this species as they move through the Broad Pass area on the upper Chulitna River. These migrating peregrines are occasionally reported to include members of the two endangered subspecies. Several species of wildlife that are considered threatened or .depleted in the Lower 48 States have substantial populations within Alaska. Such species include the American bald eagle, the wolf, and the grizzly bear. 2.02.5 Vegetation. The major ecosystems of Alaska are divided into marine and land group·ings, with the land group divided into fresh-water, tundra, and coniferous systems. The freshwater system includes glaciers and ice fields, lakes, and riverine ecosystems; the tundra system is subdivided into moist, wet, and alpine tundras; and the coniferous system is divided into six plant-related classifications. The Upper Susitna River Basin includes the following four broad land ecosystem classifications: moist tundra; alpine tundra; upland spruce-hardwood forest; and lowland spruce-hardwood forest. Tne largest percentage of the basin is classified as moist or alpine tundra with most of the area in and adjacent to the main river channel below the Maclaren River classified as either upland or lowland spruce-hardwood forest. At Gold Creek, the bottomland forest of white spruce and black cottonwoood is very much in evidence on well drained banks. Ascending the river, balsam poplar replaces the cottonwoods around Fog and Tsusena Creeks. Thin hardwoods and white spruce become less and less in evidence but still occur in small stands on well drained river bars and tributary fans upstream to Butte Creek. Above this tribut~ry, only scattered stands of black spruce occur, growing up to the glaciers. The lower hil1sides have a low brush cover with moist tundra in the lower areas. The periodically flooded river flats are in willow, sedges-high brush, and wet tundra. Since much of the drainage basin is uplands, alpine tundra is one of the most prominent vegetation types. Alpine tundra is composed of low mat plants, both herbaceous and shrubby. Moist tundra usually forms a complete ground cover and is very productive during the growing season. Plant types vary from almost continuous cottongrass with a sparse growth of sedges and dwarf shrubs to stands where dwarf shrubs dominate. Tundra ecosystems are especially fragile and are very susceptible to long-term damage or destruction from overuse. Regeneration is extremely slow, with some lichens requiring more than 60 years to recover. 30 Most of the timber ecosystems in the upper Susitna basin are located adjacent to the river and tributaries on the canyon slopes and on the surrounding benchlands. The major timber species include birch, balsam poplar, black cottonwood, white spruce, and black spruce. Overall, the timber quality in this area is not good, with a wide variety of sizes, mostly smaller and noncommercial. ~1uch of the birch and spruce is more suitable for pulp than for sawtimber; however, a fair yield of sawlogs could be obtained from stands of black cottonwood and balsam poplar. The transmission line corridor transects five generally distinct vegetation types. Three of these--upland spruce-hardwood, lowland spruce-hardwood, and alpine tundra--are common within the upper Susitna basin, as discussed above. Two are related to distinctly different 1and forms. Bottomland spruce-poplar is confined to broad flood plains and river terraces, and warmer slopes of major rivers. Characteristic vegetation is white spruce, balsam poplar, birch, and aspen. Low bush, bog, and muskeg are another distinct type usually formed on outwash, and old river terraces, in filling ponds and sloughs, and throughcrut lowlands. Characteristic plants are tamarack, black spruce, alders, willows, and berries. Progressing northward from Point MacKenzie, the corridor is principally characterized by bottomland spruce-poplar, lowland spruce- hardwood, and muskeg bog to Talkeetna. From this point to Gold Creek, bottomland spruce-poplar is interspersed with upland spruce-hardwood. The segment leading from Gold Creek to Cantwell is typically bottom- land spruce-poplar interspersed with upland spruce-hardwood, and low brush-bog/muskeg. Through the Alaska Range between Cantwell and Healy, the vegetation is a mixture of upland spruce-hardwood, lowland spruce-hardwood, alpine tundra, and some low brush-muskeg/ bog. From Healy to Ester, the vegetation is characterized by bottom- land spruce-poplar, upland spruce-hardwood, lowland spruce-hardwood, and low brush-muskeg/bog. 2.03 Cultural Characteristics. 2.03.1 Population. The Southcentral Railbelt area of Alaska contains the State's two largest population centers, Anchorage and Fairbanks, and almost three-fourths of the Stat~'s total population. The Anchorage area alone has over half the residents in the State. Recently revised estimates for 1975 indicate over 386,000 people will be in Alaska by the end of the year, compared to slightly over 302,000 counted in the 1970 census, an increase of about 28 percent in that period. Other estimates by the Alaska Department of Labor indicate an expected State population of almost 450,000 for the year 1980, an additional 16 percent increase over 1975, and a population increase of nearly 50 percent in 10 years. The largest growth in the State has been in the Southcentral Railbelt area, and this trend is expected to continue. With the possible relo- cation of Alaska's capital from Juneau to the Railbelt area, an addi- tional population impact will be exerted on this area .of the State. 31 w N Looking upstream at Susitna River near Gold Creek about 15 miles below Devil Canyon. Note Alaska F.ailroad bridge. At the present time, on1y a few small settlements are located along the Parks Highway between Anchorage and Fairbanks and the Alaska Ran- road in the Susitna River valley. Except for the small settlement at Denali, there are few, if any, permanent full-time residents in the Upper Susitna River Basin above Devil Canyon. 2.03.2 Economics. Both Anchorage and Fairbanks are regional economic centers for the Southcentral Railbelt area. Government, trade, and services comprise the major portion of the area's total employment. Construction and transportation are also important. Making relatively less significant contributions are the financing, mining, and manufacturing industries, while agriculture, forestry, and fisheries contribute less than one percent of the employment dollar to the economy of the Rai"lbelt area. In 1972 the wages and salaries for the southcentral region of Alaska amounted to more than $704,000,000. In the government groups, employment is divided more or less equally between Federa1, State, and local sectors. The area's major Federal employer is the Department of Defense, with most of its employees con- centrated in four military installations. State and local government employment includes employees from agencies of the State of Alaska and the cities and boroughs within the area. After government, the two groups having the largest employment are trade and services. Their importance as sources of employment for the Railbelt area residents is a further manifestation of the region's two relatively concentrated population centers and of the high degree of economic diversity, as well as levels of demand for goods and services, which are substantially higher than in most other parts of Alaska. The importance of construction is largely due to the high level of expansion experienced by the Anchorage and Fairbanks areas since 1968. This growth can partly be attributed to the trans-Alaska pipeline project, which is encouraging much new construction in both public and private sectors. High levels of employment in the region 1 s transportation industry reflect the positions of Anchorage and Fairbanks as major transportation centers, not only for the Southcentral Rai1be1t area but for the rest of the State as well. The Port of Anchorage handles most of the waterborne freight moving into southcentral and northern Alaska. International airports at Anchorage and Fairbanks serve as hubs for commercial air traffic throughout Alaska and are important stopovers for 37 major international air carriers. Anchorage also serves as the transfer point for goods brought into the area by air and water, which are then distri- buted by air transport. truck or by Alaska Railroad to more remote areas. 33 Although exerting relatively little direct impact on total employ- ment. mining, finance, insurance, and real estate play important roles in terms of the secondary employment they generate in the region. Most people employed in mining engage in activities relating to petroleum extraction from fields in Cook Inlet and the Kenai Peninsula. A sub- stantial portion of the royalties and taxes collected by the State as a result of o11 production in the area is returned to the area in the form of jobs in State government and through revenue sharing w1th various 1oca1 governments. The total value of oil and gas production 1n the southcentral region for 1972 was almost $240 m1111on. Similarly, the Anchorage financial sector, fn spite of its small employment, exerts considerable economic leverage as the banking center for Alaska. Most agricultural activ1ties in the Southcentral Railbelt area take place in the Matanuska. Susitna, a~d Tanana Valleys. The potential for agriculture in these areas of Alaska is considered favorable, although development of the industry has not been extensive. Commercial fisheries activity is the oldest cash-based industry of major importance within the region. The industry has changed substantially during the past 20 years and continues to be modified as a result of both biologic and economic stimuli. The salmon industry has alw~s been a major component of the industry 1n terms of volume and value. Since 1955, the king crab, shrimp, and Tanner crab fisheries have undergone major development, and halibut landings have increased substantially in recent years. The total wholesale value of commercial fish and shell- fish for the southcentral region of Alaska in 1972 was just over $100 million including a catch of almost 110 mil11on pounds of salmon with a wholesale value of nearly $38 million. The southcentral region of Alaska includes the Kodiak-Shelikof area, the Cook Inlet area, and the Copper River-Gulf of Alaska area. The Southcentral Railbelt area is that portion of the southcentral and Yukon subregions that is served by the Alaska Railroad. The region•s timber output is less than 10 percent of the total timber harvested commercially in Alaska. The timber industry is shifting from supplying the local market to production a1med at the export market. Stumpage value of timber cut from State and National forest lands in the southcentra1 region during 1972 was about $130,000. The tourist industry plays an increasingly important role in the economy of the region. Precise data on tourism are not available, but the numbers of Alaskan visitors have increased from about 130,000 1n 1971 to approximately 216,000 1n 1973. A forecast by the Division of Tourism in 1973 estimated 288,000 people would visit Alaska 1n 1975 and about 554,000 in 1980. 34 L w (J1 Looking north along the Denali Highway to the Amphitheater Mm.mtains. Morainal ridges nm across the middle of the photo. The biome along most of the eastern half of the Denali Highway is moist tundra. __) With population trend projections showing a substantial increase in the number of future residents in the State and especially in the South- central Railbelt area, there will be a related increase in the demand for jobs, goods, energy, and services. Alaska has a wealth of reserves in renewable and nonrenewable resources that will have to be addressed in the very near future. The world consumption of nonrenewable resources for energy produc- tion such as oil and gas has reached or will soon reach a critical point in time where alternative means to produce energy must be developed. The need for the development and utilization of those renewable resources must be weighed against the adverse effects that these developments would have on an ever-decreasing regime of natural environment. 2.03.3 Transportation. 2.03.3. 1 Rail. The Alaska Railroad runs from Seward on the Gulf of Alaska, past Anchorage, up the Susitna Valley, past Mount McKinley National Park, and down to Fairbanks on the Tanana River, a distance of 483 miles. The Federally constructed and operated Alaska Railroad was built between 1914 and 1923. 2.03.3.2 Roads. Paved roads in the Railbelt area include: the 227- mile Sterling-Seward Highway between Homer and Anchorage, with a 27-mile side spur to Seward; the newly-constructed 358-mile Parks Highway between Anchorage and Fairbanks; a 205-mile sect1on of the Alaska Highway that connects Tok Junction with Fairbanks; the 328-mile Glenn Highway connecting Anchorage with Tok Junction; and the 266-mile Richardson Highway from Valdez, on Prince William Sound, to its junction with the Alaska Highway at Delta Junction, 97 miles southeast of Fairbanks. The only road access through the upper Susitna basin is the 135- mile gravel Denali Highway between Paxson on the Richardson Highway and Cantwell on the Parks Highway, and the 20-mile gravel road from the Glenn Highway to Lake Louise. The Denali Highway is not open for use during the winter months. 2.03.3.3 Air. In add1tion to major airlines within Alaska, there are numerous smali commercial operators plus the highest per capita ratio of private aircraft in the nation. Many small remote landing strips are scattered throughout the Susitna basin, and float planes utilize many lakes and streams to ferry freight and pasiengers to the remote back- country areas. In many areas of the State, the only access is provided by the airplane. 2.03.3.4 Other Forms of Transportation. ATVs and other types of off- road vehicles provide transportation into areas in the upper Susitna basin where there are no developed roads. Several developed trails are 36 shown on maps of the upper basin. Trails are utilized by ATVs, trail bikes, hikers, horseback riders, and winter travelers. Shallow-draft river boats, small boats, canoes, rubber rafts, and kayaks utilize sections of the upper Susitna River, a few tributary streams, Lake Louise, and some of the other lakes for recreation purposes. Except for these few areas, boating use is practically nonexistent within much of the upper basin. 2.03.4 Recreation. 2.03.4. 1 Access. The greatest constraint on recreation activities for most of the 5,800-square-mile Upper Susitna River Basin is the shortase of road access. Except·for a 20-mile gravel road from the Glenn Highway to the southern shores of Lake Louise on the upper drainage of the Tyone River, the main access to the area is by way of the gravel Denali Highway through the upper part of the basin. Float planes are used to fly in hunters, fishermen, and other recreationists to various areas within the basin, but, except for a few larger isolated lakes, this form of access is relatively minor. All- terrain vehicles and snowmobiles also provide off-road access to areas within the upper Susitna basin. Boats are used to some extent to provide access on the Tyone River drainage and to areas of the Susitna River between the Denali Highway and Devil Canyon. Much of the Upper Susitna River Basin has very little recreational activity at the present time. Great distances, rough or wet terrain, and lack of roads limit use of most of this area to a few hardy souls who enter these wild lands for recreational purposes, or to the wildlife residents and migrant birds and animals that pass through the region. 2.03.4.2 Hunting. A major recreational use of the upper Susitna area is big-game hunting and associated recreational activities. The greatest hunting pressure~ are exerted from a few fly-in camps, and from areas along the Denali Highway. Most wolves and bears harvested are taken while hunting caribou or moose. The increased use of ATVs to provide access and to haul big game is a significant factor in improved hunting success, even in the face of declining game populations. The mechanized ATV can penetrate deeply into previously inaccessible country, leaving few areas that provide havens for the reduced numbers of caribou and moose. It appears that the use of ATVs for hunting, already prohibited in some areas, may have to be further controlled. The hunting of Dall sheep, mountain goats, and waterfowl is minimal in the upper basin even in areas of road access such as the Denali Highway. 37 2.03.4.3 Fishing. Access is agai n the major factor in determining areas that are uti l ized in fish i ng for grayli ng , ra i nbow trout, white- fi sh, and la ke trout. The Susitna and Mac laren Ri vers are silt l aden throughout their entire courses dur ing the warmer mon t hs of the year . Therefore . sport fishing is limited to la kes, clearwater tr ibutaries, and to areas in the main Susitna near the mouths of these tributari es. Sport ftshing pres sure in t he upper Susitna basin is light. Many lakes and s ome ar ea s of the ri ver a fford landing sites for float-equipped aircraf • A few area s al ong the mai n Susitna and some ributaries, such as the Tyone River and La ke Lou ise, ha ve s ome pressure from boa t fisher - men . An i ncreas i ng number of hunters use ATVs to get 1nto and out of the back country, exerting inci denta l fi sh i ng pressure in some areas. As previously stated. salmon do not migra te into the upper Susitna River above Devil Canyon so are not a factor in the sport fishery of this area. 2.03.4.4 Boating. A minor amount of rec reat ion al boa ting occurs in the wa ters of the up per Su sitna basin. Some l a kes such as Lake Louise have a heavier amount of boating activity, and some r i vers such as the Tyone and the Su sitna have a righter amount of boating act i vity. Same kayakers ut1 lize portions of the main Susitna River, but very few have braved the diffi cu l t waters of the Susitna through the area known as Devil Canyon. 2.03.4 .5 Camping. Most ca mping use in this area is incidenta l to other recreational acti vities such as hunting, fishing, boating . and hig hway travel. Some developed campground facilities are located at Lake Loui se a nd at three campgrounds along the Denal i Highway outside the upper Susitna basin. Tourism during the summer months involving the use of campers, trailers, and similar recreationa l veh icles is increas ing at a dramatic rate in Alaska. Many of these veh ic les camp along the roads where adequate facilities do not exist and where thes e activities are creat1ng ever-increasing adverse impacts upon the land. 2.03.4.6 Other Outdoor Recreational Activities. Most other recreati ona l activi ti es 1n the upper Susitna River basin exert varying environmental impac ts on the area. Many activities such as hiking, backpacking , and photography take place incidentally to other recreational pursuits such a s hunti ng , fishing, boating, camping, and driv ing for pleasure. Tra il bi kes . snowmobiles, four-wheel-drive vehicles, and other mechanical e quipment can cause extreme adverse environmenta l damage to the fragile ecosystems of the basin when used in a careless, uncontrolled manner. At the present time, recreation is one of the major uses of the upper Susitna River drainage area, but the overall utilization of this area by humans rem~ins comparatively light. 38 2.03.5 Historic Resources. The current National Register of Historic Places has been consulted, and no National Register properties will be affected by the project. A historical-archaeological study recently completed for the Corps of Engineers by the Alaska Division of Parks (Heritage Resources Along the Upper Susitna River, August 1975) indicates 11 historic sites within the study portion of the upper Susitna basin. These are all essentially related to the discovery of gold. Most of the early mining activity occurred on Valdez Creek, where the town of Denali was established. Nine of the sites are located in that general area. Two sites, both designated as cabins, are located on Kosina Cree~, one near its mouth, and one about six miles upstream. The apparent deartli of historical locations between Devil Canyon and the Maclaren River is explained by the following excerpt from the Alaska Division of Parks' report (in discussing the first mapping of the area in 1912): "Except for a few prospects on the Oshetna River, the USGS never received any reports of gold being found on the Susitna between Devil Canyon and the Maclaren in significant quantities. Though the Tanaina and Ahtna Indians did a great deal of hunting and fishing on the river in this area, the white man found little gold, an almost unnavigable river. and no reason to settle anywhere near the 'Devil's Canyon'." In 1920 the Alaska Railroad was completed, g1v1ng general access to Mount McKinley National Park. Highways followed in the 1940's and 1950's, and the primary use of the area became recreational. The road approach to Mount tkKinley Park was by way of the gravel Denali Highway until the recent completion of the Parks Highway between Anchorage and Fairbanks. 2.03.6 Archaeological Resources. Only one archaeological site has been examined within the study area portion of the upper Susitna basin, and it has never been excavated. This is the Ratekin Site, located near the Denali Highway several miles east of the Susitna River. Three other late prehistoric archaeological sites have been reported, one on upper Valdez Creek, and two on the Tyone River. Very little information is presently available on the aboriginal uses of the Upper Susitna River Basin. Based upon the knowledge of the prehistory of contiguous areas, the Alaska Division of Parks' report concludes that the Upper Susitna River Basin was likely inhabited as early as 10,000 years ago, during Late Pleistocene/Early Holocene times, with use continuing in intensity during Late Prehistoric/Early Historic times. One archaeological site within the general vicinity of the proposed transmission line corridor is listed in the National Register of 4 February 1975. This is the Dry Creek site. Extensive archaeological remains have been found in the Tangle Lakes area outside the Upper Susitna River Basin near the Maclaren River drainage, and the area has been entered on the National Register of Historic Places. The remains are apparently associated with a large 39 proglacial lake that existed during and after the last period of glacia- tion, dating back some 10,000 to 12,000 years. It is reasonable to expect further remains to be found around the lakebed margins when more detailed investigations are made. 2.04 Energy Needs. Power requirements for the Railbelt are increasing rapidly, and substantial amounts of new generating capacity and addi- tional transmission system development will be needed in the near future. The Railbelt now derives most of its power from oil and natural gas. Past planning has contemplated that natural gas and, eventually, fuels from the Alyeska Pipeline would continue as long-range energy sources for Railbelt power systems. However, recent changes in the national and international energy situation indicate that other alternatives such as the abundant coal and hydro resources of the Railbelt should be recon- sidered. The energy demand curve used in the hydropower study is based on 1975 projections provided by the Alaska Power Administration. The curve represents the combined demand of the areas that could be served directly from an interconnected Railbelt system, and is premised upon assumed growth rates after 1980 that are substantially below existing trends. These growth rates assume substantial savings through increased efficiency in use of energy and through conservation programs. The load projection used in the hydropower study is depicted in Figure 9 along with the other estimates provided in APA 1 s 1975 analysis. The 11 higher 11 range anticipates significant new energy and mineral developments from among those that appear most promising, along with an annual growth rate in residential, commercial, and light industrial uses that remains throughout the study period somewhat above recent electri- cal energy consumption growth rates in the U.S. The 11 lower 11 range presumes minimal industrial development, a load growth rate for the remainder of this decade well below current actual rates of increase, and energy growth over the next twenty years that barely matches the latest population growth rate projections for that period. This lower estimate generally assumes a significant slackening of the pace of development almost immediately and continuing throughout the period of study. The 11 mid-range 11 appears to be a reasonably conservative estimate, with annual rates of increase in power requirements less than 7 percent after 1980 as compared to an historical annual growth rate of 14 percent during the period 1960 to 1971. This adopted 11 mid-range 11 projection assumes steady but moderate growth after the present boom period coupled with more efficient energy use. Because of lead time needed for coal and hydroelectric development, immediate needs for the next decade will have to be handled by additional oil and gas-fired units. However, the opportunity exists for hydro and coal to become the main energy sources for Railbelt power by about 1985, if priority is attached to these resources. 40 Studies by the advisory committees for the current Alaska Power Survey provide estimates of costs for alternative power supplies from coal, natural gas. and oil-fired plants. Indications are that power from Susitna hydroelectric development would be comparable in cost to present gas-fired generation in the Cook Inlet area and would be less expensive than alternatives available to other Southcentral Railbelt power markets. There are many questions concerning future availability and costs of natural gas and oil for power production. Oil prices have increased dramatically in the past few years, and there are many pressures to raise natural gas prices. There are also arguments that natural gas reserves are needed for petrochemical industries and for other non-power uses. Many people in Government and industry question the use of natural gas and oil for long-range power system fuels. On 31 December 1974 the Congress enacted Public Law 93-577. This act established a national program for research and development in non- nuclear energy sources. One of the sections of the law stipulated that heavy emphasis should be given to those technologies which utilize renewable or essentially inexhaustible energy sources. 41 a: :I: 3: :::.:: z 0 ....J ....J -~ 40,000 30,000 20,000 10,000 0 1970 LOAD k::: ~ f.; PROJECTIONS v v ~~/ v v 1/ / v ,.I/ "" 1-- ~ ~ 1--:: -.- 1980 FIGURE 9 42 I I I v ~\ / / I/ v v I / v I :/ ~Q~v ~;..:.-- v vv L~r-- ~ -1-r--1-/ -v 1-1--1-- 1-1- 1990 2000 YEAR PROJECTED ENERGY DEMAND SOUTHCENTRAL RAILBELT 3.0 RELATIONSHIP OF THE PROPOSED ACTION TO LAND USE PLANS. 3.01 Present Land Status. Lands in the general project area of the proposed Upper Susitna River Basin hydroelectric development at Devil Canyon and Watana are under Federal jurisdiction and administered by the U.S. Bureau of Land Management. These lands have been classified as power sites by Power Site Classification Number 443, dated 13 February 1958. The project areas are designated in the Power Site Classification by approximate damsite locations and contour designations as fol :ows: Devil Canyon: This area begins approximately 1.4 miles upstream from the mouth of Portage Creek and includes all lands upstream from this point below the 1500-foot contour. Watana: This area begins approximately 1.5 miles upstream from Tsusena Creek and includes all lands upstream from Tsusena Creek and from this point below the 1,910-foot contour. Transmission Corridor: Most of the route segments lie in lands that are pending or tentatively approved State selections, native village withdrawals, and native regional deficiency withdrawals, all of which are in a state of flux at the present. There is very little privately owned land within the proposed corridor. Most of the affected lands between Point MacKenzie and Ta.lkeetna are potential State selections. Native village withdrawals relevant to the settlements of Montana Creek, Caswell, and Knik are indeterminate. From Talkeetna to Gold Creek, the corridor transects State selected land and borders on Denali State Park. Between Gold Creek and Devil Canyon, the lands are 50/50 State selections and native regional deficiency. From Gold Creek to Cantwell, the lands are comprised of native withdrawals and State selections. From Cantwell to Healy, the route is State selected land bordering on Mount McKinley National Park. Route lands between Gold Creek and Healy also fall within the Mount McKinley Cooperative Planning and Management Zone. From Healy to Ester, the route primarily transects State selected land with some existing Federal withdrawals and native village withdrawals. Land status described above is subject to change as determinations are made for ultimate disposal. 3.02 Alaska Native Claims Settlement Act. The Power Site Classifi- cation withdrawals are in an area designated under the Alaska Native Claims Settlement Act (Public Law 92-203) for village deficiency with- drawals: lands which can be selected by village corporations which cannot meet their selection entitlement from withdrawals in the areas immediately surrounding those villages as provided in Section ll(a)(3) of PL 92-203. Lands within the power site withdrawal may not be selected as Native Village deficiency lands. Accordingly, the effect of PL 92-203 concerns only the lands lying above the contours designated in the Power Site withdrawal. A proposed exchange of lands is presently being considered 43 by the Cook Inlet Native Regional Corporation. the State of Alaska, and the Bureau of Land Management. This proposed exchange would result in the State's becoming owner of the lands above the contours designated in the power site withdrawal in lieu of the Native Village corporations. The proposed exchange, however, necessitates an amendment to PL 92-203, and possib1y to Alaska statutes, to permit such an exchange to proceed. 3.03 ytility Corridors. The U.S. Bureau of Land Management has pre- pared a report suggesting a Primary Corridor System for the State of Alaska. The report was p;·epared in accordance with the provisions of Section 17 (b)(3) of the Alaska Native Claims Settlement Act (Pub l ic Law 92-203). The Primary Corridor System is defined as a network of corridors intended for the systematic transport of high-val ue, energy-rel a ted resources from their point of ori~in to processing or trans shi pment points in other regions of the State. The network is i ntended to identify transportation routes for resources of nationa l or statewide significance and is analogous to the transportation network that already exists in conterminous states consisting of navigation, highway, rail- road, and pipeline systems. The Susitna project is one of the hydroelectric power developments sufficiently advanced in the planning phase to warrant corridor consider- ation for high-voltage power transmission lines. The transmission lines from the proposed Susitna project have been identified as a portion of Corridor No. 29 in the suggested Primary Corridor System. 44 4.0 ENVIRONMENTAL IMPACTS OF THE PROPOSED ACTION 4.01 Hydrology and Water Quality. About 86 percent of the total annual flow of the upper Susitna River occurs from May through September. Average daily flows from the latter part of May through the latter part of August fluctuate in the range of 20,000 to 32,000 cubic feet per second (cfs). November through April the average daily flows range between 1,000 and 2,500 cfs. The river also carries a heavy load of glacial sediment during the high runoff periods. During the winter when low temperatures reduce water flows the streams run relatively silt- free. Some of the impacts that could be caused by the project downstream from Devil Canyon Dam are discussed below. Significant reductions of the late spring and early summer flows of the river and substantial increases of the winter flows would occur. The flow of the river during the period 1950 through 1974 averaged about 9,280 cfs. The projected average regulated downstream flows for a Devil Canyon-Watana system computed on a monthly basis would range between about 7,560 cfs in October to almost 15,100 cfs in August. In extreme years, the monthly averages would range from about 6,300 cfs to nearly 28,300 cfs. The average monthly regulated flows compared to the average unregulated flows based on the period from 1950 through 1974 are as follows: TABLE I -FLOWS Regulated Unregulated Month cfs cfs January 9,905 1 '354 February 9,429 1 '137 March 9,026 1 '031 Apri 1 8,278 1 '254 May 8 '158 12,627 June 8,329 26,763 July 9,604 23,047 August l 5, 091 21 '189 September 10,800 13,015 October 7' 560 5,347 November 8,369 2,331 December 8,968 1 ,656 The heavier sediment material now carried by the river during high runoff periods between Devil Canyon and the junction of the Chulitna and Talkeetna Rivers with the Susitna River would be substantially reduced, and a year-round, somewhat mi"lky-textured 11 glacial flour" (suspended glacial sediment) would be introduced into the controlled water 45 rel eases below the dam. Pre limi nary stud i es by the Corp s of Eng i neers i nd ica te that the suspended sediment in releases at Devil Canyon Dam wou l d be at low levels (15-35 ppm). According to fishery investigations du ring the win ter of 1974-75 by the Division of Commerc i al Fisheries of the Al as ka Depa rtment of Fi sh and Game on the Susitna Ri ve r between Portage Creek and the Chul i tna River. suspended solid samples of r iver water at Gold Creek, Chase and the Parks Highway bri dge, indicated a range of fron1 4 to 228 ppm , and that these suspend ed so li ds are with in anadromus fish tolerances. Al thoug h the a verage sediment load in summer months is le ss than 1000 ppm , loads sometimes reach a ~x1mum of 5000 ppm in the unregulated r i ver . Reduction of ex i s ting summer sedi - mentation peaks ihauld ha ve a beneff c i al ·effec t on ana dromous and residen t fi sh popu l at ions f or some dista nce d ownstream from Devi l Canyon D~. On oc cas ions when spi ll ing water over Dev il Ca nyon Dam would be necessa ry during la te summer periods of ex treme high (lows, nitrogen supersaturation coul d be i ntroduced into the r iver be l ow the dam. Fis h ex pos ed to hi gh levels of this condition can suffer gas -bubb le d isea se (like bends to a deep-sea diver) which can be fata l. The combined high level regu1ating outlets a nd powerhouse capacities {30,000 cfs and 24,000 cfs respectively) at the Wa tana Dam are adequate to accommodate floods with recurrence intervals of up to approxima te ly 50 years. At the Devil Canyon Dam the hydraulic capacity of the i nit ial four generat i ng units is approximately 25,000 cfs at normal maxim um pool e l eva ti oon of 1,450 feet. The low level outlet works at Devil Canyon ar e not desi gned to generate at pool elevation 1,450 feet, therefore, total outfl ow without spill is limited to a maximum of 25,000 cfs. Of the 25 years of streamflow record, spills were estima ted to occur in 11 of the operation years, with the average spill last ing 1 4 days with an average flow of an additional 8,500 cfs. However, any ni trogen su pers- aturation and dissolved oxygen thus introduced should be reduced s ub- stantially in the turbulent river section just downstream from Dev il Ca nyo n dam. The proposed sp i llway at Watana Dam is not conducive to high levels of nitrogen or oxygen supersaturation, and spills would occu r very seldom, only on the occasions of extreme flooding conditions in l ate s unmer . Few fish, under existing conditions, are believed to occupy the two and one-half mile section of Susitna River between the propos ed Devil Canyon damsite and the mouth of Portage Creek. This s i tua ti on could change with a decrease in regulated flows during the summer months. Temp erature of the wa ter released from Devil Canyon Dam would be adj us ted to approach the natural river water t enperatures. This would be made poss ib le by the proposed incorporation of selective withdrawl outl ets into the dam structure. Var iations i n wa ter relea s es at Dev il Canyon Dam would cause less than d one-foot dai1 y fluctuation of downstream water 'evels in the r iver during the May through October period since the reservoir would 46 not be used for peaking purposes. The regulated daily fluctuations during the winter months could range up to one foot under normal oper- ating conditions. According to U.S. Geological Survey studies, the natural normal daily fluctuations in the Susitna River below Devil Canyon range up to about one foot. Stratification conditions within the reservoirs could cause some temperature and dissolved oxygen problems in the river for some distance downstream from the Devil Canyon Dam and within the reservoirs them- selves. These conditions could have an adverse impact on the downstream fishery. However, this problem can be minimized by multiple-level water release structures which are proposed for incorporation into both dams. This would provide the capability of selective withdrawal of water from various levels within the reservoir to moderate release temperatures and dissolved oxygen content. Spillway designs will a1so be considered to reduce supersaturation of downstream water flows with atmospheric gases. There would be a period of channel stabilization in the 50-mile section of the Susitna River below Devil Canyon Dam in which the river would tend to adjust to the stabilized flow with low sediment levels but general channel degradation caused by a river•s attempt to replace the missing sediment load with material picked up from the riverbed is not expected to be a significant concern along the coarse gravel bed reaches of the Susitna River between Talkeetna and Devil Canyon. However, this phenomenon would be the subject of future detailed studies to determine the distance at which sediment loads would become reestablished. Upstream from the dams the major environmental impacts would be caused by the reservoir impoundments. Under the proposed two-dam system, the reservoir behind the Devil Canyon Dam would fluctuate up to 5 feet during the year, while Watana reservoir would fluctuate between 80 and 125 feet during the year under normal operating conditions. The maximum daily fluctuation at Devil Canyon reservoir under normal operating conditions would be less than two feet. Devil Canyon reservoir would cover about 7,550 acres in a narrow steep-walled canyon (1/4 to 3/4-mile-wide) with few areas of big game habitat and a minimal amount of resident fish habitat near the mouths of several of the tributaries that enter the Susitna River in the 28-mile section above the proposed damsite. The reservoir would also flood approximately 9 miles of the 11-mile, whitewater section of Devil Canyon. Watana reservoir, with a structural height of 810 feet and a pool elevation of 2,200 feet, would flood about 43,000 acres in a 54-mile section of the Susitna River that would reach upstream about 4 miles above the Oshetna River confluence. Except in a few areas near the mouths of tributaries such as Deadman Creek, Watana Creek, Jay Creek, and Kosina Creek, the Watana reservoir would be contained within a fairly narrow canyon l/3-mile to 1 mile in width for much of its length. 47 The spillway design at Watana diverts the excess river flows into the Tsusena Creek drainage approximately 2.5 miles above the creek's confluence with the Susitna River. On the occasions (approximately once every 50 years) when it would be necessary to divert excess river flows over the spillway during extreme flooding conditions in late summer~ the adverse environmental impact on fish and vegetation resources in lower Tsusena Creek could be significant. Watana reservoir would flood reaches of the Susitna River upstream from Tsusena Creek that are sometimes used as caribou crossings. It would also flood some moose winter range in the river bottom. The reservoir would also cover existing resident fish habitat at the mouths of some of the tributaries in this section of the river and possibly would create other fish habitat at higher elevations on these tributaries. Potential water quality impacts caused by construction of trans- mission facilities are the increased siltation of rivers and lakes; alteration of stream flows; eutrophication (increased nutrient levels) and pollution of lakes and streams; and disruption of aquatic habitat due to gravel borrow, fill, and excavation. Eliminating or minimizing these potential adverse impacts would be emphasized during the design, construction, and maintenance of the proposed project. 4.02 Fish. One of the environmental impacts caused by the proposed Devil Canyon-Watana project would be the substantial reduction of natural river flows during the latter part of June and the early part of July when salmon start migrating up the Susitna River. The projected average monthly regulated flows during periods in August and September, when the majority of the salmon are spawning, approach the average natural flows of the river during this period. In a 1974 study by the Alaska Department of Fish and Game on surveys conducted to locate potential salmon rearing and spawning sloughs on the 50-mile section of the Susitna River between Portage Creek and the Chulitna River, 21 sloughs were found during the 23 July through ll September study period. Salmon fry were observed in at least 15 of these 21 backwater areas. Adult salmon were present in 9 of the 21 sloughs. In 5 of the sloughs the adult salmon were found in low numbers (from l to 24 with an average between 6 and 7). In 4 other sloughs large numbers were present (from 107 to 681 with an average of just over 350). During December 1974 and January and February 1975, the Alaska Department of Fish and Game investigated 16 of the 21 sloughs previously surveyed during the summer of 1974. Of the 16 sloughs, 5 indicated presence of coho salmon fry. The numbers of fry captured in the 5 sloughs at various times ranged from l to 21 with an average of 5. Many of the 16 sloughs surveyed were appreciably dewatered from the summer/fall state. 48 The report also stated that a number of coho fry were captured in the Susitna River near Gold Creek indicating that some coho salmon fry do overwinter in the main river. The winter investigations indicated that the Susitna River between Devil Canyon and Talkeetna was transporting suspended solid loads ranging from 4 ppm to 228 ppm. It may be reasonable to assume that one of the most critical factors in salmon spawning is the dewatering of areas in which the salmon have spawned. If winter flows are insufficient to cover the spawning beds it would be of"'litt·le consequence if high summer flows allowed salmon to spawn in some of the sloughs that are dewatered during the egg incubation or alevin stages. According to a Hydrologic Reconnaissance of the Susitna River Below Devil 's Canyon, October 1974 by the National Marine Fisheries Service when comparing regulated flows to natural flows (see Table 1 on page 45), "It is reasonable to conclude that during the months of October through March spring flows may be enhanced in the river valley bottom, during the months of May through mid-September these springflows may be depressed." It is reasonable to assume on the basis of existing data that there will be some changes in the relationship between the regulated river and access to existing salmon rearing and spawning sloughs and tributaries downstream from Devil Canyon Dam. It appears feasible to develop a program to improve fish access to and from some of the sloughs and tributaries in the Susitna River as a consequence of the project's stabilizing effect on summer flows. Such a program would be a project consideration. Flooding, which occurs frequently under natural conditions and presently destroys salmon eggs in this stretch of the river would be almost completely eliminated by regulation of the upper Susitna River flows. Reduction in flows and turbidity below Devil Canyon Dam might cause some disorientation of salmon migrating into the section of the Susitna River between Portage Creek and the Chulitna River during an initial period after construction of the dams and until future salmon stocks readjusted to the change in regulated river conditions. During the period of construction, river flows will be diverted through tunnels in the canyon walls and past the construction areas at the damsites with minimal changes in existing water quality. During the periods in which the newly-constructed reservoirs would be filling with water, downstream flow maintenance would be. coordinated with the fish and wildlife agencies to prevent unnecessary damage to downstream fishery resources. It is proposed to initiate construction of Watana Dam in about 1981. and Devil Canyon approximately five years 1 ater. 49 According to a study discussed in the Journal of Fisheries Research Board of Canada--Volume 32, No. 1, January 1975, Ecological Consequences of the Proposed Moran Dam on the Fraser River, some of the beneficial downstream impacts of the dam could include the following: The higher regulated winter flows might increase the survival of salmon eggs in the sloughs and backwater areas of the river downstream from the dam. The increased flows could insure better coverage and better percolation through the gravel and presumably increase egg and alevin survival. Salmon alevin are young fish with attached egg-sacs that rema1n in the gravel beds until they emerge as fry. An additional consequence of reduced turbidity below the dam might be a gradual reduction in the percentage of fine materials in the salmon spawning areas near the mouths of sloughs and tributaries as they enter the Susitna River. This could also lead to improved percolation through the gravel in the streambed and possibly improve survival of eggs. Reduced siltation during the summer months should prove beneficial for both anadromous and resident fish 5pecies for some distance down- stream from the proposed Devil Canyon Dam. It is also reasonable to expect that some additional salmon spawning and rearing habitat would develop within some sections of the Susitna River between Devil Canyon and Talkeetna. According to the Moran Dam study, reduced turbidity during the summer months or during the periods of seaward migration could lead to an increase in visibility within the river and therefore an increase in predation of salmon fry. A slight increase in turbidity during the winter months might also increase the survival of young salmon due to a decrease in visibility during that period. Another impact on juvenile salmon could be the extention of the seaward migration period due to less turbid water in the 50-mile portion of the Susitna River below Devil Canyon. Other hydrologic factors previously discussed would also affect the fishery resource downstream from the dams. These and other changes could also influence the food and life cycles for fish in this section of the river. Biological and physical changes likely to occur are the subjects of ongoing studies by State and Federal agencies under the direction of the U.S. Fish and Wildlife Service. Results of these studies will be used in determining needs for more detailed final design phase studies, feasible project modification, and mitigative or ameliorative measures. 50 Upstream from the dams, the major impact on the resident fish populations would be caused by U;2 reservoir impoundments. Under the proposed plan, Devil Canyon reservoir would fluctuate very little. Even though the steep-walled canyon of this reservoir might prove less than desirable for a program to develop a resident fish population, some species of fish might be able to adapt to this reservoir and provide some future sport fishing benefits. Watana Dam would have a widely fluctuating reservoir which WOJTd generally prove detrimental to the development of resident fish popu- latlons. Suspended glacial sediment could be a factor in both of the reservoirs after the heavier glacial sediments have settled out; how- ever, many natural lakes in Alaska such as Tustumena and Tazlina, with heavy inflows of glacial debris sustain fish populations under similar conditions, so to develop populations of fish under related conditions may be feasible. Most resident fish populations, especially grayling, utilize some of the clearwater tributaries of the Susitna River or areas near the mouths of these streams as they enter the glacially turbid main river channel during periods of high runoff. Many of these tributaries would be flooded in their lower reaches by the proposed reservoir impound- ments. The resident fish populations would be affected by the increased water levels in the proposed reservoirs; but in some areas, access to tributaries for resident fish may be improved by increased water elevations. It appears highly unlikely that anadromous fish such as salmon could be successfully introduced into the Upper Susitna River Basin. With the succession of very high dams and the related problems and costs of passing migrating fish over and through these dams, such a program appears infeasible {Report, Ecolo ical Conse uences of the Pro osed Moran Dam on the Fraser River . This report states in reference to high dams: 11 The choice is clearly between upstream salmon stocks or dams.11 However, the introduction of a resident salmon species, such as sockeye (kokanee) or others to some waters of the upper Susitna basin might prove feasible with further studies. Other problems related to the introduction of anadromous fish into the Upper Susitna River Basin would include the following: Fish would experience high mortality rates if they attempted to move downstream through turbines or outlet works in the proposed series of high-head dams. According to Corps of Engineers studies, a 35 percent mortality rate could be expected on fish such as young salmon at each high dam. Perhaps even more significant than turbine loss is the experience background that juvenile salmonids will generally not migrate out of large storage type reservoirs. Reverse currents, temperature strati- fication, etc., apparently disorients the migrants and causes them to lose their migrational motivation. As a result many never even reach the dam and they spend their lives as residuals in the reservoir. (Example: Brownlee Reservoir, Snake River, Idaho and Oregon) 51 Impact upon aquatic life from the trans1nission line should be small because of the care that would be taken to prevent degradation of streams within the corridor. However, the aquatic food chain in the taiga (boreal forest) and tundra is extremely simple, and as a result, disruption of habitat for one species quite often indirectly affects many other s pecies. Potential impacts are: increased siltation of rivers and l akes; alteration of flows; eutrophication and pollution of lakes and streams; and disruption of habitat due to gravel borrow, fill, and excavation. All construction and maintenance activities would be controlled to prevent or minimize adverse environmental impacts. 4.03 Wild1ife . Reservoir impoundments, transmission line corridors, and access roads would have varying degrees of environmental impact on wil dlif e. The Devil Canyon reservoir would be located withi n the confines of a narrow, steep-walled canyon with few areas of bi g-game habitat and on no major migration routes for big-game anima ls . In some cases, animals such as moose and caribou may find it easier to cross t he narrow reser- voir than they would the present fast-moving river at the bottom of a deep, steep-sided canyon. The proposed Watana Dam would be generally contained within a fairly deep and narrow river canyon. Watana reservoir would lie across one of the intermittent seasonal caribou migration routes between the main calving area of the Nelchina caribou herd, located south of the river in the northeast foothills of the Talkeetna Mountains, and some caribou summer range on the north side of the Susitna River. Calving generally takes place during a month-long period starting in the middle of May and most of the caribou move out of the calving area in June and July. Ice-shelving conditions caused by winter drawdown on Watana reser- voir or spring ice breakup conditions on the reservoir could cause problems for caribou, moose, or other animals if they attempt to cross this reservoir when these adverse conditions exist. Warmer weather and a rapidly filling reservoir should eliminate any adverse ice conditions at Watana during the month of May. As caribou are. strong swimmers, they should have fewer problems crossing the narrow 2/3 to 1 mile wide section of the reservoir in the historic crossing areas in the vicinity of Kosina and Jay Creeks during July after calving than they would crossing the swollen glacial river during periods of high runoff. Some caribou could also migrate around the upper reaches of the proposed Watana reservoir area as indicated in existing spring migration patterns. Caribou migration patterns for the Nelchina herd are continually changing, as stated in Alaska Department of Fish and Game study reports. Their studies also indicated the use of the Watana reservoir site by Nelchina caribou for grazing and crossing was minimal during the period November 1974 through April 1975. Under adverse ice conditions, the reservoirs could result in increased problems for some segments of the herd. Also, there could be some permanent changes in historical herd movement patterns. 52 Within the transmission line corridor system, impacts to caribou would be limited to the 136-mile segment extending north from Cantwell. There is no significant caribou use of areas to the south. Although the transmission line and related access roads would not impose a physical barrier to migration of caribou, construction and maintenance work during certain seasons may inhibit herd movement. Since caribou are primarily confined to the west bank of the Nenana River, they will not be significantly affected in this area if the line runs along the east bank. Although physical destruction of caribou habitat will not be a sign f1cant impact of power line construction, there are indirect consequ~nces which could be significant. Increase of fires resulting from manmade causes could destroy tundra lichen which is their prime source of winter food. It is estimated that approximately 50 years are required for a burned area to recover a usable cover of lichen for caribou. Noise generated by the transmission lines could also modify normal behavior. as could public accessibility provided by transmission line roads. A moose survey conducted in early June 1974 by the Alaska Depart- ment of Fish and Game indicated that, although spring counting conditions were less than ideal, a total of 356 moose were seen along the upper Susitna River and in the lower drainage areas of the major tributaries. A 1973 fall count in the same general area sighted a total of 1796 moose. Of the 356 moose counted in the June 1974 survey, 13 were seen in or near the area of the proposed Watana reservoir below Vee Canyon. None were sighted within the proposed Devil Canyon reservoir impoundment. Although limited moose habitat appears to exist within the pool areas of the proposed Devil Canyon and Watana reservoirs, it is considered critical to those moose now utilizing the area. Special studies will be required to determine impacts upon moose habitat and populations. During the June 1974 Fish and Game survey period, one grizzly was sighted on the upper Oshetna and one on the Maclaren River. Five black bears were sighted on the Susitna River. A total of 56 caribou were sighted in the survey area. Moose are found throughout the length of the transmission line corridor. The greatest adverse impact to these animals would be the increased hunting access provided by roads and the openness of the corridor itself. Habitat, on the other hand, would overall be improved. Subclimax growth within the transmission line corridor would increase moose browse. The proposed reservoirs at Devil Canyon and Watana are located along a major flyway for waterfowl. Very few waterfowl appear to nest on the sections of the river that would be flooded by these reservoir proposals. On the other hand, the reservoirs would provide suitable resting areas for waterfowl migrating through the basin. 53 Migrating b irds would possibly su f fer some mortality from collisions with towers or lines, but such losses shoul d be negligible. The line woul d generally parallel normal north-south migration routes. The cab l es would be large enough to have a high degree of visibility and wou1d be widel y enough spaced to be i neffec tive snares. Electrocution of b;rds is a 1so unli kely since the di stance between lines and between lines a nd ground would be great enough to ma ke shorting out by birds almost impo ss ib le. A transmiss ion li ne per se wfl1 not have ma ny impacts upon wild- life; most of the impacts will be as a resul t of cons truc tion and maintenance. Direc t des truct ion wi ll affect the less mobile an imal s such as the small mamma ls, whose territor ies may be small enough to be encompa ss ed by the construction area. The s ignif icance of this impac t to these ani ma ls is sma ll in relation to thei r popu l ation in surrounding areas. The l oss of habitat for bear s, wol ves, wol verines, Dal1 sheep, and othe r an ima ls also appears to be mini mal. However, losses to any s ign ificant element of the food web wil l affect consumers. Thus, losses to moose or caribou would impact upon predator species. Other birds, inc l uding raptors, songbirds, shorebirds, and game birds, do not appear to be significant l y affected by the reduction of habitat in the area of the proposed dams and reservoirs and on the transmission line corridor , although some habitat will be lost for all species of wildlife that ut ili ze the affected areas. Road access to the two damsites and to the transmission line would ha ve a significant impact on fish and wildlife resources in areas opened to vehicle encroachment. Specific areas such as Stephan Lake, Fog Lakes, lower Deadman Creek, and the northern slopes of the Talkeetna Mountains could be significantly impacted by hunters, fishermen, and other recreationists by a n access road to the Watana Dam. The same wou ld be true a1ong various segments of the transmission line. State game ma nagemen t policies could control some of the adverse impacts on fish and wil dli fe in these areas. However, this increase in public access i bility would significantly increase the necessity for intensified 1aw enforcement and fire prevention measures. 4~04 Re c r eati on . Much of the Upper Susitna River Basin has little or, in many area s$ no recreational activity at the present time. A combi- nati on of poor road access, rough terrain, and great distances presently lfmit the use of t he 5,800-square-mile basin, especially the lands directly impacted by the proposed project, to a few hunters, fishermen, and other hardy souls who utilize these wild lands for recreational purposes. The construct i on of the proposed hydroelectric project would have an impact on a nu mber of present and projected recreational activities both in the immediate dam and reservoir areas and downstream from the dams. 54 At the present time, the Susitna River upstream from Portage Creek to the Denali Highway bridge is a free-flowing river with few signs of man's activities and minimal public use. The project would significantly change both the present riverine setting and human use of the area. Improved road access into the upper Susitna basin would substantially increase pressures on all the resources impacted by outdoor recreation activities within these areas. Along with a potential increase in hunting pressure, the construction of project-oriented recreational facilities would further increase public use in the immediate vicinity of the proposed dams and reservoirs. These recreational developments would eventually include visitor centers at the dams, boat launching ramps on the reservoirs, campgrounds, picnic areas, trail systems, and other related developments, as shown in Figure 10. It is estimated that with the recommended development plan, the initial annual visitation to the project area would be about 77,000 people. The possible relocation of the state capital to the Lower Susitna River Basin could have a substantial impact on the extent of development of recreational facilities within the Devil Canyon-Watana project area. At the present time, few people reside within a 100-mile radius of the project area, and day-use of the project by local residents would be minimal under existing growth conditions. Any project-related recreational development program would involve cooperation between the appropriate Federal, State, and local interests and would require State or local sponsorship, sharing of costs for construction, and maintenance of the developed recreational facilities by the appropriate State or local sponsor. The State of Alaska (Divi- sion of Parks) has indicated an interest in sponsoring a program of recreational development in the area of the proposed project. 4.05 Historical Resources. Although a preliminary investigation by the Alaska Division of Parks (Heritage Resources along the Upper Susitna River, August 1975) indicates the location of ll historic sites within the upper Susitna basin hydropower study area, only one of these would be directly affected by the currently proposed two-dam development. This site is located near the mouth of Kosina Creek and would be inundated by the Watana reservoir. The significance of this site, a cabin, is not disclosed in the State report. However, on the basis of the limited early modern history associated with the upper Susitna basin, part- ticularly the downstream portion above Devil Canyon, it is most likely that the site is related to early exploratory mining in the area. The Knik historical site, although located in the vicinity of the trans- mission line would not be affected by the transmission corridor. 55 0 L SITE "c" TRAIL HE AD t.ND PI C NIC AREA . 0 ; JO 15 . 20 Mdu -.../ f 1"' I ,r-,r....._...___..._...l\./. ,...------- " \ AREA. ALASKA UPPER SUSITNA RIVER BASIN RECREATION PLAN ALASKA Ol~TR1CT, OORP3 OF ENGI~[ll$ _) ___ _ Looking upstream at Susitna River near Denali. Tundra ecosystems with scattered areas of black spruce. 4.06 Archaeological Resources. Of the four presently known archaeo- logical sites in the upper Susitna basin, all lie upstream from the influence of the Watana Dam and reservoir, according to the Alaska Division of Parks report of August 1975. On the basis of probable highest game diversity in early times, the report selects areas most likely to have been inhabited by people, and thus identifies sites for potential archaeological exploration. These sites are most generally designated as being near the confluence of streams where habitat diversity was likely highest. The report concludes that "--the entire river system should be regarded as an area of extremely high archaeological potential." The report further sfates: "While it is difficult to measure the amount of adverse impact each of the four dam complexes will have on heritage resources, it is possible to ascertain that the Devil Canyon Dam will have the least effect. The Watana Dam will have the second lowest adverse impact, followed by Denali Dam. The construction of the Vee Dam site will have the most adverse impact on significant heritage resources. 11 (The Vee and Denali Dams are not in the proposed plan of development.) More intensive reconnaissance of the affected areas will be neces- sary following pr~ject authorization to determine the actual existence and locations of sites. The Dry Creek archaeological site is located in the vicinity of the proposed transmission line corridor. The site will not be affected by development within the proposed route. 4.07 Vegetation. All of the vegetation within the pools of the pro- posed reservoirs and in the proposed road locations would be eliminated if the dams were constructed. Trees would also be cleared in areas within transmission line corridors. Most of the treei and shrubs would be cleared during construction operations, and some of the commercial timber would probably be marketed. Most of the residue slash material and debris would be burned or buried. Much of the existing tree and shrub cover in the Upper Susitna River Basin is located in the river and creek bottoms and on the steep canyon slopes above the streams and would be lost during dam construc- tion. The operations to clear the vegetation within the reservoir impoundments and other areas would require a network of temporary roads and work areas for personnel, equipment, and vehicles within and around the areas to be cleared. Controls over the clearing and related opera- tions would include provisions to reduce or prevent many of the adverse environmental impacts of these activities including the possibility of uncontrolled fires. The major ecosystems of the upper Susitna basin include the upland and lowland spruce-hardwood forest systems and the moist and alpine tundra systems. All these ecosystems are susceptible to long-term 58 damage or destruction; the predominant tundra systems are especially vulnerable. Particular care would have to be taken to protect the land and the vegetation from unnecessary damage, and remedial actions would also need to be taken to make feasible repairs to whatever damage should occur. Except for the river itself the area within the proposed reser- voir pool is dominated by the upland spruce-hardwood forest ecosystem. Most of the direct impacts of the transmission line and required access roads upon vegetation would be relatively small with respect to the magnitude of surrounding unaffected land. Up to 6.100 of the approximately 8,200 acres of right-of-way would have to be c1eared. The effect on scenic quality would be a major impact of the cleared right-of-way. Regrowth beyond a limited height would be prevented by maintenance, thus cuts through forested areas would be permanently visible. This effect would not be as significant in more open areas at higher elevations, such as Broad Pass, where no tree clearing is required. On the other hand, in such areas the transmission line itself would be more visible. This effect is more fully discussed under the heading of Esthetics. The disposal of slash and debris, whether by burning, burying, chipping, or stacking has potentially adverse effects upon remaining vegetation and other resources. Although stacked or dispersed slash may provide habitat for small animals, there is a high potential that slash may result in increased fire hazard and increases in insect populations which could damage surrounding forests. Chipping is very expensive and requires more machinery to travel along the right-of-way. Disposal of chips is a problem because they should be dispersed to prevent killing the plants on the ground. Since decomposition rates are slow, chips may not revert to humus for quite some time. Vegetation along most of the transmission line corridor is conducive to a high rate of fire spread and is considered to be of medium to high resistance to fire control. However, with proper precautionary measures, burning would probably be the most desirable method of slash and debris disposal from an environ- mental viewpoint. Significant impacts to wildlife would result from habitat modifi- cation resulting from impacts upon vegetation. Transmission corridor clearing in forest areas and maintenance of a subclimax plant community of brush and low plants would improve habitat for some species by increasing primary productivity in the cleared areas. Browse far moose will be increased; the conjunction of good cover in the original forest with a swath of browse creates a diverse 11 edge" habitat for many animals dependent on subclimax growth. Animals dependent on climax or near- climax vegetation will suffer loss of habitat; examples are the red squirrel and northern flying squirrel, both of which depend upon white spruce. 59 4.08 Mining. The U.S. Department of Interior, Bureau of Mines office in Juneau. Alaska, has stated that the Susitna River basin in the pro- posed reservoir impoundment areas is generally favorable for various types of mineral deposits, but the area has never been mapped geologically. 4.09 Agriculture. No project benefits are anticipated for irrigation at this time~ and except for provid i ng reasonably priced electrical power to farms and agricultural activities, no other major impacts on agriculture are expected. Presently most agricultural activity in the Stdte. from crop farming to dai ry farming, occurs in the Cook Inlet subregion. Of the 2.5 million acres of land that have soil characteristics conducive to the production of cultivated crops in the Cook Inlet-Susitna Lowlands, about 70 percent occurs in the valleys of the Matanuska and the Susitna Rivers and their tributaries. Most of th is land is as yet undeveloped. 4.10 Roads. Permanent roads would be built to provide access from the Parks Highway to the Devil Canyon and Watana damsites and some segments of the transmission line. Permanent roads would a lso provide access to proposed recreation facilities within the project area. Temporary roads for project construction and reservoir clearing operations woul d also be constructed. No roads would be built within the transmission line corridor in the 39-mile reach between Cantwel l and Healy, and the 10- mile reach between Gold Creek and Chulitna. No permanent roads would be constructed upstream from the vicinity of Watana dam. The impact of road access to areas within the proposed hydroelectric developments would be significant; also, the roads themselves would have a definite impact upon the land. Resource values impacted by proposed roads include fish, wildlife, vegetation, recreation, scenery, water, and soils. Air and noise pollution related to road construction and dust generated by vehicle travel on unpaved roads could also be signifi- cant adverse environmental impacts. In sections where permanent transmission line access roads are required, the road would be built and maintained to a standard suitable for four-wheel-drive vehicles. Not all sections will have access roads; in critical areas, winter construction or helicopter constructidn will be used. It is also expected that helipads and possibly an aircraft landing strip would be provided within the project area for air evacuation of injured workers and for the convenience of reduced travel time; any temporary aircraft landing facilities would be rehabilitated after project construction. Proposed right-of-way restoration after construction includes removal of temporary s{~;·uctures and temporary roads, disposal of slash and refuse, and where necessary, revegetation. 60 Design, location, construction, rehabilitation, and maintenance of a project road system will be given prime consideration with the utili- zation of good landscape management practices. 4.11 Construction Activities. Proposed project-related construction activities include the building of the dams and their related facilities; the clearing of reservoir areas; the construction of roads, electrical distribution systems, and recreation facilities; and the building of facilities for workers. The construction of the Susitna project is estimated to take 10 years to complete, with an estimated 6 years of construction for the Watana dam and 5 years for Devil Canyon with a one- year overlap. The impact of these construction activities on the existing environ- ment would be significant. The activities themselves would cause varying degrees of physical pollution to the air, land, and water the project area and to some areas outside the development area. wildlife, vegetation, visual resources, soils, and other resource within Fish, values would be adversely impacted by construction activities within the project ar·ea. General construction activities would intrude on existing fish and wildlife habitat, cause soil erosion problems with related reduction of water quality, clear areas of vegetation, cause noise and dust problems, intrude on natural visual resource values, introduce air pollutants into the atmosphere by burning slash and debris, and cause other related environmental impacts. For instance, breaking the surface mat of vegetation and disruption of surface drainage can result in wind and water erosion, and melting of permafrost, resulting in subsidence and disruption of groundwater tables, which in turn results in erosion. Most of the damage to soils along the transmission line would occur during the construction phase. The construction schedule would be arranged so that work requiring use of an access road, such as delivery of materials, could be done in winter and spring, when the ground is least vulnerable to physical disturbances. This would eliminate the need for extensive filling and consequent use of borrow pits or quarries. To obtain materials from borrow sources and quarry sites for the construction of the dams, roads and other facilities would be necessary. Borrow areas would be located within the proposed reservoir pool areas where feasible. Any borrow or quarry sites necessary outside of the pool area would be rehabilitated. Areas will also be needed to dispose of some materials and debris. All construction activities would be control1ed to minimize or to prevent adverse environmental impacts. 4.12 Workers' Facilities. No communities within commuting distance to the p~6posed project area could absorb the number of workers required for the construction of the dams and related facilities. Some type of temporary construction camps with the necessary facilities would need to be provided during the construction periods, and permanent facilities would need to be built for maintenance and operational personnel after completion of the construction phase. 61 The construction and operations of the workers' camps would comply with State and Federal pollution control laws and standards, and all activities would be controlled to minimize adverse environmental impacts presented by the camps. Lands used for operating the temporary camp areas would be rehabilitated when the project work was completed. 4.13 Esthetics. The proposed project would be located in areas that pr~sently h~ve practically no permanent signs of man's presence. The lana between Portage Creek and the Denali Highway is a natural and scenic area which would probably qualify for wilderness classification under most definitions of the term. The construction of the proposed hydroelectric project would have a significant impact on the existing natural scenic resource values within the project area. Any dam construction on the upper Susitna would change a segment of what is now a natural, free-flowing river into a manmade impoundment. Within a 12-month period, Devil Canyon reservoir could fluctuate up to 5 feet while Watana reservoir would fluctuate up to 125 feet under normal operating conditions. The proposed Watana impoundment is located in a narrow, steep, isolated canyon where the seasonal fluctuation would not have a substantial scenic impact. The violent, whitewater section of the Susitna River through Devil Canyon would be substantially inundated by a dam at Devil Canyon. Roads and transmission lines would also impact the natural scenic resource values of the area. Since it is expected that a considerable number of tourists and State residents would visit the damsites, every effort would be given to minimizing the adverse visual impacts of construction activities. A great deal can be accomplished to maximize scenic resource values that will remain after construction. Good landscape management practices would add substantially to the recreational experience of the project visitor with facilities that are well planned and well maintained. The proposed transmission line corridor would cross no existing or presently proposed scenic, wild, or recreational rivers, nor would it cross any existing or presently proposed wilderness areas or wildlife refuges. In most segments, the transmission line would parallel exist- ing corridors or traverse no significantly large areas of intact wil- derness. However, in some segments where the transmission line would pioneer a corridor through a previously intact area, the quality of wilderness would suffer, especially where the transmission line is easily visible. Location and design of the transmission facilities will include maximum considerations to minimize the adverse esthetic impacts within the transmission corridor. 62 The transmission line would have m1n1mum impact on scenic quality from Point MacKenzie to Talkeetna since it could be concealed or in some areas be laid parallel and adjacent to existing line clearings. The line would have a moderate impact on scenic quality between Talkeetna and Gold Creek. The line could be hidden well from rail lines unless the corridors were consolidated. From Gold Creek to Devil Canyon, the line could either be largely concealed from the road or could be used as the ~Jad access route itself. Between Gold Creek and Cantwell, a visible li;;2 would have substantial impact, particularly if located west of the nighway and railroad. The line through this area could be somewhat concealed, with the exception of Broad Pass which has the least veg- etative cover. From Cantwell to ·Healy, the line would have a severe impact on scenic quality; not only is the canyon an area of high scenic quality, concealment of the line is difficult and the west bank of th~ Nenana is Park land. The impact would be moderate near Healy and in the Goldstream Hills and low along the lower Nenana River. Impact would be less if Golden Valley Electric Association right-of-way were joined. It would be more difficult to reduce the visual impact of the transmission line corridor from the air traveler, but the design of the transmission facilities would consider this important factor. The installation of significant lengths of high voltage underground electrical transmission cable is limited by present technology. From the standpoint of esthetics, underground transmission cables would definitely be preferred to an overhead transmission system. Should technology of underground electrical power transmission become sufficiently advanced prior to transmission line construction, it may be feasible to utilize underground cable in short reaches of the transmission system where the visual obtrusiveness of an overhead system is particularly objectionable. In seismically active areas the reliability of underground cables must be questioned where slicing of the cable can result from settling or slumping of the soil; oil-filled or compress-gas filled cable may rupture during soil movement; and it is more difficult to locate and correct damaged underground cable. Overhead transmission lines also have more inherent resiliency than underground cables. 4.14 Earthquakes. Several major and minor fault systems either border or cross the Upper Susitna River Basin, and the southcentral area of Alaska is in one of the world's most active seismic zones. One of the strongest earthquakes in recorded history struck southcentral Alaska in March of 1964; the magnitude of the quake was 8.4 on the Richter Scale. The quake was centered just north of the Prince William Sound area, approximately 120 miles from the proposed damsites (see Figure 2). Devil Canyon and Watana Dams will be designed to withstand a Maximum Credible Earthquake of 8.5 magnitude with an epicenter of 40 miles at a focal depth of 20 miles, which is the approximate distance 63 of both damsites to the Denali Fault system, and is the most likely source of a seismic event of this magnitude. The Susitna Fault, trun- cated by the Denali Fault, bisects the region in a northeast to south- west direction approximately 2.5 miles west of the Watana damsite. Due to the relatively short length of the Susitna fault, a maximum credible earthquake of 6.0 is considered reasonable. An earthquake of this magnitude along this fault will be considered in the design of Watana and Devil Canyon dams. 4.15 Sedimentation. Reservoir sediment inflow would vary at each reservoir. Under the proposed system, Devil Canyon reservoir would lose approximately 6.5 percent of its total storage area to sedimenta- tion during a 100-year period. Watana reservoir would have a 100-year sediment inflow that would equal about 3.6 percent of the reservoir's storage capacity. Both proposed reservoirs have a dead storage area that is not utilized for power production; therefore, much of the initial 100-year sedimentation for the reservoirs would be contained within this "dead storage space," which would not have any significant effect on reservoir operations. Much of the heavier sediment deposited in Watana reservoir would collect at the head of the 54-mile-long reservoir. Even though the project-life is computed on a 100-year period for economic reasons, with adequate maintenance, the useful life of the proposed project due to sedimentation is estimated to be in excess of 500 years. If at some future time a feasible program of sediment removal were developed, the useful life period could be extended. 4.16 Climatic Conditions. The severe climatic conditions in the Upper Susitna River Basin could have a substantial environmental impact on the design, construction, and operation of the proposed hydroelectric development. Permafrost conditions, extreme cold winter temperatures, a long period of cold weather, and ice conditions on the reservoir and river are some of the significant climatic conditions that would have to be considered. The Upper Susitna River Basin is underlain by discontinuous perma- frost, so some project areas will have to contend with permafrost and other areas will not. Extremely cold winter temperatures and long periods of cold weather will place substantial restrictions on many project construction activi- ties and increase the time needed to complete the construction of the project to a total of 10 years. Icing conditions on the reservoirs and the river may cause a wide range of adverse impacts both on project construction activities and on project operations. An ice-free stretch of warmer, open water below 64 Devil Canyon Dam could cause ice-fog conditions in that area during periods of extremely cold weather. Regulations of winter flows are not expected to have any significant effects on river ice conditions neces- sary for the continued use of the stream for winter travel downstream from Talkeetna. The effects of possible high winds and icing conditions on the transmission lines will be evaluated and design features will be incor- porated into the construction of these facilities to reduce or eliminat~ the adverse impacts posed by these conditions. 4.17 Air Pollution. Most of the existing electrical power in the Southcentral Railbelt area is ~roduced by gas, coal, and o:~-fired generating units which cause varying degrees of air pollution. Cook Inlet gas is a clean fuel that causes few serious air pollu- tion problems at the present time. The existing gas turbines have very low efficiencies and emit visible water vapor during the colder winter months. Also, nitrogen emissions could be of significant concern for any proposed larger gas-fired plants. Hydroelectric energy could replace the burning of fossil fuels for electric power generation in much of the Fairbanks area and could help to alleviate the severe winter ice fog and smoke problems in that area. Hydroelectric projects provide a very clean source of power with practically no direct air pollution-related problems. This type of electrical power generation could reduce a substantial number of future air pollution problems associated with the burning of gas, oil, and coal. It would be necessary to burn some of the residue slash material and debris during project construction and clearing operations, and fires would be controlled as necessary. 4.18 Social. 4. 18.1 Population. Substantial increases in population are expected within the Southcentral Railbelt area through the year 2000 ~nd, with the possible relocation of Alaska's State capital from Juneau to the Railbelt, an additional population impact can be expected in this area. The population of the area will increase with or without the development of hydroelectric projects proposed for the Susitna River; construction of the project is not expected to have any significant long range effect on overall population growth, but is rather designed to fulfill presently projected needs of a growing population as one alter- native means of producing power which will have to be provided in one way or another. Thus the total amount of power generated by the pro- posed Susitna hydroelectric project would generally be an alternative source, which would have as one of its major considerations a renewable 65 energy source, rather than being an additional power source. Projected power requirements based on mid-range estimates show that the proposed Susitna hydroelectric development program could supply a substantial portion of the Railbelt's projected electric power needs starting in about 1985. The proposed upper Susitna River hydro projects will not create large blocks of excess electric power for heavy energy-consuming industries. If larger amounts of electric energy are needed for a program of heavy industrial development, additional energy-producing sources will have to be constructed. In summary, the project is destgned to serve projected population needs--not to stimulate population growth as a consequence of industries which would be attracted by large b1ocks of excess electrical energy. A 10-year Devil Canyon-Watana hydroelectric development program would have an economic impact on the Southcentral Railbelt area that would be felt to a greater degree during the construction phase of project development. It is expected that this proposed project would have some stabilizing influence on the overall economy of the Railbelt area during the period of construction starting in about 1980, since construction would be initiated several years after the Alaskan oil pipeline has been built and about the time the proposed gas pipeline is scheduled for completion. The number of men required to construct this project is estimated to be about 1,100 men during the peak summer construction period. Various community, borough, state, and private facilities and agencies would be impacted to varying degrees by the workers involved in the construction of the proposed project. Workers 1 camps would be constructed in the vicinity of some of the various construction acti- vities, but additional impacts would be created by the families of the construction workers living in various nearby communities who would require additional facilities and services. It is also expected that due to adverse climatic conditions, much of the construction on the project facilities would be restricted to the warmer months of the year--probably April through October. The seasonal nature of the construction work would have an adverse impact on the local economy during the winter months. After the construction of the project, a small number of people would be required to operate and maintain the project and project- related facilities--these people would not create a significant social or economic impact on the railbelt area. 66 5.0 ADVERSE ENVIRONMENTAL EfFECTS WHICH CANNOT BE AVOIDED Approximately 50,550 acres of land would be flooded by the reser- voirs (7,550 acres at Devil Canyon, 43,000 acres at Watana) at normal pool elevation. This encompasses an almost continuous 84-mile reach of the upper Susitna River. Approximately 2 miles of natural river would remain unflooded between the two reservoirs. All woodlands and other vegetation within the reservoir pools would be permanently lost. Trans- ;~:ssion line clearing would be required essentially the full length of ~~~e 136-mile-long Susitna corridor for a total of about 3,700 acres. Only about half of the 198-mile-long Nenana corridor would require clearing, or approximately 2,400 acres. Water released from the reservoirs would be slightly turbid through- out the year, whereas under existing conditions the stream normally runs clear from late fall until early spring breakup. Studies to date indicate that the sediment in suspension would not be high in the releases at Devil Canyon dam, ranging probably from 15-35 ppm. On the other hand, heavy sediment loads now carried by the stream during the warmer months of spring through early fall would be significantly reduced. Downstream water quality problems related to temperature, dissolved oxygen, and nitrogen supersaturation could occur. These would be held to minimal, and possibly insignificant levels by spillway design and the incorporation of multiple-level water withdrawal structures. Approximately 9 miles of the existing 11-mile whitewater reach through Devil Canyon would be lost through inundation. The lower 2.5 miles of Tsusena Creek, which would be utilized as a spillway for excess river flows (this would occur only on the occasions of a period of excessive late summer flooding), will suffer adverse impacts to fish and on-shore vegetation during such periods. Some moose habitat within the canyon floor and adjacent slopes would be inundated by the reservoirs. Most of the present use is upstream from Tsusena Creek, thus the greatest impact to moose would result from the Watana reservoir. The amount of good habitat is limited, but its loss would be permanent. The Watana reservoir would lie between the spring calving grounds and portions of the summer range of the wide-ranging Nelchina caribou herd. Mortality to caribou and other animals attempting to cross the reservoirs could result from ice-shelving conditions which might occur into the month of May, on Watana reservoir, and other difficulties which might be encountered in swimming both reservoirs. The reservoirs could conceivably alter historical herd movement and distribution, although the animals do not exhibit any readily definable patterns, other than in the broadest of terms, at the present time. 67 Although other major wildlife species, such as bears, wolves. wolverines, and Dall sheep are not expected to be directly affected by the project to a significant extent, there will inevitably be some secondary ;mpacts resulting from disruption of existing predator-prey relationsh1ps. Overall, terrestrial wildlife habitat will be reduced. Small animals resident to inundated areas will be lost. Within the transmission line corridors, those species dependent upon climax or near-climax vegetation will be the most adversely affected. Examples are the red squirrel and northern flying squirrel. Resident fish populations above Devil Canyon Dam (there are no anadromous fish under existing conditions above this point) could be adversely affected to some extent by the change from a riverine to lake environment within the reservoir pools, and by the substantial winter drawdown conditions at Watana. The resident sport fishery fs not significant within the main river channel. Primary impacts would occur near the mouths of a few clearwater tributaries which provide some known grayling habitat. The intricate changes expected to occur downstream from Devil Canyon will result in both beneficial and adv~rse impacts to resident and anadromous fishes. Adverse impacts could result from possible reduction in nutrients and primary productivity, cutting, and eros1on of existing streambed configuration, increased turbidity during the winter months, and changes in the hydraulic and biological regime of salmon rearing and spawning sloughs. (As pointed out in Section 4, many of the anticipated changes downstream from Devil Canyon Dam could prove beneficial to both the ai1adromous and resident fishery. Determinations as to the offsetting effects of these changes are the subject of on-going studies.) Roads required for project construction, operation, and maintenance would impair visual qu~!ity and permit general public access into a largely pristine area. This would have the potential to increase pressure on existing game populations through hunting, trapping, and general disturbance and harrassment. This in turn would require inten- sified game management and law enforcement practices and preventative measures for the control of wildfire. Another harmful effect would be the impact of some of the roads themselves where delicate ecosystems are traversed. Some of the inevitable consequences of road construction are destruction of vegetation and wildlife habitat, reduced insulation of frozen soils, and settling from permafrost degradat1on, resulting in both erosion and alteration of the groundwater regime. Degradation of visual quality in general would be a major adverse effect of project construction. This would be attributable primarily to roads, dam construction, right-of-way clearing for the transmission line, and the obtrusiveness of the transmission line itself. Although care would be taken to minimize these impacts to the greatest possible extent, the overall natural setting and scenic quality of the damsites and transmission line corridor would be permanently impaired. 68 Although only one historical cabin site and no archaeological sites are presently known to exist within the proposed reservoir pools or transmission line corridor, ground reconnaissance of the affected areas which would take place prior to any construction activity could result in the discovery of such sites. Where determined necessary, sites would be salvaged at project cost. Disposal of slash and other woody debris resulting from reservoir and transmission line right-of-way clearing would have varying degrees and duration of impact. Material in the reservoir pools would most likely be disposed of by burning. This could increase the possibility of wildfire in woodlands adjacent to the clearing area, and would affect ambient air quality, and introduce ash and other material into the Susitna River during reservoir filling. These impacts, while temporarily harmful, would be of short duration. Other methods of disposal, such as stacking, burying, and chipping, have related adverse impacts, many of which are more severe or of longer duration than burning. Mineral resource potential within areas which would be inundated by the reservoirs is not fully known. Inundation would obviate the practi- cability of future mining or extraction of such resources. Future options concerning any other use of lands within the reser- voir pools would effectively be foreclosed. Impacts on land use related to the transmission lines are more difficult to assess. There will be unavoidable impacts on present and future land use with foreclosure of some alternative future uses. These could be both adverse and beneficial. For instance, the transmission line would probably predate agricultural land use along much of the corridor. This could be beneficial since a right-of-way would provide cleared land at little or no expense to the farmer. On the other hand, irrigation and tilling methods would have to adapt themselves to the spacing of towers and land occupied by the tower bases would be unusable. Also, the transmission corridor could attract future corridors. This could be beneficial in preventing separate rights-of-way impacts such as ·more clearing and additional road con- struction, but might further impair visual impacts associated with additional structures within the existing corridor. Both temporary and permanent facilities would have to be provided for project workers. Impacts from temporary fac.ilities, while adverse, would be temporary. Permanent facilities would be located and designed to minimize adverse impacts. Small communities near construction activities would be impacted by an influx of temporary construction workers and their families, with resultant increased demand upon com- munity services. The temporary nature of this influx of people would be difficult to cope with, and could well have community effects lasting well beyond the departure of this transient population. Another problem related to work generated by the project would be its seasonality. In many instances, construction activity would be limited to the warmer season, thus many of these workers would be seasonally employed. 69 Susitna River at Vee damsite. This demonstrates the typically in- cised character of the Upper Susitna from Devil Canyon to the Tyone River. Note that heavier vegetation is limited to slopes and creek valleys. - 6.0 ALTERNATIVES TO THE PROPOSED ACTION 6.01 General. Alaska has a wide variety of energy alternatives to produce electricity. Each of the major energy resources--oil, coal, natural gas, and hydroelectric potential could easily meet projected power requirements well beyond the year 2000. The nuclear energy alter- native is also available, and geothermal resources could be significant in some parts of the State. Present energy generation systems depend heavily on fuel oils and natural gas with smaller amounts of electrical energy coming from hydro powerplants and coal. It is assumed that hydroelectric power from the Upper Susitna River Basin could be operational by 1986 with the completion of the first dam and powerplant; thus economic and financial feasibility should be assessed in terms of realistic alternatives that could be made available in about the same time frame. Such alternatives include power from Cook Inlet oil and natural gas, coal resources in the Beluga and Nenana fields, oil from the Alyeska pipeline, natural gas from the North Slope, other hydro resources, nuclear power, and geothermal power. Public Law 93-577 passed by the Congress on 31 December 1974 has emphasized the conservation of nonrenewable resources and the utili- zation of renewable resources where possible. The construction of the proposed hydroelectric dams on the upper Susitna River is a feasible project that utilizes a renewable resource to generate electrical power while helping to conserve the use of nonrenewable resources such as oil and natural gas. Present Alaskan power systems have a significant environmental impact on urban environments, but a relatively small environmental impact outside the urban areas. Substantial increases in Southcentral Railbelt power requirements will involve the development of future electric power systems, larger facilities, and some alternatives that have very important environmental implications. Future power systems will also require approaches that include full consideration of environmental values and alternatives and must antici- pate that Alaska and the nation will attach increasing importance to environmental protection, energy conservation, and conservation of nonrenewable resources. Additional requirements must be anticipated for long-range advance planning and site selection, public participation, and full consideration of the environment in planning, design, construc- tion, and operation of power facilities. The significant environmental impacts of the various proposed alternatives would vary depending on the location, design, construction, and operation of the facilities for each of the alternatives. 71 Solutions considered in this investigation to meet electrical needs in the Southcentra1 Railbelt area were grouped in three major categories: alternative sources of power; alternative hydropower sources in the Railbelt area; and alternative hydropower plans in the Upper Susitna River Basin. The extent of study given to each potential so1ution was established by first screening each alternative for suitability, appli- cabi1ity, and economic merit in meeting needs£ Each alternative was tested for physical, politfca1, financial, inst1tutiona.l. economic, environmental, and social feasibili~. Continuous coordination was maintained w1th area St~te and Federal agencies which have related interests. Alternative measures considered for power purposes are discussed in the following paragraphs. 6.02 Alternative Sources of Power. 6.02.1 No Action. One of the alternatives to the deve1opment of facilities to generate additiona l electric power would be not to build any additional facilities. This approach would save the costs of planning, designing, constructing, and operating additional facilities. It would also avoid the adverse environmental impacts which would be generated by the construction of dams or of other electrical generating facilities; however, additional power sources are thought to be nec- essary and would not be provided by this alternative. If a hydroelectric system is not developed, alternative power sources would be required to satisfy projected future growth needs of the Railbelt area. Because of lead time involved in planning, financing, and construction of any currently viable alternative, oil and natural gas must continue to provide the bulk of the area•s power supplies until the 1980's. On an equivalent time-frame basis, coal is the most likely future electrical energy source for the Railbelt area, if hydropower is not developed. The impacts of the coal alternative are discus~ed in the following paragraph. 6.02.2 Coal. Coal is the most abundant fossil fuel in the nation. So~hcentral Alaska has two known extensive deposits (F1gure 11). The Beluga River area northwest of Cook Inlet contains coal reserves of at least 2.3 billion tons or, energy~wise, an equivalent of almost 6 bfllion barrels of oi1. Development of Beluga coals would enhance possibilities for coal-fired power generation at reasonable cost. Coal resources in the Nenana Fields in the Southcentral Railbelt south of Fairbanks near Healy, Alaska, are even more extensive than the Beluga River reserves, totaling at least 7 billion tons, or equivalent of about 18 billion barrels of oi1. In many cases, the major obstacle to increased coal usage is the problem of removing the high sulfur content in order to meet air pollu- tion standards when the coal is burned. Other problems include strip and subsurface mining, with associated environmental impacts, and trans- portat1on of the coal. The Beluga coals have low amounts of sulfur but also have high ash and water content. Considerable refining would be needed to enable its use in power generation. 72 MAP 1111 11 11111 Cool Areas 00@ Geothermal Areas ) FIGURE 11 73 COAL AND GEOTHERMAL AREAS 0 50 IOO Miles A.P.A.-JULY 1975 The coal alternative could be available on about the same time frame as other major new power sources such as hydropower and possibly nuclear power. It appears that baseload thenma1 plants could be utilized 1n the Railbelt area by 1990. Coal and hydro potential for the South- central Railbelt may be the least expensive alternatives for the new power supplies 1n the 198o•s and beyond~ but coal would be more expensive than hydro. Coal-fired plants should also be given consfderation in remote areas which could be supplied by water transportation. In the absence of major hydro development or the disco~ery of addi- tional gas reserves, it is assumed that the Railbelt power system would shift from oil and gas-fired power units to coal as the ~rinc1pa1 energy source starting about 1985. It is further assumed that the coal plants wouid either be conventional steam or steam and gas turbine units located near the Beluga and Nenana coal fields. In view of the quantities of coal involved and present-day mining practice, it is presumed that strip mining wou1d be employed to obtain the coal. Without specific knowledge of the mining site, it is not possible to project how much acreage would be affected; however, it is assumed to be in the hundreds, possibly thousands, of acres. Much addi- tional land would be required for stockpiling of overburden and mine wastes until such time as a portion of the pit became worked out and could be used for disposal. The immediate impacts would be the destruc- tion of the overlying vegetation and thus loss of habitat for the resi- dent animals and birds. Additional land would be altered for roads or other routes for working the mine(s) and transporting the coal to generation facilities. Air quality could be expected to suffer from large inputs of dust. Water in contact with coal and mine wastes genera1ly become acidic and toxic to vegetation and animal life. It is difficult to prevent such water from entering either the underground water table or the natural drainage streams in the area and thus impact- ing water quality to some dfstance from the actual mine. Any scenic values in the mine area would be lost at least unt11 the mine was exhausted and restoration completed. Environmental qualit1es would also be affected at the power gen- erating facilities. Considerable land would be occupied by the struc- tures and more by the operating coal stockpiles and access routes. The associated vegetation, habitat~ and scenic values would be lost. Even with emissions controlled to 1egal levels, there would be an input of particulate matter and chemical compounds into the atmosphere. Large amounts of water would be needed for cooling ponds requiring either land for installation of the ponds and the removal of the water from natural sources or the use of a natural water body (lake or river) for the cooling element. In the latter case, the effects of 11 thermal pollution .. on the receiving water would be substantial, especially as regards stimulation of vegetal growth and adverse impacts on fish, if present. Disposal sites for the waste combustion products would be needed and could require alteration of large quantities of land and its natural values. 14 Social impacts would be mixed in effect. The operation of the ri·i1epowerplant would provide long~terrn employment for many more people than for hydroelectric facility of the same size. Because· of this, the visible economic effects related to disposable income and the multiplier effect of additional cash circulating in the economic community would be much more evident than with a hydropower system. However a coal-thermal facili·cy would forego the recreational and possible flood control benef ·, ts provided by a hydropower project. The adverse effects of coal mining w111 occur eventually regardless of t;·ie presence of hydropower development as this ·resource wi 11 be uti 1 i zed for other purpos·e~:-- Using coal as a power source involves extensive adverse impacts to the env~ronment, both in the magnitude of the effects and in the size of the areus affected. Development of hydropower sources would a1low for other, more beneficial uses of our coal resources. Ther~fore~ coal is determined to be a less desirable source of electrical energy production than hydroelectric development. Coal was the economic standard by which each of the hydro alternatives was tested. 6.02.3 Oil and Natural Gas. In the period following the 1967 Depart- ment of Interior report, Alaska Natural Resources and the Rampart Project, rnost studies by Federal agencies and area utility companies focused on the Cook Inlet supplies of natural gas and, more recently, on pipeline fuels for Railbelt power. Location of potential oil and gas reserves in the Southcentral area are shown in Figure i2. Cook Inlet gas is a clean fuel, and few serious air pollution prob- lems exist for gas-fired units. Gas turbine exhaust is noisy, but modern noise suppression equipment can reduce this impact. Energy conservation aspects of gas-fired units may become significant because existing gas turbines have low efficiencies and emit visible water vapor during the colder winter months. Also, nitrogen emissions could be of significant concern for any proposed larger gas-fired plants. Existing plans for the Cook Inlet area involve additional large, advanced-cycle gas turbine units at Beluga and additional turbines and waste-heat-recovery units in Anchorage. The Fairbanks area utility companies plan additional gas turbine units using pipeline fuels. Plans for the near future include a number of measures to increase efficiency, including the advanced cycle and waste-heat-recovery units mentioned previously. However, because of lead time involved in planning, financing, and constructing alternatives, oil and natural gas must provide the bulk of the area's power supplies, at least until the mid- 1980's. Cook Inlet natural gas has provided low cost power benefits for the surrounding area in the recent past and, with substantial reserves under contract, should handle area power requirements for several more years. 75 r MAP High Potential for Oil and Gas ~ Moderate Potential []]] Low Potential FIGURE 12 76 OIL AND GAS POTENTIAL = a · so rOO Miles A.P.A .-JULY 1975 J Also, additional reserves may be found in future exploration to meet future demands. It appears reasonable to assume that there will be sub- stantial increases in costs for future oil and gas supplies as U.S. do- mestic reserves decline, worldwide demand increases, and foreign oil prices remain high. Higher costs for fuels in the future, especially for oil and gas, should be considered in all future planning. and should anticipate ~erious national efforts to develop alternative energy sources that 1 ~mft the use of oil and gas for power generation. To a very large extent these factors invalidate many previous power studies which we.re made on the assumption that·~heap, long range oil and gas fuel sources would be available. Alaska power systems now depend on o11 and gas for about 60 percent of total energy production, and by 1980 a~out 90 percent of the State 1 S electric energy will come from these premium fuels. Estimated 1972 fu~l use for Alaska 1 s power systems included 1.4 million barrels of oil and 16 bfllion cubic feet of natural gas. If recent trends continue, the use would increase to about 26 million barrels of oil and 134 billion cubic feet of natural gas annually by the year 2000 under mid-range level estimates. Since low cost natural gas became available for power production in the Cook Inlet area, the Upper Susitna River Basin hydro power develop- ment has not looked attractive to the area utilities. Now the long range outlook for availability and cost of gas 1s changing; this, coupled with high power costs in the Fairbanks area, possibilities that pipeline fuels will also be quite expensive, and broader new interest in conservation of nonrenewable resources has created renewed interest in Susitna hydro potential. A concentrated effort to develop alternatives for power generation such as coal, hydro, and eventually nuclear power could result in sub- stantial reduction in demand for oil and natural gas. The lead tfmes and large investments required to develop alternatives reinforce the point that oil and natural gas must supply near future requir2ments. For most smaller power systems, basically no economically feasible alternatives to diesel generation exist, at least for the present. The availability of fuels in Alaska will undoubtedly improve as reserves and facilities are developed, which should lead to reduced dependence on costly imported diesel fuels and other petroleum products for power generation and other uses within the State. However, there is no longer any reason to anticipate that Alaskan oil and gas will provide an abundant, cheap energy source for the long term. These fuels will be 77 expensive, if only because of pressures to export the fuels to areas where higher prices can be obtained. The present use of oil and natural gas as a source of electrical energy is viable for Alaska; however, a high~r and better future use of these resources can and, in all prob- ability will, be made. In view of the national efforts to develop energy sources that limit the use of oil and gas for power generation, this alternative was rejected. 6.02.4 Nuclear Power. The use of. nuclear power as a commercial elec- trical energy source for the nation is expected to increase considerably by the year 1985. Adverse environmental impacts are associated with surface and subsurface mining of uranium, changes in land use, disposal of waste heat, risk of accidents, and safe storage of highly radioactive wastes. In spite of these factors, more than 50 percent of the elec- trical power of the nation is expected to be generated by nuclear power by the year 2000. By the end of this century, breeder plants, which produce additional fuel while they produce power, will gradually take over a larger share of the production of electricity. Possibly at some time in the next century, nuclear fission plants and proposed nuclear breeder plants will be replaced by nuclear fusion reactors and by central generating stations running on solar power. Nuclear power should be considered a likely long-range source of baseload power for the Railbelt area and is generally considered a distant option because of size of power markets, cost and environmental factors, and the availability of more favorable coal and hydro alter- natives. The foreseeable future for nuclear power generation in Alaska should become materially more favorable only if there is either a break- through in costs and technology or significant new development in small- sized plants. Because of the size of power markets, costs, and environmental factors, nuclear power development in Alaska is not considered to be an attractive alternative to cheaper, readily available power sources during this century. 6.02.5 Geothermal. Geothermal resources may eventually provide significant power generation in Alaska; the Southcentral Railbelt area has substantial geothermal potential (see Figure 11). This source of energy is not considered a reasonable short term alternative to other more proven types of power generation, as increased utilization of geothermal resources depends upon additional technological development and economics. Geothermal power generation is also considered to be a future supplement to other power sources rather than an alternative method of producing electricity. 78 ) Some of the possible problems associated with the generation of electric power from geothermal resources include siting of facilities, brine disposal, and corrosion. This renewable resource could also provide usable side products such as heat, water, and chemicals. This is not considered a realistic alternative to other energy sources within the foreseeable future. 6.02.6 Solar. The radiant heat of the sun is another renewable source of energy that has considerable potential for generating power in this country and the world. Practical use of solar energy to produce electric power on a large scale i~ primarily a question of developing the technology to generate and to store large amounts of electricity produced by the sun's radiation. A major disadvantage wherever such development is pursued is the large land area required for reflector installation to provide usable amounts of power and thus the large environmental disturbances inherent in such a change in land use. A second concern especially in Alaska is that during the winter, when demand for electrical power is greatest, the sun is either absent from or at best a brief visitor to local skies. Solar power generation is not considered a feasible planning alternative for Alaskan power systems in the near future. 6.02.7 Wind and Tidal. Research and development proposals for wind generators should improve future capabilities of wind-powered electrical generating systems. With increased diesel fuel costs, wind-generated electrical power is a possible alternative power source for remote areas with small loads. The extreme costs and environmental effects involved in most tidal flow hydroelectric proposals are major factors opposing this alternative method of generating electrical power. Neither alter- native is considered feasibl~ for provision of large amounts of energy at this time. 6.02.8 Wood. In parts of southeastern Alaska, wood is used to fire steam-generating power plants. Alaska does have vast forest reserves that could be used; however, these same trees have far higher and better alternative uses in wood, paper, and other industries. In addition thP esthetic, ecological, and environmental impacts of the large harve~~s necessary to allow production of large amounts of energy appear to be massive. Wood as an energy source is not considered a major alternative. 6.02.9 Intertie. Alaska could purchase surplus power from sources in Canada or the "Lower 48;'' however, the cost of transmission facilities and the uncertainty of available dependable power would be major factors opposing such a scheme. Therefore, an intertie does not appear to be feasible at this time. 79 6.02.10 Solid Waste. The burning of solid waste products to produce electrical power has potential in some areas of the country, but there does not appear to be an adequate supply of solid waste products in the railbelt area to produce substantial amounts of energy. Associated air quality and odor problems would also appear to be severe. This alter- native is not considered feasible to meet the energy needs in the railbelt area, but could supplement the total power needs for the area. 6.02. ll Hydropower. The reconnaissance report on potential development in the State of Alaska made in 1948 by the U.S. Bureau of Reclamation, included hundreds of potential power development sites located through- out the five study regions of the State: Southeast, Southcentral, Yukon-Kuskokwim, Seward Peninsula, and Arctic. In 1969 and again in 1974 the 1948 report was updated, and in May 1974 the latest revision was published as the 1974 Alaska Power Survey. The two largest market areas for power are located in the Southcentral Railbelt, particularly the Anchorage-Cook Inlet area, and the Fairbanks-Tanana Valley area. The large amount of the available renewable water resource which could produce electric power has excellent potential to answer the energy needs of the Southcentral Railbelt area. 6.03 Alternative Hydrologic Basins in the Southcentral Railbelt Area 6.03. l Rampart Canyon. Considerable study has been made of the possibility of developing hydroelectric power in the Upper Yukon Basin with a damsite located in Rampart Canyon on the Yukon River approximately 140 miles northwest of Fairbanks, Alaska. The project has one of the greatest hydroelectric potentials in North America. The proposal would create a reservoir with a water surface area of approximately 10,600 square miles, with a maximum length of 280 miles and a maximum width of about 80 miles. The project would provide firm annual energy of 34.2 billion kilowatt-hours (the energy equivalent of over 74 million barrels of oil per year). However, the impacts on fish and wildlife resources in the Yukon Flats would be significant. Im~lementation of such a project would also be extremely controversial. Rampart is engineeringly feasible and the proposed project would provide enough excess energy to encourage further industrial development in Alaska, but it would introduce a number of secondary impacts not associated with the recommended alternative. Excess energy could also be transmitted to the 11 Lower 48 11 through an intertie system. However, this would be a major action not directly applicable to energy needs of the Railbelt Area. Justification would have to be based on a nation- wide plan which included Rampart as a recommended alternative to the development of other energy sources. Within the time-frame criteria established for fulfillment of projected growth needs in the Railbelt Area, this is not considered a viable alternative. 80 ) SOUTHCENTRAL RAILBEL T KEY HYDROELECTRIC AND TRAN SM ISS ION ALTERNATIVES FIGURE 13 81 ' SC ALE ,.......,------------~ ------------------··a 0 !>0 IOO MIIes The tremendous financial investments, the substantial environmental impacts.·the limited opportunities for marketing the enormous amounts of power, and the availability of more favorable, less costly alternatives preclude recommending construction of the Rampart project at this time. Rampart Dam could be developed if future national needs recommend the project•s construction. 6.03.2 WoOd Canyon. Another possible location for significant hydroelectrfc power development is Wood Canyon on the Copper River. The damsite would be located about 85 miles above the mouth of the Copper River fn the Chugach Mountains of southcentral Alaska. A "high dam'' would develop firm annual energy of 21.9 billion kilowatt-hours. A "low dam" wou 1 d provf de J 0. 3 bi 11 ion kilowatt-hours of firm a nnua 1 energy. The construction of a dam at Wood Canyon would force relocation of two communities and would create serious environmental problems affect i ng both fish and wildlife values, .especially to the large salmon runs on the Copper River. Unless the problem posed to migrating salmon could be solved satisfactorily, the project would have an extremely adverse effect on the major commercial fishing industry in a wide area of the Gulf of Alaska. This alternative is 'not considered feasible at this time. 6.03.3 Chakachamna Lake. The possibility of developing hydroelectric power from Chakachamna Lake was investigated. The lake is located on the Chakachamna River which empt;es into the west side of Cook Inlet approximately 65 miles west of Anchorage. The facility would generate 1.6 billion kilowatt-hours of firm annual energy. The project would require the erection of transmission facilities over difficult terrain to tie into a Southcentral Railbelt transmission system and the con- struction of a high-cost 11-mile tunnel for power generation. The adverse environmental impact would be substantially less than for many proposed Alaskan hydroelectric projects. However. the low energy output and the high costs render this alternative infeasible at this time. 6.03.4 6radley Lake. The site fo~ this authorized hydroelectric project is at Brad1ey Lake on the Kenai Peninsula at the head of Kachemak Bay near Homer, Alaska. The proposal would generate 0.4 billion killowatt- hours of firm annual energy and could serve as a southern peaking in- stallation for a Southcentral Railbelt power system. Adverse environ- mental impacts of this ~reposed project would be relatively minor com- pared to the other hydroelectric development alternatives which were considered. If an economically feasible plan can be developed for Bradley Lake, the project could be integrated with future development of the Susitna R1ver basin. By itself, this project would fulfill only a small portion of the projected electrical needs of the Railbelt area. 82 Upstream view of Devil Canyon damsite. ) 83 6.03.5 Susitna River. Surveys for potential hydropower development in the Susitna River basin were reported by the Corps of Engineers in 1950 and by the U.S. Bureau of Reclamation in 1948, 1952, 1961, and 1974. The 1952 USBR report indicated 12 potential hydropower sites in the basin; of these, the five damsites studied in the upper Susitna basin showed the highest potential. These studies showed the environ- mental impact from projects in the Upper Susitna River Basin would not be as severe as those from other basins~ and the firm energy potential r.ould contribute substantially to satisfying the needs of the South- central Railbelt area. 6.04 Alternative Hydroelectric Plans in the Upper Susitna River Basin: 6.04. l General: Eight plans for hydroelectric development of the Susitna River basin including the proposed actions were studied as follows: 6.04.2 Devil Canyon. The possibility of a single da~ development of the Upper Susitna basin located at the Devil Canyon damsite was investi- gated. The proposed thin-arch dam with a structural ·height of about 635 feet would have a water surface area of about 7,550 acres at the normal maximum pool elevation of 1,450 feet, m.s. 1. The project would produce 0.9 billion kilowatt-hours of firm annual energy from an installed capacity of 220 megawatts. Because of the very limited storage capacity, the project has a low firm energy capability and is not considered economically viable. 6.04.3 Watana. This single dam development of the upper Susitna basin located at the Watana site would be an earthfill dam with structural height of about 810 feet. The reservoir would have a normal maximum pool elevation of 2,200 feet, would have a surface area of approximately 43,000 acres, and would extend about 54 river miles upstream to a point between the Oshetna and Tyone Rivers. The annual firm electrical pro- duction of Watana would be 3.1 billion kilowatt-hours from an installed capacity of 792 megawatts. Although feasible, the project develops less than half of the basin potential and is not viable in itself since more productive feasible plans are available. 6.04.4 Devil Canyon High Dam. In September 1974, Henry J. Kaiser Company prepared a report proposing an alternative hydroelectric develop- ment project on the upper Susitna River. The report states that pre- liminary investigations indicated that an 810-foot-high, concrete-faced rockfill dam located about five miles upstream from the proposed Devil Canyon site would provide 3.7 billion kilowatts of average annual energy, or 2.6 billion kilowatt-hours of firm annual energy (figures converted to standard Corps of Engineers evaluation parameters). This dam would inuhdate about 58 miles of the Susitna River with a reservoir of approximately 24,000 surface acres at a full pool elevation of 1,750 feet. 84 This project would be located in much of the same area of the Susitna River canyon occupied by the proposed Devil Canyon-Watana project and would have similar environmental impacts with some exceptions. Whereas the Devil Canyon reservoir in the two-dam proposal would remain nearly full all year, the Kaiser reservoir would fluctuate substantially. Kaiser 1 s proposed Devil Canyon High Dam, located about 25 miles downstream from the Watana site, would have proportionately fewer miles of permanent roads and transmission lines than the Devil Canyon-Watana project, therefore less environmental impact on resources affected by +hese facilities. The recreation opportunities would be fewer for the one-dam proposal. The substantial fluctuation of the reservoir would reduce some recre- ation potential and reduce resident fish populations while increasing the adverse visual impact associated with reservoir drawdown. The plan was found to lack economic feasibility. 6.04.5 Devil Canyon-Denali. This alternative two-dam system would include the thin arch concrete dam at Devil Canyon and a 260-foot-high earthfill dam in the vicinity of Denali. The Denali Dam would provide storage only and would have no powerhouse. This system would generate 2.5 billion kilowatt-hours of firm annual energy from an installed capacity of 575 megawatts at Devil Canyon Dam. The surface acres flooded would total about. 62,000 acres (Devil Canyon, 7,550; Denali 54,000). The plan would entail significant environmental impacts on waterfowl nesting areas, moose range, and archaeological/historical values in the Denali reservoir area. Economic feasibility is lacking. 6.04.6 Three-dam System. A three-dam Devil Canyon-Watana-Denali hydroelectric development on the upper Susitna River could be built as an extension of the two-dam Devil Canyon-Watana project if the Denali storage site proved feasible. Such a dam system would provide a total of 6.8 billion kilowatt-hours of firm annual energy. If a three-dam Devil Canyon-Watana-Oenali project were constructed, it would include Devil Canyon and Watana dams previously des:ribed, and a 260-foot storage dam at Denali. This three-dam system would inundate approximately 104,550 acres and would take 13 to 17 years to construct. With a three-dam system, the 100-year storage capacity in Watana reser- voir would be reduced by less than 3 percent due to sedimentation. Environmentally, this plan would result in the adverse impacts associated with the Devil Canyon-Denali two-dam system, plus the added impact of inundating some additional moose range and bisecting a sea- ~onal caribou migration route. Though the latter impact should not seriously impede summer caribou migration, it could result in some caribou mortality if animals attempted to cross the reservoir during adverse ice conditions, including the possibility of ice-shelving during periods of reservoir drawdown. 85 This alternative has significantly greater total adverse environ- mental impacts than the recommended plan (Devil Canyon and Watana development) and is economically feasible. 6.04.7 Four-dam System. In May 1974, the Alaska Power Administration updated a March 1961 report of the ~ureau of Reclamation which proposed development of the hydroelectric resources of the Upper Susitna River Basin. The report proposed an initial plan to build the Devil Canyon Dam and powerplant and an upstream storage dam and reservoir at Denali. Subsequent development of a four-dam system would include dams ~~ ooth the Watana and Vee sites. The four-dam system would generate a :otal of 6.2 billion kilowatts of firm annual electrical energy. The Watand Ja;~ under this plan would be about 300 feet lower than in the selected Devil Canyon-Watana proposal, and the Vee Dam would be about 55 feet lower than in the original Bureau of Reclamation 4-dam proposal. Initial development of the four-dam system, Devil Canyon-Watana- Vee-Denali, would include only the construction of the hydroelectric d~~ at Devil Canyon and the storage dam at Denali. This combination of two dams would produce 2.5 billion kilowatt-hours of firm annual energy. This initial two-dam stystem would also be compatible with the three-dam Devil Canyon-Watana-Denali, alternative proposal. The four reservoirs considered in this development would inundate approximately 85,000 acres of land and river in the upper Susitna basin, compared with about 50,550 acres flooded in the selected two-dam proposal. The two reservoirs proposed in the lower section of the upper Susitna River would have substantially fewer known adverse environmental impacts than the two upper area reservoirs at the Vee and Denali. Generally the further upstream a reservoir is located in the four-dam system, the greater the overall adverse environmental impact would be on fish, wildlife, and esthetic resources. In a four-dam plan, Watana reservoir would cover a surface area of about 14,000 acres behind a 515-foot-high dam with a pool elevation of 1,905 feet. The reservoir would extend over 40 miles upstream from the damsite and would be contained in the narrow canyon for most of its length. Under either Watana alternative, the reservoir would flood areas used by migrating caribou and would flood some moose winter range in the river bottom. It would also cover existing resident fish habitat at the mouths of some of the tributaries in this section of the river and possible would create additional stream habitat at higher elevations. The 455-foot-high Vee Dam would be built only under the four-dam plan in conjunction with the lower height Watana Dam. Vee reservoir would inundate about 32 miles of glacial river and would have a pool 87 elevation of 2,300 feet with a surface area of approximately 9,400 acres. The reservoir would flood a substantial amount of moose habitat on the main Susitna and on the lower reaches of the Oshetna and Tyone Rivers. Car i bou migration routes along the south bank of the Susitna River would a l so be affected as would some waterfowl habitat of minor significance. Present resident fish habitat, especially grayling, would be flooded at the mouths of many of the clearwater tributaries in the area covered by the Vee reservoir. Any road to the Vee damsite would open up larger areas of wi ld lands thdt are prime wildlife habitat and escapement areas (inaccessible to man) for caribou, bear, and moose, and would have a significant impact on these and other fish and wildlife resources within these areas. Denal i Dam, with a structural height of 260 feet, would form a 54,000-acre storage reservoir with a pool elevation of 2,535 feet. Large areas of wildlife habitat, especially for moose, caribou, and waterfowl, would be inundated in an area between 2 and 6 miles wide and approxi- mately 34 miles long. Many clearwater streams entering the Susitna River in this area have varying populations of arctic grayling; how the fluctuating reservoir would affect this fishery is generally unknown at this time. Substantial areas of lands would be exposed during the seasonal drawdowns of this storage reservoir; from an esthetic stand- point, this would be a substantial adverse environmental impact, espe- cially when viewed from the well-traveled Denali Highway during the earlier summer months when the reservoir would be low. The relocation of 19 miles of the Denali Highway necessary with the r.onstruction of a dam at the Denali site would provide additional access to this area with increasing pressures on the fish and wildlife resources in Coal Creek, Clearwater Creek, lower Maclaren River, Butte Creek, and the eastern slopes of the Watana Hills. There would be substantially less developed recreational potential at the Vee and Denali sites than at Devil Canyon because of travel distances involved and reservoir draw- down, especially at the Denali damsite. It is expected that construction of the Vee project would take 5 to 6 years, while the Denali dam and reservoir would take between 3 and 5 years to construct. The construction period of the four-dam system would be between 18 and 23 years, if the dams were constructed in sequence. The magnitude of environmental impacts resulting from a four- dam system in the Upper Susitna River Basin clearly makes this a less desirable alternative than the one-, two-, or three-dam plans. 88 Nenana-3 ) DELTA CORRIDOR __.-~-------MATANUSKA ~ CORRIDOR •Palmer ALTERNATIVE TRANSMISSION CORRIDORS I I Scale in miles 50 75 100 125 A.PA .-March 1975 14 6.04.8 Kaiser Four-Dam System. An additional study of a four-ddm syst~1 was made by the Corps of Engineers utilizing the Kaiser Devil Canyon High Dam as the main component in an upper Susitna basin system. This a lternative included both the Vee and Denali Dams and a low reregu- 1ating dam {Olson) just below the confluence of Portage Creek. This f our~dam system could provide an estimated 5.6 billion kilowatt-hours of f irm annual energy. The environmental impa cts of thi s f our-dam sys tem are a combination of the impacts of the Ka iser Devil Canyon Hig h Dam , the Vee dnd Denali dams1 tes, and a ·l ow reregulat i ng dam downstream from Oev11 Canyon ju st be low Portage Creek. The system would inundate about 88 ,250 a cres. One of the major additional impacts wou l d include anadromous and resi dent fi shery impacts caused by the reregulat i ng dam just below Portage Creek. The plan is not economically feasible. 6.05 A1ternative Power Trans mission Corridors. Any development of hydroe l ectric power in the upper Susitna basin would require development of electric transmission facilities to the Railbel t load centers. In determining the preferred system, the Alaska Power Admi nistra ti on studied all feasible ·corridors joining the upper Susitna complex to Anchorage and Fairbanks. The most feasib1e corridor was selected on the basis ol cost, reliability, and potential environmental impact; the remaining corridors represent alternatives of vary i ng degrees of feasibility. Four groups of alternatives were considered : fi rst, those that lead from Devil Canyon-Watana to Anchorage via the Susitna watershed; second, those that lead to Fairbanks via the Nenana and Tanana drainage; third, those that lead to Fairbanks via the Delta and Tanana drainages; and fourth, those that lead to Anchorage via the Copper and Matanuska drainages. ~ithin each of the four basic corridor systems, a number of alteinative corridor routes were considered. Figure 14 displays these var·1ous routes. Susitna 1 and Nenana 1 are the selected routes. 6.05. 1 Alternatives to Susitna 1. As shown in Figure 14, a common corridor is shared by all Susitna alternative alignments from Point MacKenzie to Talkeetna. From Talkeetna to the reservoir sites, four alternative corridor segments were considered. Impacts attributable to Susitna 1, the selected corridor, are discussed in Sections 4.0 and 5.0 ~f the EIS. The other three corridors are discussed as follows: Susitna 2 This corridor is 140 miles long, 4 miles longer than Susitna 1. It differs from Susitna 1 in that from Talkeetna it crosses the Susitna River, leads north into Denali State Park, then northwest over Troublesome Creek and on to Gold Creek where it rejoins Susitna 1. 90 This alternative segment is 42 miles long. Alpine and moist tundra are crossed in addition to those ecosystems crossed by Susitna 1; however these are limited in extent. In comparison to Susitna 1, this alternative also requires clearing 100 more acres. It traverses 26 miles of Denali State Park, and conflicts with trail systems in the Park. Susitna 3. This corridor is 129 miles long, 7 miles shorter than Susitna 1. It is basically a more direct corridor from Talkeetna to Devil Canyon, bypassing the Alaska railroad between Talkeetna and Gold Creek. The length of the alternative segment is 45 miles. It crosses over a plateau of almost 4,000 feet elevation as compared to maximum elevations of about 2,000 feet for Susitna 1 and 2. It also crosses about 25 miles of moist tundra and 20 miles of upland spruce-hardwood. In comparison to Susitna there would be 1,610 acres less clearing of vegetation required, there would be possible impacts on caribou winter range, sizeable amounts of land would be opened up to vehicular access, primitive values would be adversely affected, and the transmission line would be highly visible. Susitna 4. This corridor is 147 miles long, 11 miles longer than Susitna 1. It leads from Talkeetna, up the Talkeetna River and Prairie Creek to Stephen Lake, then west to Devil Canyon damsite. This segment is 63 miles, versus 52 miles for the comparable Susitna 1 segment. This segment traverses upland spruce-hardwoods for most of its length, and crosses a few miles of moist tundra. Permafrost is present at the higher elevations, which rise to aboJt 2,200 feet. Compared to Susitna 1, this alternative would result in permafrost and soil erosion problems, 75 acres less vegetative clearing, penetration of a moose concentration area, impact upon recreational use near Stephen Lake by creating vehicular access, and be highly visible in the upland area which is relatively intensively used by recreationists. 6.05.2 Alternatives to Nenana 1. There are five alternative corridors connecting the project area with Fairbanks by way of the Nenana River. Nenana 1 parallels the highway and railroad and comprises the northern half of the selected corridor system. Nenana 1 is described in Section 2.0 and impacts are discussed in Sections 4.0 and 5.0 of the EIS. The other four Nenana corridor alternatives are discussed and compared to Nenana 1 as follows: Nenana 2. This corridor is 220 miles long, 22 miles longer than Nenana 1. It departs Nenana l at Cantwell, leads east to Wells Creek, north to Dean Creek and the Wood River, and follows the Wood River north to Ester. This segment is 158 miles. The corridor rises to 4,000 feet on the Dean Creek-Wood River pass. A wide variety of 91 ecosystems is traversed, from ijlpine tundra to bog and muskeg. Perma- frost can be assumed to be prevalent. For 25 to 30 miles the corridor runs adjacent to or through the Blair Lake Air Force Range. Habitats of moose, caribou, and Dall sheep are traversed. The following conditions or impacts are of greater magnitude along this corridor than along Nenana 1: Peaty, permafrost soils are more prevalent and would cause greater problems related to access road construction and erosion prevention or control; about 90 more acres of clearing would be required; and dis- turbed areas 1n moist and alpine tundra would be very slow to recuperate. Dall sheep and caribou~ in addition to moose, would be disturbed by construction activity, and most of the corridor would provide vehicular access to areas now access1ble only by foot. Viewer contact would be relatively low because of the isolation from existing transportation routes. Nenana 3. This corridor is 231 miles long. 33 miles longer than Nenana 1. It is ider.tica1 to Nenana 1 from Devil C5nyon to Cantwe11 where it then loops east and north through the Alaska Range, rejoining Nenana 1 at Healy. This segment is 72 miles long while the comparable segment of Nenana 1 is 39 miles. Terrain along the alternative segment varies from rolling hills and valleys to high passes and sharp ridges, the highest of which is about 3,900 feet. The alternative segment traverses moist and alpine tundra, upland spruce-hardwood, muskeg, and bog; however, rocky thin soils and bedrock predominate. Erosion would generally be low. Valley floors have continuous permafrost. As com- pared to Nenana 1, nearly 200 acres less c1earing would be required, and increased access would cause a potential increase in hunting pressure on Dall sheep, caribou and moose. Construction of the transm1ssion 1ine within the alternative segment between Cantwell and Healy would be technically difficult and expensive, and it would be difficult to maintain. However, since it would not be visible from existing trans- portation routes, it would have low viewer impact. Nenana 4. This corridor is 223 miles long, 25 miles longer than Nenana T. From Devil Canyon it leads east and northt tying in at Healy to Nenana 1. The length of this separate segment is 126 miles; the comparable segment of Nenana 1 is 101 miles. From Devil Canyon, the corridor leads east to Watana Oamsite and then north up Deadman and Brushkana Creek to Wells Creek where it continues over a 3,900-foot pass to Louis Creek and Yanert Fork. then over another pass (2,900 feet) to Moody Creek which it follows to Healy. Ecosystems traversed are moist and alpine tundra, muskeg and bog, and upland spruce-hardwood. Moose, caribou, and Dall sheep inhabit this corridor. Between Watana and Wells Creek, soils are very vulnerable to permafrost degradation and frost heaving. Erosion would be a serious problem related to powerline and road construction and would result in degradation of water quality in the clearwater streams encountered. From Wells Creek to Healy, 92 soils are rocky and thin. Erosion would be relatively low in this reach. Permafrost is continuous in the valley floors. As compared to Nenana 1, this corridor would require about 380 acres less clearing. Little modification of habitat would be required on this differing segment. Vehicular access would be provided which would potentially increase human pressures on Dall sheep and caribou, and to a lesser degree on moose. Most of this segment would have low viewer contact because of its isolation from existing transportation systems. Nenana 5. This corridor is 212 miles long, 14 m·:-~es lor;ge:--th.:tn Nenana 1. It is totally separate from Nenana 1, being a paral iel corridor lying to the east of the proposed corridor. It is identical to Susitna 4 from Devil Canyon to Yanert Fork where it becomes separate a~ it leads up Dean Creek and crosses over a 4,000-foot pass into the Woe. River drainage. It then leads north along the Wood River to Ester. Permafrost is prevalent. Alpine and moist tundra, upland spruce-lowland spruce-hardwood, and bog and muskeg ecosystems are traversed by the segment which differs from Nenana 4. Significant numbers of Dall sheep and moose are encountered as well as important winter range for caribou. Construction problems along the Wood River and Tanana River valleys would result from the lack of well drained soils and the presence of ontinuous shallow permafrost. Soil erosion and permafrost degradation would pose serious siltation threats to clear-water streams. This corridor would require clearing of about 100 acres less than Nenana 1; Dall sheep and caribou habitat would be adversely affected. Increased access to relatively inaccessible areas would be provided. Viewer contacts would be relatively few as a result of the remoteness of the corridor. 6.05.3 Alternatives to Susitna and Nenana Corridors. In addition to the Susitna and Nenana alternative corridors previously described, consideration was given to an alternative routing system for transmitting electricity to the two major load centers, Anchorage and Fairbanks (see Figure 14). Two other corridors were considered as access to Anchorage via the Matanuska Valley. These are referred to as Matanuska Corridors and 2. Essentially only one other corridor is deemed feasible from the hydropower sites at Devil Canyon and Watana to Fairbanks. This is called the Delta Corridor. Matanuska 1. This corridor differs radically from Susitna l in that it loops to the east and south, and approaches Point MacKenzie from the east. Its total length is 250 miles, 122 miles longer than Susitna 1. A considerable portion, 125 miles, parallels the Glenn Highway or other secondary roads or planned transmission corridors. From Devil Canyon the corridor leads east to Watana Damsite thence southeasterly over a sparsely forested, poorly drained plateau to the head of the Little Nelchina River. Here, the terrain is fairly open and gentle 93 with predom i na nt ly rolling hills. The corr i do r. on passing just to the west of Slide Mountain, turns west to parallel the Glenn Highway. It crosses over Tahneta Pass into the Matanuska drainage, which it follows to the flat land at the mouth of the Matanuska Valley . It continues southwest a l ong the northern shore of Cook In l et , traversing considerable amounts of f orest and muskeg as it approaches Point Ma cKenzie. Perma- frost in th i s corr i dor is continuous from the upper end of Wat ana r eservoir to Tdhneta Pass, discontinuous in the Upper Matanuska Va lley, and sporadic 1n the lower va l ley. Ecosystems traversed inc lude spruce- ha rdwoods and moist tundra between the Watana Oamsi te and the Littl e Nelchina River, and upland spruce-hardwood i n the l ower valley . Between Devil Cany on and the Litt le Nel c hi na River ~ the corri dor general ly runs between car fbou ca l ving a nd wintering~ranges . Also, some wintering ra nge is traversed a long the l ittl e Ne lchina River and Glenn Hi ghway to Ta hneta Pass. Some Dall sheep habitat ex i sts in Tahneta Pass and Moose concentrations a re encountered in the Point Ma cKenzie area. Between Watana reservoir and Slide Mountain, the potential for permafrost degrada t ion is very high. Frost heaving in the poorly drained fine- gra ined soils would require heavy ma in tenance of both l i ne and access road . Erosion would cont ribute sediment to clearwater s treams in the area. Eros i on potential is relatively low al ong the remai nder of the corridor. This route would require approx imatel y 750 acres more c l earing than Su sitna--mostly in the lower Matanuska Val l ey. Moose would gen- erally benefit from clearing . whereas caribou range would suffer loss. Lake Louise and some other high recreational use areas would be impacted upon. Increased access would be provided to area s north of the Glenn Highway. The scenic quality along the highway would generally be lowered, since concealment of the line would be a problem a l ong most of its route. Matanuska 2. Alternative corridor Matanuska 2 is 385 miles long, 120 miles longer than Matanuska 1 and 249 mi l es l onger than Susitna 1. From Watana Damsite it loops much further to the east tha n Matanuskd 1, rejoi ni ng i t at Sli de Mountain . This s egment of Matanuska 1 is 217 mi les 1ong ~ versus 97 miles for the comparable segmen t of Matanuska 2. From Watana Damsite the corridor crosses the Susitna Ri ver and leads northeast toward Butte Creek and the Denali Highway, which it parallels to Paxson. Here it turns south, paralleling the Richardson Highway and the Aleyska Pipeline to Glennallen. From Glenallen it parallels the Gl enn Hi ghway up the vall ey of the Tazlina River to Slide Mountai n and the ju nc t ion with Matanuska 1. Host of the corridor traverses flat terra i n. Hi ghest point on the corridor is a plateau of about 4,000 feet elevation in the Tangle Lakes -Rock Creek area between the Maclaren River and Paxson. This area is poorly drained and covered with post- gl aci a l fea t ures such a s eskers and termina l moraines, and many smal l la kes. Permafrost is prevalent. The predominant ecosystem is moist tundra. From Paxson to Sl i de Mountain the corri dor lies within the Copper River lowlands, a basin underlain by near ly continuous permafrost. 94 Generally poorly drained, this basin is dominated by upland and lowland spruce-hardwood and muskeg ecosystems. Except for the area around Glenallen, the entire corridor runs through the winter range of the Nelchina caribou herd. Moose concentrations are found along the Copper, Gu.lkana, and Tazlina Rivers. Most of the corridor traverses medium density waterfowl habitat. Within the segment from Watana Damsite to Slide Mountain the potential for permafrost degradation is very high. Frost heaving would entail high maintenance of this line and road. Subsequent erosion could cause significant impact on clearwater streams in the area. Clearing would be required for about 2,200 acres more than the Susitna 1 corridor. Moose would generally benefit from clearing while some caribou range would suffer damage and loss. Existing recreational uses in the Lake Louise area would not be significantly impacted by this corridor. ·The archaeological richness of the Tangle Lakes area makes it likely that presently unknown sites would be discovered, and possibly disturbed, as a result of the project. Impact on scenic quality along the Denali Highway to Paxson would be high as a result of large numbers of viewer-contacts and little opportunity for line concealment. Delta Corridor. This corridor is 280 miles long, 82 miles longer than Nenana 1. From Devil Canyon, it follows essentially the same path as Matanuska 2 to Paxson. Here it turns north, following the Richardson Highway -Alyeska Pipeline corridor over Isabel Pass, a wide, gentle divide at 3,000 feet of elevation. It continues along the pipeline corridor through the Alaska Range, following the Delta River. North of Delta River canyon the terrain consists of rolling hills until the Tanana Valley is reached. The terrain here is flat to Fairbanks. Shallow rocky soils dominate the Delta River Canyon stretch, followed north by mixed poorly and well drained soils. This segment traverses upland spruce-hardwood northeast of the Delta and Tanana Rivers. Along the Tanana floodplain, bottomland spruce-poplar forest predominate. Some lowland spruce-hardwood occurs immediately south of Fairbanks. Bison range would be traversed between the Delta River Canyon and Big Delta. Sporadic moose concentrations occur along the Tanana River. Dall sheep range occurs in the Delta River Canyon. Ice-rich permafrost is found throughout the corridor, and the soil is vulnerable to perma- frost degradation, frost heaving, rutting and scarring. Generally well drained upland soils between Shaw Creek and Fairbanks are subject to gulleying, unstable slopes, and wind erosion. Clearwater streams are subject to sediment pollution from construction and maintenance activity. Thixotrophic soils in Isabel Pass would expose transmission towers to higher than normal seismic risk. Clearing required in this corridor would be about 430 acres more than in Nenana 1. The Nelchina caribou herd south of the Alaska range would be adversely impacted by this alternative. Additional access to hunters would be provided. The areas of highest scenic value along the Denali and Richardson highways coincide with the least opportunity for transmission line concealment. 95 Denali Highway bridge across upper Susitna River. This area would have been inundated bv a dam at the Denali site. 7.0 RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF MAN'S ENVIRONMENT AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY The project as presently conceived could have a useful life span in excess of 500 years based on the "dead storage space 11 (space below the lowest water intakes for the powerhouses) within the reservoirs for sediment accumulation. Individual components would be replaced as necessary, but the overall system would remain essentially the same. Should the system last this long, or for any number of reasons be made inoperative at an earlier date (an example would be development of more desirable alternative sources of electrical power), many of the resou1 :es described above in Sections 4 and 5 would have been, for all practical purposes, committed to permanent foreclosure of options for alternativn future uses. In this sense, the long-term productivity of the directly ~ffected environment will have been sacrificed for a shorter-term altern~tive use, since impacts attributable to the reservoirs will be of much longer duration than the useful life of the project for hydroelectric power production. By the same token, the project would contribute to a savings in nonrenewable energy sources with an energy equivalent of about 15 million barrels of oil, or approximately 112 billion cubic feet of gas per year. Although this savings is a principal factor in the consideration of a hydroelectric alternative, over the long haul, hydroelectric energy must be viewed as an interim measure for conserving the nation's nonrenewable energy sources until some more practical, permanent method of producing electricity is achieved which will not overburden the nation's or world's finite resources. Some features of the project wi 11 have 1 ess 1 eng thy fmpact on the environment than the dams and reservoirs. Many of the impacts will be encountered during--and for a relatively brief time following--the construction phase. Of the longer-term impacts, some would terminate or lessen immediately or shortly after retirement of a given project component. For instance, if the transmission line were to be removed, many of its impacts would soon disappear. Maintenance activity, noise and electromagnetic interference, and visual impacts associated with the lines and towers would be immediately eliminated. Roads could be removed, top soils replaced, and eventually natural revegetation proc- esses would largely obscure the previous existence of the transmission system. Other impacts would, to varying degrees, be 11 imprinted" into the environment. Wildlife patterns may have been affected by continual hunting or habitat modification. Vegetative patterns, altered by continual maintenance or introduction of nonnative plants, may continue for a long time. Land use patterns influenced by the project would linger after it ceased to function. No extremely short-term benefits from the project are the basis for justifying the long-term, if not permanent, commitment of the productivity of the affected areas. The trade-off is essentially a long-t~rm benefit which can be achieved only at the expense of an even more extended commitment of the affected resources. 97 MAP ~VERY HIGH POTENTIAr----- ~111 11111 1 1 HIGH POTENTIAL IIII I '1 ,I II ,.,,,,, l 1l i1 I 1 I 1 1 I ' I I 'I' II I I I !IIJ I 1 1\ I ·j FIGURE 15 98 POTENTIAL MINERAL DEVELOPMENT AREAS ' SCALE. ~-....;..;........ . ==-=a 0 SO 100 Mi les A .P.A .-JULY 1975 ) 8.0 IRREVERSIBLE OR IRRETRIEVABLE COMMITMENTS OF RESOURCES IN THE PROPOSED ACTION. 8.01 Changes in Land Use. The development of hydroelectric dams on the upper Susitna River would present an irreversible change of land use from an existing wilderness type land-use situation, along a free- flowing river with limited access, to a land-use situation where public access would be provided to a series of manmade lakes created by the construction of hydroelectric dams within the river corridor and to recreation sites within the project area. Proposed transmission lines and permanent roads would also be located in areas of existing wild lands or where transportation corri- dors presently exist. 8.02 Destruction of Archaeological or Historic Sites. At t~e present time, no archaeological sites are known to exist within tr.e areas of the proposed impoundments, damsites, power line routes, or roaG locations. Should such sites be located during on-the-ground reconnaissance during the detailed study phase, measures will be taken to avoid disturbance where possible. Should they fall within the reservoir pools, salvage will be undertaken. In the latter event, however, the sites would be permanently lost to alternative future uses. One old cabin site, probably related to early m1n1ng exploration, is located at the mouth of Kosina Creek within the Watana reservoir impoundment area. This site is designated as a historical site by the Alaska Division of Parks. 8.03 Change in River Use. If the proposed project is developed, the 84-mile portion of the river above the dams would be converted from a free-flowing river to a series of manmade lakes totaling about 50,000 surface acres. Such development would preclude any consideration for Wild and Scenic River classification. The 11 Whitewater 11 section of the river through Devil Canyon would be substantially inundated, as would sections of the river bottom now used for wildlife habitat. Downstream the initial 50-mile section of the river would be changed from an uncontrolled natural river, with very high summer flows and heavy glacial sedimentation and low winter flows with practically no sedimentation, to a river with regulated flows and a small amount of suspended glacial sediment. The 80-mile section of the river between Talkeetna and Cook Inlet would be affected to a lesser degree because of major tributaries. 99 8.04 Construction Activities. 8.04. 1 Fuel Requirements. Significant amounts of fuel oils and gasoline for use in transportation and construction activities related to project construction would be irretrievably committed. 8.04.2 Man ower. Manpower resources during the construction and operation p ases of the project would be irretrievably committed. The majority of these man-hours would be committed over a 10-year period, depending on the final development program. 8.04.3 Material. All the material us~d in project-related construction would constitute an irretrievable commitment of resources, as tnis material would not be available for other uses. Some amounts of material might be salvaged if the facilities were removed at some later date. 8.04.4 Land. Any land committed to project development such as reser- voir impoundment areas, damsites, roads, etc., would be unavailable for other than project-related uses until such time as the facilities were no longer needed. 100 9.0 COORDINATION WITH OTHER AGENCIES 9.01 General. A public participation program was maintained throughout the investigation. Coordination with various agencies and groups was made to provide and to obtain pertinent information, and the following methods were used: public meetings, workshop meetings, and informal meetings. 9.02 Public Participation Program. A workshop meeting was held in Anchorage on 30 April 1974 to discuss the study with interested e!1viron- mental groups. Representatives of the consultant firm of Jones and Jones, which was contracted by the District to conduct an inventory and evaluation of environmental, esthetic and recreational resources of the study area, presented and discussed results of their studies. A similar workshop meeting was held with Federal and State agency representatives on 29 October 1974, and another was held with Native Corporations on 12 March 1975. Initial p~blic meetings were held on 6 May 1974 in Fairbanks and 8 May 1974 in Anchorage to notify the public that the study had been initiated, and to furnish available information and receive comments. Several environmental groups stated that they would reserve judgement of the project until the Draft Environmental Impact Statement was available for review. Concerns expressed by these groups (the Alaska Center for the Environment and the Sierra Club) included impacts upon the future quality of life in Alaska which would be caused by hydroelectric development. They also questioned the Alaska Power Administration's projection of power needs, the examination of alternatives, and the shipping of Alaska's fossil fuels elsewhere. They stressed the need for coordination with the Alaska Land Use Planning Con~ission, and suggested public hearings on the Final Environmental Impact Statement. Interim public meetings were held in Anchorage on 27 May 1975 and Fairbanks on 29 May 1975. Environmental groups represented included the Alaska Conservation Society, the Sierra Club, and the Alaska Center for the Environment. Comments of these groups included the opinion that the project would spur more growth, but that nuclear energy was believed not to be an acceptable energy source at this time. They further recommended the alternative of burning solid wastes to produce power. They were troubled by the location of transmission lines, and stated that we may have a greater need for hydroelectric power in 50-75 years. They questioned hydroelectric power as being a renewable resource. Other concerns included land status of the affected areas, siltation, costs of power, and the need for considering alternative sources of power. 101 Late stage public meetings were held in Anchorage on 7 October 1975 and Fairbanks on 8 October 1975 to present and discuss the selected plan. A number of environmental groups were represented at one or both of these meetings. They included: the Isaac Walton League, the Mountain- eering Club of Alaska, the Alaska Conservation Society, Knik Kanoers and Kayakers. and Fairbanks Environmental Center. Comments included the need for Corps funding for fish and wildlife studies and data processing of environmenta l information. Expressed concerns included the i nundation of a scen i c ~ white-water river, location of the project &rea too c l ose to a proposed Tal keetna State Park, too much human use in the area y 'i,npacts on moose habitat and downstream salmon runs, differences refl ected in the 1960 and 1975 cost es tim ates, the low interest rate used in computing project benefits, who woul d operate the dams and sell the power, reservoir s il tation, turbi di ty, fluctuations in stream flo ws , impacts on permafrost, the possibi l ity of earthquakes, the format ion of frazil ice, the geology of the area, benefits claimed for flood cont rol, the location of transmission corridors and construction of transmiss i on l~o"1es, land status, impacts upon population growth, recreational dev el opment, the production of secondary energy, and others. Most of these groups voiced either strong opposition to the project or reserved judgement pending further studies and specific project recommendations. --Many organizations, groups, and individuals expressed support of the selected plan. An informal poll of people attending the late stage public meetings indicated support for the project by about 5 persons for each person who opposed it. l 02 SELECTED BIBLIOGRAPHY Dames & Moore Consulting Engineers. Subsurface Geophysical Exploration for Proposed Watana Damsite. Anchorage: U.S. Army Corps of Engineers, Alaska District. 1975 Federal Energy Administration. PrQject Independence. A main re~ort, summary, seven task force reports and the Draft Environmental Impact Statement. 1974 Federal Power Commission. Advisory Committee reports, 1974 Alaska Power Survey (with 1975 update): Report of ;he Executive ~dviso~1 Committee. December 1974 Economic Analysis and LoaifPro_jections. May 1974 Resources and Electric-power Generation. May 1974 Coordinated SySteri1s_ DevelOpment and Interconnection. December 1974 Environmental Considerations and Consumer Affairs. May 1974 Geen, Glen H. ~'Ecological Consequences of the Proposed Moran Dam on the Fraser River," Journal of the Fisheries Research Board of Canada, Vol. 32, No.1 {January1975). -- Jones and Jones. Upper Susitna River, Alaska -An Inventory and Evaluation of the Environmental Aesthetic and Recreational Resources. u.-s.-Army Corps of Engineers, Alaska District: 1975 Kellerhals, Rolf, and Don Gill. 11 0bserved and Potential Downstream Effect of Large Storage Projects in Northern Canada," Commission Internationale Des Grandes Barrages, Onzieme Congres des Grandes Barrages. Madrid, 1973 Little, A.D. Underground Power Transmission Report to the Electric Research Council. 16 October 1971 Ray, Dixie Lee, Chairman, U.S. Atomic Energy Commission. A speech given at 25th Annual AIBS meeting at Arizona State University, Tempe, Arizona. 17 June 1975 State of Alaska, Department of Fish and Game. Alaska's Wildlife and Habitat. January 1973 Alaska 1973 Catch and Production Commercial Fishery Statistics. ----~S~t-a~t~istical Leaflet No. 26. -------Various letters, review comments and reports. 103 --....---~ An Assessment Study of the Anadromous Fish Popu 1 ati ons in. the UpQ.e! Susitna Watershed Between Devil Canyon and the Chulitna River, by Bruce M. Barrett. 1974 ------Spring 1974 Moose Parturition Counts of the Proposed Devi 1 Canyon Dam Area, by Donald Caikins. 1974 State of Alaska, Division of Parks. Heritage Resources Alon9 the Upper Susitna ~iver. August 1975 State of Alaska, Joint Federal-State Land .. Us.e Planning Commission for Alaska and the University of Alaska. Coordinated by Lidia L. Selkregg. Alaska Regional Profiles -Southcentral Region. 1974 U.S. Department of the Army, Corps of Engineers. Analyzing the Environmental Impacts of Water Projects. Prepared by Institute of Water Resources. March 1973 U.S. Department of the Army, Corps of Engineers, North Pacific Division. !l Compendium on th_P. ?ucs_ess _of. Parage of Sma 11 f_i_s_h_ Through Turbines. May 1967 (OUt of pr~nt U.S. Department of the Army, Corps of Engineers, Alaska District. & Report on the· Rampart Canyon Project, Yukon Basin, A1aska. 1971 -~.....:::---,--Offshore Oil and Ga2_ Development..:!.!! Cook Inlet. Alaska - Environmental Impact Statement. September-r974 -~....,....--Southcentra_l_ Ra i 1 belt Area, A 1 aska, Interim Feasi bi 1 i ty Report -Hydroelectric Power and Related Purposes for the Ueper Susitna River Basin, with technical appendices. December 1975 U.S. Department of Commerce, National Marine Fisheries Service. A Hydrological Reconnaissance of the Susitna River Below Devi·, Canyon Dam. October 1974 U.S. Department of the Interior. Alaska Natural Resources and the -·---· Rampart Project. June 1967 Alaska Power Administration. ~~vil Canyon Status ~e2ort. ----.M"'"'a-y---o;-<1 97 4 ---~~~Bureau of Land Management. Multimodal Transportation and Utility Corridor Systems in Alaska - A Preliminary Conceptual Analysls. October 1974 l 04 ~---Bureau of Reclamation. Potential Development of Water Resources ~the Susitna River Basin of Alaska. August 1952 ----~~-Bureau of Reclamation. Feasibility Report, Devil Canyon Project, Alaska. March 1961 ----~---Bureau of Reclamation. Engineering Geology of the Vee Canyon Damsite. November 1962 ----~A Fish and Wildlife Service. Survey of the Peregrin~ falcon and Other Raptors ~ the Proposed Susitna River Reservoir Impoundment Areas. Fish and Wildlife Service, Bureau of Sport Fisheries and Wildlife. Threatened Wildlife of the United States Resource Publication No. 114. Washington: -r973 ----~--~Geological Survey. Water Resources Data for Alaska, Water- Supply Papers. Washington: 1950 through 1974--- --~--~National Park Service National Register of Historic Places Washington: 1975 Various Fish and Wildlife Service letters, review comments and -------reports. 105 ECONOMIC DATA EXTRACTED FROM U.S. ARMY CORPS OF ENGINEERS INTERIM FEASIBILITY REPORT COMPLETE DOCUMENT IS AVAILABLE AT U.S. ARMY ENGINEER DISTRICT, ANCHORAGE, ALASKA Estimated First Cost (Includes Non-Federal Recreation) Estimated Value of Public Domain (land transferred without Cost) Average Annldl Cost Average Annual Benefits Power (Includes Transmission Line Intertie) Recreation Flood Control Area Redevelopment Net Annual Benefits Benefit to Cost Ratio l 06 $1,520,000,000 $ ll ,800,000 $ 104,020,000 $ 137,876,000 $ 128,153,000 $ 300,000 $ 50,000 $ 9,373,000 $ 33,856,000 1.3 to 1 ) Lower Susitna River Valley. This area is charac- terized by extensive muskegs, intermingled with bottomland spruce-poplar forests. Permafrost is absent or discontinuous in this area, although the soils are generally poorly drained. ) Susitna River Valley. Lakes are prevalent and assoc- iate<.! with muskegs, which succeed them in formation. Muskegs are succeeded in tum by forests dependent upon well-drained soils. The three stages of success- ion are shown here. Town of Talkeetna. This town is at the confluence of the Talkeetna, Susitna, and 01ulitna Rivers. The Alaska Railroad can be seen cross- ing the Talkeetna River near the right edge of the picture. ----~ -------~------------------------ Near Honolulu on the Anchorage-Fairbanks Highway. Biomes shown on low brush muskeg in foregrm.md and upland spruce-han:n.vood in back- ground. BJ.ack spruce in foreground are associated \vith poorly drain- ed soils and/or shallow permafrost tables. Alaska Range from And1orage-Fairbanks Highway near Broad Pass, late spring. Vegetation biome is lowland spruce-hardvood. Soils here are basically glacial deposits. I Looking south along Nenana River to Upper Nenana Canyon. The And10rage-Fairbanks Highway parallels the left bank. Motmt l\1cKinley National Park and the Alaska Railroad are on the right bank of the river. ) Very restricted canyon along Nenana River north of HcKinley Park. Alaska Railroad is off left- hand edge of photo. Land left of river is within Mount [.JcKinley National Park. ..------ ) 111e Tanana River flood plain. This area is extreme- ly flat and poorly drained. 1nrce types of biome are represented in this picture: muskeg, lowland spruce-hardvood, and bottomland spruce-poplar. The dark forests are mainly black spruce. The sinuous lighter forest is white spruce, aspen and birch. This forest type prefers well-drained soils, and so is found on old levees of existing and extinct channels. FEDERAL COMMENTS AND RESPONSES U.S. Department of Agriculture Soil Conservation Service U.S. Department of Interior Alaska Power Administration Fish and Wildlife Service Geological Survey Bureau of Indian Affairs Bureau of Land Management National Park Service -Anchorage National Park Service -Seattle Bureau of Outdoor Recreation U.S. Department of Commerce National Weather Service National Ocean Survey National Marine Fisheries Service U.S. Department of Housing and Urban Development U.S. Department of Transportation Feqeral Aviation Administration Federal Highway Administration United States Coast Guard Department of the Army Cold Regions Research and Engineering Laboratory U.S. Environmental Protection Agency Federal Power Commission 108 Comments 1-4 14-21 25-35 36-40 41 42-78 79-90 91-94 95-97 5 6 7-12 13 22-24 22-24 98-100 101 102-103 104-108 109 UNITED STATES DEPARTMENT OF AGRICULTURE SOIL CONSERVATION SERVICE 204 East 5th Avenue, Room 217, Anchorage, Alaska 99501 Charles A. Debelius Colonel, Corps of Engineers District Engineer Alaska District, Corps of Engineers P. 0. Box 7002 Anchorage, Alaska 99510 Dear Colon~l Debelius: December 2, 1975 We have reviewed the draft en.vironmenta1 impact statement, "Hydroelectric Power Development, Upper Susitna River Basin, Southcentra1 Railbelt Area, Alaska." We offer the following comments for your consideration: This represents all comments of the Soil Conservation Service. GENERAL COMMENTS Tl1e statement represents considerable effort i·n the assembly of available data and in effective presentation of pertinent facts throughout the re- port. The statement appears to appraise impacts adequately for a feas- ability ~tage study. We have previously reviewed and commented on the environmental assessment of the transmission line proposal that is an integral part of this proposal. SPECIFIC COMMENTS The. statement contains no information on soils involved with the proposal, except for some brief statements in the captions at the end of the volume. The caption of the second photo, implying that well drained soils su~ceed muskegs, is erroneous. The absence of soils information at the dam site or in the transmission corridors is a serious deficiency of the statement. I 2 practices being considered. It is suggested that following construction, :3 In the discussion of aesthetics, mention is given to lundscape management ,- consideration be given to mitigating unpleasant aesthetic results by planned. use (landscaping) of adaptive plant species. The "Vegetative Guide for . Alaska", attached, may be of value to you. This discussion of "adverse environmental eff~cts which cannot be avoided" I 1 notes the need for temporary and permanent f~cilities for project workers. I We.suggest that a soil survey, and the interpretations therein should be useful in locating facilities on suitable soi1s. ~ t09 4 Charles A. Debelius 12-2-7 5 We appreciate the opportunity to comment . Sincerely, / c:· /ijyxc JJf (.C.;:;/ Weymeth E. Long ( State Conservationist enclosure cc! Council on Environmental Quality (5 copies) Office of Coordinator of Environmental Quality Activities R. M. Davis, Administrator, SCS, Washington, D. C. K. l Williams, Director, WTSC, SCS, Portland, Oregon District Conservationist, SCS, Fairbanks, Alaska 11.0 - 2 I RESPONSE TO COMMENTS BY U.S. DEPARTMENT OF AGRICULTURE SOIL CONSERVATION SERVICE jL Comment noted. ~ Comment noted. Detailed soils information at the damsite and in the transmission corridors is not presently available. Such studies would be the subject of future investigations required for facilities siting, construction techniques, etc. The SCS letter was received too late to change the referenced photo cap- tion, since that portion of the EIS had already gone through final printing. However, the statement that "muskegs are succeeded in turn by forests dependent upon well-drained soi1S 11 is acknowl- edged as an error. Obviously, muskeg areas do not rapidly, if ever, evolve into well-drained soils. They may, however, eventually support water-tolerant tree species . . -, ~ Concur. Unavoidable construction scars related to project features, such as roads and borrow areas, will be rehabilitated, including dressing with topsoil and appropriate landscaping and vegetative planting. The Soil Conservation Service will be consulted with regard to these efforts. ~Concur. Temporary and permanent facilities will be designed and located with a view to aesthetics, erodibility df soils, and other relevant factors. 111 November 25, 1975 Colonel A. Debelius UNITED STATES DEPARTMENT OF COMMERCE The Assistant Secretary for Science and Technology Wash1ngton. D.C. 20230 District Engineer -Alaska District Corps of Engineers U. S. Department of the Army p. 0. 7002 Anchorage, Alaska 99510 Dear Colonel Debelius: This is in reference to your draft environmental impact statement entitled 11 Hydroelectric Power Development, Upper Susitna River Basin, Southcentral Railbelt Area, Alaskan. In order to expedite transmittal of the enclosed comments from the National Oceanic and Atmospheric Administration, we are sending them to you as they were received in this offic:e. Thank you for g1v~ng us an opportunity to provide these commen~s, which we hope will be of assistance to you. We would appreciate receiving eight (8) copies of the final statement. Sincerely, rtl~~~ · Deputy Assistant Secretary for Environmental Affairs Enclosures: Memo from NOAA -National Marine Fisheries Service Memo from NOAA National Ocean Survey Memo from NOAA -National Weather Service 112 ' ' -~ . Date To From Sub1ect: U.S. D'EPAHTM.ENT Of COMMERCE f\Jational Oceanic and Atmosphe.-ic Administration N~T.,~~..!.\t \\(".\1~~t:R ~~:F~\'~C'~ !11.\Jt!:'"' Spr1ng, r~:c. ::·\.1!JhJ 1· Reply to Attn. ol: WZxZ/A'f Dr. William Aron Director, Office of Ecology and Environmental Conservation (EE) lJi1:· , 1 ~luHlD BY Dr •. George P. CressmaL1 l<. ~-h,c.i..:..ii.t.N. Directo~, National Weather Service (W) DEIS 7509.61 -Upper Susitna River Basin, Alaska The plan proposes the construction of dams and power plants on the upper SUSITNA River. The operation of these facilit:les will impact upon the public river and flood forecast warning service provided by the National Weather Service in this basino These services emanate from NWS offices at Anchorage and Fairbanks as described in the enclosures. This should be made a part of the EIS. 11.3 0 . ·rr.:? :::!tional tJccanic ~nd A~'""'s~:J~:""ic 1\-J:nin·is~r~tion (t:c,\..;) N~tionalt·:~a.ther s~~·:'ic~ jli"'O'IiC~S flco:! fore~t1St~~~ s~r·:ic~ fer f:i;lj~J;"' r·iver: b;lSl:l~. This sy:::te.!'l i:-:•nh~; pr~dicU'J;;:> ._,; ~n~ic-ipJtL.J st-!-;J.-?::. l!t <1 p;:rticu"!~r ~~~~ c;-: !;:l~:~s in th~ t~~!sin. Ti~~:,~ fc .... ~~-:·.!Sts.~~~·c·b:~:=·:!~~ n:l o:.:;~r·Jt:!1 -~, ... ,.!c!p:t.~t"!o."t "'r:,-i ,..t~ ... !"'\.-..... )'-"'J-'-, ........ ., ... ~:r.'-... ,:""11-t ........ .;_.;_ ••• a.i , ... ~L~.·,..,r ct·-.. •:·,..~0"'"' ·r· .r.· .& ~ ·-->-'~',-:..-' •---. ~~· :..-.:'" .,:.. •• !..::. -•-l: ............ ,.~ ... ---•.:.:.~.-.... J.,;..,._, ·•>-.r;e :·ta::•.J.· fcrec.:::sl: 1s trc:!n.Si.iitt~d to C"ity of"i'icials, n~·.~Spi!p-?rs, <!.1d radio and tele- . visi.on stC!tio:ls "ir: th~ bJsir.. These media clissemir:~te the infc:--,il~tton to residents of the-.flood pldn in th~ form. of c:. flocd \·iarning. This timely . fcr-e·.·J~rr.ir.g permits protectiv~ measures to be·underti!ken by ir.dustria1 plants pubiic uti1itie::., wunicipaLofficials,. and individuals ~-lith prc~2~ty in the » lo·r'l1ar.ds .. Services available e.re of the "folimo~ir.g typ~s~ ~ '• 1. !' Fl?.sh Flood: . The responsibl-e Heath:!:"' se·r'-:icc forecast Offic~ st.!p~l·ic-:; \-/e<!th~l"' forccJsts t•,.,ic~ dclily fer th~ Stt\te. In additicn to t~~ routine forcc~~t~, special for~cast~ of severe stotms and gener.:!l flash flood \-latches for sr.~c1ll strc.:!r.lS ·are issued as required. HSR-57 Heather Radar· installations have capahility for ir. . .-r.~iate detection and evaluation of rainfall int~nsity,. l·acaticn,. ar:d sto=m mo•J&11?nt ... Jnforw.at_ion is pro~ptly r-~layed by teletypa· cir-cuits· 2nd telephone to ne\vs Jnedia ar.:i ce"-mur.ity officials 2t!d la• . .; enforcement .• agencies. TJi~ .Heath~r Se..-vice Office··-issues Flash Flood 1·1arni r:gs 'as · required for ~~11 stre~~s in its ~rea of responsibility_ -. · .... ' 2 •. Najar Flct::Jds: . River stage forecasts 'ure based on radar coverage> reports frcm ri~e:r and r9~nfall reporting _stations ?nd telem;;t:-y in .or near l the basw. :--The RlVer Fol'Ct;q~t ,Centers ~re staffed 'rnth . professic~al hydrologists responsible for the preparation of river. · .'forecasts b~sed ·on \•later equivalent of sr.~·:'l co•t~'f',. rainfull-'runo·ff . relations, s treamflO'.'I rcu t ing, and a \·1or:nng knm-11 edge of anticipated w~athzr conditions. The lead time between distributicn of the fore- .. casts a;1d the flood crest may be sho·rt; ho~·:e'le·r,. lead tir.te namally ranges from 12 hour-s far rc1infol1 and up ·to several· \·:e_el<s for sno'lllitelt. Specific crest forecasts are issued as required. River District · Offices are r~sponsible for the interpr~tatian and distribution of .·-.flood forecasts and ·the C?Peration, ... of _the hydrologic reporting sub- _ station net\·lork in its area of responsibility. · -. - ••1.• • • • 3. Hydrocl i;-;-:atic Data: t·!ost of the data. from the netw~rk is published- These records provide the basis for_ forecasts as \·Jell ilS for the pl~r.:1!~3 ~nd des{gn of protective \·:arks and their o'peration during flco~s-· P.h·er and flood forecasting is fur.d~m~ntal i"n the c!esign. and esse:-:tial ·in the o.perat1an of a l~vee or reservoir system. .. . 114 ' ;· RESPONSE TO COMMENTS BY U.S. DEPARTMENT OF COMMERCE NATIONAL WtATHER SERVICE !5 Comments of Dr. George P. Cressman, Director of the National Weather Service, are acknowledged. As suggested, the Weather Service Statement on Flood Warning Program, as appended to Dr. Cressman's letter, is reproduced in the EIS. 115 6 OCT 311975 TO: FROM: Dr. Willi am Aron Director Office of Ecology and Environmental Conservation Dr. Gordon L 111 (signed) GO Deputy 01 rector RDON LILL National Ocean Survey SUBJECT: DEIS #7509.61 -Upper Susitna River Basin South Central Railbelt Area, Alaska The subject statement has been reviewed within the areas of NOS responsibility and expertise, and in terms of the impact of the proposed action on NOS activities and projects. The following comment is offered for your consideration. Geodetic control survey monuments may be located in the proposed transmission line routes. If there is any planned activity which will disturb or destroy these monuments, NOS requires not less than 90 days notification in advance of such activity in order to plan for their relocation. NOS recommends that funding for this project includes the cost of any relocation required for these monuments. 116 C52/JLR RESPONSE TO COMMENTS BY U.S. DEPARTMENT OF COMMERCE NATIONAL OCEAN SURVEY f) We concur. Every effort will be made to avoid disturbing geodetic control survey monuments in locating the proposed transmission lines. In the event that disturbance is unavoidable, the National Ocean Survey will be given at least 90 days advance notice, and costs of relocation will be borne at project expense. 1~7 November 19, 1975 Colonel Charles A. Oebelius District Engineer U.S. DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration NATIONAL MARINE FISHERIES SERVICE P. 0. BOX 1668 -JUNEAU. ALASKA 99801 Alaska District, Corps of Engineers P. 0. Box 7002 Anchorage, Alaska 99510 Dear Colonel Debelius: The National Marine Fisheries Service has reviewed the draft environ- mental impact statement for "Hydroelectric Power Development, Upper Susitna River Basin, Southcentral Railbelt Area, Alaska." In order to provide as timely a response to your request for comments as possible, we are submitting the enclosed comments to you directly, in parallel with their transmittal to the Department of Commerce for incor- poration in the Departmental response. These comments represent the views of the National Marine Fisheries Service. The formal, consolidated views of the Department should reach you shortly. Sincerely, ~"'l!!J 114~ / Harry L. Ri etze ~ Director, Alaska Region Enclosure 1:!.8 - U.s. DtC:i:l,.~HrMEN!" c:= CiJMMi:t:iCE Na);i\)r.ai -Dcltal'3ic and A::mosp:utrlc Admininraticn Nrt.l.irmu.l f.1u.r•1:nr.: Fi:;Ju=n:··i:::r.; Dervice 1'. G. i:0x 1CC8~ Jv:neau, Alaska 99802 Date November 19, 1975 Reply to Attn. of: FAK/RJM/ To Director, Office of Ecology & Environmental Conservation, EE Thru: Associate Director[for~Refour;, Ma~agement, F3 From J1Jiarry L. Rietze tf-~:.)/ H~ T Director, Alaska Region Subject: Comments on Draft Environmental Impact Statement--Hydroelectric Power Development-Upper Susitna River Basin, Southcentral Railbelt Area, Alaska. Corps of Engineers DEIS #7509.61 The draft environmental impact statement for Hydroelectric Power Development, Upper Susitna River Basin, Southcentral Railbelt Area, Alaska, that accompanied your memorandum of September 30, 1975, has been received by the National Marine Fisheries Service for review and connnent. The statement has been reviewed and the following comments are offered for your consideration: General Comments It is estimated that ap'proximately 3,300,000 salmon, which include all five Pacific species, are produced in the Susitna River for the Alaska commercial catch. Based on 1975 prices, the annual value to fishermen would be nearly $9,000,000. ~/ It should be noted that the Southcentral Railbelt Area plays a significant role in the recreational activities of the resident and tourist fishing industry. Presently, there is no data available on salmon recreational fishery values accruable to the Susitna River. However, we would expect this value to increase proportionately to projected increases in population and tourism in the project area. As outlined by the Alaska Department of Fish and Game at recent public meetings regarding the DEIS, much of the information needed to make a systems analysis of the living resources of the river environment has never been collected. We believe it would be imprudent to make any objective comments regarding the fishery·aspects within the various sections of the DEIS, because of the lack of any substantial data on which to base our conclusions and because inventories and evaluations are still being conducted by resource agencies. !/ U.S. Fish and Wildlife Service. 1975. Southcentral Railbelt Area Upper Susitna River Basin Hydroelectric Project Two Dam Plan. U.S. Department of the Interior. October 1975. 28 pp. •. -.. """' JL1.~ 10 S rwc: ·j f i c. Commeu L.~; ..=J..:....::.._... . • -··------ 4.0 Environmental Impacts of the Provosed Action 4.02 Fish Page 49, paragraph 7. He believe the collection of one field season's data is not sufficiently definitive to make any assumptions regarding the relationships between salmon spawning and rearing sloughs and any regulated flows within the proposed project. · Page 49, paragraph 8. The statement regarding the elimination of I salmon egg destruction should be qualified by noting that it is based on an inconclusive sin&le-year observation. ~ Pa&e_lO, paragraph 1. The statement regarding salmon disorientation by initial project startup should be expanded to include the effects of project construction. Water quality degradation, diversion, etc., would all serve to confuse salmon returning to their natural spawning areas. Paae 50, last e_aragraph. This paragraph should be written to qualify the status of future fisheries studies noted. The Corps of Engineers j_Jl has no assurance that any proposed fish and wildlife studies will be funded or carried out in time to be of value in making any feasible project modifications. 6.0 Alte~natives t~ the Proposed Action 6.02 Alternative Sources of Power 6.02.3 Oil and Natural Gas Page 72. Because the proposed El Paso Alaska natuxal gas line could be .. !constructed to bring fuel from the known Prudhoe Bay field to the t~ Anchorage-Fairbanks area, it should be g~ven consideration as a possible alternative source of power. We would appreciate receiving two copies of the final environmental' impact statement. Jj Barrett, Bruce M. 1974. An Assessment of the Anadromous Fish Populations in the Upper Susitna River Watershed Between Devil Canyon and the Chulitna River. Alaska Department of Fish and Game, Division of Commercial Fisheries, Anchorage. November 1974. 56 pp. RESPONSE TO COMMENTS BY U.S. DEPARTMENT OF COMMERCE NATIONAL MARINE FISHERIES SERVICE .• J ,. Comment noted. (j The need for additional environmental data to make an objective analysis of the proposed projects is a recognized concern of the Corps. During the post-authorization phase, environmental studies will be made to obtain the needed data to develop both design and mitigation measures to minimize or delete the chances of environ- mental impact. The preliminary data presently available is a basis for identifying areas of concern that need detailed analysis. As post-authorization studies proceed, supplements to the statement will be prepared and coordinated. :~Noted. / ' JL\) Water quality degradation during construction would be limited to possible increase in turbidity. However, this condition would only be minor since the runoff in those areas that would produce turbid conditions will be diverted into settling basins prior to returning to the river. During construction natural river flows will be diverted around the construction area above any known spawning areas and would have no impact on downstream fish populations. At the time of initial storage, the fish and wildlife agencies will be requested to furnish necessary flow releases to prevent any downstream impacts. iY._ Future studies identified i~ referenced paragraph are those that would be considered if congressional authorization is received for the proposed project. These studies would be accomplished during the post-authorization and design phases of the projects. No assurances can be given at this time that these studies would be funded since funding will be dependent upon congressional appro- priations: i, .. The proposed new natural gas pipeline from the Prudhoe Bay field, although not specifically identified in the alternative discussion of Oil and Gas, was taken into consideration when this alternative was investigated. l2J.. REGION X DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT ARCADE PLAZA fiUILDING, 1~)1 SECONO AVr:Nilr SEATTLE, WASHINGTON 98101 Office of Community Planning & Development Charles A. Debelius Colonel, Corps of Engineers Alaska District Corps of Engineers PO Box 7002 Ancho~age, AK 99510 Dear Colonel Debelius: Subject: Draft Environmental Impact Statement IN REPLY RE:I lOD Hydroelectric Power Development, Upper Susitna River Basin We have reviewed the draft statement submitted with your September 22, 1975 letter-requesting comments within 45 days. The proposed action is to construct dams on the upper Susitna River at Watana and Devil Canyons, power plans, transmission facilities, access roads, and operating and recreational facilities. At this point we do not see any significant impact in our areas of concern. As plans develop, we would like to be kept up on possible changes in population projections and related housing and community facilities needs. Your plans appear to be consistent with the Alaska Water Study Committee's assumptions that there would be initial and continued hydropower development in the Susitna River Basin. Since both our agencies as well as the State, is represented on this Committee, there should be no problem in adequately coordinating water related project plans. Thanks for the opportunity to review your statement. •" Sincere~~,! :L' . . .....::: ! . .-./7/ 2C\) . t! ;_··,;{A__~ ! . >:-J(l;4 ~ ~~ ert'c. Sc lia ssistant Regional Administrator RESPONSE TO COMMENTS BY U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT J....J Comment noted. United States Department of the Interior ALASKA POWER ADMINISTRATION P. 0. BOX 50 JUNEAU. ALASKA 99802 ,,_ N~:PL Y I<(H.R TO: December l, 1975 14 15 16 700 Colonel Charles Debelius District Engineer Corps of Engineers Bpx 7002 Anchorage, AK 99510 Dear Colonel De bell us : The Interior Department, Office of Environmental Project Review, requested that we furnish you comments on your draft EIS, "Hydroelectric Develop- ment, Upper Susitna River Basin, Southcentral Railbelt Area, Alaska." General Comments We believe the draft statement does not provide adequate information on the proposed project transmission sys tern, and impacts , alternatives considered, and measures to mitigate potential adverse impacts of the transmission system. Such material could be included by extract or by appropriate reference to the Alaska Power Administration 1s Environ- mental Assessment of the project transmission system. I The statement includes a list of references cited, but for the most part, the text of the statement does not indicate sources of data. We believe a more complete citation of data sources is ne.eded. We believe the draft substantially overstates potential adverse impacts of the identified upstream dam and reservoir sites at Vee and Denali (see, for example, the 1965 report of the Fish and Wildlife Service, 11 A Detailed Report on the Fish and Wildlife Resources Affected by the Vee Project, Alaska 11 ), We believe it is very likely that a full development of the Upper Susitna River hydroelectric potential, including one or both of the upstream reservoirs, would result in significantly less adverse environmental impacts than would development of available alternatives outside the Susitna basin. 1.2'1 Save Energy and You Serve A me rica! 2 If the Corps' proposed development plan is authorized (Devil Canyon and Watana) , we believe it is probable that the Denali Dam would receive further consideration as a potential additional development. The data generated in your current studies indicates additional reservoir capacity would be beneficial; we feel this is particularly significant in view of very heavy winter energy demands in the Railbelt. We believe this matter should be discussed in the final statement. Specific Comments These are referenced to section numbers in the draft EIS. 1. 03. Description of Action. Suggest including a concise description of actions involved in constructing and operating the transmission system (clearing, access, towers, lines, substations, maintenance). 2.02.2.2. Raptors. The Fish and Wildlife Service made aerial surveys to determine relationships of the proposed transmission facilities to raptors, The data should be referenced in the EIS. The attached letter of July 14, 1975, from Dr. Clayton R. White discusses findings. 2. 03.6. Archeological Resources. Based on informal consultation with the Alaska Division of Parks on the transmission corridor studies, we understand that there are known and potential archeological and histori- cal sites along the proposed transmission corridors, To avoid possible disturbance, these sites cannot be identified in the project reports. We believe the project report and EIS should recognize needs for pre-con- struction archeological surveys under applicable regulations. 4.03. Wildlife. We believe that experience with the existing Healy to Fairbanks transmission line, and CEA and APA lines in the lower Susitna Valley and Anchorage-Palmer areas is pertinent with respect to potential impacts on caribou and waterfowl. We are not aware of any experienced or alleged problems with caribou on the Healy-Fairbanks line. Similarly, the existing lines in the Cook Inlet area have apparently not caused significant problems for migrating birds. 6·.02.11. Hydropower. The referenced 1948 report of the Bureau of Reclamation was but one of the early evaluations of Alaska hydro potential. Subsequent studies, including the Statewide Inventory published in the 1969 and 1974 Alaska Power Survey reports, and the June 1967 Interior Department report. "Alaska Natural Resources and the Rampart Project, 11 provide a great deal of further definition of these resources. .... ., :1.4' 20 21 3 We believe these more recent studies should be referenced as the basis for selecti.na the Upper Susitna project as the most desirable near-future major hydro project for the Railbelt. The existing data are adequate to demonstrate that the very large alternatives such as Rampart and Wood Canyon would involve greater environmental problems. An alternative plan to replace Susitna with equivalent power supplies from other poten- tial hydro projects would require developing several projects in different basins with attendant impacts. 6.04.5. Devil Canyon-Denali, and 6.04.6., Three-Dam System. We do not concur in the statements that economic feasibility is lacking for these plans, since we believe this findini is premised on unreasonably conser- vative evaluations of costs involved in the Denali Dam. As indicated in the 11 General Comments ,11 we believe the Denali Dam may ultimately prove to be a desirable future addition to the proposed Watana-Denali Canyon Plan, considerlna need for winter energy, environmental aspects, and available alternatives. Enclosure Sincerely yours, 7 r ~--~ o/0~/~ Robert J. Cross Acting Administrator cc: Office of Environmental Project Review ·r - ~- u.s.: .. /.LJ.' ": ·. ~-. ~-·: . ·~ .. • .. c:l~:: • , · .... ... 0 1875 ·Brigham Young University Centennial·1975 Mr. Melvin Monson U. S. Fish and Wildlife Service 813 "D" Street Anchorage, Alaska 99501 Dear Melvin: July 14, 1975 I am sending this brief letter for your use in discussion with the Alaska Power Administration concerning the proposed Susitna Dam Site and associated Power transmission lines. A full report will be sent to you which will include the entire summer's ffndings. This, however, will require some time to complete and I am desirous of you and the power administration receiving the following information as early as possible. We use both helicopter and fixed wing (helio) to search for falcons. The transmission lines that form the basic figure 8 configuration of the Alaska-Fairbanks, Fairb~nks-Big Delta, Big Delta-Anchorage, Denali Highway were investigated. These routes basically parallel existing highways. Within this area there is considerable habitat for cliff nesting raptors. However, as I indicated in my 1974 interim report to Fish and Wildlife Service, I found no nesting Peregrine Falcons within the confines of any of the 4 proposed dam sites. Historically there may have been Peregrines there, but in the year of the survey none was found. The transmission routes also ~raverse areas that look excellent for Peregrine Falcons, however, the only area of concern at the moment, as regards Peregrines, would be that portion of the proposed transmission line route which basically parallels the highway and Tanana River from 1-airbanks to Big Delta. There are s~veral historical Peregrine sites along ·-:he · Tanana River and Sulcha River. One should be mindful, however that aside from the Peregrine, the Gyrfalcon is also found in limited numbers within that portion of Alaska and because of its overall restricted range in the Arctic, one should be cautious of this species. Several nesting pairs are found from Sum~it Lake region to the Denali Highway region, thence, north along the Anchorage-Fairbanks HighHay in the area of the Healy-Cantwell region. To produce least impact in .terms of raptors, the transmission lines should probably be placed along the south side of the Denali Highway and the west side of the new Fairbanks-Anchorage Highw~y. 12f7 Department of Zoology, 575 WIDB, Brigham Young University, Provo, Utah 84602 (601) 37 4-1211, Extension 2006 Mr. Melvin Monson Page Two July 14, 1975 The·only conceivable area, then, of impact with the Peregrine Falcon would be that part of the transmission route from Fairbanks to Big Delta, thence, south along the Big Delta region to about Summit Lake. In this region no recent Peregrine Falcon nestings (since 1972) have been made. The Peregrine is indeed in trouble in this region. Further impact can be avoided by perhaps running the transmission lines across the flats south of the Fairbanks-Big Delta Highway keeping, perhaps, 2 to 3 lines away from the Tanana River. · Hopefully, these data will _suffice .until the entire report can be submitted to you. mp Si;;Ltv4 Cl~ ~White, Ph.D. Associate Professor of Zoology i~B \ ) RESPONSE TO COMMENTS BY U.S. DEPARTMENT OF THE INTERIOR ALASKA POWER ADMINISTRATION 14 The portion on alternative transmission systems has been expanded. The cooperation of APA in evaluating potential hydroelectric facilities on the Upper -5usitna River has been extremely helpful. The environmental assessment of transmission facilities has been used as a supporting document in compiling the EIS and has been incorporated into the Appendix of the technical feasibility report. 15 The Selected Bibliography has been expanded to list sources not previously cited as well as additional sources utilized in revising the document. 16 The environmental impacts stated for the upstream damsites are in relation to those in the lower portion of the basin. But when compared to impacts of hydroelectric alternatives outside the basin, i.e., Rampart and Wood Canyon, they are significantly less overall. 17 The alternative three-dam scheme does show a net benefit, but under an incremental analysis the third dam add-on is not economi- cally viable at this time. 1 8 Comment rioted. 19 Comment noted. Referred letter is included in the EIS as an attachment to APA's letter. 2UComments noted. 21 Comment noted. See response number 17. 129 22 23 24 DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION 0 C T 3 0 1975 Colonel Charles A. Debelius District Engineer Department of the Army Alaska District Corp of Engineers P. 0. Box 7002 Anchorage, AK 99510 Dear Colonel Debelius: ALASKAN REGION 632 SIXTH AVENUE ANCHORAGE, ALASKA 99501 TELEPHONE 272-!'>561 We have completed our review of the draft EIS on the Hydroelectric Power Development for the Upper Susitna River Basin Southcentral Railbelt Area. The following comments are offered for your consideration as you prepare your final EIS. I We recommend using the word "airplane11 in place of the term "bush plane" as it is used in paragraph 2.03.3.3 Air. The term may be misleading or confusing since many of the locations that are only accessible by air are served by large jet aircraft. I Section 2.0 Environmental Setting without the Project, covers the existing Air Transportation in paragraph 2.03.3.3 Air. Section 4.0 Environmental Impact of the Proposed Action, makes no mention of any aviation impact related to the project. As a minimum, the potential impact of the heli- copter construction mentioned in paragraph 4.10 Roads should be covered. Also, we have noted that on other construction projects, even when there is road access, there has been a tendency to provide helipads or landing strips for air evacuation of injured workers or the convenience of · , reduced travel time. If these aspects have been reviewed, it appears that Section 4.0 would be enhanced by including some comment on the poten- tial for impact or the lack of it from air operations. Thank you for the opportunity to review and comment on your draft EIS. Sincerely, -, ,.· ·:.~ . ..4_;_-"/~·,--­ <:..-Lyti K. BRO~ Director // 130 I RESPONSE TO COMMENTS BY U.S. DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION AOt~ItHSTRATIOH ALASKAN REGION ~~;~ The suggested change has been made in the appropriate section in the Statement. Section 4.10 has been revised to indicate that any helipads constructed would be of a temporary nature and would be rehabilitated when no longer needed. i~,.} Section 4.10 has been revised to discuss the need for facilities to provide for air evacuation of injured personnel. ).31 25 26 2'7 United States Department of the Interior FISH AND WILDLIFE SERVICE ALASKA AREA OFFICE 813 D STREET ANCHORAGE, ALASKA 99501 Co]onr.l C:hnrl.e-s A. D0.!1elitlS Di~trict ~n~inner, Cnr~s of Alr~l(n. Distdct p • (). 11M: '700?. Anchor,qn,e, ~~::.; 99'>10 O~nr CnJoneJ f)('hPlins: En~.i ncer 13 lqQV 1 ·~ '~115 Upf!e"C Su~i. t.n.1 ll~·cirnele~tric Power Development ER 75/942 NPAEN-PR-F.N Th~ Al:1sl~o<1 flrP."l nf the U. S. Fi.sh nnrl Hi.lrllift Ser.v:lc~ h.1~ the fnllmrin~ comnent~ to offer on this P.nvirnnml"ntal statement. H~ re"'ret th~t thr>rn NilS no ~cneral oisc\1ssi.on i.ncl\1/"lcrl on nos!>iblc r.iti.r-:atin~. meas\1rns to he cmnloycrl in the ~rojnct. We unrlerstanrl that ~etail~d studies tmrlP.rt.1~ten h~r the Cnrnr; lAter in the'! nuthnd.zation prorcss ~·rill nrovirle the I hnr.C'!S on ,.1hic:h ~iti" . .<it.in" M('!,1SII'['f'S Will he df!VC'l.Op!'!r1; hnt·ICV~r, t1 ~.enP'['lll I outlin,.. nf !)O.'l"lihl,.. m~l"l.1nrntin.-. mn:t!':lll':cs :1t this !"'ni.nt \'!Oit1n l~e 1.nfnr~l'T:ivC". T.o!=!'1 of hnldtnt, ff)r ~Y.<l~"'Plo, rn'"ht hr. miti~nterl hy Acc;uis1.tion or. nr.otP.c:tion of nimil~r ~c:r~n~~ C"l.~~whf!rc. Anticipate~ hnnvy llSC" hy rccrention1sts mi~ht he .<lll,..vi i'lt<'ci hy f'l :1c: f n.~ llCCe!:ls ro:'lns RO AS to di ~cottrn.-.,e such uf\e or hy ORV Tf'["nlotions enforced hy the l:1ncl-mnn.1~i.n~ n~cnry. An outline presentAtion R11ch n.r; this 'mul ci r.l~nrly dcmnnr;t·r:lt~ the forC'tho11~ht r;iv!'n thts suhject hy th~ ~orr~ ~r!thout re~uirin3 cictail which is unavailRhle yet. Ye Are pl~ns~cl r:o note that cnnsi~cration will be niven to improvinn fish acceRs to and from some of the slour,hs and tributnries do,-mstrcam from Devil Canyon • We are also 'pleased that the results of onr.oinr, studies Hnder the direction of the Fish and t-lil~lif:e Scrvi.ce will be used durinr. the fl.n~l dcsi~n ph.1sC! studies for feasihle project moclificlltf.on and mitir.atin.~ measures.· SPTo:CTFIC Smll"!\.1 rv, 3B onrl pn:;c 53, pnr.<h 3 ... the pre sent document tcnrl s to minimb:e impactR to moose habitnt. Espcc:ially on par,e 53, the effectA of the loss of mooRe habitat should he describeci in detail ll.nd thete-r-;;-11 preferred 11 nnrl otcr'i tical" defined. The number of acr.es to be inundnted And secondary nclv~rse effects, if any, sho11ld be discussed. A smt-~11 loss of habitat may to be sif';nificant' when assessed alone, but when addeci with all the statewid~ losses of similar si~e, the loss may be siRnficant. ·save Energy and You Serve America! Pa~e 23, nara. 3 -Other nirds. The statero1cnt "Sor~c inci.dcmtal huntinr, tal<cs pl.'lce alon.r>, th"'e Denali 1Iir,h,vay 11 is misleadin!"\, thou~h this is presumably a reference to ·r.ame bird huntinr;. Huntinl", pressure ~cnerally is {leavy alon.~ tl1e Denali Hip,hway and this statement needs to tie more. closely "'ith bird huntin~ only. PAr.e 37, first para. -Other'' Forms of TransportAtion. The statc~ent concernin~ shallow-draft river boats-,-smafl-b~t"S7-C'ano"Cs-;-·r'"Ubocr rafts and kayaks needs expandinft, since La~cs Louise, Susitna, Tyone and the Tyone River cor'lnlex in the Upper Busitna draina~e receive heavy boatin~ nnrl floatplane tJ~e by hunters and fishermen! from the Glennallen cmd Anchorar.c area. Pa:-:c '•r;, narn.. 3 -The 5t.~tcr::ent "• •• and e. Minimnl ar::ount of resident fish hnhitat at the months of a fm·; of the tributnries that enter the Susitna ~iver in the 2C-r.1ile section of the proposed damsite" s'f1oulrl be e:cpancled to identi f:y he'l~ many td lmtnries enter the Susitna Rf.ve.r J n the nffected r.e~tch of r:J.ver ,<~nil to iiJRcuss more fully the 11m:l.nir.1al fish hahtt11t 11 • P.1"C 1;8, nnrA. 5 -'T'hi.s f!ara~r.-tph. should he expn.mleci to i.r.("lm'le the Antici;.>nterl numhcr of 11r£lre occ:asions" HI-len excess \UI.ter WOlJld he rlivert~rl ov~r the s.!lilhrny, the clirvttir. or en.r~:fneed.n~ fllctnrs !lrcci~tt.r:tin": the:c;c occ.nsions, nn~ th~ rl~nrne of si~ntf4c:Ant Adverse irnpncts on fish nnrl vc~ctntJon. p,..,.c M'., pn,..:1. n -Tl1i.s ·TH:lr~:"'.t'rt!'lh ~honl r1 '"!l"ci fy t.hc-i'!C,..I'!fl of ~,n~c lMhf tl'lt innnnntl'n rmd it:<~ i.m~.ortnnt:".c to moose. l.iltP.wisP., the fl'sh h:1hitnt i.nnnrlaterl sho11lrl hi" rlcflcrihNl i.n ,rwreater det.'lil. !ToH mnr:h fi!':h h11hJtl\t: wfll he immrl.'ltl'rl nnrl 't'th:'lt s~cci!'s ,.,ill he o.ffectc~? Hhllt t?!lC!r. o.f fi.r.h hnbit~t will he crenterl at hir:her clcvllt:i.ons and uhat s'!'ecics .?r.c expectccl to use the 11new 11 hahi.. tnt? Pfl~,.. 51 1 lnst pnrtt. -I.J't'! SU",..C':'lt: s11.,stit11tion of th~ '\'m1-rl "fr.;,..iJc" for the \·TOni "siMnle" i.n the !ltntemP.nt, 11Hnw~ver 1 the lll'!ttrtt:lc foon C".h.;1n· i.n thP. tnt~n (hore:Jl forest) nnrl tllnrlr~ is ~xtre1"1r.ly Ai1"'1ple, .1nr1 n!l ;~ t"C'l'ntl t, rli.srtJr>tion of hnhtt~t for C'ln~ ~nrcfcs ~"lte oft~n indirectly nffects nrtny other sr>ec:l.es.11 Pn":c> .'13, ~.,r/'1. 3-11 .\lt_hott~h I""C'la~e htthf.t;~t ~oe!l e}:i~t \·.dthin the ~ool areas of the ~ro~osen Devil Cnnyon and WatRna reservoirs, the ovcr~lJ lofls of or!'f!'rrccl or c.r.i. ticRl. ,.tinter fortt~e nrcnr: ,.,oulrl ,qffN•.t. hut."" !':T"'Fil 1 ncrcentA"'e ;.,f the! UnoC'r '>usitnn rr,oose nonnlation"'11 (emphnsl.s arlded)-.-t-le--fiOr.~lelieve tii'~re-t;-'suffi.cient inform1.1.ti.on avnilahle at thfs ttme on the Upper Susitnl\ moosP. po:l\ll<'lt:i.on to cl\ter~oric.nlly imply on]v a ST"itiJ 1 ocrr.ent.l'l~C of moose will hC' nffected. Anticipnterl sturl1en hy thC'! Finh nnrl Wil~life Ser.vfce :J.n cooncrntion "lith the Alnskn Dcp,'lrf.~cnt of. Ff.sh t1nc'l Gnmc should. provide the needed informntion for n dctcr~:lnntfon wtthfn the next four yenr.~. I. s trw· I ;~9 I ~0 ·I 3:!; I .,., e-, L), ."! I :i3 PA"B 6l~, ~l'lrn. 1-the ho'"!Cl~":T.'O\tnrl rllltA surmortin~ the Ps~ertion that lar.c~e I blocks of excess po,.,er ui1l not he created hy the proiect should he presented. Obvioltsly, the iJl1!>act on the State of Alaska would he profotmd .and lon;>,-lastinr: r·. ":':""' i.f a lnr~.e SUr!JlU9 of pmvet' became avai lAhle and industrial development Were oJ,.J stir.mlated by this. Since this· l>1C'l11ld be viel>red by many as ·an adverse impact, or at the least a secondary impact of ma~nitudc, i~ should be explored here. . Thnn!< vm1 for the o)')~ortuni t~· to rcvi.cH this clrr.ft r.t::tC'n:ent. As <tn n!".cncv with snccific rcspon~ihilities reletcd to the project, the Fish nnd Wildlife Service looks fon1nnl to rcvicl'l'inr, the other documents :1s the project goes throur;h its Authorization procedure nnn offers to assist flt any tir.e. 134 RESPONSE TO COMMENTS BY U.S. DEPARTMENT OF THE INTERIOR FISH-AND WILDLIFE SERVICE i~~ An outline presentation of possible ameliorating or mitigating measures can not be made until a determination as to what types and to what extent such measures will be required. As stated at the end of Section 1.0: 11 Examples of problems expected to be addressed during the detailed design study phase include identifi- cation of significant adverse impacts to important fish and wild- life species, and specific actions which should be taken to prevent, ameliorate, or mitigate these impacts.11 The provisions of the 1958 Fish and Wildlife ·coordination will be fully complied with in the consideration of project damages to fish and wildlife resources, and the implementation of appropriate ameliorative or mitigative measures. f-~.·3 Comment noted. True, past fish and wildlife reports generally discounted moose habitat in Devil Canyon and showed comparatively low moose popula- tions in the Watana reserva.ir area. A definition of 11 preferred 11 and 11 Critical 11 in relation to moose habitat has not been defined in the EIS at this time. Future wildlife studies should determine and define critical moose habitat and number within the proposed impoundment areas. ~j.] The words 11 game bi rd 11 have been added to the statement to clarify this discussion of hunting pressure. ~-~~ In Section 2.03.3 (Transportation), the EIS indicates boating and floatplane use in areas of the Upper Susitna River Basin. c~t) The fish habitat at the mouths of clearwater tributaries which would be inundated by the proposed impoundments is more fully discussed in Section 2.0 under the heading Resident Fish. According to a survey conducted jointly by the Fish and Wildlife Service and the Alaska Department of Fish and Game in May and September 1974, only Fog Creek and Tsusena Creek provide good resident fish habitat within the reservoir impoundment areas. Some of the other tribu- taries provide poor habitat, whil~ others indicated no presence of fish. . -a ~~--The EIS has been expanded to indicate that excess water would be diverted over the spillway once in approximately 50 years. The factors precipitating these occasions would consist of a full reser- vior concurrently with inflow in excess of the combined turbine and regulatory outlet works capacity. Impacts on the 2.5-mile reach of Tsusena Creek would consist of channel and streambank erosion, ,. , ~ ---- .A•-"'0 flushing of fish and other stream organisms, and damage to stream- side vegetation. 3~ A discussion of the importance of inundated moose habitat has been added to Section 4.0 of the EIS. Acres of significant moose habitat can only be determined from studies which are proposed to be conducted during the pre-construction stage of planning. These studies wil l determine the extent and types of ameliorating measures required to offset any unavoidable damage to moose habitat and populations. As stated in Section 2.0 of the EIS, grayling, rainbow trout, lake trout, Dolly Varden. whitefish, sucker, sculpin, and burbot comprise the principal resident fish population of the Susitna drainage. As also stated, grayling is the principal sport species inhabiting the mouths of clearwater tributaries. It is expected that this would be the predominant species inhabiting any new habitat created at higher elevations by the reservoirs, since habitat conditions would probably be similar at the higher elevations. As with the case of moose, such eventualities can only be ascertained by detailed future studies. 3 3 We disagree. Admittedly, the taiga and 'tundra are "fragile 11 ecosys- tems.· However, an ecosys tern cou 1 d be fragile and s t i 11 have a complex aquatic food chain. Such a food chain would probably be less severely damaged by a given action than would a "simple" food chain in which loss of one link might directly affect the entire system. 3 4camment noted, but past studies indicate low numbers of moose are found within the proposed reservoir areas. 3 5 See response number 255. 136 -- - United States Department of the Interior GEOLOGICAL SURVEY RESTON, VIRGINIA 22092 nrPI{;lt OF TIIP, OIMV.<:I Cll< ER-75/942 Colon~l Charles A. Debelius Alaska District, Corps of Engineers P.O. Box 7002 Anchorage, Alaska 99510 Dear Colonel Oebeliua: NOV 1 7 1975 We have reviewed your draft environmental statement on the Upper Susitna hydroelectric development and offer the following suggestions: It has been noted that impacts will be analyzed after project authorization and prior to project design (p. 8, par. 1). Information conspicuously absent in the present statement, but which should be incorporated in a revised or final environmental statement, includes the geology of the proposed dam sites, including permafrost conditions, and related impacts. Much pertinent information can be found in a iecent Geological Survey report, "Preliminary geologic and seismic evaluation of the proposed Devil Canyon and Watana Reservoir areas Susitna River, Alaska," by John C. Lahr and Rueben Kachadoorian. That report notes that the Devil Canyon damsite is underlain by argillite and graywacke of Cretaceous age, and describes joint sets and shear zones in the damsite area (p. 5-6). The Watana damsite is described as being underlain by granitic rock which has intruded the Cretaceous argillite and graywacke. In discussing potend:al geologic and seismic hazards to the project,. the Survey r..:port states that "on~ must assume that tho:: proposed Devil Canyon and Watana Res~rvoirs could be subject~d to carthq~ake generat~d landslides" (p. 14, par. 1). It has also been observed that unconsolidated sediments high above the river on the canyon · walls would be inundated when the reservoirs are filled and "during a major seismic ~vent these scdim~nts may slide and generate waves in thc reservoir" (p. 14, par. 2). Another hazard discussed in the preliminary report is that of the runup against the dams of waves that might conceivably be generated by blocks falling into the reservoirs ·or by subaerial or subaqueous landslides; additionally, the possibility Save Energy and You Serve America! 13'7 36 37 38 39 40 ER-75/942 2 of damag~ by seich~s that might develop in th~ reservoirs during earthquakes has b~en briefly discussed {p. 14-15). Possible hazards of earthquakes induced by reservoir filling have also been discussed (p. 15~16). It is concluded that all of th~ foregoing possible hazards should be carefully assessed in the siting and design of the propos·ed dams (p. 17). Recommendations are presented for geologic and geophysical studies (p. 18-19; p. 21-24). Daily fluctuations of up to two feet in the river below the proposed Devil 1 s Canyon dam are compared to the natural fluctuations of about one foot (p. 46, par. 5). Howev~r, the natural daily fluctuations occur during the spring and summer runoff of snow-melt at high flows while those after construction of the project would occur at lower flows, be more abrupt, and occur in winter. Thus, some different effects might be expected and these should be discussed in the final statement. The spillway design a·t the upper dam would divert flows that cannot be taken through outlet structure into Tsusena Creek, 2.5 miles above the confluence with the Susitna River. It is indicated that on the Tare occasions when this diversion would take place, the impacts on Tsusena Creek could be significant (p. 48}. The frequency at which damaging diversions might occur should be given as well as ~stimat~s of extent of the resulting effects. The occurrence of ground-water resources in the project area is not addressed in the environmental statement, although bits of information on geology (p. 14-i5) and the suggested ground-water impacts of the coal alternative ·(p. 71) indicate that appreciable ground-water resources exist in the area. It is not possible to evaluate the impacts of the proposed project on ground water without more information. Aithough we realize that this document represents only a feasibility stage, we believe that impacts on ground water should be evaluated for each major component of the recommended developmen1 plan, especially for the proposed dams, powerplants, transmission facilities, roads and recreational facilities. These evaluations might be presented in detail after the project is authorized, but current knowledge should · be sufficient for evaluation in general terms. IThere is some apparent conflict in the interpretation of the Alaska Native Claims Settlement Act which is not resolved (p. 43-44). A further statement seems necessary to say that this difference between the intent of the law and the understanding of the Bureau of Land Management'is yet to be settled. We thank you for the opportunity to comment on the draft environmental statement. Sincerely yours, ...- ,d-~10~ 4l'i1-~tor · . ~ ' '.;) ....~ro..u.u RESPONSE TO COMMENTS BY U.S. DEPAinMENT OF TilL 1NTLR10f< GEOLOGICAL SURVEY ~~E) The geology of the foundations for Devil Canyon is a phyillite complex with joint sets crossing the river at a slight diagonal. Due to the steep cliffs there is no overburden. Foundation rocks at Watana are granitic types with joints crossing the river at a slight diagonal. Overburden varies greatly and is expected to be 1 to 10 feet deep in the vicinity of the axis. Depth of bedrock in the river channel could be as much as 70 feet according to seismic studies. The bedrock formation of the canyon walls changes from igneous complexis to metamorphized sediment complexes. The exact boundaries will not be known until later design studies are authorized. Detailed seismicity studies will be required in deter- mining the exact siting and final design of the dams. The Corps concurs with the Geological Survey that the geology of the project area must be studied in depth to identify hazards which the dams and reservoirs could be subjected to. ~~,:The hydro projects ~1ill be operated in a manner similar to the normal load demand of the railbelt area which presently has an annual load factor of 50 percent. Monthly load factors throughout the year have ranged between 70 to 76 percent~ and weekly load factors are frequently above 80 percent. Therefore, under the normal energy demand makeup, the Watana turbines would have ade- quate capacity to meet all peaking requirements, and the Devil Canyon project would serve the baseload, thus regulating the Watana discharges and maintaining a relatively stable downstream discharge. However, if the Devil Canyon projects were operated within a 70 to 80 percent plant factor range on a monthly basis, the respective river fluctuations would be minimal (on the order of less than a foot on a monthly basis). Under extreme conditions when a rail- belt system failure of existing thermal units may require heavy hydro usage, abrupt fluctuations could oc~ur. Spring, summer, and fall stage increases would have relatively the same effect as natural stage fluctuations brought on by flooding. Generally, however, system failures at this time of the year could be met by other thermal units held in reserve. Therefore, a winter system failure would probably provide the most adverse river effect. In regard to premature ice breakup brought on by river fluctuations, I studies conducted by the Missouri River Division, Corps of Engineers. have found that stage increases of up to 7 feet. at moderate rate can be tolerated without pre~ature breakup. A 7-foot fluctuation is far in excess of the maximum stage increases anticipated for the proposed hydro projects. ~· ... 8 This paragraph has been expanded on page 48 of the EIS. The spi 11 frequency is approximately once every 50 years. 3 ~Groundwater within the confines of the proposed reservoirs and dam structures is limited to the shallow aquifer which discharges to the Susitna River and to local benches perched on bedrock. The aquifer is roughly 80 feet deep and is underlain by bedrock. Because the stream channel and subsequent bedrock are "river cut," the lateral extent of groundwater is intermittent and confined to benches shaped by glacial scour. The flood plain of the Susitna River upstream from the proposed Devil Canyon damsite but below the upper reaches of the Watana reservoir is confined to a steep- walled, narrow canyon. Groundwater within the study area has no existing or planned human use. From an engineering standpoint, few problems are anticipated from groundwater interference during or after construc- tion. Conversely. although inundated within reservoir areas, downstream groundwater impact is expected to be minimal. Adequate freshet recharge coupled with the influent nature of the winter flow regime should maintain existing downstream water tables. Access roads will traverse the basin on relatively high ground outside of the canyon confines. While some groundwater may be encountered, the general route of the roads has been chosen to minimize design problems such as groundwater. The topography of the area would not indicate that the roads would have any signifi- cant groundwater impact. The same general observations hold for the transmission system; however. considerably more terrain would be crossed and a greater potential for groundwater impact may exist. Much of the transmission system will follow existing transportation and utility corridors and an analagous observation of groundwater interference along these routes would indicate few potential problems. 4UThe discussion of the Alaska Native Claims Settlement Act has been expanded and updated in the EIS to reflect the latest status of the lands in the project area and to indicate that some of the matters concerning the ultimate disposition of these lands have not yet been resolved. See Section 3.02 in EIS. 140 UNITED STATES DEPARTMENT OF THE INTERIOR BUREAU OF INDIAN AFFAIRS Juneau Area Office P. 0. Box 3-8000 Juneau, Alaska 99802 IN ~LPL I' Hl.f~t-.H l {I November 3, 1975 Memorandum To: District Engineer, Department of the Army Anchorage From: Area Director Subject: Review of draft environmental impact statement for Hydroelectric Development, Upper Susitna River Basin, Southcentral Railbelt Area, Alaska (ER 75/942) General Comments: The document is presented in a good format so the document is readable I and easy to follow through. There appear to be provisions made to avoid LjJL any future land conflicts under the Alaska Native Claims Settlement Act. . Specific Comments: We have no further comments. 141 ~~~·comments noted. RESPONSE TO COMMENTS BY U.S. DEPARTMENT OF THE INTERIOR BUREAU OF INDIAN AFFAIRS "' .. I ~ ') L·~,J United States Department of the Interior BUREAU OF LAND MANAGEMENT State Office 555 Cordova Street Anchorage~ Alaska 99501 Colonel Charles A. Debelius District Engineer Corps of Engineers Alaska District P.O. Box 7002 Anchorage, Alaska 99510 Dear Colonel Debelius: IN REF'L V REFER TO. 1792.5 (911) We have reviewed the draft environmental impact statement titled "Hydroelectric Power Development, Upper Susitna River Basin, Southcentral Railbelt Area, Alaska" ER 75-942. Our concerns basically center arotmd the lack of assessment of the effects of the proposed project on the downstream portion of the Susitna River. We are also concerned that ,~:~ since the project is only in the feasibility stage, future design efforts and ongoing studies may uncover additional environmental data. Thus, another impact statement or an update would be desirable at the time the project became more specific. General Comments The proposed Devils Canyon-Watana Dam project is being placed on one of I the major river drainages in southcentral Alaska, but the DEIS does not ,:.]- provide a comprehensive overview of the impacts of this proposed hydro-~ electric complex on the stream ecosystem and associated resource values. Consideration of the environmental impacts of the project and affects on recreation, navigation and fisheries, for example, need to be expanded to include the lower Susitna River from Devils Canyon to its mouth on Cook Inlet. In this regard~ the DEIS is deficient, and adverse impacts 1._±1 in the lower river may outweigh potential beneficial aspects 'of the proposal in opening up access to the Upper Susitna Basin. Specific Comments Summary Page 2. Description of Action -The draft states that all impacts were not I exhaustively evaluated since the project is only in the "feasibility study" stage. However, it appears that the proposal has gone . . ' ') _i_ 1...::oJ. 45 3. 46 47 I far beyond the feasibility stage and should require a detailed EIS Which evaluates all possible impacts. If another impact statement will be prepared after design and further studies, this should be so stated or explained. a. Environmental Impacts -Increased turbidity of the Susitna River downstream from the project area during the winter months is listed as a major adverse environmental impact. Yet, no analysis is made in any of the remaining sections of the EIS of the potential impacts of this water quality change upon overwintering resident and anadromous fish in the main stem Susitna River below the site. IThe recreational opportunities would more than likely be altered rather than increased. Use patterns would shift from de facto wilderness oriented activities to more intensive activities adjacent to the new roads and reservoirs. 4 81 The project would also promote the development of adjacent private (Native) lands. 49 50 51 Page 1, paragraph 1.02 l it is suggested that it is premature to consider the subject project without first completing the Stage 2 comprehensive repo~ on the feasibility of developing other hydroelectric sites· in the area. Page 6, paragraph 1.03 IThe discussion of access road design/location should be st~ngthened, if possible. Mention is only made that such construction will 1include consideration pf environmental factors. It would appear appropriate for such considerations to be discussed in detail. It is understood that the operation and maintenance of project- related, recreational developments will be assumed by the land managing agency having responsibility for the major portion of adjacent public lands; and, as such, it would seem best to resolve that matter at an early date and incorporate that organization's goals/plans into the design of any recreational developments. Page 15, paragraph 2.01.4.3 I It is impossible to co~sider the environmental impacts of the 52 transmission corridor as described. A considerable expansion this section is warranted. of 144 2 L Pages 18-21, paragraph 2.02.1 The draft would benefit in this section by the inclusion of a fisheries habitat map detailing the distribution and the spawning and rearing habitat, by species, of both anadromous and resident fish in the immediate area of the dam proposals (Chulitna River conflu-~:J ence to the upper end of the Watana impoundment). Page 23, paragraph 2.02.3.1 Rather than state that ATV access to the back country has improved hunting access in spite of a rapidly declining caribou population, it might be justified to state that increased access, whether via ATV's or roads, coupled with an increasing human population, may be a contributing cause of the rapidly declining caribou population. Page 36, paragraph 2.03.3.4 River boats and airboats are a common form of transportation to recreational cabins, homesites, and the hunting and fishing oppor- tunities of the lower Susitna River. Due to the braided and often shallow character of the Susitna River in the area between the mouths of the Kashwitna and Deshka Rivers, the 3,252 and 19,160 cfs reductions in flow created by the proposed project during May through July (as shown in Table 1, page 45) could have a considerable impact on the navigation of the lower river, particularly for boaters using propeller-driven outboard craft. I The impact of flow reductions on current transportation to recreational opportunities in the lower river should be examined and weighed against the suggested advantages of increased access to the Upper Susitna Basin (Page 54, paragraph 4.04). In winter, the lower Susitna River is also a highway for travel by snowmachine for homesteaders and recreational tract owners. It should be determined if regulated discharges ranging from 6,038 to 7,428 or 481% to 657% increases over natural flows in January through April will result in hazardous travel due to thinner ice formations or their complete absence in the lower segment of the river. Page 37, paragraph 2.03.4.1 55 56 It is incorrect to state that floatplane access is relatively minor and restricted to a few large lakes. Such use is actually quite common and in all probability, most lakes large enough to accommodate a Super Cub are utilized. 157 . . . -~:.:.tJ 3 58 60 61 It is also incorrect to say that the Upper Susitna River Basin has very little recreational activity. ·As noted previously, float- planes and ATV's are utilized quite heavily by hunters, fishermen and other recreationists. Preliminary studies indicata significant populations of hunters, fishermen and miners utilizing the Susitna River Basin. Reference: Upiversity of Alaska 1975 ORV Study (report being prepared ) . 'Page 37, paragraph 2.03.4.2 Reference to the hunting of sheep and goats being minimal, even along the Denali Highway, implies a general lack of interest in that direction; however, the real reason for minimal hunting pressure along the h.ighway is probably the result of minimal sheep p:~pulat ions . Page 43, Earagraph 3.01 Although the general project area is presently under the jurisdiction of BLM and the area to be inundated is classified as a power site, the entire area is withdrawn under ANCSA for possible selection by Native corporations. Selections have already been filed for lands in the immediate area of the proposed sites. We suggest you contact the Land Office, 555 Cordova Street, for the specific locations. Pages 45-52, paragraphs 4.01 and 4.02 The present relationship of food supply, water temperatures, turbidities, 1 velocity of flow and dissolved.oxygen levels currently found in the lower Susitna River provide a balance which permits the existence of overwintering fish populations migrant to the stream from clearwater sloughs and tributaries which have diminished water flows or are frozen to the bottom. Alteration of any one of these conditions produces changes in the others which degrade the lower Susitna River's ' capability to support wintering and will result in a decline of resident and anadromous fish populations. Any attetnpt through engineering design and discharge management to maintain the lower Susitna River is subject to failure because of the harsh climate an~ the complex interaction of the above Tactors. I Assuming, for example; that discharges from the Devils Canyon Dam are increased 657% above the natural flow level during the winter period and all other of the above factors remain at the natural level, the following will happen: 4 /-..., 1. Temperatures remain at natu~al level of 32° F. Fish, being cold blooded organisms, have their basic activity level "set'~ by temperature--in this case their lowest. Stream velocities have been increased and fish cannot maintain their station in the river currents. By their inability to maintain or produce a higher activity level, they are subject to stress an~ mortality. 2. Food supply is presently limited, and for this exercise, is presumed to remain the same. Utilization of available food supply by fish is decreased because more of their basic energy expen- diture must go into swimming rather than into the activity cos~ 63 to capture prey organisms. Fish lose condition, are stressed and subject to mortality. · 3. Dissolved oxygen is presently above 5 mr./L At this level, oxygen is in sufficient supply to maintain the low metabolic rate of. the fish. Much lower levels would be required to cause fish stress and mortality. Discharge-stream velocity would have no impact. 4. The waters are presently clear in the winter situation. With increased flow, there would be no impact on fish life, adverse or beneficial. In the above case, alteration of stream velocities affects swimming performance of fish and utilization of their food supply introducing stress and mortality. If all the possible permutations and combinations of change and interaction of the above factors are worked through, it can be realized that construction of the Devils Canyon project 64 will affect the lower Susitna River's suitability as critical winter habitat for resident and anadromous fish with little hope for mitigation. This should be ~learly and positively outlined by the Corps of Engineers as an adverse impact of the project. The effect on fish production and stream ecology should be expanded to include the entire lower Susitna River. PaBe 50, parar,raph 4.02 What is the basis for the readjustment of fish? Presumably some sort I of evolutionary adaptation is to be accomplished in a short period of time to complex habitat changes and alteration of natural biological {;5 cues. More likely, the adjustment will be a substantial decline in fish population numbers. This should be positively stated. Page 50, paragraphs 4-6 Presently, it is doubtful that spawning by salmon occurs in the main I stem Susitna River. This paragraph is irrelevant to the true fisheries 5 ~47 6{)1 value of the river, namely winter habitat for fish from sloughs and tributaries. Additional spawning habitat will not be of any value, provided the critical winter habitat for fish survival is not available. 67 68 69 70 Pages 55-56, paragraph 4.04 The lower Susitna Dasin encompasses one of the largest blocks of land currently patented to the State of Alaska. The area will see increased public use in recreation due to the fact that many areas of the state will shortly be turned over to the private ownership of Native regional corporations and villages which will restrict access to lands previously used by recreationists from the densely populated Anchorage area. Also, as sug~ested, a new capital may be constructed close to the lower Susitna River. The impacts of ' reduced discharges in the Susitna River during the summer months should be examined to determine the effect on current modes of transportation and navigation for recreational purposes in an area which has a growing demand. I The dra~ estimates an annual visitation to the project area of 77,000 people. The methodology for arriving at this figure should be shown, since there are no previous similar situations or case analyses in Alaska. Page 59~ paragraph 4.10 'I It would be of value for the reader to know the actual locations of proposed roads and the conditions under which it would be considered necessary to accomplish revegetation of temporary roads and other disturbed areas. I Page 61, paragraph 4.13 ICare should be exercised in locating the transmission line between Point MacKenzie and Cantwell so as to avoid a degradation of the scenic views of Mt. McKinley. 71 IAn expansion of the brief discussion of planned landscape management techniques would be appropriate. IThe last sentence in the first paragraph should read positively, 7 2 i 11 That would (delete probably) qualify for wilderness classification" (delete rest). 6 148 We suggest qualification as to what extent roads and transmission lines will impoct aesthetics. The third paragraph reads as a justification statement. Page 68, paragraph 6.0 It is suggested that alternatives to the proposal might surface in the feasibility study (Stage 2) for the development of other hydro- electric sites in the Southcentral Railbelt area which is scheduled to be completed in 1978. Pages 69 and 78, paragraphs 6.02, 6.03 Development of the Beluga Coal Fields will probably occur regardless of the presence or absence of the Upper Susitna Hydroelectric Project. Considering the adjacency of the Beluga Coal Fields and the potential Chakachamna Hydroelectric Project, some consideration should be given to potential power production based on a blend of these two systems. Other factors in favor of concentration of power production in the ar•ea are the potential for industrial development, deepwater port capabilities and the presence of some power trans- mission lines at present. Oil and gas field development has already occurred throughout the Beluga area and a major timber operation exists, so the projects would not be affecting a de facto wilderness like the Upper Susitna Basin. Page 71, paragraph 6.02.2 Reference is made to the lack bf recreational and flood control benefits in a coal-thermal facility. There are no known flooding problems along the river which require control; hence the flood control "benefits" of the two-dam proposal are of little value. Page 89, paragraph 6.05 A transmission corridor is indicated in figure 15 as possibly passing through the Copper River Basin served by the Copper Valley Electric Association which has plans to increase their service by a new hydroelectric project at Solomon Gulch near Valdez with a transmission line to the Copper River Basin. The coordination of these tHo transmission or power systems should be explained in the· · final. Sincerely yours, ~~~- Curtis V. McVee State Director IJ I. ·- :·a . ., ~ RESPONSE TO COMMENTS BY U.S. DEPARTMENT OF THE INTERIOR BUREAU OF LAND MANAGEMENT <lZ The purpose of future design efforts and ongoing studies is to obtain additional environmental data. The EIS will be amended or updated periodically during the course of these studies to reflect all significant impacts identified. '1:3 As acknowledged in the first paragraph of BLM 1 s letter, the project is currently in the feasibility stage. A comprehensive and detailed overview of the impacts of the project cannot be ascertained until the detailed, pre-construction stage of planning is authorized and funded by the Congress. The FEIS will be revised and updated to include all additional information received during the EIS review process. '~t.l The need for further studies to determine detailed impacts of the project is acknowledged in the EIS. The Corps does not view opening up access to the Upper Susitna Basin as being beneficial. The EIS fully addresses the general impacts expected to result from such access--both adverse and beneficial. Any 11 benefits 11 from such access are not weighed as a trade-off to adverse impacts which may or may not occur downstream. · '~~ All Corps project studies are in a feasibility stage prior to being authorized and funded by the Congress for advancement to detailed studies, which are made prior to--and results of which are a determining factor in--a determination by the Congress that the project should be authorized and funded for construction. Thus, this proposal is currently in a feasibility stage, and will remain so until such time that Congress may approve authorization for pre- construction studies and appropriation of funding therefore. On the basis of detailed studies made during the next stage, the EIS will be appropriately amended or updated. "' ·~ Increased turbidity which is expected to occur downstream from the project during the winter months is not listed as a major adverse environmental impact in the EIS. It is discussed as an unavoidable adverse impact, the significance of which presently is not wholly known. There is some evidence to support a view, however, that the impact may be relatively minor. Estimates of 15 to 35 ppm of sus- pended sediment are based on concentrations below glacial-fed natural lakes in Alaska. One of these is Skilak Lake. The Kenai River, which flows from this lake, is generally recognized as one of the more important salmon streams in Alaska. J ,• "1 :.s. Comment noted. 4 b Comment noted. 4bThe most feasible alternative hydroelectric sites in the Southcentral Railbelt and Yukon regions were considered during the Stage 1 Interim Report. Stage 2 studies would consist primarily of a more in-depth evaluation of the alternatives already considered. 50considerations of environmental factors related to road construction will be considered in great detail when and if studies for such roads are authorized and funded. At the present feasibility stage of planning, the exact location of access roads is not known. 5lconcur. As soon as it is determined--as a result of consumation of the provisions of the Native Claims Settlement Act--what agency or organization will have the management responsibility for the major portion of adjacent lands, efforts will be made to incorporate recreational development into that organization's plans and goals. These lands are presently in a state of flux, having been designated as Native Village Deficiency Lands. 52Impacts of the transmission lines, insofar as can be presently predicted with a reasonable degree of accuracy, are discussed under appropriate resource categories throughout the EIS. A comprehensive environmental assessment of the impacts of all the alternative transmission line corridors has been made by the Alaska Power Admin- istration. This document is included in the appendix to the Corps' interim feasibility report. and is available for public review in the District office. 53we agree. Such a map would have been included had it been made available by any of the responsible fishery resource agencies. This type of information will not be available until fishery studies currently underway are completed. 54The statement describes suspected and known impacts of ATV access to basin moose and caribou herds. It also acknowledges that road access will increase the potential for additional hunting pressure. As stated by the Alaska Department of Fish and Game, in commenting on the EIS, that agency has the statutory authority and capability to control hunting pressure. 55This could conceivably happen, particularly during the early years following project completion while the river is still divided amongst a series of braided channels. However, the river is expected, through regulated flow and elimination of high flood stages, to eventually assume a basically single, meandering channel. When this occurs, with water having been concentrated in a single channel, the summer navigability of the stream might well improve. Concurrently 151 with this, downstream recreational opportunity may well improve during the summer months. Heavy sediment loads and high flood stages which now characterize the river during the height of the outdoor recreational season will be significantly diminished, thus making the area more attractive to general outdoor recreationists. ~(;As stated in the EIS, winter ice conditions are not expected to be significantly changed downstream from Talkeetna. Above Talkeetna the river may become more hazardous for winter travel. Such use above Talkeetna, at the present time, is minor. t»:7The extent of floatplane use is described in more detail in a pre- vious paragraph entitled Air. The terms "minor" and "common" are relative in context. In comparison to known areas of common or high floatplane use in Alaska, such use in the Upper Susitna Basin is considered to be relatively minor. ~3 Again, "very little" is a relative term. The use of ATV's and floatplanes by hunters, fishermen, and other recreationists in the remote setting of the Upper Susitna Basin is miniscule compared to areas near human population centers where easy access is provided by roads. The first half of this comment is not clear as to what is meant by "implies." It is agreed, however, that minimal sheep and goat hunting along the Denali Highway may well indeed be the result of minimal populations. {,!)This section has been updated to reflect the current status of lands affected by the project. The status of filing on these lands is not cogent at this time, since exchanges presently proposed are subject to an amendment to PL 92-203 and possibly to Alaska statutes. fJ~ This is a purely conjectural statement. No such assertion has been made by any of the responsible fish management agencies, since such a determination can only be made based on detailed studies, which are currently underway. It would be just as valid to state that the opposite condition could occur; i.e., alteration could improve overwintering capability of the main stream . . ., b.·"' Comment noted. tv:l Comment noted. ~ l There appears to be a conflict between the first sentence of this paragraph which states: " ... alteration of stream velocities affect swimming performance of fish and utilization of their food supply introducing stress and mortality."--and subparagraph 4 of the previous paragraph which states: "With increased flow, there would be no impact on fish 1 ife, adverse or beneficial.'' The content of the remainder of this paragraph is noted. 65The statement has not been modified. Comment noted. 66 Comment noted. 67The subject of reduced discharges during the summer months as related to recreational transportation (navigation) is discussed in response to an earlier BLM comment. ~Je agree that if lands in the project area are turned over to the Natives, recreational usage in the Upper Susitna Basin will likely be restricted, and that if a new State capital is constructed close to the Susitna River, recreational demand will increase. The project, by providing public use on lands which would otherwise be restricted to such use by Native ownership, will contribute significantly to the recreational needs of people living in the new capital. 68 The visitation figures were developed by a private consultant in coordi- nation with the Bureau of Outdoor Recreation and the Alaska Division of Parks, and are included in the Recreation Section of Appendix I of the feasibility report. 6~ Comment noted. 70 Comment noted. 71 Comment noted. 7 2 The sentence referring to "probable" wilderness classification is accurate. 73 It is stated in the EIS: "Degradation of visual quality in general would be a major adverse effect of project construction. This would be attributable primarily to roads, dam construction, right-of-way clearing for the transmission line, and the obtrusiveness of the transmission line itself." No meaningful qualification as to what extent roads and transmission lines will impact upon esthetics can be made, since such impacts are wholly subjective in nature, and are dependent upon each individual's sense of what constitutes esthetic impairment. 7 ~ Comment noted. 75 See response number 49. 76 Coal and other hydroelectric alternatives, including Lake Chakachamna, are sufficiently addressed in the EIS to explain why they were not selected as the recommended plan. Development of the Beluga Coal Fields may indeed be developed regardless of the presence or absence of the Upper Susitna hydroelectric project. 153 77 On the contrary, there are existing flooding problems along the Susitna River which require control. One involves the town of Talkeetna which is being threatened by riverbank caving, and the other involves nearly annual damage to the Alaska Railroad tracks. "Benefits" from flood control are indeed small, thus very little of project benefits are attributed to it (0.03 of 1 percent of average annual benefits). 78 The EIS makes it perfectly clear that the depicted transmission corridors are all alternatives which were considered and all but one of which were rejected. There are no transmission line planned for construction in relation to this project which would pass through the Copper River Basin. 154 United States Department of the Interior NATIONAL PARK SERVICE IN REPLY REFER TO: Alaska Task Force 524 West 6th Street, Room 201 Anchorage, Alaska 99501 November 11, 1975 Colonel Charles A. Debelius District Engineer Alaska District Corp of Engineers P.O. Box 7002 Anchorage, AK 99510 Dear Colonel Debelius: We have been asked to submit our comments on the draft environmental statement, "Hydroelectric Power Development, Upper Susitna River Basin, Southcentral Railbelt Area, Alaska" directly to your office. Our comments are as follows: A section should be included to show projected future power require- ments of the railbelt area. This section should provide a comparison of existine requirements and projected needs. The impacts concerning recreational opportunities need expansion. In a land of so many natural lakes it seems that a reservoir of the proposed design (long and narrow) would be of little recreational attraction. The attraction would be the fish that were planted and the facilities provided (which could be done for natural lakes, thus not requiring the project). The document states that very little recreational use is now made of the upper Susitna basin. Future needs (1986) should be shown. This area will receive increased pressure by 1986 and will be significant when the Susitna flats are further developed. The summer draw down of the Watane project will impair the recreation use of the project and leave a barren area which will not be ~vailable for any use or provide wildlife habitat. Does this activity balance the loss of white water and river boating due to the impoundments? Aside from access to a previously primitive area, how do the recreational improve- ments compliment or blend with those of the region e.g •• Mt. McKinley National Park and Denali State Park? How was the figure of 77,000 potential visitors arrived at? The power line should not be built to Fairbanks. Such an approach I would eliminate the severe impacts of such a line through the Broad . [. . ·-~·--"4.~·:._,.) 82 83 84 85 86 Pass area and the Nanan~ Canyon. Why is it necessary to transmit ?Ower north to the Fairbanks area? The esthetic damage caused by transmission line construction should be more carefully examined. Consideration of underground lines in certain stretches should be carefully considered. Economic costs should not be the only consideration for those sections where ethetics are most important. 6.02 Alternatives All alternatives need expansion. On page one of the draft EIS, the resolution states in part an investigation of "any competitive alternative.'1 Can this really be done if on the one hand oil and 1 gas alternatives are dismissed in view of a "national effort,11 and coal is discounted on the basis of extensive adverse envi~ental impacts even though statements such as on page 71 i~icate-~ extensive studies of the impact of coal m~ning have not been conducted. An alternative consisting of the development of several sources combined to produce the power requirements of the State should be considered. 6.02.2 Coal It should be stated that the Healy Coal fields have been developed and that the strip mining damage in this area has been taking place for a number of years. Roads from the Healy coal fields have been built and the transporta- tion problem is minimal when the generating plant is adjacent to the coal source. Higher local employment will be realized by develop- ment of coal energy sources. 6.02.3 Oil and Natural Gas I These fuel sources need to be considered in more detail. available in the Fairbanks area by 1986 and what are the benefits in relation to the $1.343 billion 1975 required dam project .. 6.04.2 Devil Canyon What will be cost for the two This alternative should be more carefully examined. Even with a l'ow firm energy capability it appears that this project would produce power during the season when it is most needed. The impacts from this single dam project are minor as compared to the two dam project. Less transmission line construction would be required with this alternative combined with other projects. This project appears to have the highest recreation potential. We recommend that the question of environmental impact versus cost benefit of development for a number of energy sources be explored. 2 156 - I Not enough discussion of the intertie and the secondary social- economic impacts of the intertie, i.e. encouragement of strip development all along the power line. Do we really need/want an intertie in Alaska? How much energy is lost through transmission lines? Water for domestic/agricultural use will soon be in short supply. How does this use of water fit in with long range water needs. Under section 4.0 the impact of the material sites to construct the dams has not been evaluated. Gravel, limestone for cement, and earth for land fill if taken from sites not be to flooded will have a major impact on the areas esthetics and important sightseeing use. 189 If local limestone is used to make the cement necessary for the ~() Devil's Canyon Dam, this will create scar~ on the landscape and considerable air and noise pollution in an area critical to the visitor to this Mt. McKinley region. Limestone sources near Cantwell if utilized and processed there would create visual and air pollution impacts to the Mt. McKinley National Park visitor, as well as the residents of Cantwell. This impact must be evaluated and mitigated in this EIS. AGHenson: jkm Sincerely, Albert G. Henson Project Leader 157 RESPONSE TO COMMENTS BY U.S. DEPARTMENT OF THE INTERIOR NATIONAL PARK SERVICE ALASKA TASK FORCE 79 An entire section (2.04) is devoted to a discussion of energy needs. Figure 9 is a graph which illustrates a five-year record of energy consumption (1970-1974) plus projected load growth through the year 1999. 80 Recreation is not the purpose of the reservoirs. However, they will inevitably attract some visitation for recreational purposes. Recrea- tional usage, as estimated in the EIS. is claimed as a project benefit, but its contribution to project justification is infinitesimal--being less than 0.2 of 1 percent of total project benefits. 81 The reservoirs, either directly or indirectly, afford more recreational opportunity in the Upper Susitna Basin than would otherwise exist, both as a result of the flatwater recreational opportunity afforded by the reservoirs, and access provided by the road system which will be necessary to construct and operate the project. Most of the reservoir recreational visitation will be associated with the Devil Canyon site. Watana will be much less attractive as a result of its drawdown. The loss of white water, itself, cannot be measured in terms of trade-offs to recreational uses afforded by the hydropower project. Recreational uses of the white water, on the other hand, can be directly related_to post-project recrea- tion. Present and future boating uses of Devil Canyon would not begin to compare to other forms of recreation uses in the Upper Susitna Basin (primarily hunting and fishing), with or without the project. The visitation estimate was provided by a private consultant who closely coordinated his procedures and methodology with the Bureau of Outdoor Recreation and the Alaska Division of Parks, and is included in the Recreation Assessment section, Appendix I, of the feasibility report. 82 The purpose of the hydropower project would be to provide projected energy load requirements to the Southcentral Railbelt area and parti- cularly to the two large demand centers of Fairbanks and Anchorage. The esthetic impact of the transmission line will be carefully examined, and every effort made to minimize its visual impacts in determining the exact alinement of this facility. Consideration of underground cables has been made, and a discussion of this alternative has been added to the EIS. 83 Achievement of national energy goals was not the only criterion upon which the selection of the hydropower alternative was based. Neither were environmental impacts the sole basis for the rejection of the coal alternatives. Economic factors played a larqe role in these determinations. 158 84 The development of coal as a means of producing electrical power was the economic standard against which each of the hydroelectric plans was tested. That is, the power benefits used in computing the benefit-to- cost ratio represented the cost of producing the same amount of power by constructing and operating a generating system using coal as the fuel. For purposes of simplification and more direct comparability to each hydro system alternative evaluated, a single large coal-find complex located in the Healy area was utilized. The Healy Creek coal district has available reserves approximately equal to the energy production requirements of the lOO~year period of analysis. Since this coal field has already been developed for this very purpose, it is a logical choice for comparison. Socioeconomic impact would develop each time a generating facility was constructed in the area, but the overall permanent jobs arising from operation would have a minimal effect on the overall economy of the area. 85 Oil or natural gas, from whatever source, is expected to be an expensive source of energy in the future. A major consideration in the hydropower proposal is the conservation of nonrenewable resources. The benefit/ cost ratio of the proposed hydropower project would be comparable to near future oil and natural gas alternatives. 86 As stated, the project--by itself--has a low firm energy capability and, therefore, is not economically viable when compared with the economic standard of coal. That is, in order for the project to pay for itself, the wholesale mill rate would be greater than that of an alternative coal system. A fluctuating pool has less recreation potential than a steady reservoir as proposed in the selected plan for the Devil Canyon facility. This alternative is discussed in Section 6.04.02 of the EIS. 87 During the process of plan formulation, the objective of Environmental Quality was considered along with the objective of National Economic Development in the development and evaluation of alternative plans, as prescribed by the Water Resource Council's Principles and Standards. Thus, environmental impacts were weighed against the monetary benefits for each of the alternatives explored. 8b The discussion of the transmission systems has been expanded in the EIS. Since essentially all of the corridor system traverses either.public lands or lands which may be assigned to the Natives, there should be no significant potential for uncontrolled "strip" development. An intertie is essential if the proposed hydroelectric project is constructed. It also has other advantages related to reliability of energy supply to the State's two largest load centers. Average energy loss through the transmission lines will be 0.7 percent of the total energy transmitted, but the 6.1 billion kilowatt-hours of firm annual energy is the net energy available at the delivery points near Anchorage and Fairbanks. 89 Should the proposed plan be implemented, the summer flows of the Susitna River will be regulated, and water in excess of summer power needs 159 will be stored for release during the fall and winter months. There would not appear to be any future water supply shortages for domestic/ agricultural use in the Lower Susitna River Basin, and the proposed dams only temporarily store the water for hydroelectric_ power generation. 90 Restoration of material borrow areas outside the reservoir pools will be conducted to blend the sites into the surrounding area as much as possible to minimize the esthetic impact. In compiling the construc- tion costs for all alternatives, the utilization of cement manufactured outside of Alaska was used. If local areas are developed as limestone sources, appropriate measures will be taken to minimize the adverse impacts of such action. 160 United States Department of the Interior NATIONAL PARK SERVICE IN REPLY REFER TO: L7619 (PNR)CAE Pa~ific Northwest Region Fourth and Pike Building Sculllc, W:t~hin!!;lon !JHIOI October 22, 1975 Colonel Charles A. Debelius District Engineer Alaska District, Corps of Engineers P.o. Box 7002 Anchorage, Alaska 99510 Dear Colonel Debelius: We have reviewed the draft envirorunental impact statement for Hydroelectric Development, Upper Susitna River Basin, Southcentral Railbelt Area, Alaska, and have the following comments. We are quite concerned about the possibility of an above-ground, high-voltage power line paralleling the eastern boundary of Mount McKinley National Park. The statement does not give specific information on routing, tower design, or vegetational and scenic (')1 impacts, so it is difficult to determine t~e extent of impacts on the ~ Park and its visitors. We request that contact with our office in Anchorage be maintained regarding the progress of this project and that we be informed of decisions regarding the Cantwell to Healy transmission corridor. We feel that the alternatives for power transmission corridors on page 89 are inadequate. Firstly, underground systems are not considered--especially in the Cantwell to Healy section. Certainly the cost for underground lines would be more, but the statement should weigh economic considerations against the other impacts involved. Impact on scenic values near Mount McKinley National Park and in the Nenana Canyon will be substantial, and thus we feel that undergrounding must be seriously considered. The second reason we consider the alternatives for power transmission corridors inadequate is that there is no analysis of impacts. Figure 15 graphically presents the alternatives. The text then states that the proposal was selected on the basis of cost, reliability, and potential environmental impact, but none of the needed information is presented. An envirorunental statement should present enough informa- tion for the reader to understand why the proposal was selected over the alternatives. ~o\..\JTJO.y ~Q;-~o~~ "( '-l ~ m !:(. <: ~ ~ .... .>-~ T;>?6-191 10 161 93 9 11 cHh.i.n which was i.dentific:d by the Alaska Division of Parks and would ' The National Register Criteria (36 CFR 800) should be applied to the ~ be inundated by the Watana reservoir. These procedures were printed . in the Federal Register of February 4, 1g75, and should be consulted. Sincerely yours, Edward J. Kurtz Acting Regional Director t62 J RESPONSE TO COMMENTS OF THE NATIONAL PARK SERVICE PACIFIC NORTHWEST REGION ~JLA map has been added to the EIS which more clearly indicates the location of the transmission line corridor. The exact alignment within this corridor, and tower design, have not yet been determined, but esthetic impacts will be a primary consideration in powerline location and tower design. In any event the transmission line will be located on the east side of the George A. Parks highway and the Alaska Railroad through the Broad Pass--Mount McKinley National Park area, and every effort will be made to either entirely conceal the line or minimize its visual obtrusiveness. The National Park Service will be kept fully informed of decisions regarding the Cantwell to Healy segment of the transmission line corridor. ~~The EIS has been expanded to include a discussion of underground cables as an alternate made of transmitting electricity. Economic considerations will not be the basis for selecting overhead trans mission lines in lieu of underground cables. Other factors which will be considered include environmental impacts, technical problems, maintenance, and reliability. S:JThe EIS has been expanded to include a discussion of the relative impacts of the alternate transmission line corridors. ~~As stated in the EIS, the current National Register of Historical Places was consulted, and revealed no National Register properties which would be affected by the project. National Register criteria (36 CFR 800) will be applied not only to the cabin identified in the preliminary reconnaissance study made by the Alaska Division of Parks under contract to the Corps, but to the entire area affected by the project. This includes thorough archaeological and historical surveys along all access road routes, transmission line corridor, and the dam and reservoir sites. 163 UNITED STATES DEPARTMENT OF THE INTERIOR BUREAU OF OUTDOOR RECREATION NORTHWEST REGION IN REPLY REFER TO: \0°0 ssca••n ovsN' •s 95 96 E3027 913 SECOND AYINUIE, RM. 990 5 5 'Tlfls.. UUA8111tl.'f'8t' OSUQ4 Sf.AtTLI, WASHINGTON 93174 Colonel Charles A. Debelius District Engineer Alaska District, Corps of Engineers P.O. Rox 7002 Anchorage, Alaska 99510 Dear Colonel Debelius: NO'-' ' ~ 1S15 The Draft Environmental Statement, ••Hydroelectric Power Development, Upper Susitna River Basin, Southcentral Railbelt Area, Alaska," has been received in this office for review and comment. The following comments are provided for your consideration. We recognize that environmental studies are not complete; nonetheless, we would like to mention two subjects which we feel should be covered in more detail. I The whole subject of roads to the hydroelectric developments, to the recreation facilities, and to and along the transmission corridor has not been adequately addressed. Locations and impacts of roads whether per- manent or only for the construction period need to be discussed in greater detail. IThe intrusion of man as construction worker and later as recreationist may have significant impacts on the ecology of this area. The effect of man and his rnachint~s and the impacts associate::! should be discusse(f in greater detail also. I It should be noted that this is the view of our office and does not 9 rJ f necessarily represent the official view of the Secretary of the Interior. We appreciate the opportunity to comment and hope our comments will assist in the preparation of the final statement. Sincerely yours, Maurice H. Lundy 164 ;;;;;:;:z;y~ - RESPONSE TO COMMENTS BY U.S. DEPARTMENT OF THE INTERIOR BUREAU OF OUTDOOR RECREATION ~t)Specific location of roads, both permanent and temporary, has not been determined at this stage of planning for the proposed projects. Detailed planning and design for this transportation network will be accomplished in the post-authorization stage. A proposed road corridor has been identified for the approximate 64-mile road to the Watana damsite (Figure 4). Location, design, construction, rehabilitation, and maintenance of the project road system will be given prime consideration with the utilization of good landscape management practices. When the specific road system has been developed, this system and its related impacts will be discussed in future supplements to the statement. ~('The opening up of the Susitna Basin to man and his machines is ...... } considered one of the major adverse impacts of the proposed pro- jects. This action will increase the need for institutional regulations in an area that presently has few to control activities that would be magnified because of easy access. This, in turn, will have both social and economic impacts in that man may not be able to do things in the future that he was used to doing in the past, and would cost more because of the need to enforce the regulation to protect the environment. 97 Noted. . ~ r..:..s ...Jt •. v 98 100 -~ U. 5. DEPARTMENT OF TRANSPORTATION FEDERAL HIGHWAY ADMINISTRATION Room 412 Mohawk Building 222 S.W. Morrison Street Portland, Oregon 97204 November 24, 1975 Colonel Charles A. Debelius District Engineer Alaska District, Corps of Engineers P. 0. Box 7002 Anchorage, Alaska 99510 Re: Draft Environmental Impact Statement Hydroelectric Power Development Upper Susitna River Basin Southcentral Railbelt Area, Alaska Dear Colonel Debelius: IN REPLY REFER TO 10ED.3 We have the following comments on the above DEIS which you may wish to consider: 1. The report depicts that the general choice of the routes to place the transmission lines is within the existing highway corridor from Summit to Healy. At present, there is nothing to mar the pristine beauty of the valley except for the railroad on one side and the highway on the other. The Nenana River meanders through a pass in the Alaska range. The beauty is stunning viewed from both the railroad and the highway. To add a transmission line through this corridor would certainly destroy the unusual natural beauty. The Broad Pass area south of Cantwell is without trees and transmission lines would be difficult to hide. We have noted there is no mention of the recent archeological find near Carlo Creek. You may wish to include this in your discussions on page 93. 3. A discussion of impacts to the existing highway system that may occur as a result of this project is needed. This should include the potential need for reconstruction or added maintenance costs resulting from transporting necessary construction materials. Also, any hazards to traffic that m&y occur during construction should be discussed. We appreciate the opportunity to comment on this draft EIS. 166 Si~~ly_yours, ~:~~c//!ct:~~f~u·/-~Richard C. Cowdery, Direc~ Office of Environment and Design RESPONSE TO COMMENTS BY U.S. DEPARTMENT OF TRANSPORTATION FEDERAL HIGHWAY ADMINISTRATION 98 Comment noted. 99 100 The recent archeological find near Carlo Creek was excavated in a road cut on the Parks Highway near Mt. McKinley National Park. The remains of both fossils and artifacts were found in this buried site. Thorough archeological reconnaissance will be made of the entire transmission line corridor prior to establishing the exact alinement of the transmission line. It is expected that most sites can be avioded by judicious alinement. If and where this should be impossible, appropriate salvage or other mitigative measures will be taken. The total impact of this project on the existing highway system has not yet been evaluated. the impact would include additional vehicle travel due to the project construction phase. Only a mod- erate increase in vehicle traffic over normal highway travel due to the use of project facilities is expected after project construc- tion. Studies required to evaluate the potential need for recon- struction or added maintenance costs will be made during the detailed planning phase. No such needs have been identified during the feasibility stage of planning. Impacts on the highway system, overall, should be minor. 1617 rorm ::..ur r 1320.1 (1-67) Memorandum DATE, Hydroelectric Power Development, Upper In reply SUBJEC1, Susitna River Basin, Southcentral Rai1belt Area, reler lo, Alaska FROM TO Secretarial Representative, Region 10 District Engineer Corps of Engineers Anchorage, Alaska OFFICE OF THl StCRL lM\' November ll, 1975 Attached is the only comment received from DOT agencies on the subject EIS. ~ Regional Representative of the Department of Transportation, Region 10 Attachment 168 DEPARTMENT OF TRANSPORTATION UNITED STATES COAST GUARD From: Commander, Seventeenth Coast Guard District MAILING AI:)ORESS: COM MANDER { fin l \ 17TH COAST Gl.fAl#b OISTRICT FPO SEATTLI: 11771 l October 1975 To: Secretarial Representative, Region 10, Seattle, WA. Attn: CAPT R. T. BROWER Subj: Review of EIS for Hydroelectric Power Development, Upper Susitna River Basin, Southcentral Railbelt Area, Alaska; comment concerning 1. Subject EIS has been reviewed and the only significant Coast I Guard impact waul d be the increase in recreati anal boating activity 101 on the newly created lakes behind the dams. No other areas of Coast Guard interest were revealed. By 169 101 Comment noted. RESPONSE TO COMMENTS BY U.S. DEPARTMEflT OF TRANSPORTATION COAST GUARD 170 DEPARTMENT OF THE ARMY U.S. ARMY COLD REGION~ RESEARCH AND ENGINEERING LABORATORY HANOVER, NEW HAMI-'SHIRE 03755 CRREL-RE 12 November 1975 SUBJECT: Review Draft Susitna Impact Statement District Engineer U.S. Army Engineer District, ALASKA P.O. Box 7002 Anchorage, AK 99510 1. USACRREL staffs both in Fairbanks and Hanover have reviewed the Draft Environmental Irn:pact Statement, "Hydroelectric Power Development, Upper Susitna River Basin, Southcentral Railbelt Area, Alaska." We find the report a comprehensive assessment of the proposed project and one which deals realistically with the adverse environmental effects. 2. Our comments are more specifically directed at questions requ1r1ng further investigation and which should be kept in mind as the project develops. These are briefly stated: a. The influences and constraints of permafrost at the dam sites for design purposes and in the reservoirs, particularly as related to erosion along shorelines. The need for proper assessment of permafrost conditions and how the impoundment will modi~ ground temperatures is apparent. b. The influence of a fluctuating river level below Devil Canyon on winter ice formation. Ice production is likely to increase as a result of the fluctuating water levels (breaking up of the ice cover due to peak power releases). This may cause down river ice problems due to natural or man-made obstructions. c. The production of frazil ice i~ the white water section of Devil Canyon and earlier ice formation in the reservoir. These· may result in restricted flow conditions and greater ice formation in the impoundment. d. The change in reservoir and down river water qualities particularly under winter, ice-covered conditions. The question of modified sediment load and its significance to both fish productivity and flood plain ecology requires additional investigation. 171 102 103 l CRREL-RE 12 Ncwember 1975 SUJ!JE~: ?.eview Draft Susi tne. Impact Sta:.c:··ent e. Modification in flood plain and reservoir shoreline vegetation as a source of high quality forage for moose and waterfowl and methods to reduce adverse visual impacts. The question of large, seasonal fluctuation in the Watana impoundment and how to stabilize the shoreline for wildlife and recreational use and erosion control requires further investigation. f. Site investigations related to transmission line corridors. These are required to resolve questions of large mammal impacts and optimal restoration techniques for erosion control and visual impacts. 3. We also ~ote an apparent discrepancy ~n the calculation of the annual production of 3.0 billion KWH for the Devil Canyon (180MW/440Q cfs/Francis l unit is given on p. 3; on p. 45, Table I, average regulated flow is approximately 4200cfs/month; 9200cfs/4400cfs/l80MV :::::: 376MW per month or 4.5 billion KWH per year). Is this a real difference or due to assumptions made in arriving at the 3.0 billion figure? 4. I look forward to receiving copies of,the final statement and in pro- 1viding the District with continued input from our staff. 2 172 RESPONSE TO COMMENTS BY DEPARTMENT OF THE ARMY CRREL jL()~ The Corps generally concurs with the needs for further investiga- ~ tions as itemized under paragraph 2 of the CRREL letter. All necessary additional engineering and biological studies will be conducted during the pre-construction stage of planning. 103 The 4,400 cfs relates' to the maximum discharge per each 180 mw (name plate) unit, and in no way enters into the energy potential of the river. The actual dependable capacity of each unit is roughly 171 mw based on the firm annual energy and a 50 percent plant factor. It must be realized that only under peak load re- quirements or heavy reservoir inflow would all 4 turbines be operated simultaneously. For example, if all 4 turbines were . ·operated at full overload capacity for an entire year (4 X 180 mw X 1.15 = 828 mw), the energy produced would be 7.25 billion kilowatt hours of energy. By applying the Devil Canyon maximum head to the basic power equation, the resulting average monthly streamflow required to produce the hypothetical 7.25 BKwh energy would be in excess of twice the average monthly streamflow of 9,200 cfs. Subsequent estimates of dependable capacity based on average annual evergy have resulted in a re-sizing of the Devil Canyon units to 194 mw, each with a maximum hydraulic capacity of roughly 6,200 cfs. . I U.S. EN VIR 0 N M'E NT A L P R 0 T E C T I 0 N AGENCY I ' REGION X 1200 SIXTH AVENUE SEATTLE, WASHINGTON 98101 REPlY TO AnN of, lOFA -M/S 623 November 13, 1975 104 Colonel Charles A. Oebelius Department of the Army Alaska District, Corps of Engineers P. 0. Box 7002 Anchorage, Alaska 99510 Dear Colonel Debelius: We have completed review of your draft environmental impact statement, "Hydroelectric Power Development, Susitna River Basin" and submit the following comments. The increased river turbidity during the winter months caused by releases from the reservoir is of particular concern .. The statement, on page 46, says "preliminary studies by the Corps of Engineers indicate that the suspended sediment would be at low levels {15-35 ppm)." These levels of suspended sediment are sufficiently high to warn of potential violations of water quality standards. These Joint Feder,al-State Water Quality Standards (18AAL· 70.020) limit suspended solids by prohibiting deposits which adversely affect fish and other aquatic life reproduction and habitat. The standards limit turbidity to less than 5 Jackson Turbidity Units (JTU) above background. We recognize the high natural suspended solids l~ad carried by the Susitna River. During the winter, however, the Susitna contains relatively clear water. The absolute value of the solids level is not as important as the change in timing of the higher solids level from summer to winter. The magnitude of this change and potential standards violations should be discussed in the final impact statement. I Another concern would be possible altered temperatures due to releases from the reservoir. According to the statement, by using multiple level discharge outlets, the temperature of the released ,water could be made to approximate natural conditions. We are interested i'/4 I 2 in the operational details of this procedure. How will natural tempera- tures be established once the project is in operation? . .The discussion of supply and demand of electric power on pages 40 and 64 implies no large excess of power not needed by the projected population increase. That is, no large amounts of power~would be available to promote large scale industrial projects with their secondary environmental effects. A more quantitative d1scussion is needed to show the approximate equivalence· of future demand and supply of energy. Under "Sedimentation" on page 62 mention is made of deposits of heavier sediments in the upper reaches of the Watana reservoir. Would the higher drawdown at Watana combined with gradual bottom slope and sediment accumulation form large mud areas devoid of vegetation? Would these areas tend to increase as the age of the project increased? These questions and possible remedies need to be addressed. Additional environmental studies are promised when congres~ional authorization for the project is obtained. Because of the present insufficiency of information in some areas, the statement is not adequate for review purposes at this time. Consequently, we are classifying our comments on this project as ER-2 (Environmental Reservations- Insufficient Information). The ER rating is based on the potential violation of Water ~uality Standards. This issue must be addressed in the final sta~eent. The Insufficient Information rating is based on the anticipated·~uture studies. This classification of the Environ- mental Protection Agency's comments will be published in the Federal Register in accordance with our responsibility to inform the public of our views on proposed Federal actions. !" Our rating of the project relates solely to its water quality aspect's and does not indicate either our opposition or support. The Environmental Protection Agency's responsibility is to make certain that adverse impacts within our area of expertise are clearly documented. Thank you for the opportunity to comment on this draft environmental impact statement. If you have any questions concerning· our comments or categorization procedures, please let us know. · Sincerely yours, () {.di~-v .D ~ (..: -zr~-vJ Walter D. Jaspers Director Office of Federal Affairs 1.75 lios 06 1107 :tos RESPONSE TO COMMENTS BY U.S. ENVIRONMENTAL PROTECTION AGENCY REGION X 104 Due to the sediment retention characteristics of the reservoirs, suspended sediments downstream from the Devil Canyon Dam would be significantly reduced overall. This reduction would be most apparent during the summer months when glacial melt results in extremely high sediment loads. This presently occurs during the salmon spawning period, when siltation and turbidity are likely the most critical to aquatic life reproduction and habitat. The EPA estimated increase in turbidity during the winter months may be high. These estimates of 15 to 35 ppm in the releases at Devil Canyon Dam are based on measured suspended sediment concentrations below glacial-fed natural lakes in Alaska, including rivers flowing from Skilak, Tustumena, Eklutna, and Long Lakes. The proposed projects will have multiple-level discharge outlets which will permit selective withdrawal of outflows from a range of reservoir elevations. As stated in Section 4.01 of the EIS, sediment samples taken by the Alaska Department of Fish and Game during the winter of 1974-75 in the Susitna River between Gold Creek and Talkeetna indicated a range of 4 to 228 ppm. 1U 5 One of the major reasons, along with control of oxygen content, for incorporation of multiple-level discharge outlets into the dam structures is to provide for temperature regulation of water released from the reservoirs. Since there will be thermal stratification in these deep pools throughout the year, water can be released from various heights, or combination of heights above the 11 dead" storage space, to provide a mix of waters approaching natural streamflow temperatures. 106 See response number 255. 107 The answer to both questions is "yes." These are phenomena charac- teristic of any reservoir receiving heavy sediment loads and having significant periodic drawdown. Mudflats would become most extensive in areas immediately above the low-water pool. As the water level falls from the high pool elevation, much of the sediment accumulated within the inundated streambed would be flushed down into the reservoir. Lands immediately above the low pool elevation would become inundated too early in the spring for plant growth to establish. However, the higher elevations within the drawdown area would probably develop a growth of annual grasses and forbs prior to being inundated late in the summer or early fall. 1 (; 8 Comments noted. 17b FEDERAL POWER COMMISSION REGIONAL OFFICE 555 BATTERY STREET, ROOM 415 SAN FRANCISCO, CALIF. 941 I 1 Colonel Charles A. Debelius District Engineer Alaska District, Corps of Engineers P. 0. Box 7002 Anchorage, Alaska 99510 Dear Colonel Debelius; December 4, 1975 We have reviewed your Draft ~~vironmental Impact Statement on the Hydroelectric Development Upper Susitna River Basin, Southcentral Railbelt Area, Alaska, dated September 1975. These comments of the San Francisco Regional Office of the Federal Power Commission's Bureau of Power are made in accordance with the National Environmental Policy Act of 1969, and the August 1, 1973, Guidelines of the Council on Environmental Quality. Our comments are primarily directed toward the need for power that would be produced by the Upper Susitna Development, the alternative power sources, and the fuel situations relative to non-hydroelectric power alternatives. The recommended plan is to construct dams and power plants at the Watana and Devil Canyon sites and electric transmission facilities to the Railbelt load centers. The proposed plan for the Watana site would include the construction of an 810-foot high earthfill dam and power plant which ·would contain three Francis turbines with a nameplate capacity of 250 MW each. The firm annual generation would be 3.1 billion kWh. Development of the Devil Canyon site would include a 635-foot high thin-arch dam and power plant with four Francis turbines, each rated at 180 MW. The firm annual generation would be 3.0 billion kWh with regulated streamflow from Watana storage. The electrical power generated would be transmitted to the Fairbanks -Tanana Valley and the Anchorage -Kenai peninsula areas. The recommended development is shown to be economically feasible. 177 - 2 - (1) The Need for Power We agree with and endorse the subject report's assertion in Section 2.o4 ~ that substantial amounts of new generating capacity will be needed to meet future power requirements of the Southcentral Railbelt area. Recent studies ·~ of the Sou::;hcentra.l and Yukon region (which includes the Southcentral Rail- belt as its main component) , as defined in the 1974 Alaska Power Survey Report o~ the Executive Advisory Committee, indicate that rapid rates o£ increase in power requirements will continue at least for the balance of the 1970's, re£lecting economic activity associated with North Slope oil development and ex.p&nsion of commercial and public services. Estimates beyond 1980 reflec·G a range of assumptions as to the extent of future resources use and industrial and population growth. All indications are that accelerated growth wi::Li continue through the year 2000, with economic activity generated by North Slope oil' and naturaJ. gas development being a major factor -but only one of several important factors. It is generally considered that the Southcentral-Yukon regional population will continue to grow at a faster rate than the national and state averages, that fUture additional energy systems and other potential mineral developments will have a major ef£ect, and that there will be notable expansion in transportation systems. Signi- ficant economic advances for all of Alaska and especially for the Alaska Native people should be anticipated as a result of the Alaska Native Cl.a.ims Settlement Act. Other influencing factors could be cited, but the general outlook is for :f'urther rapid expansion of energy and power requirements in the Southcentra.l-Yukon area. A range of estimates for future power requirements of the Southcentral and Yukon regions is presented in the 1974 Report of the Alaska Power Survey Technical Advisory Committee on Economic Analysis and Load Projections. The range of estimates attempts to balance a myriad of controlling tactors including costs, conservation technologies, available energy sources, types of Alaskan development, et cetera. The higher growth range anticipates significant new energy and mineral de~lopments from among those that appear more promising. The lower growth r~e generally assumes an unqualified slackening of the pace of development f'ollowing completion of the Al.yeska pipeline and, in our opinion, is not considered realistic. The mid-range growth rate appears to be a reasonable estimate which we adopt as most repre- sentative based on recent manifestations and our assessment of future condi- tions. It should be noted that there are several re~onsible advisory committee members who feel that recent acceleration of mineral raw material shortages of all kinds indicates a possibility that ~n the high range estimates could be exceeded. Table 1, which is a co~nsed extract of information contained in the aforementioned advisory co~ttee report, summarizes load estimates for the Southcentral and Yukon Regltns. Indicated load increments by decade are as follmvs: 1.78 - Higher E:stima.te Mid-Range -1 - Increments of 3outhcentral-Yukon Power Requirements 1972-19f10 ~ea...k; "Jema..nd MH 8B8 l'umual Energy GWh 4 623 3 093 19no-~990 Pea.'. MnwU Demand 2nergy MW GWh 4 460 28 llO 930 4 570 19CX>-2000 i~&,_, Am\ 1 ll!\l Demand 2nergy 1>M GWh 2 800 13 070 1 950 10 240 1972-2000 1~1\ Al~;;f Dema.nd :Energy w GWh 8 148 45 803 3 518 17 903 According to the sub.j ect report, a total of 6100 GWh of firm annual energy would. be produced by the combined Devil Ganyon-Watana system which would have a nameplate capacity of 1!~70 W. Although the report does not indicate proposed commercial operation dates, based on information in our files the project would be staged and the initial Devil Canyon installation (3000 GWh and 720 M-1) could become operable in 1985 and the ultimate installa- tion in 1990. Under this timetable it is apparent that there is a need for power in the Southcentral-Yuk.on Region by 1985 and 1990 in the order of mag- nitude of at least as much as the proposed subject development. Therefore, operation of the proposed project would help meet the power needs of the Southcentral Railbelt area by 1985 and beyond. (2) Alternative Power Sources and Fuel Situation Our recent estimate of power values for the Devil Ganyon-Watana project indicates that the most economical alternative to the project's output would be power from a combined cycle generating plant using natural gas as an operat- ing fuel. We acknowledge the subject report's premise that there are many questions concerning fUture availability and costs of natural gas and oil for power production. It is the policy of this Commission to discourage use of natural gas as an operating fuel for power generation in the contiguous United States. Due to changes in requirements, other Federal and/or Sta~e agencies may impose restrictions on the future usage of natural gas and oil for electric power production throughout Alaska. Recognizing the undertainty of the fUture availability of natural gas and oil af'ter 1985 for new generat- ing capacity, the possibility of its restrictive use if available, and its sensitivity to worldwide pressures, coal may be the most likely alternative fuel for thermal-electric plants to be constructed in the mid-l980's and beyond. Essentially, we agree with the discussion of alternative sources of power in paragraphs 6.02.1 -6.02.10 of the subject report. 179 - 4 - (3) other Alternatives to the Proposed Action The Corps' ur:I Z discusses several potential alternative lcy,iroelcc lr .l.:: developments within the Southcentral Railbelt Area. All of these alternatives either have a greater adverse environmental impact than the proposed plan, or are not considered feasible at the present time. Attachment (Table l) Very truly yours, J!tf:!!f:. f7/~ / ~ . ·.. [.):;/ (Deputy) M. THOMAS (Acting) Regional Engineer 1.80 Region Southcentra1 Yukon (Interior) Tcta1 ~ (l) ~- Southcentra1 Yukon (Interior) Total TADLE 1 Totol PoHcr Requirements Southcentral and Yukon Regions l! Actual Requirements -. 1972 Estimated·Future Requirements 1980 1990 Peak Annua 1 Peak Annua1 Peaf~ 2000 Ann~,;e-1 Pea:< ·· Annua 1 Dem:J.nd· E!1ergy Demand Energy Demand Energy. O;;rr~nd :.ner;y tiM · .. G·~/h t·1H Gl·!h 1111~ GHh Jvl\~ G'd~ Higher Rate of Growth 317 , 4-65 990 5 020 5 020 30 760 7 190 40 810 115 542 330 1 610 760 3 980 1 390 7 ·"~'I . ....,"'...., 432 2 007 1 320 6 630'. 5 "780 34 740" 8·580 47 810 Likely Mid-Range Growth Rate 790 3 790 ., 530 7 400 3 040 1 r" ~1"\1"\ 0 "' ... .J ., 280 1 310 470 2 270 910 ·4 5~0 1 070 5 100 2 000 9 670 3 950 19 91 J ... '. 1J As defined in the 1974 Alaska Power Survey RESPONSE TO Cm1MENTS BY FEDERAL POWER COMMISSION REGIONAL OFFICE 1(;9Statements and corrrnents from the Federal Power Commission are noted, including the general agreement on power needs and alternatives. 182 ----.. STATE COMMENTS AND RESPONSES State of Alaska State Policy Development and Planning Department of Environmental Conservation Department of Commerce and Economic Development Department of Fish and Game Department of Natural Resources Department of Public Works 183 Coi11Tlents 110-111 112 -125 126-128 129-160 161 162-169 lAYS. HAMMOND, GOVERNOR STATE IILICY DErflOPM£111 AND PLANNING I'OIICH AD-JUNEAU 1911 t PHONE 465-JSit Colonel Charles A. Oebelius Corps of Engineers Distric~ Engineers Department of the Army Alaska District P.O. Box 7002 Anchorage. Alaska 99510 November 10, 1975 Subject: ·southcentral Railbelt Hydroelectric Project State I.D. No. 75091103 Dear Colonel Debelius: The Alaska State Clearinghouse has completed review on the subject project. The following agencies were invited to review and comment: State of Alaska Department of.Community & Regional Affairs Office of Planning & Research (H&SS) Deparbnent of Environmental Conservation Department of Fish & Game Anchorage Fairbanks Department of Highways Deparbnent of Law Department of Natural Resources Division of Lands Division of Parks Department of Public Works Department of Commerce & Economic Development Alaska Energy Office Division of Policy Development Five'of the above agencies responded and their comments are attached. IThe State does not object to this project at this time. however~ our final 110 position cannot be determined until a more comprehensive r.eview or this project has ·been completed by the State. 184 Colonel Charles A. Debelius - 2 -November 10, 1975 It is obviow; frpu; 11,,. l'"'·POI1~('5 n·•:1~iv,.d in !.!lis office that a great deal of additional Sludies will huvc lo ue dune before tl1c reul :111pact can be determined. The Governor has created a multi-agency State Task Force to conduct a thorough assessment of the Susitna River hydroelectric power development proposals. This group will make recommendations to the Governor on a number of critical aspects of the proposal, including an analysis of demand projections, al,ternate energy sources, growth impacts, and environmental effects. The Corps should consider this Task Force as its basic contact with the State on this project . . The Clearinghouse finds this project to be consistent with State long-range planning goals and objectives. Therefore, this letter will satisfy the review requirements of the Office of Management and Budget Circular A-95 •. Sincerely, =1.~~ State-Federal Coordinator Attachment cc: Commissioner Langhorne Motley 185 111 _, If'·; .. 110, 111 RESPONSE TO COMMENTS OF STATE OF ALASKA STATE COVER LETTER Subsequent to receipt of the Alaska State Clearing House letter of 10 November 1975, the Corps met with the Governor·•s multi- agency State Task Force on 12 December 1975. This group was established to conduct a thorough assessment of the Susitna River hydroelectric power development proposal, and to make recommend- ations to the Governor on a number of criti~al aspects of the project. The purpose of this initial meeting, which was considered very fruitful by Task Force members, was to provide a more comp- rehensive review of the project. Subsequent coordination will be conducted with the Task Force to provide them with additional information on which to base their recommendations. Detailed studies will be conducted in the future to evaluate, in depth, the impact of the project before recommending funding of construction should the additional studies indicate the project is still viable. 186 'MEMORANDUM State of Alaska -. I. \ I . .., TO: FROM: , r ~ '•-· ;· • • I ~ ( ., , I d , I. ,' ~.·1 ·,-~ Raymond \v. Estess State-Federal Coordinator Division of Pol~cy Development : ( : ;~ _. ~; t .. I ' DATE: November 3, 1975 1 • • : .. l:~ ··, ; : o / if ~~r.J/. ~-· ·-~. .,~_:;-:;i "~- .,-and Planning FILE NO: Office of the G~ TELEPHONE NOo Ernst W. Hueller ~ SUBJECT: Commissioner Department of Environmental Conservation . .. ... .,. Draft EIS--Hydroelectric Power Development, Upper Susitna River The Department of Environmental Conservation is aware that the proposed activity is a legislative action. However, if the Congress does authorize the construction of this project as the Corps of Engineers is requesting, the Corps must initiate detailed studies culminating in the formulation of a comprehensive environmental impact statement on the proposed hydroelectric power project. Rather than.simply commenting on the draft EIS, it is essential that this Department and other interested State and Federal agencies particj-12 pate in all stages of the planning, research, and construction review phases of this activity. To j~plement this proposal, the Department of Environmental Conservation proposes that a joint Federal-State task force be formed and meet on a regular basis to review, comment,Jand advise the Corps on the environmental implications of each phase of the proposed hydroelectric power project in the Upper Susitna Basin. Members of this task force should include repre- sentatives from the Governor's Energy Office, the Department of Environmental Conservation, the Department of Fish and Game, the Department of Natural Resources, the United States Fish and Wildlife Service, the National Marine 13 Fisheries Service, the Bureau of Land Management, and the Alaska Power Administration. By utilizing such an interdisciplinary planning team, the environmental, social, economic, and engineering aspects of this project can be fully analyzed and researched, and appropriate mitigating measures taken. The following are our comments on the draft EIS: The figure of 35~ salmon ~ry mortality in turbines (p. 51, EIS) shou14 be footnoted and referenced as there are a large number of variables that may affect this figure. In ·addition to fish mortality in turbines, there are several other project-associated conditions listed which, if considered collectively, might represent potential for signific«nt imp<~ct to resident and anadromous fish. They are as follows: a. The unspecified effects of cooler summer and winter water tcmper'atures on anadromou~ and resident fish (p. 67 of the Feasibility Study). b. The effects on migrating fish caused by the reduction of natural river flows during late June and early July (p. 69). 1 15 1 116 117 119 Raymond w. Estess - 2 -November 3, 1975 c. ·Effects of the spilling of water over Devil's Canyon Dam (pp. 66-67). d. The possibility that reduction in flow, turbidity, and temperature below Devil's Canyon Dam might cause disorientation of migrating salmon during an "initial period" during and ,after construction (p. 70). e. The feasibility of passing migrating fish over and through the high dams (p. 72). • ; On page 75 of the Feasibility Study, there is the possibility, however small, that transmission lines might impede migrating big game through its inherent characteristics, such as constant noise (line hum) and "smell" (ozone). Any in-depth studies of impacts resulting from this project's transmission line routings; including a~ternate routes, should be referenced. In addition to direct impacts such ~s on scenic-visual quality and archeological sites, such studies should deal with indirect impacts such as new residences, for example, the new capital site and industries that otherwise could not locate in the region without the available power. The figure cited for frequenc·/ of spilling excess water at the Devil' s Canyon Dam on page 46 (once every 10 years, three-day duration) can also be con- tested. The magnitude of the nitrogen super-saturated water problem on the Columbia River suggests that resident and anadromous fishes could be adversely affected on a much more fr~quent basis. The reduced flow velocity downstream from the dam will more than likely allow passage of fish upstream into pre- viously inaccessible areas adjacent to the dam, subjecting them to the problems cited above. Precautions taken to mitigate these problems are not stated and one has to assume that few, if any, measures will be taken in dam construction to accommodate these concerns. In reference to page 58, EIS, the climax or near climax vegetation, in this case predominately white spruce, is also preferred nesting for a number of important avian species. One major potential adverse impact not mentioned (p. 67, EIS) is failure of the dam structure. With regard to this, more detail is need~d on the high potential in the region for severe seismic activity. What, in addition to seismic shocks, are the chances for landslides generating surges of dis- placed water, fault displacement, and other respons~s to seismic activity ~xcecding structural limits? The effect of inundated areas of seismic at:tiv.ity is only now being und0.r~;tood, and must b'7 fully addressed in the EIS. l\t tent ion should also be given to any l<mc.lslidc potentl al res~l ting from inundation and subsequent saturation and/or erosion of !>lopes. Tht~• is particularly true where permafrost exists. Little is known and less is understood about the behavior of permafrost around and under an inundated area, but one certainty is that it will thaw under water and where exposed at' shoreline. This could lead to mass wasting on even moderate slopes, creating an unstable condition that could then miqrate uphill. A detailed 188 Ra)~ond W. Estess - 3 - November 3, 1975 treatise on the behavior·of permafrost is strongly recommended for this pro- ject. The threat of massive erosion resulting from liquification of perma- frost constitutes a priority impact consideration. What volume of sediment annually do the ppm load figures represent, i.e., what is the basis for projecting a "500 year" project life? (p. 91.) One failing of the environmental impact statement is a more detailed analysis of Alternative Hydrologic Basins in the Southcentral Railbelt Area (6.03) and Alternative Power Transmission Corridors (6.05). While the case for the Upper Susitna River site is convincingly and completely presented and acknowl- edging that the DEIS is written specifically for this site, the alternative areas are not developed in sufficient detail. Phrases like "tremendous financial investments" and "substantial environmental impac:ts" (p. 78) are used to justify rejection of specific alternatives. These comments are highly subjective and should not be substituted for factual data. It is alno a point of conjecture that alternative exotic enc:~:gy sources~ particularly geothermal, should be categorically dismissed as be.ing economic- ally and technologicatly impractical in this region. This is not necessarily so and may represent a serious underestimation of their long-term potential. For example, hydrogeneration from non-constant energy sources is showing much promise. Also, tidal power was understated as there is potential for using Cook Inlet's large tide range in an environmentally acceptable manner. The use of different scales for the map series Figures 4-8 makes easy com- parison of competing land use values difficult. This is.especially true . where the major landmarks (e.g., Susitna River and tributaries) are not included on the map. For example, compare Figures 4 and 7. The Upper Susitna River, Watana, Devil's Canyon Damsites, .and proposed transmission corridors should be highlighted on the habitat map so that the impacted area can be easily seen. It would also be helpful to incorporate more detailed information on wildlife distribution and seasonal movements in the final environmental statement than that provided by the map series of the Joint. Federal-State Land Use Planning Commission. One major source in this regard could be the Alaska Department of Fish and Game's hla~ka Wildlife and Habitat Att~s. This information base could be further expanded through informal dis- cussions with wildlife biologists of the State and the u. s. Fish and Wildlife Service. One point that has not been adequately addressed in the DF.IS is the following question: Will the proposed hydroel~ctric· power development act as a catalyst f~r um·1ilnted growth in Southccntral 1\laska? 1'hc literature is replP-te with cuses which clearly indicate that hi'ghways and scwt!r <m<l water systems can induce unwilntecl growth. Doc~ the s<.un<.· rationale hold trtt•-~ for. the proposed hydroelectric facility in the Upper Su~itna B.::u:;in? These questions have been only weakly. addressed on pages 63 and 64 of the DEIS. 189 J120 22 123 1.24 1_25 RESPONSE TO COMMENTS BY STATE OF ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION 112 Concur. jljl~ ·concur. We suggest that local government entities also participate. 1.14 Comment noted. 115 1 1 6 The 35 percent mortality rate on fisht such as young salmon, is a figure based on Corps of Engineers experience at other high dams. a. This will be a factor. Alteration of temperature regime will certainly influence salmon egg development~ and possibly outmigration time. As stated in Section 4.01 of the EIS, the use of multi-level discharge outlets at the dams would allow for some adjustment in temperature to approach the natural river temperatures. b. The EIS acknowledges in Section 4.02 the possible impact on migratory salmon. c. Supersaturation of gases requires more than spill. Tem- perature, distancet and volume are also factors. This i~pact is discussed in the EIS and will be the subject of detailed desi~n studies. d. Same as b. e. Based on extensive studies on the Columbia River and in British Columbia, cost, engineering, and biological considerations cumulatively make fish passage over high dams infeasible. Concur. These considerations will be studied and evaluated in detail prior to any recommendation for project construction. Jlll ~ A change in design of outlet and generating facilities at the dam has revised the spill frequency at Devil Canyon as shown in the EIS. Salmon are not likely to attempt to migrate to the dam. even if passage is possible (wh;ch appears un1ikely)since the last tributary in which they are able to spawn is Portage Creek-- several miles below the dam. Contrary to the stated assumption, features will be incorporated into the dam outlet works to mini- mize nitrogen supersaturation. 118 Comment noted. 119 Dam design will incorporate features to withstand earthquakes of 190 ........ An extreme magnitude of 8.5 with an epicenter of 40 miles which is greater than the maximum credible earthquake that could be expected to affect these damsites. No dams designed by the Corps of Engineers have ever failed, and the Corps has a record of being very conservative in designing safety features into dams. 12 0 For a discussion of landslide potential resulting from thawing of permafrost, see response Number 173. 1~1 Additional sediment information can be found in Appendix I of the feasibility report. Project costs and benefits are based on a standard 100-year period for this type of project. Actual useful life of the project would be substantially more than 100 years, and, based on sedimentation studies al~ne, the project would have a useful life in excess of 500 years. 1~2 The alternative hydrologic basins and power transmission corridors were studied in sufficient depth to determine their economic, social, environ- mental, and engineering feasibility. All alternatives rejected for further consideration failed to meet standards of acceptability under one or more of these criteria. A more thorough analysis of each of these alternatives is displayed in the Feasibility Report and its technical appendices. Phrases such as "tremendous financial invest- ments" and "substantial environmental impacts" are supported by the results of previous studies on many of the alternative damsites. Reports of these studies are available in the District office. These terms are not the basis for rejection of specific alternatives. The Congressional mandate specifically directed the Corps to evaluate the Devil Canyon Project. 123"Exotic energy sources" were not categorically dismissed. The long-term potential of geothermal energy is clearly acknowledged in the first sentence of the discussion of this alternative, which states: "Geo- thermal resources may eventually provide significant power generation in Alaska; ..... " (emphasis added). However, as clearly stated in the EIS, this alternative depends on technological development and economic feasibility. Futhermore, it is considered to be a future supplemental means of generating power. It is not considered to be a reasonable alternative to proven types of power generation within the time-frame of projected future electrical needs. Tidal power is not rejected on the basis of technical feasibility. We do not agree that it could be developed in Cook Inlet in either an economically or environmentally acceptable manner within the foreseeable future. 124 The Susitna River and the damsites have been emphasized in figures showing the various resources within the Railbelt area. Information in the Alaska Wildlife and Habitat Atlas is similar to data in the 191 12.5 Southcentral Regional Profile printed September 1974 in cooperation with the Joint Federal-State Land Use Planning Commission for Alaska. The Corps of Engineers also had the close cooperation of the State and Federal fish and wildlife agencies in developing the EIS. As stated in Section 4.18 of the EIS: 11 The population of the area will increase with or without the development of hydroelectric projects proposed for the Susitna River; construction of this project is not expected to have any significant long-range effect on overall pop- ulation growth, but is rather designed to fulfill presently projected needs of a growing population as one alternative means of producing power which will have to be provided in one way or another.11 For further response to this comment, see response No. 255, 192 STAll: &fJ:fft/!!1/@!i~Zllf&JltfjW/ · -of A!ASi<A ! i ,.... t~ (:'i'l !7." '! ~~:: ir'~ r -.... TO· I FROM1 DEPARTMENT OF COMMERCE AND ECO~?ri~ DEVELP~~~~T~~) •. : 1 '. , .. "·.· :; 1 ~·~ . l.L.:....bPR: Mike Raymond w. Estcss State-Federal Coordinator Division of Policy Development and Planning Office of the Governor DATE ....... ·~ ·~ .;J. t 465-2022 ~· ::r./ .. .,.1!111~ .. -.r ~..:. .. ,.~.· .. ,;.:{ ,) ., October 16, 1975 Ford Langhorne A. Motley ~ Commissioner vu· Department of Commerce and SU~J~CT1 Southcentral Railbelt Hydro- electric Project State I.D. No. 75091103 Economic Development The hydroelect·ric project proposed by the Alaska District Corps of Engineers is a key element in meeting Alaska•s future power needs. Jt26 At present, the project needs to receive an intensive and detailed~ study of several potential adverse impacts on the environment. iZ~""j These include further examination of the dam•s effect on the ~ anadramous fish, the increased turbidity of the Susitna River during winter months, and the inhibition and higher mortality of the caribou population. t However we believe the project should, at this point, receive the full support of the State for the following reasons: a) It utilizes a renewable resource; b) environmental impact is comparatively less than alternative power sources; c) federal approval would result in the Corps receiving needed funding to obtain the answers to the necessary questions of adverse environmental impac·t ,· through further detailed unalysis and study. In summary, project is definitely necessury if Anchorage and Fairbanks are to receive low-cost, dependable power, and the subsequent lack of heat, noise, and air pollution problems cdd to its feasibility. The draft.environmcntal imp~ct statement raises several pertinent questions, but the answers will only be achieved through State and Federal support of the project. 19~ •• ····128. RESPONSE TO COMMENTS BY STATE OF ALASKA DEPARTMENT OF COMMERCE AND ECONOMIC DEVELOPMENT Comment noted. Concur. Such studies are proposed for the pre-construction stage of detailed planning . 128 Comments noted. 194 . . . . . . . ~ ~ . .. . ---r-···---.. ---.. ·- M·EMORANDU.M State of Alaska TO: fROM: 01)1 lr;, •. 517!.1 Pete Ci zmich Regional Supervisor Habitat Protection Department of Fish & Game Anchorage Larry J. Heckart Mgt/Research Coordinator Division of Sport Fish Department of Fish & Game Anchorage OATE: October 2. 1975 FILE NO: TEI..Ef'HO:~E NO: . SUBJECT: Susitna (Devil's Canyon)·· E. I. S. Comments Following are the consolidated comments on the Corps of Engineers draft E. I.S. pertaining to the Susitna River Hydroelectric development': Page 18, 1ast paragraph -It is significant that some salmon species rear juveniles for several years in fresh water prior to seaward migration. This paragraph implies they originate in salt water. The fresh water rearing segment may be the most critical .. .· Page 19, paragraph 1 -Should mention what surveys and the year(s) they were 11an conducted to determine that fish do not migrate beyond Devil Cany~n. 'r .parag~aph 2 -This is not indicative of Northern District Cook Inlet 1 Jl~l· (Susitna River Basin) as a ~hole. paragraph 3 -ADF&G currently has escapement goals for Kenai and I Kasilof rivers. We cannot conclude that adequate escapement occ~rs ' jl~~ into the Susitna River because escapement goals have been reached in the· Kenai and Kasilof rivers. t· paragraph 4 -.This paragraph should be rewritten as it is misleading as written. i.e .• : according to the ADF&G. a significant percentage of the Cook Inlet salmon run migrates up the Susitna River. Spawn- ing is found to occur as far upstream as Portage Cr k, approximately 133 three miles downstream from the Devil Canyon dam site. Spawning · ' and rearing salmonids occur in many clearwater s1oughs and tribu- taries fl·om Portage Creek downstream to the confluence of the Susitna Chulitna rivers. r . Last two sentences in paragraph are okay. paragraph 5 -Should identify study (first sentence) as 1974 assess-I ment study by ADF&G. 1.,j4 Omit last sentence. I ~ Also, king salmon are excluded. Barrett's 1974 repo~t indicates king salmon present. 195 Pete Cizmich - 2 -October 2, 1975 Page 20, 13 6 ·1 Page 21, 13 7 ~1 Page 23, 13srg· 24. 13 si·Page 27, paragraphs 1-5 -Trying to relate Cook Inlet catch to Susitna River stocks may be misleading. The Department does not have a method of differentiating salmon stocks in upper Cook Inlet that are landed in the commercial fishery. We do know that the majority of salmon landed in the Northern District commercial fishery are produced in the Susitna basin. However, we do not know what proportion of the commercial catch landed between the latitudes of Anchor Point and the Forelands are produced in the Susitna basin. In certain years, primarily even years, a substantial per cent could be from the Susitna River. Therefore, to use the Northern District catch as an indicator of the Susitna production would be invalid. The case pack for Cook Inlet as an indicator of Susitna production is also worthless in that it reflects the total cases of salmon packed in all districts of Cook ·Inlet and in some yea~s includes fish packed from Bristol Bay and other areas. In essence there js no present method of affixing a value to the Susitna River salmon production. We do have a "gut feeling" based on experience, that a substantial proportion of Cook Inlet salmon pro- duction i~ from the Susitna watershed. ·? paragraph 1 -Why not a life history section for resident sp~cies, as given for anad~omous species? paragraph 3-Omit "limited". The numbers of game birds is unknown. Figure 7 -The white (unmarked) area in the center of the caribou range map is both summer and winter range. This area should be so indicated. paragraph 3 -Not true~ transmission corridor. Bears occur in both directions along the 14 01 Page 37 & 38 -Recreation in the areas. affected downstream of. Devil' s Canyon would appear to warrant ment1on. Page 46. paragraph 1 -What is the source of information indicating unregulated summer silt loads? Again. while summer siltat~on is decreased and the effects may be beneficial, the increased winter silt load may cause deleterious effects. At what point is the (15-35 ppm) sediment load calculated and at what seasonal period? If multiple level discharge outlets are utilized to approximate normal stre~m temperatures it may be implied that in .the winter water will be drawn from the bottom of the reservoir. It is logical 196 Pete Cizmich - 3 -October 2, 197 5 I to assume release from these levels would .carry a greater silt load than those closer to the surface. If this is so, discussions referring to a winter milky textured 11 glacial flow" may be extremely optomistic. If the 15-35 ppm winter sediment load is calculated at the release sits it can.be expected to increase rapidly as the downriver flows replace the sediment load lost upstream in the reservoir. Estimates of 15-35 ppm winter sediment load appear extremely low and likely would not apply fo~ any distance below Devel Canyon. Winter turbidity may well exceed the indicated estimate. 141 Page 49, paragraph 1 -If regulated flows are not great enough adults may be ~ unable to enter sloughs and tributaries to spawn.· Concern is ex-~~~· pressed for extremely low water years and planned regulated flows ~ under these conditions. paragraph 2-What flow reductions will occur during construction and I jlA~ the subsequent fill period and for what duration? ~ paragraphs 3 & 4 -More current data is now available re numbers of I Jl~~. sloughs and tributaries utilized by salmon and other 111ainstem mig~a- tional characteristics. The clear water condition of the Susitna River during winter.months I could be a contributing factor to salmon fry utilizing the mainstem. If a year-round somewhat milky-textured "glacial f1oor" condition is introduced because of controlled water releases below the dam, fry may not be able to rear in the mainstem Susitna River. 145 paragraph 7 -It is likely that a program to improve fish access to I the sloughs as a result of decreased summer flows \'lill not only be 146 feasible but "necessary" and required. Page 50, paragraph 1 -Previously (page 46) it was stated downstream water temperatures would approximate normal winter regimes. This para- graph implies decreased temperatures. Green stated in his paper, entitled Ecological ~onsequences of the P~qpps~ MoraQ_Q~~-~~fraser Riv~J: that reduction in downstream discharge and resultant water velocities during the spring seaward outmigration could adversely affect survival of young salmon by ex- tending the period required to make the migration. He also suggested reductions in turbidity would likely limit daily migration to the darker hours, further extending the total migra- ·tional period. ~ ... ·, 19? Pete Cizmich - 4 -October 2, 1975 14? 1481 14 15~ 15.11Page 51 , 152IPage ~2, 15~Page 53, Columbia River data indicates mortality of salmon increases wfth th! time required to complete the downstream migration . . (see further comments following re increased mortalities dependent on silt loads).· Reductions in summer flow temperatures can be expected to reduce the speed of upstream migrating salmon. The degree to which this may affect maturation and eventual spawning must be determined. Increased winter temperatures downstream of Devil Canyon can be ex- pected to increase the rate of development and may load to premature fry emergence and downstream seaward migrations. These effects must be determined. paragraph 2 -Should indicate what flows will be during this period. What about other water quality parameters? paragraph 4 -This agency currently has available little evidence of significant mainstem Susitna River spawn_ing downstream of Devil Canyon. Therefore, unles.s flows are high enough to flood the slough and tri- butary areas ,where spawning is known to occur, benef.its. are likely to be of little value. paragraph 5-While Green made this statement as re improved.egg survival, he also suggested further increases in mortalities due to predation were possible due to decrease in turbidity. It was also suggested that altered temperature, discharge, and tur- bidity regimes could significantly reduce the survival of outmigrant juvenile salmon. There is no solid evidence available that adult salmon can adequately adjust to altered flow, temperature, and turbidity regimes. paragraph 6 -final sentence -There is no evidence of mainstem spawn;ng so it is doubtful there is anything to enhance. The red.uc- tion in summer flows may cause a reduction in both tributary spawning areas and tributary and/or mainstem rearing. paragraph 7 -This also applies to downstream areas. Insects are found to provide an important part of rearing fry diets. paragraph 3-This sentence sounds theoretical. Cite evidence supporting this statement. paragraph 4 -Paragraph meaningless. significant. 198 Sample size too small to be ./ PetEl! Cizmich - 5 -October 2, 1975 paragraph 5 -Improvement of habitat quality through construction of I1.S~ transmission lines is theoretical. Page 56,. paragraph 1 -Hunting pressures will not increase, only the potential ~ . for hunting pressure increases. ADF&G has the statuatory capabilities fi~· · · to contra 1 the actua 1 pressures. · Page 65, Pag~ 66, paragraph 2 -Will the summer silt loads during the 10-12 year con- struction period actually be decreased, or perhaps increased as a direct result of excavation, road b~ilding, etc.? paragraph 3 -Again, only the potential for hunting pressure is increased. General Comments: Findings indicate the lower reaches of the Talkeetna River are very important to adult and fry salmon. Changes in the Susitna River could potenti~lly have . a great effect on this area, too. Another area not mentioned in the report is the possibility of· the Susitna River just north of Talkeetna being a major milling area for salmon spawning downstream as is indicated by two seasons of tagging studies. The changes in the Susitna River could affect fish returning to the Talkeetna, Chulitna, and lower clearwater tributaries of the Susitna River. Mention is not made of the loss.of game habitat downstream of D~vil Canyon due to flow regulation, thus eliminating the periodic flooding necessary for maintenance of ri·parian bar areas. Moose habitat can be expected to be ad- versely affected due to resultant successional changes in the downstream areas from Devil Canyon to Talkeetna. This statement refers only to regulation versus non-regulation. The 12-year period of constroct1on and.1resultant effects on the fish, wildlife, and recreational resources are not addressed. 199 _J156 15S 11$9 RESPONSE TO COMMENTS BY STATE OF ALASKA DEPARTMENT OF FISH AND GAME ~29 A sentence has been added establishing the fact that juvenile salmon may spend several years 1n freshwater before migrating to. saltwater. jl~The paragraph is cons1dered factual as presently stated. No data have been provided from any authoritative source, including the Alaska Department of Fish and Game, that salmon have ever been recorded upstream from Devil Canyon. 131 The sta.t1stics presented in this paragraph of the EIS are taken, as indicated by reference, from Leaflet #26 prepared by the State of Alaska Department of Fish and Game. 1.J2 Co11111ent noted. jl~~A statement has been added that a significant percentage of the Cook Inlet salmon run migrates into the Susitna River Basin. jl:)4lThe paragraph has been revised as suggested with exception of omitting the last sentence. The s.tatement made in the 1975 Alaska Department of Fish and Game assessment that a portion of the pink salmon run may have been destroyed by a late August-early September flood has not been omitted. 1l~There 1s no attempt anywhere in the referenced five paragraphs to relate Cook Inlet catch to Susitna River stocks. Neither is there any reference to case packs for Cook Inlet as an indicator of Susitna production. We agree that there is no present method of affixing a value to the Susitna River salmon production and have not attempted to do so. We have added a statement that the Alaska Department of Fish and Game accords a significant percentage of the Cook Inlet salmon run to the Susitna River Basin. jl~ The inclusion of a life history section for anadromous fish was an optional ~ec1s1on made by the writers of the EIS. There is no requirement by NEPA or CEQ guidelines that such a section be 1ncluded in an EIS. Salmon were included because of the great s1gn1ficance {recreational as well as economical) accorded this species. Also, project impacts are more subtly associated with the life requirements of salmon than with any of the other major ftsh species. jl:)~Concur. The statement has been revised to indicate that the numbers of gaTne birds are unknown. 200 • 1 3~ Caribou range map is as. shown from maps in the Southcentral · R_~nal Profil~ and the Alaska Wildlife and Habitat Atlas. 140 141 The statement hds been clarified to indicate that grizzly bear are also found throughout this part of Alaska. Possible improvement of summer fishing conditions might occur with reduced sediment loads downstream of Devil Canyon dam. Other recreation downstream of Devil Canyon does not appear to be sig- nificantly affected at this time. Detailed information on hydrology, including sedimentation, can be found in Appendix I of the feasibility report. Multi-level water release structures do not draw water from the bottom of the reser- voir storage pool (the so-called dead storage pool), but generally from the upper one-half to one-third of reservoir storage. Comment on the replacement of sediment load in water releases at Devil Canyon is discussed in Section 4.01 Hydrology and Water Quality of the EIS. We concur that sediment loads below the dam would probably increase as sediment is picked up from the riverbed, but the 15 to 35 ppm refers to the releases at Devil Canyon dam. ii.!Z Contnent noted. jLJi:J There will be no reduction of downstream flows druing construction. Close coordination with the U.S. Fish and Wildlife Service and the Alaska Department of Fish and Game will be undertaken to pre-determine minimum flows downstream from the dams during filling. 144 The EIS will be updated or supplemented as significant new information is acquired and provided to the Corps of Engineers. 145This determination will be an objective of fishery investigations as the study progresses. lqG Fish access to the sloughs as a result of decreased sullliTler flows will be improved if it is found to be necessary and required. 14'7 Comments noted. 148As previously stated, minimum flows required to maintain the fishery will be determined in cooperation with U.S. Fish and Wildlife Service and Alaska Department of Fish and Game. Impacts on other water quality parameters which might result from withholding a portion of the water during high flows for reservoir filling is not known at this time . • 201 14S Crnnments noted. The EIS has included additional temperature and turbidity information from the Moran Dam study. 1 5 (1 I r prov i <; i one:; .!l'fl m;ldf' tn I'I'•'VI'Il t ilydr.llJ 1 i I; h 1 oc~.,q.·~ I 0 'iclllllnll ·.po~wninq Lribult~rie'> dnc.J ~lou~Jhs (ds the E:.IS says there will be, it necessary), it is not likely that tributary spawning areas will be reduced. The EIS does not state that mainstem spawning will be enhdnced. We agree that little, if any, mainstem spawning occurs under present natural conditions. H~1ever, it is not unrealistic to a~sume that some spawning habitat could develop in the mainstem within ttle reacn subjected to significantly reduced surruner sediment loads and flooding. 1 b 1 Concur. 152 The second sentence in the referenced paragraph does make a theoret- ical statement. The evidence supporting the statement is contained in lhe ~entence itself where an eAample is cited of natural lakes in Alaska which have heavy glacial inflow, yet sustain fish populations. 153 The Alaska Department of Fish and Game is the source of these figures (as indicated by reference in the paragraph). They are included here only as a matter of officially recorded data--observations made during one moose survey. The paragraph contains no allusion as to the significance of the figures--they speak for themselves. 154 Disagree. Transmission line rights-of-way are known to improve habitat for wildlife species which benefit from subclimax vegetation. 155 Concur. The sentence has been modified to indicate that there will be a ~ntial increase in hunting pressure. 156 The paragraph which is the subject of this comment refers to sediment and turbidity changes which would occur upon completion of the project. Any increases in turbidity during construction wou1d be of extremely short duration, while small diversion dams were being placed to direct river flow through bypass tunnels. Dam construction, itself, would be done "in the dry." thus construction of the dams would have no significant impact on water quali~y. 157Concur. The sentence has been modified to indicate a p,otentidl_ increase in pressure on existing game populations. 158 Comments noted. 159 Disagree. conclusion regulation Until studies are made of this situation, no positive can be made concerning the Aownstream impacts of flow upon moose habitat. However, there is c good possibility 202 160 - that moose browse will be increased as a result of regulation. Bar areas within the braided stream channel are too frequently and extensively flooded under natural conditions to support any signif- icant amount of browse vegetation. When the flow becomes regulated, the stream channel is expected to become more unified and will probably assume a meandering pattern. Large, barren bar areas, no longer subjected to intensive erosion from frequent flooding, will probably establish permanent plant growth. As this growth evolves through the shrubby successional stages, moose browse will be increased. Eventually, much of these lands will establish trees, mostly cottonwood, and thus evolve beyond the browse stage. Moose habitat will, at that time, decrease but will probably continue to exist in greater quantity than is presently available within the braided channel system. There will be no significant effects on fish during the 10-year construction period. As previously stated, there may be some very temporary degradation of water quality through increased siltation during the short period when the stream will be blocked with temporary diversion dams required to divert river flow through the bypass tunnels. This impact should be minor. With regard to terrestrial wildlife, construction activity will result in some outright destruction of habitat and the evacuation; and probable decimation, of species inhabiting the immediate and surrounding construction areas. This impact, overall, will be much less signi- ficant, however, than the subsequent impact related to habitat inundation as the reservoirs are filled. 203 . STATt:i of. ~LASi<A IJi:ll:foW.tf;}?{tJ1];/ff/lftl/J!l ' -•, f- DEPARiMENT OF NATURAL RESOURCES ;•J 'J • • I ( Tell r DIVISION OF LANDS R~YMOND W. ESTESS State-Foderal Coordinator Oftlco of the Governor Division of Polley Development and Planning Pouch AD DATi • Juneau, Alaska 99801 GARY JOHNSON, Acting Chief ~~ Pl~nnlng & Classification Secffon Alosk~ Division of Lands 32J E. 4th Avenue Anchorage, Alaska 99501 5VDJECTo ''~· ... 1 : f. '. ,..: • •• ' ( o •""'' -· ~-•• ,~'}H October 27, ·r975 St~to J.D. No. 75091103 Southcentral Rallbelt Hydro- electric ProJect . The above-noted project has been reviewed by the Division of Lands' staff, with the following comment considered appropriate: "General Corrm&nt: This project appears to have f~vorable energy development benefits while h&vlng a relatively low environment_,! lmpact.11 (Planning & Class~flcatlon. -G. Johnson) ~ . Thank you tor the opportunity .to review this project. r I 204 :; I .... . I 161 Comnent noted. RESPONSE TO COMMENTS BY STATE OF ALASKA DEPARTMENT OF NATURAL RESOURCES DIVISION OF LANDS zos ···M.EMORANDUM State of Ala1:_)>~.9·.Y· (!:.;. ;r "/.' ~~ .... \ TO; F"J\OM; 162 163 Rnymond W. Estcss Stntc-Fcdcral Coordinator Divi~ion of Policy Development <'lnd Plonnlng OAT!!: FILE NO: Office of the Governor TELEPHONE NO; Jam~s E. t-lnody ~~ 1 Chief Planning Engine .1 ~ • Divloion of Aviation i Deportment of Public Works SUBJECT: "\ .. ~ •. 9 ,~ JJ II (. 1 n tn1 . .,. ·ftt I October 21, 1975 · .oc: .~ ~ 19"!S ··'"' ... ' State I.D. No. '75091103 Susitna River Hydroelectric Proposal ar~ Followlng ~ off-the-cuff comments on the subject project as requested Jn your September 24 memo, and as related to the September 22 trans- mlttnls from the Corps of Engineers. Att.,chcd is a copy of the :october 9 memo with Nr. Baxter's comments following his review of the materiaL ' . ThP. d~ta. ns nnxtcr. noted,. was too broad in scope and brief to allow us to cv;aluatc how the project could effect our present and future operations. Specifically, th~re is no inventory of the airports or recognized landing nrca9, either public or privately owned, .in the immediate vicinity of the project. The scale of the map~ and the quality of the printing supplied with the data arc such that it is not possible to ident·ify the boundaries o[ tlw project so that 1~e can compare them against our inventory of landing nrcaH, although we doubt that very many fields would, be involved. The b.lgr,cst question from the standpoint of trnnsport.:.~tion deals mainly with sur(.:.~ce cransportation rnther thnn aviation. 'I'hJ.t is, how would the dnm~, l~kcg, ~nd related faciliti~s improve, and restrict, accessibility to the Susltna Basin? The creation of an 80 mile long system of lakes 1 would certainly restrict the selection or alignment of road routes 1 trnver3tng the ure~. On the other hand, the lakes themselves might offer ! n certain degree of flexibility relative to surface transportation. Perhnps the most important point is the fact that there would likely be a I r.pur hir,hway constructed connecting the railroad and George A • .Parks I lltr,hway to thP dam :.ystcm, thereby providing convenient public vehicular access to what is now a relatively remote region. : I lt ifi ~lso likely that some type of airport or landing strip will be con!;tructcd in the immediate proximity of cA.ch of the dams, to provide 16 4. qutck .1cccss durlng construction if for no other reason. It \muld be lnlcrcr.t:lng to kn~w whc;re these strip!> might l>e. l)OW large the;,: w~uld ~" .. ~ 1) · he. vnd so on. (r,l<'nlt.,.f /_.-fu;f~ u.u. ~f./er" ~,.., u-,,;,-~;_ ;.s c..-t'"'r' ';/ I The d:.m~ nnd their rclntcd hydroelectric plants \~ill in themselves create employment opportunities. Since the projects will result in improved ourfJcc access plus a major supply of electrical energy, nnd since the area I 1s rclat ively close to mineraliz~d zones • mineral and other r.esources may 206 -2-October 21, 1975 he cl(·vC'lO(u>d thus c:ont·ributing to more employment, incrcast>d settlement ' <~r pupulallon, and an lncrl!ased need for both nir and surface transportntion. 1hc iucrt!£11-H!ll acct.~asihUity will likely attract: consldl~rnble rl!crcationnl tic t iv Lly, whether or not any minf~ral or other industrial resources are <.1 t'Vl•l.opt!d. 165 !Ia~{ anyone consldcrcd the nltcrn.ltive of private development of this 1·"'_{)~--: hydro~ Lt:ctr .ic resource? Which wou'ld benefit the State more -federal .J 'L• dcvt>.lotlme-nt o( the resource, or private development? The: tone of the draft EIS .1nci the draft Interim Fcas·i.bility Report seem to indicate a relatively detailed n~view of the impact on the lands actually encompassed by the proposed project. Howev~c. a project of thio R~ope which will create an 80 mile system of lakes with road access (such that perhaps 75 percent of the State's population '¥'ill be withiq roughly 4 hours driving time) will have a significant impact on the adjace11t lands. The subsequent impact on air and other transportation cnn only bl! :hlentif led after probable uses of this adjacent land have b{'Cil cal:llop,l•lL For example, if the-N;1tional Park Service, or t;,he DiviH.ion of Parks of the State's Department of Natural Resources,dcsircs to pn~serv~ th~ surrounding area for recreational purpose9, one type of j_6,7 avl;Jliun activity will predominate. That is, recreational flying or slmplc transportation for recreational purposes 1night he tht! prime tr:m::portntion mode. Seaplane traffic ml~ht coJnpr.Lsc> the highest percentage of :H•ronnut.l.cal net lvity <Ind oli.r,ht result in h~.1vy Jm~acls at corresponding 1a•:~plane b:•!a~!3 in 1\m:lwrace and clscwh~rc. On the otlwr hand, t>hould. tlJ<:r.(• he cx.tPns'lv<• settlement of the area, and partic.nlnrly if. this is. <wno~·lat(~d w.lth mineral or industr1Hl dc!velopment, a hi{;hur pcrcentoge of a(.~nmautlcal ~ctivity mir,ht involve commercial (scheduled airline) operations -possibly with medium to heavy ai~craft. A hcttcr m.:lp showing the lake system, probable surface access routes, mHl surrounding area; plus more information on the wildlife, mineral, and ~grjcultural resources of the area from respective State offices wmdd help uH better gauge the impact of the project. It is apparent that the project itself will have less long range impact on air trans-1.68 portatlon than the secondary developments which will spring from the propoAccl hytlroclectric complex. i\1 1 ;ll'hml?nl 207 ···--·-··--· --··--------------~---- --~TATS . tlf ALASXA .. PIOMo 169 James E. ~loody Chief Planning Engineer Kinney R. Ba-~ Aeaietant Pl~ngineer -DAlE $UIIJ£CTr October 9; 1975 Alaska State Clearinghouse State I.D. No. 75091103 Upper Susitna River Basin Southcentral Railbelt Area After reviewing the Draft Enviro~ental· Impact Statements for the llydroelectric: Power Develop111ent, I have found that the vay in which it is written does not create much detail to analyze constructively or destructively. The approach is of a general nature. and prohibits many comments being made'towards the EIS. In the past EIS's that have.been reviewed, -the author will commit himself to particular controversial topics, thus creating a flock of comments from the various agencies. The only comments that I have to make arc concerning the introduction of two large lakes that will greatly influence the activities of float planes and boats. This will open the adjacent land to hunting and fishing camps as well as other recreational functio~s. Will the adjacent land be open to public sale or will it be established into a llildlife Reserve, or whatever? I am sure that with the introduction:of visitor centers that other people will follow and a community will more likely be es.tabliahed. . . .... . \ 0 • 0 • r I 208 , .. - RESPONSE TO COMMENTS BY STATE OF ALASKA DEPARTMENT OF PUBLIC WORKS DIVISION OF AVIATION 162 Comment noted. Air transportation is discussed in the E IS to the depth necessary for the feasibility stage of planning. During detailed planning, all Alaska State agencies would be closely coordinated with to insure consideration of resources or develop- ments within their areas of purview. The Corps, upon request, will be happy to provide the Division of Aviation with detailed maps of the project study area. 1b3 Construction of the dams will not restrict surface accessibility to the Susitna Basin, since no road access is presently available through the canyon area. Construction of an access road leading from the George A. Parks highway will provide public vehicular access to what is now a relatively remote region. We agree, road route selection will be restricted by the reservoirs. Also, the reservoirs, themselves, may provide some benefit as landing sites for amphibious airplanes. 164 1b5 166 No landing strips related to project construction will be developed in the area without prior consultation with the Federal Aviation Administration and the Alaska Division of Aviation. Comment noted. Yes. The Devil Canyon High Dam alternative discussed in the EIS is a proposed development by Henry J. Kaiser Company. Private financing of electrical energy projects is one of the standard tests in computing benefits of Federal projects. In the instance of this study, coal, which was determined to have a lower benefit- to-cost ratio than hydropower, could easily be a privately developed power source. Either Federal or private development would be of benefit to the State. If identical resources were developed to the same degree, presumably the benefits would be approximately equal. ·167 Comment noted. 168The quality of maps has been improved in the revised EIS. However, they are still small in size and scale. As previously noted. the Corps will provide larger, more detailed maps upon request. 16!:1 A 11 pub 1 i c 1 ands acquired for project purposes wi·ll be open to the public. The status of wildlife on these lands would be deter- mined by the Alaska Department of Fish and Game. Other comments made by Mr. Baxter are noted. 209 GROUP COMMENTS AND RESPONSES /\Iaska Conservation Society -College Alaska Conservation Society -Anchorage Greater Anchorage Chamber of Commerce Cook Inlet.Region, Inc. Knik Kanoers and Kayakers, Inc. Orah Dee Clark Jr. High -7th Grade, 6th Period Sierra Club 210 CoiTVIlents 170-182 183-199 200 201 202 203 204-257 Ata4u ~,_ S<Jdd, "-~u./960 !lox 80192 CoiiOJ<,Aiuto 99701 AT..ASI<A CONSERVATION SOCIETY COMMENTS ON THE ALASKA DISTRICT, CORPS OF ENGINEER'S ENVIRONMENTAL IMPACT STATEMENT, HYDROELECTRIC POWER DEVELOP- MENT, UPPER SUSITNA RIVER BASIN, SOUTHCENTRAL RAILBELT AREA, ALASKA dated: September 1975 GENERAL COMMENTS Considering the rn~gnitude of the proposed ~o dam project for the upper Susitna River, the draft environmental impact state=ent (deis) is wholly inadequate in a great many respects, even as a feasibility study. A thorough analysis of its inadequacies would require considerably more energies than we, as an organization dependent upon volunteer workers, can muste~ in the =hort time period available for st~dy since the re- lease of the document on September 22, 1975. Instead, we have chosen to identify types of deficiencies and present examples of these types- in the remarks that follow. TYPE ONE: CONFUSING PRESENTATION Is this or is this not a draft EIS, that is the question? According to the title page, the document published in September 1975 is a draft EIS and according to a cover letter sent with the document that is dated- September 22, 1975 signed by Col. Charles A. Debelius, District Engineer, the document. received by us is THE draft EIS. "A final Environmental Impact Statem~nt, incorporating all comments received, will be prepared and will be filed with the Council on Environmental Quality'' (letter dated Sept. 22, 1975 from Col. Debelius). However, at the public hearing held by the Corps of Engineers on 8 October 1975 in Fairbanks, Alaska, Col. Debelius and his staff stated that the document entitled draft EIS was in fact a preliminary draft EIS and that a draft EIS ~ould be developed later followed by a final draft EIS. To add to the confusion, the summ- ary page, under item ?. 01 D<!s~ription nf Action" states that "since th~­ current study is in the feasibility stage, impacts are not exhausitveiy evaluated. If the project is authorized and funded for detailed studies environmental, social,economic, and engineering aspects of the project will be studied at length prior to a recommendation to Congress for advancement to final project design and construction ... Later, on page 1 211 1 '70 171 AlaRkA Conservation Society Comments S~:~sltn.J llydroeh•ctric Power Development Nov.l'mncr 15, 1975 Page Two of the c.Joc.:umcnt, lmdcr paragraph 1.02, "Scope of the Study" a two stage study l.s indiC<lll'd wherein Stage 1 "is an interim report, to be comple- ted by l D<'c(•mhcr 1975, on the feasibility of hydroelectric development I on the llppl•r Sus i tna Ri vcr" and Stage 2 "is a comprehensive report, an- ticlpatPd to bl! cumpleted in 1978, to determine the feasibility of d<.:vl'lopming othPr hyur-ocll'ctric sites in r::he Southcentral. Railbelt area." From this statl!mf!nt is one to conclude that the document we received is a draft ( or preliminary draft) EIS for Stage 1 of a feasiblity study? Will this then be followed by a final EIS on Stage 1? And this followed by a draft EISon Stage 2; followed by a final EISon Stage 2; followed by a draft EIS on the Devil Canyon/Watana authorized project; followed by a final EIS on the authorized project???? What makes these questions relevant is the vast difference in importance between being asked to comment on a draft EIS on Stage 1 of a feasibility study versu s a draft EIS on a project that is authorized. Although the latter has not yet been accomplished, the Corps is recommending authori- zation ~nd Senator Mike Gravel has already introduced a bill to the U.s. Scnatt> "authorizing construction of Devil Canyon and Watana dams in order to hurry the proj<·ct along so that it can be included in this sessions ·•omnibus water resources development package". (Gravel, l August 1975 News Release.) If authorization is given by Congress, what happens to the normal and proper sequence of environmental evaluation required by NEPA?. Will the two stage feasibility study of hydroelectic sites in·the rail- belt area be continued even though construction of one project (Devil Canyon/Watana) has been authorized? TYPE TWO: BIASED EVALUATION OF ALTERNATIVES The resolution adopted by the Committee on Public Works of the u.s. Senate on 18 January 1972 specifically requests that the Board of Engineers for Rivers and Harbors include in its evaluation of materials relating to developing power resources in the Southcentral Railbelt area of Alaska a review of the potential of "the Susitna River hydroelectric power d~velopment system, including the Devil Canyon Project and ANY COMPETITIVE ALTERNATIVES THERETO •.. (p.l: caps are ours). Ten alternative power ~ources are mentioned in the DE!S but all are dismissed as non- competitive in the course of ten pages! Two of these sources, natural gas and coal, are really viable alternatives in Alaska at this time, yet the trl'atmcnt in this EIS is, to say the least, biased and wholly inade- quate. For example, in paragraph 2, pa!'e 71 the document states: 11 In view of the quantities of coal involved and present•day mining practice, it is presumed that strip mining would be employed to obtain the coal. Without specific knowledge of the mining site, it is not possible to pro- ject how much acreage would be affected; however, it is assumed to be in the hundreds, possibly thous<Jnds, of acres .•. " If this isn't biased, I don't know a biased statement when I see one. If it isn't deliberately 21.2 - Alaska Conservation Society Comments S~sitna Hydroelectric Power Development No~~mbe~ lS, 1975 Page Three biased, then it reflects a non-objective and incompetant review of existing knowledge regarding coal as an energy source in Alaska. In the first place t' ~ distribution of coal suitable for use in generating electricity for the southcentral railbelt area IS K~OWN; the sites are few in number and there are reasonable estimates of the coal reserves available in them. (See paragraph 6.022 USGS Report). Thus, the acreage that would have to be disturbed to extract the coal to supply a given amount of generating capacity can be calculated but apparently wasn't. Second, if we assummed that the acreage that would be affected was "in the hundreds, possibly thousands," how does that compare with the 50,500 acres (•78.91 square miles) which will be inundated by the two dams to say nothing of the roads, construction camps etc.!!! Furthermore, a strip mined a<ca can be rccontoured and revegetated so they come back into being productive habitat for at least some (and in the Nenana coal field, perhaps most) of the species chat inhabited the area before stripping occurred. In addition, the total acreage disturbed is not affected all at once, whereas, inundation by a resevoir with the consequent siltation, buries the total acreage in a few years, and, for all practical purposes, completely eliminates its biological productivity or at least significantly reduces it forever. Later in this same paragraph the statement is made that ·~ater in .contact: with coal and mine wastes generally become acLdic and toxic to vegetation and animal life." What does that general statement have to do with the specific alternative of using coal to generate electricity in Alaska? Coal in the Nenana coal field (near Healy, Alaska) is very low in sulfur and thus there is very little potential of a serious acid waste problem. Furth~rmore, burning this coal produces very low emissions of sulfur dioxide and that which is produced can be captured by appropriate stack design. Thus, the impression given the uninformed reader that !Jl coal produces bad environmental conditions is very misleading especially in the case of the Alaskan situation. The final sentence in this same paragraph appears absolutely ludicrous when compared with another sentence from this samP document: '~he construction of the proposed hydroelectic project \ would have a significant impact on the existing natural scenic resource values within the project area.;' (Draft EIS, page 61, paragraph 2). Yhich is worse? The final paragraph of the coal alternative concludes: "In view of the extensive adverse environmental impacts as.sociated with the coal alternative, both in magnitude of effects and areas affected, this is determined to a less (sic) desirable source of energy production thaq hydroelectric development." (p.72) How could the Corps C~r"t"ive at this conclusion when NO EVIDENCE is presented that using Alaskan coal as an energy resource would produce more "extensive adverse envir- onmental impacts" than hydroelectric power from two dams on the Susitna River?' 213 172 AlDsk~ r.onscrv~tion Society Comments SusiJ;nn llydrocl('ctric Power Development Nov~mb~r 15, 1975 PRge Four TYPE THREE: LACK OF QUANTIFICATION OF MATERIAL DESCRIBING EXISTING ENV I RONM~~NT Throughout the draft EIS, meaningless adjectival descriptors are used rather than numbers. Examples: 1 "'.'3 -a. Page 12, p;Jra. 2: "Mo.st of the upper Susitna River Basin is • underlain hy dtscontinouous permafrost." ·How mueh is most? What is the relationship of discontinous permafrost to the success or failure of the hydro pl·oject? \.Jh<Jt are the environmental consequences of building dams in such terrain? I b. Page 14, para. 1:" Fe1., kayakers have attempted the dangerous 1 ''1 4 eleven milC' run through Devil Canyon." How many is a few? Were white- water cancer groups contacted and asked about their views? c. Page 25, para. 2.02.3.: "Grizzlies are common throughout the 1 r7 51 Susitna River drainage and are fairly numerous in the upper Susitna des- pite the absence of salmon (see Fig.8)" "Common" and ''fairly 11 numerous in relation to what other areas? How many per square mile? 1. ''1 6 1 Many ;1ddi tional examples could be cited but they are almost too numerous to 1 count! If thP data are available, present them and if they are not available, say so. 1'18 TYPE FOUR: IMPORTANT ISSUES NOT ADDRES.SED ANYWHERE OR VERY LIGHTLY TOUCHED UPON a. On page 17,-paragraph 2.01.4.5 the point is made that "much of the drain<lgc basin has never been geologically mapped," and the "the basin constitutes one of the least known areas in the State" .•. yet NO WHERE in Section 4.0, Environmental Impacts, does the EIS consider the con- scquenc~s of inundating 50,500 acres of geologically unmapped terrain. The potential loss of mineral resources is dismissed in one sentence: "Inundation would obviate the practicability of future mining or, ex- traction of such resources." (page 67). b. The EIS makes the following statements: page lO:"The Susitna River ... ts the large<>t stream di.s<'h.Rrging into Cook Inlet." page l4:"Freshwater runoff into the Upper Inlet is an important source of nutrients and sediments" page 45: "Significant reductions of the late spring and early summer flows of the river and substantial increases of winter flows would occur" if the dams nre built. In spite of these facts, no where does the EIS consider the impact on Cook Inlet of modifying the river flow! 214 - Alaska Conservation Society Comments SIJ s l tn .:1 llyd roc lt•c t ric Power Development Novcmb~r 15, 1975 Page Five TYPE FIVE: INADEQUATE REFERENCING OF SOURCES UTILIZED "cnvironmcnt<ll !;~ttin~;, without the project", very few references are _ 17 9 Although Jl p~gcs of the draft EIS are devoted to a description of the I made to the sources of the material presented and the few citations that arc giv<·n, are incomplete so that someone wishing to check with_ the original source would have a difficult time locating it. TYPE SIX: UNREADABLE OR INADEQUATE FIGURES Figure J (page 7) is so sketchy as to be useless for assessing relation- ships between the transmission corridor and even basic terrain features. Figure 4 (page ll) is unreadable. SUMMARY Following a review of the draft EIS for hydroelectric development in the Upper Susitna River Basin, the Alaska Conservation Society found the document to be a totally inadequate evaluation of the environmental impacts likely to occur if the Devil Canyon and Watana dams were to be constructed on the river. Deficiencies in the document are so numerous that an item by item enumeration of them would probably require a document equal to or greater in length ·than the draft EIS itself. In order to keep our conunents to a ~easonable level, we classificed the deficiencies into six types: l. Confusing Presentation; 2. Biased Evaluation of Alternatives; 3. Lack of Quantification of Mater~al Describing Existing Envrionment; 4. Important Issues Not Addressed; 5. Inadequate Referencing; and 6. Unreadable Figures. Several examples of the deficiencies noted for each category are presented and referenced to their location within the draft EIS. CONCLUSION In view of the inadequacy of the draft EIS, the Alaska Conservation Society 181 feels that the existing document needs to be completely revised and up-182 graded BEFORE any further recommendations are made to Congress by the U.S. Army Corps of Engineers. In particular, the Corps should meet its responsibility as mandated by the Committee on Public Works of the u.s. Senate to evaluate .. any competitive alternatives" to the Devil Canyon and Watana Dam project in an unbiased manner and present this evaluation to th~ ~ublic. ----- 215 170conunen t no ted. .RESPONSE TO COMMENTS OF ALASKA CONSEVATION SOCIETY COLLEGE, ALASKA 1?1 This conuncnt indicates a lack of understanding of the procedural re- quirclllents established by the Council on Environmental Quality for fcderdl (lfJPncy compliance with the National Envi-ronmental Policy Act. Guidelines to Federal agencies for preparing detailed Environmental Stat~ncnts on proposals for legislation appear in the Code of Federal Hcqulations in Title 40, Chapter V, at Part 1500. In addition, pursuant to Sect·ion 2(f) of Executive Order 11514, the Corps has developed agency procedures in consultation with CEQ which even more specifically provide quidance for the preparation of Corps Environmental Impact Statements. floth CEQ guidlines and Corps regulations have been adhered to in the preparation of the Draft Environmental Impact Statement. Following coordination of the DEIS with other agencies, groups and individuals-- and incorporation of all comments received, responses thereto, and addition to the EIS of any new or additional information received-- the Corps will prepare an updated revised Draft Environmental Impact Stui:P.rnent. The ROElS will then be subjected to intensive in-house r·eview ut higher levels of authority, and the District will make any necessary rev1s1ons. After such revisions are made, the RDEIS will he submitted to CEQ and, at the same time, will be sent out to the Board of Engineers for Rivers and Harbors, the final review agency of the Corps, and to Federal and State agencies for review and comment. Groups and individuals commenting on the draft statement will be furnished informational copies. The District will prepare appropriate responses, make necessary revisions to the main text due to comments received and forward a Final Environmental Statement to the Office of the Chief of Engineers which in turn will forward the document to the Office, Secretary of the Army. If the Chief of Engineers determines that new inionnation received is of such significance as to warrant recon- ~ideru.tion of previous recommendations of the Board of Engineers for Rivers and Harbors, he will send the document back to the Board ior such reconsideration. When the Office, Secretary of the Army, tr~nsmits the Final Feasibility Report and accompanying FEIS to Congress, it will also transmit the Final Environmental Impact Statement to CEQ. At th~ same tillle, the Division and District office will be notified of the transmittal for timely distribution of the FEIS to agencies, groups, and individuals that have received and furnished comments at various levr.ls on the stotement. The document commented on by the reviewer is a Draft Environmental Impact Statement, as indicated on the cover and in the text. The DEIS addresses Stage I of a two-stage study. Stage I involves a study, as mandated by Congress (by resolution of the Committee 216 -on Public Works of the United States Senate on 18 January 1972), to determine the feasibility of hydroelectric development on the upper Susitna River. Stage II will involve an additional study (not yet undertaken) which will determine the feasibility of other hydroelectric sites in the Southcentral Railbelt area. Thus, the second state study will be conducted to fully respond to Congress' directive. There is a vast difference in importance in being asked to comment on a Draft Environmental Impact Statement of a feasibility study versus a Draft Environmental Impact Statement on a project that is authorized. If this project is authorized, extensive, detailed environmental studies will be undertaken to identify unavoidable adverse impacts which will result from project construction. Procedures will be studied whereby the project can be modified to minimize adverse impacts or to otherwise mitigate unavoidable damages. At this time the EIS will essentially be rewritten and the review process initiated again. As a result of this detailed evaluation of project impacts, Congress will again have an opportunity to consider the merits of the project and make a determination as to whether or not it should be authorized for funding and construction. The latter requires a distinct and separate action by the Congress. 1~~ In reference to the alternatives to the proposed Susitna River hydro- electric development. the Interim Feasibility Report discusses in greater detail the reasons that coal was determined to be a less desirable 173 source of electrical energy production than hydroelectric development. The alternatives to hydroelectric development are also discussed in Section 6.0 of the EIS. The information was gathered from a wide variety of sources and presented in a condensed form. Many unquantified--and unquantifiable--resource values are described naratively throughout the EIS. The statement makes it clear that pennafrost is primarily restricted to areas of the Upper Susitna Basin upstream from the reservoir sites, though the Watana site is known to have some permafrost. The exact extent of this condition will not be known until proposed detailed geologic studies have been completed. Permafrost will have no relationship to the success or failure of the hydro project. It will, however, be a factor (one of many geological considerations) that w~ll have to be taken into account in the design and function of the project. Permafrost is not present in the Devil Canyon damsite but may be present within a portion of the reservoir site. The Watana reservoir site contains areas of intermittant permafrost, particularly on north-facing slopes. In these areas the overburden mantle aasumes a steeper angle of repose than would normally exist. It is expected that as the reservoir fills and permafrost degrades, some slumping of natural slopes will occur. These slumps or slides will be minimal in their effect on the capacity of the reservoir, since very light overburden is found in the lower elevations of the canyon where such slumping would occur. Above these rocky walls the valley flattens abruptly into the high terraces of glacial deposits where the slopes are generally stable. Permafrost 217 will not he a factor in the success of the dam since the foundation will he estahlished well below the level of permafrost conditions. 174. There have been only two or three people, to our knowledge, who have 'cl.1imed to have run the 11 miles of "whitewater" at Devil Canyon; there have heen others who have kayaked portions of this section of the river Jnd portaqed out of the deep canyon around dangerous sections of the river. A copy of a report by Or. W.L. Blackadar of Salmon, Idaho 175 1'76 is included. See response No. 257. The words ~CO!I.!!.'!.Q.'l" and "fairly" nu'!!__erous are descriptions used from Vdrious State and Federal agency wildlife statements and reports - it is presumed that these terms were used in relation to the animals in the State of Alaska. The terms and numbers used in the EIS were from available data from Fish and Wildlife Agencies. It is also stated that additional fish and Wildlife data will be obtained during the preconstruction planning process. 177· By selectively quoting portions of two sentences the reviewer conveys the impression that absolutely nothing is known about mineral resources in the drainage basin. In their entirety, the two sentences which are partially quoted read thus: "Though a number of mineral occur- rences are known and the area is considered favorable for discovery of udditional deposits, much of the drainage basin has never been geologically mapped. Thus geologically, the basin constitutes one of the least known areas in the State except for a few areas in the vicinity of Denali where some geologic mapping has been done." Additionally, the previous paragraphs states: "Most of the Susitna nasin above Devil Canyon is considered highly favorably for deposits of copper or molybdenum and for contact or vein deposits of gold and silver." The paragraph goes on to identify two known n1ineral deposit sites -one for copper and one for gold. The rotential loss of know, suspected, and unknown mineral resources is thus candidly acknowledged in the sentence as quoted wholly from Section ~.0. Geologic mapping of the impound~ent areas, required to determine faults and foundation conditions, would be extensive prior to any recommendation that the project be funded for con- struction. 17l:l Althouqh Cook Inlet is not specified by name in discussing the downstream effects of modified river flow, the following statement is made in Section 5.0: "Adverse impacts could result from possible reduction in nutrients and primary productivity, cutting, and erosion of existing s trea111bed configuration, increased turbidity during the winter months and changes in the hydraulic and biological regime of salmon rearing and spawning sloughs." These impacts will diminish with downstream distance, but some of them may well be felt to some extent in Cook Inlet itself. A determination of any significant 218 i111puct on Cook Inlet can only be determined subsequent to lengthy and costly detailed hydrological, biological, and water quality studies of the entire downstream system. Such studies are planned if the project is authorized and funded for preconstruction planning. The magnitude and cost of these and other studies which will be required prior to final recommendations for construction authorizations are clearly beyond the scope and funding constraints of the current feasibility study. 179 Many specific material sources are referenced within the body of the draft EIS and general information sources are listed in the bibliographic references section of the EIS. 180 181 A new schematic drawing of the proposed transmission corridor has been furnished by APA. The exact on-the-ground location of the proposed transmission line will be determined in future studies that will incorporate environmental, economic and engineering considerations. The word "if" is significant in the context of the first sentence of this comment. The Corps has clearly stated in the draft EIS that if the project is authorized and funded for preconstruction planning, detailed environmental studies will be undertaken prior to any recoiTillendations for construction authorization and funding. At the present time it is not known if the project will even be funded for further studies, much less const.ruction. In response to the remainder of.the "Summary" co!llllent, every deficiency that can be specifically identified has been given an individual response and clarified in the RDEIS. 182 The Corps of Engineers is very aware of its responsibility as mandated by the Committee on Public Works of the U.S. Senate. The public has been kept fully informed throughout the progress of this study. A number of public meetings have been held, workshops with interested environmental groups have been conducted, and the draft EIS has been sent to everyone indicating an interest in it, along with a letter specifically requesting their views and comments. See response No. 171, for a discussion on procedures of updating the EIS prior to formal submitta1 to Congress. 219 Charles Debelius Col,, Corps of ~ngineers District Engineer !3ox 7002 Anchorage_, Alaska 99510 8ol, Deheliusa PaLASitA CoNSERVATIOtl SociEtY UPPER COOK INLET CHAPTER BOX 3395 ANCHORAGE, ALASKA 99501 Oct. 17, 1975 The following are the comments of the· Upper Cook Inlet Chapter of the Alaska Conservation ;:>ociety on the Draft C:nvironmental Impact :_;tatement on "H.vriroelectric Power ~velopment-Upper ;)usitna River ;'aGin .;;outhcentral Railhelt Area, Alaska", Ala:3ka District, Corps of ~ngineers, Sept. 1975. UCIC,ACS protests the short time frame jn which this statement has been brought out. rhe agencies much less the public asked to comment on the statement has scarcely enough lead time to iJentify what needed to be 18 3 done, much less to do it, .;,orne of the following -1_uo:stions askeJ at the hearings were partially answereJ at the public rnee ting held by the Corps in 1\nchorage Oct. ?(which was only 16 days before ·Nri tten comments were Jue) but we wish to. assure they are contained in the final ~I~. I UCIC,~c., believes this o.cr., to be genera~ly inadequat: anJ unacceptable. 11e agree w~th the ...,tatement on pg. 8 ",,,'l'he 1:.I._, does not ~nclude a 18 4 detailed and exhaustive evaluation of pro'ject impacts .. ," .je object strenuously to the fact that the proposed project has to be a11thori~ed to be built before adequate environmental s'tudies can be made, The following are some general observations an·l. questions on the DEl.:.ia Fish, Game. Habitat · 'l'he most obvious factor is the· loss of 50,000 plus acres that will be inunrlate1 by the resevoir waters and lost as habitat, ralks with F de G personnel reveal that they need more time to do aJequate game counts (moose, caribou, etc,), range work to determine what kfun.i of habitat will he lost, identify specific caribou migration routes through the area, an1 they nee-:l time to i ientify exactly which streams the mixed stock!> of salmon spawn in. As we un1erstan:l it, they had at the most a year to start 1oing this work with only 2 full time regular staff people anJ the DEDICATED TO THE WISE USE, PROTECTION AND PRESERVATION OF ALASKA'S RENEWABLE AND NON-RENEWABLE NATURAL RESOURCES. 220 ) parttime help of 2 ai'ies. Also, money was not available to :io the stujies I nee:le:l. This money, as we unlerstanl it, woulJ be proviJej unier enabling ler,islat~on shoull it be passe1, but again, we protest that this proposej proJect shoul1 not be authorizeJ until aJe~uate stuJies are Jone. F "~as well as other concernej agencies, neeJ time to initiate stuJi s 185 to . .leflne impact, regulatory changes anJ to define mitigation to compensate~ for loss of habitat. 'l'hey also neeJ more specifie .Jata from the Corps in or<.ler to evaluate Jownstream effects on fish an.1 other a-1.uatic inhabitants of the streams anJ tritutari~s affected by this proposeJ Jam system. Game counts siteJ in the u.::I. .. are completely ir de~uate -i.e. pg. 53 •ouring the June 1974 survey, one grizzly was sightect ••• five black bears were sited on the ..>Ul>itna Hiver. " total of 56 caribou were sighted in the survey area" ~hat was the survey area? ls one years data the only available? How many times during the year were counts maJe? Information as basic as this does not seem to be available in the 0~1~. ~pecific stu~ies need to be done to determine how increased river 186 water temperature will effect such things as downstream icing con:litions, salmon egg emergence, and effects on other inhabitants of this system. The effects will not be limite:! to just the immejiate area of the :lams. What will the specific changes be in going from an unregulate:l river to a regulate:! one'? 'llhat effect will this have on the moose range? What will the Corps :lo to mitigate these effects? The Corps seemingly will have· to I mitigate for the loss of moose range -will they give lands to the :::ita te somewhere else or proviie money to increase management on other lands? This question :lees not seem to be aJdresseJ at all in the DEI.;. Siltation The problem of siltation raises many ~uestions in our minds that are not adJresseJ in the statement. How will JecreaseJ siltation in the summer effect primary productivity? lf the nutrients are decreased during the warmer months when life re-emerges in this northern latitude, what will be the result up the foo:l chain? especially in Cook Imlet into which the .,usi tna drains? now will this effect the zooplankton? An:l on up the food chain? ~ventually, could this possibly effect the salmon runs? Also, ail decreased siltation is predicted after completion of the propose.:! dam&, what about the increasej siltation bound to result from the construction phase (est. to be 10 -15 years)? Other questions -How much silt will be picked up after the water is released from the jam? 1'here may be a low sediment load spilled from the Jam, but what are the' figures say, 1 mile below the dam? ;:;edimentation The factors that influence the rate of erosion, transportation of materials to a reservoir ani the trapping of sediment within a reservoir are complex ani highly variable.-The geology of an area, nature of the soils, slopes, rainfall, runoff, hyiraulic characteristics, cover anj other coniitions vary greatly. However, given the glacial silt ani other se1iment content of the wate of the ~usitna River, the state1 loss of storage capacity for a 100 year I periol (6,5J' for Devil Canyon 1am, J,6fo for the 1/atana dam) appear low. The rejuction of suspen•1e'1 seJiment to 15-)5 ppm (pg. 46) means that much of the unregulate I river seiiment loaJ (less than 1000 ppm in summer months) wouUR9e rj:t.aipeJ ~tl the proposeJ iams. I cor s f om existing reservoirs in the u.s. having Jrainage areas greater than 1000 s~uare miles an1 storage capacities ranging from 0.05 to 2.06~ and averagi~ 0,72fo (Uottshalk, 1964). A couple of exampless 221 -2!..,- .·:1~pt"1nt IJutte reservoir in New l1iexico. lost 16){. of its original storage c:'lp."lci ty (2.6 million acre-feet) in )2 years of operation, L:uernsey reservoir in Nyoming lost )9~ of its storage capacity of 7),000 acre-feet in just · 18 7 26 years. 'fhe ·lata sources anj metho1s useJ to compute those sedimentation rate~;; are not incluJed in the D.C:l,:, anj are thus not available for "'vnlu:;tion hy reviewers of the statement. Also, there is no mention or· the construction of a sejiment pool to mitigate tne estimateJ loss of ~;;tor.age volumne over the years, r·ra:d.l lee Has the problem of fraz.il ice been consijered? ·rhis phenomen of northern climates i~;; a great ha:z.:r.ard to power plants, It is essentially ice fog that solidifies into a special crystal formation on the intake system us the cold (glacial in this instance} water .hits the warmer area nearer the 188 turbines. It solidifies instantly pnd when this happens, the fast revolving turbines have a decreased water flow and could burn out. There is t;upposerlly technology to overcome this, but the problem is not addressed in the DEL.i and we feel it is a very important environmental consideration. (~ee ~llllams, J.P. "Frazil Ice -A Review of its Properties with a ~electeJ Bibliography», Engineering , ~ov, 1959, pg. 55-60). rie are not convince~ this prohlem can be jismissej by saying the water temperature i.n the reservoir will be "to high for this to occur". Nhat will be the effect of essentially eliminating peak and low flows? j 89 Provilin~ flow fir,ures for the Chulitna and other jown stream areas we do I .'Ia te r F'lows · not feel "are beyonJ the effect of the project". Also, what will be the effect of w~rmer water flow in winter anj cooler in summer? i'o rmafrost . There ~eems to be incomplete identification of permafrost areas, How 0 will melting ice on reservoirs effect the permafrost? How much will erosion 19 contribute to the sediment loaJ anJ will wave action cause increaseJ erosion on permafrost areas? t~hat will be the effect of innunctating large areas of li~continuous permafrost? ~xactly how much permafrost will be under the impoumleJ area? ·~arthquakes .1-'g. 62 ~:>tatesa »JJevil Canyon and .~atana Dams will be designed to with-1.91 stand a i~aximum CreJible .C:arthquake of 8.5 magnitude with an epicanter of 40 miles at a focal Jepth of 20 miles which is the approximate distance of both damsi. tes to the Denali F'aul t system anj is the most likely source of a seismic event of this magnitude. The .,usitna Fault, truncated by the Denali Fault, ~i.Hects the region in a ~~ to ~~ jirection approximately 2,5 miles west of the ;latana damsite", As the ...iusitna Fault is par.t.of the Denali raul t system~ is it not possible that a quake coulJ occur closer than ''O miles? rle reel this certainly neejs more study and further clarification. 19 2 ,/hat is the geology of the founiation of the dams? How far to I Geology l">elrocll? ·llhat is the fonnation of the canyon sijes that will be innunjatej ., with water? Pr,. 71 mentions un'ier Alternative .>ources of Power -"A coal-thermal I Floo I Control . 19 3 rae i li ty woull forer,o the recreational anJ flooj control benefits prov i.Jej tay a h.v lropower project" •• ~·here is the Jata Jocumenting flooHng anj the nee I for floo.l control on the :..usitna? ls flpojing a problem on the ;:,usitna? He creation I ;,s moose and caribou habitat will be JestroyeJ (thus Jecreasing hunting) and there will be no fish in the reservoirs, what will the great recreational benefit of these proposeJ jams be to the public? ~oatipg? rlater sports? Nhat? n.s the area below the proposeJ Jams will probably be ... 222 clo:;e l luc to safety reasons, kayakers will probably be exclujed from I usin~ the river. Also, will the acc~ss roals be open to the public of will they be closel ·lue to safety reasons? /,c .. ~·!~S 1<oa.Js 194 -.:.xactly where will these be built -it is very harJ to tell by 5 thu m;,ps in the D::.l .... ttlso mileage e:>timates vary, ·•ill they be open to the f 19 public? How wi ie will the right of way be? itow will the Jirt and gravel be I ohtaine J to uuild these roads? 1 r·an~rni:.;siori lines an·J corrijors '!he Gtatemcnt is very unclear as to exactly where these will be. l!ow will rieht of way be obtaine<.l? It proposes to cross federal, state, private, anl native lanJs. with increaseJ. pressure on land resource anj use or lan-J for nonproJuctive purposes, has burying the transmission lines been consi len~d? Technology is available to Jo this anJ could cause much lcf;s ·lisruption of the lanl, Fewer trees woull have to be destroyel anJ the hurie1 limes area coull be revegetated, ~uch a corrijor coulj have varied elges iostcal of a ~traight swath cut thru the willerness, ~e realize t.hts t!l terna tlve is very expensive but we feel it shouli be consijerej :'1:; an al tc rna tivc to overhea i transmission lines in the DEL:>, :le al:;o note the effect of earthquakes on overheai transmission lines h:w not hccn al'iresse.l, He have. some questions as to possible health h~~~arie ~roun! transmission lines iue to high wattage radiation. 765,000° voltG seems to oe the critical point at which ajverse impacts begin • . ;orne of the problems encountere.J inclu.Je 1 l. ozone formation 2, interferance with raJio and T.V. signals ), noise pollution -humming an1 crackling sounj (up to 70 iecibels has been recorled -90 Jecibels is the legal noise limit) 4. poGsibility of electric shock s. possibly health hazzarJs -increaseJ b/p, chromosome Jamage, nervous system Jamage) ·~e .!o not know if any of this would happen with this proposej project, but we feel in the interests or public health, that thi~ should be lookej into an1 a.ld re sseJ in the DC: I.:>. #hat stuJies have been jone on strength of the wind in the areas for transmission lines? tie un,ierstanj the project arounj Juneau has ha-1 inr.re~ible problems with wind blow-jown of lines -not that there. are as strong win·:Js in the interior, but then who knows? 1\o ..;ata is presenteJ on this. What will be the energy as delivered to .:.nchorage an1 Fairbanks? dhat will be lost in transmission? On pg. ) it statesa ·~ subsiJiary purpose in the construction of the electrical transmission line will be the int~rconnection of the largest electrical power listribution grijs in the ;tate of Alaska,.," What are these 2 power gri1s'? Co:llj they ':;e interconnected without the propose j Jam? 'll'hy is it necessary to interconnect them? D=:~m operl'ltion ;/ho will he chargel with operating the Jam if it is built? The Corps? lltUities commission? The :.>tate? Also a very important question is what is going to be Jone with the "seconlary power" proiucej? The proposej project has a built in surplus of power-or in other ~orJs, it is builiing w<lY ahea I of the current neels of the railbelt. :ihat is the purpose of this seconlary power proluction? Is the purpose to attract inJustry? lf so, we feel that this is a sell out from the origir.al statel purpose. ".~xtra power" with no where to go will necessate car:-Jing charges ani as u~~fl, the taxpayer will pay, Plus the fact that this overproluction Wl be wastel anJ thus the rational to attract big inJustry to use it. 223 196 19~ 198 -J- Cost benefit ratio This ratio is computeJ as 1.4 so supposeJly there is more benefit thiin cost? llUt, looking at the interest rate which was computeJ at 6 J/8j., we .Jo not feel this is an accurate reflection of the realistic market .. fie neeJ to kno'll' the cost of this proposeJ project in terms of how much energy will be used to builJ the Jam, he'll' many ::ar-rels of oil will be irretrevibly committe.1, and how much energy will it "cost" to maintain the dam? Let's look at the cost -as one of the benefits, the Jam is suppose1 to be "lower cost of power generation" (pg. Jj how are we to evaluate the following figures of estimateJ cost of the Jam anJ transmission lines 1 1. When first proposei in April 1960 -:~>478,874,000 (iJevil Canyon Project Report of Commission of Reclamation, March 1961) 2, Jnn 1974 -$6A2,000,000 (Devil Canyon ~tatus Report, May 1974, Dept, of Interior, Al3ska Power Adm,) ), Jan. 1975 -$1.)1!) billion (Corps, .J::.b) To our way of thinkinF,, this project is economically unfesible, How can the Corps justify this outrageous expenJiture -which almost amounts to their total operatinr; bu !get for the entire Corps last year? 'Ire ::lo not feel all the alternative sources of power have been evaluatel with' an "open min.i". CoulJ currently available power sources Jevelope-:1 to their fullest supply the neeJs of the railbelt? How much energy will really be nee1e I in the railbelt? What will be th~ net energy ::'enefit analysis? ~ill other energy resources be JevelopeJ concurrently anJ be available by the time the Jams are on line? I lnconclusion, we have very serious questions about the lack of factual content of the D.::I.,, the potential attraction of big industry 199 due to overproduction of power, anJ socio-economic impact that would be inevitable. Ne see no proven neeJ for this project ani certainly cannot see that it is economically fesible, 224 RESPONSE TO COMMENTS BY ALASKA CONSERVATION SOCIETY UPPER COOK INLET CHAPTER 1A3 Formal public meetings to discuss the selected plan for hydropower development on the Upper Susitna River Basin were held in Anchorage on 7 October 1975 and in Fairbanks on 8 October. The public was given 15 days to include written comnents they wished to be inserted into the public record for those meetings along with any statements they made at the meetings. The District Engineer stated that all written comments on the Draft Environmental Impact Statement for the proposed project, which was distributed by the Corps of Engineers on 22 September 1975, should be made to the Corps by 17 November 1975 so that these comments could be included in the Environmental Impact Statement due to be completed in early December 1975. Actually, environmental comments dated through 3 December are included in the Comment and Response Section of the EIS. 184 As stated in Section 1.03 of the Draft Environmental Impact Statement for the proposed Devil Canyon-Watana hydroelectric project on the upper Susitna River, the sjludy is in the feasibility sta]e, and the EIS does not include a deta1led and exhaustive evaluation of project impacts, many of which cannot be fully ascertained prior to congressional authori- zation and funding of detailed economic, environmental, and engineering studies (including additional fish and game studies). The two-stage authorization process requires congressional approval before advancing from the detailed studies stage to final project design and construction stage when the actual project funding would be authorized and project construction would begin. Many projects have preliminary authorization _from Congress, but for one reason or another they are not all funded or constructed. 185 As indicated in Section 4.03 (Wildlife) of the EIS, the numbers of big name and the amount of habitat are minimal within the proposed Devil Canyon impoundment area, and preliminary data indicate that low populations of such anima 1 s presently utilize the proposed reservoir area. · If the project is authorized, it is expected that construction on the first dam would start in 1980 or 1981. Authorized fish and wildlife studies would be funded to continue during the interim study period and the information would be used to prevent, ameliorate, or mitigate the adverse impacts to important fish and w1ldlife species. 186 All project data, including river regulatory information, are available to the fish and wildlife agencies at the District Engineers• office in Anchorage, and these agencies are aware of this coordination 225 of information. 1\lthough up-to-date information on fish and wildlife is somewhat limited. past data--including information from the 1950's and 1960's--indicate that these are low game populations in the proposed Devil Canyon-Watana project areas. One survey study made during the winter of 1974-75 does not constitute a reasonable scientific study, as such, but it further indicates that the numbers of various animals in this area are relatively low. lb7 Sedimentation studies to determine the significant environmental impacts-- both adverse and beneficial--that would be generated by the proposed project, will be continued. Preliminary studies, including ~drologic R_,.~_c_O!l_n_a_i_~_sance_of ___ the Susitna River Below Devil's Canyon, October 1974, prepared for National Marine Fisheries Service at Juneau, Alaska, and various detailed U.S. Corps of Engineers and Bureau of Reclamation hydrological studies and other studies on sedimentation are available for review at the Alaska District, Corps of Engineers' office in Anchorage, Alaska. During the construction phase, the river's flows would be diverted through tunnels around the dam construction areas and should not significantly affect sediment below the dams. Other activities, such as building roads and bridges and clearing vegetation in the proposed reservoir areas and transmission line corridors, could cause some siltation or sediment problems. These activities would be done in such a manner as to minimize possible adverse impacts (see Section 4. 11). Preliminary sedimentation studies and post-Bureau of Reclamation studies indicate the rates of sediment deposition in the reservoirs as stated in the EIS. These computations are available for review at the Corps' office in Anchorage. The sediment load one mile below the Devil Canyon dam should be substantially the same as the releases at the dam due to the rocky nature of the riverbed in this section of the Susitna River and with no significant tributaries in this section of the river that could contribute higher sediment loads. There wou1d be a period of channel stabilization in the 50-mile section below the proposed Devil Canyon dam in which the river would tend to adjust to the stabilized regulated flows with low sediment levels. Some channel degradation in some sections of the river would occur as the river would attempt to replace the missing sediment load with material picked up from the riverbed~ but this is not expected to be of significant concern along the coarse gravel bed reaches of the river between Devil Canyon and Talkeetna. Projected studies should further clarify and define deg- radation of the riverbed in this section of the Susitna. 188 Yes, the problem of frazil ice has been considered. Also see response number 298. 226 • lbU li1e detailed effects of altering the present flow regimen of the river Cdn only be determined by studies which have not yet been made, but which are proposed during the pre-construction stage of planning when detailed studies are normally made. Effects of flow changes will be studied as far downstream as they can be measured, including Cook Inlet. Winter and summer water temperatures will not be significantly affected by the project. Multiple outlet structures will permit withdrawal from the reservoirs (in which water will be thermally stratified) at any level required to maintain near-natural stream temperatures. 19osee response number 173. 191 See response number 240. l~~See response number 36. 1~3 The quoted sentence is a statement of fact. The Corps has a wealth of data, available for public perusal in the District office, documenting flood damages to the Alaska Railroad and the town of Talkeetna. Bene- fits attributable to reducing damages to the Alaska Rai1road are com- puted in the project cost-benefit ratio. Benefits to Talkeetna are not. Uenefits resulting from increased recreational opportunity are also included in the cost-benefit analysis. Benefits attributable to flood control and recreation comprise about 0.2 of 1 percent of the total project benefits, thus neither is a factor in project justification. 194 The recreational benefits ascribable to the project are summarized in the EIS. The detailed recreational analysis is contained in Section F to Appendix l of the Interim Feasibility Report. This document is available for public inspection in the District office. Access roads and all other facilities will be open to p~blic use unless some areas or operational procedures of the project are determined to be dangerous to public safety. 1~5 Exact locations of the roads are not presently known, nor have mileages and right-of-way widths been exactly determined. It is anticipated that the majority of access roads will be open to the pub1ic. This is a basic premise in the estimate of public recreational usage on project waters and lands. Dirt and gravel will be obtained in the vicinity of road construct;on. Necessary borrow areas, where possible, will be screened from v1ew from the access road. These areas. will be rehabili- tated as necessary. 2~7 19b Transmission line right-of-way will be obtained through standard real -~ estate procedures. Very little of the line will cross private property, and, wherever possible, private lands will be avoided altogether. In the event some private lands are traversed, property will be acquired where possible by negotiation. If this cannot be accomplished, the government will exercise its power of eminent domain. Yes, burying the transmissiJn line has been considered, and a discussion of this alternative has been added to the EIS. It is the conclusion of the Alaska Power Administration that underground cable is much more sus- ceptible to damage from seismic activity than are overhead transmission lines, and that the installation of significant lengths of high · voltage underground electdcal transmission cable is limited by present technology (see Section 4.13 of the EIS). A number of studies have been made concerning health hazards associated with radiation from high-power transmission lines. It is generally concluded that lines transmitting less than 500 kv pose no threat to human health. One of these studies was made by Battelle Pacific Northwest Laboratories and is entitled Measuring the Social Attitudes and Estheti~ and Economic Considerations Which Influence Transmission Line Routing. The report is dated July 1974 and is identified by index number NW-1837UC-ll. There are very few climatic data for the area tra- versed by the transmission line corridor, particularly in regard to wind speeds. The Interior Zone (north of the Alaska Range) is domi- nated by high pressure air masses resulting in relatively mild winds. The Transitional Zone (south of the Alaska Range) has generally calm winds, although high winds over 50 m.p.h. can be expected. The Mountain Zone (Alaska Range) can be expected to have the highest winds. High winds are reported to have knocked down 138 kv towers in the area lying between Cantwell and Healy. As stated in the EIS, the net firm annual energy delivered to Anchorage and Fairbanks would~ 6.1 billion kilowatt-hours. This is net of losses in power transmission, which amounts to 0.7 percent of the energy generated at the power sites. The two referenced power grids are comprised of existing networks of transmission facilities which separately serve the greater Anchorage and Fairbanks areas. Yes, they could be interconnected without the proposed dam; however, it is not necessary to connect them. The advantage to interconnection is largely related to the greater relia- bility of electric energy supply to the two separate communities. They would automatically be interconnected if the proposed hydropower system is developed. 197 The marketing agent and operator of the system would be the Alaska Power Administration. For a detailed discussion of secondary energy and attraction of industry, see response number 255. 198 Ideally, the interest rate shown reflects the opportunity cost of the funds committed to the project. It should not necessarily reflect current financial market conditions, but rather the approxi- mate return to savings and investment over the 100-year project 228 life. Current high interest rates are very possibly a short-term aberration. By law, the interest rate is annually set equal to the average interest rate on long-term government securities, limited by a maximum increase of 0.25 percent per year. A sensi- tivity analysis using a range of interest rates is described in Section C of Appendix 1 to the Interim Feasibility Report which is available for public review in the District office. The costs mentioned are costs of different systems with different capabilities; they are not altered cost estimates of the same project. Currently available power sources (coal and natural gas) could supply the needs of the railbelt but at higher cost than the proposed plan. The energy needs of the Railbelt area are discussed in the revised main report. If constructed, the selected plan is to meet increased energy loads during the period from about 1936 to 1997. During this time, if the load projections are not exceeded, the existence of the hydro project would take the place of any net addition to thermal plant capacity that would otherwise be added in the Railbelt area. 1.99 Col1lTlent noted. 229 ~reate~--~~_,!l~~a~!_­ CHAMBERof COMMERCE I . October 12, 1975 C>·o•sroad• of !he Air \l'orld Colon~! Chdrles A. Debelius District Engineer Corps of Engineers P .0. Box 7002 Anchorage, Alaska 99510 Dear Colonel Debelius: On behalf of the Board of Directors and membership of the Anchorage Chamber of Com~~rce, 1 wish to express our total support for the development of hydro- electric power in thP. Upper Susitna River area. The Chamber would like to offer its services in helping to promote the con- struction of the Devil 's Canyon and Watana dams as soon as possible. Please call on us for any further help we may provide. Sincerely youl's, 200 ll d~~J~~ - Loren 11. Lounsbury "j)t- Pres.ident U GPE-.~TEn ,.a..NcHOR.II(;.E. CHAMBC"' OF COMMEFICE-ISil F STREET. ANCHORAGE, ALASKA !iUt!501-t'GII07) 2.72-~401: 230 RESPONSE TO COMMENTS BY GREATER ANCHORAGE CHAMBER OF COMMERCE ;..?.00 Conment noted. 231 •)hn COlberg. Jr; '"""-• ol !he llo<Ud Roy Huhndorf ~~JSl~ Al~ska District, Corps of Engineers Attn: Colonel Charles H. Debelius, District Engineer P.O. Box 7002 Anchorage, Alaska 99510 r I October 9, 1975 Preaida111 This is to notify you of a possible error in the impact statement ."Hydroelectric Power Development Upper Susitna River Basin Southcentral Railbelt Area, Alaska." On page 39 the second paragraph under Archeological Recources Btates that, "two archeological sites within the general vicinity of the proposed transmission line corridor are listed in the National Register of 4 February 1975. These are the Knik and Dry Creek Sites." According to Doug Re(.rcr, State Archeologist, the Knik site is not an archeological site, but .:~n historic townsite. It i.'s not listed in the National Register as an archeological site (p. 5250}. However, Dry Creek is listed as an archeological site. Employed as a research assistant with the Cook Inlet Historic Sites Project, I have encountered this apparent inconsistency. The Project is involved in compiling an inventory of Native histor.ic and cemetery sites in the Cook Inlot Region. If you have any comments on this matter, please direct them to: 201 1 Thank you. MW/mr Mary Weirsum Cook Inlet Historic Sites Project 1211 West 27th Avenue Anchorage, Alaska 99503 232 Sincerely, Mary Weirsum, Research Assistant Cook INlet Historic Sites Project 1211 W. 27th • ANCHORAGE. ALASKA • 99503 • PHONE 274-8638 RESPONSE TO COMMENTS BY COOK INLET REGION, INC. ~()jl The correction has been made in the EIS. 233 Kn:tk Kunoers & Kayakers, Inc. 30lL~ Columbia Anchoraec, Alaska 99504 17 November, 1975 Col. Charles A. Dehelius, District Engineer 1\.l.aulca DJ.st:r·.lct, Cor>pa of Engineers D(!parlment of the-Army P.o. Box 700~~ Anchora~e, /\la3ka 99510 Dcur Col. Dc~br;liu~: rellc l(nJ.k J\'<mocr~J & Kayalccrs wish to go on record as opposing l-l1r: con:Jtructlon of uny damn on the Susitna River. Such dr:vr:loprnr.:nl lvould destroy a major wilderness whitewater river, tr'l"lllcd 11 thc bic;c;~st :Ln North America" by its first paddler, 1)1'. \'lu1ter TUaclcadar. I11 the 1 f:lftleD and. 1 s :ixtien the Corps dammed a number of' t.hr~ natJon's finest v...-hitcvmter rivers in the name of 11 progress." Yc:t each ncvJ dam served only to spur on further profligate uuc of cnr~ccy. In other vwrds, these beautiful rivers were :::;;Ha·11'J cNl to no LWcful purpose. Nmvadays such economic l >OOIH.lor;r:,ler.> would never v11n approval, yc t the Corps is attempt- tnc: to :~ tn.rt the :>u1ne dr!:J tructl ve, was tcful process here with nllr. or UH~ c uun troy 1 :; mo::; t spectacular, wilde~ t, loveliest r:·Lvcr~. 'l'hc Susitna munt be left to run free for future ccnc.; cu tion~>. -~- ' 234 Sincerely yours, I .)., . ......-v·•··--~---:..--""-"p-~ Ed Swanson Prer.;ident 20~ Corrrnents noted. RESPONSE TO COMMENTS BY KNIK KANOERS & KAYAKERS, INC. r-rom: Orah nee Clark Jr. High 150 South !3ragaw Anchorage, .AK To "'hom it may concern, October 8, 1975 · · The seventh c;rade sixth period class took n . poll,· "i:ui.d has decided, at tho rate of seventeen to thron, naainst the series of dams, bnr,inning with the Dcvj_J.s Canyon Dam .. \.Je decided against it for. vn.rious rea.sonsj ( 1) that it "rould harm tho ecology, ( 2) That it "'ould h~m the natural .1· 'habitat of moose·· and other:wildlifu,l}nd (J). that it "'auld damage the scenery, •.1hi. ch \.IP. fcf:] hns berm d8.mntjod <'!not~[';h. Ho \Jere uppolntcd to this conuni tee by our teacher Hrs. Stark of Ornh Dec CJ.a.rk Jr. Ilir;h~. Sh~ _eave us the pro! s and con 1 s of the issue, o.nd took the poll. Reopectfully yours, Kris Ashley Theresa Rusnak .... ,.J•\ :'<.~O~J Comments noted. - RESPONSE TO COMMENTS BY SEVENTH GRADE emAil rlF r f. I /IJH' ,JR. H 1 GH SCHOOL 237 204 205 Sierra Club 3301~ Iowa~ l 15 Anchor·ac;c, Alaska 99503 15 November~ 1975 Col. Charlc~ A. Dcbeliua, District Engineer JilLt ::;lm DiGlrict, Corpa of Engineers D~!Plll'tmcnt of the Army P.O. Hox 7002 Anchora~c, Alaoka 99510 nc: NP/\EN-PR-EN Dcnr Col. Debelius: The followin3 are~the comments of the Sierra Club on the Corps or ;::n!.£lncer:..;' draft environmental statement on Susitna River hyclropo\·lcr de vel opmcn t. 'l'l1c clrart stu.Lcment i:J inadequate. Its basic fault is that it i:..; one lone; propac;anda piece, vri th a notable lacl<: of hard data preoentcd. Such date must be supplied in the final docu- rnell t :..;o that reader::; can malcc a rational choice as to vthcther the pr·opo:5ed Susl tna uam3 arc economically and ecologically ju:..;tlfiablc. · There h6~ been a serious failure to discuss alternatives to tlw proJect. 'l'he Federal Po~r1er Commission did the scopine .:tn~1ly:~ .L::; to .sclcc t the least-cost alternative for. comparative cvaluntlon with the .hydro pr~ject. In doin3 so, the FPC climi- na t8d fl•om con~ideration several al terna tivcs \'lhich could, if allocated the ~1.5 billion projected hydro cost or even lesser ~~<lount.:J, compare favorably to the dams. These alternatives lnclude colar, Hincl, c;eothermal, and tidal pm.,cr c;eneration :.;:,'~~tcm~; and :l.nvcstment in conservation measures. ' . /\lnslm '~ m;:ijor pmrer sources for· at least the next decade. During 2 0 6 th.i.s tlme it rnalcc3 much more sense to invest in technolor;ies IThc DRIG recoGnizes that oil, natural eas, and coal will be \·il1lch the scopine; analysis ruled out and have them on line by . tlw end of the decade. lA major advantac;c of non-hydro alternatives is their flexibility. Coal plants, for example, can come on and off line in response to 2 0 '7 demand. Once a hydro project is built it \'Till generate large a:.10unts of electricity rer:;ardless of need. The effect of this will be to attract iQdustrlcs that need laree blocks of electricit~ I On pac;c six, it is stated that '1The benefit-to-cost ratio compared to the coal alternative at 6 1/89~ interes.t rate and 100-year 238 project life is l.l~ usinc; Federal financinc;." Surely 'the \'iritera or the DEIS understand thn.t a benefit-cost ratio is 2 -meant to indica tc whether a project 1 a costs out\·tcich its expected benefit::;. It is an internal relation:::;hip and the coal alternative 3hould not have entered into the calculation at all, thouch it ia proper, once the D/C ratio is computed, to compare lt to the B/C ratio for other projects. Furthermore, toe DEIS e;i ven no information on how this figure vvas arri '\,!ed at.· Hhat are the project's expected benefits? On page 71 recreation and flood control are mentioned as benefita, but within the body of the DEIS flood control is' otherwise never referred to. The Corpo accepted the FPC scopin~ study and proceeded to evaluate coal as the lea~t-cost alternative. Coal was evalu- ated at a 8.77~ discount'lrate while the hydro project was evalu- ated at the 6 l/8% interest rate prescribed by the Principles and Standards Act (which, .while a vast improvement ove~ the ridiculous interest rates the Corps used to assume, is still extremely low in terms of today 1 s money market). The draft interim feasibility report gives a B/C ratio of 1.4 for hydro and 1.3 for coal. But the difference in interest rates seems to account for the reason the B/C for hydro is more than that for coal. Even with that favorable interest rate, the ratios are almost the same! Furthermore, the B/C analysis ~ives no . wcieht to flexibility and responsiveness of the power generating systems. The coal alternative is a flexible system which the private sector would .finance, and coal is a resource which can be developed ton by ton as it is needed. The hydro project would be an inflexible commitment of resources underwritten by the federal government; its 11 front-e~7-d 11 costs are extremely hi~h and repre3ent bills which fall due before any energy is produced at all. · Another flaw in the B/C study ia the estimate for recreation benefits. Recreation benefits are.estimated at $300,000 annually. Irt fact, there are virtually no recreational benefito for the project and there arc very hi~h recreation losses. Accordine to the draft interim feasibility report (p. I•'-3), 11 Few places in the world offer the variety of outdoor recreation resources available in Alaska ... Both residents and visitors alil<e have unexcelled opportunities for recreation activities among a pro- fusion of beautiful lakes, rivers, and mountains, largely un- touched by modern civilization." Given these fortunate -circum- stances, why would anyone want to visit a narrow, murky, arti- ficial lol<:c? 'l'he Hatana reservoir, \<lith its annual drawdo\'m of frrnn 80 to 125 feet (which would be at its worst in early June, then rise steadily throu~hout the summer)1 would be virtually unusable for recreation purposes. A boat-ramp which can allow for a 125-foot variation in water level in a steep, narrow canyon woyld be difficult indeed to design. The Susitna flows "some 130 milf?'S through uninhabited.country 11 I (p.. 10). This is another, roundabout way of stating that it flows 130 miles through wildernes~. .Were the writers of the DEIS 239 208 209 216 3 2111 nrra.l.d that the I·Tord 11 \tllldcr-ne::;::;" mir;ht IIID.l<:e the river in its -undarnmcd state sound too valuable? 212 213 · Tl"le :;;tatcmcnts at the top of par;e 111 arc misleadinr;. It should tw noted th<:~.t none of thc::::;c rivers is Clas:J VI in its entirety. 'l'urnbaclc Canyon on the 1\lselc can be portar;cd; the rest of the rlve1• lws been run by inexperienced lcayalccrs. Devil C<:~nyon on the Susi~na can al::>o be portaced; here ar;ain, the river above the canyon c;:in be <:~nd has-been run by kayalccr::; of limited experience. Lcs:J i::; lcno~tm or the Brcmnc'r, but the heavy whitewater is con- fined to ita two canyons. Th~ point i~ that even a very diffi- cult rlver c.J.n be utilized by 'inexpert kayalccrs and rafters if the raplds can be portac;ed. As for Devil Canyon itself instead of m<.tl\:inc value judr;ements and usinr; loaded words like ''daneerous, 11 the final EIS should emphasize that it is attractive to·l<ayakers precisely BECAUSE it is difficult. Walt Blackadar, the ·first i)crson to run it and a heavy-water paddler or extensive exP.er- ience, termed .it 11 the bige;est whitewater in North America. 1 • r mt:lon is made here that the Su:3itna was recommended as a BOR study rivc:r ''t.n1t vms not one of the 20 rivers recommended for inclusion in the (Wild & Scenic Rivers) system by the Secretary of the Interior in 197ll.11 'l'rue, as far as it goes, but it doesn't go fnr enoue;h; Interior's d-2 bill is only one of seve~al. The Susitna io indeed proposed as a wild river in the conservationists' d-2 bill, as the author~ or the DEIS were surely well aware. I Pac;e 23. 11 Sevcral 11 ne,stine pairs of bald eae;les and gyrfalcons 214 \·Jere observed in the canyon area. Hov1 many is "several 11 ? vier e there so many that they could not be counted? 215 216 On the same pac;e, it is noted that 11 Motorized all-terrain vehicle acccos to the baclccountry has improved huntJn~ success even in the f;)ce of a r<.tpldly decllnlnr; caribou population" (Nelchina herd). A critical factor has been winter maintenance of the Nabcmm road, Nhich pcrmi t::::. :::.nm·Fmobilers to haul their machines in as far as they wish in comfort, then tal<e off. Caribou-- especially prc[_~nant cow::.--are not able to withstand the rcsul tant noi:Jc nnd harasnme11t. Roads va::::.tly increase the activity of off- roud vehicles, and the Su::;itna damn will require roads (built at state ex~cnse?), presumably maintained in winter (also at state expense?). The final EIS should 1nvestic;ate the·probable con- sequence::::. to an already threatened caribou herd. ' l'nc;c 211. 'l'hc mops throuc;h the cnt:Lre docUiucnt arc ooor. Only :JOrnuonc vtho rcc otjnlzc:::; the shape of the Su:::;l tna vtould be able t.o loc<:~tc it on the .map3, since it is not labeled. Yet pt>csumably the relationship of the river to the habitat being mapped is critical--far more so, for instance, than the location of Cordova (v1h,lch appears on each map). Without knowing which line represents the river, and the location·or eac~ dam, the graphics are quite literally meaningless. I Hunting, pressure for rams in the Cantwell-Healy area is 11 fairly 240 - .. heavy due to relatively c;ood access from high\'tays, by air, and by A'l'V 1:.:;" ( p. 27). 'fhe statement is true, and the Sus i tna 4 hydro project would provide equally easy access for an area that 1o now w1lderneoo--a road, which can also be used to haul A'rV 1 s on, and two or more enormous lakes to land a floatplane or ski- plane .on. The effect on moose, caribou, and boor ohould be noted in the final EIS.· The Susl tna area "has consistently produced Jaot·c \'hll Vl,'l':lllc:.> tkm any other area of comparable ::; lzc in tl1e. S t.a lc ••.• t·Jol V!,;l'lnec have withstood human encroachment and tr<J.ppinc; Nithout any noticeable reduction in numbers or rane;c" (p.-28). Yet it has already been <J.dmltted that the area is presently wilderness, so any 11 encroachment 11 so for ha::; been huntinc; lodc;cs and trappers' cabins--not 70,000 visitors a year. Would the DEIS have us be- lieve that wolverines Hon't mind the dams, roads, people, noise_, etc.? Absurd. The wolverine is an extremely secretive, wary wilderneso species which cannot coexist with highways and industrial development. ru'ge · 37: 11 J:i'loa t planes are uned to fly in hunters ••• but this form of access is relatively minor.~-•• A major recreational use ••• ln big-game hun.tin~ •••• Th~ greatest pressures are exerted from a few fly-in camps.11 If fly-in access is 11 minor," then how can it produce the "greatest" pressure in a "major" recreational use? The statements are inconsistent, a frequent problem in the DEIS 11 It appear::; that the usc of ATV's for hunting, already prohibited in some. a·reas, may have to be further controlled. 11 This state- ment misleadingly implies that such use ~ be controlled, when in fact it is very difficult (and expensive) to do. What will be the costs of the extra wildlife protection officers needed to enforce such a closure in un area wherefeasy access has newly been created? Who will pay these costs~ race· 38. A~ain, the superlative, hu~e whitewater of Devil Canyon is implied to be very unattractive, equivalent to lmplylnc; th<.lt Mt. St. Eliaa is "no eood 11 for clirnblnc; hccausc it is very difficult and succc~nful attempts huvc been few. ~-lc 1'1nd 1 t, cxccccllnr.:;ly oud that the DJ::IS wa::.; rushed·· to publication just before the Corpo was due to receive the Jones and Jones study on recreational use and potential of the Susltna. Although as <J. consequence \·lc have not had the benefit of reading the study itself, we understand that it recommends that the whitewater of ~~vil Canyon not be inundated, because of its great value as a scenic and recreational resource. Page 40, cner~y needs. Ac;ain, these are mere unsubstantiated otatementr;. . 'Because of lead time needed for coal and ·hydro- electric d~velopment, immediate needs for the next decade will have to be hundled by additional oil and 9as-fired units." True, even too e;encrous, as regards hydropower \the Corps fact sheet of Oct. 23, 1975 estimates c·onstruction time at 14 years), but Beluga coal has already been leased and is ready to be mined, and Heal;y coal is already in production and has been for years. 241 218 219 221 2~3 224 225 22'1 PQf~~"; ill. 11 llcavy cmrhnsis should be 13ivcn to those technoloc;ies wh:lch utilize rcnc\'IO.ulc or e:.;Gentially incxhau~tiblc encrc;y :::oul'ces. 11 It 1:.; prepos tcrous to imply, here as clsc\'lh'ere in the DE.r:1, that the ~Ju::;itna dilm:> represent the usc of renewable re-. :.;out'<.:e:J. A wlldernes::; rlver is not a renewable rc:::wurce. Once developed, it 1::> destroyed forever. And great;. wilderness white- water rlvcr~ arc not only nonrenewable, they are exceedingly rare, thanks largely to the Corps of Encinecrz. P<J.r;c II?.. More ~nrbntje c;raphic::;. tlhat on earth do the fic;ures on tile left rcprr.::~.;cnt'? 50,000 !HI/\rl'? On '.'shut infor·mation is the (~raph based'? Here ae;ain,. we are to accept it on faith. And it 1 s .:m old, old tricl-:: to Get forth one absurdly hir~h figure to make one 1 u preferred alter'native look rnorc reasonable by comparison. \Jiw tevcr those left-hand numbers symbolize, the high range indicate~ we'll use 19 times us many of them in the year 2000 as we did in 1970. Even hamsters dc.:>n't multiply .that fast. Pa1.:;c 115. There arc ::;ome intercstinc; implications on sedi-, menta t1 on here, al thouc;h the DEIS wronc;fully fails to make them cxpllclt. The avcra13e natural flow in the five high-flow months of May-September ls 19,328 cfs. If we assume an average sediment loo.d of about 1000 ppm (the DEIS says it is 11 less than 1000,11 lt~adlnrs the cynic to bel ievc tha. t it must be very close indeed to 1000 ppm), then 19.3 cubic feet of silt would be flm'fine; into tlle \'/a tana. reservoir. every second during those five months for a total of 255,130,560 cubic feet (9,L~49,280 cubic yards), just ln the May-Suptcmber period, every year. We will charita.bly n~sume that no silt enters the reservoir from October-1\pril. Me;mwhilc, of course, a small amount of :silt·is leavinG the 0y::;tcm: 15-35 prm year-round in on uvcrac;c flm'l of 9300 cfs. /\r~aln (~cnr:rou;;ly n::;oumJ.nr~ that l.l llJr~h 32 ppm leaves the ~;y:.;Lcrn that 1 :.; .3 cubic L'cct ol.' Gc<.llmcnt lo~>t per second or ~),lluO)~oo cubic feet each year (350,l~OO cubic yards) •. In short, 9, 1ili9,2DO cubic yarda of silt, sand and r;ravcl entering the sy~tcm every year, 350,400 cubic yards c;oinc; out, and a net yc~rly eairl of 9,098,880 million cubic yards. That 1 s a formidabl~ amount of silt. Con the Corps euarantee that reservoir siltation problemG will not occur here as they have at other dams? Pa1.~0 11(-j. If vthi te•t~a tcr can 11 rcduce substantially 11 the super- satllratcd nltr~oe;en and dissolved oxye;en introduced into the w;.1tur in passinr; over the apillway, then \-Jhy not leave more vlllllcvt\1 tcr ava.:llable for thls useful purpo3C, instead of sub- lllCr[~ine; nine of the 11 miles of Devil Canyon? Pa(.ic 113. 11 Futuec detailed stuc.lles 11 will be necessary to make sure ~cncrul chntlnel degradation won 1 t occur below the dam as the rl vcr a ttcrnpts. to rcc;ain its normal scdimcn t load. 'fhesc :.; tud:Le~; arc to be part of 11 pre-construc tion planning,'' ·which the Corps would have us believe does not necessarily commit us to buildinr, the dams, despite th~~ name. I \ve nrc told that the Wa tana would flood ex is tine; fish habitat but might create '1 other fish habitat at hi~her elevations on .... 242 . . 6 theGe trlhutnries." Perhaps. But it 1 s certainly not c;oinc; to I replace !3p{;HI/l~ habitat, which requires clean, well-oxyc;enatcd . 13ravcl; not ~ttl1llc the i-Jatan,a reservoir is fluctuating 125 feet 2ztj every r.umrner! Page 49. The Susitna carries winter silt loads of 4-228 ppm; earlier the.DEIS had termed the winter water 11 Clear.11 Yet the dinchapc;c below the dams would be 11 milky 11 at 15-35 pprn. Both statemcntG can't be true. The problem may be that the DEIS 229 tends to usc flc;ures distorted by extreme circumstances when the mode \'lOUld be more usq f'ul. Trl vial here, perhaps, but not so elsewhere--as regards energy demands, fo~ lnstance. Par.;e "51, the question of fish h~bitat in lakes with heavy Gilt I lnflow. 'l'hc DEIS admits that it could be a problem, but mentions the many natural lakes \·there there is f13h habitat despite heavy 230 inflows or silt. But these lakes have equally heavy silt flows back out, LlS anyone knows who has paddled the Tazlina. 'l'he lakes don't simply silt up as the Watana reservoir will eventually. Also on thin rac;e is the first hint ("the proposed series of h!J:jh-hcad dilm!i 11 ) that the Corpo does indeed intend to build all four dams once it gets its foot in th~ door, despite the pious (13surance on page 89 that "the mac;nitude of environmental lmpo.c ts resul tine; from a four-dam sys tern in the Upper Susi tna 231 Rl ver Basin clearly makes this a less d¢·sirable· alternative than the one-, two-, or three-dam plans.11 The final EIS should make·explicit the Corps' intention to build all four dams. Pac;e 52. The problem of ice shcl ving in the \rla tana reservoir and the attendant difficulties for caribou and moose attempting to cross it is a serious one and there is no justification for r;losGing over it, as the DEIS does. Studies indicate that cari-232 bou usc of the \•Jatana site .for grazinG and cro::;sing 11 was minimal durinc; the period November 197t~ throuc;h April 1975.11 One five- month study} on a migratory species like caribou, 1::; of very limited utility, yet the render of the DEIS mic;ht well rccieve the· 1mpre:::;sion that 1 t proved thr:l t caribou do not and will not usc the area. No such conclusion is posoib~e on the basis of a single winter's study. Pac;e 53. Countin[$ conditions in June 1971~ were "less than ideal." ADF&G saw only 356 moose, wherens they 1 d seen 1796 the '·previous fall. Unless the winter wa::; inordinately ::;evcre, we can assume that countinc; conc.lit.lons were not merely 11 lca:3 than idcnl 11 : they were totally lnadequa te •. Yet the DEIS mention::; the fi~ure:J as 233 thour.;h they were meanine;rul. 1\D!o'F:.G han rir;ht Cully rc::wn ted the unreil:Jonuble ha::;te with which it ha~ had to curry out itG Susitna dam otudieD, and on a meager budeat. Cooperation from the Corps has been very poor. Page 51~, trannmission line impacts. The DEIS sta tez t~ere will J be "not many per se; most ••• will be as a result of construction and.maintenance." In fact the growth the Susitna dams will foster, and the easy access i"t will provide~ will cause major 243 • ·7 ·r 2 3 4llmpnct:::;. /\nd ar; nny hunter can attest, ..,.,ildfowl tend to avoid tJ·o.n:..;ml::;:::;lon l.Lnc corridors • 235 .P:1r~c ~(). 11 Tnlt.tal annual visitation to the projc~ct area would 1be a'Uout ·n, 000 people 11 ! Is thi::> figure part of the source of· tlmt inflntcd 1.11 D/C ratio? Hovr was it derived? If 77,000 pr:ople really di<l u:..;e the area (nn opro~•cd tP l~li~t·r:l~· (h'.lvln!~ by out of curio::-;.lty to (~lance nt tlh• d:un, lv\11 .• •1\ 1\'••u\,\ \la~·,\\y peovlc\c Ll sir;r1:li'lcant rec.J''(!!tl:.lnlt:tl IH'IH~l.'.U.), l.llc .l.mpni.!L 1-1ould be trcmcndou:.;ly heavy. Clt·n .'l.':d.lru(~tnn (~op. 2l)0) lmndlc sucll·a 1vJ.sitor load? I PJ.~e 57. 11 r~uch of the ox:l:>tinE tree and sh·r.tlb cover in the Upper 2 3 6 .::u:~j t..nn fUver Basin is located in the river n.nd creek bottoms . · <:trtd on the steep canyon slopcr; above the streams and would be lost durtne; darn con;jtruction.11 'l'his is importa'nt moose habitat. 237 23 239 240 Pac;c 61. I.nncl alone; the Susi tna 11 is. a natural and scenic area t..lla l. would 12.rabal.!.l.;L qualify for wilderness classification under !!~Ql;l dcflnll:l.Oli:J ol' the term." (Emphasis added.) Under what dcf:lnitlon could it po:Jsibly fail to qualify? The proposed Corps project would definitely destroy a wilderness river and area of hleh qunlity. That fact should be admitted forthrightly in t.hc flnal EIS. 11 'rhe prop_oscd trnnsmission line corridor would cross no existing or presently proposed scenic, wild} or recreational riversJ nor v;oulcl. 1 t cross any existing. or presently proposed wilderness . m·ca!.; or \·lildllfe refuc;es. 11 'frue, but \·lhEJ. t of the dams "them- r.clvcs, anu the proposed Susitna National \Vild River of censer-· vutionlsts 1 d-2 lcc;islation novJ pending before Con(jress? 11 Be tween Gold Creek and Cantm::ll} a visible (power) line would . h~vc ~ubstantinl impact, particularly if located west of the hlc;hwny and rallrond.11 It could not be concealed throuc;h Broad Pa:;n, This area provides some of the most strikin~ly scenic · vJ.cw::; of ~1\:.. r1cKlnley and the impact of nuch a transml~:;::;ion lJ.nc ~>t01Jlc1 be devnstotinc;. It 1::; appnlling that the Curpr. would even con~Ji<..ler placlne the line on the wc::;t niuc of the hic;hwny and railroad. Par.;c G2. How fortunate that the "most likely 11 source of an 8.5 car·thquake would be a 3nfe IJO miles distant. Yet it is also ad1nltt.<.:d that Hthe Su:::;itna Fault, truncated by the Denali PnultJ ~i~ccls the rcEion in a northca8t to ~outhwc8t direction appt"ox:l.tllii.Lt.:ly 2.) mllc:J 'IIC:::>t of the: \·Jntanu durn0:LLr:,11 vll'1ot ::;t.ucJlcs or tile i'uult :-,;y:;tcm and 11 rnost .lilcc~ly 11 quake::; have been uorH: by indcpc~nch:nt scl:imlc cxpcrt:-:1? \·Jhy doc:.> the DEIS contain. no map::; or r.;l'aphic -: di:::;plays ~lhowine; the loca tlor.L of these raul t:..; '? \·Ja:J it feared thn t. 1 t would loolc a 11 t tle too graphic only 2.5 mlles from an 810-fool-hieh earthfill dam? • IPnee 63 •. There could be ice-foe conditions in the area below Devil Canyon Dam "during period::; of extreme cold weather.~~ The implication is that ice fog is a rare occurrence indeed, happenine 244 only under ''extreme 11 conditions. Alaskans lmow better. \vhy did the DEIG not frankly state that ice fo13 would, be present? It'o hardly a critical point. Of cdurse, the defensive attitude carrie:.:; throu~h clse\'rhere in the DEIS to mor>e important rna tters. Page 6h. 11 'J'he proposed projects will not create large blocks of excess electric power for heavy energy-consuming industries." An amazing statement! Without some good demand figures, how are we to believe this? What of the Healy and Beluga cotil and the Cook Inlet and Prudhoe gas? Are these other entrepreneurs 8 ex pee tcct to give up-.their mrlccts and go else\'lhere? More plausiuly, there will be a vast surplus and industry will be cncourut:;ed to come up to Alaska to use it. And in fact the Corps• own Joe Auberg (Western Planning Division, Washi~gton office) says that the final EIS will recognize that construction. · of the hydro project would mean commitment to a growth policy · for the oouthcentral region. Can the town of Talkeetna handle the impact of 500 to 1000 conntruction workers? 'l'he construction period ::11 auld be mentioned here. The reader should not have to look up a oc~uratc Corpo fact sheet to find that the project will take 111 yearn. l'i.tl~'~ (j). Prol1l cm:J w .l th tempe t•n tur't!, tUG o ol vcd oxyljen, · und oupcr .. :;a Lura t<:d n1 t.rotjcn "would be held to minimal, and poss iuly in::;ie;niflcant levels by spillway design ••• 11 If the problem is really that easy to solve{ why does it still exist on other major dums (e.~. Columbia)? The final EIS should not imply _that the Corps has the answer to all the questions on super- saturated nitro~en, etc. It doesn't. Pac;e 68. 11 Future power systems 11 (but not this one?) "will also require approaches. that include full consideratbn of environmental values and alternatives and must anticipate that Alaska and ·the nation will attach increasing importance to environmental pro- tection, energy conservation, and conservation of nonrenewable resources. 11 Ac;ain the DEIS fails to recognize that huge wilderness whitewater rivers are nonrenewable resources, and scarce, too. · Nor is a dam, rapidly filling up with silt, truly a 11 renewable 11 resource. Pa~cz 70, 73. It is interesting to note the close proximity of major coal and petroleum resources to the cities of Anchorage and Fair~l:Janks. Since the concept of the "rail belt" as having high en~rgy needs is fallacious (the two widely-separated cities of Anchorage and Fai~banks are heavy energy consumers, and so to a much smaller extent are the to•ms of the Kenai Peninsula, but t'he handful of homesteaders, U.odge-owners and railroad workers livinc; along the "railbelt" alccount for a minute share of the total energy demand), why not simply utilize these nearby re- sources, which are already being developed, and without the need for federal funding? Or is the Corps-telling Alaskans: that we .· 245 . 242 244 245 I rnus t endure the cnv:l.ronmcnto.l costs of s trip-mininc; for coal, and Lilt! :;t1·e:;:.; oi' p.lpc:llnc t>oom:-J_, uut are not to uc permitted to 246 ~~;1l.n any llr~rwru fron1 tl1e dc:veloi)mcnt of our :..;tate's resources? f·lu:;t ;dl uur• ~oal, oil <.md r;o.~ be shipped to the Lov1er h8 for otl11:r:.> to u0e ':' l'ilf",(! '(~). 'J'hc foPccast or cnc.?rc;y needs is absurd. Havinc; used 1.11 ml.Jll on bar1·el:..; or o.il and 16 billion cubic feet of natural 9 247 1:~;!:; :l.n .11.)'(~~ .. we <Ire cxp0ctcc.l to usc.? (under ''mid-ran13e'' estimates!) ;~() rnJ.lJ.Jon b.Jrrr:l:..; of oil (19 t.Lmcs a:.> much) and 134 billion cublc Ccct of c;a::> (eight timcG as much) in the year 2000 ''if l'cccn t t:r·crHi:J continue. 11 ~H thout further documentation of tllc:jc amaz:i.n(j f 1i_:o;urcs, the reader must inevitably think them Cf1UlvalrJnt to ::;ayin(j, 11 If recent trends continuej the teenager v1.Lll lJc 10 1 6" by the time he's 33 years old.11 2 J 11 n1o:J t t.lcial flow hydroelectric proposals are major factors i Pac;c Tf. The "extreme costs and environmental effects involved 4 oppo:j111f,11 tldnl pov1er. True enouc;h; very few places in the v!Urld are .suitable for the development of tidal poHer. Cook Inlet happens to be one of the be;,t, however. I It. 18 noLl:blc that the DEIS find::; us· "too small" for nuclear power· 2 4 9 or· soJ J.d 1 Waste burnlnc;, but "too big" to be allowed to use our o~>m o:\..1 a_nd ga:J. 2 5O el~~ar<~d land at Ll t tlc or no e;{pen5C t~ the farmer." A danger- CHJ~Lly ll't'C:Jpon::;lblc ::;tntcmcnt ·'tl1at should be deleted from the I r~l/~1! G7. 'l'hc tranzmi!:;oion line "right-of -way 'v/OUld provide 251 1' lnnl t·:rs. na(lJ.a tlon from hlgh-vol tage power lines is ht.J.zardous to llvlnr; tlsuuco. Pu~c.75. · The difficulty of safe disposal of radioactive wastes · 1~ noted. Many people question the wisdom of a system that must rely on many future c;enerations to deal responsibly with the by- product~ of cncrBY used by this generation. Dut the same argu- n :nt can be ral: . .>cd in connection I'Jith this hydropO\'ier project. Even lf it becomes obsolete, even if it silts up and can no longer produce power, a huc;c dam must be maintained and repaired forever, elGe downstream residents will be at risk of horrendous floocl:::; or mud-slides. A dam is a sword of Damocles hanging over the lwnds of our c;reat-granchildren. Pac;c 911. \•/c concur with the J\laslca Energy Office criticiGm that the final EI.S should ipclude a net energy benefit analysis for the whol~ :::;y~tcm, includ1n~ the enercy used during construction and lessen durinG lon~-distance transmission. Pngc 6, co~t. Total first cost ·(January 1975) prices of $1.343 bJ.llion. There was no justification for us1n3 January 1975 prices in the DEIS. The Corp3 1 Octob1:.c 23 fact sheet already shmoJs a price jump to :p. 5 billion (a ~!>15'7, 000,000 rise--more than enough to build Senator Gravel's federal office building!), but even this figure is ludicrous. The contractors will not be paid in 1975 dollars. The came fact sheet mentions a 14-year construction period. If the project \·;ere already in proc;ress today,· it could not be fin1s,l1ed until late 1989. The ~>Jhole DEIS is filled 10 with speculative projections on dubious grounds; why was there 52 no projection of costs in October 1989 dollars? If inflation rontinuco at its current 13~ rate--note that we ar~ playing the t..-orp~ 1 m·m r.;amc here--the final cost \r/ill be $8.33 billion, a ::>taer~crinr; Gum. nut let us a::;:.;umc that inflation will be nonexistent for the next ll~ years nnd that there will be no cost overruns. A modent proposal: instead of building the Susitna dams, that $1.5 billion could be invested. Even at a mere 6%, it would produce $90 million a year. It could be split up among some· 4oo,ooo people.expected to live in the railbelt area at $225 per capita. Surely most Alaskans would prefer to have the cash--253 :~900 yearly for a family of four would go far toward paying the ~as blll~--and the ccnerous u.s. taxpayer would be sure to approve, oince the $1.5 billion principal would remain untouched. !\ bcu.utlful '<'J:Uderness whitewater river·\'wuld not have to be destroyed, and Alaskans would not have to suffer through still another wraclcinE; cons true tion boom. The hydro project not only makes little sense for Alaska, it I makes little sense in terms of a \'lise national energy policy. The opportunity cost of investing $1.5 billion to produce power for approximately 1100,000 people is extremely high. This large an 254 invc~tment in projects other than hydropower could provide more cner~y for more people at lower environmental cost. 'l'he DEI:l :>ucr,c;csts that !\laslw. would be dependent on .oil and gas durinr; the darns 1 llr-ycar construction time. l·Jhen thy dams come on l:.Lnc, the hydropoucr would theoretically replace oil a.nd natural 1~<1G r;cncratlnc; facilities thus freeing up the oil and gas to be shlppcd to the Lower l.~S. (This scenario is unlikely to occur, as c~rlicr noted, because the hydropower would probably attract larc;e block industrial users and stimulate demand, rather than meetinG existln~ and projected demand.) But even if oil and natural c;as were no longer needed .for electrical generation, the yearly 8avlnr;s would be insignificant compared to national oil cot1sumptlon. The DEIS states that estimated 1972 fuel use for 2 55 !\laska' s power system::> included l.l+ million barrels of oil. For purpor;cs of comparison, in 1972 the nation as a whole used 5 .. 99 billion barrels of oil. (Source: Ford Foundation Energy ·rol icy Project, Preliminary· Repar t. ) Thus Alaska represented leus than one four-thousandth of the total demand. A major c;oal of the project is to conserve fossil fuels (p. 91).· 11 By the :=.;arne token, the project would contribute to a savl.n~s in nonrenewable energy resources with an cncr~y equivalent of about 11.3 million barrels of. oil, or approximately 80 billion cubic feet of gas per year. Althou~h this savings is a principal factor in the consideration of a hydroelectric alternative, QVer the lon~ haul hydroelectric energy must be viewed 247 257 c:t:i an :tn l:'~ r ltn ll\!.:.:t:.;ul.~c for c on:::;crv inr; the na tj_on 1 s nonn:tw•,;;.dd.l~ C:nL:I'I~Y :JourccG unl i I some rttOl'C pl'Clc- 1.; .teal, J::tTttlt.lncn t method of prod1.1c inc; clec tric l ty J.:i <.Icll.Lc:vr~d \·fh:.i.cll 1·J.I.ll not ovcrbur'den the na t:lon 1 s or 1'/orld 1 ~ flnltc rc:;ources. 11 nut $1.5 billion invested now in new enercy sources and con- :~CJ.'Vd.\..J.on r;v•:t:..;ut'l:::; I·JOuld yield much c;t~catel~ ucncflt.s. tlwn the d;::un:.;. 'J'hc r.:nr·pc, l~ pu~;ll1.tlC Cor "pr·c-conc;tructlon pl<.Inn:lnc;11 11 fund:l.nr-j f!n thouc;ll un energy cmerc;cncy r.ituo.tlon, r·o.thcr than n i>Ul'plu:;, cx:l.~~t;s or vlill e:xi~:.t wlth:ln tl1c next couple of decades. 'l'h~r<2 1:> no ·r:nwrc;(;ncy, hov1evc1'. 1\la::>lc.l 1:..; 1vcll Stlpplicd vlith · rm:rr~Y r·e~iOUl'Cc:; in the proccn::J or being developed. The just- relca~cd Gludy lJy the state Qivlsion of Gcoloclcal and qeophysicaJ ~~ urvc y r: hu\·/:j 1...ha L 1tri th tl1c Prudhoe Bay c;a:::; ol'lncd by the ·state 1·1e l·fl.ll,_llu.~u an cmbarra::.;:.:mcnt ~r cncr~y ricr1<:s. Since there:: is timeJ U1c :,.1.:; billl9n or :li3 bill~on or ;~B bill~on of the federal tilxp~j'C:r:J r money. 1·1hlch the c.lnms will cost should instead be lnvc0 t<!d in re:::;carch for al tcrna ti ve, bet tcr mean::; of cner~:;y pt•oc.iuc tion, re :::;carch Nhich would be a godsend to the whole nutlon. Sincerely yours, : I Jc-t!c/k.s:s.~~ Jaclc Hesnion 1\la::;ka Heprc:::;entative 248 2 0 4 Comment noted. RESPONSE TO COMMENTS BY SIERRA CLUB 205 The Federal Power Commission, in carrying out its functions under the Federal Power Act, is concerned with all elements in determining power values. The Corps cooperates with the Federal Power Commission in evaluating power benefits on the basis of unit power values developed by the Commission. Project power benefits include financing factors related to the alternative source of power, public or private, that would mos~~ be utilized to serve the same market area in the absence of the project. The alternative is usually a new, privately financed, modern, and efficient thermal powerplant. However, all alternatives are carefully examined. In the case of this stud~both natural gas and coal were chosen as the most reasonable potential alternatives. Gas was eliminated on the basis of projected availability at the time hydropower would go on line in 1986, and by the direction of Congress to conserve nonrenewable resources and to utilize renewable resources for power generation where possible. There is no longer any reason to anticipate this fuel will continue to provide an abundant, cheap energy source for the long term as has been exercised in the past. In calculating the benefit/cost ratio of coal and hydropower alternatives, the latter was determined to have the greater benefits. 2 0 6 Comment noted. 207 It is true that some non-hydro alternatives, such as coal, are more flexible than hydropower in response to fluctuation in demand. However, the hydropower project presently proposed will not meet energy demand projected to exist within a relatively few years following project completion. Thus, existing or future coal or gas plants may well be used to provide the flexibility to cope with fluctuation in demand above the level of baseload requirements fulfilled by the hydropower project. For a thorough discussion of the effect of the project upon industrial development, see response number 255. 2,)8 The coal alternative does enter into the hydro project cost-benefit calculation, because this alternative is the economic standard against which each of the hydropower plans is tested. That is, the power benefits of a given hydro system represent the cost of producing the same amount of power by constructing and generating a conv~ntional, state-of-the- art generation system using coal as fuel. Thus, the coal alternative, by definition, has a benefit-cost ratio equal to one. The interest during construction was added to project costs, and those expenditures accruing after 1986 were discounted to the 1986 power-on-line date at 6-l/8 per- cent to give the total investment cost. The present worth of the benefits was calculated also by discounting at 6-l/8 percent to 1986. The invest- ment cost and present worth of the benefits were then amortized at 6-1/8 percent over the 100-year project life to give annual costs and benefits which were then compared to give the benefit-cost ratio. 2ll 9 The coal alternative was not evaluated at an 8.77 percent discount rate. The 8.77 percent figure is used to calculate annual fixed charges and, as such, is used for different purposes than the discount rate employed in the hydro analysis. Incorporated in this 8.77 percent is the composite of municipal and REA borrowing costs in the Anchorage and Fairbanks areas. It is this cost of borrowing that is properly compared with the 6-l/8-percent discount rate annually established by the Treasury Department. The composite financing used by FPC in analyzing the public, non-Federally financed coal alternative was 6.25 percent interest rate for the Anchorage-Kenai market area, and 5.95 percent interest rate for the Fairbanks market area. 21LMost of the recreation benefits attributed to reservoir development are associated with the Devil Canyon site. Also see response number 81. 211 Comment noted. 212 The paragraph has been reworked to indicate that portions of the listed rivers are Class VI boating rivers, and that Devil Canyon is Q_i_fJicult instead of dangerous. For more infonnation on white water of Susitna, see response number 257. 21 3 The Corps of Engineers is aware that "The Sus itna is indeed proposed · as a wild river in the conservationists' D-2 bill--11 • Furthermore, all land and water within the immediate area of project influence, including the upper Susitna River, are tentatively scheduled for selection as Native deficiency lands, which are classified as D-1. Section 3.0 of the EIS is devoted entirely to a discussion of the relationship of the proposed action to land use plans. 214 The paragraph from which the word "severa 1" is excerpted refers to the 1974 findings of the U.S. Fish and Wildlife Service during a survey of raptor populations in the canyon area of the upper Susitna River. During this survey, three nesting pairs of bald eagles and two gyro- falcon nests were observed near the Devil Canyon area. 215 The Susitna River dams will require access roads which will be built at Federal expense. They will require year-round maintenance. The State may choose to incorporate these roads into the State highway system. If it does, then maintenance will become a State responsibility and cost. On the other hand, if the State does not choose to incorporate the roads into its highway system, maintenance will continue as a Federal responsibility and cost. Hunting pressure will not increase as a result of road access into the damsites since ADF&G has the statutory capabilities to control the actual pressures. Thus, only the potential for hunting pressure will increase. The Susitna River has been drawn with a darkened line to more clearly show its location on the schematic maps. 250 217 The EIS clearly states (in Section 5.0) that increased pressures on existing gdme populations through hunting, trapping, and general disturbance and harassment will require intensified game management and law enforcement practices. As previously stated, ADF&G has the statutory capabilities to control these pressures--albeit, at greater cost and effort on the part of State government. 218 The quoted statement is included in the EIS to emphasize the importance of Susitna River Basin to wolverines. Encroachment to date has included more than "hunting lodges and trappers' cabins;" it has also included hunting and significant impact on wolverines in the Upper Susitna River Basin. We have expressed concern, however, (in Section 5.0) that any losses to moose and caribou occasioned by the project will 11 ••• impact upon predator species." This, of course, includes the wolverine. 21 & Of course, the use of ATV's can be controlled. The Alaska Department of Fish and Game, in commenting on the draft EIS, has stated that it has the statutory capabilities to control the actual pressures of increased hunting potential. In the discussion of adverse environmental effects which cannot be avoided (Section 5.0), with reference to required road construction, it is stated: "This would have the potential to increase pressure on existing game popu- lations through hunting, trapping, and general disturbance and harrassment. This in turn would require intensified game management and law enforcement practices and preventative measures for the control of wildfire.'' Increased costs related to intensified management and law enforcement would be borne by the State . 220The•-e is nothing in the referenced paragraph which implies that the "Super- " lative, huge whitewater of Devil Canyon" is unattractive, much less 'very unattractive'." However, to be constant with an earlier change in adjectives suggested by the reviewers, we have substituted the word "difficult" for "violent." 2G1 The Jones and Jones report was provided to the Alaska District in f1arch 1975, and has been available in the District office for public review since that time. All relevant, significant information contained in the report was utilized in preparation of the draft EIS. With respect to the report 1 S recommendation concerning the inundation of Devil Canyon. the following is quoted from page 8 of the report: "In particular, it is suggested that relocation of the Devil Canyon Dam to a point above Devil Creek be investi- qated. perhaps at a higher pool level, coupled with relocation of the Vee damsite somewhat downstream and deletion of the Watana damsite entirely. Possible benefits include preservation of the esthetic resources of Devil Canyon and enhanced reservoir fish habitat and recreational opportunities.'1 In fact. not only was this alternative considered and evaluated, it was but one of a number of dams and combinations of reservoirs which were evaluated in selecting the proposed plan. The authority and responsibility for this final decision rests with the District Engineer--not with a consultant. 222 Comment noted. 2~ J The ElS candidly discusses the inundation of some 82 miles of the Susitna River, including 9 miles of the existing 11-mile whitewater section in Devil Canyon. The whole section from which the sentence is quoted deals with ~nergy needs. The Susitna River does. in fact, constitute an inex- haustible energy source. 2~ 4 The ordinate scale of the load projections on the projected energy demand graph was inadvertently not labeled in the draft EIS. The numbers in this scale represent kilowatt-hours (in millions) and have been so labeled in the revised draft rrs. The origin and meaning of the curves on the graph are fully discussed in the EIS. The mid-range load projection curve selected for the Corps• analysis is considered conservative. with annual rates of increase in power, requirements less than 7 percent after 1980 as compared to an historical annual growth rate of 14 percent during the period 1960 to l971. 22 5 On the basis of data from reservoir projects on many types of rivers, the Corps has developed a re1iable methodology for calculating sedimentation rates. On the basis of this methodology~ which includes consideration of geologic characteristics of the basin, river gradient, precipitation patterns, runoff characteristics, and topography. the Corps has estimated that the project will exceed by a large margin the 100-year life upon which economic just1fication is based {it fs presently believed that the useful life of the project due to sedimentation may exceed 500 years). 2~ b Nitrogen supersaturation is a phenomenon which would only occur when water is released through the overflow structure. This would occur at an estimated frequency of once every 2 years with a duration of 14 days. The overflow structure will be designed to minimize introduction of nitrogen. The expected impact of this condition is not significant enough to warrant relocation of the dam. 2 2 7 Quoted fully, the sentence containing the phrase "future detailed studies" states: 11 However, this phenomenon would be the subject of future detailed studies to determine the distance at which sediment loads would become reestablished." There is nothing 1n the EIS indicating that such studies " ... will be necessary to make sure general channel degradation won't occur below the dam ... " It is true that the referenced future detailed studies are recommended as part of preconstruction planning. Detailed planning of all Corps projects is done following specific Congressional authorization and funding of such studies. Following the completion of detailed preconstruction planning. Congress agafn determines whether or not the project should be funded for construction. ~52 2Gb The EIS states only that possibly other fish habitat would be created at higher elevations on the tributaries to the Watana reservoir. The actual effects can only be predicted on the basis of detailed field studies. There is a good possibility that reservoir fluctuation would not significantly affect spawning habitat. Drawdown will occur during the winter months, when river inflow is low. The reservoir will be filled during the spring and summer months of higher runoff. Should spawning occur during the period when the reservoir is full and relatively stable, there may be little adverse impact on any new spawning habitat created at the higher elevation. 22 9 fn describing river charac~eristics under existing conditions in Section 2.0 of the EIS, it is stated: "During the winter when low temperatures retard water flows, str-:ams run relatively silt-free." We see no conflict hetween this statement and the one on page 49 of the draft EIS which states that winter investigations by the Alaska Department of Fish and Game indi- cated that suspended solids ranged from 4 ppm to 228 ppm. Following project construction it is predicted that suspended sediment in releases at Devil Canyon Dam would be relatively low (15 to 35 ppm) year-round as a consequence of heavier sediments being retained in the reservoirs. However, even at this low figure, it is predicted that the water may not be as clear in the wintPr months as it now is due to the nature of the very fine "glacial scour" which will be introduced into the reservoirs during the summer months and r·emain in suspension during the winter. Sediment samples taken by ADF&G under existing conditions reflect a transport of heavy sediments which originate from the riverbed itself. Relatively high concentrations of large, granular material may not significantly affect water clarity, whereas much smaller amounts of a finely suspended sediment will cause a turbid or "mi"Jky" appearance. The last two sentences of the reviewer's comment are noted. 230 All lakes silt up. The rapidity of filling is related to the amount and characteristics of sediment inflow, outflow, and the size, depth, and len~th of the lake. This is equally true of natural bodies of water and manmade lakes. 231 The "proposed series of high-head dams" refers to the Devil Canyon and Watana dams. These are the only dams proposed for development in the Upper Susitna River Basin. The proposed high-head Watana Dam inundates the Vee damsite thus making it unavailable for hydroelectric development. There are no other damsites suitable for development of a high-head dam. 232 The following statement is made in the referenced paragraph of the EIS: " ... under adverse ice conditions, the reservoirs could result in increased problems for some segments of the herd. Also, there could be some permanent changes in historical herd movement patterns." The five-month study by AOF&G was referenced because it is the only study that has been made of caribou crossing at the Watana reservoir site. A previous paragraph states that caribou do use the area. 253 2~ 3There is no implication in the referenced paragraph that the moose count figures are 11 meaningfu1." They are included simply as a matter of recorded fact. If any conclusion can be drawn from these statistics, it would appear to be that the upper Susitna River and the low drainage areas of the major tributaries provide important moose wintering habitat. The statement "cooperation from the Corps has been very poor" is a misstatement of facts. The Corps has cooperated and worked very closely with ADF&G. 2d 4 Impacts resulting from the transmission lines, including secondary effects resulting from road access, are thoroughly discussed in other paragraphs in this section of the report. We note with interest that some reviewers regard transmission lines as a p;1reat to wildfowl because of the possibility of collision while others believe that wildfowl tend to avoid transmission line corridors. 23 5 The visitation estimate was provided by a private consultant who closely coordinated his work with the Bureau of Outdoor Recreation and the Alaska Division of Parks. Benefits attributable to recreation constitute approxi- lnately 0.2 of 1 percent of the annual project benefits. The Corps has not predicted that the estimated 77.000 people who will visit the project annually will also visit Talkeetna, which would be separated from the Devil Canyon site by over 110 miles of roads. There is no planned direct project road access between Gold Creek and Talkeetna. 23 6As required by the 1958 Wildlife Coordination Act. the Corps has requested from the U.S. Fish and Wildlife Service an evaluation of project impacts upon fish and wildlife resources, including moose. Upon the conclusions of their study, a determination will be made through the cooperative efforts of wildlife agencies to determine mitigation measures necessary for the unavoidable destruction of moose habitat. 237 The Corps' description is accurate as written. There are many criteria established for wilderness classification of an area. The description was put in the EIS to inform the reader of the wilderness q~ality of the area. The fact that a portion of this area will be extensively modified, including complete inundation of some 84 miles of river. is clearly stated and exten- sively described in the EIS. 23 8 As stated in response to a previous question, the lands affected by the project are presently classified as native village deficiency lands, and the Corps is aware of conservationists' D-2 legislation now pending before Congress. 23 9 The Corps is not considering placing the transmission line on the west side of the highway and railroad between Gold Creek and Cantwell. The quoted sentence is factual as written. The schematic figure indicating the location of the transmission line corridor has been clarified.- 25'! 24U The Susitna Fault, although close to the project, does not have the probability of creating as violent an earthquake at the reservoir sites dS does the more distant Denali Fault. For this reason, an 8.5 Richter Maximum Credible Earthquake (MCE) at the Denali Fault (40 miles distant) was selected for design purposes rather than the 6.0 Richter MCE event which could result from the Susitna Fault (2.5 miles distant). The fault system of the entire area would be thoroughly studied prior to final project design and construction. 241 Again the statement concerning the possibility of the occurrence of ice- fog conditions below Devil Canyon Dam during periods of extreme cold weather is factual as written. As noted in the comment, this is hardly a critical point given the remote location of the damsite. 242 The EIS 9lready recogniz~s growth as an inevitable occurrence in the Southcentral Region, unless an anti-growth policy is established to prevent it. The projected energy demand upon which justification for the project is based is clearly explained in the EIS and illustrated in Figure 9. A medium growth rate~ as projected by the Alaska Power Adminis- tration, contains no provision for energy needs which would be required of large industrial development. The question of industrial development is more fully addressed in response number 255. 243 The temporary impact of construction workers upon small communities is discussed in the EIS (Section 5.0). The fact that the impact is temporary is one of the primary reasons that it may be particularly adverse. The total period of construction is expected to take 10 years. Approximately 4 years will be required for preconstruction planning. Construction workers will not be present during this period. As stated previously, Talkeetna is over 110 miles by road from Devil Canyon Dam and nearly 150 miles by road from the Watana damsite. 244 Nitrogen supersaturation in the Columbia River is caused by the depth of the plunge pools immediately downstream of the various dam projects. The Corps of Engineers, through extensive research conducted jointly with State and Federal environmental agencies, has developed a "flip lip" that is being incorporated into the Columbia River spillway section of hydropower projects to prevent flows from plunging into deep pools. Although nitrogen supersaturation is still present in the Columbia River, the concerned agencies are optimistic that with the installation of "flip lips" into the spillway of critical projects, the level of nitrogen supersaturation in the Columbia River system will be reduced to noncritical levels. Other factors influencing nitrogen supersaturation include water depth in the river, stream turbulence, distance, etc. 245 The sentence quoted from the EIS states that, along with energy conservation and conservation of nonrenewable resources, environmental protection will be at~ached increasing importance by the nation. The EIS clearly indicates the trade-offs between these different values which would be required by hydroelectric development. The nation, as represented by the actions of Congress, will in effect determine whether or not the costs of the trade-off are justified by the benefits. The EIS does not state or imply that dams constitute a renewable resource. Only water is indicated as having this characteristic. 255 24 b Alternatives related to gas, oil, and coal are sufficiently discussed in the LIS to explain the justification of their rejection as alternatives to hydropower. 2 4 7 Comment noted. 248 Th~~ sentence from which the phase is quoted refers to all tidal flow hydro- electric p'oposals. Tidal power is seldom if ever proposed in areas where it is not suitable.~~ Cook Inlet may be one of the best areas for such development; nevertheless, the "extreme costs and environmental effects 11 are the basis for not recommending it for tidal flow hydroelectric develop- lllent. 24 9 The basis for the rejection of nuclear power, solid waste burning, and oil and gas alternatives are explained in the EIS. Some of the alternatives were rejected on the basis of providing either excess or insufficient energy to meet a reasonable amount of the needs of moderately projected growth. 250 The statement is factual and has not been deleted from the EIS. Scientific studies of the radiation effects of high voltage power lines indicate that there are no harmful human effects from lines transmitting less than 500 kv. The maxinrum power transmitted on the proposed system would be 345 kv. Farming practices, furthermore, generally do not expose humans to sustained, close-range contact with transmission lines. For reference to an authori- tativE! study concerning the health hazards of transmission line radiation, see response number 196. 2 51 Comments noted. 252 rrices at the actual time of construction will undoubtedly be higher than January 1975 prices. Similarly, the price of energy will also be higher, and since the project produces energy long after the great majority of project costs are paid, incorporation of a general price level escalator would have the effect of amplifying benefits to a greater degree than costs. Assuming inflation would, therefore, cause the project to appear more economically favorable. Inflation is not assumed because assumptions about future price levels are deemed too speculative. Future values, cost, and benefits will be equally affected by inflation. Long-range projections are not made based simply on historical rates of growth. They are often included in a discussion for purposes of comparison. 2 ~ 3 Comment noted. 2 54 The s tudy reveals that the hydro project will produce the required energy at a low economic and environmental cost. 256 - 2' .. 55sLimulntion of ::;i_gnif.Lc·<~nt hei!vy industrial development is not expected to n.•su I L from the Susi tna Project for the following reasons: 256 I. The proj~cted energy load growth upon which the marketability as- s•tmpt fons are based, does not incorporate significant heavy industrial dL'Vf' I opmt'nt. Rather, the projection assumes a gradual expansion of industry ha~wd only on nlready pl;mned expansions to existing facilities and on readily idc•ntifiable new industry closely tied to proven resource capabilities and l'l'Drl0m1c realities; this development is expected with or without the project. 2. Thc-hydro project is d~signed to provide additional power incrementally throti)\h phased construccion. From 1986 to about 1995, the Susitna power will ll~<·c·l both lncn•nscd .lo:1d and displace otherwise produced by more costly stream- fired plnnts. Tlw less efficient and obsolete steam-fired plants will be fiJnctfvatc'd or retired. 'J. There will he some secondary energy associated with the proposed 1ll;1n. Such enerp,y is not designed into the plan, but is a result of defining tlw ''firm" cneq;y :lF> that which can be produced in the worst water year (drought). Thus, in most years, there is additional water available to produce "sl'C'OIH.l<lry" ent•rgy which, because it cannot be quaranteed to the user, is usll;-tlly sold at n discount on a when-available basis. Tlw sc·~ondary capability of the proposed plan is seasonal, occuring during Llu· St1mmer months of .June through September, and amounts to about 12 Percent of ·IIH' r inn e.nergy output. Of the 25 years of stream flows utilized for the opcrntlonal stud:ics, secondary energy would be available during the summer months or Jo of the years. It is estimated that secondary energy would be m:1rk<'l ed at about 10 mills per KWH or approximately 50 percent of the estimated cnsl nf firm energy. Neither firm nor secondary energy generated from the Sus I tnn 13Asi.n projects wi 11 be what is commonly termed "cheap" power even Lhou!!,h it i.s attractive when compared to the thermal generated alternatives nv:~l lable for satisfying future Railbelt energy needs. Marketability analysis lws tlt-tcrmlned that the required pay-back usage rate for firm energy from liH• S11sitna Pro.iect, ls 21.2 mills per KWH. 1n comparison, present rates for r i rm t'nC'rgy markl~tcd by Bonneville Power Administration in the Pacific North- WPSL during the w.inter months is 4.1 mills and less in the summer. In general, <•1wrgy hy the hydro project will be somewhat less expensive than energy provided from :11 tt'rnative sources. It is for this and environmental reasons, that the hyJrn proJect is the selected plan. The resulting energy cost savings will nc<"ntc to all Rai.lbelt area elec:trlcty users. This lower cost energy will provide> a slight locational advantage to the Railbelt area in comparison to cond.ltlnns without the plan. Significant stimulation of heavy industry is nell expected to result, however, becnuse as noted above, the project is cl('s f )'.Ilt'd such tlw t avail able capacity as closely as possible approximates 1 11(' pro.i l'C tC'cl d0m;1nd. Further, the cheaper secondary energy will be available 1111 too irregular ;1 basis to serve as an important determinant in industrial 1 oc;1 t lona 1 decIsion-making. ConH·nt noted. CITIZEN COMMENTS AND RESPONSES W. L. Blackadar Eric Boerner Mary Evans, Dan Huttunen, and Bob Fox Sea Airmotive, Inc. Stephen Kurth Dan Mawhinney Thomas E. Meacham Philip N. Osborn Christopher Pearson R. John Strasenburgh C. H. Swanson, Jr. ~lohn R. Swanson Barbara Winkley 258 Corrments 257 2sa-2o1 26~ 263 264-276 277-280 281-310 311 312 313 314 315 316 - SALMON MEDICAL CENTER sex 1110 SALMON, IDAHO 83467 W. L. 8LACKADAR, M.O. ?56•:116:1:11 BOVO K. SIMMONS M.D. 7S6-31U2 October 16, 1975 Alaska District Corps of 'Engineers Anchorage, Alaska · Dear Sir: Re: Draft environmental impact statement on the Upper Susitna Basin -Hydroelectric power development · I have reviewed carefully your 95 page statement and am alarmed that you dismiss the adverse changes in Devil's Canyon in a two line insert on page 93. The loss of Devil's Canyon for white water kayaking deserves much more impact than you have given it. This section of canyon has only been paddled a few times but it is paddleable and it is destined to become extremely well used and extremely popular. Ten years ago, almost no one had run the Grand Canyon in kayaks. Now, thousands are traversing this famous gorge. As these thousands look for new horizons, Devil's Canyon looms as the only challenge which is technically feasible to do without undue risk. I paddled Devil's Canyon in 1972, plan to return with a large group this next summer and I know of another group that will go independently. To lose the Devil's Canyon section of white water would be a tragic loss to America and it's future generations because there is no other place like it in North America, or for that matter the world as far as I know. You dismiss the anadromous fish capacity of the Susitna by stating that fish do not now traverse Devil' s Canyon. This to my knowledge is true and yet it would be a ver,y simple project to pass fish successfully through Devil's Canyon since the bottleneck, I believe, is only in two drops. These could easily be altered with short tunnels to permit this passage or some sort ofladder operation so actually the loss t~ fisheries of Devil's Canyon is thoroughly as great as that loss would be at Rampart over a five hundred ye~r period. 2,59 .. Alaska District Corps of Engineers October 16, 1975 Page Two While you have listed many proposals for the Susitna all of them include a dam in Devils CaQYon. Certainly some alter- native thought should be given towards having only the upstream dams built allowing future gen~rations to make the decision in, Devi1s Canyon. · Please enter this statement in the hearing record and have it show that there is·atrong opposition to the Devil's Canyon dam and that this loss will be irretrievable. WLB:kc 260 - 'V :'. r-: r.• "r: ~: :.r.1 t. ~ .. 1.\. r:. ; •. r ~, ' '.'Y. 111 ;J · - RESPONSE TO COMMENTS BY W. L. BLACKADAR, M.D. 2b7Contnents contained in Dr. Blackadar's letter of 16 October 1975 are noted. Drawings and notations made by Dr. Blackadar on 1 October 1972 (not an inclosure with Dr. Blackadar's letter of 16 October 1975) are also inclosed, since they contain additional information related to the navigability of the whitewater section of Devil Canyon. Comparing the possible loss to theoretical salmon introduction into the upper Susitna basin to the huge area covered by the Yukon River drainage above Rampart appears to be somewhat exaggerated. 267 259 'Y'f\ .J YlA"b\~ ·,-s E '('ic. Coe~r lt~Vd .1· Li~rc. #" OAJ i)e4rlt1ov"' i2o-J. A~ o r "'OW "W1 j o c 1 . 1 ,_ • . I <vr-4r.o .... •:) A 'SU,eol bu'!o r:Jr;vc.r. ,..,.. IN f!J"-tsf~J. ,.N who\ ·~ -t.l\l.<i,.,~ pl"'c'C. her-e iN~;~ w.'LJ ,.,.,,c. bMvh{vL s~A~c of ALAsi(A o ... ~."" Alt.., I ,.,.,.,. P...o'M CAL; fo..-,.J•A-A AI/ ...,., .{',q "t71ilf{lfr-wi-11.. -}1.;~ ~:.~JCU·ti I( ,, .. fl we. ,.IQ\oJ ~ p.ray~ .. Al..~ 1,.... +,.,..;{tty-w;JI.. Me. A.,-,..1 c .... p "'f GAJ~;,.,u,. ~~t--1 1~-<-i..-OC.C.Vj>A-fio"' · 1 h(. 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(,..>I ~l.o ~f{~c.h.., #-t.. ?~apC-c. of /4(1tS/flf, -skJ. '(hA.vf( j"'-' /7),..-:J{)JI"' f;.._c.. AIVd (t+lt"t'NC.C i'N ~~~;ll"i!V' P'1 2S9 RESPONSE TO COMMENTS BY ERIC BOEMER 25bThe growing populations of the Anchorage and Fairbanks areas will generate an increased demand for energy. Hydroelectric power is considered to be the most desirable method of supplying projected energy needs at this time. 25~ The alternatives are listed and discussed in Section 6.0 of the EIS. 260 See response number 240. 2ti1 The possible impacts of the impoundments on the Nelchina herd have been discussed in the EIS. Additional studies concerning the wildlife within the region will be conducted during the preconstruction planning phase of the project . 27u - I Al•nk• Di~triot,·Corra of Engineer• Box ?002, Anchor~fl"• Ak., 99510 Octobotr 19, .1"9?5. 426 Skarlitnd Hall · We'vs bet"'n dirJeoure~ad by r .. t :propo11•l.• m .. rle by the Corp•, particularly th~ F!111mp•rt Dem )'•ropo~t•l. W•'re mnr• encour•g•d h,y the Zu11itn-D•m prnj•ct, \lh.tch demonstrat•• mor~ thorouch !"fta~•reh •nd mnr• •tteDtion to environment•} impact• th•a th't pr.,ceding atudiea. However, """ L'.o find •om• we•kne,.ua in thot atudy, and we two dtor.'l'!l will huvP nome "itnific•nt impact•,· which we found were in•dequ.r.tdy eonold-:-r,..d, or not considerfl'd •t •11, in yuur lltudy. . . ~t til,. F•oirh,.nl:" h""rinl': on u., .. l>r•ft. };I~ lh•t th411 herr! cond .. tently c.ro..,.,,..., th• riv,.r in Jto1y, .. nrl th•t tht~~ ru•Jvr imp•ct cjf th" clt•ml'! <•n lht~~ hftrd wouJd be •n thot h•rd b lik~tly. In mitlcll .. ~~·y, thf' hlllrd C•.!.V"I" •long th• •outh b•nkli or. · ..... · the f.u~itn• RiVf•r, b.,t.id!! th~ propo~ed ,/~thn• r~n~rvoir. Tht~~ 'herd norrn,.ll;y . cronu to tht! ."umm .. r f;roundn north or th~!~ riv&r in ~ •h !loy •nd urly Junf'l. 271 1nform•tion cornea '!r~m ·~ Al~•k• D•p•rtment of Fiah and G•m~ r~port entitfed• I "Ndt liu C•ribou :Report", b] Gr~gory N. Boa, publhhed in Apr~l 1973 by the · ..... ~: .. It ie likely th•t th~t h~rd would fr~quently cross the reaervoir before the r · I ice i• out. C•ribou •r• ~xc~ll•nt ewimmere •nd low mortality woul~·be er.pected .. I even when laree numbers of.v8ry youn~ c•lvfta cro~~ ~nice-free. turbulent ~iver. :· Howevl"r. hoofe-d attim•l~r c•n't cope with !~t.lls throuch ice: they •rc not able to climb 1out •e•in. At lake Louhe, bit~loginh h"'ve oburv"d c~.ribou brc~r.kine throue;h thil"l ic~, •n<l "ll.th" •11im»l« •ub11equently drowned. ~~ wonder •bout the atQlJility of thft ice on Wat~n• Reeervoir with expected w•ter level fluctu•tiona o! 125 feet." Ice d.,vdoping on nuctu~tinG Wll.ter ... urf•c~(\· •nd •u;orhd memb~r~ of th11 public to the •re11., .further incrtt•sing rn"rt~lity. Th" •.;-•• P'"""'~ntly .;..ct.~~ ae • recharc;e arfl:\ for wildlife: • number o! rliffore!lt game popul~tion~ ~njoy at•bility of number• and •ocurity in the dam •reM, duo moatly . to difficult •ccears. I! th~t da.ma are built, \-te £~tronp;ly r~commend kettpin.g th~t;I!CCea• ro•d cloaed to th~! p•1blic, and we· reco!Mlen,d aot plannine; camp.ai't••' and recreutioa are•a •rounrl thot r~taervoir•. We looked·•t the Al•ek• Power Commi•eion report on which 1our enerGY dem•nd oft tncre.llt'l'!'n ~tn""rgy us~' 11t~tmming from t.h~t oil pipl'llin• irnp~ct: •n =imp.,ct wo don't expect to continue. h:aove r-rojected. Th• Corp•' Public Brochure t~t.llt"l<l," f... p~rtic\lll".rly iinpo.rhnt con:sid11r;at:!.~n or c~rtAin hydror~w~r proj~ct~ i~ th~ pot~nti;al to provid~ fpr more pow~r than ~·m•~d~J - fa • very r••l rbn~"" from thi• h:rlrofll•rtritl prnjent. l'rin111d ly fC'r 'thi.• r•••un, we wouJd r•th~r ~ ... :·.forth., imrnedjate !11ture, utilb.•ti<"n of n•tur•l g•• from the .... proJ'(i:o•d D•~ur•l r.•• pipdine, rotphc•d in th" mor~t dhhllt !'\ttur" by :eeoth .. rm-.1 We ~on't w•nt enerr,y produet~n above that Deceas~ry for the im~•diat~ future, ai•~~ ex~eft• enercy could atimul•t.,, ~ot only indu•trializ•tior., but waftteful ea~rgy u~•--• b•d h•hit for the public to dev .. lop. We !eel that it i• poor ~lanaiag to deeid~ to build a d•m betore knowing wh•r• the gaa pipeliae will go. We quuation ColoMl D-.beliua' •htement, m•d• •t the F•irb•nlua h .. rbllh tha·t th• life exp•ctii:"CJ' ot th .. d•m would be 500 :yeara. Thi11 l!e,..ml!l ;i.mprob•bl•, aiJlc'e we k11ow or 11.0 d11m with • proj~tchd lif'•t1••• ot over 100 ,. .. r.. Hoover dam w•• · •l•o predict~d to h•vft • low ailtatioa r•te, •Rd it beg~ nilting up b•!ore coaatructioa ~~~ eomrlet•d. ~~·t would the b•n•!it/coat anal:y~i· look like it the projected lifetime wa" 100 yearn or leu, rath"r than 5<)o :yeara? W• fot~l thia would be a more bnut:1 and in tl"rf!lll Of the abuDd•acll Of wildlife in' ita dr•ituoge area. We plac• ' . but tor it• value •• • wild•rn•••·· It eaergy ia r••lly nece~aary, ~~ approve o! hydropower projer.te o• em•llf'r •c•lea. 'i• ful that th• Cutoitau• River i• the wro•g I Sin~•r•l:y, ·>1~1 (Jw,~ _Mary Ev.-ns ' 2 6 2 wi~~re rnn;p;~;;t rn•jor,. u. ot A. /./d.-Jl ,... ' (..~---- o .. n Hutto.nen wildlit~ m~n•3oment major, U. ot A. ~'-"r(_,-;f O'"f· Bob Fox I , TVCC int~tructor .273. RESPONSE TO COMMENTS BY MARY EVANS, DAN HUTTUNEN, AND BOB FOX 2G2 l\11Jllll('llts ~rrc' not"c.xl. In reference to comments on the Nelchina caribou herd~ ~he information on caribou (Sections 2.01.3.1 and 4.03 of the EIS) was taken from Sf~veral sources including the Alaska___B,g_g_ional Profiles--Southcentral Region, July 1974 and the State of Alaska, Department of Fish and Gi!IHe's Alaska 1 S Wildlife and Habitat, January 1973. As stated in the EIS~:-"Warmer-weather and a rapfdly filling reservoir should eliminate any adverse ice cor,jitions during the month of May.11 The major calving area for the Nelchina herd is on the upper reaches of Kasina Creek, Oshetna River, and Little Nelchina River drainages with calving generally taking place between mid-May and mid-June. Migra- tion to the surrounding summer ranges usually begins in the latter part of June with the major movement taking place in July. As stated in Section 4.15 of the EIS: Even though the project-life is computed on a 100-year period for economic reasons, with adequate n~intenance, the useful life of the proposed projects due to sedi- rnentiltion is estimated to be excess of 500 years. The benefit-cost ratio is based on a project-life of 100,years and is a fixed standard for ull Federal hydropower project evaluation. 274 - St:A AIRMOTrvE, rNC. Mr. Chafrman, Ladies & Gentlaren: My narre is Ward I. Gay. We operate Sea A:inrotive, Inc. at Lake Hood, . . an air taxi operation, '1t: have lived in Anchotage for the pa~t 40 years and have seen a lot of changes here. we have needed the Devil canyon Dam on the Upper S\.isitna River for 20 years and ,in fact, I f~ew personnel on survey trips of this dam site rrore than 25 years ago, before any gas or oil was discovered in Alaska, I also renember when. tlle Eklutna hydroelectric plan was fir_st propo~ (before W'Jrld War II) • The original ~timate .was slightly over six million dollars. When we finally got around to doing it, the cost was in . . excess of 32 million dollars. 'lbe big delay was because we did not I'1.E!e;I that much po;Jer. Then gas was discovered at Kasilof. 'Ihe people in .. j Anctorage ~ted gas, so we voted a 20 year franchise to a ooopany and built a pipeline fran Kasilof .to Anch:>rage that we are still paying for, even though \Ye have 'natural gas right across the inlet fran us that there is no use for. Chugach Electric has built a power plant at Dciuga, that should have been in llnctorage, but the gas was cheaper at Dcluga even with building 2 ~r lines to transmit it to 1\nchorage. It seens they can bring the power in but not the gas. Maybe because of the franchise. Anyway, the people have to pay for it no matter how it is done so ins.tead of TMking rrore mistakes, lets build the Devil canyon Dam on the Susitna and furnish ~r to the whole railbelt. This will be utilizing a natural resource that is not expendable. Then the natural resources that are· expendable, such as natural gas, oil and ooal can be sold to other states · and countries that are not as fortunate.as ~ are in having an aburrlanoe of water. 275 . SEA AIRMOTIVE.. INC. It has been said that this dam would dest.roy wild g-ane habitat and calving ~ fot caribou. I took my first bmting party 'to the Fog I...akes in the fall of 1947 and have hunted there every year· since. I have seen thousands of caribou 90 down the bank arxl ·swim the 100_ y~ of river ar;;:l go up the other 'side, selcbn stq:pinq in the small spruce timber because they know they are vulnerable to ~lves and bear in the · , I timber, and there is Very little for "tJ.n to eat there. I have never seen a c::rM have her calf down in" the oanya1. 'lhey like the hills above· timber where they can see and run. · 'l'his also applies to noose.' With the dam Wilt, the cari}x)u w:>uld only have to swim across a 1/4 mile lake. That is ooth.i.nq for them or 1'fCO&e either, or a grizzly bear for that rratter. 'nlere has never been crt fish in the SUsitna drainage above the dam site. Even the salrron cannot buck the lrt'hi te water in the canyon. 'nle l:ake oould be stocked with fish and ~e a -wooderful., accessable recreation area that the people of the rail.l::elt are already . . in need of. The garre animals are nearly gone in this area now, mainly because we have protected . the w:>lves for the last 7 years. lftds can be ·····. · changed in a few years. I .. think the proper people have now learned tllat rran Canrot. allc:M the other predators to inc:rease, unl.imi.ted, and still have ~ \toiOnderful game paradise that he desi%'es to view. , f sincereiy, : 2631 -~~ fkcr-· :-' . v/ WaM. x. Gay ' . 276 - 263 Comments noted. RESPONSE TO COMMENTS BY l>JARD I. GAY SEA AIRMOTIVE, INC. atw~ ~ &yuftt~ iLr? •7 () () z. . / {i<U_;;.'/'di.dr!<f. ?9:JIO · J&'-1., A: 278 fAt« U//fA'I<lMh, ciu ./~""' d ~ -· ~..:«~~·-a k/ £/S r ..d ~ 7/ tJ}_~~~~~ t<AI~at'( ~'~ .:AJ fiaU'<&<.-~ ~ J~ 7 ~- 1 o/ ftr:t)/~1-P=J~ A~~J:-~y~~-~ . . 2 6 ~ /Z4t c~/~~~r~ ~ /;~~~?t;=~.~ ~ un~~ .24 ~~~~ ~.,q// . 280 • 68 281 270 271 282 2'73 - 283 284 275 276 285 r. w TLA DS of the UNITED STATES THEIR EXTENT AND THEIR VALUE TO WATERFOWL AND . OTHER WILDLIFE By Samuel P. Show and C. Gordon Fredine Office of Tliru;r Bn~in Studies CIRCULAR 39 FISH AND WILDLIFE SERVICE UNITED STATES DEPARTMENT OF THE INTERIOR THE PROBLEM OF SAVING WETLANDS The grco.t natural wealth that originally made possible the growth and development of the United St.o.tP-8 included o. generous endowment of shallow- wo.ter and waterlogged lands. 'rhe ori•)na.l inhab- ita.nte of the New World had utilized the animals living among these wet places for ':>od and cloth- ing, but they permitted the land to remain essen- tially unchanged. The advent of European settlers brought great changes in the land, and aquatic habitats were particularly vulnerable to the settlers' activities. Kcr111cy and McAtee wrote in 1938: Among ~hi! IUtllt'tl or mankind, wildlife receives its true apralsal .!.'~Y. Jn ~dv~ced stages o_f c~~i~izatioii",_ w~en, ow.!'' tn ~h(' ~eedht811 ~eatruc~lon or ea~!~ times, it has be~n !""~rlnu~ly if not irr!!pKr&t:!l. reduced. Under pioneer coml!llmut tne rull'l\ for tlietreatmf'nt ol wildlife are imme- dlaht exptuit.ation or the U~teful and drastic destruction of Lhe uaeiPIB, mnd the11e rules tend to remain in effect long after the origlual mo~ive11 are gone. In the earlier stages of a.oUh1men~ no one thinks of allotting any land for the use of wild !Ire; ~he effort is to wrest every possible sere from nAlur•! And muk11 it yield an income. There is no vision to "f!c, tht"re iR no time to learn, that land unitll wUh their nal.ural or.r.•tpa.nLJ<, ns exemplified by a ben~er meadow, a mu"kr~t· nutrr~<h, 11 duck lake, a deer f~U"est, or an antelope nu'"''• Me prmlur.Li" entitiPS thllt under certain cireum- a.Lnm:l"!l may b~> wnrth far more than Rnything man can put t In ~heir pll1cll and that once des~royed may never be ro- utabll•lu"l · [71 I ·-- THE NATURE OF WETLANDS 'l'he trnn 11 wctlands/ afi uRrd in this report and in the wildlife field generally, rdcrs to lowl~nds covrrr.u witt"• shallow and sometimes temporary or inlerrnittt>nl wnters. They are referred to by auch nnmrs as marshes, swamps, bogs, wet mead- ows, potholt•s, sloughs, and river-overflow lands. Shallow lakt'B n.nd pon<IR, usun.lly with emergent vegctat.ion as n conspicuous f<>nturc, arc included in the dl'finilion, b~t the permanent waters oF streams, rcsrrvoirs, and deep lakes are not in- 'Jlalle uurnbl-n In nmckrt• rdllt to ll~m, In the List or R•lcr~nCI'S on I•~•• 47. eluded. Neither are water areas that are,so tem- porary as to have little or no effect on the develop- ment of moist-soil vegetation. Usually these very temporary areas are of no appreciable value to the species of wildlife considered in this report. Most wetlands can be drained or filled to creato suitable land for agricultural, industrial, or resi- dential expansion. Others lie in potential im- poundment sites where permanent deep-water en- vironments can be developed. If either type of project is carried out, however, the food and cover plants required by ~aterfowl and other wetland wildlife no longer grow in abundance. These aquatic plants ne.ed waterlogged or shallow-water soils in order to thrive. Apparently, a great many people still think that until one of these two courses i.s followed, any wet- land area is just so much wasteland--an unfortu- nate occurrence in the land-economist's classifica- tion of productive land uses. So long as this belief ·.prevails, wetlands will continue to be drained, filled, diked, impounded, or otherwise altered, and thus will lose their identity as wetlands and their value as wildlife habitat. COOPERATIVE PLANNtNG State and Federal agencies engag~d in conflicting programs of wetland dPstruction and wetland pres- ervation must work together to develop unified wetland-use programs ~hat. are both acceptable to the landowner and beneficial to the N a.tion. It is one-sided plannin~ for example, if a. flood- control agency neglects wildlife !!{a.lues as it plans for the elimination of river-overflow areas, when these areas are used by millions of ducks during the winter season. In land-use planning, an ngency dealing with drainage projects would be subject to criticism if i'ts plans to remove water from ext-ensive marsh- lands or scattl'l'cd potholes were dto~vtlopcd without regard for the fact that, indivh1ua.lty or collec- tively, they provide essentin.l h!inita.t for thousands 3 SUMMARY OF CHAP-rERS Th(' problem of sa\•ing wetlands is to pr<•Hnt mnrs!H•s, swnmps, opMl sllll.llow wntrrs, 1111d ,;ca- SIJllHIIy floodPII IH1Jcls from hl'ing rlr~linl'd, flood<'d, or lilll'd, lli'JH'<' losi11g I lll'ir vuh11•ns wildlifl' hn bitat. 'J'h,·~f' t.ypros of uqnntiC'. <'11\'ironlllPIIIS, c.ollc•ctin·ly id<•ntifiPd in this n•porl ns U'tfland:'l, furnish <•ssen- tiul hnhitnl for nil wntl'rfowl, most spPciPs of fur anirnnls, und lliSI.Jl.)' i'.Jl<'Ci<•s of fnrrn gomr, for!'sl. gnm<', 1111d wnrllJ-11'1\.!C'r fish. Coordinated ndvn.nce plnnning by ILII rrsnliH'-e int<'n:sts is the keynote l.o sol vi 11 g tlw pro hh' m. As n n n id in su r.h pln.n- ning, thP Vish oru-l Wildlif,~ f-lprvice, with the coop- t•ru.t ion of St ul <' gnrne ngPilt~ics, conduct<'O n wet.- lnnds invpn(.ory with crnphn.Ris on present usdul- nf'ss of tlw lnnd.o; ns wiiiPrfowl hnbit.at. A ct•rJiury of welland cxploilation has taught rnn11y lr•ssoTlS in lh<' u;;p nnd misuse of wellnnds. Tlw Swump Lnnd Ar.ts of 1849, 1850, -and 1860 pn vNI t.hr• wRy for 1 mnsf!'rring n!'fl rly ().') million nr.rPS of wc·llrtnds in 10 Stutes from FNleral t.o St.nt.e ndminist.rntion for t.he purpost> of exprditing t.lll'ir clrninnge. N!'nrly nil I hPse lnnrls nrr now in pri,•n.l.n ownl'rship, and lhC'ir use by wildlifl' is usu- ally only a minor considerution. Although evi- df'rtCP.S of wetland loRscs as revealed by previous inHIII.orif's arP not. r.ornpktely rrliable b~?cause t.hey rPpn~sPnt diffcrf'nt types of covl'rage, it nppr\IWI I hn.t. n.t Jpn.st 45 million of the original 127 million acrel'! of nA.tural wetlanrls have been dntined or otllt'rwiR~ destroyed. Agricultural. drainage (102 million ncrcs now in organized enterprises) and flood control are thE' forces primarily respon- sihlP., hut. other a.ctivities such as canal construc- t.ion, dminngf~ for mosquito control, industrial ex- panAion, and highway b11ilding have greatly re- duced th~ wildlife values of some wetlands, partic- ulo.rly alo11g the coasts. 44 Wetland soils hnn physical and chrmicul pl·op- !'rl.irs thn.t nre dc•r·ivrd from the rnvironm!'nl in which t.Jw soils or~inntr. Climate, lnndform, and native vegl'IH!ion lnrgp]y govrrn the Jlllllll'P of this PnvironmPnt, hence nlso the nnturr of thr soils nnd their pott•ntial usrs. Most wdlnnds arc und1~rlain by orgunic soils known as pent nnd muck, or by recently deposited, watcr-c.urri!'d alluvial soils. In gt·ncral, allu\'ial soils have higher f\.grir.ulturl\.1 pott•nl ials than peat nnd muc.k. MR.ny pent and muck soils,have pron•d unproduc- tive for ngriculturr after drainage; others are in- herently fertil~:. In many areas, therE" nppenrs to he a direct r!'lation between potent.ially good agri- cultural wetlands and presently good wnterfowl wetlands, suggpsting that competition betwe>en 11gricultural n.nd wildlif<' inlt'H'Sts will becomE' more intense in the years ahead. The wetlands inventory rcYeals the loc.ation, dassification, nnd (n-a.Juntion of 74,439,300 acrE's of wetlands as waterfowl hR.~itat. At IC'ast 90 pcrr.cnt of nil wetlands of importance to waterfowl are included. From the standpoint of waterfowl value, the total acreagE' covC'fed by the in,·entory is distributed as follows (in millions of acres): 8.9, high; 13.6, modC'rate; 24.0, low; a.nd 27 .9, negli- gible. Values are based on relat.ive waterfowl use in the State where the wetlands are located. By wetland categories, the eight inland fresh types comprise 63,491 ,000 acres, the three inland salinE' types comprise 1,618,000 acres, the three coastal fresh types comprise 4,041,000 acres, and the six coastal saline types comprise 5,290,000 acres. The 20 wetland types are ecological classifica- tions designed to help recognize the relatiYe im- portance to watE'rfowl of the many different kinds RESPONSE TO COMMENTS BY STEPHEN KURTH 264 Comment noted. Practically no "wetlands" for waterfowl are located within the proposed Devil Canyon and Watana reservoir areas. 2 6 5 Cmm1en t noted. 266 The 6-l/8 percent interest rate is provided by Water Resource Council, and is based on the current cost to the Federal Government of borrowing money. 2C.7 Reduction of flooding and erosion could result in subclimax'growth of vegetation in the braided channel system and would provide browse for moose. 26b Project power will be marketable by existing power marketing agencies, at rates to be established by normal rate-setting procedures and after public hearings have been held. Use of power by industries can be regulated by means of power rates. Also see response number 255. 269 Growth projections in Alaska are not based primarily on past growth statistics, but rather on demographic, economic, and other factors which will control future growth. 270 The no action alternative is covered in Section 6.02.1 of the EIS. 271 Statement regarding nuclear power providing 50 percent of the electrical power by the year 2000 refers to the nation as a whole. Nuclear power does not represent the most feasible alternative power source for Alaska, as stated in Section 6.02.4 of the EIS. 2 7 2 Corrunents noted. 2 7 :1 Comments noted. 274 Comments noted. 275 Comments noted. 276 Comments noted. 289 - /O --()./' --? J -- 290 280 291 RESPONSE TO COMMENTS BY DAN MAWHINNEY 277 The proposed Susitna project would change the areas where project facilities such as dams, reservoirs, roads, transmission lines, and recreation areas would be built, but we would design and construct these facilities using the highest standards to lessen the adverse impacts and to maximize the beneficial impacts. 278 Alasku is and will continue to be a great state where people can live, work, play and enjoy the wonderful natural resources that are found here, but those of us who moved here from other places or were born here will have to consider that others will come here in the future for much the same reasons that motivated the present residents to live here. To some this might not necessarily mean progress, but it is the 11 real world." With good planning we hope to help provide a good place to live and work and still retain much of Alaska's great wealth in the natural environment. True, some people will be more directly affected by our proposals for hydroelectric power than others, but we believe that what we do propose will adversely affect fewer people than any other viable alternative which would provide equivalent electrical energy. Also, we believe that the proposed project is economically and engineeringly feasible and less environmentally damaging than any other alternative which could meet electrical energy needs of the future. 279 In the Alaska Native Claims Settlement Act more than 80 million acres of Alaska's 356 million acres are proposed to be retained in the 4 Federal systems including parks, wildlife refuges, wild and scenic rivers and natural forests. The State has also proposed millions of acres for park and recreation lands. It is also reasonable to assume that much of the over 40 millions of acres of native lands, 106 millions of acres of State lands and the balance of lands left in other private and Federal control will be left in its natural state or developed to encourage recreation but it is obvious that some development will also take place. 280 As noted in Section 9.0 of the Environmental Impact Statement. we have had three sets of Public Meetings in both Anchorage and Fairbanks where all the public has been invited to attend and to express their feelings and concerns on this proposed project. People from the Talkeetna area and from the areas that would be directly affected by project facilities attended the meetings~ the people listened to the proceedings and some made comment, both for and against the proposed project. 292 -THOMAS E. MEACHAM ATIORNEY AT LAW ' SUITE 403 310 "K'' STREI!:T ANCHORI\OE, ALASI<A 9111:101 11107) 278·132.2 '11107) 278-1443 October 9, 1975 Colonel Charles Debelius District Engineer Alaska District u.s. Army Corps of Engineers Box 7002 Anchorage, AK 99510 Re: Written Testimony Concerning Draft Environmental Impact Statement Dear Colonel Debelius: I am enclosing with this letter a copy of my comments concerning your Draft Environmental Impact Statement on hydro- electric power development on the Upper Susitna River Basin, Alaska. I delivered this testimony orally at your public hear- ing on October 7, 1975, and would request that my written tes- timony be included in your hearing record. I would also request that this letter of transmittal be included in your hearing record, since additional facts con- cerning the production of your Draft Environmental Impact State- ment became evident during the. course of the hearing.Tuesday night. From the testimony given by the Alaska Department of Fish and Game, it is apparent that your Draft Environmental Statement was issued prior to completion of studies by the Alaska Department of Fish and Game, which had been on contract with the U.S. Fish and Wildlife Service to conduct wildlife studies in the affected area, and for the specific purpose of your environmental analysis of the proposed project. By accel- erating the completion and issuance of the Draft Impact State- ment, your office has totally excluqed a body of knowledge which, if available to the general public, would have permitted a much more thoropgh analysis of the effects of your proposed project. In addition, I would assume that availability of the results of this study would have aided your own planners in evaluating the proposed project. Not only is this deliberate omission very detrimental from the standpoint of an adequate environmental statement, but Colonel Charles Debelius Alaska District Corps of Engineer~ October 9, 1975 Page two. I learned at the hearing that the Corps of Engineers had also excluded an additional contracted study which was intended to explore in depth some aspects of the project, for purposes of your Environmental Impact Statement·. I believe that the firm of Jane~ & Jones, Consultan~s, was engaged to study certain aspects of the project. I have seen their report, entitled Upper Susitna River: Inventory and Evaluation of the Environ- mental, Aesthetic and Recreational Resources. This firm was also contracted to analyze spec1f1c aspects of the proposal, but the last-minute acceleration of the deadline date for the Impact Statement precluded any analysis of the voluminous results of their study in your Draft Environmental Sta~ement. I believe that the deliberate exclusion of these two relevant source ma·terials, and the lack of public knowledge of their conclusions, has dealt a very strong blow aga-inst your Draft Environmental Statement. I would expect that, at the least, full consideration of these documents will be given in your Final Environmental Impact Statement, and that these doc- uments will be available for evaluation by the interested public. · Thank you very much for your even-handed treatment of the hearing itself, and for the efficient manner in Which it was organized and conaucted. 2811 TEM/bja Enclosure I • Yours sincerely, Thomas E. Meacham 29~ RESPONSE TO COMMENTS BY THOMAS E. MEACHAM LETTER DATED 9 OCTOBER 1975 281 A concerted, continuing effort has been made throughout the study process to acquire all data possible from all concerned sources with special emphasis on fishery and wildlife data so vital for a valid assessment of project effects on major ecosystems and the total environment. We have worked through the U.S. Fish and Wildlife Service (FWS), as the lead agency, to coordinate our study with Alaska Department of Fish and Game (ADF&G). We had, prior to the Public Meeting, a preliminary report of FWS (containing the AOF&G contribution). This report, prepared in accordance with the Fish and Wildlife Coordination Act, was formally published on 10 October 1975. In addition, we had informal contacts on a nearly daily basis with FWS personnel to be as sure as possible that no new or important information relative to their area of responsibility was being omitted from consideration. The fact that the Jones and Jones inventory and evaluation (prepared under contract to the Corps of Engineers) is not contained in toto in either the DE!S or feasibility report does not mean that it has been excluded, omitted, or ignored in our evaluations. Quite the contrary, it has been of much value to us, and has been in our hands for over six months prior to completion of the DEIS. 295 282 COMMENTS REGARDING DRAFT ENVIRON~lliNTAL IMPACT STATEMENT: Gentlemen: HYD~OELECTRIC POWER DEVELOP~NT ON THE UPPER . SUSITNA RIVER DASIN, ALASKA October 7, 1975 My name is Tom Meacham. I am a reside_nt of Anchorage, Alaska and am conservatior. chairman of tho Mountaineering Club of Alaska. I am testifying as an individual. I believe that your Draft Environmental Impact Statement regarding hydroelectric power development on the Upper Susitna River is subject to criticism both in concept and in detail. I will deal with the criticisms I have regarding the conce~t first. Your Draft Impact Statement was issued on September 22, 1975. This hearing comes exactly two weeks after that date, offering no realistic opportunity for public input based on the assertions of fact and assumptions made in your Impact Statement. Instead, this hurried consideration of the Impact Statement seems designed to nullify or elimin-ate any meaningful criticis'tn from persons or organization~ which may have some doubts about your project. This certainly is not the "atmosphere of public under- standing, trust, mutual CQoperative, and in a manner responsive to the public interest", as your regulations require. The Draft Impact Statement itself is much too narrow, given the scope of the problem. The Draft Statement purports to analyze the feasibility of hydroelectric power in the Upper Susitna Basin, in relation to other alternative power squrces which may be available .. we are told that more extensive studies will ~e made of the various .factors required under the National . Environmental Policy Act, if the project is approved. However, I have found nothing in the.Draft Statement which could be termed a feasibility report, in relation to other alternative power sources and the projected needs of the rail belt area in future years. Because the question of feasibility and of future need will receive'only the present. environmental analysis, that anal- ysis must be as complete as any required under NEPA for any spe- cific aopect of actual hydroelectric.plant construction. The 296 Comments to Draft EIS October 7, 1975· Page two. and very little actual authority, determined that hydroelectric ' writers of this Impact Statement have, with no statutory authority I power is the "most feasible" means to meet the area's presumed • 28 ~ future needs, and have, without further analysis, proceeded to ~ present the details of the proposed dam construction. Questions which thoy have left unanswe~ed are t~e following: 1. What is the source 6f any assumptions regardinq I population growth and growth in electrical de- mand in the .rail belt area? Are there variations . 284. · among sources in these projections; and if so, which projections did the Corps examine and adopt? 2. ' Has' any comprehensive economic, social or environ- mental anal~sis been done of other alternatives to the hydroelectric project, including purchase of power from Canada, coal gasification, coal'burning, 285 use of natural gas, geothermal resources, or any . other available ·o·r projected source· in Alaska? If ·. studies have been examined regarding these factors, what is the source of these studies? 1. Will hydroelectric development in tpe rail belt area discourage use and development of alternative ·' I ·28 ·6 sources? · Will other sources develop despite con- struction ~f hydroelectric projects? These questions, and others which I am sure other persons will raise,· go to the very premise upon which your Environmental Impact Statement was based: · the "feasibility" of hydroelectric power development in ~· the rail belt region. Until these issues are addressed, there is no point in discussing specific construction proposals for various dams. However, the tone of your Impact Statement indicates quite clearly that "feasibility" to your agency is merely a question of receiving the requisite amount of dollars from Congress, and that once that grant is assured, the Corps of Engineers will very quickly demonstrate that hydroelectric power in·the rail belt region is physically feasible The real question. of the propriety .of hydroelectric power, in the con- text of this region's needs and in contrast with other available sources, will never be answered. Because the majority. of your Draft Impact .Statement deals with t.he reality of a two-dam construction proposal, I have some 297 . ' : Comments to Draft EIS October 7, 1975 Page three. 287 ' ! questions to raisc·conccrning that proposal. I feel that there arc s~vera~ very serious inconsistencies or un~arranted ~ssumptions made 1n that Impact Statement, and I feel conf1dent that satisfac- tory answers will be provided at the time the final impact statement is written. Among my ques~ions are the following: l. 288 2. 4 • 291 5. 292 Is the capacity of the Devil Canyon-Watana project cxccssjve? The projected electrical output is approximately six times the present need for the entire state, yet it is only one- fourth of your projection of the rail belt area's needs in 198~. Whut entity will manage the proposed project? Will it be a TVA-type authority, which has dem- onstrated little responsiveness to the public interest? Will the authority operating the .project be subject to jurisdiction of the Alaska Public Utilities Commission? What will be the policy on sale of "secondary energy"? What is the purpose for providing a c~pacity to produce secondary energy? Will sale of secondary energy be subject to regulation by the Alaska Public Utilities Commission? · Will rate structures favor sale of large blocks of power, at low unit cost, to major industrial users? If so, will the availability of cheap power induce basic industries to locate in the rail belt region? Would this location for basic industries be desirable, from the social, econ- omic and environmental standpoint of the existing rail belt community? f" You have stated that the project area contains some discontinuous permafrost. Is any permafrost located beneath the impoundment areas of the two dams? If so, will the extreme yearly drawdown be- hind Watana Dam lead to continuous melting of permafrost and erosion of resevoir banks?· What will be the effects upon fish, wildlife and human activities downstream from the dam sites 298 Comments to Draft EIS October 7, 1975 Page four. during the twelve years of construction? Will the Susitna River be entirely impounded, ,by Watana Dam while Devil Canyon Dam is being constructed? 7. What effect will the loss of low, clear flows of the Susitna River in wintertime have upon the fish which migrate from the tributaries to the main stem during wintertime to avoid freezing? 8. What effect will the increased wintertime volume, more than eight 'times the· existing uncontrolled winter flow, have upon fish and wildlife in the Lower Susitna? What effect will this increased winter flow have upon erosion potential? 9. Will multi-level releases of water from behind the dams lead to increased siltation during re- leases·, when, water and silt from the bottom por- tions of the1 resevoir are released? . 10. What will be the peak monthly flows antici~ated on the river after construction? The Impact Statement lists only average monthly flows, not peak flows. 11. What measures will be taken to control the·problem of "frazzle ice" 'under cold winter conditions? 12. What is the present cons.umption of the rail belt area, in terms of barrels of oil? ·13. Has the total energy cost of twelve years of dam construction been debited against the eventual production of the project, in terms of barrels of oil1 . 14. How much oil would the total first costs of the project buy at today's prices? 1293 I 294 I 295 I 296 I· 297 I 298 I 299 I 300 I 301 15. What will be the actual amount of delivered power I to Fairbanks, Anchorage, and other rail belt points? The Impact Statement lists only the projected power production at the dam site, and does not calculate ·, f 302 299 I, Comments to Draft EI~ October 7, 1975 Page five. , lG. .303 17. 304 20. 307 power losses. What factors w~re used to calculate a benefit- cost ratio of 1.4? Why was ah artificially low interest rate of siY and one-eighth per cent used? Does the nature of this project, on· a glacial river with no presently known technique for dredging rcsevoirs filled by sediment, jus- tify a 100-year life projection? ·Upon what factors was the 100-year project life calculated? Does 'the Corps of Engineers have any available data from other hydroelectric pro- jects constructed on glacial rivers with stream flows comparable to the Susitna River? · ·What will be the effect of increased energy, velocity and abrasion of the released water below Devil Canyon Dam upon the Lower Susitna River, and upon the turbidity of the river? ·Is "flood control" a planned benefit of the 'resevoirs, as mentioned on page 71 of your draft? 'What is~the historical incidence of Susitna River floods? Why has the proposed project been stressed for a "maximum credible earthquake 11 with an epicenter forty miles distant, since tpe Susitna fault is .only 2.5 miles from the site of the dams? Upon ·what assumptions is the ·turbidity rate during winter flows of 15 to 35 parts per million calcu- lated? This assumption seems excessively low, when measured against the· river's increased abra- sion potential, the multi-level releases, and the significantly increased winter volumes. . . 'J Your Draft Impact Statement has seriously neglected to place Devil Canyon in the context of present and future recreation potential in Alaska and in North America. You state that it is one of three major white water riVers in Alaska. However, you neglected to point out that, among white water experts, it is considered the premier stretch of white water in North America, if not in tbe world. Of .. 300 Conunents to Draft EIS October 7, 1975 Page six. the three Alaskan rivers mentioned, the Alsek and the Bremner are inaccessible by boaters at either their origin or their terminus. By contrast, Devil Canyon can be reached on the Denali Highway for departure, and its terminus lies on ~he Parks Highway. Recre- ational white water boatiftg is one of. the fastest-growing sports in the nation, and particularly in Alaska, yet we have no analysis of this increase in popularity in your Impact Statement. On the contrary, your only statemen~s concerning outdoor recreationists, or to white water boaters in particular, are repeated references to "a few hardy souls" witi1 veiled implications that anyone who · tries to kyak any portion of Devil Canyon has a death wish. Your impact statement fails to analyze the tremendous growth of self-· propelled sports, such as mountain~ering, hiking, backpacking, and white water boating. Instead, it assumes without basis in fact that the Devil Canyon area has no present or future poten- tial' for these sports, and can only be made available for recrea- tion users by creating some sort of artificial access, such as· resevoirs and roads. The Draft Impact Statement does not discuss the proposed Talkeetna Mountains State Park and the effect such a resevoir might have on that proposal •. Nor does it disc~ss the federal lands surrounding the resevoir proposal which may be se- lected by Cook Inlet Native Regional· Corporation, or may be traded to the State of Alaska as an addition to the Talkeetna Mountains State Park proposal. With increased mechanized access being one of the prime features of the project, it will almost certainly h~ve some type of impact upon a State Park proposal. What value was added to your bene~it-cost ratio for the recreation opportunities \ihich you foresee as a result of construction of the project, and I upon what factors were these values based? i Simply stated, I feel that the value of Devil Canyon of the ~usitna River, as the freest, wildest, most violent and most impressive free-flowing river 'on the continent, ·has been entirely overlooked. The river, to my knowledge, is still eligible for wild river status under federal law, and any decision by the Interior Department not to recommend the river iri 1973 was based on the fabt that a hydroelectric project was proposed, and not on any inherent characteristic of the river itself. ·Base·d upon the content of your· Draft Environmental Statement, I have found no compelling reqson why Devil Cahyon should not remain free and uncontrolled, a monument to nature and·. no't ·to man·, or particularly to the Corps of Engineers or our Congressional deleg~tion. Please include my statement in your record of oral testimony 301 308 309. 31.0 Comments to Draft EIS October 7, 1975 Page seven. concerning this proposed project. I am also submitting a written statement which I would like included in your hearing record. I will expect to receive copies of any further public correspondence which you may issue as consideration· of the feasibility of this proposed project continues. In addition, I would expect to re- ceive your Final Environm~~tal Impact Statement'concerning hydro- electric project feasibility in Southcentral Alaska. Thank you very much. I • I • ~{~ Thomas E. Meacham · 1410 "H 11 Street Anchorage, Alaska 99501 302 RESPONSE TO COMMENTS OF THOMAS E. MEACHAM DATED 7 OCTOBER 1975 282 The timing of the issuance of the DEIS (22 September} and the scheduling of the Public Meeting(s) (7 and 8 October in Anchorage and Fairbanks) were responsive to CEQ guidelines. Guidelines for agency compliance with NEPA are promulgated by the President's Council on Environmental Quality. These guidelines stipulate a 45-day review period for the DEIS following the announcemr,1t of its availability in the Federal Register. Such announcement was made in the Federal Register printed on 3 October 1975. Thus, the periJd for public review and comment on the document does not expire until 17 November 1975. With regard to public hearings, CEQ guidelines stipulate that a DEIS be made available at least 15 days prior to the time of such hearings. This requirement was met in scheduling the Public Meeting in Anchorage on 7 October 1975. Opportunity for public input into the DEIS in this instance is 57 days--from 22 September to 17 November 1975. Actually, comments received by 3 December 1975 are included in the EIS. Public Meetings (hearings} are designed to involve public participation in a continuous two-way communication process which fnvolves keeping the public fully informed on the status and progress of studies and findings of plan formulation and evaluation activities. It is a means of actively soliciting from agencies, groups, and individuals their opinions and perceptions of objectives and needs. And, finally, it is one tool for determining public preferences regarding resource use and alternatives thereto. Two previous sets of meetings had been conducted prior to the October meetings. The first informed the public that the study was underway and solicited their views as to the direction it should take and as to what specific concerns, wishes, or inputs they had relative to the study subject matter, the study area, and any other allied fields they cared to address. The second set of meetings reported to them the study progress, especially a number of possible alternative means of accomplishing (and even the option of foregoing accomplishing) the basic study purpose of providing electrical energy to supply projected area needs. Once again the comments, desires, and inputs (both factual and intangible) of the public were solicited. The latest meetings continued the previous progress from general to specific by presenting the end results of the preceeding studies, expressed public opinions and wishes, and weighing of the many technical, environmental, and economic aspects of the alternatives. 303 2 83 Related to the above misunderstanding of the public review period of the DEIS, there appears to be some confusion as to the purpose and scope of this document. Simply stated, under NEPA (Public Law 91-190), <J summary document (EIS) must be prepared outlining for public scrutiny (and review by Federal, State, and local agencies) the s_t!J_n_ifi cant impacts (both adverse and favorab 1 e) which can be reasonably foreseen to result from a specific course of action proposed by a Federal agency. The content of the document is out- lined to include five major areas of discussion. They are: the environmental in1pact of the proposed action; and adverse environmental offects which cannot be avoided should the proposal be implemented; alternatives to the proposed action; the relationship between local short-tenn uses of man's environment and the maintenance and enhancement of long-term prod~ctivity; and any irreversible and irretrievable commitments of resources which would be involved in the proposed action should it be implemented. A great body of· interpretations, regulations, legal decisions, and policies have subsequently evolved to more specifically define the procedures, fonnats, detailed contents, and processing of the various and sundry versions of EIS's. The feasibility report is a separate and distinct document which examines in detail many of the questions you raise. This document, as well as the DEIS, contains data which were summarized at the Public Meeting. Because the report could not be finalized until the public views on its general content, especially on the conclusion and recommendations to be contained therein, it could not, of course, be published prior to the meetings set to obtain those views. It is now being given final revisions as a result of the meetings and of review by higher authority. 284 The growth rate projections for energy demand are by the Alaska Power Administration (APA). They reflect a 1975 revision of the figures from the 1974 Alaska Power Survey. The major competitive projections are those published by OBERS (Office of Business economics--now renamed Bureau of Economic Analysis--and Economic Research Service). These projections are based almost solely on population trends and have to date consistently badly under- estimated all varieties of growth in Alaska. 285 The alternatives mentioned have been considered as a part of the feasibility study. Data from all available sources have been utilized. Coal is found to be the major alternative to hydropower. 286 Hydrodevelopment may or may not supplant development of alterna- tive rower sources. The proposed project will supply the area power deficit only to about the mid-1990's when either additional hydropower or other alternative sources will have to be developed. 304 287 Comment noted. 288 The capacity of the two-dam project is not excessive. The electrical output is less than three times the present Railbelt need (not six times the present State need, as you state). As such, in conjunction with present systems (and any others developed to meet the demand growth prior to hydropower availability), the proposed system will satisfy the mid-range demand curve until the l990 1 s when additional power will be needed. 289 Alaska Power Administration (APA), a Department of Interior agency, will manage the project much in the way Bonneville Power Administration manages the Federal hydro system in the Pacific Northwest. They are not subject to APUC regulation, but work closely with them. 29U Yes. However, there is very little secondary energy associated with the proposed plan. Such energy is not designed into a plan, but is a result of defining the 1'firm 11 energy as that which can be produced in the worst water year {drought). Thus, in most years, there is additional water available to produce 11 Secondary 11 energy which, because it cannot be guaranteed to the user, is usually sold at a discount on a when- available basis. The secondary capability of the proposed plan is only about 12 percent of the firm energy output. Again, APA is not subject to APUC regulation, per se, but cooperates closely with them. 291 The proposed project is not intended to be developmental, but to meet a projected, conservative growth projection. If the projection is correct, there should be little in the way of large blocks of power available to induce extraordinary industrialization. For further response to this comment, see response number 255. 2~2 Yes. some permafrost is located beneath the Watana reservoir and may be also within a portion of the Devil Canyon reservoir. We foresee both melting of this permafrost and some erosion as a result. However, the overburden subject to erosion is shallow over a majority of the steep, rocky canyons, and the net effects on either storage capacity or the shoreline should be minor. 2~~ The downstream effects during construction should be minimal inasmuch as the entire natural river flows will be passed by diversion tunnels until completion of the Watana Dam about 1986. At that time, a regulated flow consistent with the needs of downstream fishery management will be passed until completion of Devil Canyon about 1990. Again the river flows will be diverted through a tunnel around the Devil Canyon damsite during the construction period at that site. After that, full regulated flow, as 305 described at the Meeting, will be released. It is now standard procedure to minimize construction inputs of turbidity-pollutants to the river during construction to the extent that all construction waters will be cycled through settling basins, etc., if such need is found. 294 The low level (less than 35 ppm) of glacial 11 flour 11 which we expect to be passed downstream year-round (in lieu of highly turbid summer flows and very clear winter flows) is similar to the natural conditions at Kasilof River-Tustumena Lake where fish thrive very well. We foresee no noticeable adverse impact from this source. However, a final determi- nation of these effects will not be made until detailed studies, some of which are currently underway, are completed. 2~5 The wintertime flow volume, even though substantially greater than that of minimum natural flows, is still quite moderate and should have little adverse impact on downstream fish and/or wildlife. The equalization of the summer and winter flows and the elimination of most of the sediment load will tend to change the dimensions at the river and will increase its erosive potential, but not necessarily actual erosion. The rocky nature of much of the canyon below the damsite will resist any regime change for centuries. Only in areas of alluvial deposits would the tendencies for concentrated flow in a narrower, deeper, possibly meandering channel manifest themselves. Furthermore, they would only be noticeable in that portion of the Susitna River upstream of the Chulitna River confluence. In the past, estimates of erosion downstream of damsites have been too great. In these estimates, the phenomenon of channel armoring (i.e., the small size material is swept away and not replaced, leaving a uniformly large stone bottom highly resistant to further erosion) was not considered. With the present state of the art, most of the above-mentioned morphological processes are calculable, and any potentially adverse effects can be minimized. 296 The purpose of the multilevel intake structures is to allow selection of the water released to preclude just such downstream quality problems. 297 No releases will be made from the reservoir bottom, but only from the active power pool--say about the upper one-third to one-half the reser- voir depth. The peak monthly flow would occur during a major flood and would be much less than the natural peak flow since the reservoirs offer storage to allow a spreading of the total flood volume over a period of days rather than a few hours under unregulated conditions. During non-flood periods the combined Devil Canyon and Watana system would be operated so that Devil Canyon would reregulate the Watana reservoir discharge to provide 306 nearly constant hourly streamflow below Devil Canyon. Devil Canyon, in effect, will be serving a component of the baseload of the system and Watana would be utilized to serve peaking requirements. The composite effect of this operation would provide a nearly consta~t hourly hydro- graph for the river reach below Devil Canyon. 2U8 Frazil ice is a short-term early.winter phenomenon involving a specific set of meteorological conditions in association with shallow, clear rapidly flowing water, and the absence of ice cover. The very deep, milky, relatively placid waters of the reservoirs are totally opposite to the conditions favorable to frazil ice formation. Be that as it may, if such ice did form, t~e capability of selective withdrawal of deeper- lying, warmer waters provided by the multilevel intake system would offer a simple, immediate, built-in solution to the problem. 2~~The estimated Railbelt energy demand for 1975 is 2.4 billion kilowatt- hours, the equivalent to consumption of 5.2 million barrels of oil. 300 In terms of construction costs, yes; in terms of energy consumed, no. 3t}l The answer depends on what value is assigned to today•s oil. At a price of $13 per barrel for oil from OPEC nations, the project•s first cost is equivalent to approximately 115 million barrels of crude oil. It should be noted that the energy provided by the project over its 100-year economic life will result in non-use of over 1.5 billion barrels of oil or its energy equivalent of over 11 trillion cubic feet of natural gas. It is also likely that future oil prices could increase substantially. 3 l) 2 The quoted 6.1 bill ion kilowatt-hours reflect the net annual power delivered to the two distribution ~enters, Pt. Mackenzie for Anchorage and Ester-Gold Hill for Fairbanks, after deduction of transmission losses estimated at 0.7 percent of prime energy. The approximate split of delivered energy is 25 percent to Fairbanks and 75 percent to Anchorage. 303 The basic benefits are shown on page 106 of the EIS. The interest rate is that set by regulation of the Water Resource Council for use in econrnnic evaluation of Federal projects, and reflects the government•s cost in borrowing money. Sedimentation is calculated to reduce the system storage capacity by 4.2 percent in 100 years. Most of the lost storage is in the "dead storage" zone, not available for power production in any case. The system power output reflects the storage lost to sedimentation over the 100-year project life. Also see response number 121. 307 3\) 4 The 100-year life is a Corps of Engineers standard for this type of project, used in computation of project economics. This policy is accepted by the Water Resources Council and by Congress. The actual useful life of the structures should exceed the 100 years by a large margin. The Corps has data from projects located on many types of rivers. It is from this data that a standard methodology of calculating sedimentation rates has been developed. To attempt correlation of sedimentation of the upper Susitna River with other rivers only on the basis of flow or storage of water is meaningless. Many factors, including but not limited to geology of the basins, river gradients, precipitation patterns, runoff characteristics, and topography, influence sedimentation and must be considered to detennine any valid correlation. 3 0 5 Increased kinetic energy in the form of high water velocities due to the large head of water behind the dam is dissipated at the dam. Most of the energy is absorbed by the power station turbines. Spillway and outlet works releases spend their energy in the discharge pool below the dam. Thus, the discharge velocity ratios in the canyon downstream of the dam are the same after project completion as under natural conditions. 3tl6 Flood control is a project benefit. The present adverse effect of floods on humanity is limited to damages to the Alaska Railroad. Pre- vention of these damages is the sole claimed flood control benefit. As the downstream area develops, there will be a growth in population and property which could be adversely affected by unregulated flows; however, no estimate of this future benefit is claimed. Flood control benefits are about 0.03 of 1 percent of average annual project benefits. 3t)7 The Susitna Fault, although close to the project, does not have the probability of creating as violet (high magnitude) an earthquake as the 111ore distant Denali Fault. It is for this reason that an 8.5 Richter Maximum Credible Earthquake (MCE) at the Denali Fault {40 miles distant) was selected for design purposes over the 6.0 Richter MCE event at Susitna Fault (2.5 miles distant). The turbidity level is predicted on the basis of all settleable solids being trapped by the two reservoirs with only the suspended solids {glacial flour), 15-35 ppm being released at Devil Canyon Dam. The present summer sediment load of the river is attributable to easily erodable soils in the upper basin and is not an indication that signi- ficant material is being picked up downstream of the canyons. In fact, the lower riverbed is relatively stable under all but extremely high flows because of the gravel-cobble nature of the bed materials. 308 . ·. The DEIS and feasibility study do not slight the recreational potential J~ (j of the whitewater river. Factually, the area is isolated, has little access, no supply-subsistence facilities, and the Devil Canyon portion of the river is so violent as to discourage all but the most skillful kayakers. As best as we have been able to determine, less than a dozen attempts have been made to run portions of the rapids in the .last 50 years. Its classification as a Class 6 river, a threat to the life of even the most skillful boatsman, and the awe of its violence exhibited in written accounts of some who have challenged the rapids guarantee that its recreational use would be limited to a very few people. The reservoirs could and wou~d. however, provide recreational opportunity to broader sections of the public, while about three miles of the rapids would remain to challenge the whitewater enthusiasts. As to ignoring the area potential for "self-propel1ed sports," our view is that these are the most likely recreational uses for the lands surrounding the reservoirs. As such, we have estimated only a limited recreational development based on camping-hiking-boating, rather than a heavy day-use type of development. The DEIS does not discuss the conceptual Talkeetna Mountains State Park inasmuch as the State Division of Parks has not indicated any plan that the project area should be a part thereof when or if the park becomes a reality. Rather, they have discouraged association of the project too closely with the existing Denali State Park, preferring that the area be considered a separate State Recreation Area if the State becomes the project recreational sponsor. The fact that the lands for many miles to the south of reservoir sites are presently set aside for native selection under the Alaska Native Claims Settlement Act would appear to argue heavily against the probability that the proposed park and project would be in any way closely associated, at least for the foreseeable future. ,J, :J Comment noted. ,J.i_d Comment noted. philip n. osborn • geologic consultant U·92NO AVf.. N.E. • BELLEVUE, WA 98004 • (206) 45,·3588 17 October 1975 Col. Charles A. Debelius, District Engineer nepnrtment of the Army Alaska Dietriot, Corps of Engineers P.o. Box 7002 Anchorage, Alaeka 99510 SUBJECT: Draft Environmental Impact Statement: Hydroelectric Power Develop- ment, Upper Susi:na River Basin, Southcentral Railbelt Area, Alaska Gentlemen: 'rhe following material is submitted for inclusion in the records of the public meeting of 7 October 1975, RE: Southcentral Railbelt Area, Hydroelectric Power ~tudy, and as specific comment in reply to the Draft Environmental lmp~ct Statement recently issued by the Corps in relation to this study. Within my capacity as a geologic consultant I have had previous imput to this study; specifically, in preparing a reconnaissance geologic study of the Upper Susitna River watershed for the report to the Corps by Jones and Jones; Upper Suai tna River, Alaska: !!!. Inventory and Evaluation of ~ Environmental, Aesthetic, and Recreational Resources. My comments are restricted to the geologic aspects of the proposed project and within this discipline to the inherent seismic dangers of the site and the geomorphological adjustments ~hich may ensue construction of the project. I have thoroughly reviewed the Draft EIS and have personally communicated with Mr. Yould and Mr. Chandle~. RespectfUlly submitted, '1j§J. ;V. ((k~ hi 1i p • Osborn Geolog o Consultant Eno. 310 pacific northwest and alaska geology • ground water resources The Draft Environmental lmpact Statement for hydroelectric power development in the Upper Susitna River basin contains insufficient data within the geologic discipline. This data is essential to a complete and adaquate evaluation.of the proposed project - -its merits, benefits, and costs. Specifically: 1) The geologic map on page 16 is incomplete; faults which transect the Sueitna Basin are not shown. Major faults intersect the Sueitna River down- stream from Tsusena Creek (Susitna Fault), at-Vee Canyon, upstream from the confluence of the Susitna ana Maclaren Rivers, and near Denali. Several smaller faults are located in the Valdez Creek area and at other areas within the site. Undoubtably, other faults exist within the study regionl' they may be presently inferred or unmapped due to the immense area and the lack of detailed geologic surveillance. 2) The geologic map shows no indication of structural features, particu~ larly in Devil Canyon. A larger scale map should be included showing faults, joints, shear zones, and lithology of the Upper Susitna Basin at the proposed dam sites. Specifically, at Devil Canyon, a master joint set striking N. 25° w. and dipping 80° east, a minor joint set striking east -·west and dipping north, a shear zone with strike and dip similar to the master joint set, and the massive phyllite lithology striking east -west and dipping 0 . . approximRtely 50 -60 south are not shown lKachadoorian, 1974; Osborn, 1974; Jones and Jones, 1975). ~) There is no mention of actual movement along the major faults within the study area and those outside but which could have significant effect on a dam and reservoir system; in particular, but not limited to, these faults and offsets should be mentioned: Denali Fault .t-post-Pleistocene displacement of 120m measured and 200m from aerial photograph interpretation; Totchunda Fault--poet-Wieconsan displacement of 270m {Page, 1972); Susitna Fault--11 km of displacement inferred from morphological expression (Unborn, 1974J 3:11 4) The possibility of an increase in seismic activity as a result of reservoir impounriment and fluctuation is not mentioned. Noting the immeqiat.e proxil'lli ty of the Watana reservoir to the Susitna Fault, this possibility shoulfi be considered. This phenomenon has been widely recognized and io well documented, e.g., increase in earthquake activity following tho impoundmont of Lnko Mead behind Hoover Drun tRichter, 1958). 5) There is no mention of the recurrence periodicity of rrreat earthquakes ~greater than 8.0) within Southcentral Alaska. A great earthquake may be expected approximately once every 30 years {Sykes, 1971) or 16.7 times during the reasonRble lifespan of the dam structure. 6) LA.rt;e portions of the Upper Copper River basin subsided during the March~ 1964 earthquake lPlafker, 1965). The implications of further subsidence during future earthquake3 and the possibility, however remote,.of a change in drainage patterns whereby the Watana reservoir might invade the Upper Copper River b~oin should be analyzed. It should be noted there is only 162 feet of elRvation gain from the· Vfatana full pool level to Lake Louise. There is · a high probability that the Copper River system has been the outle't for the Upper Susitna nrainage at least once and possibly·several times during the geologic history of the Upper Susitna River tUsborn, 1974). 7) lt is absolutely imparative that the possibility of a seiche generated by seismic activity or landslide within either reservoir be considered. These standing waves can have devastating effects, as evidenced at Lituya r·· Bay {Miller, 1960), and have been responsible for several overtoppings and dam failures in historic times. In addition, the following geomorphological problems and questions, should be addressed. 0) How will the accumulation of sediment at the bedload "dumping.ground" at the upper end of the Watana reservoir effect the river morphology? •. 312 9) What changes will occur in delta building at the mouth of the Susitna River and what are the effects on sedimentation in Turnagain Arm as a result of lower sediment loads in the Susitna? (The principal source area of sediment in Turnagain :Arm is the Susi tna drain~e.) 10) All existing sediment load study samples are instantaneous; there are no continuous samples. Due to the tremendous sediment load in the 30 day period following breakup {perhaps 60 -BO% of total) when discharges may exceed 90,000 cfs, the existing data ~.s inadaquate to allow volumetric extrapolation for·a 100 year period. 11) WhAt'effectA will fluctuations of the Watana reservoir have on solifluction mass wReting and will there be a substantial increase in shoreline erosion? r I 12) What effects will the transmission corridor have on permafrost in the area of traverse? How will the transmission towers be anchored to prevent dislbcation by heavinR.of the disturbed surface? These and mony other questions, problems, and inadaquacies suggest that the document should be returned to the Southcentral Railbelt Task Team for additional studies and voluminous additions to the Draft Environmental lmpact Statement. ~!i:n.a~1 Geologic Consultant 311 313 ' . ,Jones anrl Jones, 1975, ~ Susitna River, Alaska: An Inventory nnd F.vnluation of tha rnvironmentnl, Aenthetic, and Recreational ReAources. Prepared for Alnnk:l. Diotrict, Corpo of J•)'lgineers. KacharlooriM, R., 1974, Goology of the Devil Canyon Dam Sito, Alaskn., Q • .§.. Gr::ological fiurvoy Open Pile Report .1A=..1Q.. Miller, D. J., 1960, Giant Waves in Lituya. Ray, Alaska, Q. §.. Geol'ogical Survey Professional Paper ~. OF.lborn, 1-'hilip N. ,. 1974, Geologi~ Reconnaissance of the Upper Susi tna River YIRtershen. Prepared for Jones and Jones. Page, nobort A., 1972, Crustal Deformation on the Denali Fault, Alaska, 1942- 1970, Journal of Geophysical Research, v. 77, p. 1528. Plafker, Georee, 1965, Tectonic Deformation Associated with the 1964 Alaska F~rthqunke, Science, v. 148, p. 1675· Hichter, Charles F., 1958, Elementary Seismology, San Francisco: W. H. l•'reeman and Co. Sykes, J,ynn n., 1971, Aftershock Zones of Great Earthquakes, Seismicity Gaps, and Earthquake Prediction for Alaska and the Aleutians, Journal of Geophysical Research, v. 76, p. 8021. - - RESPONSE TO COMMENTS BY PHILIP N. OSBORN 311 The EIS recognizes the most important and major geologic aspects Jf the project area. The Corps of Engineers will study all of the areas of geologic concern expressed in Mr. Osborn's letter and many more geologic conditions as the Southcentral Railbelt study continues. To this end, the Corps has already retained two con- sultants specialized in the field of tectonics and seismicity .'o'f the area. The United States Geological Survey has been asked to do the geological mapping of the river and reservoirs. This would include tectonics of the area, land slides into the reservoir, seiches in the reservoir, as well as the required geologic data as outlined in Corps of Engineers' regulations and manuals. 3i5 Deor t i'r. I J 0 ri-\ C)+L\H. hu~ tht 'l'V\CI~ th(Ai t~Q Ch r1~ tup hQr Pec:.n(/'o't (j..~op h y \ ,.,."'\ Ins-h Cull ec., (' A-k th1nh t hl.\t tht UY\y 'Y'\eeJ F-CIY" t h c.," 'J ~ ,)),.;~ ~ \V h1) pr-upo:J two ,.. "'m ~ Oh ·HH v pper s U\ a+Y\c.a ray e,.. t.vwiJ p r o J u t Q • I . t h 1 Y\ h t h "'1 + ht hUVt.. CJf of e ner-'1 y -nCJt prvbubl~ ;o tH 1 h !-o Jowy.. turn· rut~ of tht Fa. n· h v. "-hJ a~ u fffn.. p 1 in I 1 \·"~ r1 f 1 n ., h~. t h \ V\ ~ t "' ~ 1 0, [) t \ 0 Y\J 1 l.--1. . ~ {) e v 'h c. u n t~ ~ -nt P · (. l-t'"" h J Cvm. t) · mo~ ,.-ec..v,~(it~k. ;2. +-~y .. T ht rA cJ J eJ a J Vc.tnTCA.~ wov\J flooJ \~'\ \e.s~ lu.hJ l +hu-' 316 l'rnp~c,~" I Ja th ''r\ \-\ thuvf-1~ th~t ,F-rA -JC'AV'f\ I ) "fa b-t bui\t \n Al<4sh~ t-ht s u Sit~ - ttVtt 1S ~( p l (A.U. F0r lh - -312 -.. 312 Comments noted. RESPONSE TO COMMENTS BY CHRISTOPHER PEARSON ,, Col. Ch:1.rlen A, Dcbcllus Dl~tr\~t ~nglnccr Al:t~!~a !:i::;t."C'lct., Corps of Ene;1nccrs r.c. nox 7002 Anchorac-:c, AK ?95)0 Dear Col, Inbelluct P.O. Box 171 Anchorage, AK 99510 October 11, 1975 I arn wrHlnc ln ~uncral rcfe~nco to the Upper Su.sitna River Project. AHhour~h I n.m nca\n:~t •_;,o project for onvironmcntnl and social lmpact rcn!':On!::., J' woul<i .1. tkt:: to focuo my commcnta on 1\ spec inc part of the ~tucly. The foll oH1 nr: cornmentn, therefore, havo to do 'l>ri th the trans- ml~::;ion cor.rldl>:r, call,~d alternative "Suaitna.-1" in the Scptcmbnr 1975 drart of the l~nvlror.r.:cntJ.l Asscnnmcnt of the Susitna Tr.:ln~nic~ion :.::yutcm, which rarnlJcl:-; -l:.h!':' Alanka flaUrond between Talkeetna and Gold Croek, A-:J a r-1.rt.-ycar rcdrlcnl of Lnnc Creek, located near mile 241.7 of the hln.r:k.1. lb.Hrna.d, I .:1m rlceply concerned about th:\.G part of the project. I a.m not alone; thorc n.rc hundn)d!: of pcoplo who o wn or lca.r.e land and tlho have recreation or rcs1dcncc cabins in the n.n!.J. afTnclci.l by "Susitna-1" between Talkeetna and Cold Crc~k. Ar.ccn::; road:.; w111 rul n this ureJ., l'lrlngtng ln lnrr,e r.nmbcr~ of penplc and nll tho nttcnrl.-Lnt problem:., whlch !.fl prcclG~ly wh:1.t mc:-:t people l."ho built in thh; area ~~<Lntcd to get away from. In a.ddttlon to tho roadu, the transrnin51on towcrn, line!:, and clcaro1 area.::; wHl ~ un:::\ehtJy nnct nn impairment of the wilderness cnvlronr.tcnt. In rea.d.lng the above rncr.tiom~d d!"aft, I W"-S ::;urpr1:>cr1 and dintre::;::;cd at. the 1nr.omplctc nnd ntbl cad ing information which 1 t cnntni ned, I a.n rcfering here to lhc r1:1trl ~cs and ~upportlne text for the E:nviror.tncnlal As~essmcnt and F.nvironnlen·l·,a.l Impact eectionc.' Although the draft '-CCrr,s to have been intond")ci n:::: 'l surcrficio.l study, the errors I will nclc ar~ .r;o glarinG that they ro!],uir~ corrurr~nt a.nd corrt!ction before the draft 1~ u~o:d a~ a baniz for .:uty doc1nior.::.. The mal.r1x fo:r. thi~ noGrnent· of "f.usitna-1" 'under Ex1st1nr; Duvclopment::; indicate scvcr:1l l'l'dl.co.J.d ~topn, of llhich.L."lnc' 1~ oru:, !.ann is not even a fl.J.g r~tnr • m11l 1\i'.:>n • t bc•cn for many ycar:1. Tho curr.m t. flac; stops arc mile 2)2, ?.)).5, 2J{,, ~)iJ,If, 239.5, 2'•1.7, 21~1~.6, ami nt.llt!r:; nnrth to Gold C:r.eok. l~ch of ~.he=-.r: ~t')1J.::; rcpr<lr:rmt mr.all co:nmun1t1C!; of .J. ccattc.r.cd three to ten cabin~ t!hi<:h pt~c'plf~ u::::n for ro~rcation or re~~ir!cnc~P, mo::.t.ly'the latter. Th~ locn.tl(')r!~ of' th" r..1.b1n:; rant:;c up to thrc~ mll(]t, and o<;c.:li!;ionally furth~r, fp'n th~ rn.~ lroad tra~k:::~, The r.utrix for Inp.ct::; under Jo;xicting Dcvelor,c::~cn~:". lnd1 ea~r:~ no impact in this area, a.l thouch lm;er down on the r.o.r;c t:1·.~ :>t~ph~:1 ! .. 1.!-:e cn.btn!1 are rn~:1tloncd. The tC'xt h: cqnally incomplete. Infnct, the "Irr.pct:-:: of rr~ferrcd Corridor Susitna-1• (pc. JB) scnrcely ~cr,tlons the T:J.::..l~c~tr::J.-Cold Crc~k :;eGmcnt at all. -2- The rather 51gn1flc~nt ov~~z1gnt of lgnorine this large block of people a:1d thr. impact the "::3·.r~i l:.r.:t-1• corridor. will have on them, indicates a vory 51lP~rf1cl al ~!Hl .:-.1~o::;t irrc!jponsi blc analysis. I note that the matl.ce~ can 1Y.! ca:-:0 y l!pr!n:Lcd. In l ic;ht of the lmformntion cont.1.ined herein, I hope th;J.t th{· dr.:~n., ma.t:r-iccf: and text, will be corrected br:forc bclnc ~:ub~llt ~r:-d ~" ~~d.~~cn na!H:r:;. A wildernc~!:i lire _f{•T :-::r~~l'\.!" <1nd a larc;c numbur of peo~1le \fill be dc~t.royed lf the t.ran:;mi:;:;~on l~.n~·:; ar(l bullt in thl~ corridor. 1 would therefore li kc to :;c..: U:c .. :~u:: t ::.-.:1.-l" al te-::-na::.l vt:-between 'faH:ec'tn.J. ~nd Gold Creek ul:andoncd. If thl::; car1no!. b~: done, tiler. at h~a:;t ::;tucly it carefully to mln1m1ze the 1.r.tp.;~.c~. ':'Lcrefo!:"e, I c'::rtalnly hopo you wlJ.l con~ider hcJJ.coptcr con:;tructlon ln lhl::; ::\!"~~a and cho':lcc a route whlch will avoid privately . ln:1:1r:d or mmod 1 ~.t!vl. -::c. :::e ~n:t Ot'3 Craw~ l U!lrl ::;tcven~ n~p~e~cnt~tlv~ Y~ung "'t'"' ~r;..;.:; t .".:;~ ~~-~ :-'o",.~'.: r J .. dr.:l!l.!.~t '!"a. t 10:1 81nccr~ly, ... f • I /f /'t I•. ·;· .,/ u ' /_/I~ ( , ...... . R. John Strascnburgh 3'13 RESPONSE TO COMMENTS BY R. John Strasenburgh The study is currently in the feasibility stage~ thus detailed design and routing of the transmission line has not yet been accomplished. For this reason, the present routing of the line is designated as a relatively broad strip of land constituting a "corridor." As stated in the Environmental Assessment for Trans- mission Systems (APA}: "To avoid presumption of private lands~ the final route will be flexible enough to circumvent small blocks of private land.11 The assessment goes on at some length describing the actions which will be taken to lessen the obtrusiveness of the transmission line wit 1 1 care given to proper design and locations. The section of the assessment dealing with impacts on scenic quality and recreation end<; with the following statement: 11 Whenever possible. existing rights-of-way should be shared or paralleled to avoid the problems associ~ted with pioneering a corridor in inaccessible areas. Trails in these 11 inaccessible 11 areas should, however, be avoided; preserving wilderness quality entails sharing or paralleling all rights-of-way except trails~ and from these, lines should be shielded as much as possible.11 Thus. preservation of the wilderness setting will be a major consideration in transmission line location and construction. 321 STILLWATER CLINIC fiOl\ 8 COLUMBUS, MONTANA October 21, 1975 AlaGka DiGtrict Corp of Engineers Anchoraee, Alaska 99500 Re: Upper Stwi tna B'lsin Hydro-Electric Power· Development. Dear Sirs: It come::; to my attention that a power development including a dom or several dnms in the upper Susitna and Devil 1 G Canyon is otill being proposed. It is my feeling that very little thought has been given to the environmental im.JX".lC t that (iUCh a project would have, and the permanent loss of some tremendous river floating and booting in the future years. This particular stretch of river is as magnificent, as far as rivers go, as HcKinley i~ when one considers its relationship to other mountains. I feel th."Jt any mea.Gure to change or deface this river should he as carefully considered as would a proposal to chang~ or deface Mount Me Kinley. I wiGh you wou]~ enter this statement in the hearing record aa evidence that there is strong opposition to the Di!vil's Canyon Dam that will permanently destroy the marvels of thiG canyon. 314 CH3/ch :~1~4 Comments noted. RESPONSE TO COMMENTS BY C. H. SWANSON, JR. M.D. 32d ()·~~'""' \7,1.~~"\t~.w... Y~~-i 7u~ ,.,~16-•. ~ ""'""' \ JOliN II. :;w 1\NSON J>. (). """ 'Ill "··~····· c~lifnrnla ')4701 324 - - . -/ ...... .~ , ~.l.J Comments noted. RESPONSE TO COMMENTS BY JOHN R. SWANSON Alaska District Corns of ~n~ineors P.o: nox 7002 Anchora.ce, Alaska 99510 Dear !iir: .... 410 S!<arland Hall University of Alaska Fairbanks, Alaska'99701 Oct 7, 1975 I att<'nrlP.d your hco.rin.:;s helrl here in Fairbanlm in October, with t;rent interest and concern for the ·future development of th.e. proposed rlams on thP. Dir; Susi tna RivP.r. I war. comc:\'/ll:l t e.u r'l)riscd when Colonel T)ebclius mentioned that there mic;ht otill hr.> a. !'cmsibility of arlcUtional dam construction such . as the Ha':'l;nart. ·,'/hen the Corps tri0s to resurrect such sl~el11 tons of thi!l r.:wcnitudo of .Oiolocical blunder, it maJtcs on9 \'lander about oomc of th~ rooaonin~ behind present studies. !Llthou::;h I wonlci he the first to adr:1it that the ·Dcvil's Canyon arfla ~ould be ~ probablv tho best location for a dam site in the State, I ·!eel that ~ s ncc~Gsary to evnluatc all of Alas~t:a 1 s rcnourccs, · nnr:. \'.'inc land usc planninc, \'tith the best and wiF>cst use of resources instead of dcvclopins in a piece mnal style. · . . I f0.r.l that the qu("'r;tion should be rais~c1: as to the necessity of . a c\ett'l for hyt!ro-elcctric por1c:dr'lt this tir·H'. 'rhcrc nrc presently Mnny cnrrry resources beinG ~dsted in Alask~. FlarinG of natural t:as haa been carried out for over a decade in Cook Inlet. As a stuflcnt· on cm1!lU!3 at tho University of Alaslm at Collc~e, I '.'.ritnese ('n tire flo ore urinoc cooarily burn1n:: clcc trici ty 211 hourn a clay, and conct~~a!)tion io at a mai·imum. ThP. fact that 'tho.· Corpn of Enl;inccrs is planninr; this proj0.ct at this tiMe, prior to l~nowlcdc:!'.) of the route the r::a.s p~pclinc will tnltr.t ind1..cJ.tcs v.n J.ttJ.tudo of 1'dr.volopmcnt for cl.cvclopmcnt 1 s sake 11 to r>crhap::; qnotc J. \'!elll':.nO\'ffi Alns\wn inversely. If ~.nfact th(• i'Torth ::nope _:as onipcline cl.ocn r;o throu.:h Alnsl~a, it would a~p0.ar to me to be extremely short cichtcd at this time to co nhca<l Wl th construction !'llans, as v:cll as cncouracinc more \'Jaste ot Alaol~a 1 o rcncr:able J.nd non renewable rcsou rccc. · · ,., ... cc: Governor Hammond Yours· ~dncr.rcly 1 ~ ~~~ 7 Bo.rbnra ~'linklcy . . 3 ] 6 Corrments noted. RESPONSE TO COMMENTS BY BARBARA WINKLEY 327