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HomeMy WebLinkAboutAPA4040REVISED DRAFT ENVIRONMENTAL IMPACT STATEMENT i:3~O Hydroelectric Power Development UPPER SUSITNA RIVER BASIN SOUTHCENTRAL 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 .,/t..f s (X)~evised Draft Environmental Statement Sta tel;ient ( )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 s1a t i ve 2.D_t:!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 ll-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~ Alaska Resources Library &Information Services J\nchorage,AJaska 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 0 air,water,and vegetation as a result of slash and debris disposa ;inundation of one historical site and any archaeo- logi 1 sites which might be discovered within the reservoir pOD social impacts related to seasonality of construction work and emands 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 Department 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 Deve1opment--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 Environmental 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 __ j ~~~..'~'---".-, ,, } II \ 0:::: lL1 W r->->(/) >---<«e:::::I-w L):r: c::I:w r- 2:0-0:: l-V)0 CC Z V)w ::=>0-tD V)Z Z 0::::..........~ lL1 V)0 0-c::I:0 0-eo -.J ::=> ; "r :>p / .' .' .,r ) -'/ ,~'i !/ I I I, I ,,' '. ':.' \ i, .~ .I..... " i r I / I, \.' ,i \ '\I, i }1 OJ '!r:,,, \\'( 1,'/ J ,I"; .i ,~ \\ I·\;'\ I \\. I O· , 0,, I. I 0 I\"l! :(~~'I ,...~, 'i~.' I /./ \ /) ) l \ \ JI \ } ( / I I Looking downstream on Susitna River at Devil Canyon damsite.Dam would be located near bottom of photo.Vegetation is mostly white spruce. Ta p 1 3 the ProJ~ct 9 9 ctlvft 3.02 E iii 8.0 I l TA lows Oa on the Pt ....e ct Pa e 99 100 100 lal 1 1 1 p 5 fl ,. 2 6 7 11 12 l3 1 1'" i e Brown r- iv Pa.e 2 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 Railbe1t 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 Railbelt 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 "Railbelt"(see Figure 1).Major power resources,both hydroelectric and fossil fuels,and the greatest power demands are in this region. o L 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,and electric transmission facilities to the Railbelt load centers,access roads,permanent operating facilities,and other project- related features. A subsidiary purpose in the construction of the electric trans- mission line will be the interconnection of the two largest electric power distribution grids in 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 .J:> Looking upstream toward Watana damsite.Tsuena Creek in left center of photo. Da~site just beyond the visible section of river. 100"1(1 .. SUSITNA BASIN MAP .",.:':'. SCALE---~o 50 UPPER LOCATION VICINITY MAP FIGURE 2 5 add;ional 0,8 billion kilowatt-hours per yea.The 6.9 billion kilo- watts of irm and secondary annual energy would be the energy equivalent of about 1 ill 11 'on barrels of oil per year,or abou 112 billion cubic feet of natu a gas per year,or about 1.5 billion barrels of oil over a 100-year project-life period. Most of he enerated electrical power would be .ized in the airbanks-Tana:a Va ley and the Anchorage-Ke a'Pen'ns a a ea.The ropo ed tra smlssion ystem would consist f two 19B-mi1e,23 kv s'91 circui lines from Devil Canyon to F 1rb nk (c lled the enana cOl"rid r),and Lwo 136-mile,345 kv sin 1 cir u't lines froll .vil Canyon to the Anchorage area (c 1 ed che u i a corridor).oth lines would eneral1y pa t 1 1 the A ska Railroa,Power wOLl-id be carri fro.Watan to Dev I Ca yon via two single clrcuit 230 kv tran r i 10 lin t di tance of 30 miles.Total ength of the transmission 1 s wo d be 364 iles.The general locations of the transmisslon lines are shown on Fig re 3.Transmission 1ne corridors wa 1 require a rig t- of-way of approximately 186-210 feet in idtl otaling slightly more than 8,200 acres of which about 6,100 acr s would re u're clearing.Towers would be either steel or aluminum and of free-standing or guyed type, depending upon final design and local conditions. Ace ~to the Devil Canyon and Watana sites would be determinec by siting s u ies that wo ld include consideration of the environmental impacts for f0ads and transmission lines,Preliminary studies indicate an access road approximately 64 miles in length would connect the Watana site with the Parks Highway via Devil Canyon,A factor considered in location and design of access roads would be their SUbsequent use for public recreational purposes. Project-oriented recreational facilities would include visitor centers at th dams,boat launching ramps,campgrounds,picnic areas, and tra'l systems.Some of these facilities would be developed in cooperation with Federal,State or private owners of 12:,d adjacent 0 the project.Housing would also be provided for operations personnel, The total first costs of the proposed hydroelectric project bsed 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 financing. 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 8ibliograp~.) Th"s 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 exhaust;-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 La 93-251,sets forth a two- stage post-authorization pre-construction planning process rior 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 will 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 '" FIG::RE 3 8 J-- {20 .u.~()~...·.fwlfce :W1t U 4M ..IJ.s~u~../~l;j(7I/~ ,. ..'... PPER ITNA RIVER -ROJEC T A 8M IS S ION SYSM Your SCAL.E o APA-)'I7S 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 l3,832-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 grave1- filled valley 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~in,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 o Susitna Glacier on Susitna River drainage.Glacier melt in summer months contributes to hiQh sediment in the river. - FIGURE 4 11 ~..J i r:; ~ o o z BV)'!<l:gCD a::~~~~~a: 8 r<l:~iz I- Vi :::> i5II) a:gw "'..J 0-..0- :::> ,/ ;-:::;:v I ~ ~:I ..J_ i l \.,-, < > \ j ( \.. I I \ ( ) i 2 <} I ~o The principal tributarie of the up ade Maclaren,the less tur'Oshetna, (rigur 4).Numerous other smal er t i S :reamfl ow .n the Sus i tna 'ver bas'n "I d'charg f om May through September a d hr ug Apri 1. er sitna a in are the si t- a d th~clear-lowing Tyone taries generally run clear. .h racterized y a high ra e of by low flows rom October , discontlnuas r wrli c a TM area above and b low he Mac aren iv r june ion Wl he Susi na is gener .ly unde ain y thin 0 ode a ely hick pe af S". Max"m pt t the base of penllafrost in thi area is bout 6 0 feet. Aro d ~1 rger water bodies,such as lakes,permafrost is eneral1y absen.I some areas of the lower section of h uppe Susitna b sin permafr st is not present.Additi 11 data i req ired be ore pe frost areas can be specifica 1y identified upstream from evil Canyon. Be.cause of the 1eng th of the proposed tr'sml sian sys em an the diversity of terrain and ecosystems bisected by corridor extending rom Anchora e to Fairbanks.the system is div'd d into six major segments w . h 1 nd themse ves to discussion in erms of genera 1y si "r ec logica characte ·stics.The ro te ex e d"lng soutll from Watana Dam Pint MacKenzie is referred to as t e Susitna Corri 0'. The rou e nort fro Gold Creek to Ester is cal ed the Nenana Co r'dor (both orrid rs share the line from Watana to Gold Creek).The corridor for most of its length generally parallels the Alaska Railroad, TMe Susitna Corridor is subdivided i 0 three m jor segments:(a) Point MacK nzi north to Talkee na,a distance of 84 miles;(b)T lkeetna to Gold Cre k,38 miles~and (c)Gold Creek to Watana,iles.The N n na Corr;o is als d'vided into three se ments (conti uing nortn): ( )Gold Creek to Cantwe •62 miles;(b)Cantwell to Healy,39 miles; n (c)H aly to Ester,97 mi es.These locations are shown on Figure 3, Re"evan physical and ecological features of individual transmission line segnents are described in the following paragraphs, 2.01.2 River Characteristics,The upper Susitna River is a scenic. free-flowin r i ve'\~\"i th very few signs of man's presence,The extrem upper and lower reaches of the Susitna occupy broad,glacially scoured valleys,However,the middle section of the river between the Denali Highway nd Gold Creek,occupies a stream-cut valley with extremely violent rapids in Devil Canyon. 12 i--' V) Confluence of the Tyone 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 ll-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 glacial melt.The main streams during the high runoff periods. retard water f10ws,streams run caused by snowmelt.rainfall,and carry a heavy load of glacial silt During the winter when low temperatures relatively silt-free. 2.01.3 Cook Inlet.All of the major water courses which flow into Cook Inlet either originate 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,the 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 Mesozoic volcanic rocks in the Talkeetna Mountains.Figure 5 delineates t' 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 GEO LOGY OF TH RAILBELT AREA ~',r-50--~_~""- .-/' " ~-- '\ ~' «;:> e~c .; uaJ d£hris, ,..~'.: OCKS rir:e ilnd l'lc·"rna"lne; h1C rocks r ..t ....,..hale,ml.ld,.tor.-£; ~ •~itiary vu:i1n1..;r.x.J..' ;o]c:lnic rv~l-;~ 4;I;C intr~ive nJCks;m;;wiy gyuf11nc :del.ArnOrpl-.ic !"'Oc.Y~:....:l-..5!.5ntds!S J tn"j dy Pi!:t"'IlI01C l"luntT1i.1rm Sdr:d~tur.t;;I ::-.R IA~Y l ATER.\.-".R':' S lldidal cliJpcsitt>.alluv:um. eoilan.o;ln!:l aDa .;;i 1 -- F~u~l (il;t"ihr:d wh~...e ifJ fe"red) "'al"oz...i,;.ntT'tJ.:ive rocks;granitic and uhramati<: 1\~p""od.II!C volcanic racks PAl£OZOlC 1'..:,1)?RECA~.[ f';',U:OZOIC .\:~D P RECA!.1BRl,.l_' S=nd5IOfl~~iialE'.):;:YSlc:ne.mostly IT::anr.". inrlud~some early ~.:e5n,l:'Jic rocks JG~.EUL·S '<.C':::':S LEGEI'.'r, Source:C.S.C.S. APA-jlft5 Si'T'[r-.~fi'"TAHY N:n ~IF-:-A~,:G!<.PJiiC o TJ >-< G) C ;:0 fTl <.J1 -' O"'l 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 t e north into a series of tight canyons separated by the wide valley of Ylnert Fork.The corridor emerges from the canyon into a wide rolling plain south of Healy,with stream terraces adjacent to the r:>ana River.The corridor is bisected by the Denali Fault at '/li::dy Creek.Elevation at Healy is 1400 feet,dropping to 350 feet at Nenanc, 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- qua ke. Much of southcentral Alaska falls within seismic zone 4 (on a scale of a 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 flineral resource potential within the proposed reservoir impoundment a rea s. 17 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 Climat The Susitna basin has a diversified climate.The latitudeo:r-h region gives it long winters and hart mmers~wi great variat"in the length of daylight between winter an sum e • The lower Sus'na basin owes its relatively moderate cllmate (.0 he wann waters of t acific on the south,the barri.er effect f the Alaska Range on the west and north,and the Talkeetna Range n t e east.The $u~mers are characterized by moderate temperatures,cloudy days,and gentle rains.The winters are cold and the snowfall s fairly heavy. At Talkeetna,at an elevation of 345 feet,which is representative of the lower basin,the normal summer temperature ranges between 44 0 and 680F,with winter temperatures ranging between 00 and 40 0 F.The extreme temperature range is between -48 0 and 91 oF.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 0 F and annual precipitation 21.85 inches.From Cantwell to Healy,the annual temperature is 27.7oF 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 oF 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;Gowever,population studies and additional resource studies are needeG.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 co.nercial salmon ~~ught in Cook Inlet during 1973 comprised about 10 percent of the 136.5 millia pounds of salmon harvested in Alaska during tle year.Chum,red,an ink salmon totaled about 94 percent of the salmon catch for Cook Inlet during 1973. (1973 Catch and foduction--Commerci 1 isheries Statistics--leaflet #26,State of Alaska Department of Fish and Game). The 1973 comnercial 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~snificant 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 rJ,- fluence with the Chulitna River during the 7-week study periud 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 soczeye, 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- mined from peak slough and stre,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.t is not unusual for this species to attain a weight of over 40 pou ds.The aximum age is 8 years.In 1973,over 5,000 kings were caught in Cook Inlet;the total COl'nmercial c c comprised about 1.5 percent of the total weight of s.a Ion cau t i this area.The 1973 catch fi'gures for king salmon were very low when compared to the average yearly cutch for this species. Sockeye a i a (Red}.The sockeye s lmon ave"ag s between 6 and pounds wi h a range of from 2 to 12 pow ds.This ecies spends from I to years 1 a river system in which there are connecting akes.The maximum age attained by this salmon is 7 years but most return to spawn a-4 or 5 years of age.The landlocked va ·ety of this species is c T ed 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 tota wight of over 5 million pounds,or 37.0 percent of th tota eight of th Cook Inlet commercial salmon catch.About 14.5 percent of the sockeye salmon catch in Alaska occurred in Cook Inlet. Coho Sa lmon (i I ver).The coho or silver sa 1 lOn spends from 1 to 2 years in fresh water and returns from the ocean to spawn at 3 or 4 years a 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 (Humpback).The pink salmon migrates to sea immediately after hatching and returns to spawn at 2 years of age.The average weight of a mature pink is 3 to 4 pounds,with some pinks weighing up to 10 pounds.The 624,000 pink salmon caught in Cook Inlet during 1973 w 'ghed over 2,260,000 pounds and comprised abou~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 mi1lion pinks. Chum (Dog Salnlon).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 Pac'fic Sdlmon.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 .~er 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 r 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. uring the warmer months of the year.when the Susitna ,iver is si t 1 Je~,sport fishing is limited to clearwater tributaries and to areas ~n the main Susitna River near the mouths of the e ri ULar:J. Resident fish,especially 'grayling,apparently inhabit tl e mouths of some of the cle [water streams on the Susitnh River between Devil Canyon and the Oshetna River;however,most of the tributaries are .O~ steep to support significant fish populations.Some of the upper s ·.lio~~ of these clearwater tributaries,such as Deadman Creek.support grayling populations.Lake trout are also prominen'in many of the tprrace ar. 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 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 thousanr.; lakes and ponds in this area to nest and to raise their YG~ng.Q h numbers of migrant birds also use the Susitna River basin for fee ing 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 Raptors.Raptors.including golden eagles,bald ean es~arc various species of hawks,owls,and falcons.occur throug out t ert:f Susitna River basin but in smaller numbers in the river canyon betweef 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 MAP I High Densily tlTM'~Medl m Densily Low Densily SOurco'Jol'."Flderol,Slot.Lon U>e Plonnl""Commission FIGURE 6 22 i I WATERFOWL HABITA I ~....L...;;E.--.;,~=~? o ~o ,r·1 Mil., A.P.A.-JULY 1975 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 th;s large bird arp often used by raptors,including peregrines and·yrfa cons.Ho ever ere was no evidence that the nests observed were being used by r ptor . 2.02.2.3 Other Girds.Unknown numbers of game birds,such as spruce grouse and willow ptarmigan,inhabit the Upper Susitna River asin. 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. 2.02.3.1 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 FIGURE 7 ?/~ o W D FE CARIBOU AND 81 s ---- ......~ ,r The Alaska Department of Fish and Game considers the Nelchina herd to be one of the State1s 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 11 ited in distri ution w'~h:n ,2 tra mission ':';ne system to the 136-mile segment extending n rth fr III ~antwell. In the mountainous area between Cantwell and Healy,they concentrate south of canyons.They are found in concentrations on the west bank ~f the Nenana River north of Helly 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 1,800 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, huY1ting pressures,wolf predation,unbalanced age-sex ratios,and elir i- nation of habitat. Much of the Upper Susitna River Basin is at or above tililberl ine, resulting in large amounts of "edge"at timberline which produce con- siderable quantities of willow,an important winter forage "0r moose. Successional vegetation changes following fire also contribute heavily to areas favoring moose habitat. Limited numbers of moose i nhabi t the Sus itna Ri ver bottom b~ot~.;een Devil Canyon and the Oshetna River,because of a restricted a~ount 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 as 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 rizzlies,although the more timbered areas are seasonally important. enning 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, otner herbaceous plants,and carrion when available.On occasion, 25 lL SHEEIR BROW I BEAR Cd Moose Concentration MOOSE. FI lURE 8 26 , SCA!-,E. :'>0 001,111 • 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'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'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 p~ovide a significant amount of hunting in the upper Susitna basin. The goats generally inhabit rougher terrain than do Dal1 sheep,and are thus less susceptible to man's activities. 2.02.3.7 ~olve.Wolves occur throughout most of the Upper Susitna River Basin.ropulations 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 Ta1kee na Mountains,and the upper Copper River drainage area.The wolf has b ~n removed from predator classification and is now classified as a game animal in Alaska. Alaska Department of Fish and Game nlartagement studies concluded that,from 1957 to 1967,wolf predation neither adversely affected other game populations,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 damsites. 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 W'ldlife Services publication,Threatened Wildlife of the United States,th,t 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 V~~ation.The major ecosystems of Alaska are divided into marine and land groupings,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.The 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 tributary,only scattered stands of black spruce occur,growing up to the glaciers.The lower hillsides 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 suscepti 1 _to long-tenn 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.Much 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 land 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 through~ut 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 Railbe1t 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 Railbe1t 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 Failroad bridge. At the present time,only a few small settlements are located along the Parks Highway between Anchorage and Fairbanks and the Alaska Rai-I- 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 Railbelt 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 Federal,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 region1s transportation industry reflect the positions of Anchorage and Fairbanks as major transportation centers,not only for the Southcentral Railbelt 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 ittle dire impa.ct on t tal e ploy- ment,mining.finance,i surance,nd r 1 tao e play importa troles in terms of the secondary mployment they ge era e in the region.Most pe ple employed in mi inngage in activities rela ing to petroleum extra ion from fields'Cook Inlet and t e Ken'Peninsula.A ub- ~tan ial rt10n of he oya 1ti s and tax s col ec ed by the -a e s a result f oi production in the area is retu to the area ~he arm of jobs i ate government n_through r v nue s aring wit variou local overnmen s.T e tot lue of oil an ga productio i h outhcentr 1 reg on for 972 as almost $240 m'llion Similarly the A'l'Ichorage fi nan 1 sec in p,e of 1 t sma emp10yment exerts considerable conomic 1 v ra e as the bankin center for A aska. Mas 9 icultural activi ies in he Sout central Rai elt area take place 'n e 1atant.Jska.usitn,and Tanana Va leys.The pot n . 1 for agricul ur in these areas of Alaska is conside ed f vorable,altho gh deve 'opmen of the industry has not been extensive. Commercial fisheries activity is the o1dst a -based industy of m~jor importance within the region.The 'ndus a changed substantially during the past 20 years and continues to be mod fied as a result of oth bio ogic and economic st'mul1,The s~lmon indu t y has alwa s been jar mpo ent of t e 'ndus y ,terms of VOlume and value.Since 9~51 h ki,crab,shrlmp,an Tanner crab fishe ie have undergone ma r devel pment,and halibut landings have increa d substantlally in re nt years.The total wholesale value ofoi11lTlercial fish and ell- fi'for he southcentral region of Alaska in 1972 w s just over $100 millio inc\uding a catch of almost 110 mil 'on pou ds of salmon 'Jith a wholesale value of nearly $38 million. The southcentral ~g on of Alaska inc udes th Ko a -Shelikof area.the Cook Inlet area,and the Copper River-Gulf of Alaska area, Th So thcentral Ra'lbelt area is that portion of th southcentra and Y Kon sub egions that is served by the Alaska Railroad. The region's timber output is less than 0 percent of the total timber harvested commercially in Alaska.The tlmb industry is shifting from supplying the local market to production 1med 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 roe fn the ecoomy of the region.Precise data on tourism are not availab'\,e,but tiL numbers of A askan visitors have increased from about 130,000 in 1971 to approximately 216.000 in 1973.A forecast by the Division of ourism 1,1973 estimated 288,000 people would visit Alaska in 1975 and about 554,000 in 1980, 34 w U"l Looking north along the Denali Highway to the Arnphi theater Momtains. Morainal ridges rtm across the middle of the photo.The biome along most of the eastern half of the Denali Highway is moist tmdra. 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 uti·lization 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 section 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 ;s 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 addition 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 ut~lize many lakes and streams to ferry freight and passengers 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 Access is again the m or fac or In determining reas t tare u ilized in fishin for gray i g,a'nbow trout,white- fish,and lake trout.The Susit a and Mac aren ivers are silt laden throughout their entire courses during the warmer man hs of the y ar. Therefore.sport fishing is limited to a es,clearwater tr'butaries, and to areas in the main Susitna near the mouths of these tributa"ies. 5;ligh any or flo -equippe r'ibuta 1e',such me pres re f 'om oat fl S ,r- ATrs to get I t no t of ing pressure in some areas. prssure in the upper s of the river afford eas along e ain Su y ne 'iver and ake Lo ise h ve r en.A lncre.asing nur,ber of hunters I -e e back country.exerting incident 1 fi As previously statea.salmon do not migrate in River above Devil Canyon so are not a factor in the this area. the upper S til a port fishery of 2.03.4.Boati".9.A minor amount of ree'a i n 1 boa lng occurs in the wa ers of he upper Sus;cn-basin.Some ake such as Lake Louise have a heavier a ount of boating activity,and som f'vers such as the y'ne and the u itna have a lighter am 0 boaLi g activity.Some kaya'ers utilize portions of the main Sus·tna River.but very few have br ved the difficult waters of the Susitna through the area known as Devil C nyon. 2.03.4"~Camping.Most camping use in this area is incidental to other recrea.iona activities such as hunting,fishing.b tin and h,gh\~ay travel.Some developed campground facilit'e are located a Lake Louise od at three campgrounds along the Dena .Highway outside the upp~r u itna basin.Tourism during the summer months involving the use of c mpers~trailers,and similar recreational vehicles is increas"f1g at a dramatic rate in Alaska.Many of these ve ic es camp along the t'Oads where adequate facilities do not exist and where these activities are creatlng ever-increasing adverse impacts upon the land. 2.03.4.6 0 er Outdoor Recreational Activiti s.Most other recreat'onal activi ies 1n the upper Susitna River basin exert varying envir nmental impa ts on the area.Many activities such as hiking.backpackin •and photography take place incidentally to other recreationa pursuits such s hu tin,fishing.boating,camping~and driv ng for pleasure.Tra" ik s.sno obiles.four-wheel-drive vehicles.and other mechanical e uipment can cause extreme adverse environm tal damage to the fragile eco ystems of the basin when used in a careless.uncontrolled manner. At t e 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 remains 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 nrea. Two sites,both designated as cabins,are located on Kosina Cree~,one near its mouth,and one about six mil es ups tream.The apparent deartll 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 lndiar~ 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.glvlng 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 McKinley Park was by way of the gravel Denali Highway until the recent compl eti on 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 proglac:'al I a ex'sted d rin ion dating bac Oll1e 10,000 to 1 expec fur h r ema"ns to be found detai e ve,stigatio-ns are made. Power The energy demand 1975 projecti s provi represents h cffinbine fr ma interconn cted row r tes Tee ow h ate a use 0 en rgy an nd afte the last period of glacia- ,000 years.Its reasonab 1 to around the 1 kebed marg ns when more for th a"lbelt are increasing gene atin ca city and addi- TIe load projection used "n the hydropower study is depicted in 9 a ong with the other esti ~tes prov~ed in PAls 1975 analys·s. "hi.her"range anticipates ~igni 'icant ne energy an minera lopm nts from among those th t appear ost pro is 'n "a10 9 with an 1 growth rate in r idenl..ial,commerci 1,nd 1ight i dustnal uses remains throughout the study period s mewhat above recent electri- nergy onsumption growth ra es in the U.S.The "lower"range r'me fit nimal ind s ria development,a load growth rate for th rem'der of this d c de ell below current actual rates of incre se n en r y growth over t e next twenty years that barely matches th 1a test PQPtll a ion growth r te projections f r that peri d.Thi slower est mate enerally assum,-a significant sl ck n ng of th pace of evelopment almost irrunediately and conti llJing throughO t the peri d of s'~dy,he um'd-,ange"appears to be easonably conservative estimdte, wi h ann Di rates of increase in power req irements less than 7 percent after 19 0 (s compared an historical a n growth rate of 14 percent d r"g h period 1960 1971.This adopted "mid-range"projection ssume te dy but mod rate growth after the present boom period coupled w t-more efficient energy use. Because fed t'me need d for coal and hydroelectric develop en • mmedia e eeds for the next decade wi 1 ve to be h od ed by additional 0'1 nd gas-fired uni ts.However'>the opportuni ty e-xis ~for hydro d coal:'be orne t e main energy sources for Railbelt power by about 85, 1f prio 'ty 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 40,000 cr 30,000 J: 3: :lr::: Zo .J 20,000 .J ~ 10,000 ,I I I I ---LOAD 0 C I.~y ~~~/V y I I ~"I "I V- I/ ,V V v V I I I ( , 1/' ! v I ~O~vJ~....... !,II v v LO'H..-__v 1--1--"-.,1/!J--- V 10-I--J...-I--I-- -'J...-I--'l---l--- I--:I...-l:::=;l--:-.- J...-1= o 1970 1980 1990 YEAR 2000 FIGURE 9 42 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 l500-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 1,9l0-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 11(a)(3) of PL 92-203.Lands within the power site withdrawal may not be selected as Native Village deficiency lands.AccordinglYt 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 possibly to Alaska statutes,to permit such an exchange to proceed. 3.03 Utility 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 pTepared in accordance with the provisions of Section 17 (b)(3)of the Alaska Native Claims Settlement Act (Public Law 92-203). The Primary Corridor System is defined as a network of cor ida s intended for the systematic transport of high-val e.energy-related resources from their point of orl~in to processing or trans 'pment points in other regions of the State.The network is ntended to identify transportation routes for resources of nationai 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 fall ows: 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 1 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 miHy-textured "glacial flour"(suspended glacial sediment)would be introduced into the controlled water 45 releases below the dam.Preliminary studies by the Co ps of Engi eers in icate t t the suspended sediment in releases at Devil Canyon Dam would be at low levels (15-35 ppm).According to fishery investigations uring t e winter of 1974-75 by the Division of Commerc'al Fisheries of th A aska -artment of ish and Game on the Susitna R'vrr between rtage Creek and the Chulitna River,suspended solid samples of river water a"Gold Creek,Chase and the Parks Highway bri e indicated a range of from 4 to 228 ppm,and that these suspe ded sol'ds are i in Cl ddlomLs fish tolera ces.Alth U h th aver_9 s dinent load' S fllier month!>is les _han 100 ppm,10 s som_times Y"dch a maximum or 5000 ppm .n he nr g 1 '.d ri v r.Reduc on ~ex·ting summer sedi- Illen a .n p a k h \l d nave a nefic .a 1,effect an ana ramo sand re~'dent fis opulat ns for sam dista ce downstream rom Devil anyon Da . o occ ions W en spil ing water over Devil Canyo ecessary dur'r,g ldte s mmer periods of extre e high ~l WS~n su er a Ufa io cou be introduced into the r'ver el w the d m.flSh exposed to high levels of this condition can suff r gas-b bble disease (i'e bends to a deep-sea diver)which can be fata • The olTlbined high level regu-:ating outlets a ,d powerhouse capacities (30,000 cfs and 24,000 cfs respectively)at the Watana Dam are adequate to accommodate floods with recurrence intervals of up to approximately 50 years.At the Devil Canyon Dam the hydraulic capacity of the initial ur generat"ng units is approximately 25,000 cfs at normal maximum pool eleva ioon 0 1,450 feet.The low level outlet works t Devil Canyon are not designed to generate at pool elevation 1,450 feet,therefo e, total outflow without spill is limited to a maximu of 25,000 cfs.Of the 25 years of streamflow record,spills were est"mated to occur in 11 of the operation years,with the average spill lasting 14 days with an average flow of an additional 8,500 cfs.However,any ni rogen supers- aturation and dissolved oxygen thus introduced should be reduced sub- stantially in the turbulent river section just downstream from Devi1 Canyon dam.The proposed spillway at Watana Dam is not conducive to high levels of nitrogen or oxygen supersaturation,and spills would occ r very seldom,only on the occasions of extreme flooding conditions in ate s IIimer.Few fish,under existing conditions,are believed to occ y the two and one-half mile section of Susitna River between t e propose Dev'l Canyon damsite and the mouth of Portage Creek.This situation could change with a decrease in regulated flows during the summer months. Temperat re of the water released from Devil Canyon Dam would be adju'ted to approach th latural river water t peratures.This would be made possible by the roposed incorporation of selective withdrawl outlets into the dam structure. Veri ti ns in water relea s at Devil Canyon Dam would cause less than a one-foo do"Jy fluct ation of downstream water 1 ,vels in the river 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 also 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 ll-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 1/3-mile to 1 mile in width for much of its length. 47 ana reservoir would ~Isp.n :reeK that are WIU also -lood some moose res rvoir waul 1 0 cover f some of tributaries would create other fish h Ie spi lway design at Watana diverts the excess river flows into n 7susena Creek drainage approximately 2.5 miles above the creek's confluence with the Susitna River.On the occasions (approximately once every 50 year)when it would be necessary to divert excess river flows v the spillway duri 9 extreme flooding con i ions in late sun er,the v r envir.ental impact a fish and vegetation resources in 1 wer Tsu ~Creek could be significant. flood reaches of the S sitna River pstre m so etimes used as c ibou eros ·n95.t win er range i ri er bottom.e xisting r ident ~i abo at at the ouths in this sec on of he river and possibly it at higher elevations on these tributaries. Po enti water ality impacts caused by constr ction of trans- nissio ,ilit;s are he increased sil atiol'1 of ri rs d al<e' a t a . n of stre m flows;eutrophicatlon (i r se't e t 1 v 1 ) nd 01 ution of lakes and streams;and disruptio of uatic habitat lie to gravel borrow)fill nd excavation.El-n -no i or minimizing tnese potential adverse impacts would be emphasized during the design, construction,and maintenance of the proposed project . .0 Fi One of the environmental impacts caused by the proposed Devil Canyon-tana project would be the substantial reduction of ~tur 1 rive flows duri 9 he latter part of June nd the early p rt of J ly w en salmon start igrat"ng up the Susitna River.The roje ted dver 9 m nth y regulated flows during periods in August and Septelliber, hen e majority of the salmon are spawning,approach the average natura 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 rear"and spawning sl ughs on the 50-mile section of the Susitna River etwE~en Portage C and the Chulitna River,21 sloughs were found duri 9 the'23 July t rou 11 September study period.Salmon fry were observed in at east 1 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 rt Irl)ers (from 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 ju t over 350). During December 1974 and January and February 1975,the Alaska o artment 0 fish and Gutle investigated 16 of t e 2 sloughs reviously ':)'veyed during the summer of 1974.Of the 16 sloughs,5 indicated pre ence of coho salmon fry.The numbers of fry ca tu d in the 5 s10u IS at various times ranged from 1 to 21 with an average of 5.Many of he 16 sloughs surveyed were appreciably dewatered from the summer/fJIl s 48 The report also stated that a number of coho fry were captured in the Susitna Riv.er 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'little 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 spri ngfl ows 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 later. 49 According to a study discussed in the Journal of Fisheries Research Board of Canada--Volume 32,No.1,January 1975,Ecolog'cal 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 h dam.The increased flows could insure better coverage and be ter p rCG ~'on through the gravel and presumably increase egg a~d dlevin $vi al.Salmon alevin are young fish with attached egg-sacs na r a1 'n 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 iver.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 species 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 alkeetna. 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 t~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. W~tana Dam would have a widely fluctuating reservo;wh:-OJl genera'ly prove detrimental to the development of res nt fish )u- at~ons.Suspended glacial sediment could be a factor in both of he 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 Proposed Moran Dam on the Fraser River.This report states in reference to high dams:"The choice is clearly between upstream salmon stocks or dams." 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 transiGission 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 ecies.Potential impacts are:increased siltation of rivers and -kes;alteration of flows;eutrophication and pollution of lakes and s reams;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 Wild i Reservoir impoundments,transmission line corridors, and access roads would have varying degrees of environmental impact on w dlife. The Devil Canyon reservoir would be located wit in the confines of a narrow,steep-walled canyon with few areas of b·g-ame habitat and on no major migration routes for big-game animals.In some cases,animals such as moose and caribou may find it easier to cross he narrow reser- voir than they would the present fast-moving river at t e 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 l36-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 bal k.Although physical destruction of caribou habitat wjll 0 be a s "qn'lcant impact of power line construction,there are indirect conseif ences 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~'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 aY'~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 irds would possibly suffer s me mortality from collisions towers or lines,but such losses should be negligible.The line (generally parallel normal north-south migration routes.The c 1 5 would be large enough to have a high degree of visibility and would be wi ely enough spaced to be ineff ctive snares.Electrocution of bi 'ds'also unlikely since the distanc between lines and between i es and groun would be great enough to make shorting out by birds lmo t imposs·ible. A transm-j 5 ,i on ne pJ se w'1 not va m ny lmpacts upon wi 1 - life'mas f th ltlpatts will e as a result of cons ruct'on and lMin enance.Oirec de ruction wi 1 a ect the les mob Ie an'ma s such d 1 armn s,whose territories In y e sma 1 enough t be n ompas dye con truction area.The s gn'fica ce of this im ct to hese im I s is small in relation to the r pop lation in surround'ng ar s. "he los of habitat for b -·s,wol s.wolverines,all sheep,and o her anima s also appears to mini However,losses to any significant element of the food web wil af ect consumers.Thus, losses to moose or caribou wou~d impact on predator species.Other birds,inc uding raptors,songbirds,shorebirds,and game birds,do not a ear to b significantly affected by the reduction of habitat in the "r d of th~pro osed dams and reservoirs and on the transmission line corridor,a houg some habitat will be lost for 11 species of wildlife that ut'ize the affected areas. ROad access to the two damsites and to the transmission line would ave a significant impact on fish and wildlife resources in areas op ned 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 1 access road to the Watana Dam.The same would be true along vari us segments of the transmission line.State game management policies could control some of the adverse impacts on fish a wil 'fe in these areas.However,this increase in public access;i ity would significantly increase the necessity for intensified law 1forcement and fire prevention measures, 4.04 Recreation.Much of the Upper Susitna River Basin has little or, in many reas,recreational activity at the present time.A combi- nation of poor road access,rough terrain,and great distances presently limIt the use of t e 5,800-squa -mile basin,especially the lands directly impacted by the proposed project,to a few t nters,fishermen, and other hardy souls who utilize these wild lands for recreational purposes, The constr tion of the proposed hydroelectric project would have an impa t on a number of present and projected recreational activities both in the i mediate 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 vicf ity 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 thJ~ 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 11 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 " .....ilL'n:"0411p.o,O)~(JI ( RECREATION i"L.e. =-~~- \ ~ \ <7)-- UPPER SUSITNA RIVER BASIN 'G,,<:?, L v1 \,)-,~ = -.....~---!--\.'\ ~ I I (.....' ~ "- \ I / ~.......r") ~ (\-1./" ) P ~~,\". o~r r I ---....( -.v/-'(,--,~../\_/, o ,,~"'j"l ~';':)-'f"':".:/'~tr.J /~/__j~r _._;::/V ,~ !.Ul.£ ~ Q o ! o "T1 >-< c" (Jl Cm:;;0rn r.n -...J 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.lj The report further states:"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."(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 project a~thorization 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 acr:ess roads upon vegetation would be relatively snlall with respect to the magnitude of surrounding unaffected land.Up to 6.100 of . e approximately 8,200 acres of right-of-way would have to e cered. 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 for moose will be increased;the conjunction of good cover in the original forest with a swath of browse creates a diverse "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 Mini".',he U.S.Department of Interior,Breau of Mines office in Jun~au,A aska,has stated that the Susit a iver 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 A ricult reo No project benefits are anticipated for irrigation at this tfrn ,and except for provi 1ng reasonably priced elect ieal power to farms a d ag 'cultural activities,no other major impacts on agricultur re xpected. Pres ntly nost agricultural activity'the Stat I ~rom crop fan ing to d-iry far ing,occ rs in the Co k ln1et u region.Of the 2.Inil1 n c es 0 land that have soil c aracteristics con ucive to the prod ction of cultivated crops in the Cook Tn et-Susitna Lowlands. ab ut 70 percent occurs in the valleys of the atanuska and'he Susi na Rivers and their tributaries.Most of this land is as yet undeveloped . .10 Roads.Permanent roads would be built to provo -access from the Parks Highway to the Devil Canyon and Watana damsi s d some segments of the transmissio line.Permanent roads ou d also provide access to proposerl recreatio facilities within the roj rea.Temp rary roads for role construction and reservoir clearin operations would also be constructed.No roads would be built within the transmission line corridor in the 39-mile reach between Cantwell and Healy,and the 10- mile reach between Gold Creek and Chulitna.N 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 constructi6n 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 within Fish, values 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 pro:ect 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 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 controlled to minimize or to prevent adverse environmental impacts. 4.12 Workers'Facilities.No communities within commuting distance to the pioposed 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 contro laws and standards,and all activi ie'i would be controlled to min'"ze adverse evironmental 'mpacts presented by the c.mp.Lands used for operating t e temporary camp ar would be rehabilitated when the project work was completed. 4.13 E betics.The pr posed project wou d be located in areas that pr~s nt ly h ve pact iea lly no permanen sino;of man s pres ce.The no be ween Po~tage Creek and the Denali Hilhw y 's a natural n sceric area whic would probably qualify for w'ldernes classifica ion under most efinitions of the term. T e construction of the propos d W r ele ic p~oject wo ld have a signific nt pact on the existing at~ra en'c resour _val es within the project area.Any dam construction on the upper Susitna would h nge a eglllent of what is now a natural ee-owing river into a manmade impou,d(lIent.Wi th ina l2-month peri od,Devil Canyon reservo ir could fl ctuate up to 5 feet while Watana reservoir would fluctuate up to 125 feet under normal operating conditions.The proposed Watana impoundme is located in a narrow,steep,is 1 ted canyon where the seasonal1 fl ctuation would not have a substantial scenic impact.The vi ent,hitewater ection of the Susitna River -hro h Devil Canyon would be substanti ,y inundated by a dam at Devil Canyon.Roads and nsmission lines would also impact the natural scenic resource values of the drea. 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 wi 11 rema i n after cons truction.Good 1andscape management practi ces 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 existin or p sently 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 visi leo 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 mlnlmum 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 ir1pact,particularly if located est of h~ nighway and railroad.The line through this area coul be so wha 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 t ~ 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 a'l syst )and is the most likely source of a seismic event of this magnitude.The Sus1tna Fault,trun- cate by t e Denali Fault)bisects the region in a north ast to south- wes.direc ion approximat ly 2.5 miles west of the ~a ana damsite.Due to _h-relatively short length of the Susitna f ult a maximum cr dible edrthq~ke of 6.0 is considered reasonable.An r hq ake of this magnitld along this fault will be considered in the design of Watana a d Devil Canyon,ams . .1 Reservoir sed·ment inflow auld vary at each res rv proposed sys e ,Dev·l Canyon res rvoir 10 1 los approxir ely 6.5 percent of ts total storage are to sedimenta- t·n during a lOa-year period.Watana reservoir would have a lOa-year sedi nt inflow that would equal about 3.6 percent of the reservoir's storage capacity. Both roposed reservoirs have a ead 0 ag area hat·s not utilized for power produ ion;thelefo e,mu h of he ini ia lOO-year sedimentation for the reservoirs would be contained wiUlln this "dead storage space,"which would not have any si ni icant effect on reservoir ope atio~s.Much of the heavier sediment deposited in W tana reservoir wou d collect at the head of the 54-mile-long reservoir.ven ough , p oject~l 'fe is computed on a lOO-year period for economic reasons, W h adequate aintenance,the useful life of the proposed project due IJ s,edi entation is estimated to be in excess of SOD years.If at some uture time a feasible program of sediment removal were developed,the useful life period could be extended. 4.16 ClimaL"c Conditions.The severe climatic conditions in the Upper Susitna River Basin could have a substantial environmental impact on the esign cons ruction,and operation of the proposed hydroelectric c:I velopmp.o.P·errn rost conditions,extreme cold winter temperatures, 1 ng per ad of c ld weather,and ice conditions on the reservoir dod i are some of the significant climatic conditions that would haJ to c nsider·ed. TUpper Susitna River Basin is underl n by discontinuous perma- frost,so some project areas w~)i have to co tend with permafrost and other areas will not. Extremely cold winter temperatures and long periods of cold weather wiT place substantial restrictions on many project construction activi- ti s and increase the time needed to complete the construction of the project to a total of 10 years. I 'n c nditions on h.reservoirs and the river may cause a wide r nge f ad er e impacts bo on project construction activities and on project 0 erations.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 A1r Pollutio~.Most of th existing electrical power in the Southcentral Railbelt area is P'uced by gas,coal,and o:~-fired generating units which cause varying degrees of air pollution. Cook Inlet gas is a clean fuel that caus s few serious air pollu- tion problems at the present time.The ex's ing 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 exp cted within the Southcentral Railbelt area through the year 2000 1nd,-th 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 add tional power source.Projected power requi ements based on mid-range estlma'ces show that the proposed ,usitna hydroelectric development program could sup y a substantlal portio I of the ailbel 's proj td electric P \'Jer eeds starting in abo t 19 5.The proposed upper Susitna River hydro projects will not crea e large bl cks of excess electric power for h vy ergy-consuming indus ries.If larger amounts of electric energy re eeded for a program of heavy indus rial dev lopment,additional nergy-producing sources wi I live to e cons tr c :rI mmary he rojec is de.igned to serve proje ted po atio eeds--no ~o s~1m lat popu ct on rowt s conseq e re -ndus ries which would be attracte by large bloc's o excess lectrical energy. 10-y ar Devil Canyon-Wa ana hydroe ectric dey opment program would hav an economic impact on the Southce tr 1 Railbelt are hat would e It to a greater degree during the constru i n ph se of project development. It is expected that this proposed projec would ave some sail ·zing influence 0 he overall economy of the Railbelt ar during the period of construction starting in about 1980,since const etion would be initi te eral years af er the Alaskan oil pipelin has been built ahd abou t e time the proposed gas pipeline is scheduled for completion. e lumber of men required to construct this project is estimated to be bout 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'camps would be constructed in the vicinity of some of the various construction acti- v'ties,b t additional impacts woul be created by the families of the c nstruc ,on workers living in various nearby commu Hies who would require a d'tional facili ies and services.It is also expected t at due to adverse climatic conditions,much of the construction on the project facilities would be restricted to the warmer months of the year--probab y April through October.The seasonal nature of the construction work would have an adverse impact on the local economy during the winter months. A-ter 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 1 "gth of ~~le l36-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 ll-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 Al hough other major wildlife species,such as bears,wolves wolverines,and Dall sheep are not expect d to be directly affected by the project to a significant extent,there wil 'nevitdbly be some secondary impacts resulting from disrupt'on of ex's ing predator-prey lelationships.Overa 1,terrestrial wild,ife hab"tat will be reduced. Small animals resident to 'n ndated areas will be lost.Wit 'n he transmission 1 'ne corridors,those species dependent upon limax or near-climax vegetation will e the most a verse y affected.Examples ar he red squirrel and nor hern flying squi rel. Resident fish op lat'ons above Devi Cal1yon Dam t re ar no anadromous fish der existing conditio above this point)cou d be adversely af,ected to some exten y the hnge fro a iverine to lake environment 'Jithin the reservoir pools,and by the substantia winter drawdown conditions at Watana.The resid nt sport fishery i nat 'gnificant within the main river channel.Primary impacts would ace r nea the nout s of a few clearwater tributaries which provide some n wn graylin habi a.The intricate changes expected to 0 cur downstran from Devil Canyon will result in both beneficial and adverse impacts to resident and anadromous fishes.Adverse impacts co 1 result from pos ib e reduction in nutrients and primary productivity,cu ting and erosion of existin streambed configuratiorl,increase turb'dity during the winter mo th,nd changes in the hydrau ic and biol g'cal regime of salmon rearing and spawning sloughs.(As pointed 0 t in Section 4,many of the anticipated changes downstream from Devil Canyon Dam could prove beneficial to both t e ctnadromous and resident flshery.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 qUGiity and permit general public access into a largely pristine area.This would have the pote t"al to increase pressure on existing game populations through h~nting,trapping,and general disturbance and harrassment.This in turn would require inten- s'f'ed game management and law enforcement practices and preventative measures for the con 01 of wildfire.Another harmful effect would be the impact of some of the roads themselves where delicate ecosyst ms a'e traversed.Some of the inevitable consequences of road constructio are destruction of vegetation and wildlife habitat,reduced insulation of frozen soils,and settling from permafrost degradation,resu 9 in both erosion and alteration of the groundwater regi e. Degradation of visual quality in general would be a major adverse effect of project construction.This would be attributable primarily to roads,dam constru tion,right-f-way clearing for the transm"ssion line,and the obtrus veness of t transmissiOl line its If.Although care would be ta en to minimize these impacts to the grea est 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 "-....Jo 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 hydroelett~ic power from the Upper Susitn 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 So tons c nsid red n this investigation to mee.elec rical needs in the uu hcentral Railbelt area were gr uped in t ee m jor categories: al ernative sources of power;alternative hydropower sOU'ces in the R ;lbel area;a d alternative hydropower plans in thp.Upper Susitna iver Sl.T e extent of study glven to each potentia 01 tion was e t 1;ed by first screening each alt rnative for suitabil ty,appli- c bility and economic meri on me ting ne ds.Each alterna.ive was tested for phys'ala pol i l.ical financial,i sti tutiona t econ ic. enviro TIeI1"I an ocial easibillty.Con inuous coo d nati 11 WaS mai t lned w'h area Sta and ederal a encies wh'have related r ts.A erndcive as res cons'der d F power purposes are d"cusse in the 0110wing paragr phs, 6.02 lte native ~QLJrces of P wer. 6.02.1 ction.One of the alter tives 0 the development 0 .ocili i s to generate additi n'ectric power w klld be at to b il anyaddi 'on faciHties.his approac 'wo Td a e ne cos of planning,designing constructing,and operatin additiona facil'ties. It would also avoid the adverse environmental 'm acts wh'ch wo ld generae by the onstruction of dams or of 0 h r lectr'cal generating facili ie;0 ever,additional power sources a t 0 gh to be nec- essary and would not be provided by this alte native.If a hydroelectric sys em 's not developed,alternative power sources wou1'd be required to sat;y projected future growth needs of the R i belt area.Because of lead time involved in planning finan ing.and const uction of any currently viable alternatfwe,oil an natura gas must continue to provide the bulk of the area1s power supplies ntil t e 1980 1s.On an equivalent time-frame basis,coal is the most ik 1y future electrical energy source for the Rallb area,if hydropow r is not developed. Th impacts of the coal alternative are discussed in the following pa agraph. 6.2.2 Coal.Coal is the most ab ndant ossi1 f el in the nation. Southcentral Alaska has two known extensive ep sits (Figure 11).The Be uga iver area northwest of Cook Inl t c tains coal reserves of a least 2.3 biT ion tons or,energy-wise,e lvalent of almost 6 b lion barrels of oil.Development of Beluga cOo s WOUld enhance possibilities for coal-fired power geleration at reasonable cost.Coal resource_in he Nenan FieldS in the Southcentral Railbe1t uth of Fairbanks n ar H aly,Ala ka,are even more extensive than the Be 9 River reserves, to l'ng a least 7 billion tons,or equivalent of about 18 billion barrel s f oil. the major Obstacle to in reased c 1 usage is the the high sulfur c ten in order to meet air pollu- the coal is burned.Othe p oblems include stri with associated environmenta1 impacts,and trans- e e1u coals have low amounts of sulfur but high sh and water content.Considerable refining would be enable its use in power generation. 72 5 U~-----:""';;"':":"-J IOOMile'5 A.P.A.-JUlY 1975 COAL AND GEOTHERMAL.AREAS o~_~LF FIGURE 11 73 02:0 • VICINITY MAP The coal alternative could e available on about the same time frame as othe major new power so rces such as hydropower and possibly nuc ear power.I appears that a,eload thermal plants could be tilized 'n the ai be t area by 1990.Coa a d hydro p ent'al for the South- c ntr 1 Ra 'lbel t Illay be the 1 a 't ex e,shea ernativs for the new owet'u~p in t ~980'sand ey d but co wo ld e more expensive th n hydro.Coa1-fired plants should a 50 be glve consideration in e reas whi h d be sup lie by wa er transp rtation. In he absence of major hydro developme t or the discovery of addi- t anal gas reserves,it is assu erl elt ower sys em wo l shift from oil and gas--'red powe the rinclpal nergy s LJrce s a\'"ting bout 1985.t s hat the eoa plant wo ld either be co vent cn 1 s am or team t rbine units laca d n ar the Beluga a Nenana coal fields, I I v'ew of t qua t·ti.es of coal "invo ved and pres n -day mHllng [1'ctire it is presu ed that strip mining wo ld be ernrloy d to obtain t·coal.Without specific knowledge of the mining site,it is not possible to project how much acreage wo ld be affect d;however,it is assumed to e in the hundreds,possibly thous nds,of acres.Much addi- tional 1 n W uld be required for stockp 1 ng of ov rblrden nd mine wastes until such time a a portion of the p t be ame worked out and could be used for disposa.The immediate impacts WOI ld be the destruc- tion of the overlying vegetatio nd thus loss of habi at for the res'- dent animals and birds.Additio al land would be ltered for roads or other routes for working the mine(s)and transport ng the coal to generation acilities.Air quality could be expecte to suffer from lar e inpu s of dust.Water in contact with coal an min~wastes generally become acidic and toxic to vege a ion a d animal life.It is difficu t to prevent such water from enter'ng ei her th underground water tahle 0 the natural dra'age streams n the area and thus 'mpact- n ter qual'ty to orne ist.anc from the actu,1 min Any sce~lic val es in the mi ~a e wIld be lost at least u t t ,Ii e was exhausted and restorati completed. nv tal q a ities would also be affected at the power gen- r~ng acil ·t·es.CQ siderable 1and would e occu ied by the struc- tJres ~nd mo'y the p ra 'ng coal stockpi es and access routes.The associated veg ta ion,habitat,and scenic values would be lost.yen ~ith emissions controlled to legal levels,there would be an input of particula e llIatter and chemical compounds into the atmosphere.Large amounts 0 water would be needed for cooling ponds requiring either land for installation of the ponds and the removal of the wat,r from natural sources or he use of a natural water body (lake or river)for the coolin el€lllent.In the 1 tter case,the effects of "thermal pollution" tte receiv n water would be substantial,especially as regards ·timula on of vegetal growth and adverse in,acts on fish,if present. Oisposa sites for the waste combustion products would e needed and could require alteration of large quantities of land and its natural value. 7 Social impacts would be mixed in effect.The operation of the ri!1epowerplant would provide long~erm employment for many more people than for hydroelectric facility of t e same size.Because'of this.the visible economic effects related to isposable 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 facility would forego the r c eational and possible flood control bene:ts provided by a hydropower project. The adverse effects of coal mini 9 wl11 occur eventually regardless of t~e presence of hydropower development as this resource will be uti 1 i zed for 0 ther purpose~s .--- Using coal as a power ource invo yes xte s've adv rs impa'ts to the env~ronment,both in the f,agr it de of'ef-ects and in he sin:.of the aredS affected.Develop ent of hydro ower sources ou llow for other,more beneficial uses of 0 r coal resources.Therefore aal is determined to be a less desird e s urce of electrical nefgy 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 0 lo~ing the 19-7 Depa t- ment of Interior report,Alaska Natural Resources n the Ram art Project. most studies by Federal agencies and area utility con~anies ocu ed on the Cook Inlet supplies of natural gas and,more recently,on pi line fuels for Railbelt power.Location of potential oil and gas re erves in the Southcentral area are shown in Figure 12. 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 1east until the mid- 1980's. Cook Inlet natural gas has provided low cost power benefits for the surrounding area in the recent p t and,with substantial reserves under contract,should handle area power requirements for several more years. 75 FIGURE 12 76 v OIL AND GA POTENTIA 5'::-"--.....,;;..=- .' 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, H~gher costs for fuels i t J re,especially for oil and gas, shou b~considered in 1 f tU'e p ,0 iog and ~auld anticip te _erio s n t na effor s to d vela,lterna ive energy so rc~s t1at II it the Jse of oi 1 and gas -or power 9 .nera t on.To a very extent ~ese factors inva idate many pr via ower stud"es w made on the assunption that'~heaJ,long r ng 0'1 and gas fue would be available. Alaska power syst s now depend on oi1 af~0ds for aboli 60 percen' of to energy produc ion,and y 1980 out 90 percent 0 the Sate's electric energy will Cal from S :lrem'm f els.Est1Inated;c)2 ru"l use for Alaskals power sys ems include'mi Ilon barrels of oil nl 16 bi ion cubic feet of natural gas.If recent trends con inu ,the use would increase to about 26 million b rre s of oil and 134 billion cubic feet of natural gas annually by th'year 2000 under mid-range level estimates. Since low cost n~t ral 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 g's is changing;this,coupled with high power costs in the Fairbanks area, possibilities that pipeline fue S lill also be qu'te expensive,a d broader new i nteres tin conserv 'i of nonrenewab e resources has created renewed interest in Susi na hydro potential. A concentrated effort to develop alter .atives for power generation such as coa l,hydro,and eventually nucl ear power caul d r sIlt in sub- stantial reduction in demand for oil and natural gas.L -J t ".le and large investments required to develop alternativ rei f rce th point that oil and natural gas must supply near futl'r qUlri'lmen <:>. For most smaller power systems,basically no economically asible 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 f els to areas wh re higher prices can be obtained.The present use of oil and natur 1 gas as source of electrical energy is v"able for Alaska;however,a h gher and better future use of these resour es can and,'n all prob- abil ity wi,1 ~be made ," rI V i e~'i 0 limit h us 0 rejec ed. he national efForts to develop energy sources that o and gas for power generation,this alter at"vB was ~uc r Power.f'l use of nuclear power a corrmercial e ec- en rgy urce for tne na i is ex e ted to rea e consider bly -y 1e y ar 1 5,Advers nvironm 1m s re a.s ciated w'th surf c an su surface minin fanium,Clang s in ij1d use,disposal Jf wdste heat,risk 0 cciden~s.and safe storage of ighly radio ct"ve wastes.In spite of th se factors,more than 50 perc nt of the elec- trical ower of the na ion is expected to be genera ed y nuclear power .Y th year 2000.By the end of this century,breed plants,which prod ce additional fUel while they produce power .•wil 9 adually take over larger share of the production of ele tr'c ty.ossibly at some tOme in the next ntury,nuclear fission lalnts and roposed nuclear eed r p an s wi 1 be replaced by nuclear fusion reactors and by central ene tlng stations running on solar power. Nuclear power should be considered a likely long-range source of baseload po-W r for h Railbe t area and is ger;~:>ra1iy considered a 'stant optio because of size of power markets,cost and environm a fa tors,and the availability of fliore favorable coal and hydro alter- natives.The foreseeable future for nuclear power generation in Alaska shou ecome materially more favorable only if there is either a break- throug in costs and technology or significant new development in s all- sized plants. Be ause of the size of power markets,costs,and environment 1 factors,nucl ar power devl?lopment in Alaska -is not considered to be an ttractive a ternative to che per,readily avaiiable power sources du i ng ,i seent ur y. 6.02.5 Geoth rmal.Geothermal resources may eventually provide signrflc nt power generation in Alaska;the Southc tral Railbelt area has substantial geothermal potential (see Figure 11).This source of e ergy is not considered a reasonable short term alternative to other more proven type f power generation,as increased utilization of geothermal resources depends upon additional technological development and econo ics.Geothermal power generation is also considered to be a future suppl nent 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 geother~al 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 is 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 tho 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 a~ter­ 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 harV€5 c, 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. 6.02.11 Hydropower.The reconnaissance report on potential development in the State of Alaska made in 1948 by the U.S.Bureau of Reclamation, included hu dreds of potential power development sites located through- out the five tudy 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 6.03.1 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.Implementation 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 "Lower 48"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 1 0 1 ':e /~.Jr/a~_..:.. CHAKACHAMNA . \ '.'.. SOUTHCENTRAL RAIL8EL T KEY HYDROELECTRIC AND TRAN SM ISS ION ALTERNATIVES , =-~.........2Lf UJ o ~o IOOMUo, FIGURE 13 81 ""he ttemendous financ'al investments,the Lib tantial envi,ronmental impacts,'t imited opportunities for marke ing t e enormous amounts of power,and t e availability of more favorab e,less costly alternatives preclude r cmme ding construction of the Rampart project at this time. Ramp rt Da co 1 be developed if future nationa,l lleeds recommend the project's cons ruction. Another possible locatio for signif"cant er e elopment is Wood Canyon 0 the Copper River.The located about 85 miles above the mouth of the Copper a h Mountains of southcentra Alaska.A "high dam" annual energy of 21.9 111ion ki 0'a.tt-hours.A "low .10.3 bil ion kilowatt-hours of 'rm annual energy. TIle construction of a dam at Wood Canyon would force relocation of two commun'ities and would cre te serious envi onmen 1 problems affec ';9 both f"sh and wildlife values,es ecially to the la . e salon runs on the Copper River.Unless the problem posed 0 migra 'ng salmon could be solved satisfactorily,the p oj ct would have an extremely adverse effect 01'1 the major commerci fishin industry in a wide area of the Gulf of Alaska.This alternat've is 'not considered feasible at this time. 6.03.3 Chdk~cha na Ldke.The possibility of developing hydroelectric power f am Cnakachamna Lake was investigated.The lake is located on the Chakacharnna River which empties into the west id 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 ll-mile tunnel for power generation.The adverse nvironmental impact would be substa ally 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 6~~~Jey Lake.The site fo~this authorized hydroelectric project is at Bradley 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- stal at;n for a Southcentral Railbelt power system.Adverse environ- Iilen 1 impa ts of this proposed project would be relatively minor com- pared to the other hydroelectric development alternatives which were considered..f an economically feasible plan can be developed for Bradley Lake.the project could be integrated with future development of t e Susitna lver 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 ..ould contribute sUbstantially to satisfying the needs of the South- central Railbelt area. 6.04 Alternative Hydroelectric Plans in the Upper Susitna River Basin: 6.04.1 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 dam devel'opment 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.l.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 8l0-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 inu~date 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'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-t n project,therefore less environmental impact on resources affected y +hese facilities. The recreation opportunities would be fewer for the one-dam proposal. The substantia"1 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-Denali project were constructed, it would include Devil Canyon and Watana dams previously de_~ribed,and a 260-foot storage dam at Denali.This three-dam system w ~ld inuhdate approximately 104,550 acres and would take 13 to 17 years to cons~ruct. With a three-dam system,the lOO-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- conal 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 TABLE II DATA ON THE PROPOSED PROJECT AND SELECTED SUSITNA ALTERNATIVES Type Normal Miles of Billion Ki1owatt- of Structural Full Pool Surface Total Storage River Hours of Firm Construction Height Elevation Ll,cres Acre-Feet r nUild~ted Annual Ener Selected Phn: Devil Canyon Concrete,635'1450'7,550 1,050,000 28 thin-arch Wa tana Earthfill 810'2200'43,000 9,400,000 54 Totals ..•.50,550 6.1 Alternatives: Kaiser's High Earthfill 810'1750'24,000 4,700,000 58 (2.6) Dev i1 Canyon Olson Concrete,200'+1020 '1 ,000 83,000 8 co gravity Q')Vee Earthfi 11 455'2300'9,400 920,000 32 Denali Earthfill 260'2535'54,000 3,850,000 34 Totals 8~_,400 5.6 Dev il Canyon Concrete,635'1450'7,550 1,050,000 28 thin-arch Watana Earthfill 810'2200'43,000 9,400,000 54 Denali Ea rthf i 11 260'2535'54,000 3,850,000 34 Totals 104,550 6.8-_.~---"'."" Devil Canyon ------"toncrete,635'1450'7,550 1 ,050,000 28- thin-arch Watana Earthfill 515'1905'-14,000 2,420,000 40 Vee Earthfill 455'2300'9,400 920,000 32 Denali Earthfill 260'2535'54,000 3,850,000 1 To ta 1s 84,950 6.2 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 ,d powerplant and an upstream storage dam and reservoir at Denali. Subsequent development of a four-dam system would include dams ~~Goth 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 ~a;~ 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.Caribou migration routes along the south bank of the Susitna River would a 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 wild lands thdt ~re 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. Denali Dam,with a structural height of 260 feet,would form a 54,OOO-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 DELTA CORRIDOR ALTERNATIVE TRANSMISSION CORRIDORS, •Scale in miles [- o .MATANUSKA /CORRIDOR /~ ·Palmer Ntlnano-3- 50 75 100 125 A.PA 'March 1975---------------Ioo""'----F'i·~G~U~RE~1~4---------.,;..;;;.;,;.:..:....;.;,;.;;,;:.;;.;.;...~~ 89 6.04.8 ~Jr-Dam System.An additional study of a four-JaHi systenl the Corps of Engineers utilizing the Kaiser Devil Canyon igh Dam as the main component in an upper Susitna basin system. This alternative included both the Vee and Denali Dams and a low reregu- 1 ting dam (Olson)just below the confluence of Portage Creek.This four-d m system could provide an estimated 5.6 b~llion kilowatt-hours of firm annual energy. The v Illp cts of this four-am system are a '0 bina io of tho impa s 0;he Kai'r vi Canyon Hi h Dam the Ve nd en-i d m.·s,on a·ow eregulatlng dam downstream from ev'Canyon just below P rtage Creek.The system wo Id in~ndate about 88,250 acr s.One of t mdjo additional impacts wou d include anadromous and re ident ishery i pac s caused by the reregulat'9 dam just below Portage Creek. The plan is not economically feasible. 6.05 Alterna ive Powe Any developm nt of hydroelectric power i the upper SUSl na require development of electric transmission facilities to he Railbelt load centers.In determining the preferred system,the Alaska Power Ad inistration studied all feasible corridors joining the upper Sus·.t ,a comp ex to Anchorage and Fairbanks.The most feasible corridor was selected on the basis 01 cost,reliability,and potential environmental impact;the remaining corridors represent alternatives of varying degrees of feasibility. Four groups of alternatives were considered:first,those that lead from Devil Canyon-Watana to Anchorage via t e 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 alte~native corridor routes were considered.Figure 14 displays these variOUS routes.Susitna I and Nenana 1 are the selected routes. 6.05.1 Alternatives to Susltna 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 Sus~tna 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 l. 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 about 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~'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 1 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 raversed,from a n'tundra to bog an muskeg,Perma- frost can be assumed to be prevale t.or 25 to 30 m'les the corridor runs adjacent to or through the Blair Lake Air Force Range.Habi ats of moose,caribou,an I all sheep are traversed.The following conditions or impacts are of greater magnitude along this corrido than along Nenana 1:Peaty,permafrost soi s are more prev lent and w uld ca se greater probl ms related to access road construction and erosion prevention or control'abo t 90 mor acres of cleari 9 wou1d be r quired;and dis- urbed as loi and alpine tund a woul e very low to recuperate. D 1 sheep nd caribou 'in add'd n to nlOose.would be ls.tur ed by cn uc~ion a 'vity,and most of he c rrfdor wo ld rovlde vehicular ac ess to area now accesslble only by foot.V'ewer cant ct would be rel tively low because of the lso1ation from existing transportation rou es. ana 3.This corridor is 231 miles long.33 miles 1 9 r t n Nenana 1.It is identical to Nenana 1 From Devil C ny to C ntwel, where it then loops ast and north throu tfe Ala ka ange,rejoin'ng Nenana 1 at Healy.\lis s gment is 72 miles long while the co Iparable segment of Nenana 1 is 39 m'es.Terrain along the It rnative segment varies from rolling hills and val.ys to high passes and sharp ridges, the highes of which is about 3,900 feet.The alter ative segment traverses moist and alp~ne 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 ac es ess clearing would be required,and increased access would cause a potential increase in h nting pressure on Dall sheep,caribou and moose.Construction of the transmission )ine within the alternative segment between Cantwell and Healy would be technically difficult and expensive,and t woUld be difficult to maintain.However,since it would not be visib e from existing trans- portation routes,it would have low viewer impact. Nenana 4.This corridor 's 223 miles long,25 miles longer tndn Nenana 1,From Devil Canyon'·eads east an orth tying in a"Hea y to Nenana 1.The length of this separate segment is 126 miles;the comparable segment of Nenana 1 is 101 mile.From Dev'l Canyon,he corridor leads east to Watana Damsite 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,a 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 lo~ge~than Nenana 1.It is totally separate from Nenana 1,being a parallel 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,OOO-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 1 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 Wl predominan 1y ro"/ling hills.Hle corrid r on passing j,st to the west of Slide Mountain,turns west to parallel the Glenn Highway.It cros es over Tahneta Pass into the Matanuska drainage,which it follows to th_flat land at the mouth of the Matanuska Valley.It continues s 'hwest a ong the northern shore of Cook 1 let,traversing considerable amounts f f rest and muskeg as it approaches Point MacKenzie.Perma- rost in th'corridor is continuous from the upper end of \II t2lna r s 'voir to T hneta Pass,discontinuous in t e Upper Ma 'anuska Vlley, and lora c ill ~e lower val ey.cosyst .ms traversed include sp u e- ardwoods an n o;st dra betwee he Wa tan a 51 ~e an L i Ne 1eil \na Ri v r,and 1 J -pruce-rdwoo i the ower val y,Betw~el'l Devil Ca y 1\and t~l L'Ltle Ne ch 'na Riv r the corrido e er l1y run:> betwee carib u ca vi 9 lid wintering'fa ges.Also,some i ering range is traversed a on_the l i tle Nel ina iver a d Glenn Highway to Theta Pas.Some Dal sheep habitat exists in Tahneta Pass an Moose concentrations ar encountered in the Poi t M cKenZle area.Between ~t reservoir and Slide Mountain,the potential for permafrost degradation is very high.Frost heaving in t e poor y drained fin - grained soils would require heavy nlalntenance of bo h 1 ne and acce road.Erosion would contri te sediment to clearwater treams in th area.Eros'ion potential is r--elatively 1mv long the r 13 ,der of the corridor.his route would require approx a ly 750 a res In re c'earing than S sitna--mostly in the lower Matanusk Valley.Moose wo ld gen- erally enefit from clearing.whereas caribou range would su~fer loss. Lake Louis and some other igh recreational use areas would e impacted upon.In reased access would be provided to areas north of the Glenn Highway.The scenic quality along the highway wou generally be lowered,since concealment of the line would be a problem along most of its route. M u ka 2.Alternative corridor Matanuska 2 is 385 miles long, 120 miles longer than Matanuska 1 and 249 mil'es 1 ng r than Susitna 1, From Watana Damsite it loops much further to the east han Matanuskd 1, rejoini 9 it at Sl'de 'Mountain.This segm,ent of Mataouska 1 is 217 miles ong.vers s 97 mi es f r the comparable segment of Matanuska 2. rOt Watana Damsite the corridor crosses the Susitna River and leads northeast toward Butte Creek and the Denali Highway,which it parallels to Paxson.Here it turns south,paralleling le Richardson Highway and t~e Aleyska Pipeline to lennallen.From Glenallen it paralle e Glenn Highway up the valley of the Tazlina River to Slide Mountair and t june ion with Matanuska 1.0 of the corridor traverses flat terrain.Highest point on the corridor is a plateau of about 4,000 feet elevation in the Tangle Lakes -Rock Creek area between the Macla~en River and Paxson.This area is poorly drained and covered with post- glaci 1 feat res such as eskers and terminal moraines,and many sma 1 akes.Permafrost is prevalent.The predom nant ecosystem is moist tundra.From Paxson to Slide M ntain the corri or lies within the Copper River lowlands,a basin underlain by nearly 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 l.D 0'> .... .. Denali Highway bridge across upper Susitna River.This area would have been inundated by 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"(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. ShOl'.the system last this long,or for any number of rlo s !'L b m E inoperdtive at an earlier date (an example would be develo nent of more desirable alternative sources of electrical power),many of the resou : s described above in Sections 4 and 5 would have been,for all practical purposes,committed to permanent foreclosure of opt ions for a lterna.ti vn future uses. In this sense,the long-term productivity of the directly.fr :ted environment will have been sacrificed or a shorter-term alternJtive 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 will have less lengthy 'Hlpact 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 woul d,to varyi ng degrees,be "impri nted"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 mi~.~,I VERY HIGH POTENTIAc-- ~~.....I HIGH POTENTIAL FI GURE 15 98 POTENTIAL MI N'ERAL DEVELOPMENT AREA , SCALE. ~'2o,0 100 ..,;,., A.P.A.-JULY 1'375 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 t~2 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 mining 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 "whitewater"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 . .04.1 Fuel R guireme~~.Significant amounts of fuel oils and gasoline or use n transportation and construction activities related to project construction would be irretrievably committed. 8.04.2 Manpower.Manpower resources during the construction and operation phases of th project would be irretrievably committed.The major"jty of these man-flo rs would be COHilli ed over a la-year pe~"od. depe,d"ng or the final deve opment program. 8.04.3 M teriai.All the material used in project-re ated L nstruction would cons itlJ -an irretr"evable commitment of resources,as his rna rial w u1d not be available for other u es.Some amount-of I a e nl lIlight be sa vaged if the facilities were removed at some later da'e. 8.04.4 La d..!y land committed to project develop ent such as reser- voir impoun ment areas,damsites,roads,etc.,would be unavailable for other than project-related uses un'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 he .-in Anchorage on 30 April 1974 to discuss the study with intereste e~viron­ 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 tn 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~~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 Commission,and suggested public hearings on the Fi na 1 Env i ronmenta 1 Impact Sta tement. 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 environmentdi information.Expressed concerns included the inundation of a scenic,whi ~e-wat€'r river,location of the project Gitea too close to a proposed Tal eetna State Park,too much human use in the are. ~mpacts on moose habitat and downstream salmon runs,differences reflected in the 1960 and 1975 cost es ·mates,the low interest rate used in computing project benefits,who would operate the dams and sell th power,reservoir siltation,turbi i y,fluctuations in stream flows impacts on permafrost,the possibility of earthquakes,the format'on of frazil ice,the geology of the area,benefits claimed for flood contro J the location of transmission corridors and construction of transmission Liles,land status,impacts upon population growth,recreational deve 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. 102 SELECTED BIBLIOGRAPHY Dames &Moore Consulting Engineers.Subsurface Geophysical Exploration for Proposed Watana D~~site.Anchorage:U.S.Army Corps of Engineers,Alaska District.1975 Federal Energy Administration.PrQject Independence.A ma re~ort, summary,seven task force reports and the Draft Environment","1 Impact Statement.1974 Federal Power Commission.Advisory Committee reports,1974 Alaska Power Survey (with 1975 update): Report of ~he Executive Ady_~~r1 Committee.December 1974 Economic Analysis and Lo?~£rQjections.May 1974 Resources and Electric Power Generation.May 1974 CoordinatedSySter;l~veTOpment and Interconnection.December 1974 Environmental Considerations and Consumer Affairs.May 1974 Geen,Gl en H."Eco 1og i ca 1 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 R"eS·ources.U.~Army Corps of Engineers,Alaska District:1975 Kellerhals,Rolf,and Don Gill."Observed 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 ArBS meeting at Arizona State University, Tempe,Ari zona.17 June 1975 State of Alaska,Department of Fish and Game.Alaska's Wildlife and Habi ta t.January 1973 Alaska 1973 Catch and Production Commercial Fishery Statistics. Statistical Leaflet No.26. Various letters,review comments and reports.----- 103 __----,------:'~An A_ssessment Study of !:b.-Anadromous Fish Populations in ~1!P2~,t Susitna Y.Jatershed etweeQ.Devi 1 Canyon and the Ch lit a River,by Bruce M.Barrett.1974 __,,--__S~1974 lioose P~!.t rition Counts of!tL rORosed Devil ~an on 0 Are,by Donald Calkins.1974 State ()Ala ka~Division of Parks.'eritage Resources Alon the er S $1tn~Biver.August 1975 State of AI,sk ,J int Federa -State land.U~e Plann:n Commission for Alaska and h L~iversity of Alaska.Coordinated by Lidia L. Selkreg9.A ska Re ional Profiles -Southcentral Region.1974 U.S.D par en of the Army,Corps of Engineers.A~in the viranrnenta1 pa ts of Water Projects.Prepare y Institute of vI ter Resources.-March~3- U.S.Departm.t of the Army,Corps of Engineers,North Pacific Division. ~Compend .urn on th,R ?uc_~_e~,of parage of Small .E.i.sb.Through lu~~~.May 1967 (OUt of pr~nt U.S.Department of the Army,Corps of Engineers,Alaska District. 6..Re art .Q.Q.U Ram art Canyon Project,Yukon Basin,Alaska.1971 f shore Oil,and Gas Development ~C~ok ~l~~,Alaska - Environmental Impact Statement.September 1974 Southcentral Railbelt Area,Alaska,Interim FeasibLLi!l----~R~e-Q-o-rt -Hydroelectric Power and Related Pu poses for the Upper Su itna Rive!B sin,with technical appendices.December 1975 U.S.Department of Commerce,National Marine Fisheries Service.A .1lydrological Reconnaissance of the Susitna River Below Devil Can on Dam.October 1974 U.S.Department of the Interior.Alaska Natural Resources and the Ram art Project.June 1967 ___-::?"'_.."P Idska Power Administration.Devil Canyon Status .R.eport. r"1ay 1974 of Land Management.Multimodal Tran.sportation and in Alaska - A Preliminary Conceptua--l-- 104 ~Bureau of Reclamation.Potential Development of Water Resources ~the Susitn~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 Fish and Wildlife Service.-----,.--=-and Other Raptors ~the Proposed -----'-__.-.L--'-__t Areas. Fish and Wildlife Service,Bureau of Sport Fisheries and Wildlife.Threatened Wildlife of the United States Resource Publication No.114.Washington:1973 ____~--~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) Es 'mated Va ue of Public Domain (Land transferred wit lOut Cost) Average Ann~dl Cost Average Annual Bene.fits Power (Includes Transmission Line Intertie) Recreation Flood Control Area Redevelopment Net Annual Benefits Benefit to Cost Ratio 106 $1,520,000,000 $11 ,800,00 $104,020.00 $137,876,00 $128,153,0 a $300,00 $50,0 a $9,373,000 $33,856,000 1 .3 to 1 PROPOSED TRA S N LiNE CORRIDOR (Ph to courte-sy of A ska PQW&Adrn"nistr tion) Lower Susitna River Valley.This area is charac- terized by extensive muskegs,intermingled with bottomland spruce-poplar forests.Pennafrost is absent or discontinuous in this area,although the soils are generally poorly drained. Susitna River Valley,Lakes are prevalent and assoc- iated with muskegs,\.;hich 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. \ l!, Town of Talkeetna.This town is at the confluence of the Talkeetna, Susitna,and Chulitna 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 foregrOlmd and upland spruce-harch"rood in back- ground.Black spruce in foreground are associated with poorly drain- ed soils and/or shall~",permafrost tables. ~ '~, Near Honolulu on the i\nchorage-Fai rbanks Highway.Biomes shown on Imv brush muskeg in foregrmmd and upland spruce-harchvood in back- ground.Black spruce in foregrolffid are associated with poorly drain- ed soils and/or shallmv permafrost tables. \. !J Alaska Range from Anchorage-Fairbanr..s Highway near Broad Pass,late spring.Vegetation biome is lowland spruce-hardwood.Soils here are basically glacial deposits. Looking south along Nenana River to Upper Nenana Canyon.The AndlOrage-Fairbanks Highway parallels the left bank.Mount McKinley 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 McKinley National Park. TIle 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-hardwood,and bottomland spruce-poplar.The dark forests are mainly black spruce.The sinuous li~lter 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. COMMENT A,0 RE.SPO 107 1- e .5 u. o. Dvlpmn 13 102-1 104-lOB 9 Engin Ag ncy lower COTIml ionFe 1 B UNITED STATES DEPARTMENT OF AGRICULTURE SOIL CONSERVATION SERVICE 204 East 5th Avenue.Room 217.Anchorage,Alaska 99501 December 2,1975 Charles A.Debe1ius Colonel.Corps of Engineers District Engineer Alaska District l Corps of Engineers P.O.Box 7002 Anchorage,Alaska 99510 Dear Colonel Debelius: We have reviewed the draft environmental 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 The statement represents considerable effort in 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 succeed mUSkegs,is erroneous.The absence of soils information at the dam site or in the transmission corridors is a serious deficiency of the statement. This discussion of "adverse environmental eff~cts which cannot be avoided"I i notes the need for temporary and permanent facilities for project workers. II We,suggest that a soil survey.and the interpretations therein should be useful in locating facilities on suitable soils. ~ t09 4 her es A.Debelius 12-2-15 ~e appreciate the opportunity to comment. Sincerely, /C-/lj y x e ,z{f'(";:;7~)/~ 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 Conservation1st,SCS,Fairbanks,Alaska 110. 2 I RESPONSE TO COMMENTS BY U.S.DEPARTMENT OF AGRICULTURE SOIL CONSERVATION SERVICE 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 soils 'l 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 . jL Comment noted. 2 .-,~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 of soils,and other relevant factors. 111 UNITED STATES DEPARTMENT OF COMMERCE The Assistant Secretary for Science and Technology Washington,D.C.20230 November 25,1975 Colonel A.Debelius D·r:t ~ngineer -Alaska District rps of gineers U.S.D'partment of the Army P O.7002 A chorage,Alaska 99510 Dear Colonel Debelius: This is in reference to your draft environmental impact statement entit,led "Hydroelectric Power Development)Upper Susitna River Basin,Southcentral Railbelt Area,Alaska". In order to expedite transmittal of the enclosed comments from the National Oceanic and Atmospheric Administration, e re sending them to you as they were received in this off ceo Thank you for g~vlng us an opportunity to provide these co ents,which we hope will be of assistance to you.We wul appreciate receiving eight (8)copies of the final statement. Si cer ly, C?i~~~ . D ty Assist nt Secretary "or Env~r nmental Affairs Enclosures:Memo from NOAA -National Marine Fisheries Service Memo from NOAA National Ocean Survey Memo from NOAA National Weather Service -!, 112 Date I. u.s.D£PAHTMENT OF COMMERCE flJational Oceanic and Atmospheric Administration Reply to Attn.of:W2x2//\Io To From SubJect: ) Dr.William Aron Director,Office of Ecology and Environmental Conservation (EE) U;~-~·_..LI I ~~i':"'~LD BY Dr.George P.Cressman Ie i;.ji,.•.L:':"tN. Director,Natioual Weather Service (W) DElS 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 facilitIes will impact upon the public river and flood forecast warning service provided by the National Weather Service in this basin o These services emanate from NWS offices at Anchorage and Fairbanks as described in the enclosures.This should be made a part of the EIS. 'Encl. 113 1. .{~~,':~tioncl 1Jc~cr.ic en:!At:71,JS:;J:J2:"'lc 1'\-:I:nin'ist,ri!tior.(t:C,'\.;)nJi:.iona1·!':~athei S~r':'ic~~rO'/jc2S f1co:l ;'OI~:t~st~~Ci-S~l"·.'jc~fer r;;,lj~l:"I-i'/(::;-.LJ.si:l~.This S.y:::t2.~1:;'.'·:->:','2;picdict~'J.~::;clT 2ntic·ipJL.L.J St·~J2:'~t do p.:~rtjCl!1cr ~~~~~cr: S)S:~$in t;'l~~~~!si;j ..,'(:~J2 fG,....~~c·.~sts.:·:~~c·b=~:.;·:~~~CJ:'l ()0~2r·j(:~':"~"I~C!P~~I~t~o,~ :.r.ri rt"""1:"'l;·-••~'11""'\-..,···-,-'J:r.\--,....;".·.::,-;-···"i '-''':'l~~'''''r Cf'--':~:·!-'':o"....--..r:'c.:._'>_'...\",'_.'i,......_:J..:l '_.";';1 t"I .~~__t.~~;,-••J:':''-_",••'~:.L ..f....J.,JI'_''I~_:r;e ;'la.::d. fcrec.::si:.is tr~ns~i:tec to City or-riciah,n~"~$pc'p~rs)~i1d rt:dio une:tele- 'vis~.o:1 ste.tiO~5 ·ir:the bJsir:.These r.12dia C:iss2r.;ir:~te erie infc;i";l~tion to residents of the.flood pl~in in th~form.of a flocd warning.This timely, forew~rni~g p~rmits protective measures to be'und~rt~k2n by i~dustrial plants pUDiic utilitie5)r.iun'icipa1.officials,and indi'liduals '..lith prc~e';"ty in the • 10'tllar.ds.,S2r~'ices '::'Jaililble ~re of th~·folim.,lir.g typ~s~ Fl~sh Flood:The resconsibl'e Weath~~Servic~forecast Office5~p~lic~~th~:"forp.~Jsts t·.,lic~daily fc:'"th~Sta,te.In additicn ';:'0 t;:~routine forCC.J~t~.special furecast:;of severe storms and ge(le("'~1 fli1sh flood \'12tch~5 for sr.lall strci!r.lS 'are issued as reqlJired. t·/SR-57 !-lea the'"?~dilr'i nstalla tions hwe capabi 1 i ty for ir.::n2diate det~ction and evaluation of rainful1 int~nsity,l'oc~tioi1,cr:d stO':""l':1 mO'/E:il1?flt ...Informat.ion is pronptly r~layed by teletYPc'circuits·2nd telephone to ne\>/5 m~di2 ar.1 ccr.:mur:ity officials and la·...enforcement:' • <:lgencies.Th~\'leather Service Office'··issues flash Flood Harnir:gs ·as required for sm~ll strecms in its an~a of responsibility_.,. . 2.'~l~jor Floads:River st~ge forecasts are based on radar coverage> repolts "frc:Il rive'r 2nd rcinfal1 reporting .stations ~nd telem~tiY in ,.or nearithe basin'....The River Fm'eC;4~t ,Centers (lre staffed \'lith professic~al hydrologists responsible for the preparation of river ,.f ccasts b~sed ·on \·/.:iter equivalent of sr.9',-l co'/~'r,r~inf<111-'runoff r 1 tions,streamflo'../routing)and (l \·/or:':lng :<nm-lledge of 2nticipated w~ath2~conditions.The lead time betw22n distributicn of the fore- casts aT1d the flood crest may be 5hoi~t;ho~':elJe·r,lead tir:Jc nOriilally ranges from 12 hours for rainf<lll and up ,to s~vera1·\'/2.eks for-sno'llJilelt. Specific crest forecasts are issued as required~River District . Offices are responsible for the interpr~tutio~and distribution of flood f,orecasts and the 0p2ra tion..of the hydrologi C:reporting sub- station net\,/ork in its area of responsibility. ... 3.Hydrocl j:7:atic Data:l'~ost of the data.from the network is published. These records provide the basis for forecasts as well as for the p12r.:l'!~9 an,-!design of protective \':orks and their o·peratian during f1 ~~s_River and flood forecasting is fu~dzm~ntal in the ~esign, and esse~ti~l in the ope~at1on of a ~evee 0:'"re~ervoir system. .' 114 RESPONSE TO COMMENTS BY U.S.DEPARTMENT OF COMMERCE NATIONAL WtATHER SERVICE ~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. Cressman1s letter,is reproduced in the EIS. 115 TO:Or.William Aron Director Office of Ecology and Environmental Conservation Dr.Gordon L111 (signed)GO Deputy D1 rector RDON LILt National Ocean Survey C52/JLR SUBJECT:DEIS #7509.61 -Upper Susitna River Basin South Central Railbelt Area,Alaska Til·su··t statement has been reviewed within the areas of NOS responsibility and expertise,and in tenns of the impact of the proposed action on ~WS 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 d s ur 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 p,e t includes the cost of any relocation required for these monuments. • 116 RESPONSE TO COMMENTS BY U.S.DEPARTMENT OF COMMERCE NATIONAL OCEAN SURVEY E;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. 117 u.s.DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration NATIONAL MARINE FISHERIES SERVICE P.O.BOX 1668 -JUNEAU.ALASKA 99801 November 19,1975 Colonel Charles A.Oebelius District Engineer Alaska District,Corps of Engineers P.O.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 corrunents 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,consol idated views of the Department should reach you shortly. Sincerely, ~~l-/(/ILu:I~ctHarryL.Ri etze Director,Alaska Region Enclosure its Date November 19,1975 U.S.~H:i:;),.'~HrMEN:'"C~CwMh4k:t:iCE Ns~i",r.al i:;1:3anic ijnd A~mQ:sp:utricAdmininraticn !Jrt./.irJr!tJl /.!uP?:nt';Fi:;;lfn"/~:?:';.~·e('7.)ice I'.G.jy./x lCC8~JL-:n~o:u,AlasY..Q 99802 Reply to Attn.of:FAK/RJMJ To Director,Office of Ecology &Environmental Conservation,EE Thru:Associate Director[forf,Refour7~Ma~agement,F3 From J1J:larry L.Rietze ;;j-~:J-/H~1 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 approximately 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.l/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 t3 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. 1/ ". 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 • . .a Ji.1.:J Spec;f j <:CommeHL~;__----- 4.0 4.02 Environmental Impacts of the Proposed Action Fish 10 Page 49,paragraph 7.We 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 statemen~regarding the elimination of salmon egg destruction should be qualified by noting that it is based on an inconclusive single-year observation.~/ Page 50,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. Page 50,last earagraph.This paragraph should be written to qualify the status of future fisheries studies noted.The Corps of EngineersjJLasnoassurancethatanyproposedfishandwildlifestudieswillbe funded or carried out in time to be of value in making any feasible project modifications. 6.0 Alternatives to the Proposed Action 6.02 Alternative Sources of Power 6.02.3 Oil and Natural Gas Pa&e 72.Because the proposed El Paso Alaska natural gas line could be "lconstructed to bring fuel from the known Prudhoe Bay field to the ~~Anchorage-Fairbanks area,it should be g~ven consideration as a possible alternative source of power. We would appreciate reeeiving two copies of the final environmental' impact statement. l/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 .'1"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 DEPARTMENT OF HOUSING AND URBAN OEVELOPMENT ARCADE PLAZA flUIL01NG.lJ21 SECOND AVrNIJr SEATTLE,WASHINGTON 98101 R EGlON X Office of Community Planning &Development IN REPL.Y REI laD Charles A.Debelius Colonel,Corps of Engineers Alaska District Corps of Engineers PO Box 7002 AnchoFage,AK 99510 Dear Colonel Debelius: Subject:Draft Environmental Impact Statement 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. Tbanks for the opportunity to review your statement. Sincere~~/I """~l ,,/fl'~\).I /'/f ~~!'.)<1{~~t~ (~ert 'c.Sc l~a Regional Administrator RESPONSE TO COMMENTS BY U.S.DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT J..J Comment noted. 1:'\~l-:PL y kEF-~.K TO: 700 United States Department of the Interi0r ALASKA POWER ADMINISTRATION P O.BOX 50 JUNEAU,ALASKA 99802 December I,1975 I 14 15 16 Colonel Charles Debelius District Engineer Corps of Engineers Bpx 7002 Anchorage,AI<99510 Dear Colonel Debelius: The Interior Department,Office of Environmental Project Review,requested that we furnish you comments on your draft EIS,IIHydroelectric Develop- ment,Upper Susitna River Basin,Southcentral Railbelt Area,Alaska.11 General Comments We believe the draft statement does not provide adequate information on the proposed project transmission system,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's Environ- mental Assessment of the project transmission system. 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 I a more complete citation of data sources is needed. 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, II A Detailed Report on the Fish and Wildlife Resources Affected by the Vee Project,Alaska ll ).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 S usitna basin. .1.2,1 Save Energy and You Serve America! 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 AP A 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 }-eports.and the June 1967 Interior Department report,It Alaska Natural Resources and the Rampart Project,II provide a great deal of further definition of these resources. """::L{ 20 21 3 We believe these more recent studies should be referenced as the basis for selecting 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 finding is premised on unreasonably conser- vative evaluations of costs involved in the Denali Dam.As indicated in the "General Comments,II we believe the Denali Dam may ultimately prove to be a desirable future addition to the proposed Watana-Denali Canyon Plan,considering need for winter energy,environmental aspects,and available alternatives. Sincerely yours, ~1,Vd:~~-~ Robert J.Cross Acting Administrator Enclosure cc:Office of Environmental Project Review I U.:,_:- ~. ·r 1875 -Brigham Young University Centennial-1975 July 14,1975 ~Ir.Me 1vin Monson U.S.Fish and Wildlife Service 813 liD"Street Anchorage,Alas~a 99501 Dear Melvin: 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 findings.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-Fairoanks,Fairbanks-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 traverse 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 r.airbanks to Big Delta.There are several 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 Highway in the area of the Healy-Cant\\ell 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. 121(1 Department of Zoology,575 WIOB,Brigham Young University,Provo,Utah 84602 (801)374·1211,Extension 2006 Mr.Melvin Monson Page Two July 14,1975 The ·only conceivable area.then.of impact witn 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. Sincerely. Cl~~~ Associate Professor of Zoology mp ...,:~)..JL""".~ • 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 Susitna 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. 1 7 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. 18 Comment rioted. 19 Comment noted.Referred letter is included in the EIS as an attachment to APAls letter. 2UComments noted. 21 Comment noted.See response number 17. 129 DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION ALASKAN REGION 632 SIXTH AVENUE ANCHORAGE,ALASKA 99501 TELEPHONE 272-5561 OCT 30 1975 22 23 24 Colonel Charles A.Debelius District Engineer Department of the Army Alaska District Corp of Engineers P.O.Box 7002 Anchorage,M(99510 Dear Colonel Debelius: We have completed our review of the draft EIS on the Hydroelectric Power Development for the Upper Susitna River Basin South central Railbelt Area. The following comments are offered for your consideration as you prepare your final EIS. We recommend using the word "airplane"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. 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 he1ipads 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, -, 130 RESPONSE TO COMMENTS BY U.S.DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMI~ISTRATION AlASKA~REGION ~.r~The suggested change has been made in the appropriate section in{dr""! the Sta tement. Section 4.10 has been revised to indicate that any helipads constructed waul d be of a temporary nature and woul d be rehabil itated when no longer needed. ...~~.~Section 4.10 has been revised to discuss the need for facilities to provide for air evacuation of injured personnel. J31 United States Department of the Interior FISH AND WILDLIFE SERVICE ALASKA AREA OFfiCE 813 D STREET ANCHORAGE,ALASKA 99501 ~ov 1'~'~175 •Co]on0.1 (;hnr1.('s A.D0.I )eb.llS District ~n~in~er,(;()r~s of En~ineer9 AJ.r~l~1l n strict P.o.no.:7002 Anchor,qn.e,11:.:99')10 lJr!,Ct"S\tsi.tn,'!Hyrlrnele~td.c Power Development ER 75/942 NPAEN-PR-F.N 25 26 f)0f1r (;o]one]J)chelil1S: The J\J:"lf;l:f1 Ar~n of the U.S.n.sh nnrl IHlrl1iFt Servi("~h,1R the follO\-lin~ com~cnts to oEfet"on this envtronment~1 st~tement. He re"'ret thnt thc>r<:HM;no "'cnet'Cll rlisc\lssi.on i.nc:lurkcl on nossihlc ritipatina. measures to he cmnloyerl in the ~roj0.ct.We unrlct"stancl that ~etail~d sturlies \',"rlert,1~<en h;,thf'(rorn"lAter in the I1l1thoriza[jon nrorCRR ~'ri 11 nrov;rie the h,1r.0.S nn Hhic:h ~it:in..:'1t:in"MC,1811rf>S will he d0V('l()p~r1;hoocv0.r,:'1 ~,cnpr<11 outlin0 nf !'In!';'dh10 nI.1('>l.1nrtltin"I'1C,1SlITC'f],1t this nn;nt \H)ll1r1 l~e inF()r~~t;v('. LOR";of h.11dtl1t,fnr cy'<1T"nlc,m;"'ht h~miti~.l1tc<i hy !'l.('.<;lJisi.tin"or "r.()tp.~ti()n nf Aini1~r ~~r~n~~rlqcwh~re.Anticipntcn h~RVY \150 hy rccreRti()ni~ts mi~ht h0..:'111 (>vi :'\1:<>0 hy r1.1'-'i Tln;acc:ess t"<1:'lns 1'10 AS to di ~COl1rCl",e s\1ch use or.hy ORV rf'~1l1oti ons enFnTcecl hy the l:lnr1-ml1n;):'.i.n.~l1~enry.An outl ine prescntFltion 1'I\Ich 11:'this \'70uJrI ....1~l1r1y dcmnn,ql'r:ltc the forcthOll.a,ht r,ivf>n thi.s ~\lhject hy th~(OTre;',r!tholJt refJuirin::,netai 1 Hhich is unF.lvllll .qhle yet. We Rre r10I1s~r1 to note that cnnsirlcration will be ~iven to improvin~fish acce~s to and from some of the sloup.hs and tributaries dm-mstrcam from Devil Canyon.We are also 'pleased that the results of onr,oinr,studies Imder the direction of the Fish and Wilrllife Scrvi.ce wi]1 he used durinr, the fi.nnl dcsi~n ph"sc st\ldics for feasihle project moclificl1t1.on and rnitir.atin,~measures.' SPP:CTfIC SUI11"1V1TV,38 {Inn fll1:'.C 53,por.'l.3 ..the present document tcnrls to minimize i.mpActs to moose h.::lbitnt.Especially on par,e 53,the ~ffectA of the loss of 1:'008e hAbitat should he descriherl in detnil Jlnd thete-rl"1s "nt"eferred" Inne1 "c t"iticeJ."defined.The number of acres to be in\lndl'lted and secondary I<'c\v<.>rse effects,if any,shollld be discussed.A smt'll!loss of habitat may not ~nnGar to be si~nificant when assessed alone.but when added with all CONSERVI!!h .d 1 .f .i 1 . h 1 b'ftAM~ICA'8 t e state'H e osses 0 Slm ar sl?:e,t e oss may e slgn cant. I!!NeReV . Save Energy and You Serve America! Pa~e 23,fll1rR.3 -Otl~nirds.The stctter,lcnt ItSo~~c jncincntal huntinr, takes plFlce £lIon."',the Denali Hir,h,vay"is misleadin:;,thou~h this is presumahly a reference to r,ame bird huntinr._Huntin~pressure ~cnerally is ~eavy alon~ the Denali llip,hway anc!this statement needs to tie more closely ,"lith bird hLlnti.n~only. PRr,e 37.first para.-Other"For!~of Tr~~[)or..!::::,...s_.i..?.22..The state~ent concernin~ shallow-draft river boats,small boats,canoes,rubbcr rafts ctnd kaya!,s needs cXflandinr.,since La',cs Louisc,Susitna,Tyone anc!the Tyone ~iver cor,nlex in the Uflfler -Susitna drain.'l"e receive heavy bOatin"nne.floatplane\J~C by hunters and fishcrmcn!from the Glennallen nnd !\nchorar.c o.rea. Pa:""e Lf~;,narn.3 -The t>tntcr.-:cnt "•••and e rlinimnl <lI:1ount of resident fi9h hahitat at the mouths of a fm:of the tributnri.cs that enter the Susitna :1iv<!r in the 2G-r:1ile scction of the proposed damsite"shouln be e:<flamled to identi fy how many tri lmtaries cnter the Sus!tnll rUVE>.r in the nffected reRch of d.ver -"nn to il1 Reuss .more fully the "minir:1al fish hAh1tllt". Ii-·S'"1<.;. I~9 P.""C'I~,o"nnrA.5 -1'his :>ara~r"T'h,"hOlllcl he eX!'1n.nr1eil to ir.,lt·('1e t.he AntiCif.l<lteCl.1 ntlr:1hcr 0 f "r <lrc oee:as ions"ul-lcn exc:e s s \'1;1 ter wO')1 n he cl i vertccl ov~r the ~~fllwn1,the cli~f\ti~or en~jne~rin~fActoTs ~rp.ci~ltntin~these occ~Rions, llnn the rl~nr"e of si~nlf4C:Ant Rdverse jrnpllcts on fish nno ve"ctntion. PI1'>C !Ir'"pn"".<t.f,-TiltS ·T):)r ..~~r.'T)h Aho"Jd A1")('cify t,hr-f1.\".rI'lA of ~f)O~('hrthftAt inllnnntNi ,1nd its fTJ1n.'"lrtnnc:c to mOO[lc.T.11C~wiAP.,the fish h:1hitl11:innnnatec1 5ho1110 hI'c1CAcrihcn in nreat.er oCUlil.!Tou mllch fi.<:h h"'lh1t:1\t".vo'5l1 he i nunrl:ltl'cl ::\nr!"lh,'lt s~eci~s '''i 11 he llffectcn?Hhnt t~rnc"o,f HAh hnbi tttt wi.ll he cre"tecl at hir-her elevllti.ons line:!what S'nedes .?re cxrectc(l to use the ttnewll h ahi tilt? Pn,n('5),If\st p"rl1.-\.J'e tlU"'"('!"t:sl1~stit\ltion of thp."1{);-n "fr.,"iJc"for the \'10rrl "s1Mn le"in the ~tlltemp.nt,"H""w~vnr,the 1l<:t1Fltfc fnor!\"h.,1n in thn tai.,tt.tl Chore':ll forest).1"0 t\mnr;l i s (!xtrern~ly f'linple,,1nn ns ;]rC'~=nl1 t,(Hsn'~tion of hnh{t~t for nne ~n~ctes ~t11t"of ton tnr!ire~tly nffec:ts MAny oth~r s~ecins.I' P.,,,:~~3,~,'lrFl.3 -".\1thol1"'h {"'loose h",hlt"lt noes e}~ist Hithin the pool are<'lS of the pl"o!"osecl Devil C'nnyon nnd Hatnna reservoirs,the over;"!1 J loss of orl'f(>rrorl or (".r1 ti.r:Al ",inter forn.,"',e nrel1:":'",o\llrl aff('(·t.hu~""SMl'lll nerr:entR"'e ;"f the lJnoC'r ,')t1S i tnn rr-oose nonulat fan ...II (emphns i.s arlded).--!.[~i0"r.-;:)tlleI ieve thc-;C-i;-'s~fi.cient informatf~n avnUable tlt t1119 ti.me on the Upper Susitnl1. moose PO!'llllCltfon to clltc~ori(',l\lly ilnply on1 v a srnnJ I ncrr:cntl)~C of !noose will he nffected.Antir:innteo studl(>~hy the Fi~h nncl Wil~life Service in cooncrntion Hi th the IIlflS'<:l J)cp.1rtmcnt of Ffsh l1ne!Glmc should nrovinc the nC'cded tnformntion for n clctcr~fnntinn within the n0xt fnur venrs. I ~3 Pa"'fl 61~,nnt'.'l.1-the h.'"lck°.T.'O\mn e!ntR sllnT}ortin~the psscrtion that ler.~e I bloc:ks of excess pm"er wi 11 not he created hy the pro tect should he presenten. Ohvio\lsl?,the impact on the State of Alaska would be profOtmd .nnd lon:,.-lastin~...~~ if a ll1r~.e surplus of pmvcr beC8r.1C eva!lahle and industrirtl development were uJ s tir:mlated by this.Since this'10101lld be ViCHCd by many as an adverse impact, or at the least a secondary impact of ma~nitude,i~~hould be explored here., Th;\n 1(V()\l for the o:"lnnrtuni ty to rcv'i.cH tid s r1r,'"\f't ~t.:t('n~er\t.As <tn 1I;>.cncv with snccific rcsnon8ihilities rel~ted to the project,the Fish and Wildlife Service lookr.fonTD.nl to rcvic~'1inr,the other documents as the pro;cct f,oes throllr,h its Authorization procedure nn(\offers to assist <'It any tise. 134 RESPONSE TO COMMENTS BY U.S.DEPARTMENT OF THE INTERIOR FISH AND WILDLIFE SERVICE ~,~;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:"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."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. (~,·3 Commen t noted. True,past fish and wildlife reports generally discounted moose habitat in Devil Canyon and showed comparatively low moose popula- tions in the Watana reservoir area.A definition of "preferred" and "critical"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. >.<]The words "game bird"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. 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. 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.'~"'~) - 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 p~anning.These studies will 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 J 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. 33 We disagree.Admittedly,the taiga and'tundra are "fragile"ecosys- tems.However,an ecosystem could be fragile and still 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. 34 Comment noted,but past studies indicate low numbers of moose are found within the proposed reservoir areas. 35 See response number 255. 136 United States Department of the Interior GEOLOGICAL SURVEY RESTON,VIRGINIA 22092 f)YF,r.:a 0'TH'.OI~F.C I OJ{ ER-75/942 Colonel Charles A.Debelius Alaska District,Corps of Engineers P.O.Bo)(7002 Anchorag~,Alaska 99510 Dear Colonel Debelius: NOV 1 7 1975 We hav~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,includin~permafrost conditions,and related impacts.Much pertinent information can be found in a recent Geological Survey report,"Prdiminary geologic and seismic evaluation of the proposed Devil Canyon and Watana Reservoir areas Susitna River,Alaska,lI 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 describ~d as being underlain by granitic rock which has intruded the Cretaceous argillite and graywacke. In discussing potentl.'al geologic and seismic hazards to the project, the Survey ro-:port states that "One must assume that the proposed Devil Canyon and Watnna Reservoirs could be subject~d to carthq~ake generated 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 event these sediments may slide and generate waves in th..: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! of damag~by seiches that might develop in th~r~servoirs durinR earthquak~s has been briefly discussed (p.14-15).Possibl~hazards of earthquakes induced by reservoir filling have also been discuss~d (p.15-16).It is concluded that all of the foregoing possible hazards should be carefully assessed in the siting and design of the prop09~d dams (p.17).Recommendations are presented for geologic and geophysical studies (p.18-19;p.21-24). 36 ER-75/942 2 II 40 37 38 39 Daily fluctuations of up to two feet in the river below the proposed Devills Canyon dam are compared to the natural fluctuations of about one foot (p.46, par.5).However,th~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 thes~should be discussed in the final statement. The spillway design it 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 ~are 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 8S estimates of extent of the resulting effects. The occurrence of ground-water resources in the project area is not address~d in the environmental statement,although bits of information on geology (p.14-15)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.Although 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 developmenl 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, 'Aot1.0S ~ .d-~~l~O~4)'}r;ctor . ,,'.-:;:)~..,)0 RESPONSE TO COMMENTS BY U.S.DEPAlnMENT OF TilL INTLRlOR 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 \'/i11 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,f. studies conducted by the Missouri River Division,Corps of Engineers. have found that stage increases of up to 7 feet at moderate rate I can be tolerated without premature breakup.A 7-foot fluctuation ( is far in excess of the maximum stage increases anticipated for the proposed hydro projects . ..8'>-c.....,.This paragraph has been expanded on page 48 of the EIS. frequency is approximately once every 50 years. The spill B~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.O.Box 3-8000 Juneau,Alaska 99802 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 , and easy to follow through.There appear to be provisions made to avoid 11JL any future land conflicts under the Alaska Native Claims Settlement Act.. Specific Comments: We have no further comments. 141 Z~~Comments noted. RESPONSE TO COMMENTS BY U.S.DEPARTMENT OF THE INTERIOR BUREAU OF INDIAN AFFAIRS .',.') ...A.."~rJ II United States Department of the Interior BUREAU OF LAND MANAGEMENT State Office 555 Cordova Street Anchorage,Alaska 99501 IN REPL Y REFER TO. 1792.5 (911) Colonel Charles A.Debelius District Engineer Corps of Engineers Alaska District P.O.Box 7002 Anchorage,Alaska 99510 Dear Colonel Debelius: 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 around 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 the major river drainages in south central 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 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 I'*.] 2.Description of Action -The draft states that all impacts were not I exhausti vely evaluated since the project is only in the '1feasibility study"stage.However,it appears that the proposal has gone 45 Ifar 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.I 3. 46 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. 47 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 (Nat i ve)1 an ds . Page 1,paragraph 1.02 49 50 51 l It is suggested that it is premature to consider the subject project without first completing the Stage 2 comprehensive report on the feasibility of developing other hydroelectric sites in the area. Page 6,paragraph 1.03 , The discussion of access road design/location should be strengthened, lif possible.Mention is only made that such construction will ·include consideration of 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 IIt is impossible to co~sider the environmental impacts of the52transmissioncorridorasdescribed.A considerable expansion this section is warranted. 144 2 of 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-~:3 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. f 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 S5 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 58 59 60 61 ·62 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 indicate.significant populations of hunters,fishermen and miners utilizing the Susitna River Basin.Reference:Upiversity of Alaska 1975 DRV 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 highway is probably the result of minimal sheep p::>p ulat ions.. Page 43,paragraph 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, 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 anyone 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 attempt 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 £actors. 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 III 1.Temperatures remain at natural 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 cost 63 to capture prey organisms.Fish lose condition,are stressed and subject to mortality.. 3.Dissolved oxygen is presently above 5 ror./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 clearly 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. Pa8e 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 Jheriver,namely winter habitat for fish from sloughs and Ad'itional spawning habitat will not be of any value, critical winter habitat for fish survival is not value of tributari provid d t e available. 66 Pages 55-56,paragraph 4.04 67 The lower Susitna Basin encompasses one of the largest blocks of land cu .n ly patented to the State of Alaska.The area will see incre-d public use in recreation due to the fact that many areas 0"".state will shortly be turned over to the private ownersh'p of Native regional corporations and villages which will restrict access to lands previously used by recreationists from the densely populated Anchorage area.Also,as sugGested,a new capital may be COTI3 ructed close to the lower Susitna River.The impacts of ~educeu disch r es 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. 68 The dra:L stimates 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 nalyses in Alaska. Page 59,pa agr.aph 4.10 69 .t would be of value for the reader to know the actual locations of propose roads and the conditions under which it would be considered necessary ·to accomplish revegetation of temporary roads and other disturbe<areas. I Page 61,paragraph 4.13 70 Care S lould be exercised in locating the transmission line between Point MacKenz~e and Cantwell so as to avoid a degradation of the I scenic views of Mt.McKinley. 71 IAn expansion of the brief discussion of planned landscape management techniques would be appropriate. 72 The last sentence in the first paragraph should read positively, "That would (delete probably)qualify for wilderness classification" (delete rest). 6 148 We suggest qualification as to what extent roads and transmission lines will impQct 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 f,iven to potential power production based on a blend of these two systems.Other factors in favor of concentration of power production in the al:'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 two transmission or power systems should be explained in the final. Sincerely yours, If},//,},t1,"~1/(~-e-- CurtisV.McVee State Director .~;)..u 7 RESPONSE TO COMMENTS BY U.S.DEPARTMENT OF THE INTERIOR BUREAU OF LAND MANAGEMENT ,){~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. L1(j As acknowledged in the first paragraph of BLM'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. I j' ":~./ 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 "benefits"from such access are not weighed as a trade-off to adverse impacts which mayor 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. Comment noted. 4 b Commen t 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. 5UConsiderations 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. 51Concur.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 t 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 £15.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 t through regulated flow and elimination of high flood stages t to eventually assume a basically singlet 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. ~::The extent of floatplane use is described in more detail in a pre- vious paragraph entitled Air.The terms "minor"and "common'l 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. 03 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.1I It is agreed,however,that minimal sheep and goat hunting along the Denali Highway may well indeed be the result of minimal populations. tj~)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. b-':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~Comment noted. "',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 mortal ity."--an d subparagraph 4 of the previous paragraph which states:"With increased flow,there II would be no impact on fish life t 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.We 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. 72 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 Dther 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 IN REPLY REFER TO: United States Department of the Interior NATIONAL PARK SERVICE 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 ments of the railbelt area. of existine requirements and to show projected future power require- This section should provide a comparison projected needs. The impacts concerning recreational opportunities need expansion.In I a land of so many natural lakes it seems that a reservoir of the proposed design (long and narrow)would be of little recreational ts<) attraction.The attraction would bf~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 ~Jl 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 .'£.'.- ...1...'4...~....._) 82 83 84 Pass area and the Nanan~Canyon.Why is it necessary to transmit power 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 ErS,the resolution states in part an investigation of "any competitive alternative.II Can this really be done if on the one hand oil and gas alternatives are dismissed in view of a "national effort,"and coal is discounted on the basis of extensive adverse envi~ental impacts even though statements such as on page 71 indicate~ 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 85 IThese 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. What will be cost for the two 86 6.04.2 Devil Canyon This alternative should be more carefully examined.Even with a low firm ener~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. 871 We recommend that the question of environmental impact versus cost benefit of development for a number of energy sources be explored. 2 1:56 Not enough discussion of the interti e and the secondary social-IS8 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.IseA 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. 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 ElS. Sincerely, f"~!'HI,.I I· ,,\.I \.>../.j~\~ Albert G.Henson Project Leader AGHenson:jkm 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 100~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 IN REPLY REFER TO: L7619 (PNR)CAE United States Department of the Interior NATIONAL PARK SERVICE Pa~ific Northwest Region Fourth and Pike Building Scalllc,Washinglol\9HI01 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 environmental 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 1 or vegetational and scenic impacts,so it is difficult to determine the 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 environmental statement should present enough informa- tion for the reader to understand why the proposal was selected over the alternatives. -.\o\..\.JTlO.y >I(-«;C~~ -i ~~mex:~ \V ~?-t.-~ '''>76-191 '0 1.61 91 93 ' The National Register Criteria (36 CFR 800)should be applied to the cahin which was identified by the Alaska Division of Parks and would be inundated by the Watana reservoir.These procedures were printed .in the Federal Register of February 4,1975,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 91A 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. 9·J The EIS has been expanded to include a discussion of the relative impacts of the alternate transmission line corridors. ~'1 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. J.63 \OOQ sEesLIn OVEN''E IN REPLY REFER TO: E3027 UNITED STATES DEPARTMENT OF THE INTERIOR BUREAU OF OUTDOOR RECREATION NORTHWEST REGION 91'SECOND AVENUE,RM.990 sEoTlf ....""ellltl ••a.'OiUQ4 SEATTLE,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 95 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. IThe 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. 96 The 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 rtIachitlt~s and the iiilpacts Clssocia.te::!should be discusseli in greater detail also. It should be noted that this is the view of our office and does not 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 ;;;;;;;;:2IY~ 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 54-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 1andscape management practi ces.When the speci fi c 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. .~(j,:·,S~......v 98 99 100 U.S.DEPARTMENT OF TRANSPORTATION FEDERAL HIGHWAY ADMINISTRATION Room 412 Mohawk Building 222 S.W.Morrison Street Portland,Oregon 97204 November 24,1975 IN REPLY REFER TO 10EO.3 Colonel Charles A.Debelius District Engineer Alaska District,Corps of Engineers P.O.Box 7002 Anchorage,Alaska 99510 Re:Draft Environmental Impact Statement Hydroelectric Power Development Upper Susitna River Basin Southcentral Railbelt Area,Alaska Dear Colonel Debelius: 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. 2.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,~:-I!tr-c/;Z~V~{iLC'~-~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 10n 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. Form ~uT F 1320.1 (1~7) Memorandum OFfiCE Of THl ScOL 1ARY DATE, Hydroelectric Power Development,Upper In reply SUBJEC1,Susitna River Basin,Southcentral Railbelt Area,r.fer 1o Alaska November 11,1975 I FROM , TO Secretarial Representative,Region 10 District Engineer Corps of Engineers Anchorage,Alaska 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 M"IL.ING "DDRESS: COM MANDER (fin 1\ 17TH COAST Gl1Alib diSTRICT FPO SEATTLIt 11771 1 October 1975 From:Commander,Seventeenth Coast Guard District 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 would be the increase in recreational boating activity 101 on the newly created lakes behind the dams.No other areas of Coast Guard interest were revealed. By 169 l01 Comment noted. RESPONSE TO COMMENTS BY U.S.DEPARTMErn OF TRM~SPORTATION COAST GUARD 170 11II DEPARTMENT OF THE ARMY u.s.ARMY CULD REGION'o RESEARCH AND ENGINEeRING LABORATORY HANOVER,NEW HAMl-'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 Impact 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 requlrlng 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 modify 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 in 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 cr.NL-R 31~EC"::?eview Dre.ft Susi tne.Impact 8ta:.cent 12 November 19'75 102 103 t 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 (18oMW/44oQ cfs/Francis unit is given on p.3;on p.45,Table I,average regulated flmy is l approximately 4200cfs/month;9200cfs/4400cfs/180MV ~3'76MW 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- viding 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. V3 u.s. ,, EN V I RON ME N TAL PRO T EC 11 0 N REGION X 1200 SIXTH AVENUE I'SEATTLE,WASHINGTON 98101 AGENCY I R~'lY TO ATlN Of,lOFA -MIS 623 November 13.1975 104 Colonel Charles A.Debelius Department of the Army Alaska District.Corps of Engineers P.O.Box 7002 Anchorage.Alaska 99510 Dear Colonel Debelius: We have completed review of your draft environmental impact statement.IlHydroelectric Power Development.Susitna River Basin n 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 Il pre liminary studies by the Corps of Engineers indicate that the suspended sediment would be at low levels (15-35 ppm).11 These levels of suspended sediment are sufficiently high to warn of potential violations of water quality standards. These Joint Fede~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 load 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. 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 !" Our rating of the project relates solely to its water quality aspects 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. 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 discussion 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 Infonnation).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. 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. ULJIi ..;V j)~(~'1f~)'~ Walter D.Jaspers Director Office of Federal Affairs 175 1105 06 1107 tOB 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. lv 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 "dead"storage space,to provide a mix of waters approaching natural streamflow temperatures. 106 See response number 255. 1U7 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 {j 8 Comments noted. 17b FEDERAL POWER COMMISSION REGIONAl.OFFICE 555 BATTERY STREET,ROOM 415 SAN FRANCISCO,CALIF.94111 December 4,1975 Colonel Charles A.Debelius District 8ngineer Alaska District,Corps of E:ngineers P.O.Box 7002 Anchorage,Alaska 99510 Dear Colonel Debelius: We have reviewed your Draft ~~vironmental Impact Statement on the Hydroelectric Development Upper Susitna River Basin,Southcentral Railbe1t 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 lmvironmental 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 2.04 ~ 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:::hcentral and Yukon region (which includes the Southcentral Rail- belt as its main component),as defined in the 1974 Alaska.Power Survey Report of the Executive Advisory Committee,indicate that rapid rates of increase in power requirements will continue at least for the balance of the 1970's, reflecting economic activity associated with North Slope oil development and expW1sion of commercial and public services.Estimates beyond 1980 reflec~a range of assumptions as to the extent of fUture resources use and industrial and population growth.All indications are that accelerated growth wi~continue through the year 2000,with economic activity generated by North Slope oil and natural gas development being a major i'actor -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 i'uture additional energy systems and other potential mineral developments will have a major effect, and that there will be notable expansion in tranSJ:!'ortation 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 Claims Settlement Act.Other influencing factors could be cited,but the general outlook is i'or fUrther rapid expansion of energy and power requirements in the Southcentral-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 factors including co ts,conservation technologies,available energy sources,types of Alaskan d>velopment,et cetera.The higher growth range anticipates significant new energy and mineral dev~lopments from among those that appear more promising.The lower growth railge:generally assumes an unqualified slackening of the pace of development ~ollowing completion of the Alyeska 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 n~ifestations and our assessment of future condi- tions.10 should be noted that there are several responsible advisory committee members who feel that recent acceleration Of mineral raw material shortages of all kinds indicates a possibility that $'en 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 Re~ns.Indicated load increments by decade are as follo'ffl; 178 -'1 - Increments of 80uthcentral-Yukon Power nequirements 1972-19[\0 ~ea.1<::umual Jerr.and 8nergy MH GWh 19110-1990 Pea.'.Annusl Demand 2nergy MW GWh 1900-2000 i'N1K :\1U\\\31 Demand 8nergy MW GWh __1 9,..7:?-.?090 _.. \~~~\j\1IJ \\1:11 Demand mergy W GWh Higher E;stimate Mid-Range SBS 4 623 3 093 4 460 28 110 930 4 570 2 800 13 070 1 950 10 240 8 148 45 803 3 518 17 903 According to the sub,ject 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 MW.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-J)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-Yukon 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 Canyon-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 p~Ner 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 after 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-1980 1 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 I j>~i ,-:discus ses several potential a1 ternati v-e 1~,iroe1e('l-r i" 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. Very truly yours,Jlif:!:/7/1//~.__LJ/(Deputy) M.THOMAS (Acting)Regional Engineer Attachment (Table 1) 1.80 ;.. TAOLE 1 Tota 1 Po\ycr Rc~ui rcmcnts SOllthcQntral und Yukon RQg;ons ]j Actual Reguire~ents Estimated·Future Requirement~ Region .1972 Pea<"Annual DeIT:3nd'E!lergy ~i'.l ,.G'1lh :..!.!-...-""'-- '980 Peak Annual Demand Energy t·1H G\'!h 1990 Peak Annua 1 Dem2.nd Energy, 1\1\~GHh 2000 Pea k Annt.:e.1 D",,"";lnd ;:1'Y''''Y""II ___I;'~ /vll.~I..f~ Higher Rate of Growth Scuthcentre.l 317 1 4,65 990 5 020 5 020 30 760 7 190 40 810 Yukon (Inter;or)115 542 330 1 610 760 3 980 1 390 7 r"'~'!"->J"-J-.J Tctal 432 2 007 1 320 6 630 ..5780 34 740'8'580 47 810 ~ CO Likely Mid-Range Growth Rate~,-- - Southcentral 790 3 790 1 530 7 400 3 040 15 ~":t"\.....oJ., Yukon (I nteri or).280 1 310 470 2 270 910 ,4 S~:J- Tota 1 1 070 5 100 2 000 9 670 3 950 19 9iJ .,'.. 11 As di?fined in the 1974 Alaska PO~ler Survey RESPONSE TO COMMENTS BY FEDERAL POWER COMMISSION REGIONAL OFFICE JL(;~Statements and comments from the Federal Power Commission are noted, including the general agreement on power needs and alternatives. 182 ] STATE COMMENTS AND RESPONSES Sta te 0 f A1as ka 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 Comments 110-111 112-125 126-128 129-160 161 162-169 STATe /DlIer Df'([lOPM£NT AND PUNNING . November 10,1975 Colonel Charles A.Oebelius Corps of Engineers Distric~Engineers Department of the Army Alaska District P.O.Box 7002 Anchorage.Alaska 99510 JAY S.HAMMOND,GOVCRNOR POIlCH AD -JUNEAU 19111 PHONl 4153511 Subject:Southcentra1 Railbe1t Hydroelectric Project State 1.0.No.75091103 Dear Colonel Debeliu~: 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 Fai rbanks Department of Highways Department 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 oDject to this project at this time.however,our final110positioncannotbedetermineduntilamorecomprehensiverevieworthis project has ·been completed by the State. 184 Colonel Charles A.Debelius - 2 -November 10,1975 It is obv;o!J';frl1";1'1,'j"",pnIIJCS fi"civ"d in 11';5 office that a great deal of additional studies will hllvc Lo ue dune llcfo~·e tile rl:Jl ~lIq)()ct 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,alternate 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, ~~~~ State-Federal Coordinator Attachment cc:Commissioner Langhorne Motley 185 111 110, 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 Governm·1 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 Draft EIS--Hydroelectric Power Development,Upper Susitna River State of Alaska, \ II ('\, I ~/(,::,~.",'.'~.'1 : (;.;.?o,~!•..1..... DATE:November 3,1975'"!,)l:_:", /,'ij /'f I,if'!!'L V',~,_ t ••~.:}~i ~~"1:r,..' ",'.:-.,.~".7 ,'. ;,'"4,.1 FILE NO: Raymond W.Estess State-Federal Coordinator Diviuion of Pol~cy Development and Planning Of.fice of the GO~TELEPHONE NO, Ernst W.Hueller ~e./2f2.'SUBJECT: Commissioner Department of Environmental Conservation TO: FROM: 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 ErS,it is essential that this Department and other interested State and Federal agencies partici-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,rand 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 14 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)should 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 lmp<lct to resident and alladromou5 fish.They <:lre as follows: a.The unspecified effects of cooler summcr and winter water temper'atures on anadromou5 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). Raymond W.Estess - 2 -November 3,1975 115 116' 117 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 hinitial period"during and ,after construction (p.70). e.The feasibility of passing migrating fish over and through the high dams (p.72). r IOnpage75oftheFeasibilityStudy,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 ~5 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'i 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, case predominately white important avian species. Ers,the climax or near climax vegetation,in this spruce,is also preferred nesting for a number of 119 One major potential adverse impact not mentioned (p.67,CIS)is failure of the dam structure.With regard to this,more detail is necdQd 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 displac0.ment,and other.respons~s to seismic activity ~xc8cdinq structural limits?The effect of inundated areas o(seismic activity is only now being und~rstood,and must be fully addressed in the EIS. l\ttcntion should also be given to any lClntlslide potenUal res\-llting from inundation and subsequent saturation and/or erosion of !;lopes.Tht~,is .p~rticularly true where permafrost exists.Little is known and less is undcrstooo about the behavior of permufrost around and under an inunduted 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 migrate uphill.A detailed 188 Ra)~ond W.Estcss -3 -l~ovember 3,1975 treatise on the behavior'of permafrost is strongly recommended for this pro- j0.ct.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 DElS is written specifically for this site,the alternative areas are not developed in sufficient detail.Phrases like "tremendous financial investments"and "substantial environmental impacts"(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 al~;o a point of conjecture that alternative exotic enc~qy sources, particularly geothermal,should be categorically dismissed as being economic- ally and technologically impractical in this region.Thi~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 Darnsites,.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 m~p series of the Joint Federal-State L~nd Use Planning Commission.One major source in this regard could be the Alaska Department of Fish and Game's Ala"ka wilulife and Habitat Atlns.This information ba~c could be further expanded through infOrmal dis- cussions with wildlife :.·,iologists 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 hydroelectric power development act as a catalyst for Un\"ilnted qrol"th in SouthcClltral Alaska?'1'h0 litcr~tul:e is rep10te with cases which clearly indiciltc thut hi<]hway:;and sewer i'lnd wat~r system:.:;can induce unwanted growth.Doc;.the saint'ration.'llc hold tnw for the propo!lcd hy<lroelcctric filcility in the Upper Susitna n~sin?These questions have been only weakly·addressed on pages 63 and 64 of the DEIS. 189 11 20 1121 22 123 1.24 ~l25 RESPONSE TO COMMENTS BY STATE OF ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION 112 Concur. 11 "Concur.We suggest that local government entities also participate. 114 Comment noted. 115 The 35 percent mortality rate on fish t such as young salmon t 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,distance t and volume are also factors.This impact is discussed in the EiS and will be the subject of detailed desi.gn 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. t)Concur.These considerations will be studied and evaluated in detail prior to any recommendation for project construction. ~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 ;s possible (which appears unlikely)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. ~Comment noted. 9 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. 120 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 lOa-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 alnne,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:"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."For further response to this comment,see response No.255. 192 STATI: of A~A$j{A TO,I Raymond W.Estcss State-Federal Coordinator Division of Policy Development and Planning Office of the Governor Lang~or~e A.Motley ~Comm~sSl.oner VV· Department of Commerce and Economic Development DATE SU~J~CT, Ford ,.;;I\;_....,~r~1 ~':"-"'(........:{,~:..; October 16,1975 Southcentral Railbelt Hydro- electric Project State 1.0.No.75091103 The hydroelectric project proposed by the Alaska District Corps of Engineers is a key element in meeting Alaska's future power needs. 1126 At presen~,the project needs to receive an intensive and detailedl study of several potential adverse impacts on the environment.12'~ These include further examination of the dam's effect on the r' anadramous fish,the increased turbidity of the Susitna River during winter months,and the inhibition and higher mortality of the caribou population.~ 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 analysis and study. In summary,project is definitely necessary if Anchorage and Fairbanks are to receive low-cost,dependable power,and the subsequent lack of heat,noise,and air pollution problems ~dd to its feasibility.The draft environmental imp~ct statement raises several pertinent questions,but the answers will only be achieved through State and Federal support of the project. 193 .~ ~'12B, 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. Comments noted. 194 ~/l·EMORANDU.M -~..._-_.._-_.. State of Alaska Tel:Pete Cizmich Regional Supervisor Habitat Protection Department of Fish &Game Anchorage DATE:October 2.1975 FILE NO: TELEf'HO;~E NO: FROM:Larry J.Heckart Mgt/Research Coordinator Division of Sport Fish Department of Fish &Game Anchorage .SUBJECT:Susitna (Devil's Canyon)'· E.loS.Comments Following are the consolidated comments on the Corps of Engineers draft E.LS.pertaining to the Susitna River Hydroelectric development: Page 18, Page 19, last 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 .. paragraph 1 -Should mention what surveys and the year(s)they were conducted to determine that fish dD not migrate beyond Devil Canyon. ,paragraph 2 -This is not indicative of Northern District Cook Inlet (Susitna River Basin)as a whole. paragraph 3 -ADF&G currently has escapement goals for Ken~and Kasilof rivers.We cannot conclude that adequate escapement occ~rs into the Susitna River because escapement goals have been reached in the-Kenai and Ka's il of ri vers.!' 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,apllroximately three miles downstream from the Devil Canyon dam site.Spawning and rearing salmonids occur in many clearwater sloughs and tribu- taries from Portage Creek downstream to the confluence of the Susitna Chul i tna rivers.T" Last two sentences in paragraph are okay. 01)1 rn~.,6/7~1 paragraph 5 -Should identify study (first sentence)as 1974 assess-I ment study by ADF&G.1.,.)4 Omit last sentence.~ Also.king salman are excluded.,Barrett's 1974 repo~t indicates king salmon present. 195 Pete Cizmich - 2 -O~tober 2.1975 paragraph 3 -Omit "limited".The numbers of game birds is unknown. 13 61 Page 21 t 1371 Page 23, Page 20.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 t we do not know what proportion of the commercial catch landed between the latitudes of Anchor Point and135theForelandsareproducedintheSusitnabasin. In certain years.primarily even years t 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 is 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 species, as given for anadromous species? age 24,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. 13 ",page 27,paragraph 3 -Not true~ transmission corridor. Bears occu~in both directions alon~the 14 °1 Page 37 &38 -Recreation in the areas affected downstream of.Devil's Canyon would appear to warrant mention. age 46,paragraph 1 -What is the sourc~of information indicating unregulated summer silt loads?Again,while summer siltatl0n 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 stream 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 2~1975 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 "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 for 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-~'~I pressed for extremely low water years and planned regulated flows ~ under these conditions. paragraph 2 -What flow reductions will occur during construction and I jL A~ the subsequent fill period and for what duration?~ paragraphs 3 &4 -More current data is now available re numbers of I JL~4i sloughs and tributaries utilized by salmon and other I'llainstem migra- tional characteristics. The clear water condition of the Susitna River during winter·months I could be a contributing factor to salmon fry utilizing the olainstem. If a year-round somewhat milky-textured "glacial floor"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 will not only be JL~E> 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 Consequences of the P~~~5_ej Mo~_~~~_~~fraserRiv~r that reduction in downstream discharge and resultant water velocities during the spring seaward outmigration could adversely affect surviva1 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- -tiona1 period. Pete Cizmich - 4 -October 2,1975 Columbia River data indicates mortality of salmon increases with the time required to complete the downstream migration .. (see further comments following re increased mortalities dependent on S1 t 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 determi ned. 1 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 spawning downstream of Devil Canyon. Therefor,unles5 flows are high enough to flood the slough and tri- butary reas ,where spawning is known to occur.benef.its are likely to be of little value. 14 15 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 j v .1e sal mo n. There is no solid evidence available that adult salmon can adequately adjust to altered flow.temperature.and turbidity regimes. 6 -final sentence -There is no evidence of mainstem i-g 0 it is doubtful there is anything to enhance.The reduc- tion in summer flows may cause a reduction in both tributary spawning areas and tributary and/or mainstem rearing. 5 Page 51 •pa gr-a h 7 -This also applies to downstream areas.Insects are fou d 0 rovide an important part of rearing fry diets. age 52.parag aph 3 -This sentence sounds theoretical.Cite evidence supporting this statement. age 53.paragrap 4 -Paragraph meaningless.Sample size too small to be signifi ant. 198 Pete Cizmich - 5 -October 2,1975 paragraph 5 -Improvement of habitat quality through construction of 1~54 transmission lines is theoretical.JL Page 56,.paragraph 1 -Hunting pressures will not increase,only the potential ~ .for hunting pressure increases.ADF&G has the statuatory.capabilities fit>· .to control the actual pressures. Page 65,paragraph 2 -Will the summer silt loads during the 10-12 year con-.1 156 struction period actually be decreased,or perhaps increased as a direct result of excavation,road b~ilding,etc.? Page 66,paragraph 3 -Again,only the potential for hunting pressure is I 15~,' increased.il' 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 potentially 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 tribu taries 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 riparian 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 l2-year period of construction and'rresultant effects on the fish,wildlife,and recreational resources are not addressed. 199 i5S I 1.$9 RESPONSE TO COMMENTS BY STATE OF ALASKA DEPARTMENT OF FISH AND GAME .A.Jl...<aJo A sentence has e n added establishing the fact that juvenile salmon may sp d sever years in freshwater before migrating to s ,water'. The pa ag aph is consldered 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. The statis 'cs resented in is para£raph of the £IS are taken, -L~~~as indicay eference,fr m Leaflet #26 prepared by the State of Alaska Department of -~h and Game. 1 1 COlllJlent noted. A statement has n added that a significant percentage of the Cook Inlet salmon run migrates into the Susitna River Basin. ~,~~-T-e paragraph has een revised as suggested with exception of omitting hast s I"ltence.The s.tatement made in the 1975 Alaska Departme t of Fi h d Game assessment that a portion of the pink salm-run may ha e been destroyed by a late August-early September flood has not been omitted. her 15 no a t mpt anywhere in the referenced five paragraphs to elate Cook Inlet catch to Susitna River stocks.Neither is there y re,erence to case packs for Cook Inlet as an indicator of Susitna ra uct on.~e agree that there is n present method of affixing a va,~to the Susitna River salmon production and have not attempted o do o.We have ad ed a statement that the Alaska Department of Fish a ilni ceo "significant percentage of the Cook Inlet salmon n to the Susitna River Basin. 1 The nelusion of a 1 fe history section or anadromous fish was in opt·a 1 dec 5 i On made by the writers of the EIS.There is no requi ement y MPA or CEQ guidelines that such a section be incded in an EI Salmon were included because of the great 'gn f~cance ecreational as wen as economical)accorded this species.Also,project impacts are more subtly associated with he 11 r quir nts of salmon than wi h any of the other major lSh spa ;,s. ~Concur.e tatement has been revised to i"cate that the numbers of gaflle b,rd are unknown. 200 1 38 Car;bou range map is as shown from maps in the Southcentra 1 .~eglQ"!..C!l.f.r.2fil~and the Alaska Wildlife and Habitat Atlas. 140 t41 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. 142 COlllTlen t no ted. jL~:l 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. 1 1i5This determination will be an objective of fishery investigations as the study progresses. 146 Fish access to the sloughs as a result of decreased summer flows will be improved if it is found to be necessary and required. 14?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 1 ' 14.~,LOlllmen ts noted.The EIS has included addi ti ana 1 temperature and turbidity information from the Moran Dam study. ]5(,II"provi'~i()nc;'\1'('11\;\dp to 1'l"'VI'llt Ilydl'"lllil:hl()l'~,\llc";to ';,\1111\)11 '.poiwninlj Lril>uldrif~"dnu ~Iouqhs (ciS the US says there will be, it npcessary),it is not likely that tributary spawning areas will be reduced.The EIS does not state that mainstem spawning will be pnhdnced.We agree that little,if any,mainstem spawning occurs under present natural conditions.However,it ;s not unrealistic to a~sume that some spawning habitat could develop in the mainstem within the n~acn subjected to s ilgn i fi cant ly reduced summer sediment loads a no fl ood i ng . 1 b 1 Concur. 152 The second sentence in the referenced paragraph does make a theoret- ical stat.ement.The evidence supporting the statement is contained in the sentence 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 hore 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 Di sagree.Transmi ss ion 1i ne ri ghts-of-way are known to improve habitat for wildlife species which benefit from subclimax vegetation. Concur.The sentence has been modified to indicate that there will be a ~~~tial increase in hunting pressure. 1 56 The ~aragraph 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 would be of extremely short duration,while small diversion dams were being placed to direct river flow through bypass tunnels.Dam construction,itse1f,would be done "in the dry,"thus construction of the dams would have no :-,lgnificant impact on water quali~y. concur.The sentence has been modified to indicate a potentid~ increase in pressure on existing game populations. 58 COlilments noted. 159 Disagree.Until studies are made of this situation,no positive conclusion can be made concerning the Aownstream impacts of flow regulation 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 lO-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 .STATi:i of.~L.AS;<A ;;J;fi!:~~t};)rrJ];/f!{j)~;:-jb1l f· DEPARTMENT OF NATURAL RESOURCES DIVISION OF LANDS :I TO-I RAYMOND W.ESTESS State-Fodera I Coordinator Oftlco of the Governor Dlvl510n of Polley Development and Pouch AD Juneau,Alaska 99601 GARY JOHNSON,Acting Chief ~~PI~nnln9 &Classification Sec/Ion Alaska DIvision of Lands 323 E.4th Avenue Anchorage.Alaska 99501 Planning OAa I SUBJECT, !"•.~•1:" . : ' ._.#;.","'J .. October 27 #.r975 St~ta 1.0.No.75091103 Southcen'tra I Ra I I be It Hyd ro- electric Project . The above-noted project has been reviewed by the Division of Lands'staff. with the following comment considered appropriate: "Gener<ll Coll'lOOnt:This project Clppears to have tuvorabjG energy dove I opment benet J ts wh II e hav I n9 ()re I at I ve I y low anv I ronmanta I t mpact." (Planning &Classification -G.Johnson) ~..Th3nk you for the opportunltyto review this project. r I 204 161 COlTlnent noted. RESPONSE TO COMMENTS BY STA TE OF ALASKA DEPARTMENT OF NATURAL RESOURCES DIVISION OF LANDS 205 TELEPHONE NO: M'EMORANDUM State of Alaska.,y'(,~'..JAt.,.;;t,:~ff ~!If jft, ,OAT£!;October 21,1975 OC!,~{.1975 ,,~, State I.D.No.'75091103 Susitna River Hydroelectric Proposal , FILE NO; SUBJECT: n~ymond W.E9tcS9 St~Lc-Fedcral Coordin~tor Divl~ion of Policy Development nn(l Plllnnlng Office of the Governor J;)me~E.Noody ~~I Chief Planning Eh~ine .IV{I Divloion of Aviation i Deportment of Public Works TO: rOOM: t11"t- Follo""ing ~off-the-cuff comments on the subject project as requested In your September 24 memo,and as related to the September 22 trans- mlttnls from the Corps of Engineers. lit t.'lched is a copy of the 'October 9 memo with Nr.Baxter'8 comments 'followinK his review of the materiaL 162 , Th~d:,t;l.:IS naxter,note~was too broad in scope 'and brief to allow us to evaluate how the project could effect our present and future operations. Specifically,there is no inventory of the airports or recognized landing nrcas,either public or privately owned,,in the immediate vicinity of the projcct.Tile 6cnl~of the map~and the quality of the printing supplied with the data are such that it is not possible to ident,ify the boundaries of the project 50 that IJe can compare them against our inventory of landing nrca~l.although loll'doubt that very many fields t'/ould,be involved. 163 The b ,ll:p,es t qUC$i:i·on from the stand pu in t 0 f trnnspor t:.J tion deals mainly IJlth 5\lr(:.Jcc transportation rather thall aviation.ThJ.t is,how would the 'd:lm8,lakes,;lnd related facilities improve,and ;restrict,accessibility to the Sus1tna 8asin?The creation of an 80 mile long system of lakes would cert.Jinly rcstrict the selection or alignment of road routes trnver3ing the area.On the other hand,the lakes themselves might offer 1\certalo degree of flexibility relative to surface transportation. Perhnp9 the most important point is the fact that there would likely be a r.p\lr hip,hway constructed connecting the railroad and George A.l'arks ll'~hw:lY to th<.>d<1m ,-ystcm,thereby providing convenient public vchicular acc('t-ls to what is now a relatively remote region. 164 Tt ifi 0150 likely th~t some type of airport or landing strip will be con~trllcted in the immediate proximity of each of the dams,to provide qui.ck .1CCC.SS durlnr,construction If for no other rcoson.It \,/ould be lnlt.:r:c"t:lng to know IJhcrc these strips might be.l)ow LHgC thcy would I;'7) he,.;lnd so on.{/,.I"",Ir.',..f Ih"'"f""y../Lrl.~A-t!('1""~n7 U-"U'y~:'-'iJ Co~/~{y IThe d:1m~llnd their rcllltcd hydroelectric plants t.ill in themselves create ,employment opportunities.Since the projects will result in improved aurtocc access plus a major supply of electrical energy,(lod since the area 18 rclot ively clOBe to mineralized zones,mineral and other r,esources may 20G -2-Octoher 21.1975 165 he dl'velop4·11 thlls cont,r ibuting to more employment,incrc.:lsf;'d settlement:, (~r pUI'IlLatJoll.nnd iln iIlCt'l!ilSed need for both o1il"and surface tran~ro'('tnl:ion. 11w ill(:n~n"eJ llC.C('~BflihUily will likely :lttracl consLcll~r.:lble n~crcational {Ict tv tty.whether or not any mim~ral or otlter indu~itrial resources are developt~d. Itt:;anyone cons.t.dcrcd the alternative of private development or this I j_6~~ hydroe ll~ctr Ic rc!')ollrce?Which would benefit the SUite more -federal ~, devt>.lopmt:'nt o(the resource.or private development? TIl<'tone of the draft EIS and the draft Interim Feasthility Report seem to indicate a relatively detailed H~view of the imp<lcl~on the lands actu.l11y encompassed by the proposed project.Howev~(">a proj ect of thtn ~cope which will create an 80 mile system of lakes with road access (sllch th<lt perhaps 75 percent of the State's population ,,,ill be withiq roughly 4 hours driving time)wll1 have a significant impact on the adj ....ccllt lands.The subsequent impact on oil'and other transportation Co'ln only be identified after probable uses of this adjacent land have \)('('n cala lop,plI.For example,if the'Niltional Park Service.or t;.he Djvj~~lon of Parks of the State's Department of Natural Resources.desires to preserv~th~surrounding areo for recreational purposeH,one type of j_6 17 flY LIt ion activity will predominate.That is.recreational flying or simple trallsport:1tion for recreational PUCP0!iCS might he tht~prime tr'-1I1~;p(Jrtnlion mode.SC'flplnnc traffic ml~ht cOlnrrl~('the h1.ghest percentage of :H'ron;,\utJcal nct lvity and od.r,ht result in heavy Jmtlacts at corresponding lOcaplant'1>:1~;('~>in 1I11cllOra~c and clGt'wherc.On the otlwr hand.Hho111d. t1a(~r(~he cXLcllslv('!wttlcment of the an.!;}.and particnl.lrly if thili is aWlOt'lat(~d with mineral or industrial d{~velopment.a hicher pcrccntoge of ,lerol\;lutlcal ~ctivity might involve commercial (scheduled airline) opcrntlons -possibly with medium to heavy aircraft. II better m~p showing the lake system.probable surface access routes. and sllrrounding area;plus more information on the wildlife.mineral, and ngrjcultural resources of the area from respective State offices w0I11<.1 help us better gauge the impact of the project.It is apparent that the project itself will have less long range impact on air trans-168 portatlon than the Hecondary developments which will spring from the propo!iccI hydroelectric complex. 207 -.~TATE '.,:AlAS:<A 'lo.r James E.Noody Chief Planning Engineer Kinney R.Ba~~~ A.alatant Pl~ngineer -O"'f $U8JECT, October 9.1975 Alaska State Clearinghouse Stat~1.0.No.75091103 Upper Susitna River llasin Southcentral Railbelt Area 169 After reviewing the Draft Enviroomental Impact Statements for the Hydroelectric Power Development.I have found that the way in which it is written does not create much detail to analyze constructively or destructively.The approach is of a general nature and prollibits many comments being made'towards the EIS.In the pa~t EIS'&that have.been reviewed.-the author will commit himself to particular controversial topics.thu9 creating a flock of comments from the various agencies. The only comments that I have to make are 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 nnd fishing camps as well as other recreational functioJ;ls.\.Jill the adjacent land be open to public sale or will it be established into a Wildlife 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 eSLablished. r I I.. 208 RESPONSE TO COMMENTS BY STA TE OF ALASKA DEPARTMENT OF PUBLIC WORKS DIVISION OF AVIATION 162 Comment noted.Ai r transportati on ;s di scussed in the EIS 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. Jll):)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 lb5 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. 166 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. 1 b 7 Commen t noted. 168 The qual ity of maps has been improved in the revised £IS.However, they are still small in size and scale.As previously noted.the Corps will provide larger.more detailed maps upon request. 16~All public lands acquired for project purposes will 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. 20S GROUP COMMENTS AND RESPONSES Alaska Conservation Society -Col lege Alaska Conservation Society -Anchoralge 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 Comments 170-182 183-199 200 201 202 203 204-257 99701 ·1 I~~l,,jJ~"j,,"!,.f_.~.,r,~. ....¥"~'"-'. V""I''';1;.),.'~,~-..:,/"'"'1 f< •I~,.~. ".J,"~'wit).:r-,:''l #I<f,/l l~· ...,,1 "~('"-'?,t1;";:/I.~i h'~'" .f...t:4-.. ~~;:X')-:,OJ :::.: -~~'""~ AI~SKA CONSERVATION SOCIETY COMMENTS ON THE ALASKA DISTRICT,CORPS OF ENGINEER'S ENVIRONMENTAL IMPACT STATEMENT,HYDROELEC7RIC POWER DEVELOP- MENT,UPPER SUSITNA RIVER BASIN,SOUTHCENTRAL RAILB~LT AREA,ALASKA dated:September 1975 GENERAL COMMENTS Considering the rn3~nitude of the proposed owo 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, C3n 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. 1'70 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 Septem~er 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 E1S."A final Environmental Impact Statement,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 E1S and that a draft EIS ~ould be developed later followed by a final draft E1S.To add to the confusion,the summ- ary page,undf'r item ?"D~s.-.:ri.ptioT'of Action"states that "since the· 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 1 211 171 Ala~k~ConscrvJtion Society Comments Susitn.)Ilydroelc'ctric Power Development November 15,1975 Page '!"wo of the t.!o<.:umcnt,under paragraph 1.02,"Scope of the Study"a two stage study Is indic<lled wherein St.:Jge 1 "is an interim report.to be comple- I tcd by 1 Dl'c('mbcr 1975,on the feasibility of hydroelectric development on the'\IPlwr Sus i lna Ri vcr"and Stage 2 "is a comprehensive report,an- ticlpat,'d to be cOllipletl'd in 1978,to determine the feasibility of d(:v('lorll1ing othpr hytlroclectric sites in the Southcentral Railbelt area." Frain tilis staL~mcnt is one to conclude that the document we received is a draft (or preliminary draft)EIS for Stage I of a feasiblity study? Will this tllen be followed by a final EIS on Stage I?And this followed by a draft ~lS on Stage 2;followed by a final EIS on Stage 2;followed by a draft EIS on the Devil Canyon/Watana authorized project;followed by a final EIS on the authorized project???? What mJkes these questions relevant is the vast difference in importance between being asked to comment on a draft EIS on Stage 1 of a feasibility ~tudy versu~a draft EIS on a project that is authorized.Although the latter h~s not yet been accomplished,the Corps is recommending authori- zation ~nd Senator Mike Gravel has already introduced a bill to the U.S. Senate "authorizing construction of Devil Canyon and Watana dams in order to hurry the project along so that it can be included in this sessions "omnibus water resources development package",(Gravel,I 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 he continued even though construction of one project (Devil Canyon/Watana)has bee~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 Alaskd a review of the potential of "the Susitna River hydroelectric power development system,including the Devil Canyon Project and Am COMPETITIVE ALTERNATIVES THERETO ...(p.l:caps are ours).Ten alternative power sources are mentioned in the D EIS but all are dismissed as non- competitive in the cou~se of ten pages~Two of these sources,natural gas ':lOd coal,are really viable alternatives in Alaska at this time.yet the tr~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:IIIn 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 thousands,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\lsitnil Hydroelectric Power Development No~embe~IS,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 pl<lce t'2 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 thet 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 assummcd 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 area can be reeontoured 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 that 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 'Vater in ,contact; with coal and mine wastes generally become acidic 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. Furthermore,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 all coal produces bad environmental conditions is very misleading especially in the case of the Alaskan situation.The final sentence in this same paragraph 8pp~ars absolutely ludicrous when compared with another sentence from this S8m('document:"The construction of the proposed hydroelectic project would have a significant impact on the existing natural scenic resource values within the project area.;'(Draft ErS,page 61,paragraph 2). Yhich is worse?The final paragraph of the coal alternative concludes: "In view of the extensive adverse environmental impacts as.soeiated with the coal alternative,both in magnitude of effects and areas affected, this is determined to a less (sic)desirable source of energy production tllal1 hydroelectric development."(1'.72)H;JW could the Corps .::Irt"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 AIDsk~r.onsc~v~tion Society Comments SusUn.1 Ilyd~ol:lectric Power Development November 15,1975 Pllge Four TYPE TI1HE[:LACK OF QUANTIFICATION OF MATERIAL DESCRIBING EXISTING ENV I RONm~NT Throughout the draft E1S,meaningless adjectival descriptors are used rather than numbc~s.Examples: 1 ':'3 -a.Page 12,p.:Jra.2:"Most 0 f the upper Susi tna River Basin Is •underlain hy discontinouous permafrost."How mueh is most?What is the rcJ;ltif>llShip of discontinous permaf~ost to the success or failure of the hydro project?Wh.:Jt are the environmental consequences of building dams in such tcr-rain? I b.Page 14,para.1:"Feh'kayakers have attempted the dangerous1''(4 eleven mile run through Devil Canyon."How many is a few?Were white- water canoer 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.B)""Cornmon"and "fairly"numerous In relation to what other areas?How many per square mile? 1.'76 1H.-my additional examples could be cited but they are almost too numerous to count:If the Jata are available,present them and if they are not available,say so. 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 onc of the least known areas in the State"...yet NO WHERE in Section 4.0,Environmental Impacts,does the EIS consider the con- scquencps 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 10:"The Sus i tna River ...i.s the large.,t stream di.s('hAreing into Cook Inlet." page 14:"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 sre built. In spite of these facts,no where does the EIS consider the impact on Cook Inlet of modifying the river flow: 214 A18sk3 Conservation Society Comments SlJsltn.:J Ilydroclt'ctric Power Development Novcmb~r 15,1975 Page Five TYPE FiVE:INADEQUATE REFERENCING OF SOURCES UTILIZED Although 31 p~gcs of the draft EIS are devoted to a description of the I "environment;)l Setting without the project",very few references are .179 made to the sources of the material presented and the few citations that are give'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 3 (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 11)is unreadable. SUMMARY 1 180 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 darns 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 comments to a ~easonablc level,we classificed the deficiencies into six types: 1.Confusing Presentation;2.Biased Evaluation of Alternatives;3.Lack of Quantification of Mater~al Describing Existing Envrionment;4.Important lssues 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 181 In view of the inadequacy of the draft EIS,the Alaska Conservation Society 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 'J any competitive alternatives"to the Devil Canyon and Watana Dam project in an unbiased manner and present this evaluation to th~tlublic.----- 215 RESPONSE TO COMMENTS OF ALASKA CONSEVATION SOCIETY COLLEGE,ALASKA 170Collllnent noted. 1'71 This cOllllllont indicates a lack of understanding of the procedural re- quirolllcnts estc"lhlished by the Council on Environmental Quality for fod(~rdl (HJPrlCY compliance with the National Environmental Policy Act. Guidelines to Federal agencies for preparing detailed Environmental Stateillents on proposals for legislation appear in the Code of Federal Hr.quliltions in Title 40,Chapter V,at Part 1500.In addition,pursuant to Section 2(f)of Executive Order 11514,the Corps has developed agency procedures in consul tation with CEQ which even more specifically provide quidance for the preparation of Corps Environmental Impact Statements. Hoth 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 StcltPlilCllt.The ROEIS will then be subjected to intensive in-house review Jt higher levels of authority,and the District will make any necessary revisions.After such revisions are made,the RDEIS will he submitted to CEQ and,at the same time,will be sent out to the I~oard of Engineers for Rivers and Harbors,the final review agency of the Corps,and to Federal and State agencies for review and comment. Gr'oups and individuals commenting on the draft statement will be furnished informational copies.The District will prepare appropriate res·ponses, tl'ak(~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, Srcretary of the Army.If the Chief of Engineers determines that new inforlllation received is of such significance as to warrant recon- sideration of previous recommendations of the Board of Engineers 10r Rivers and Harbors,he will send the document back to the Board 10r such reconsideration.When the Office,Secretary of the Army, trnnsmits the Final Feasibility Report and accompanying FEIS to Congress, it will also transmit the Final Environmental Impact Statement to CEQ. At thr.sallie time,the Division and District office will be notified of the transmittal for timely distribution of the FEIS to agencies,groups, (H1f.l individuals that have received and furnished comments at various levrls on the stdtelllent.The document commented on by the reviewer is <l 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 216 172 173 on Public Works of the United States Senate on 18 January 1972),to deten"ine 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. 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 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 permafrost 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 estohlishcd well below the level of permafrost conditions. 174.Ther0.have been only two or three people,to our knowledge,who have 'c1,1imed 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 "ncl porti.lCjcd out of the deep canyon around dangerous sections of the rivet',A copy of i'l report by Dr.W,L.Blackadar of Salmon,Idaho is inc 1uded.See response No.257. 175 1'76 177' 17~ The words ~~Q!.)~l!.Q.r]_"and "fairly"~u~e..rous are descriptions used from vdrious State and Federal agency wildlife statements and reports - it is presuilled 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 frOIll Fish and Wildlife Agencies.It is also stated that additional fish and Wildlife data will be obtained during the preconstruction planning process. 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 Me 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 Rasin above Devil Canyon is considered highly favorably for deposits of copper or molybdenum and for contact or vein deposits of C]old and silver."The puragraph goes on to identify two known IIli nera 1 depos its i tes -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 ~.O.Geologic mapping of the impoundMent areas,required to determine faults and foundation conditions,would be extensive prior to any recoillmendation that the project be funded for con- struction. Although Cook Inlet is not specified by name in discussing the downstrealll 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 existinq strealilbed configuration,increased turbidity during the winter Illonths 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 1111Pi.lC t on Cook In 1et can only be determi ned subsequent to 1engthy 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. 180 181 182 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 recommendations for construction authorization and funding.At the present time it is not known if the project will even be funded for further studies,much 1pss construct i on.In response to the remainder of.the "Summary"comment, every deficiency that can be specifically identified has been given an individual response and clarified in the RDEIS. 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 submittal to Congress. 219 \ &lASi{A CONSERVAl'ION Soclm UPPER COOK INLET CHAI'TER BOX 3395 ANCHORAGE,ALASKA 99501 Oct.17.1975 183 184 Ch;lr1es iJebelius Col.,Corps of ingineers District ingineer '10l(7002 flnchoragc.,Alaska 99510 801,Deheliu81 'I'h~followinf,are the comments of the Up!,'.'!'Cook Inlet Chapter or the Alaska Conservation ,;ociety on the LJr;~rt ":nvironmenta1 Impact :tR.tement on "llv1roelectric Power ~velopment -\lpper ";usitna River ;':lsln ";outhcentral H'lilhelt Area,Alaska",1\1:\';,,'1 !)istrict,Corps of ~nRineers,..;ept.1975. UCIC,AC";protests the short time frame In which this statement has t.,'en hroueht out.rhe agencies much less the puhl i.c ;lGk~j to comment on the ut:'\tement has Gcarcely enough lead time to il~nl\.fy wh~t needed to be ..Jone,much less to jo it •..,ome of the following .;~,,:,;tions askej at the he;"rinr;s were partially answereJ at the public rr.eeting;held by the Corps in IInchorage Oct.'/(which was only 16 Jays beron.!"dritt~n comments were .luej but we wish to assure they are contained in the final il;:,. UCIC,,,C~believes this Dc.1...>to be ~enerally in:\"je"~uate anJ unacceptable. ue ~gree with the ..,tatement on pg.8 ••.•~he ~l~iDes not incluje a de tailed ami exhaustive evaluation of project imp:\c ts ......,e object l;trcnuously to the fact that the proposeJ project h;;s to he al!t~ori~ej to b(J buil t be fore a..iE:<lua te environmental s"tujies Ciln be made. The following are some general observa tions an I 'iuestions on the otl..,. fish,Game,Hahitat The most obvious factor is the loss of 50,000 plus acres that will be inun-Jatei by the resevoir waters and lost as habi tat.l'alk5 wi th F ~G personnel reveal that they neej more time to do aJequate eame counts (moose.caribou,etc.).range work to jetermine what kmn)o"f habitat will h~lost,i"lentify specific caribou migration routes through the area, ~ni th~y nee I time to ijentify exactly which streams the mixe1 stockt of salmon spawn in.As we un1erstan1 it,they had at the most a year to start loin~this work with only 2 full time regular staff people anj the nEDIC"TF.O TO THE WISE USE,PROTECTION AND PRESERVATION OF AL",SI<A"S RENEWABLE AND NON-RENEWABLE NATURAL RESOURCES. 220 parttime help of 2 ai1es.Also,money was not available to do the stujies I nee1e1.This money,as we unJerstani it.woulj be proviJej un1er enabling ley,ielation shaull it be passe1,but again.we protest that this proposej project ahoul1 not be authorizeJ until aje~uate stujies are jone. F ~~as well as other concernej agencies,neej time to initiate stuJi s 185 to Jefine impact.regulatory changes anJ to define mitigation to compensatel for loss of habitat.'l'hey also neeJ more specific .lata from the Corps in oruer to evaluate Jownstream effects on fish an~other a~uatic inhabitants of the streams anJ tritutaries affecteJ by this proposej Jam system. Game counts aiteJ in the 0';;1 ...are completely ir de-iuate -i.e.pg.5) ·Ouring the June 1974 survey.one grizzly was sighted •••five black bears were sited on the ...usitna Hiver.~total of 56 caribou were sighted in the survey area M ~hat was the survey area?Is one years data the only available?How many times during the year were counts made?Information as basic as this does not seem to be available in the D~I~.~pecific stunies need to be Jone to Jetermine how increased river 186 water temperature will effect such things as downstream icing conjitions, salmon egg emergence,and effects on other inhabitants of this system. The effects will not be limitej to just the immediate area of the jams. What will the specific changes be in going from an unregulatej river to a regulatej one?/ihat effect will this have on the moose range?What will the Corps jo to mi tiga te these effects?~he Corps ~eemingly will have"to I mitigate for the loss of moose range -wlll they glve lands to the :;;tate somewhere else or provi1e money to increase management on other lanJs? This 4ueation joes not seem to be ajdresseJ at all in the DEI~. Siltation The problem of Siltation raises many ~uestions in our minds that are not addressed in the statement.How will JecreaseJ siltation in the summer effect primary productivity?If the nutrients are decreased during the warmer months when life re-emerges in this northern latitude,What will be the result up the fooj chain?especially in Cook lmlet into which the ~u8itna drains?nOW will this effect the zooplankton?And on up the food chain?~ventually,could this possibly effect the salmon runs? Also,aa decreased siltatiOn is predicted after completion of the propose.i dam&,what about the increased siltation bound to result from the construction phase (est.to be 10 -15 years)?Other 4uestions -How much silt will be picked up after the water is released from the dam? There may be a low sediment load spilled from the dam,but what are the' fieures say,1 mile below the dam? .;jed imen ta.ti on The factors that influence the rate of erosion,transportation of materials to a reservoir an1 the trapping of sediment within a reservoir are complex ani highly variable.'The geology of an area,nature of the solla,slopes,rainfall,runoff,hyjraulic characteristics,cover anj other coniitions vary greatly. However.y,iven the glacial silt an1 other seiiment content of the wate of the ~usltna River.the statei loss of storage capacity for a 100 year I perio1 (6.5~for Devil Canyon 1am,).610 for the ~atana dam)appear low. The rejuction of 6uspende:j seHment to 15-)5 ppm (pg.46)means that much of the unregulate I river sejiment loal (less than 1000 ppm in summer months) woul1 Rge f]:ta}peJ ~e'the proposel 1ams.I co s om existing reservoirs in the U.S.having Jrainage areas greater than 1000 s~uare miles and storage capacities ran~ine from 0.05 to 2.06~and averagi~O.72~(~ottsha1k,1964).A couple of examplesl 221 -:J!..- ,';10pt,dnt Ilutte re~ervoir in New l/iexico,lost 16;.of its original storage cCipaci ty (2.6 million acre-feet)in )2 years or operation,Guernsey reservoir in Uyoming lost J9/o of its storage capacity of 73,000 acre-feet in juat -18726yeare. The ,jata sources anj methods useJ to compute those se,jimentation r~tc~are not incluJed in the D~l~anj are thus not available for ",v;:llu~tion hy reviewers of the statement.Also,there is no mention of' the con~truction of a seliment pool to mitigate tne estimateJ loas of c to r,age vol urnne ove r the years. !"rJzil Ice Has the problem of frazil ice been consijered?~his phenomen of northern climates ie a great hazzard to power plants.It is essentially ice foe,that solidifies into a special crystal formation on the intake system ;JS the cold (glacial in this instance)water )1its the warmer area nearer the188turbines.It solidifies instantly pnd when this happens.the faat revolving turbines have a decreased water flow and could burn out.There is !;upposed ly technology to overcome this,but the problem is not addressed in the DEI~and we feel it is a very important environmental consideration. (:~eelJil1iams,J.P."Frat.il Ice -J..Review of its Properties with a ~electeJ ~ihliography",Engineering •~ov.1959.pg.55-60).~e are not convince;1 this prohlem can be jismissej by saying the water temperature i,n the reservoir will be "to high for this to occur". IHater Plows ~h~t will be the effect of essentially eliminating peak and low flows?1 89 Previ j in/>,flow fif,ures for the Chulitna and other jown stream areas we do .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? 1'0 rmafrost . There Geems to be incomplete identification of permafrost areas.How O will melting ice on reservoirs effect the permafrost?How much will erosion19contributetothesediment10aJaniwillwaveactioncauseincreaseJerosion on permafrost areas?tlhat will be the effect of innundating large areas of li~continuous permafrost?~xactly how much perm~frost will be under the impounueJ area? t~;';rthy uake a i-'g.62 etateDl "Devil Canyon and ,yatana Dams will be designed to with-191 stand a j~aximum CreJible earthquake of 8.5 magnituje with an epicanter of 40 miles at a focal depth of 20 miles Which is the approximate distance of both damsites to the Denali fault system anj is the most likely source of a seismic event of this magnitUde.The ~usitna Fault,truncated by the Denali r~ult,~isects the region in a ~~to ~N jirection approximately 2.5 miles west of the ilatana damsite".As the ~usitna Fault is par.t,of the Denali faul t system~is it not possible that a quake coull occur closer than /10 miles?'/Ie feel this certainly nee:15 more study and further clarification. ICeo10gv 19 2 dhat is the geology of the foun1ation of the dams?How far to l'c lrock?Ilhat is the formation of the canyon sijes that will be innunjatej with water? IFloo 1 Control ' Pt',.71 mentions unjer Alternative ";ources of l'ower -"A coal-thermal193rac~lity woull forego the recreational anJ flooj COntrol benefits provided fly a hyJropower project H •,~'here is the lata Jocumenting floojing and the nee I for flooJ control on the :"usitna?Is flpojing a problem on the ;:>usitna? Hecrea tionIASmoose and caribou habitat will be Jestroyel (thus lecreasing hunting)and there will be no fish in the reservoirs,what will the great recreational benefit of these proposeJ Jams be to the public?Joatipg? "ater sports?I'/hat?"5 the area below the proposed Jams will probably be ",222 194clo:je t lue to safety reasons,kayakers will probably be exclujed from' usin~the river.Also,will the access roaJs be open to the public of will they be cl05eJ 'lue to safety reasons? /d~\>.~~s Hoa,is -.exactly where will these be built -it is very harJ to tell by the m;,ps in the D::.l"."lso mileage e:otimates vary •.•ill they be open to the public?How wi Ie will the right of way be?flOW will the Jirt and gravel be obtaine J to lJuild these roads? J 1';ln~lOission lines an1 corriJors lhe Gtatemcnt is very unclear as to exactly where these will be. lIow will rieht of way be obtaineJ.?I t proposes to cross federal,state, private,anJ native lanJs.~ith increased pressure on land resource and use of Ian J for nonproJucti ve purposes,has bury ing the transmiss ion lines t)(!cn consi lert~;j?Technology is available to Jo this anj could cause much less!isruption of the lanJ.Fewer trees woulj have to be destroyeJ anj the huriei limes area coulJ be revegetated.~uch a corrijor coulJ have varied elges insteai of a ~traight swath cut thru the willerness.ne realize this '11 terna tive is very expensive but we feel it shoulj be consijere1 ~:;nn alternative to overhea1 transmission lines in the DEI;;;. :Ie also note the effect of earthquakes on overheaj transmission lines t'I'J!.i not heen a 11resse.l.tie have.some questions as to possible health h;)7.7.arls ~rouni trClnsmission lines jue to high wattage radiation.755,000' volts seems to he the critical point at which ajverse impacts begin • .;ome of the problems encountered include I 1.Olone formation 2.lnterferance with raJio and T.V.signals ).nOlse pOllution -humming an1 crackling sounj (up to 70 jecibels has been recorle.J -90 Jecibels is the legal noise limit) 4.possibility of electric shock 5.possibly health hazzarJs -increaseJ blp,chromosome Jamage. nervous system Jamage) ,ye -10 not know if any of this would happen wi th this proposed project,but we feel in the interests of pUblic health,that thi~should be lookej into an1 a.ld re s seJ in the DC:I",• ~hat stuJies have been done on strength of the wind in the areas for transmission lines?rle unQerstanj the project arouni Juneau has ha~ in~rejible problems with wind blow-down of lines -not that there·are as z:;trong win·:ls in the interior,but then whO knows?i\o ..;,ata is presented on this.What will be the energy as delivered to A.nchorage an1 Fairbanks? uhat will be lost in transmission?On pg.)it states.H~subsidiary purpose in the construction of the electrical transmission line will be the lnt~rconnection of the largest electrical power listribution grijs in the ;tate of Alaska •••"What are these 2 power gri1s?CO:.lll they:e interconnected wi thout the propose 1 Jam?·....hy is it necessary to inte rconnect them? D.:tm op~rCl t ion ;/ho will he chargeJ with operating the lam if it is built?The Corps? lIttlities commission?The 0tate?Also a very important question is what ls going to be Jone with the Hseconiary power"proiucej?The proposej project has a built in surplus of power -or in other ~orJs.it is builjing W,ly aheal of the current neeJs of the railbelt.:.hat is the purpose of this seconlary power proluction?Is the purpose to attract inJustry? If 60,we feel that this is a sellout from the orieinal stateJ purpose. "~xtra power"with no where to go will necessate car~jing charges anj as u~~il.the taxpayer will pay.Plus the fact that this overproJuction Wl be wasteJ anJ thus the rational to attract big inJustry to use it. 223 196 19'4 198 -J- Cost benefit ratio This ratio is computeJ as 1.4 so supposeJly there is more benefit than cost?Dut,looking a t the inte rest ra te which was computeJ at 6 J/8)"we ·jo not feel this is an accurate reflection of the realistic market~~e neeJ to know the cost of this proposeJ project in terms of how much energy will be used to buill the Jam,how many :arrels 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 Eluppose::l to be "lower cost of power generation"(pg.Ji how are we to evaluate the following figures of estimateJ cost of the Jam anJ transmission lines I 1.When first proposei in April 1960 -~478,874,oOO (Jevil Canyon Project Report of Commission of Reclamation,March 1961) 2,Jnn 1974 -$682,000,000 (Devil Canyon ~tatus Report,May 1974,Dept. of Interior,Alaska Power Adm.) ).Jan.1975 -$l.JI~J billion (Corps,J::'l:.:i) To our way of thinkinF"this project is economically unfesible.How can the Corps justify this outrageous expenjiture -which almost amounts to their total operatine bulget for the entire Corps last year?we jo not feel all the alternative sources of power have been evaluatel with' an "open minjOo Coull currently available power sources JevelopeJ to their fullest supply the neeJs of the railbelt?How much energy will really be nee1e I in the railbelt?What will be the net energy ~enefit analysis? ~ill other energy resources be JevelopeJ concurrently an!be available by the time the Jams are on line? I Inconclusion,we have very serious ~uestions about the lack of factual content of the D~Iv.the potential attraction of big industry199duetooverproductionofpower,and socio-economic impact that woulJ be inevitable.~e see no proven need for this project ani certainly cannot see that it is economically fesible. ":')(;,..!,~T:,:,A:.):~:,7.',I I~",t(,;- (c'''''''''L,77<"(.(/(/~'(')::I 224 RESPONSE TO COMMENTS BY ALASKA CONSERVATION SOCIETY UPPER COOK INLET CHAPTER 183 Formal public meetings to discuss the selected plan for hydropower development on the Upper Susitna River Basin were held in Anchorage on 7 October J975 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.."study is in the feasibility sta.ge,and the EIS does not include a detailed 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 de~ign 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 qalfle and the amount of habitat are minimal within the proposed Devil Canyon impoundment area,and preliminary data indicate that low populations of such animals 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 wildlife 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 or information.I\lthough up-to-date information on fish and wildlife is somewhat limited.past data--including information from the 1950's and 19GO'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. 1~7 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 ~dro1ogic R_('_c9!l_n_a_i_~..sancE'=--..Q!the Sus itna Ri ver Below Devil's Canyon,October 1974. prepared for National Marine Fisheries Service at Juneau,Alaska,and vdrious 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).Prel il11inary 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 would 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 Ibti ltlC detai led effects of altering the present flow regimen of the rlver 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. 1905ee 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 Railroad are com- puted in the project cost-benefit ratio.Benefits to Talkeetna are not. 8enefits 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 1 of the Interim Feasibillity Report.This document is available for public inspection in the District office.Access roads and all other facilities will be open to pUblic 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 pUblic.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 construction.Necessary borrow areas,where possible,will be screened from view from the access road.These areas will be rehabili- tated as necessary. 2~7 l~b Transmission line right-of-way will be obtained through standard real estute 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 qovenlillent wi 11 exercise its power of eminent domain.Yes,burying the transmission 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 electrical 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 Ihigh-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 ent it 1ed Me_d_suri n9 the Soci a1 Attitudes and Es theti c and [con_o~~i~._C_0!ls i c!eI_aJ i ons~i c.!l~l uence Transmi ss ion Line Routi n9. 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 wir:1ds. 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 1yi nq between Cantwe 11 and Healy.As stated in the EIS.the net firm annual energy delivered to Anchorage and Fairbanks would be 6.1 billion kilowatt-hours.This is net of losses in power transmission, which amounts to 0.7 percent of t~energy generated at the power sites.Tlhe 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 darn~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 Jnd 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 lOa-year project 228 life.Current high interest rates are very possibly a short-term aberration.8y 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. 199 Conment noted. 229 ~!-!Bte~__~~~~!-a~!--+-_ CHAMBER of COMMERCE October n,1975 C,·os.roods of the Air World Colonel Chnrles A.Debelius District Enp-ineer Corps of Engineers P.O.BOK 7002 Anchorage.Alaska 99510 Dear Colonel Deballus: On behalf of the Board of Directors nnd membership of the Anchorage Chamber of ComIOerce,I wish to express our total support for the development of hydro- electric power in the Upper Susitna River area. The Chamher would like to offer its services in helping to promote the con- struct ion of the Devil's Canyon and Watana dams as soon as possible _Please callan us for any further help we may provide. 51 ncere1y yours. 200 1:,d~/J~~U'Loren H.Lounsbury President sww OPI-.AtEn ,"-NCHOF(A(";E CHAMBeR OF"COMMERCE -61Z F STREET,ANCHORAGE.ALASKA 91i15Ql _(007)2.72._240l 230 RESPONSE TO COMMENTS BY GREATER ANCHORAGE CHAMBER OF COMMERCE 200 Comment noted. 231 ,jhn COlberg,Ir. JoQhWlQa 01 u..IloaJ'd October 9,1975 r I Roy Huhndorf ~>&15<~ Pleaide.lll Al~ska District,Corps of Engineers Attn:Colonel Charles H.Debelius, District Engineer P.O.Box 7002 Anchorage,Alaska 99510 Dr::tr Sir: This is to notify you of a possible error in the impact statement "Hydroelectric Power Development Upper Susitna River Basin Southcentral Railbelt Area, J\loska."On page 39 the second paragraph under Archeological Recources states 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 RCIJcr,State Archeologist,the Knik site is not an archeological site,but ~n historic townsite.It fs not listed in the National Register as an archeological site {po 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 historic and cemetery sites in the Cook Inlot Region. If you have any comments on this matter,please direct them to: 201 I Thank you. Mary Weirswn Cook Inlet Historic Sites Project 1211 West 27th Avenue Anchorage,Alaska 99503 Sincerely, 232 Mary Weirswn,Research Assistant Cook INlet Historic Sites Project MW/mr 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 lCn1k Kunoers &Kayakers,Inc. 301L~Columbia Anchorac;e,Alaslca 99501+ 17 November,1975 Col.Charles A.Debelius,District Engineer f\.La:jlca D.l.stt'1ct,COr-P8 of Engineers llcparlment of the Army P.O.Box:'700~~ Anchorap;e ..J\la~)ka 99510 Dcur Col.Dcbcliu:::;; '['lIe l<:nlk J\cll1ocr~J &:J(aynJccrs wish to go on record as opposing \J l(!C on:)true t .Lon of <.:tny d<:llnG on the Sus i tna Ri vcr.Such d,:v(.:loprn(~nl would destroy a mnjoI'wilderness whi tewa tor river, t('l~IIICd lIthe blC;C;0:Jt 1n North America II by its first paddler, Ill'.\'luI t(;I'TUaclcadar. III tho I r:l.rtlo~cmd r G:i.xtloG the Corps dammed a number of tll(~n<1 tJ on t::;f illes twill lc\',<.':L ter rl vcrs in the name of llprogres s.11 y(~t each ncw dam ::3crvcd only to spur on further profligate U:JC of cncr.'l.~Y.In oth(~r ~\fordG,these beautiful rivers were :3;:1(:1'1 fJ ~cd to no lWC ful purpose.Nowadays such ec onomic 1,ool\<.lui':C';l.c;,;~\foul(1 never vlln approval,yo t the Corps is attempt- 1n/.':to ;:;'\;tU't the':,:;<.llnC d(~:Jtructlve,wClsteful process here with ClllC;or tllr~C('llIllf'Y'~;mo::.;t spectacular,wildest,loveliest !'Lve:rtl.TI')C Susitna must De left to run free for future 0:11(.;CiJ tlon~;. Sincerely yours, / ;'-:"~...-v,..-~,-_:..-'~",::-.-"L ,,' Ed Swanson Pre3ident 234 20~Conrnents noted. RESPONSE TO COMMENTS BY KNIK KANOERS &KAYAKERS,INC. October 8,1975· rrorn: Or~h nee Clark Jr.High 150 South [3ragaw Anchorage,AK To "Ihom it may concorn, The seventh (';Tade sixth period class took tl poll,'find has decided, at the rate of seventeen to thrcn,aGainst the series of dams,beginning wi th the Devil:J Canyon Dam.\~e de cided agains t it for VIl,rious reasons j (1)that it "rauld harm tho ecology,(:?)That it 1-rould harm the natural .1 'habitat of moose"and other:wildlift;l,~d ())that it "lOuld damage the scenery,'.Jhtch 1,10.feel has bop.n <31J.miiGed p.nol~[';h. \-/0 "JeTe appoJnted to this conuni tee by our teo.cher Hrs.Stark of Orah Dor;Clark Jr.Ilir.h~Sh~~eavo us the pro!s and con'.s of the issue, find took the poll.,.,, Respectfully yours, Kris Ashley Theresa Rusnak ~o~~Comments noted. RESPONSE TO COMMENTS BY SEVENTH GRADE ()I~AH f1Fr (I J\fH',JR.HIGH SCHOOL 237 S1er1'.:1 Club 330J~Jo\\'o,/~!5 AnchOl'nc;e,Alasko 99503 15 NoYember,1975 Col.Charle~A.Dcbeliu3,District Engineer f\JL\sl(u District,Corps of Engineers J),~pCL1'tment;or the Army P.O.f-)ox 7002 Anchorn~e,Alas!ca 99510 Re:NP/\EN-PR-EN Denr Col.Debelius: The rollowin~arelthe comments of the Sierra Club on the Corps of ;·:nc;ineer:.;'dra rt environmental s ta tement on Sus1 tna l1i vel' llyclropo\'Jcr deyel opmen t. 204 205 The drort staLement i3 inadequate.Its basic fault is that it 1:..;ol1e lone;propac;anda piece,\'lith a notable lack of hard Jntn prcoentcd.Such date must be supplied in the final docu- IIlCII t :';0 thn t rCLI(lcrs cun malcc a rational choice as to vlhcther the pt'opo::;e<.1 Susltna <.1am::s arc economically and ecologically jU8tj.rj.~lble. There h~~been a serious failure to discuss alternatives to the proJec t.'I'he Federal Pm'/er Commission did the scopine ~11l~lly:;l:J to salce t the leas t-cos t al ternatl ve for.compara tlve evaluation wJt.;h the .hydro pr<f\ject.In doine;so,the PPC climl- na tc:<.l f1'om consideration severnl al terna tives ..,hich could,if allocated the $1.5 billion projected hydro cost or even lesser Li.\,\o\.1l'll:J,compare fo vora bly to the dams.These al terna tives ll\cludc 801a1')Hind,c;eothermal,and tldo.l pm'ler c;enerotion ~jr~~tCIll:~and Jnvcs tmen t 1n conservation measures., IThe DRI~recoGnizes that oil,natural c;as,and coal will be 1\1C\3 t\U r ~mo.'J or pm,cr sources for at leas t the next decade.During206lh.i.3 t1111e 1t Il1n)(C3 much more sense to invest in technoloeies l'/lllch the scoplnr;analysis ruled out and have them on line by . till:end of Uw decade. 1 /\major advantac;e of non-hydro alternatives is their flexibility. Coul plants,for cxomple,can come on and off line in response to207dcmand.Oncc a hydro project is built it I;rl11 generate large a:,lOunts of electricity rec;ardless of need.The effect of this wll1 be to attract i0dustries that need larc;c blocks of electrlclt~ I On pac;c six,it ls stated that liThe benefit-to-cost ratio compared to the coal a1 ternative at 6 1!8~~interes.t rate and 100-year 238 2 proj ec t life is l.l~us inc;Federal [inane inc;.II Surely the writers of the DEIS understand that a benefit-cost ratio 1s meanl to indicate whether a project's costs out~ciC;h its expected benefits.It 1s an internal relation3hip and the coal alternative ohould not have entered into the calculation at all, thouGh it is proper,once the DIC ratio is computed,to compare it to the Blc ratio for other projects.Furthermore,toe DEIS e;ivea no information on how this figure was arrived at.Hhat are the project's expected benefits?On page 71 recreation and flood control are mentioned as benefits,but within the body of the DEIS flood control is'otherwise never referred to. The Corps accepted the FPC scopine;study and proceeded to evaluate coal as the lea~rt-cost alternative.Coal was evalu- ated at a 8.77%discount'rate while the hydro project was evalu- ated at the 6 1/8%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's money market).The draft interim feasibility report gives a Blc ratio of 1.4 for hydro and 1.3 for coal.But the difference in interest rates seems to account for the reason the BIC 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 wel~ht 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 "front-end"costs are extremely hiGh and represent bills which fall due before any energy is produced at all.. Another flaw in the B/C study is the estimate for recreation benefits.Recreation benefits are.e3timatcd at $300,000 annually. I~fact,there are Virtually no recreational benefitc for the project and there are very hi~h recreation 10s8e3.According to the draft interim feasibility report (p.1"-3),"Few places in the world offcr the variety of outdoor recreation resources available in Alaska ..Doth residents and Visitors alike have unexcelled opportunities for recreation activities among a pro- fusion of beautiful lakes,rivers,and mountains,largely un- touched by modern civilization.II Given these fortunate -circum- stanceD,why would anyone want to visit a narrow,mur!cy,arti- ficial lake?'l'he Ha tana reservoir,with its annual drawdo\'m of frrnn 80 to 125 feet (which would be at its worst in carly June, then risc steadily throughout the summer),\'lould be Virtually unusable for recreation purposes.A boat-ramp which can allow for a l25-foot variation in water level in a steep,narrow canyon wo~ld be difficult indeed to design. The Sus1tna flows "some 130 miles through uninhabited .country'1 J (p.10).This 1s another,roundabout way of stating that it flows 130 miles through wilderness..Were the writers of the DEIS 239 208 209 21e 3 211l nrrn.ld thnt the l'lOrd ll V1 1ldcrness"miGht limlcc the river in its -undlllnmcd state sound too valuable? 212 .The :,;ta temen ts n t the top of par;e III are misleadin(';.It should UC floted 1..h.::1\;none of the:::;c rivers is Class VI in its entirety. 'l'urnoaclc C,ll'Iyon on the i\lse]c can be portaGed;thc rest of the l'JVC1'helS been run by inexperienced Jcayakers.Devil CClnyon on the 8usl~na can also bc portaced;here aGain,the river above the C'..lnyon ciJ:n be and haG been run by ]w.yalcer::;of limited experience. Les:;I::;lcno ....m of the Bremner,but the hcClvy whitewater is con- f 1neo to 1 ts tv/a c<.lnyons.'[,hc:point is tha t even a very diffi- cul t r i vcr C.::ln be utilized by 'inexpert .kayalccrs and rafters if the rapids CCln be portnc;ed.As for Devil Canyon itself instead or maldnc v<:llue jUd~ements and usinc;loaded words li]ce ('danr;erous,II the final EIS should emphasize that it is attractive to,]<ayakers preciscly BECAUSE it 1s difficult.Walt Blackadar,the first pcr~on to X'\.lD it and a heavy-water paddler of extensive exr.er- ience,tCl'med .1t "the bigc;est whitewater in North America.I . 213 r mt:Lon is made here that the SU3itna was recommended as a BOR study 1'ivc:r "but vias not one of the 20 rivers rec ommended for incl us ion in the (\V11d &Scenic Rivers)sys tem by the Secretary of the Interior in 1971~."True,as far as it goes,but it doesn't ~o far enouGh;Interior's d-2 bill is only one of several.The Susitna is indeed proposed as a wild river in the conservationists' d-2 bill,as the author~of the DEIS were surely well aware. IPoce 23."Several"ne,stinr;pairs of bald ear;les and gyrfalcons214\'IC re ol.lserved in the canyon area.HOi'1 many is "several II ?vier e there so many that they could not be counted? 215 On the same pac;e,it i3 noted that "Motorizcd all-terrain vehicle <.lCCCGG to the backcountry haG improved hunt'lnlj succcss even in the f.::lce of a rapidly declinlnc;caribou population"(Nelchinu herd).A critical factor has been ~lJ1ntcr maintenance of the Nabc~;na rOCld,\'/hich permi ts snovrmobilers to haul their machines 1n as far as they wish in comfort,then take off.Caribou-- c:.;pec lall y pre[~liaTl t cow:.:;--arc not able to Vil ths tund the rcsul tant 110i:;0 and hn raG,jlnen t.noads vue tly Increa se the ac tl vi ty of off- road vehicles,and the Sueitna dame will require roads (built at state ex~en::;e?),presumably maintuined in winter (also at state expcn8e?) •The f1no.l IUS should Investlc;a te the·probable con- sequencc~to an ulready threatened caribou herd.I 216 l'nc;c 2 11.The mop::;throuc;h the entJre dOculllcnt are poor.Only ,JOlI1cone ....,ha rec oc;nlzc8 the sllClpe of tile 8m,1 tnCl would be abl e to locClte it on the .ll1ClP3,since it 1s not labeled.Yet pt'csumably the relCltionShip of the river to the habitat being mapped is critlcol--far more so,for instance,than the location of Cordova (vlh,lch appc<:lrs on each map).Without knowing which 1 ine represents the river,and the location of eac~dam,the graphics are quite literCllly meaningless. I Hunting,pressure for rams in the Cantwell-Healy area 1s II fairly 240 • 4 heavy due to relatively ~ood access from highways,by air,and by A'l'V 1 G II (P.27).'rhe statement is true,and the Susitna hydro project would provide equally easy access for an area that 10 now w11derneoD--a road,which can al~o be used to haul ATVls on,and two or more enormous la){es to land a floatplane or slcl- plane ,on.The effect on moose,caribou,Dnd beor should be noted in the final EIS. The Susl tno area "has consistently produced l;lot'C \'Il)l Vl'l'.ll\c;j Lklll any other area of comparable :::;lze in tIle,S In Le •..•l'Jol vel'lllec have withstood human encroachmen t ond tl'Dppinc;\oJi thout ony noticeable reduction in numbers or ranee"(p.'28).Yet it has already been odmltted that the arca is prCGelltly Wilderness,so any "encroachment"so far has been huntin~lodr:;es and trappers 1 cablns--not 70,000 visitor3 a year.Would Lhe DEIS have us be- lieve that wolverines won't mind the dama,roads,peoplc,nolse, etc.?Absurd.The wolverine is an extremely secretive,wary wilderneso species which cannot coexist with highways and industrial development. Poge '37:"Ploat planes are uced to fly in hunters •••but this form of access is relatively minor.~,.•A major recreational use •.• 10 big-game huntlng .•••Th<;greatest pressures are exerted from a few fly-in camps."If fly-in access is "minor,"then how can it produce the "greatest"pressure in a "major ll recreational use? The statements are inconsistent,a frequent problem in the DEIS lilt appears that the usc of ATVls for hunting,already prohibited in some,8.'reas,may have to be further controlled.II This state- ment misleadln~ly implies that such use can be controlled,when in fact it 1s very difficult (and expensive)to do.What will be the costs of the extra Wildlife protection officers needed to enforce such a closure in an area wherefeasy access has newly been created?Who will pay these costs? Pace'38.Again,the superlative,huge whitewater of Devil Canyon is implied to be very unattractive,equivalent to implyIng that Mt.St.Elian is "no [jood ll for clirnbln[j hecause it 1s very difficult and aucce~oful attempts have ~ccrl few. lie 1'lnu 1 t exceed In,-,;ly oud ttlO t the DEIS wa~rushed'to publication jU3t before the Corps was due to receive the Jones and Jones study on recreational use and potential of the Susitna.Although as 0 consequence ~lC have not had the benefit of reading the study itself,we understand that it recommends thot the whitewater of ~lvil Canyon not be inundated,because of its great value as a scenic and recreational resource. Page 40,cner~y needs.Again,these arc mere unsubstontiated otatements.IBecausc of lead time needed for coal and hydro- electrIc d~velopment,immediate needs for the next decade will ha ve to be handled by additional oil and [jas-fired units.II True 1 even too ~enerous,os regards hydropower ,the Corps fact sheet of Oct.23,1975 estimotcs ~onstruction time at 14 years),but Beluga coal has already been leased and 1s ready to be mined,and Healy coal 1s already 1n production and has been for years. 241 218 219 1220 221 224 226 227· Parr,r:Ill.IIHcu.vy emphasis should be civen to those technoloc;ies which utilize r'cnc\'J:J,ulc or e:.Jsentially inexhaustible encrGY source:::;.II It i:..;prcpos tcrous to imply,here as elscvlh'ere in the m·:.T.'~,that the ~)u;;itna dam::;represent the usc of renewable re-, :,;OU1'<.:CG.A wllclernc:::;~;river ie:;not a renewable resource.Once cleve loped,1t 1::>des tl'oyed forcver.And grea t wilderness Vlhi te- water rivers arc 110t only nonrenewable,they are exceedingly rare,thanks largely to the Corps of Encineers. p,J.[';C II?.More r.;tlrb£l(jc c;ri'lphic:J.Ilhn t on earth do thc f1c;ures on'lhe lefl rcprC::icnl?50 J OOO I'JH/\T?On VJho.t informntion is the ;~ri;lph h3::Jeo?J[erc ae;c.l1l1 J ,\to,c nrc to accc::pt it all.faith.And itls em old,old trick to set forth one absurdly h1r~h fi13ure to make Ollct~preferr'cd alter'native look more rensonnble by comparison. Illw Lever thoGC left-hand numbers symbolize,the hi13h range lndlcalc:::;vlc'll use 19 times us many'of them in the year 2000 33 \'JC did in 1970.Even hamsters donlt multiply .that fast. Pa{~c J~5.There arc somc intercstlne;implications on sedi-, I mentatlon here,althou[';h the DEIS wronc;fully fails to make them explIcit.Thc avernce natural flow in the five high-flow months of May-September 13 19,328 cfG.If we assume an average sediment load of about 1000 ppm (the DEIS says it is "1 ess thnn 1000,11 It~<.ld In(5 the cyn ie to bel ieva tha t 1t mus t be very close indeed I to 1000 ppm)then 19.3 cubic feet of s 11 t would be fl alvine;into tlle \'Iatana res8rvoi~every second durinc;those five months for il total of 255,130,560 cubic feet (9,449,280 cubic yards),just in the May-~eptcmber period,every year.We will charltnbly225Zl.::JGume that no silt enters the reser'voir from October-I\pril. r"1cilllV/hile,of course,a small amount of silt ·i5 leavinG the ,:;y:;tcm:15-35 rrm yeo.r-round 1n an nvcrac;e flm'1 of 9300 efs. llr',aln l~ellr.;'I'ow;ly <1:J:Jumlnrr,that Ll hJr~h 32 ppm le<:lvc:::;the ~;y;;\"cln that l :..;.3 culJlc reel of.':':;Cc.lllllcnL lo~,t per second or 1),ll()O,t\OO cubic feet each ycu.r U50}l~00 cubic yards)..In short, 9,IjJ19,200 cubic yards of s11 t,sClnd and [5ravel entering the Gy:~tem every year,3S0,L100 cubic yard3 c;oine;out,nnd a net yearly ~airl of 9,098,880 million cubic yards.ThatTs a formidabl~ amount of silt.Can the Corps euarantee that reservoir siltation problems will not occur here as they have at other dams? P(J.I.~C l~(j.If I'/h1 te'tla tcr can "re duce substantially"the super- sa lura ted nJ lroC;en and cl is sol ved oxy(?;en introduced 1n to the w:).1;er in pns:;;inp;over the sp1l1"'tay,then \'Jhy not leave more Wllllcwater avallnble for this u~eful purpose,instead of sub- I lile rr',inc;nine of the 11 mile3 of Devil Canyon? P;:l~e JIG."l"utuce detailed Gtuu.lec 'l will be necessary to make sure c;cnerill chutlnel u.cc;radation \-1 on I t occur belo'tl the dam <13 the river attempts,to rcc;ain its normal sediment load.These ~tud lC~,arc to be part of "pre-cons true tion planning,\1 which the Corps v/ould have US believe docs not necessarily commit us to buildinG thc dams,despite th(;name. I \-le nrc told thv.t the Wa tana would flood exis tin~fi3 h habi ta t but ml~ht create 110ther fish habitat at hi~her elevations on 242 ·. 6 these tr ibut;)ries."Perhaps.But it I S certainly not c;oinc;to I replace :jP(:\Wl~habi ta t,which requires clean,1tlell-oxyc;ena ted ' 13ravcl;not "Ihile the \</a ton,a reservoir is fluc tua ting 125 feet 228 every summer~ Page 49.The Susltna carries winter silt loads of 4-228 ppm; earller the,DElS had termed the winter water ll c lear.II Yut the diGchal."'Cc below the dams would be "milky "n t 15-35 ppm. Both s ta temen ts can I t be true.The problem may be tha t the DEIS ,229 tends to usc flc;urcs dlstorted by extreme circumstances 'o'Jhen the mode \V'Oul<.l be more usefuL Trlv1al here,perl1upG,but not so elsewhere--n5 rcgards energy demands,fo~instance. Par;e 51,the question of fish h~bitat in 1al<es w:tth heavy Gilt I inflow.The DEIS admits that it could be a problem,but mel1tions the many na tural lakes \'Ihcre there is fi~h habi tEl t despi te heavy I 230 inflows of ::;il t.But these lakes have equally heavy sIlt flO\'/s back out,llS anyone knows who h'as paddled the Tazlina.The lalces don't simply silt up as the Watana reservoir will eventually. Also on this pac:e 1s the first hint (lithe proposed series of hi(jh-hcad dam::;")thElt the Corp::>does indeed intend to build all four dams once it gets its foot in th~door,despite the piau:><l3SUrance on page 89 that lithe mae;nitude of environmental impacts resul tine;from a four-dam system in the Upper Susitna 231 River Basin clearly makes this a less d¢sirable alternative than the one-,t\'lO-,or three-dam plans.11 The final EIS should make-explicit the Corps'intention to build all four dams. Pace 52.The problem of ice shelving in the Watana reservoir and the attendant difficulties for caribou and moose attempting to cross it is a serious one and there is no justification for glossing over it,as the DEIS does.Studie s indicate tha t cari-232 bou usc of the Hatana site for grazin13 and crossing "was minimal during the period November 1971~through April 1975.It One five- month study,on a migratory species like caribou,1s of very limited utility,yet the reader of the DEIS might well recieve the'Imprc:Jslon that it proved thr:l t caribou do not and w111 not usc the area.No such conclusion is possible on the basis of a single winter's study. Pnr;e 53.Countine conditions tn June 1971~were "1 ess than ideal.II ADF&G saw only 350 moose,whereas they'd seen 1796 the~previous fall.Unless the winter was inordinately severe,wc can assume th,1t countlnc;condit.Lons were not mer(~ly l'le3:3 than idenl":they vwre totally lnadcquQ te..Yet the DEIS men tlorts the fi13ure:J as 233 thour.;h they were Ineaningful.ADFl':.G han r113ht Cully re:Jen ted the unre<:l::::;on<.tble ha:::;te with which it has had to curry out it:::;Susitlla dam otudieu,and on a meager budBct.Cooperation from the Corps han been very poor. Page 9~,transmission line impacts.The DEIS states trere will J be "not many per sej most •••will be as a result of construction and.malntenance.1I In fact the growth the Susitna dams will foster,and the easy access ~t will provide,will cause major 243 235 7 ·r 2 3 41 .1.lTlp;:\ct::;.And a~j Gny hunter can attest,V/ildfowl tend to avoid tl·Jn:..;ml~:::;lon 11ne corridors. P;lf~C 5()."Jn Jtt;1l annual visitation to the projc~ct area would LlC'oLJau t 'n J 000 pc aplc II !Is th:LG figure part of the 30urc e of tlli1t Lnfl;:\tcd 1.1!DIC ratio?Hm'/wns it derived?If 77,000 p(~ople really did u:..;c the aretl (nfl opro~;cd t()I~Wt·i:l.~'('t'.lvln~~ by out of curlo:.-;.lty to r~lnl)C:c nt.Uk d:\ll\.wll\.I'I\\\,,1\1\,\\I:\\'\\l~) pt'ovldc J Gic;n:l1'lcant r'ccIT/lt.\I\ll:tl 1)(,1)(11.'1\'),I.hel'I\\';\c\'\~()uld he treillendou:~ly heavy.CU'1l .'I':iJlrccllltl (!JOP.2l)O)IlUndle such a vJ~jit()l'load? IP3r~e 57.rtr~uch of the 0.Y.::lstintj tree and sh'r.Ub cover 1n the Upper236~;U:;.i llla Tn vcr BJs 1n 13 loca ted in the 1"1 vc.r and creek bot toms .. ,HId on the stccp canyon slopc~;l:lbove the streams and would be lost dUl'lnE;dam con:j true tion.11 rl'his is important moose habi ta t. 237 23 239 Pac;e 61.Land alone;the Susitna Ilis'a natural and scenic area illat would prob'd!..:!:.'!.qualify for wilderness class:Lfication under lTIo:jl dcrlnlUotl~of the term.II (Emphasis added.)Under what ~1-(~{Tn:Ltion coulLl it,p08silJly fail to qualify?rrhe proposed Corps project v.;auld definitely destroy a wilderness river and area of }11Sh qunlity.That fact should be admitted forthrightly in 1.1lC flnal E13, lIThe prOPQscd trilnsmission line corridor would cross no existing or presently proposed scenic,Wild}or recreational rivers,nor vloulcl it crOSG .:tny exi::;ting .or presently proposed Wilderness ,it'ea:.;01'~'ll1dlifc refuc;es."True,but what of the dams 'them- sc 1 ve:::;,and thc proposed Susi tna Na tional ioJild 111 ver of conser-' vut:Lonlsts'u-2 lec;islation now pending beforc Conc;ress'? "netw8CO'O Gold Creek and Cant"!c:ll}a visible (power)line would. hnve substnnt1al impact,particularly if located west of the h1C)lv/;1y <:mcl railroad.II It could not be concealed throuc;h Broad ru~o.This areu provides some of the most strikinc;ly scenic view::;or ~1'c,.f1cKlllley and the impact of such a transmic:;sion 1J.nc vlD\.lld be dc;vnstotinc;.It 1s l:lppnlling that the CUl'P8 would even c Ol1~J 1der plac inc;the line on the wes t uide of the hic.;hway and railroad. 240. Irar.;c G~.How fortunate that the lImost likely"source of an 8.5 cal'thquakc would be a safe 110 miles distant.Yet it 1s also adlfllttcu that.llt.he Susitna FaUlt,truncated by the Denali Fault,lJl:Jc:cLs the reGion in ()norl;}Wl:l8t to :;ouU\v/e:jl-dlccction Uppt'OXllllt!lcly ~~.lj 1ll11c:~vlcst of the:\'!utanu U<.I11\0:1\..(:,"vll'JoL ::.;LudlCG or tile L'Liult~jY:Jteln and IIlnostlikely"quakes have been donc by 111(1(;p(~l\Cknt sel:;mlc cxpcrV~?\'Jhy doc:..;the DlnS contain no milpG or r.;1'aphic:d1cpl£ly3 ~JhoVJine;the lOCution of these fau]LG?\-J8.0 1t i'car8d thn t.1t would look a 11 t tIe too graphic only 2.5 mIles from an B10-foo\..-hiCh earthfill dam?. IPace 63.There could be ice-foe conditions 1n the area below DevJI Cahyon Dam "during periods of extreme cold weather.II The implication is that ice foe;is a rare occurrence indeed,happenine 244 8 only under II extreme II conditions.Alaskans Imow be tter.hThy dId the bElS not frankly state that ice fOG would.be present? It'o h,ll'dly a critical point.Of course}the defensive attitude carrie~throUGh cl Gevihere in the DEIS to more important rna t tel's. Page 6 1.j..liThe proposed projects will not create larc;e blocks of excess electric pm.,rer for hcavy energy-consuming industries." An amazing statement!Without some good demnnd 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 expec ted to Q;i ve up ,their rrorl(cts and go elsewhere?More plausibly,there will be a vast surplus and industry will be encouraGed 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 e onG true tion workers?'l'he cons true tion period crlould be mentioned here.The reader should not have to look up a separate Corpo fact sheet to find that the project will take 111 yearn. IJal~(:(jj.Problem:J wIth tClnpel':lluC'c.:,tlJ.soolvc.:u oxyc;en,·and nupcr- t.;aLuru.t<:d nilroc;cn "would be held to minimal,and possil>ly In::;l~nlficant levels by spillway design •••"Ii'the problem i6 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 nitroQ;cn,etc.It doesn't. Pac;e 68.II Fu ture power sys terns I'(but not this one?)IIwill also require approaches that include full consideratbn of environmental values and alternatives and must anticipate that Alaska and 'the nation will attach increasinc;importance to environmental pro- tection,energy conservation)and conservation of nonrenewable resources.II AGain 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 11renewablell resource. Pages 70,73.It is interesting to note the close proximity of mu.jor coal and petroleum resources to the cities of Anchorage and Fair~banks.S:i.nce the concept of the IIrailbel til 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.illS of the Kenai Peninsula)but U1e handful of homesteaders,elodge-owners and railroad workers 11 v ing along the II ra 11 bel t II a'ccount 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 9 I rnll~t endure the cnvJronmentD.l costs of 5trip-mJninc;for coal J and Lll'::~tl'C:;;~oC p.lpcllnc t)oom~J ou\.;arc not \.;0 00 permitted to246r'.;J1n any lWlIC r l \.;i'rOln tile develof)!nen t of our :..;tate 1 s resources? f·lu:;'-iLll UIII'coal J oil LInd G;}~be shipped to the LOVler hG for I)till?r':;\,0 u:.;c:':' 247 1';I(':C '(~).The fOl'ecast of onerc;y nccc1s is absurd.HavinG used 1.11 mUll on barl'cl:.>or a.i.l nnd 16 billion cubic feet of natural I~;~:;In V)'(~!J I'le <1l'C expc;cted to usc (under "mid_ranl3e1t estimates!) ;'()IIlUllan barrel:.;of oil (19 t.Lme:.:>c:w much)and l3!.j billion cubic reet of C;Ct:.>(eight timeG aG much)in the year 2000 I'if rccl:nt trclHl:]continue.II ~V1thout fupther documentation of tile :jC i:lIn;.l'~\nl~f icurcs J the reader mus t inev i tably think them erju.l.vClll]nt to ::3ayln(~J "If recent trends continucJ the teenager \'1111 lJc 10'6"by tho time he's 33 years old.11 iPac:e T(.The "ex trcme c 03 ts and env ironmental e ffec ts Invol ved 2 J.l\Ino::;t t.Iclal f10"1 hydroe lee tric ppoposals are maj or fac tors4OPP();jll1c;"tldal pm·ler.'l'rue enouc;h;very few places in the vlUrld LIre ~jultablc for the development of tidal power.Cook Inlet h(lprcf1~to lJe one of the best,however. IIt 1:J noL:blc th,l t the DElS finds u::;"too small"for nuclear power2490('::;0]hl ~"a:Jtc burninG,but "too big "to be allowed to usc our o"m oil "'lId gQ3. Ir~lg(~G7.The tr;ln;;ml~j:Jion line "right-of-way \'Iould provide250cl(~;Il'cd land il t 11 t tIc or no ei{pen5e to the farmer.II A danger- OlJ~;.ly 11'l'c:..;pon:.:;lble :JtLltement ,'thQt should be deleted from the r .lnn 1 \':lS.naclJ.(:1 L10n frolll hl[';h-vol taee power lines is hazardous to lIvinG tl:.:;uues. PaL~e.75.·The dlfficul ty of safe disposal of radioactive wastes 1~noted.Many people qucstion the wisdom of a system that must rely on many future e;enerations to deal responsibly with the by- proJuct~of ener~y used by this generation.Dut the same argu-251 .n :n t can be ra l:3cd in connee tion v,i th this hydropml/cr projec t. I Even if it bee olne ~obsolete,even if its i1 ts up and can no longer rroducc power J a huc;e dam must be maintained and repaired forever J elGe downstream residents \'1111 be at risk of horrendous flooel::;or mud-slidcs.A darn is a sword of Damocles hanging over the llcnds of our Grea t-granchildren. P<1Gc 9}1.\'Ie concur with the I\laska Energy Office criticism that \.;llC final EroS should lrcludc a net energy benefit analysis for the wholc ~y~tcln,lncludlnc the enercy used during construction and losses durinc lonG-distance transmission. Page 6,co~t.Total first cost .(January 1975)prices of $1.343 bJ.lllon.There was no Justification for usln3 January 1975 prices in the DElS.The Corpo I Octo}),:!,23 fac t shoet already shmvs a price Ju!np to $1.5 billion (a $157,000,000 rise--more than enough to build Senator Gravells federal office bU11ding~),but even this fieure is ludicrous.The contractors will not be paid in 1975 Z46 10 dollars.The Game fact sheet mentions a 14-year construction period.If the project were already in progress today}'it C ouI'd not be fin:"Ls,l1cd until 1a te 1989.The \....hole DEIS is filled with speculative projections on dubious grounds;why was there 52 no proJectioll of costs in October 1989 dollars?If inflation ('ontinue Gat its curren t 13~~ra te--note that \.,re are playing the tJorp~I m'Jn r;ame here--the final cost will be $8.33 billion,a s tar;f~e ring :3 urn. nut let \IS aG:.3ume that inflation will be nonexistent for the next ll~year::>and tha t there will be no cos t overruns.A modC3t proposal:instead of bUilding the Susitna dams)that $1.5 billion could be lnvested.Even at a mere 6%,it would produce $90 million a year.It could be split up among some" 400,000 people expected to live in the railbelt area at $225 per capIta.Surely most Alaskans would prefer to have the cash--253 t900 yearly for a family of four would go far toward paying the ~as blll!--and the ~enerous U.S.taxpayer would be sure to approve,31nce the ~1.5 billion principal would remain untouched. A beautiful wilderness whitewater river would not have to be destroyed}and Alaskans would not have to suffer through still another wraclcinE;cons truc tion boom. The hydro project not only makes little sense for Alaska,it I makes little sense in terms of a wise national energy policy.The opportunIty cost of investing $1.5 billion to produce power for 254 approxim2ltely iIOO}OOO people is extremely high.This large an invc~tment in projects other than hydropower could prOVide more cner~y for more people at lower environmental cost. The Dr:r;;:;uc:c:ests that I\las)ca would be dependent on .011 and gas durine;the dall1~I llr-year cons true t ion time.\-!hen th~dams corne on 1 1ne,the hydropO\Jer would the ore tically replace oil a.nd na tural {',as f",cneco,tlnc;facilities thus freeinr;up the oil and ga3 to be ~hlppecl to the LOVIer i~8.(This scenario is unlikely to occur) as e~rllcr noted,because the hydropower would probably attract li1rr~('blocle indus trial user::;and s tlmula te demand,rather than meetinc existInG and projected demand.)But even if oil and n;1 turtll cas were no longer needed.for elec trical generation,the yearly savines would be insiGnificant compared to national oil C olisumption.The DEIS states tha t es tima ted 19'72 fuel use for 255 Alaslm'8 power systems included 1.1~million barrels of oil.For pur'po~)es of comparison,in 1972 the na tion as a whole used 5.99 billion barrels of oil.(Source:Pord Foundation EnerGY Pol icy Proj ec t,Prel imlnary .Repor t.)Thus Alaska represented leus than one four-thousandth of the total demand. A major Goal of the project is to conserve fossil fuels (P.91). "ny the ::;ame token,the project would contribute to a savjn~s in nonrenewable energy resources with an cncr~y equivalent of about 11.3 million barrels of. oil,or npproximately Go billion cubic feet of gas pcr year.Althou~h this savin~s 15 a principal factor in the consideration of a hydroelectric alternative} over the lon~haul hydroelectric energy must be viewed 247 257 11 a:;(in JnLr:rJlli 11\('Z\::,U1'C for con~~crvlnc;the natj.on I s nOllJ:·I~IIL:'.lcl1d.l~c:nL:I'I~Y :jOl.1rCCG un iiI somc rno1'C lJ1'o.C- t.Lcal,l;r":l'lllalH.:rlL melhod of prccj',:cinG e1cc\.;rlclty J.:;Clcll.Lc:vcd \'Ihich \'JJ11 ilOL overblll~den the na tlon 's 01'I-/orlel I ~finite re:jources.II Dut ~la.5 b1111011 invested no,'1 in new enerc;y sources nnd con- :~Cl'VClLJ.on t;V':t:';UL'(;:;'-lould yield much c;t'cnte1'bcncfl\.s thJn the (\{'\lI1:;.'the (;()j'P:>1::.pu~)h tile Cor "pee -COJ'l0 t.nlc l10n plClnn:lnc;II funcl:lnr~D.fJ thOUGh Lin enerGY c:merc;eney DiluO-Llon,Y'Jtllcr than () ;'Ul'pJ.U:;,cX:\.~~L::;or \/111 cx1~;t wlth:ln the next couple of decades. 'I'!lrre 1:>110 (;illCTC;CllCYJ hOI-/ever.Alaslco 1:.;\Vell supplied Yllth (')l(.:rf~Y rC~;OUl'CC::;1n the procc;;s of \)eing developed.The just- rclr::a:;eel slucJy \Jy the state Divlslon of Ge010c;1c<11 and GeophysicaJ ~~\ll'VCY ;;h,,)\'/:;lha l '(11th the Prudhoe Bay c;a:J o';lned by the 'state \'Ie villI llJVC an cilllJarras:.;mcnt of cncr~y richeG.Since tl1er8 is time, tile ::',1.~)bl11J.011 or :1;3 billion or ;~f3 bll1ion of the federal LJ.xp~y(.:r8 I money.",hich tho UtltllS wl11 cos t should ins tead be lnvc::;l(~cl in l'e;::;carch for al ternD ti ve,be t tel'means of enerGY IIl'oduction}research \'Ih1ch would be a c;odscnd to the whole ntltion. Sincerely yours,: I ~J[/k S:50-~~ Jaclc Hession Alaska Representative 248 204 205 RESPONSE TO COMMENTS BY SIERRA CLUB Comment noted. 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 Camilli ss ion.Project power benefits i ncl ude fi nanci ng 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 ()6 Commen t noted. 2()7 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 6-1/8 per- cent to give the total investment cost.The present worth of the benefits was calculated also by discounting at 6-1/8 percent to 1986.The invest- ment cost and present worth of the benefits were then amortized at 6-1/8 percent over the lOO-year project life to give annual costs and benefits which were then compared to give the benefit-cost ratio. 2~l 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 6-1/8-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 8l. 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 2jlficult instead of dangerous.For more information on white water of Susitna,see response number 257. 2J3 The Corps of Engineers is aware that "The Susitna is indeed proposed as a wild river in the conservationists'0-2 bill--".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 0-1. 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 whi ch the word "several"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. 21 5 Th e 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. 2JG The Susitna River has been drawn with a darkened line to more clearly show its location on the schematic maps. 250 21 7 The EIS clearly states (in Section 5.0)that increased pressures on existing game ~)opulations through hunting,trapping,and general disturbance and harassment will require intensified game management and law enforcement rractices.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 ca ri bou occasioned by the project wi 11 "...impact upon predator speci es." 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. 220 Thet-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." 2~1 The Jones and Jones re port was provi ded to the Alaska Di s tri ct in f1arch 1975 t 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'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 t 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.1I 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~~The EIS candidly discusses the inundation River,including 9 miles of the existing Devil Canyon.The vJhole section f III hi with ~nergy nee s.The lj i na iver doe haustible enerQY 0 rce. of some 82 miles of the Susitna l-mile whitewater section in h the sentence is quoted deals t 'n fact,constitute an inex- 2G 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 repr sent kilow tt-hours (in millions)and have been so labeled in the r y'se draft ETS.The origin and meaning of the curves on the graph are 'u ly discussed in th~EIS.The mid-ange load projection curve"el cted for the Corpsl analys's is c idered con ervative.with annual rat s of increase in power,requirement less than 7 percent after 1980 as compared to an historical nnu 1 growth rate of 14 percent during the period 960 to 1971. 225 On the basis of data from r ._rVOlr projects on many types of riv rs the Corps has developed a reliable metho ology for calculatin sedimentation rates.On the ba is of this method ,logy,whi,ch includes consid ration of geologic characteri ics of the basin.iver radien prec pitation patterns,runoff harac eri ics,and topograp y the Corps has estimated that the project w 11 exceed by a large margin the lOa-year life upon \'Ihich econonlic jus 1 ication is based (it s presently bel'eved 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 he verflow structure.This would occur at an estimated frequency of once every 2 years with a duration of 14 days. The overflow struct re will be designed to minimize introduction of nitrogen.The expected impa:t of this condition is not significant enough to warrant rel cation of the dam. 227 Quoted fully,he sentence containing t e phrase "flltuetailed studies" states:"However,this p el10me on 0 1 be -he subjec of future detailed studies to determine the dis ance at hich sediment loa oul become reestdbl ished."I here is not ing i the EIS'cati 9 ha such studies "...will be necessary to ma~sure general channe d 9 a ation won't occur below the dam ..."1 is true th 'the referen e future detailed studies are recommended as part of precons ruction pl-0"g.Detailed planning of all Corps projects is done following specific Congress"anal authorization and funding of such stu;s.Following t e completion of detailed preconst uction la~ling Con ress a ~'n determines whether or not the project should e funded for construction, 2~b The [IS 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. 229 In 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 winter 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 remain 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 "milky"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 length 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 fo 11 owi ng s ta tement 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 2J 3There is no implication in the referenced paragraph that the moose count figures are "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. 264.Impacts resulting from the transmission lines,including secondary effects resu1ting 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 ";lreat to wildfowl because of the possibility of collision while others believe that wildfowl tend to avoid transmission line corridors. 235 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- Inately 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 GAs 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 qJality 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. 238 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. 239 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'i 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 ?lready recogniz2s 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. 24:~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 [IS to explain the justification of their rejection as alternatives to hydropower. 247 Co~nent noted. 248 The sentence from which the phase is quoted refers to all tidal flow hydro- electric p}2~osals.Tidal power is seldom if ever proposed in areas where it is not "sui table."Cook Inlet may be one of the best areas for such development;nevertheless,the "extreme costs and environmental effects" are the basis for not recommending it for tidal flow hydroelectric develop- llIent. 249 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 maxin~m power transmitted on the proposed system would be 345 kv. rarilling pract.ices,furthermore,generally do not expose humans to sustained, close-rdnge contact with transmission lines.For reference to an authori- tativp study concerning the health hazards of transmission line radiation, see response number 196. 251 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. 254 The ~tudy reveals that the hydro project will produce the required energy at d low economic and environmental cost. 256 2..55 Sllm\ll,ltion of :;;Lglli[Lc;tnt Ile;lvy industrial development is not expected to r('sulL from tile Susitna Project for the following reasons: I.The projected energy load growth upon which the marketability as- ~;,"nrt ions nrc b,1scd,does not incorporate significant heavy industrial development.Rilther,the projection assumes a gradual expansion of industry I>;l.'wd only on nlrcady planned expansions to existing facilities and on readily i tI('!l t if table new indus try close ly tied to proven resource capabili ties and l'l'O!lOnl1c.realities;this development is expected with or without the project. 2.The hydro project is designed to provide additional power incrementally throllf',ll phased conslruccion.from 1986 to about 1995,the Susitna power will 111,'('1 110th [nctl'il"..;cd lo;ld and displace otherwise produced by more costly stream- fired plnnts.Thl'less efficient and obsolete steam-fired plants will be ill:J,tiv<lt0d or retired. 1.There will he some secondary energy associated with the proposed 1,1;ln.Such cncq!,y is not designed into the plan,but is a result of defining t 11<''I rf rm"energy ;lS that which can be produced in the worst water year (drollght).Thus,in most years,there is additional water available to produce "sl"('onuary"enl'r~y which,bec<luse it cannot be quaranteed to the user,is IU";IIClI 1Y so I d n t ;1 di scount on il when-available basis. 'I'll('~;('condary cap<1hU i ty of the proposed plan is seasonal,occuring during L1w slimmer months of June through September,and amounts to about 12 percent of I hI'r i rm e,nergy output.Of the 25 years of stream flows utilized for the Ilpcr;1t [onal studies,secondary energy would be available during the summer months of Jf>of the years.It is estimated that secondary energy would be IIl:nl{('l cd at .:lhout 10 mills per KWH or approximately 50 percent of the estimated cosL of firm energy.Neither firm nor secondary energy generated from the SlIsltl1n Bnsi.n projects will be what is commonly termed "cheap"power even Lhough it is attractive when compared to the thermal generated alternatives nV;11 Inble for satisfying future Railbelt energy needs.Marketability analysis l1;ls tktl'rmlned th,Jt the n>quired pay-back usage rate for firm energy from the Silsitna Proiect,is 21.2 mills per KWH.1n comparison,present rates for firm energy m<lrketcd hy Bonneville Power Administration in the Pacific North- W('Sl during the winter months is 4.1 mills and less in the summer.In general, ellCrgy hy the hydro project will be somewhat less expensive than energy provided from "ltl'rn;ltive sources.It is for this and environmental reasons,that the hyur'l project is the selected p1<ll1.The resulting energy cost savings will "('('rlIC to aJ I Railbclt area electrlcty users.This lower cost energy will provldc';1 slight locational advantage to the Railbelt area in comparison to ('o"d ,I tJ nns without the plan.Signi fican t stimulation of heavy industry is n(ll expected to result,however,bec~use as noted above,the project is dl'sip,l1l"J such th;:\t available capacity as closely as possible approximates I It('proj t'C'tee!demand.Further,the cheaper secondary energy will be available (1l1 ton l rregu};1 r ;1 basis to serve as an important determinant in industrial lOGIC l0l1:11 dcclsi,on-making. 256 C0111('11 t notcd. 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 Phil ip N.Osborn Christopher Pearson R.John Strasenburgh C.H.Swanson,Jr. ,John R.Swanson [3a rbara Wi nkl ey 258 Comments 257 258-201 26~ 263 264-276 277-280 281-310 311 312 313 314 315 316 SALMON MEDICAL CENTER BOX 1110 eAI.MON.IOAHO 83467 W....Bl.ACKAOAR.M.D. "115.-2&33 BOYD K.BIMMONS M.D. 756-383:1 October 16,1975 Alaska District Corps of 'Engineers Anchorage,Alaska Re:Draft environmental impact sta.tement on the Upper Susitna Basin -Hydroelectric power development Dear Sir: I have reviewed carefully your 95 page statement and am alarmed that you dismiss the adverse changes in Devil's Ca~on in a two line insert on page 93.The loss of Devilts 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 to fisheries of Devil's Canyon is thoroughly as great as that loss would be at Rampart over a five hundred yeC\.r period. Z59 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 Canyon.Certainly some alter- native thought should be given towards having only the upstream dams built allowing future gen~ration9 to make the decision in, Devila Canyon.. Please enter this statement in the hearing record and have it show that there is·strong opposition to the Devil's Canyon dam and that this 10S9 will be irretrievable. WLB:kc -r Si~~,ly submit~d,--;'///td~)U~~c:a v{d-1 W.L.Blackadar,M.D.r 260 261 .... .,;\... '.......... \if.I ..>nlt.CI~ADJ.F~,q.D I.O.00>:1110 C'I\LrI,Q~1 Jl)AHO•B3467 . ",'- I j; ':;;' 263 -.-.-.-. '- ( ~J.t.:t.•,.U.C:-....OAR M r'\ t'.O.fJOX 1\\~..• nALMOI~IDALIO .. '.-tLI4;~7 '",-.-" ..,. 265 ?I',L ;;L.'I'.;;~A::'H\,M.!). :'.O.lJ,»:1110 (I~I.l:\l)~,IDAHO ~.'·;5T .f{,.<."--,,.',('7'\"'('l •.~,. . ._-_.._---...().....- \':',r.:r.t ,,(':~·.:,{.I/.~.,l.\.r:, :,'.f ~••'.'Y,11 i:). RESPONSE TO COMMENTS BY W.L.BLACKADAR,M.D. 2b7COnBnents contained in Dr.B1ackadar's letter of 16 October 1975 are noted.Drawings and notations made by Dr.Blackadar on 1 October 1972 (not an inclosure with Dr.B1ackadar'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 '('IA",,('\S E f"ic.~oe~r /tNd..I"Live.#OAl 1)eA,.-...,OV,""f20tAJ. 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Lv \..A-t Av"c.ou-~L~"'WA'Lvf'>+0 JI'\I-'iN~-\11<.<:)\JS,1Yv"'t r tVu'I 0'"~.r +4 ..~MA~~"1r"'j 'w<\"~,-:t'Lr,l J if\)tp..,~lIy 0 f co tN~..k~....ol.c¥j'1 J ;t s so....1-_/t1V'jM/",. ~At ~I'I Cit'"1vl hl~v"u....ilt'd )O\j,.,lt to I he CoW do,U')I""~tJ.;)"\S A b Ie.?h.Losop~') o~..Sou ('-,O~~rJf."~1 C~N A,...d,~~ould 6e.,A:\l<'Z.(~·1k<.C.0'r r 0 f X'v~i"'f"o'j feel /II'" rh ..w;....,d ~(l(o~,..~l A-~tJv<,l ..Ar f .......;bN A,L )\lot AoltSibk i ..~,....<tlf ,')'1~' ,I J I -=1 cli':>~'Y«(I.I.I.1.h('}(.(O"?il ....'\"l~rJl)IV,)()ilut;"'j ~o""')0+c,...<?r~'1 I fW(.WiW.;",Oll;-3"'''''9- -=r+;~t~<.-h,5<.1 ,vCt"..,d\~..holll~~~ 2 8 ()-t~U c.o,.J~·\6~(IotjO~$w l"i (~l\(lA."'tV!(.AiON i,..,~dlAC V-J'.~+l.~r6S~'h'IL~ ot ~(-jt..~IJ~(s.If'.}Ut<'l.>rt'~".?"'..W,U l1.{.7,oyost'd d~7 .--t4L~~O(J Vp ~ flr ~M~tu",~(of ~<~~,...;ivd<of -U<.Lor,}Iq~4 fVAlfl.'Wf\At WOvl" h~fpt'"if it Jid /V'Dt 17 1~<.-co""....,,"';hts U4+ho+f dl!,,~lorA becAv!>c:o{- ~i~('bW(t"'$vrP~wovu.b~vJ;p,J.o\Jt-. ~"I..H\At o{U£w .Ld li k 0 +{1.<.re,.·o,v?~~...f t...U ;l(hAp~I 260 ~.fk '(V\;'3("Ah.v~CA":'.b,"I~of ~<tJelcl-.j""4 tl~,rJ.·1~.<4l~J{~f;~ It-No..5~<C Q.v>iJU,;>#,.....fo b-<..~D.N~0 f U (I')'lfiS!'""'po".f,...",,!t..Ar.i· po-t>v£A.ho,,",t'rV ~<'5/-.4-t..Is ifvJoru..?.....SJ,I,v:;.u~~<....-t',..."-,.~f,,,v"""-'.2611t,J~fyn-{J,(r 1)/),~i.-vfp II.~",.l,U"I iN {.ic I-/~~o.{.d<.,t;Lc?,..,~_f -+.....A ;,...",~: I-tow v,jllL Ul;~c{{~~f ~(./IJ,q.fl"'~wt,o AY(C ~t/b~/-Sf,.,.,)o-?f of M~t;.c.W/I,.,(/-u', e,otflJ tV :;.17 /'rlot"<..rtS('~t5 ,v(erl;:~10 d~.j,o"'·..x.f{.<.(!rfee!....ItMl!-d,f-h",,{d, , ,I hrfV(0"/IJ,{.wiLd (,'k 1/oJ tJ.,t1Y't'1f /fIvd 4-LSD -H<.50(,10 -<c 0"'''';'<-~,-.,I" (".,J.""\'"~f{.~<.H..,M~r'op('{.CJ f 1''H1tS1-f"". 'f tVl,v!(j".J .f,;,.-jOJy"f;"'~!'tNd r.4f,"NCC ,-AI A~t'ly,.,v/YH1 5~J. 269 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. 261 The possible impacts of the impoundments on the Nelchina herd have been discussed in the EIS.~dditional studies concerning the wildlife within the region will be conducted during the preconstruction planning phase of the project. 27u Octob'tr 19,1975 426 Skarhnd nall . 99701 •Al.~k.Di~triot.·Corr.of Engine.ra Box 7002, Anchor~~o,Ak.,99510 We'v ..be~n diIJeo\lra~.d by r--t Jlropo".l.marle by the Corpa,particubrly thl!RllImp.,.t Dam l'rop<1".l.W~'re mnr_encouragei1 hy the ~u"it.n.'Dam prnjltct,....hich demonstrat ••mor~thorouch r~8~.rch .nd mnr ••tt.nt1~n to environmental imp.ct.th.a th't pr~ceding .tudie..However,w~co find aom .......kne~8.8 1n th~.tudy,lind we.. find we can't .cc~pt the proposal for a number of r~~aon8. two dl'M~will huv~lIome "irnU'ic.nt impact_,which we found were inadequtotdy ..t tit,.F,oirh~nb.h"..dnL~on ttl ...Dr-ft.};r~lh.t thll herr!conailltently c.roM"" t h·ri V"r 1n J\,)y,~ntl tit ..t tIl ..I?l_Jvr imrac t l'th..d"m,"em til ..hl'rd woul d be .ft the f.Ut'itnll Riw,r,b"l>i(l~th~propo~ed 'thih".r(On~rvoir.Th ..·herd norm,,11y, cro.s't~to tho ."umm"r E:roundtl north of the river in ,.t~filly I'nd ellrly Junf\., 271 information comea '[rom an Al".I<.D.partm~nt of Fiah -nd G.mt>rltport entitfed, \ "Ndl liu C.ribou :Report lt ,by Gregory N.Boe,publhh"d in April 1973 by the It 18 likely that th~h~rd would rT~qu8ntly croas the rO~8rvo1r b,for~the I· ice i.out.C.ribou .r~~xc~11.nt .wimmer_.nd low mort_lity woul~b.~Y.pected, , ev~n when l~rr.e numbers of,vltry youne c.lv~.cro~~on ice-free,turbulent ~iv.r. " Howev~r.hoofed a~im.l~c.n't cope with r.11a throuGh ice:they Arc not able to climb 'out .r-in.At b1<e Louhe,bi(lloe;inh h ..vl"observ~d c:Il,rihou broll.ldne throueh ~~wonder _bout the ~t~l)ility of th~ice on W.t~n.Reoervoir with exp~cted w.ter .nd ."':orhd mt!mb~r~of thl!public to the .re.,,further incr"."ing Illf)rt;,li ty. Thlt .ro.prltt'!~ntly ~ct,lll ae _rech:olr~e ar""for wildlife:11 lIumber ot difforel'\t to difficult .cc.a~.If th~dam.are built,We ~trongly r~commend keeping the;.cce •• road cloced to th~p'lblic,_nd wa'rl!commen,d Rot plannin'e c~rnpzdtlt.'and reereotiol1 _ro»a ~rounrl th~reaervoir•• on tncre~~~n ~n~rey uM~'~temmine from the oil pip~lin.i~pQct:-nimp~ct wo don't fexpecttocontinue.Enerr,y lIl!edo m»y wall be muchle~a th~n'the on~rG7 n.ed~you Th"Corpa'Public Brochure ~h tllcl,"t..p~rtic',11,"',rly imporhnt con3idl'lrOltion growth .nd d~v~lopm"nt,'l(p."'.11). 1••very r,..l tbnp:ltr from thh hyrlro,,1.rtr1n }'\l'oj_ot.l'r1nl"d 1y [nrthi"ru~un, we ....ouJd r ..th"r ~..e:·.for th ..imm.djate t'llture,utilb."tl<"n or ""tuN'l g••from the w.rlon't w.nt enerGY productlfft above that Dec ••sAry for the im~.di.tA tuture, .1.c~.x~eft."nerel could .timul.tA,10t onll induatrinliZlltior.,but waftteful .a~rgy U8.--.b.d h.hit for the ~ublic to d.v~lop.We reel th.t it i.poor ~l.n.i.g to d.cid~to build a d-m before kno ....ing ....h.r~the ga.pipeliD.will go • .....kDO....of 110 dl\M with.projllchd 1if.ti""of ov.r 100 Iura.Hoover dam wa • •leo predict~d to hev"..low .llt-tio.r ..t~,lORd it b.e~"ilting up berore coa.truotioa ~~~comrleted.hnat would the ben.tit/coat aft-ll~i.look 11k.if the projected lifetime w.ft 100 year~or le_~,rathAr than 500 Iear.?w.!o~l thl.would b...more r ••li.tie ••timate. but for it.value ....wild.rn ••••·It .)lergy 1a rully Dece::...ry,\OIl!approve or hldropower projer.te Oil em.UfOr IIc-l....".f ..1 th.,t th.Cu,.itu River i.the wrOllg I "/7l~1 ~~ .Mary Ev.n .. 262 wilfJ-ite m.~;:;;t major,.u.ot A.~)~J'l,~'~~~- D••Hutto.nen wildlir~m~n.~om~nt major,U.of A. ~<.:r<..~;fn-r- Bob Fox TVCC in"tructor .273 . RESPONSE TO COMMENTS BY MARY EVANS,DAN HUTTUNEN,AND BOB FOX 2.GZ (\llJlJ1l('l1tS ~Irc\n01ed. 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 s(~vera 1 sources inc 1udi ng the A1ask.9.~i ona 1 Profil es--Southcentra 1 Region,July 1974 and the State of Alaska,Department of Fish and C;-(-Illle's Alaska's Wildlife and Habitat,January 1973.As stated in the CIS-;--Ii"Warmer--weather and a raprdly filling reservoir should eliminate any adverse ice cor,Jitions during the month of May."The I11cljor 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 rart 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~intcnance,the useful life of the proposed projects due to sedi- mentation 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 Jll Federal hydropower project evaluation. 274 SEA AIRMOTIVE.INC. Mr.Chairman,Ladies &Gentlerren: My MIre is Ward I.Gay.We operate Sea Ainrotive,Inc.at Lake Hood, ., an air taxi operation.11:have lived in Anchorage for the past 40 years. and have seen a lot of changes here. we have needed the Devil Canyon Dam on the Upper SUsitna River for 20 years and,in fact,I f~ew personnel on survey trips of this dam site ITOre than 25 years ago,before any gas or oil was discovered in Alaska. I also ranember when,the Eklutna hydroelectric plan was first proposed (before WJrld War II).The original estimate was slightly over six million dollars.When we finally got around to doing it,the cost was in excess of 32 million dollars.'llie big delay was because we did not ~ that much pcMer.Then gas was discovered at Kasilof.The people in .·1 J\ncoorage ~ted gas,so we voted a 20 year franchise to a coopany and built a pipeline fran Kasilof to Anch:>rage that we are still paymg for, even though we have 'natural gas right across the inlet fran us that there is no use for.Chugach Electric has built a ~r plant at I3c1uga,that should have been in Anchorage,but the gas was cheaper at I3cluga even with building 2 ~r lines to transmit it to Anchorage.It seans they can bring the p:Mer 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 rraking rrore mistakes,lets build the Devil canyon Dam on the Susitna and furnish ~r to the woole rail.belt.This will be utiliiing a natural resource that is not expendable.'n1en the natural resources that are expendable,such as na tural gas,oil and coal can be sold to other states . and countries that are not as fortunate,as we are in having an aburrlanoe of water. 275 SEA AIRMOTIVE..INC. It has been that this dam \\10 troy wild game habitat and calving gJ:C~1s for cariOOu.I took ~hunting party to the Fog lakes in the fall of 1947 and have hunted t:her:e f!!Ifer.Y year since.I have seen thousands of caribou go DIn the bank and 'swim the 100.y~ of river ar:.d go up the other'side,seldcm stq:ping the small spruce timber because they know they ar VU1I'Ierab1e to \\101ves and bear in the . .i xl there is VerJ llttlefor \:nem to _ .I have never seen a cr::M have her calf down iri the canyon.~y like the hills above· see and run •.This &0 -lies to ncose \with the darn built,the caril:x>u \\Quld only ha:-swim across a 1/4 mile lake.That is nothing for them or -either,or a grizzly bear for that rratter.'Illere has never u!y f in the _tna drainage atx>ve the dam ..'te.Even the sa1rron canoot the whitewater in the canyon.'!he lake could be stocked with fish and m¥ie a ~erful, accessable recreation area that the people of the rai1belt are already in need ,of .The garre animals are nearly _i.n this area now,mainly because we have protected.the w:>lves for the 18 7 years. ,changed in a few years.!.think the proper people ha ,can k:e learned that nan eanrot allow the other predators to increase,unlimited,and stUl have the w:>nderful garoo paI!a41se that he es ew. 2 I . 1 s '._~r1!~.dv/Ward Gay .' 27 ' . 263 Comments noted. RESPONSE TO COMMENTS BY l~ARD I.GAY SEA AIRMOTIVE.INC. {{tJl4 ~bYU:f!i~ &/~';1002... a'U4U'7't2~t'4.'19:710 )~L'LA : 278 I 264 /"..~ 265 ,t{{-i<f<'>IVYJUMk CW -I-'a~g-"d :/i~-. ~.J7~~ZXt A/L;/Sr~~~£"'/ U!~~/~~~~~tAAI ~y£LCr .MU/t~:AJ-AU'/l-VL-~~~_.C~~;4 r~. l- I0/It/:'t J /'uV~/.0 j)A~~I~7'au:-'h -.'. 266 /Z~U<-r#~~£4~/~A4/;~~~?~a'~ ~CEH--~..<--d:~~24 ~~~~~/ 281 ~68 269 " 270 271 282 283 84 285 275 276 WETLA of the UNITE 5 THEIR EXTENT AND THl:::IR VALUE TO WATERFOWL AND'OTHER WILD FE Bv Samu<!1 P.Shew and C.Gordon Fr~di"e ClR U R 39 FISH AND W LDlIFE SERVICE UNITED STATES DEPARTMENT Of THE INTERIOR THE PROBLEM OF SAVING WETLANDS The great natural wealth that originally ma.de pO!lBible the growth and development of the United States included a generous endowment of shallow- water and waterlogged lands.The orir)nal inhab- itants of the New World had utilized the animals living among thcse wet places for tJod and cloth- ing,but they permitted the la.nel to remain essen- tially unchanged. The advent of Europcan settlers brought great changes in the land,and aquatic habitats were particularly vulnerable to the settlers'activities. Kellney allll McAtee wrote in 1938: AmonR the Bllllds of mllnk,ind,wildlife receives its true apeml~a).~.0y..'~l~ltn~c(l stnges 0,1 ~_v.J.i~aiion'L when, OWing to till'hl~l~11l1'8H d~lltrllr.tioll of earlier times,it hilS '~\!ll R,~rillllKly 'if not,irr'"pamh(reduced."·Under pioneer co~ditinllK thf;rul(,l1 for Ule treaCmrot 0 wildlife are imme- dllitl:exploit.ation of the ulleful and drnstic destruction of the IIst'lelll<,l\lId thellc rules tend to remain in effect long after the original mot;vell are gone,In the earlle,r stages of 8clllllmCill no on~thinks of allotting any land for the use of wlldlHc;th~~fforl is to wrest every pos8ible acre from ol\lu rc\I\nd milk"it yield an incomc,There is no vision to ~~C,l.ht'r"i~no time to learn,that land uni\.$with their OR/,ural oCPlipllnLK,Il8 exemplified by !J,bel\~~r me;;:-dow,a mU~kn;t nlt;rKh,n duck lake,a deer forest,or an antelope nH'Nll,I\rc produdivc eJltities thl.\t under certain circum- 8tnnCC'R may b ...worth far Illore than I\lIything lTlan ciln put In their ph\cl!Ilnd that once destroyed may never be ro- eatl\bll,~h"ll.'[7)I ... THE NATURE OF WETLANDS The trnTl "wetlands,';as u:'lrd ill this report and in the wildlife field generally,refers to lowl~nds covrr~<.1 wit!'l shallow alit!somctimes temporary or illtermiu,l-'nt waters.They are referred to by 8uell n1Ull{'S as marshes,swamps,bogs,wet mead- ows,potholl's,sloughs,and river-overflow lands. Shallow Ink"fl and pOlldR,uSllnlly with emergcnt vogel.nt.ion I\S It conspicuolls frlltllre,arc included in the ddlniLiol1,but the perma.nent waters of 8tl'ellm~,reservoirs,and deep lakes are not in- ,Il911c I.urnb,.'",In hmckrl.ror",Lo Ilo",~In the Lt.lor R,'rrrnc,'.on l'ON"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 Lemporary areas are of no appreciable value 1,0 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 'Yaterfowl and other wetland wildlife no longer grow in abundance.These aquatic plants need waterlogged or shallow-water soils in order to thrive. Apparently,a great many people still think that until one of these two courses is fonowed,any wet- land area is just so much wasteland-..an unfortu- nat'e 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 PLANNING State and Federal agencies engag~d in conflicting programs of wetland drstruction and wetland pres- ervat.ion must work together to develop unified wetland-use programs ~hat are both acceptable to the landowner and beneficial to the Nation. It is one-sided pla.llninR.for example,if a flood- control agency neglects wildlife ~a ues as it plans for the elimination of river-overflow areus,when these areas are used by millions of ducks d II ri rig thc winter sea.son. In land-use planning,an o'gcncy dellJing with drainage projects would be subject to criticism if j'ts plans to remove water from Icnsivc Dlll.l'sh- lands or scattered potholes were d~l\'doped without regard for the fact.that,individually or collec- ti vely,they proY ide essen ti ltl habitat for tho lIsO,nds 3 SUMMARY OF CHAPTERS The problem of saving wetlands is to ])J'C'Hnl IHllrshl's,swnmps,0Pl'fI sllH.llow wlltrrs,!Il1d :scu- s(Jllltily lIllOtkd JIIIJ(ls from being rll'>li11I'd,floodrd, orlilll'd,1\1'1)('('losing lh(·il'vnlul'as wildlife hnoitn.l. TIII'~'l('typros of lIC[llati('('11\'ironlllenls,c.oJlI'ctin')y idl'nlifil'd in this r\'flOr!liS 1J.'I'f[a.nds,flll'llish l'ss('n- tiltl hllhilo1 for 1111 wl;ferrowl,most spe(;ies of fllr lI11irllllls,lind IlHlIlY spe('il's of fnrm gumr,forrst. glllTl(',lI11d \\'Ilrll)-\\'nler fish.Coordinated IldvA.llce pin lining by all r/,501Ir('.e intrn:sts is the keynote to snl\';ng Lll<'prohlem.As IIIl nie!in such plnn- nillf..(,llw Vish nnri Wildlife Sl'l'vice,with the coop- l'rld ion of St III r gnmr Ilgr'IlC',ics,('.ollducC('d 11 wel- Illnds ill\'I'n\ory with clnphn.sis on presrnt usrflll- nf'SS of 1111'lflnns fiS wntl'rrow]habitue. A (('nlury of weiland exploitation hilS taught Inllny !f'SSOIIS in thr \lS/'lind mislise of wrLIllnds. Thl'SWIIITlJl LA.lld Acts of 1849,1850,uno 1860 pH \'rel t1l('WilY for l fIl.nsferring nPArly f)5 million RapS of w('llllnd~in lS Stntes from Froerll.l t.o StaLe ndlrlinistrlltioJl for the pllrposr of l'xprditing t,!reir dl'llinllgp.NeRrly 1111 lhese lfillds I1rr now in pri \'/1,1,1'own('rship,I\nd thpir use by wildlif{'is usu- ally only a minor consideration.Although evi- c1('TlCPS of wetland losses as revealed by previous in\'l'lIt.ori('s arp nol.eomplrtely r('liable because t.hey rl'prps/'nl.c1ifTcrf'nt types of cov{'rage,it npIH'arl-l 1hat.at !('l1sl.45 million of the original 127 million l1crrs of nR.tural wel.lunns have been drR.ined or otlH'rwiR~destroyed.Agricultural.drainage (102 million Ilcres now in organized enterprises) alld flood control are thE'forces primarily respon- sih!l',hul.oth(~r R.etivities sllch as cana.l construc- t.ioll,drainllgE~for mosc"uito control,industrial ex- panRion,and highway bllilding have great!y re- duced thl'.wildlife values of some wetlands,partic- ularly along the ('.Ofl.sts. 44 Wetland soils ho\'('physical und chrmicuJ Pl'0P- ('flirs thnl fire dC'l'iypd from the rn\'ironmrnt in which th/'soils ol'~jnnt('.Climale,Inlloform,llnd Ilative vegl,tRlinn Inrgl'ly govern the nnlllI'r of this ('nvironm<'nt,hence filso thr nnturr of thr soils lind their potential llsrs.Most wrllnnds arc 1I11dprlain by organic soils known as peot nnd muck,or by rrcenlly deposited,walC'J'-carrird alluvial soils.In gt'ncml,allu\'ial soils have highE'r 'ngrieultllrRl potentials than prot find muck. MRny peat and lllllck soils,have proved lI11proouc- ti ve for agricul turr oft er dru inage;0 t hers Rre in- herently fertile.In JnR.ny areas,then'npprfirs to he a direct rrlalion between potentially good ugri- cultural wetlands fwd prcsrntly good wRterfowl wet.lfl,nds,sllggl'sling that competition betwE'en !lgricuhural n,nd wildlife'inteft'sts will becomE' more inlense in the years ahead. The wetlands inventory rc\"rals the loc.a lion, ('.1 llssificat ion,find rxol uut ion of 74,439,300 acrE'S of wCllflnds as wutedow!hR.~itat.A.I I('asf 90 percent of nil wetlands of imporlance to wotC'J'fowl are included.From the standpoint of waterfowl value,the total acreage covered by the inHntory is distributed as follows (in millions of acres):8,9, high;13.6,mod('rate;24.0,low;and 27.9,nE'gli- gibJe.Values are based on rel£l.tiH 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 a.cres,and the six coastal saline types comprise 5,290,000 acres. The 20 wetland types are ecological classifica- tions designed to help recognize the reJati\-e im- portance to waterfowl 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. 265 Comment noted. 266 The 6-1/8 percent interest rate is provided by Water Resource Council, and is based on the current cost to the Federal Government of borrowing money. 2f.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. 272 Comments noted. 27:,Comments noted. 27 4 Commen ts noted. 275 Comments noted. 276 Comments noted. 289 290 291 280 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 t.o maximize the beneficial impacts. 278 Alaska 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 "rea l worl d." 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 5UITE 403 :I 10 "K"5TREET ANCHORAGE,ALASKAS900I (907)278-1322 (9071278-1443 October 9,1975 Colonel Charles Debelius District Engineer Alaska District U.S.Army Corps of Engineers Box 7002 Anchorage,AK 99510 He:Written Testimony Concerning Draft Environmental Impact Statement Dear Colonel Debelius: I am enclosing with this letter a copy of my COlnments 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 excluded a body of knowledge which,if available to the general public,would have permitted a much more thoro~gh 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 l\laska 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 yo~r Environmental Impact ~tatement.I believe that the firm of Jone~&Jones,ConsultanLs,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 sgecific 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 Statement. I believe that the deliberate exclusion of these two relevant source nta"terials,and the lack of public knowledge of their conclusions,has dealt a very strong blow against 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. Yours sincerely, 281 1 TEM/bja Enclosure Thomas E.Meacham 294 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 ADF&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 DElS 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~mNTAL IMPACT STATEMENT: HYDROELECTRIC POWER DEVELOPMENT ON THE UPPER ,SUSITNA RIVER BASIN~ALASKA October 7,1975 Gentlem~n: My name is Tom Meacham.I am a resid~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 concept 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 fnct and assumptions made in your Impact Statement. Instead,this hurried consideration of the Impact Statement seems designed to nullify or eliminate any meaningful criticism 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 pe 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 preserit envir6n~ental analysis,that anal- ysis must be as complete as any required under NEPA for any spe- cific A8pect of actual hydroelectric·plant construction.The 296 ~. Comments to Draft EIS October 7,1975· Page two. writers ot this Impact Statement have,with no statutory authority and very little actual authority,determined that hydroelectric power is the "most feasible"means to meet the area's presumed future needs,and have,without further analysis,proceeded to present the details of the proposed dam construction.Questions which thoy have left unanswered are t~e following: 1.What is the source 6f any assumptions regarding population growth and growth in electrical de- mand in the rail belt area?Are there variations 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, use of natural gas,geothermal resources,or any other available or projected source'in Alaska?If studies have been examined regarding these factors, what is tne source of these studies? 284 285 1.Will hydroelectric development in tpe rail belt area discourage use and development of alternative .,'I 286 sources?will other sources develop despite con- struction of 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 .0£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 .Statem~nt deals with ~he reality of a two-dam construction proposal,I have some 297 Comments to Draft EIS October 7,1975 Page three. 287 \ QUestions to raise-concerning that proposal.I feel that there arc several very serious inconsistencies or unwarranted "assumptions made in th~t Impact Statement,and I feel confident that satisfac- tory answers will be provided at the time the final impact statement i6 written.Among my questions are the following: 288 290 292 1. ,2. 3. 4 • 5. Is the capacity of the Devil Canyon-Watana project excessjve?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~. What 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 secondury energy?will sale of secondary energy be subject to regulation by ttw 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? I' 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? 6.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 Susi tna 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 ~ave upon erosion potential? 9.Will multi-level releases of water from behind the dams lead to increased siltation during re- leases',whenr water and silt from the bottom por- tions of the 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 consumption 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 oil~ 14.How much oil would the total first costs of the project buy at today's prices? I 293 I 294 I295 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 darn site,and does not calculate., 299 302 Comments to Draft EI$ October 7,1975 Page five. power losses. .303 1G.What factors were used to calculate a benefit- cost ratio of 1.47 Why was an artificially low interest rate of siy and one-eighth per cent used?Docs the nature of this project,on·a glacial river with no presently known technique for dredging rcscvoirs filled by sediment,jus- tify a IOO-year life projection? 304 17.·Upon what factors was the IOO-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 D~vi1 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? 20. 307 Why hns the proposed project been stressed for a ,.maximum credible earthquake"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 vo~umes. 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 Comments 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 !the Parks Highway.Recre- ational white water boatihg is one of the fastest-growing sports 1n 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"witil 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 \~hich you foresee as a result of construction of the project,and Iuponwhatfactorswerethese 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.·Based upon the content of your' Draft Environmental Statement,I have found no compelling reqson why Devil Canyon 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 delegation. Please include my statement in your record of oral testimony 301 308 309 310 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~~ltal Impact Statement'concerning hydro- electric project feasibility in Southcentral Alaska. Thank you very much. ~{.~ Thomas E.Meacham ' 1410 "B"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~t of its availability in the Federal Register. Such announcement was made in the Federal Register printed on 3 October 1975.Thus,the peri~d 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 involves 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. 303 283 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 (ErS)must be prepared outlining for publ ic scrutiny (and review by Federal,State,and local agencies) the s_t.9_n_i fi ca~!:.illlpac ts (both adverse and favorable)whi ch can be rr.~sonably 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 IllJjor areas of discussion.They are:the envi ronlllcnta 1 impact of the proposed acti on;and adverse env i ronmenta 1 effects 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 EISls.The feasibility report is a separate and distinct document which examines in detail many of the questions you rJise.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 [conomics--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 fcasibility study.Data from all available sources have been utilized.Coal is found to be the major alternative to hydropower. 286 Hydrodevelopment mayor may not supplant development of alterna- tive Dower 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 1990 l 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 "firm"energy as that which can be produced in the worst water year (drought).Thus.in most years.there is additional wa ter ava i lab 1e to produce "secondary"energy whi ch,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. 2~1 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 "flour"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. 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. 297 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 constaht hourly hydro- graph for the river reach below Devil Canyon. 2~8 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,immectiate,built-in solution to the problem. 2~~The estimated Railhelt 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)}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 laO-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. 3l)2 The quoted 6.1 billion kilowatt-hours reflect the net annual power delivered to the two distribution centers,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 lOO-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 determine any valid correlation. 3u 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. 3 U 6 F1 ood 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 more 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 sed iment load of the ri ver is a ttri butab 1e to eas ily 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. 30B ·The DEIS and feasibility study do not slight the recreational potential (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-propelled 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-hi king-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. d.iJ;Comment noted. J(J philip n.osborn •geologic consu Itant U·92ND AV F..N.E.•BE LLEVUE.WA 98004 •(206)45'-3588 17 October 1975 Col.Charles A.DebeliuB,District Engineer nepnrtment of the Army ~laaka Distriot.Corps of Engineers P.O.Box 7002 Anchorage.Alaska 99510 SUBJECT:Draft Environmental Impact Statement:Hydroelectric Power Develop- ment,Upper Susipna River Basin.Southcentral Railbelt Area,Alaska Gentlemen: '~e following material is Bubmitted for inclusion in the records of the public meeting of 1 October 1975,HE:Southcentral Railbelt Area,Hydroelectric Power ~tudy,and as specific comment in reply to the Draft Environmental Impact 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; ~Susana River,Alaska:E!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 which may ensue construction of the project.I have thoroughly reviewed the Draft Ers and have personally communicated with Mr.Yould and Mr.Chandle~. Respectfully Bubmitted, '1Jtl"N.({k~h11ip •Usborn Geolog c Consultant Ene. 310 pacific northwest and alaska geology •grou nd water resources The Draft Environmental Impact Stateme~t for hydroelectric power development 1n the Upper Susitna River baain contains insufficient data within the geologic discipline.This data is essential to a complete and adaquate evaluation of the proposed project - -ita merits,benefits,and costs.Specifically: 1)The geologic map on page 16 is incomplete;faults which transect the Sueltna Basin are not shown.Major faults intersect the Suaitna River down- stream from Tsueena Creek (SuBitna 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 faulte exist within the study region" they may be presently inferred or unmapped due to the immense area and the lack of detailed geologic surveillance. 2)The geologic map ehows no indication of structural features,partlcu~ larly in Devil Canyon.A larger scale map should be included showing faulte, 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 0 W.and dipping 800 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 o ..approximately 50 -60 south are not shown (Kachadoorian,1974;Osborn,1974; Jones and Jones,1975). ~)There is no mention of actual movement along the major faults within the 8tu~y 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 ~'-post-Pleistocene displacement of 120m measured and 200m from aerial photograph interpretation; Totchunda Foault - -post-Wieconaan displacement of 270m (Page,1972); Sualtna Fault - -11 km of displacement inferred from morphological expression (usborn,1974) 311 4)rhe possibility of an increase in seismic activity as a result of reservoir impounrtment and fluctuation is not mentioned.Noting the immeqiate proximity of the WatanB reservoir to the Susitna Fault,this possibility shoulfi he considered.This phenomenon has been widely recognized and io well documented, e.g.,incre~6e in earthquake activity following tho impoundmont of Lnko Mead behind Hoover Darn lRichter,1958). 5)There is no mention of the recurrence periodicity of rrreat earthquakes tgreater than 8.0)within Southcentral Alaska.A great earthquake may be .expected approximately once every 30 years tSykes,1971)or 16.7 times during the reasonRble lifespan of the dam structure. 6)Larr-:-e portions of the Upper Copper River basin subsided during the March, 1904 enrthquake tPlafker,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 bnoin should be analyzed.It should be noted there is only 162 feet of elRvation gain from theWatana full pool level to Lake Louise.There is· a high probability that the Copper River system has been the outle~for the Upper SUHitna nrainage at least once and possibly several times during the geologic history of the Upper Susitna River tOsborn,1974). 7)it is absolutely irnparative that the possibility of a seiche generated by seismic activity or landslide within either reservoir be considered. TheBe standing waves can have devastating effects,as evidenced at Lituya1· Bay tM1l1er,1960),and have been responsible for several overtoppinga and dam failures 1n hiRtorio times. In addition,the following geomorphological problems and questions,should be addressed. 0)Row 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~rm is the Susitna drainage.) 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 -90%of total)when discharges may exceed 90,000 cfs,the existing data ~.B inadaquate to allow volumetric extrapolation for a 100 year period. 11)WhAt'effectA will fluctuations of the Watana reservoir have on solifluction maee wRsting and will there be a substantIal increase in shoreline erosion? r I 12)What effeots will the transmission corridor have on permafrost in the area of traverse?How w111 the transmission towers be anchored to prevent dialbcation by heavin~.of the disturbed surface? ~eee and many 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 Impact Statement. ~!l:n.M~1 Geologio Consultant 311 313 ,Jones f.U'10 Jones,1975,~Susitna River,Alaska:An Inventory nnd Rvnluation of the fnvironmentnl,Aenthetic,and Recreational Re8ources.rrep~red for Alrwka Dlotrict,Corpo of F~1ISineers. Kachadoorinn,R.,1974,Goology of the Devil Canyon Dam ~l1to,Alaaka,Q.~. Gr:ologlc;ll Survey Open 1"11e Report 1.A=AQ. Miller,D.J.,1960,Giant Waves in Lituya.Ray,Alaska,Q.S.Geological Survey Professional Paper ~. Osborn,r'hilip N.,1974,Geologi~Reconnaissance of the Upper Susltna River WRtersherl.Prepared for Jones and Jones. Page,Robert 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 Ala.ska FArthqunke,~cience,v.148,p.1675. Hichter,Charles F.,1958,Elementary Seismology,San Francisco:W.H. !'TeemM and Co. Sykes,Lynn 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. ",'1 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 'of 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. 3i-S Ch rl~to r hQ r Pe.C4n(/lo'O (i..~ophy\,('",\Insf.- tull eq('It k <)+C-\k hu ~CA Y\V 'Y)e e J t~t 'lYI C/'-<:t hc.,'"I;)5,-111;'~ P""'P 0 SFthuit"'~two"UUM~Oh +hl vppec SUSlthq rave....wClvlJ p r ()J v (.Q •I t hi Y\\\t h~-\+-ht pro')£c.J-~~of e ne r'1 y J l?/rt\CNhJ J v 'n ot ;0 h-(1h -h>CH..L-OVN ~ CA rnJbCA,bl~Jow'v\tUfh In -\-k r GI t Ii'0 F e.n (>r(n q rtf YI. 11'\t~F=u,,-blA'\hj Clru.(Afk.- -t~p I iH I,...'\.~rj FI h.,h~. I t h \V\h.t '"",1 O.ll t\O~l 1.)...1.' ('Cl.~Oev,h C.CAY\t~d-i1-.t p.(.l-t"~h JCAm\.t). Qr"t.m 0 \.\.re CA.?(Jy..~'0 ~;2.t h.t.Y .. h u \(t..+h ~C-4 d cJ e J a J v G1 n +-CA.~ Clf FlooJ \~~\~~lo.nu.l thuJ W 0 v\J 'h u Vt (A ~~t4.\,tr e.~\f I t"t1l'\l'A~hJ\ 316 I ~p().(,~..I Ja th.~h thCJV~~ th~t ,F-~J c:A vY\I )-+0 b-t b (Jl \t \'n Al<4~h"t-ht SU s-it~. ~(p l U(A Fen-It,t'V(f 1~ ." - - 312 312 Comments noted. RESPONSE TO COMMENTS BY CHRISTOPHER PEARSON P.U.Box 171 Anchorage,AX 99510 October 11,1975 enl.Ch,1.r)C1s A.Dcbcllu3 Dl:;td~t l~r.cln~e;: Al~~~a ni~lrlct,Corps of Engineers P.O.Box 7002 Anchorar.:c,AK 995)0 Dcar Col.Inbellu13t I am wrlLlnc 1n ~encr::tl referenco to the Upper Su'sitna River ProJoct. AIUlou(~h I <'ll'tl nr:a1.n:;t.'_,10 project for onvironmcntnl and social impact l"('n~()n~,T wOllIn Itkt:.'to focun my comment:3 on i\specifIc part of the :Jtudy.The fall OH1 nr:comments,thereforc,h~ve to do \011 th the trans- m1.s:::lon corrloor,call(~d alt~rnatlvc "SUGitna.-l"1n the Scpte:nbnr 1975 draft of till'Envlror.r.:cnt.:l.l AS5CGnmcnt of the Susitnll Tran!}nic:Jion :::y:3tcm, which raralJcl~th0 Alacka rral1rond between Talkeetna ano Gold Croek. A-:c.a f-"rl-ycar rc:',lricnl of Lnne Creek,located near ll1\lc 241.7 of the h}11.r;!:.,\lbllrC1ad,1 am riceply concerned about thtG part of the project. I am not alone;there nrc hundn~d~of pcoplo who 0 w'n or lC<.I.r.e land and Hho havo recreation or res1dence cabln3 1n the n.rl!a afT0.ctei.!oy "SlJ~ltna~l" between Talkp.ctn:.1.<ln r)Cold Crcl"'!<.A~ce::;:;road~wi]1 rul n thi~urea, hrlnf:1ng 1n larf,c r.llmbcr~of pcnplc and nIl tho uttcnrlant.problem".which tfl proci::;~ly ~ltnt mc:-:t peoplc "ho bull t 1n thiD nt'eLl ~:(lntcd to get aw.lY from. Tn add t tlon to tho road~,the transmio5ioll towcr~,lines,and cleared ilrea::; 104111 ~un~lc;ht]y ilnd nn impairment of the wilderness cnvironr.wnt. In nmd.lng the above mcr-tioned d~aft,I W<lS :;urprh\crl and dlr,tre::;5cd at tho incomplet.e nnd nIl::;)cadine irlformation which 1 t cnntn1 ncd.I 3,r.',rcferlng here t.o lhe rn-t.rl ~c~<lnd supportlne text for the 8nvlror.loenta.l ASGessment and Rnvlronmenl·,a.l ~mpa.ct ~('ctlon::;.Although the d,r;1-rt "COlT.::;to have been intond":d 1\:::;·1.sl\pcrficb.l study,the orrors I w1.11 noLe arfl ~o glarinc that thp-y r(Hl\llr~r.omll1('nt and COrTt!ction before tho draft i~Il~"d \1.[;a basis foY'::I.11y doc1,;lor.~. The matrix for th:b ::;eGment of "Susitna-l"'under ExisUn:.:;Duvclopment:; indlcn.tc ~cvcr:l:'.)'"nro;:l.d ~t()P:1.of Hhich ·Lane'is O(ll:.l.arw is not even ,l fla(~r:.1.nr.:\l\d il:t;;n·t bl'0n for many yearn.Tho cUJT.~nt flac:stops arc mile 232,23).5.2)(,.?')13,/f,239.5.2h 1.7,2/~/~.6.anri llt.lJt~n;nnrth to Gold Creok. roAch of ~·,he:-.r.~~t'()lJ~.rcprl~"I~nt :;rr.all c0:nmun1t1c~nf.:l.cr.atturcd three to ten calJln:1 l~ht<:h I'!:l'J11(~UC(~for ror..rcoltion or re~~1r!0ne(',mo~·.t.ly the latter. The }ol;:atlor"of'~h('c.,\l!in!;1':1nl.:0 up to thrC(~Milne,~!1d occa.i~ionally furtbr.:r.fp'n th~r[l~lro~d tra~k:::;.The r.~trix for Tnr:lct:::;unr.er r:x1Gting ~veloI~C'::lCn'::".lnd1(~;t~fl::;no impact in thi~area,althouch 10l,er down on the p.i,~t>.~:~tr.I1h.'1:1 !,.1.kc cnbtn~are M~:lt10ncd.The t0xt b.:C(F~l1y incompletc. hf<tct.the "Irr·FJ.ct~~of PrMerrcd Corridor Sur;ltna-l"(PC:.In)scnrcely ~cr,tl ons the T:l:;"(r.0 ~1~.1.-Cf)ld Cre,,"k :;ec:~crrt at all. :,.,.l>.' -2- .," The rather Glgnlflc~nt OV~~Glgnt of ignorine this large ~lock of people and the imract th~"::;',lsi tr.:l-l"corridor will have on them,indlcates a vory GlIPcrficlal ".!1d .:1.1~0~t irrc:Jponnn)lc analysis.I note that.the matl.ce::;can b0 ca.:-.'J'y l!iJrlntcd.In liGht of t.he imformation cont..1.int'd herein,I hope tho.t t:--:(,dr.:'.ft I t.1at~ice~and text,Hill be corrected b~fore beine;~\U1J~ll.t~r:'C.:',;,0.~d.=;~cn D<J,!n':rs. A wndernc~~]lrcf~';:~,:"~~l·1.:<"!.nd ,J.laree number of peoJlle Ifill be de~t.royed if the tr...trl:.;mi:';:";~()fl En~':.;:H'C built 1n thl~corridor.1 would t.herefore like t.o :·,C...:th~..:~U~1.::',.1.-1":l.ltc;-:,na~lvo:>between 'f:uy.ee:noJ.and Gold Creek ul:~ndoncd.If thi~c~l~not.b~:donC',ther:at l":':>:it.stuuy it car~fully to m1.n1mlze t.he tr~p.:ic~.,');Cll'C[o:-e,I cert.:llnly hOpo you w1J.l consider heJ.1.coptcr con::;trllction 111 t.h1:.;.:\:';,J.~nd ch00ce a rOllte which will .:lvold privately In:1:lt:d or OW!lll<!1.:.\!1<1. Slnccr~ly, ,'I'••I I/1 )1/,..",I R.John Strasenburgh ~C.~e~.:l:or3 Crav~l a~1 ~tcven~ pr'p::cscnt,':.ttv'"Y";',ln~ TI .....\-..~r""';,:-;t :\.:.;~~.~~.:.:-'C'·~\·'::r !\dr.".i!13..~t"!"a:tlo:'1 ,...,,·~o 1(I 313 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."The assessment goes on at some length describing the actions which will be taken to lessen the obtrusiveness of the transmission line Wit'l 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:"Whenever possible, existing rights-of-way should be shared or paralleled to avoid the problems associated with pioneering a corridor in inaccessible areas. Trails in these "inaccessible"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."Thus.preservation of the wilderness setting will be a major consideration in transmission line location and construction. 321 STILLWATER CLINIC "OX B COl.UMBUS.MONTANA October 21,1975 AlaGka DiGtrict Corp of Engineers Anchorllee,Alaskn 99500 He:Upper SllGitnn B'lcin Hydro-Electric Power Development. Dear Sirs: It cornea to my attention that a power development including R dam or Gcveral dams in the upper Susitnn Ilnd Devil'G Canyon is 6till being proposed.It is my fecli.ng that very little thought haG been given to the environmental imp.-Act that GUdl a project would have,and the permanent 10s6 of some tremendous river floating and bonting in the future years.This particular stretch of river is as mRgnificent,as far as rivers go,as t1cKinley i~when one considers its relationship to other mountains. I feel that Bny meilGUre to change or deface this river should be a6 carefully considered as would a prop06al to chane~or deface Mount Me Kinley. I wiGh you wouJ.d enter this statement in the hearing record aG evidence that there is strong opposition to the Devil t s Canyon wm that will permanently destroy the marvels of thiG canyon. 314 CH3/ch ;31~L1 Comments noted. RESPONSE TO COMMENTS BY C.H.SWANSON,JR.M.D. 323 JOHN H.SWANSON P.O.f\r,x fJll Br..rk"l"'v.C:"Ili(ornia ')4701 ()'~~..wl. \?,t~~"\~~.wv.. l'~e-t 7H~ D.tv~~rJ>~¥,or .., c,t:...:.r...,~I '\'~~~ItV.~c~,\Lvj4 ~"'~~tJN.,VW:tt~/~~~.x ~~~ttJ:-~~~C£t~c.w.~,..vJ.,...v..,~V<\.~v-A.,"",tw..~~V~~,~ 'b.~~~V'~Nn~O~~O'.\.t~~e.t~*Af~~kk$~. ~~~IJ~~ov..(A.M~U\.&~~i<,~~~~ ~~~~"'b~' Yo.~~~~~~tJ-'lNvJ.t.V.~.~~~ct1.J:.~'\U~tv..~~A ~\.~INI9.--.M \~.x ~9~"""1 J',1:1 CoW\\-ti~¥"..~o~"".J-..Lv.~~u-MA, ~~~\...!\,I.:v..o<4.M.t 1II.....w I~n 4~M'-fU lJ .•:.J:J....~I c.£\.~ ~~t-y\!--~~~1N.t lutk,i:/\~~~YI"&V~'VA.~M<~~&~l~ ~)~~~uw.4)6W1~~WM ~t/~\"I~N;~t1~~~~,. it~I/....w~~c,.~\..-1"..:t""-.w-cvv-1.~l~~nt\1, ~A~~~~~,,'~&blJ:.v~~,.).~"I.W~~·:Xk~~"''tu..,.(j ()d.~, 324 •.".~J,~l.J Comment s noted. RESPONSE TO COMMENTS BY JOHN R.SWANSON 410 Sl{arland Hall University of Alaska Fairbanks,Alaska'99701 Oct 7 J 1975 Alaska District CorDs of :~~ineers P.O:nox 7002 Anchorace,Alaska 99510 Dear Sir: I att('nop.d your hearincs heln here 1n Fa1rbanlts 1n October,with creat interest and concern for the future development of the proposed rlams on thp.Dir;Sus1tna Rivp.r. I "'ar.r;omcI'/h:J t BU r'l)r1s~d when Colonel Dcbelius mentioned that there micht otill hp Ll !,(msib1Iity of adctitional dam construction such as the H(l,~)1;)rt.';/hen the Corps tri0s to resurrect Guch sl~el8 tonG of thi$r.wcnituet0 of .oioloCical blunder,it ma.ltos on~\'lander about Game of thr-rODGonin,..,;b0hind prescnt stuctics. fLlthoW::h I \'IOlll(~he tl10 first to adT:1it that the Dcvills Conyon arf\a \';onld be ,f proho.bl',the best location for a Jam Gite in the State,I .feel that ~s ncc~Gsary to evv.luatc all of A1as~{a I s resources, an';\':1so land use planninr;,I'li th the best and \'!isest use 0 f resources instead of devclopin~in a piece T:1Gol style.. I fr.d that the qllC'stion should be ruist;ct as to the necessity of a cio.r'1 for hy(~ro-clcctric pO\'IG~')t this tiroH'.'l'herc nrc presently nnny enr rr,y resou rc ()s beinG ':'<1stcd in Alaska.Flarinr;of natural [:08 haG been curried ou t for over a dec ado in Cool:Inlet.!I.e a sturlent·on CD.r,1~US ot the UniverGity of Alaska at Collese,I witness ('ntire noore urincccGoarily burnin;;electricity 2/1 hours a cloy,and conctll:l!"Jtion 10 0 t a r.1ni-im\lm. Thr.fact.that thC":Corps of Enl~inccrG is planninr;this projcct at this tiMc,prior to l:nQ\'/ledc:e of the route the f::D.S p~pclinc \'t:lll tllTc0,indtcJ.tcs an otUtud()of t1c1cvclopment for development IS snlta" to perhap::;q\lO te a \'lel1 l:no\'ffi Aluslwn inversely. If tnfnct th~.North ,,)lope cas 'n1pcline docs [";0 throl.l~h !l.lD.sl~a,it ~ould a!"Jpr.ar to me to be extremely short ci(htod at this time to [0 nhcnt1 \'11 th construction !llans,as \':01J.as encourac;inc more \'JasteorAlecli:a I 0 rcncr:ablo nnd non rene~ablo resourCCG.'. ...... Yours'"lnccl.'cly,~,~~/1 '1 furbara ~'linklcy . .cc:Govornor Hammond .".~..--.,. t.'/~,e:... ·3]6 COnJl1ents noted. RESPONSE TO COMMENTS BY BARBARA WINKLEY 327