HomeMy WebLinkAboutSUS347TK
1425
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S9
no. 347
AGENCY COMMENTS ON DRAFT EXHIBIT E OF SUSITNA
HYDROELECTRIC PROJECT LICENSE APPLICATION
Comments by NMFS, DEC, DNR, USFWS
This document is assigned SUS 347. It comprises four agency memorandums addressed to
Eric Yould, Executive Director, Alaska Power Authority. These memorandums are assigned
individual SUS numbers 10040, 10041, 10042, and 10043.
These submitted comments are in reference to: Susitna Hydroelectric Project FERC
License Application. Exhibit E / prepared by Acres. Draft. -- APA Document nos. 157-161.
CONTENTS
SUS 10040 (part 1 of SUS 347)
Comments on Draft Exhibit E of Susitna Hydroelectric Project License Application.
Letter to Eric Yould from Robert W. McVey, January 25, 1983.
• From Robert W. McVey, Director, National Marine Fisheries Services, Alaska Region
• 13 p.
SUS 10041 (part 2 of SUS 347)
Comments on Draft Exhibit E of Susitna Hydroelectric Project License Application.
Letter to Eric Yould from Richard A. Neve, January 21, 1983.
• From Richard A. Neve, Commissioner, Alaska Dept. of Environmental Conservation
• 4 p.
SUS 10042 (part 3 of SUS 347)
Comments on Draft Exhibit E of Susitna Hydroelectric Project License Application.
Letter to Eric Yould from Esther Wunnicke, January 13, 1983.
• From Esther Wunnicke, Commissioner, Alaska Dept. of Natural Resources
• 6 p.
SUS 10043 (part 4 of SUS 347)
Comments on Draft Exhibit E of Susitna Hydroelectric Project License Application.
Letter to Eric Yould from Keith Bayha, January 14, 1983
• From Keith Bayha, Assistant Regional Director, U.S. Fish and Wildlife Service,
Anchorage
• 7 p. with 112 p. attachment
(This and other explanatory sheets are supplied by Alaska Resources Library and
Information Services. Titles of this document and of the memorandums are supplied from
Susitna Aquatic Impact Assessment Project Bibliography with corrections made by the
cataloger.)
Note about the quality: The original papers are not available. Those papers were
microfilmed, and the microfilm was later digitally scanned into a PDF file.
COMMENTS ON DRAFT EXHIBlT E
1. NMFS 3. DUR
2. DEC 4. USF'WS
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Part 1 of SUS 347 (also SUS 10040)
Comments on Draft Exhibit E of Susitna Hydroelectric Project License
Application. Letter to Eric Yould from Robert W. McVey, January 25, 1983.
• To Eric Yould, Executive Director, Alaska Power Authority
• From Robert W. McVey, Director, National Marine Fisheries Services, Alaska
Region
• 13 p.
;~..~',.
....-...,.•.
Th e Nation al Marin e Fi sheri es S ~r vice has revi ewed dr aft Exhibit E of
th e l icense a pplicat ion f or th e Su sftn a Hydroele ctric Proje ct.We are
submitting ccnme .rts on thi s docume nt which s ilti s(/,in part ,the agency
coord inat ion mechanism e stabli shed by th e Federal En ergy qeg ulatory
Co o,"i ssi on (FERC).Th e fo rm al position o f IUlFS i n r e gard s t o the
Su s t tn a Proj ect hes been r equested iuld prov tu ed t o th ~.'\1.1::k.c:.Pow er-
Authorit}(APA)in s ev ere 1 pr evi ous in s te nces ,Sp ec if i ce 11 y.we r ef ar
to th e f o11 CJ\'1 i n!J tlMFS c or res po nde nce whi c h shou ld be cons t de red, a l ong
wi th th e Exh ibit E conme nt s,as f orm al c oordi nat ion,
1.Let ter t o Eric Youl d f r om Ro ber t rlcVey .Directo r,Ala ska Regi on
fli1F S,Ncvemb er 29,1982.
2.Statement of Rob ert l~cV cy before th e Ala s-k a Pow er Au thority Boa rd of
utrectors ,April 16. 1982.
3. Letter to Eri c Yould from Robert McV ey,October 15,19 82.
Mr .Er ic You ld
Executive Director,Ala ska P ~~er Au th ority
334 W.5th Avenue
An chorage.Al aska 99501
De ar Nr.Youl d:
Th e Nati onal Narine Fisheries Service (ril'lF S)is e ntrusted with Federal
j uri sdict ion ov er marine ,es t u~r i ne ,a nd dn adromous f is h~ry r esources.
Und er Reor9 anizat ion Pl an No. 4 o f 1970.3 C.F.R.Secti on 203 (1970
compila ti on).r eprinted in 5 U.S.C.Appendi x II a t 64 (1970).tll'IF S was
established to e xercise those function s previously carried out by th e
Bureau o f tonmer-c te l Fisherie s.By vi rtu e o f thi s del ega tion of
autho rity,Nf.lF S is r esponsi ble f or overs ight a nd e valuation of a ctiv i-
ti es wh ich may a ffect mar ine,est uarine,and anad romo us fi shery
r esources.Unde r t he Fish and Wild l ife Act of 1956, 16 U.S.C.Sect ion
661-666 (c)r equ ires th ot N:1F S be consulted "wh enever th e waters of any
s t ream or other bo dy of wa t e r ar e proposed or autho ri zed t o be im-
pounded ...fo r any purpose wh atever .••by any public or private agency
unde r Fed eral permit or 1 icen se."Nr·IFS inte res ts in t he pr otect i on of
marine,es tuarine,a nd anddromo us f i shery re sources als o de rive s from
th e An adr omous Fish Con servat i on Act,the Magnuson Fi shery Conservati on
and Manage ment Act,a nd the Nat i ona 1 En vi rorm ente 1 Po l i cy Act.Th e FE RC
r ules and r egul ation s r equ ire consultat ion with NMFS whencvet a pr oj ect
ma y affect a nadromous,es tua ri ne ,or mari ne f i s hery resourc es ,
5cJ5
/tJO,/O
J ~~\?Il \~
UNITED STATES DEPARTMENT OF COMMERCE
N.tIDn.1 Dc ••nlc end Atmospheric Admlnlstr.tlon
Nat i onal Marine Fisheries SSMJ w e
P.O .Boz 1668
Juneau.Alaska 99802
January 25. 1983
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Because of the nature and magnitude of this project,and certain
unresolved i ssues concerning resou rces for wh ich N ~FS bp.ars
responsibil ity,we do not feel the f onma l consultation process 1s
complete at th is stage.NMF S will cont inue to ass ist your agency
throughout the pl anning and l icensing process.
G~neral CO lTll'lents
Our revi ew f ound this l ic ense exhibit to be very i nfo rm ati ve and gen-
e ra l'ly well deve loped .I t represents a consi derable improv ement over
th e 1981 Feasibility Rep ort,particul arly in its consideration of
filling concerns and 1n discussing project effects from a Watana alon e
and Watan a/Oev il Cany on com bined perspective .
We have not comme nted extensi vely on chapters 5,So cioecon om ic impacts
or 10.Alt erna tives .Howe ver we beli eve it is i mp urtant to recognize
certai n re cent dev elo p ~n ts which wi ll i n f l ue n c~th e f easibility of this
project .Uo rld oil pr tces have f a il ed to esce lete as projected in
earlier economic stUd t 2S.~a t ur d l ga s alternat ives have been influenced
by r ecent pric ing a gr ee p ~n ts and a pr oposal t o construct a gas pipeline
capable of supplying mu ch of t he Southc entra l popul ation .We have
r ecently rev i.wed th e 8. tt clle Ra ilbelt Electric Powe r Authority Sludy
tl ew sletter #4,De cemb er.198 2.Thl S newsletter presents an upd ate
e l ect r-Ica l demand for ecas t which, for the year 2010 ,is 44 percent l ower
th an the 1980 ISER fo re cast.Load f orecasts wil l dictate f ac il ity
design and op erat ions which ,in t urn,will detemine th e amo unt of wa ter
r equ ired f or powe r produ ction and available for dm1n stream fish eries
flow. In an ACRES report of OCt obe r 198 2 ,E n ~r9 v Si mu lation·Studies to
SC lect Proje ct Dra wdow n and Mitigati on Flows ,e nergy s imu latlons were
made which as sumed a medium load f ore cast f or th e year 2010 of 779 1 GWH,
a f igure s ignifi cantly i n excess of t he re cent Batte lle f orecast of 3844
efld 4986 f or me di um and low 2010 dema nd .I t app edr s that many of the
basic economi c premises upon wh ich thi s project was planned pave now
changed.We believe th e license appli cation should fully -con sid er t he
tm a ct of th ese event s and dlSCUS S thclr effect or 1m act on overa ll
ro ect easl 1 lt t e nee or ~a ta n a to be 0 e r a tl 0na and
t e e conom1CS a ssoc ate W1t prov1 n9 s u Clent ownstream ows t o
minimize fi shery imp acts .
Th e data gathered from the enviro nmental fie ld studies ,begun in Jun e
1981.and pr e sented i r.t he Exhibit,s ho w the Susitna Riv er system to
support l arg e.valu able runs of pac ific salmon,other anadromous f ish,
dnd several f ne sh ~at er r e sident f i s h s pecies .Th e propo !ed proj ect
wo uld imp act th ese re so ~rc e s .particul arly .in that reach of t he Susitna
Rive r b etw ~e n De vil Canyon and Talke etna .Th e pri ma ry intere sts and
concerns of UHFS i n the Susitna fedS ib ility studi es have been t o a ssure
th at (1)th e f ishery r esources are i d~n ti fi ed dnd quantifi ed,(2 ,
s peci fic i mp acts a re identifi ed,(3)imp ~c t s are avoided wh enever
poss ible,and (4) specifi c and effr.ct ivc mitiga tive me asures a re
dcveloped for all un avoidable adverse i mp acts .
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Th e r esult s of the se stud ies and othe r ma teria ls presented with in
l icense Exh ib it E l n d i ca~e that project construct ion and op erat ion wil l
signif icantly a f fect f is hery r esources through cha ng es 1n s t reamf l ow ,
wa ter qua li ty,t emp era tures,i ce conditions.veget ati on, and slou gh
habita t.Studies to id ent ify and as sess these changes a nd to d es ~rib e
t he f ishery resou rce s of the proj ect area were i nitia ted in 1981 .At
th is t i me two fi eld se asons of data hay e been ga t ~er ed.Howe ver,the
dr aft Exhib it Edoes no t includ e mst of th e 1982 da ta nor the result s
or analysis of th at data.Th e docu me nt cl earl y suffers by thi s
omiss ion.a nd we re comme nd that Exhibit E of th e licen se appl ication
in clude a pres entah on and anal ysIS of t he 198 2 data .
Through ou t Exh ib it E references a re ma de to ongoing or proposed s tudies
which wi ll add ress i ssues we c on sid ~r criti cal to th e f easib il ity of
t his pro ject.Yet it i s not cl ear wh at t hese s tudies will entatl ,who
will conduct th em or when th ey will occ ur.Ue re cor.rn e:n d t hat th e
license a ppli cation detail ongo ing and propo sed studi e s.
Th e info rma ti on pres ent ed in Exhibi t E r egarding r eservoir operat ions
does not suffi cient ly co nvey th e range of imp acts pr esent ed by t ~e
project .lie rec orrmen d th e l icense a pplic at io n be ex ~a nde d t n i nc1 \ide a
mo re r ecis2 descri t1 0" of 1macts and rese nt t h~o l 1ow 1n
~s 1 9 n operat n9 conce rns:
Fl ow re leases -base d upon weekly rd t he r t ha n mo nthl y a verages.
Quant if ica ti on of "no rme'l ''spill ages.bel ow t he 1 in 50 yea r event.
pas sed thro ugh th e out let/cone valv e facili ty .
Po tential peaking operations a t \:at ana wit hout the Devil canyo n Da m.
ACRE S has identi fi ed this as a poss ibil i ty.h~at c ircumstances would
dictate s uch operation?What daily and hourly f luctuations would
r esult?How wo uld s uch flu ctua t i on s be attenuated by t ri~u t ary input
and th e river dis tance be tw een Wata na and Dev il Cany on?;
Co mp ensat ion fl ow pu mp s at th e De vil Canyon f acil ity.What flows
will th ey provide?How were th ese fl ow s establ ished?Are the se
pumps s ti ll pl ann ed f or th is f acility?•
We cont inue to be con cerned about devel opm ent of a r elease schedul e
which would mit igate i mpa cts to fi shp.ri es.Th e dr aft Exh ib it Estates
th at r educed fl ow s could im pa ir f ish migration, de-water s pawn ing and
re a ri ng habitat .prevent access t o s lo ug h a nd s td e ch ann el habitats.and
l ow er or e li mi nate i nt ~ r -9 ra v e l fl ows t o s lough and s ide chann el
spawn i ng g~und s.Th e mi ni mum fl ow s pr oposed in Exhib i t E,how ever,
were not developed using a ny recognized i n-s treamf lowpr edi ct ive
meth odologies ,a nd may not c on s t it u t ~the preferred f l ow r egime fo r
mi ni mi zing s uch effect s.Th e li cense exhi bi ts de not e xplain how t he
12.000 cubic feet pe r sec on d (cfs)~i nimum oper at ional fl ows f or Au gust
and Sept e mb t ~were detenmi ned .~e note tha t t hese fl ow s have been
re duced from those recon r.~n ded minimum f lows pr ~s en t ed i n th e 1982 Final
Draft Fe asibil ity .Re po r t,Volu me 2.S i ~i la r l y ,no rat i on ale 1s pr ov ided
which s uppo r ts -mininu m-wi nter flows t e n times t hat of e xisting natural
winter f l ow s.We b el i e v ~th at ~x imum wi nter f l ow l im it s should be
r equired as well ,pa rt icula rly i n 11 ght of potential staging s hould i ce
cover develop bel ow De vil Canyon.I
least t wo seasons data .
Of th e vari ou s fish hab itats bel ow Devil Canyon Dam,th e s loughs betw een
Talkeetna and Porta ge Cr eek.a re th e most likel y to be adversely affected
by t he proposed work.A p p roxi ma t~l y t hirty -fi ve s loughs exi st in th is
r each.Adul t sa l mo n have been observed i n at l east tw enty-six of t hese .
Post proj ect flows and water t emp eratures will present several
s ignifi cant impac ts t o thes e habi tats.T h e~e are discuss ed in some
deta il i n Ex hibit E.Howe ve r,on only one o f t hese,sl ou gh 9 , has
detailed i nvestigation been conduc ted wh ich in cluded groundw ater fl uw,
upw elling. and t emperature stUd ies.Th ese s loug hs a re th e mo st imp or -
ta nt s pawning a reas tr.f luenced by th e ma in stem Sus itna Ri ve r:.They are
a lso i dentif ied as pot ent ial s ites f or mit igating fi shery r e sou rce
l osses t hrough phy s i ca1 nl'Jd1fi cat ion.\Ie f ee 1 i t i s i mp ortant t herefore,
t hat Ex hibit E pr esent a n i nformed opinio n based on site specific data
as t o t he effects of project operation on s loug h habita t .In a dra ft
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Exhibit E suggests that it may be des irable to spi ke spring flows to
accommodate out-migrants and fac ilita te flush ing of sloughs and s ide
chann els.I t also states that the proj ect release schedule will need to
i ncor po r ate bo th volume and t emp erature conside ration s.Howev er.
nei ther of t hese con cerns 1s reflected 1n the prop osed f l ow re gime.Th e
r elease schedule presented i s not s upported by biological da ta.nor does
it reflect concerns f or f ish passage.We recommen d t hat t he l icense
appl i cat ion contain a s pecifi c. de tailed flow rel ease s chedule.
developed t hroulh a 9uantlfla61e Tn-stream f low anal YS TS and coord inated
wlth rl Mf S,Us F sh and '!lldld e Ser vlce a nd the Al aSKa De artment of
15 an an ~Wl C wou m n1m ze m acts an or en ance
con 1t Dns or spawnln 9!ee 10 9!passage,out -m lgratloo, an
overwl "te rl ng 1"the Sus l t na Rlver .
The Watan a and De vil Canyon dams wi ll cause chang es to th e exi sting
wa te r t empe rature re gi ~of t he Susitlla River ,generally re leasi ng
cooler wa ter during s umme r month s and wa rme r water i n winter.
Temp erature va ria ti ons affect th e abi li ty of f ish to migrate, s pawn,
fe ed,and develop i n t he Susit na sys tem.Ice f onnation will be delayed
or po s sibl y not occur. Exh ibit E discus ses th is mat ter a t length but
dces not prese nt an l ccur a t e descri ption of post·project t emperature
dlte ration s . A mo del was dev e loped t o project temp eratures,yet it has
been ope rated with only one year of data (1 981).Further , t his mod el
vas run on ly for t he mD '1 ths of June thro ug h October.Temp erature
n~deling is not pre sented for t he Devil Cany on Rese rvoir,yet Exhi bit E
states th at t he locat i on of i ce forma tion a bo ve Talkeetna will depend on
t he ou tfl ow t e mp ~ ra tur ~s f rom De vil Ca nyon Da m.
Rea liz i ng t he importanc e of an accurate un derstanding of the th e nnal
s tru cture withi n the r es ervoirs and o f out flow tem peratures,'we believe
addit ional information i s warrant ed.We re commP.nd t hat mode Jing be done
for both re servoirs through out the yea r,and the re sult a nt da ta be
lncorporated 1nto th e r lve rlne tem peratu re mode l cal ibrated wlth at
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In those areas wh ere i ce fo rma tion does not occur. water elevation s
would drop below natu ara ll y occu rring l evel s.l eadi ng to potent ial de-
watering of spawn ing gr av e ls and r edu ctions in u p w ~l l ing ar e as.Exhibit
E pr edi ct s th at the Ice f r ont should occur at son~l ocation betw een
T al ~e e tn l,RH 100 and She nman.~~130 and wi ll depend upon t he upstream
t emp e rature,i .e ,th e Devil Canyon outf low .As no mode l wa s coopleted
f or wi nter river ine or rese rvoi r te mp eratures .th e full scop~.and
me a sure of th ese effec ts cann ot be ass e ssed .
Exh ib it E di s cus ses t he i mpdc t of proj ect const ruction and op erat ions on
riv e r ic e f onnati on.App are ntl y . pos t-p roj ect ic e f onnati on will be
delayed du e t o hi gher re l ~a 5 e t em p ~r d tu rp.s fro m De vil Canyon."
Cu rrently.ic e ori gina t ing f r om t he upper Susi tna cc.t tr-ibut es'75 to 85
per cent of th e ice l oad to th e l ow er River .With t his i nput r edu ced or
delay ed by t he pr ojec t .ice f a nna tion 0 11 the l ow e r Ri ver will be
a ff ected.Thi s impa ct -is not adequ ately discussed i n th e Exhibit.
I ce fo rmation abov e Tal ke etna wi ll al so be delayed by t he proa e ct .The
l ocat ion of th e i ce f ront i n th i s reach has i mpor tant i mplica tions to
f isherie5 ha bitat withi n t he nein s t em,sf de chann els.and sl o\.lghs.In
areas with ice cove r.staging i s e xp e cted to occur whi ch wo uld i ncr ea se
water surface e leva t i ons. poss i bly inc reas ing upw el li ng.overtopp ing th e
up stream berm s of s loughs. and causing high veloc ities and scour to
occur .
report prepared for Acres American,Inc.1/,th e author note s th at
until the 1982 fiel d data are analyzed,any statements regard ing
streamflows necessary for chum s almon access t o the s ide sloughs are
provisional.Within Exhibit E,there are vague and seem ingly
contradicto ry stateme nts concerning slou gh i mpacts .Statements are made
within this Exhibit that data on the areal extent of upwelling with in
th e sloughs at low flows are not presently available,that ground water
upwell ing i s driven by mainstem r iver stage,that spawn ing areaS of the
sloughs may be affected by reduced upwelling, and that flows of 16,000
t o 18,000 c fs are required for easy access to the sloughs .The document
also conta ins statemen ts that 12.000 cfs wil l provi de access to mos t
sloughs.that a 12,000 cfs relea se will assist i n maintaining
groundwater fl ow and upw elling with in s loughs ,and th at chang es in
s treamflowdur ing the open water season pred icted und er ope ra ti on of
De vil Cany on are not expected t o affe ct slou gh ha bitats.Clearly,
post-projec t impa cts to th es e i mpor tant and s ~ n si t i ve hab itats are
poorly und erstood .NMFS rec omme nds that th e f inal l icense a pplicat i on
contain the r esults and anatysls of th e 1982 f ield dat a being gathered
by the Alaska D e~ar t men t of Fish and Ga me,e t a t ,and results of an
e xpanded study a s loughs t n the Devi l Canyon t o Talkeetna re ach wh i ch
wo uld provid e a larger a nd more r e pr ese ntat ive sam ple th an cur rently
ava l lalile._
r rce n, nc.ove e r ,
S awnf n So lma n t o Si de Slou hI.prel i mln ar Ass es sme nt of acces s b
Habi t a t a ave a ee tna.r aTt epo r-t ,
198 2.
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Exh ib it E s ta tes th at i f a lte rnative mitig at ion sc hemes pro ve i nfe asi -
bl e ,a hatchery could be developed.Whi le we re gard s uch arti ficia l
me thods to be th e l east desirable form of addressing fi shery l osses,we
r ~al ize t hat s lough mod ifi cat i on is l argely untr ied in Al aska a nd that
th ese miti gative e ffo rts may i ndeed fa il .Th erefor e,we r ecommend th at
Exhibit E sh ould a dvance t his dis cus si on be*ond th e statement that "a
hatchery could be develoscd.il Informat10n s auld be l nclu d ed'\~,thln
lI cense Exh ibIt E whI ch c sc ri bes t he nw nb er of hatcheries needed.
locations . s izes ,what th e pr odu ction ta rget f or each speci es would be .
and cost est i mat es.
Finally,none of the mit igative measures pre s ented comply with FERC
rul es and r egulations under Section 4.41 (F)(3)(iii);t ,e ••cos ts f or
t hese f eatures a re not pr ~s e nt e dJ nor a r c desi gn pl ans for mit igation
f eatures in cluded .
Specific Comm ents
Exh ibit E
Ch apter On e -No comme nt.
Chapter Two
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page 15 ,para. 4.Bre akup
The section should describe when breakup no rmally occurs,specifically
the dates of the earl iest ,D~an .and latest recorded events.
page 38,para .3
This section should consider that at least eight sloughs exist above
Gold Cre ek.several of which support large numbers of spawning salmon,
e.g •• slough 21 .IIhfl e Gold Creek may be a logical po int at which to
gauge flow, 1t does not necessarily guarant ee that upstream flow will
be sufficient to maintain habitat value in th ese sloughs. Exhibit E
should discuss th is concern and r ecommend necessary me asures to
guarant ee adequate flow to these sloughs.
pag e 47 .Section (v)Ims acts on Sl oughs
Th e section notes thatat~to confl rm t he areal extent of upwelling
at low flows are unava ilable at this ti me .Currently only on e slough
has been invest igated suf f ici ently to predict project influenc es on
groundwat er and upwell ing.Thi s slough is 1I0t r epresentative of all
such sloughs in the Devil Cany on to Talke etna r each.
Under existing winter flows, ic e fonmati on causes s taging equivalent
to an open water flow e leva ti on exceeding 20,000 cf s.Filling flows
of 1,000 cfs,for whi ch ic e f orma ti on may be delayed or fail to occur,
could significantly ilnp act sloughs through de·w a tering gravel spdwning
are as and ov erwintering hab itat .
page 49,para 2
As the temp erature of groundwat er is con sidered a fun ction 'of the
avrraye annual temperature of t he ma ins tem Susit na ;wh at will be the
i mp acts of the second fillin g year release temperatures t o the
_groundw at er ?How long would an y chang e per si st?Uo data are
prese nted t o support th e stat e ~n t t hat ground water te m~eratur es will
not chan ge.
pa ge 51,para 3. ":On thly En CfiY Simulations ;
The referenc ed pr ogram utl1:zcd load forecasts developed by ISER.
Woodward-Clyde,and Battelle.Th ese for ecasts are now serfou sly
questioned i n light of recent developments (s ee General C~~nt s).We
recommend these simulation stud ies be updated a nd run with th e most
recent load forecasts available.
pag e 58. para.1. Reservoir and Outl et Water Tcm~eratur es
This sugg ests that wlnt er outfl ow temp eratures betwe en I D and 4DC can
be selectively withd rawn through a mul tiple i ntake st-ucture.This
control would be depend ent upon the th ermal profile of the reservoir
during winter,a set of conditions which has not been mod eled.
Therefore.we question th e validity of the statement which suggests
one degree water temperatures would be available on request.
Informat;on presented by ACRES duri ng th e Nov.29 -Dec.3 Workshop
showed winter t emp eratures in Eklutna lake to be between 0 and 3.6 0 in
the upper 2 meters.while isoth er mal conditions e xist below·this
l evel.
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page 59.para.2.Ic e
I t is not cl ear what i mpa ct will occur to th e l ower River f rom
r edu ct ion of i ce flow f rom th e upper Su sftna.Ho w far down river would
f ee f orma ti on occur?When do es f reeze-up normally occur?
page 91.para.2.Mi tf ~a t io n of Watana Ingou nd me nt Imp ac ts
This section s tates t at a proposed 12.0 cfs flow at GOld Creek
would provide salmon access to mo st of th e sl oughs and would assi st in
maintaining adequate ground water l evels and upw ell ing rates .There
a re no s tudies wh ich would supp ort t hese conclusio ns,as on ly one of
approximately t hi rty-si x slou gh s has re ceive de tai led s tudy .
Sim il arly,current fn fo~tfon does not perm it the developme nt of
miti gation me asures wi thin t he s lo ug hs,as stated i n th e la st
pa ragraph on th is page.
page 93.para .2.Ni trogen Sup er saturation
While we s upport tne con cept of instaillng cone valves at th e ou tl et
wor ks of both dams, t he s ubject r equires furth er discussi on .Th es e
va lves wil l only operat e (and afford gas s upe rsa tura tion bene fit s)
during sp ill ages below t he 1 in 50 year hi gh f low event.Ac cording t o
the dis cussi on presented on pages 79 throu gh 8 1, such spi ll ages wo uld
be a r el atively un common e v~n t (for th e 32 year period s imu l ated,
th e re wer e 4 years durin g which spill ages occurred).Th e di scussion
on th e sp.valv e s shoul d present dat a on th eir frequency of us e and
expla i n t he c ri t er ia by which th ey a re p ~a n n ed and ins talled.Th is
shou ld includ e the f oll owin g:
1.Pote nt ia l te mp era ture i mpac t s res ulting from with drawa l f rom
th e ~e outl et stru ctures .
2.Potenti al impa ct s t o ri ver 'ice for mat ion attributed t o operatio n
of th e se valves du ring winte r.
p~ge 95, para. 1. Tempe r Jt ur e
The d is cussion of De vll Cany on post-pro ject t emp e rature mi ti gati on i s
in adequat e.Wha t adv antages a re gai ned by th e n~l ti p l e r e l ease
st ructure?Wil l Devil Canyon r eservo ir stratify during s u~er and
winter?
Chapter Three
page 8 . par ••2
"Si nce th e gre ates t changes in phys i cal habit ats a r e expec ted i n th e
r each between Talkeetn a a nd Devil Cany on,·f ishery re sources usin g that
por tion of th e r-tv er were con sidered to be the most sensitive to
pr oject e ffec ts ." Transforming t he mainstemSusit na Riv er into a
r eserv oir i s also a con sid erabl e chang e.Later i n this paragraph is
th e statement "The mit igati ons proposed to ma in t ~in chu m sal mon s hould
a llows ockeye and pi nk sal mo n t o be ma intained as we ll .-We are
unab'l e to loc ate specif ic mitig ati on plans f or chum sa l mo n :Thos e
c onceptual pl ans pr~sent ed for sl ough modification and ma instem
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spawning bed construction deal principally with one life history
stage .The statements made here th at improved mafnstem conditions
will replace loss of slough rearing habitat and that Juvenile
overw in tering area s ~re not expected to be adversely affected by the
project are not support p.d .In fact,preliminary data presented
elsewhere in the Exhibit indicate that overwintering habitat will be
impacted and that sloughs may provide important real'fng habft~
pag e 12.Species Biology and Habitat Utilizati on in th e Su sitna River
Drainage
Estimates of adult s a lmo n presented in th is section depict only
escapement.A n~re meaningful esti~lte should be made using catch to
escapement re t tos,as.done i n chapter five.For instance,in 1982
77.000 pink salmon migrated above Talkeetna.Howev~r only one f ish in
every 3.8 e scaped the comme rcia l f ishery.Us i ng th ~3.8 to 1 rat io,
this reach of th e Sus itna accounted for ov er 350,000 pi Ilk salmon of
which over 277,000 were available to th e commercial fishery .
Escapement est imates alone fail t o i ndicate th e high valu es associated
with anadromous f ishery resources.
page 76.Slough Habitat
Th is sectloR do es not describe i mp acts associated with lowered
wi nt er river stage during fillin g.Should u~·rell ing a nd backwater
effects during winter prov e criti cal to developing eggs or juv enile
se'lmontds ,any reduction in thes e areas could create significant
damag e .
We qu estion th e figure pr esented as th ~nu mb er of s loughs -in which
salmon spawn within the Chu l itna t o Devil Canyon reach.Using
in formation suppli ed by th ,ADFG and from Exhi bit E••dult salmon have
been obs ~rved i n 26 of these slou ghs.Exhibit E should clearly
present the total numb ers of sloughs in this reach and the 1981 and
198 2 data on spawning adul ts.;
page 77
The discussion presented on impacts to slough habitat i s not cl ear.
As Exhibit E states that groundwater upwelling in th e .loughs is
probably driven by the m ~instem stage,which would caUSe a decreas ed
flow in the sloughs (post-project),why does this section state that
under post-project cond itions only the backwater area s (of th e
sloughs'would be affected7
The second paragraph of this page states,·Uith mainstem flows above
14,000 crs , a backwater forms at th e eouth of the s Iouqh,"Ho",is
this known?Which slou gh is being df scusse d?Is this true for each
slough?The sa me paragraph explains t 'iat , during the 19 82 field
season,flows i n the 12,000 to 14,000 cfs range occurred and afforded
opportun ity to observ ~f ish passage a t flows below normal'Au gust
levels.These flows appeared to hJmp er or restric t fish passage ~J1 t o
sloughs.Backwater effects were not s een at flows of approximately
1l,OOO chi yet project low flow limits for August have been
establish~d at 12,000 cfs.This section underscores the problem s
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associated with such propos ed fl ow s.It is apparent that som e
significant chang es occur t o the sl ough habitat within a rel at ively
narrow r ange of flows ;changes which ma t have i mportant biological
implications.
pag e 87 ,para.5
Wh il e th e "de scribed floods ma y tran sport se dime nt and scour th e Riv er
bed, reduct ion or eli min ati on through flow r egulation may not
necess ar ily be benef icial .The Exhibi t p r e s ~n ts no data to su pport
the comment that hi gh main st em velociti es l imit fi sh usag"(page 87.
para.2). Further,s uch high f lowevents ma y be critical t o main tain-
ing si de channel a nd s lough habita t t hrough f lushing and re plenis hmen t
of gravel s and by remov ing y p.9~t atf on and b e ~y er da ms which may reduce
habitat valu e.This point 1s not discussed i n th e following sect ions
on slough o r side ch a n~,l habitats .
pag e 103,paragraph 3.Slough Ha bitat
Ue di sagree that chang es 1n s treamfl ow du ring th e op en-w~t er season
are not expected t o affe ct s lough habitat s.
page 116.Aqu atic Studies Program
We bel ieve th is dlScussion suffe rs from o ei s s t on o f t he ma jority of
th e 1982 f i eld stud y r esults .We s t ro<1 gly bel t evo t ha t two year s of
study are the mini mu m r equired a s a basis to di scuss the i mpact of
hydro electr ic deve ln pmen t on th e Su s itna River .
o page 130.tlea sures t o Minimize Imp act s
It is stated tha t "A f low r eleas e schedule will be used that mi nim izes
the lo s s of d own s t re a ~habitat a nd main tains norma l t iming of
flow-rel ated biolog ical s ti mu li ."Th e flow sc hedule presented in
Exhib it E,chapter 2 doe s not mini mi ze habi tat l oss ,nor do es it
oaintai n no rmal flow r e l ated biol og ical st i mu li.Thi s section s hould
also di scuss install at i o~of comp ensati on fl ow pu mps at Devil Canyon
which would provid e fl ow betw een the damand t ailrace ch an~el.
page 130,para.2.ne as ures t o Minimi ze Imp acts
The section states~Alnstream f low requlremen ts a re being
det ermined fo r each sp ~c i e s/l i fe s tage/time unit com bination."Who is
performing t hese stud i ~s?How wi ll th ey ~e d~term i n 2 d?Again, i t i s
i mp ossible to und ers t and what fl (JW regi me.i f any .is actually being
sugge sted within Exh ibi t E.I s th e r el ease s chedule pr e s e ~ted in
Table 2.17 j ust a "firs t cut?"This is apparently th e case.
Consid ~r in g that th e fi na l r elease s chedule i s t o be based on futur e
s tudies e s suggested here and may be mo dif ied to acconrnodat e out-
"i gration (page 3-13 2,pare,I)and wi ll need to consider tem perat ure
and volume (page J-l ~J.par a .1);why ;s a flow r egi me proposed in the
abse nce of such i nfo nna tio n?
page 131.pare ,1
This states,i n effec t.t hat slou gh habitat will e ither be e nhanced
or degraded by th e proj ect.s ud th at actual imp .'l cts to habita t are
t he s ubject of ongoing s tudi es .T he s ~ongoi ng s tudies should be
descr ibed.Wh .t "ill be invest ig ate I?Which sloughs will b e
studied?
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pa ge 132.pa ra .4
Th is sta tes t hat fl ~,s of 12.000 c fs are suffici ent to und ertake
r ect ify i ng imp acts by n ~d jfy ing habita t .Ho w i s thi s known ?The
paragraph s hould discu ss the s tudies upon wn 1ch t his i s based or
qual ify any such conclusions as prel im inary and subject t o furt her
s tudy.
page 133,para.1.Wi nter Flows
Th e statement i s ma de that "Slncc minimal impa cts a re e xpect ed dur ing
both f illing and operational winter fl ow,r ectifying ~a s u re s are not
needed.-This i s not s upport ~d.On page 131 . pa r a.1 ,we learn
s lough habit a t mdY be degraded by win ter fl ows a nd tha t t he~e i mp acts
a re th e s ubject of ongoing studies.Pa ge 94 presen ts a l engthy
dis cus si on of i mp act s attr ibuted to altered win t e r fl ows.
page 133,para .5 .Redu c tion of Impacts Ov er Time .
·pos t-oper ationa l monltorlng wl11 be condu cted to e valu ate the
e ffec tive ness of mi tigation ~a s u r e s (see Secti on 2.6 ).-Th e li cense
application s hould deta il what mo nitori ng wil l occur a nd how th e
e ffec ti ve ness of miti gati on effo r ts will be evaluated .
~g eI 36,~N .3 _
The di scussion of hatch e ry de ve lo ~nt 1s i n4dequate .In t he event
t ha t other mitigat i on a l ter nati ve s f ~i l ,i t wi ll be i~po rta nt t o
pres ent a clear picture of \-,h at meas ures would be taken t o -conpe nsa te
for f isher i es lo sses.
page 131, pa r a.3
.~bel i e ve t hat t he wate r tempera tu r es of 5°t o 6°C during th e second
f 111ing year will present si gnificant advers e i mpact s t o s .lmo n.
Additi on of a low le vel portal could appa rently avoid muc hi,of thes e
e ffec ts .We re commen d s uch a d!vicc be inc orporated in to he fin al
design.
page 143 ,para.1
"Cont inui ng r eservoir t herrne I mod e l lng will allow an eva luation of
available w ~t er te mp era tures th r ou ghout th e year so th at a deta il ed
r el ease plan can be de v~l op ed .The re lease plan wi ll need t o consider
bo th water temperatures and volume in orde r t o minimi ze i ~pa c t s .·We
s trongly agre e with t his ,and rec~n d th at th e l ic ense appli cat i on
contain ju st s uch a r elease pl an wh ich would mos t ef f ect ively mini mi ze
i mpac t.
Ch apters 4-9 -No Comment .
Ch apt er 10
pa ge 28.pa ra. 6.Diver sion,l Eme rge ncy Re lease F ~c il i t 1 e s
Th e r el t Jse l evels re f e rr ~d to do not avoid adverse effects on the
sal mo n f ish ery down stream.
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page 30.para.3
Figure E.2.90 indIcates that three.rather than four portals would be
constructed at Watana.We question which is correct and how the
numbers and position of the portals were considered in minimizing
impact.Also we cannot concur that temperatures wilT be controlled
within acceptable limits.
page 30. para .4
We are not awa ,~of studies which have occurrad to mitigate project
Impacts through provIsion of streamflow at Gold Creek.These should
be described .
page 31.para.5
According to pres entation by ACRE S Am erican at an APA-sponsored
wor kshop in Anchorage during th ~week november 29 to Decemb~r 3,1982,
no temp erature mod el has been run f or Devil Canyon r eservoir •.How.
then.can th e utili ty of a mul ti-l evel draw-off at Devil tanyon be
known?This again underscores th e present lack of understanding of
project temp erature i mpacts..
Th e following s tateme nts of concern wer e pre sented by NMFS before the
APA Bo ard of Oirectors on Aprtl 16. 1982.
·On e area of l imited in formdtion i n t he Fea sibil ity Re po rt deals w;th
the effects of pos t project fl ~~s on th e fish cry res ources •.••·These
sloughs t her efore r epresent'an a ~"re quiring con sidt!rat io.n of
potential mitigation and/or enh ancement n~a s u res .To dat e,les s than
one eighth of the side channel s and s lough areas h3v c been surveyed.
Further,the impact s of various flow r egimes on th e habitat are
unknown because the hydrological and ecological relationships between
the mai nst em Susitna and these ar eas have not been adequat ely
studied •.•"·The results of a compr ehen sive In-Stream FlOW Stu1y
would all owa bal ancing of fi sh habi tat los ses again st poWer ·
g en~r a t i on ••••·Cu r~n t l y,we do not beli eve a high l ~vel of
conf idence exists i n th e projected post proj ect tempera tur~within the
t~o re servoirs,the Su sitna mainstern.and th e si de chann els and
sloughs ..••1
"•••specifi c studi es mrs t occur which will develop
mitfgatlon opt ions •••"I·It i s not rea sonable to assume that (one
fi eld season of f ish eri es data)is adequ ate f or proper
characteriz at i on of th e resources.II
·W e are concerned th at the (l icense)appl icat i on will reflect t he
serious defic iencies we have me ntioned.If our review shows th is t o
be the case.we feel our agency will hav~no a lternat ive but to
r equest th e ~ERC to r eject th e application or direct that the
deficiencies be corrected ."
Our review of the mat erial pres ented in draft license Exhibit E
I ndIcates that these deficienc Ies stIll e xist .It I s regrettable that
we have reached th e dr a ft license appli cat ion stage whil e th2se issues
rena in unresolv ed.We fe el that th ~s e is sues and data mu st be
i ncorpor ated i nto Exhibit E and that \Iithout thenl the lice nse
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applicat ion will be found deficient.We believe that Exh ibit E should
be suffic iently developed so as to form t he bas is for specific license
conditions wh ich would protect anadromo us fish and their habitat.As
written,Exhibit Eonly leads to further studtes.The FERC guidelines
specify that information within Exhibit Ebe developed to a level
commensurate with the scope of the project .Th e Susitna project will b~
the most 2~ostly and comple x hydroelectrIC fac ility eve r considered by
the FER~• and th is complexity and depth should be reflected i n
license Exhibit E.
We appr eci ate this oppor tunity to comment on the draft Exhibit E.
Robe t II .~IcV ey
Direc or,Ala ska
2} Susltna proJect s tatus Re port -pre l imi nary Dr aft .Federal Energ y
~cg u la tory Commissi on -Dat a for ~c1si o n s .De cemb er I.1982.
Part 2 of SUS 347 (also SUS 10041)
Comments on Draft Exhibit E of Susitna Hydroelectric Project License
Application. Letter to Eric Yould from Richard A. Neve, January 21, 1983.
• To Eric Yould, Executive Director, Alaska Power Authority
• From Richard A. Neve, Commissioner, Alaska Dept. of Environmental
Conservation
• 4 p.
The Alas ka De partme nt o f Env iron mental Conservation is pleased t o respond to
the Alaska Powe r Au tho ri ty 's req uest for c om ments o n the Susi tna Hydroelectric
Pr o ject,Federal Energ y Re gul atory Licens e Ap plication,Exhib it E. These
co mments are organ ized into seven pr imary categories and are presented below.
4J't .::;1111:1:1
SECO ND FL OOR
ANCHORAGE.A LASKA 9 9501tsar;2 14 ·2533
P.O .BOX 615
K ODIA K.ALASKA
'90"486-3350
eo.BOx 1201
SOLDOTNA ,A LASKA 99669
(90I )2 62 ·521 0
P.O.BO X 1709
VALDEZ.A L A SKA 99686
19011 83 5-4698
P.O.BO X 1{l1j4
WASIL LA .ALASKA 99681
(3Dl)316-5038
61LL SHEFFIELD,GOVERNOR
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SOUT HCENTRAL REGIONAL OFFICE !
Jan uary 21, 1983
Dea r Mr.You ld:
Hr .Er i c Yould
Ex ec uti ve Di re c to r
Alask a Powe r Au th ority
33 4 West 5t h Avenue
Anc horage,Alas ka 99501
I;.....'-:-.::;-,~:-:=.';:::i ~..::r n .-.,rr::\1'"1 :7 t:
-','."1 1 '1 '\\\..':.•,\."I l"'~,i l :!':J I ,d I ;;1 \"\I .'II ,. ,~I .''-I'....\I ,~•\"•
r-__\;:,_,t I i ~I I J t I 1,~I .L .,_\'.'I r,"",,'':,'I-.-_.~___.'-:-.~~....-_:.1 t ........
DEPT.OF E1\"VIH01\"JIENT,\I.(;ONSEHV,\.TION
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A. Water Qual ity
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1.The discuss ion on wat er quality impacts is well done for both the
Wa ta na and Devil Canyon da ms .The major impact to water quality is
f rom a chang e in the downstream water temperat ure that will occur with
the pro ject operation.The Re s ervoir Temperature Hodel (DVRESM)i s
designed to predi ct reservoir ou tflow temperatures to an accuracy of
±2°C.Thatis a range of var i at ion of 4°C. A difference of 4 °C
in predicted outfl 0",temperatures could have a significant effect on
the actual versus the predi cted impact on downstream fisheries .This
model i ng effort shoul d be deve! oped to predi ct reservoi r operati ng
parameters when us ing a given downstream i mpact,essent ially work1ng
the model backwards.Accurate est imet es of the pred1 cted downstream
river temperatures are an essential co mponent of the impact assessment
process.
2. The sheer magn1t ude of the construction proje:t will crea te a high
potential for soil erosion that may affect wate r qual 1ty.The Exhibit
E needs t o be more speci fi c on how these problems will be mit 1gated •
r~et h o dolog i e s ne ed to be de scr ibed i n detai 1 for construct ion of t he
road , dam and townsites , a nd o ther pro ject entities.
B.Hazardous Substances
A very large amoun t of hazardous s ubstances will be transpo rted to,and
ut i l t zed a t,the project site.D1 scharges of hazardous sub stan ces coul d
con ta minat e l and as well as surface and ground water.Further i mpacts
c ould occ ur to human we lfare,f ish,and wild life.
The Exh ibit E docu ment does not addres s the major possible sources of f uel
spills,but rather the minor ones (lea ky hydraulic lines and water p umps).
A ve ry deta iled oil sp ill contingency plan needs to be developed t hat will
have s everal major objectives and be written to account for a major (i.e.,
tank truck roll-over),as we ll as a minor spill event.
Mr.Eric Yould
January 21.1983
Page 2
The plan should be responsive to project needs and yet be simple enough to
be functional.Major objectives of the plan are discussed in detail below:
1.To develop a training program that will stress spill prevention.This
program needs to cover spill response under a 11 project condi t ions and
set up several response scenarios.
2.To develop the response capability to adequately handle the worst case
spill expected.This response capability should be developed for the
Watana and Devil Canyon camps and the rail head stagi ng area.This
would mean staging spill cleanup equipment at all sites.All hazard-
ous substances that will be used on site need to be consi dered (so 1-
vents.chemical additives.etc.).
3.To develop an immediate response team for each work shift.consisting
of personnel dedicated to spill containment and cleanup,should a
discharge incident occur.This response team would have a designated
leader who would direct the team. A complete training program in
spill response for this team would be essential.
4.To contain a small s ect ton on the project area environment.This
would include a map of major drainage areas,fish habitat and seasonal
descriptions,and wildlife habitat and seasonal descriptions.The
environmental section is very important in prioritizing spill response
actions (i.e.,most sensitive areas first),and for developing an ap-
preciation for the impact a spill can have.
C.Wastewater Treatment
The type of wastewater treatment plant to be used at each camp site has to
be described in greater detail to more adequately evaluate its effective-
ness.The di scharge from the Watana treatment facility may not met.~fecal
coliform standards because of inadequate dilution.The discharge zone
should be well defined for both facil ities.The Watana and Devil Canyon
camp wastewater treatment plants are to be functioning and approved before
each camp is in operation.
D.Concrete Batching Plant
Potential impacts that may occur from the concrete production process are
not descri bed in enough deta il •The di scharge from thi s proces s will a1so
have,in addition to pH changes,problems with siltation,turbidity and
possibly toxic additives used in the curing process.Siltation from
concrete can form a mat over substrate gravels.This could suffocate
emerging sa1mon fry or other i ndigenous organi sms that requi re subs trate
habitat.Discharges that may have toxic concrete additives as a component
may kill aquat ic organi sms.The batchi ng process may a1so have ai rborne
particulate problems.Specific control measures need to be described in
detail for each type of problem that may be encountered.
Mr .Er ic Yould
January 21, 1983
Page 3
E. Access Corridors
The access route (Plan 17) was det~rm i n ed ,during the access route selec-
tion process,to have greater pote ntial for major envi ronmental i mpacts
than the oth er route options.The major impacts of conce rn were:
1.The Denali Highway to Watana Dam site portion passes through habitat
that has historically been used by portions of the Nelchina caribou
herd.
2.Many nat ive grayling strea ms can potentially be affected during the
construct i on of the Dena 1 i Hi ghway to Wat ana Dam site access sect ion.
3.Access al ong the so uth s ide of the Susitna River from the Wat ana to
Dev il Canyon Da m s ites passes th rough the Stephan Lake r egion.Th i s
r e ~i on is i mportant habitat for moos e,wi nter ing car-t bou ,mi grat i ng
wa te rfowl ,an d fur beare rs.
4.Wet lands habitat is crossed southwest of Devil Canyon.
Because of the greater potential for major impacts associated with the
Plan 17 access option ,more attention should be given to defining the
methods that will be implemented to mitigate the :e impacts.For example :
1.How wi 11 the access route be designed to mini mize disruption to
the car ibou ~erd?
2.What t echnique will be im plement ed to prevent impacts to nat ive
grayl ing streams fro m road construction?
3.How will i mpact s to the Step han Lake reg ion be reduced?
4.How wi 11 project and post-project access be controlled to prevent
seconda ry impacts related to access?
F.Fi shery Impact Assessment
The fi eld data base is incomplete for an accurate prediction of the i mpact
the Susitna Hydroelec.tric Project will have on fishery resources.A good
set of data has been collected for only two years.Fishery population and
related wate r quality data can have inherent f l uctuat tons from year to
yea r,Long t erm,1arge-sca 1e programs need to be implemented in order to
ma ke a r easonably accurate population estimate.Very specif ic detailed
s t udies des igned to correlate physical and chemical aspects of the aquatic
h3bitat t o population flu ctuations need to be part of the long term pro gram.
Th is progr am should be cont inued t hrough project construction.
Mr.Eric Yould
January 21,1983
Page 4
If impacts cannot be accurately predicted,a worst case (100~1055)estimate
of the fishery population should be assumed and the implications this
impact would have to the aquatic community and related resource use need
to be discussed.By assuming a worst case estimate,a type of mit igat ion
program can then be developed where compensation to the fishery p?pulation
can occur tL result in an acceptable 1055.
A long term post-project aquatic monitoring program should be developed as
an integral part of the project.Funds should be allocated in advance to
insure the continued existance of this program.The monitoring program is
essent ia 1 to determi ne the effect iveness of mi t i gat ion measures that are
implemented.
G.Interagency Review Board
It is strongly recommended that a formal interagency review board be estab-
Ii shed to work wi th the Alaska POVier Authority in the development of the
Susitna Hydroelectric Project.This board will identify and comment on
soci oeconomic and envi ronmenta 1 issues and regulatory requi rements.It
is suggested that the Formal Oesig~ation of the Susitna TeChnical Advisory
Committee (see attached memo to you dated November 17,1982) be i~plemented
to accomodate this recommendation.
Once project construction begins,a similar interagency board should be
established to monitor the socioeconomic and environmental impacts and
regulatory compliance.This board would make recommendations to the Alaska
Power Authority to correct associated problems as necessary.
The Alaska Department of Environmental Conservation appreciates this oppor-
tunity to comment on the Susitna Hydroelectric Project,Federal Energy Regula-
tory License Application,l xhibit E and hopes that these comments will be useful
to you.If you have any questions,or if we can be of further assistance,do
not hesitate to contact Bob Martin or Steve Zrake in Anchorage.
Si ncere ly,
~~
Richard A.Nev~
Commissioner
Attachment
cc:Bob Martin,ADEC,Anchorage
Steve Zrake,ADEC,Anchorage
Su-Hydro Steering Co~nittee
Part 3 of SUS 347 (also SUS 10042)
Comments on Draft Exhibit E of Susitna Hydroelectric Project License
Application. Letter to Eric Yould from Esther Wunnicke, January 13, 1983.
• To Eric Yould, Executive Director, Alaska Power Authority
• From Esther Wunnicke, Commissioner, Alaska Dept. of Natural Resources
• 6 p.
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I L..'"-.\•l..-,•-'...i
:.'L '.SHEFFIELD,GOVERNCR
DH"'HT~II:NT ttt·N~TU."I.RF.SOIIRCF.S
OFFICE OF THE CClMMSSlONER I,
January 13,1983
Mr.Eric Yould
Execut i ve Director
Alaska Power Authority
334 W.5th Avenue
Anchorage,AX 99501
Dear Mr.Yould:
~J 2 L H
The Alaska Depsrtment of Natural Resources has reviewed the draft Exhibit E
application for the Susitna Hydroel~ctric Project.We are submit :ing
comments on this document which in part satisfy the agency coordination
requirements established by the Federal Energy Regulatory Comaiss ion,
(FERC). The formal position of the Department of Natural Resourc~s regarding
the Susitna project is contained in the Exhibit E comments which follow ;our
April 16,1982 testimony to the Alaska Power Authority Board of Directors
(copy attached)and the letter to Eric Yould from Reed Stoops dated October
II,1982 (copy attached).We request that an unabridged copy of these
comments accompany the perfected application submitted to FERC.
ORGANIZATION AND PRESENTATION OF EXHIBIT E
In some cases the Exhibit E text,tables,and figures do not reference t he
documents from which the material was taken.The consequence of this
inadequate documentation is that the reader ca nnot determine the
specificity,accuracy or sufficiency of the Exhibit E.We recommend that
the speci fic references to ori ginal documents be included in this Exhibit E
before the application is submitted to FERC.
WATER QUANTITY AND QUALITY
During the past two years the Department of Natural Reaources has emphasized
the great lmportance of acquiring a clear understanding of the rela t ionship
of various flow-re lease rates from the proposed dams and the corresponding
i~acts on downstream aquatic re80urce~,habitats ,and uses.ibis
information ia vital to enable DNR to make informed decisions with respect
to instream flow reservations and water appropriations both of which are
required in order to facilitate the Suaitna Hydro Project.The flow
releases schedules presented in Exhibit E for filling and operation of the
Watana and Devil Canyon Dams have not been developed in consultation with
the Department of Natural Resources or by a methodology approved by this
Department whi ch 1.s charged by law witl:authority to adjudicate all water
appropriations and inatream flow reservations in the State.Indeed,
Exhibit E does not explain the process by which these release schedules
flows were devised.We strongly recommend that the license application
contain a specific.detailed flow release schedule developed through a
quantifiable instream flow analysis program coordinated with DNR and with
state and federal fish and wildlife ag encies .
Attached please find the entire text of the review comments from our
Division of Land and Water Management.Please consult that text for
additional specific comments relating to navigability .thermal modeling.and
nitrogen gas supersaturation.
ACCESS
This department's comments regarding the proposed route from the Denali
Highway to the project site should not be construed as support for that
V loj ~~L LuuLe &b the preferre~~ans of ~ccess.This agency.along Witn the
other state and federal resources agencies/has consistently favored road
access to the project from the Parks Highway.However,if the route
proposed in Exhibit E is selected.we recommend certain design
modifications .
We recommend that the principal design criteria for the proposed route be
the enhancement of scenic values and public safety.We consider the
proposed high-speed design of the road inappropriate.The long-term use of
the road after dam construction will be primarily sightseeing and
recreation.The highway should.therefore.be designed to take maximum
advantage of the scenic potential of the area which traverses some of the
most dramatic in North America.
In addition to being an unattractive counterpoint to the natural landscape.
the high-speed road proposed (55 miles per hour with 40 miles per hour at
difficult curves)may create serious safety problems.The long braking
distance for a vehicle traveling 55 miles per hour on a gravel road
endangers the stop and go driver and those who park and stand along the side
of the road to take photographs.Although a high-speed road will yield cost
savings during dam construction,it is questionable whether these cost
savings outweigh the long term benefits of a scenic road.The rationale for
a high-speed access road design should be based on an explicit
quantification of the cost saved by that design.We believe the scenic and
public safety benefits foregone by a high-sp~ed design when accumulated over
the expected life of the road are almost certainly greater than the costs
saved by such a design to facilitate the brief construction phsse of the
dams.
Although design standards for upgrading the Denali Highway between Cantwell
and the proposed access road were not discussed in Exhibit E the issue
merits comment because an upgrade will be necessary to accommodate
project-related traffic.The portion of the Denali Highway affected
provides excep tional views of the Alaska Range,Reindeer Hills and the
Talkeetna Mountains.The Alaska National Interest Lands Conservation Act
(ANILCA)of 1981 called for a joint state,federal and private study
of the scenic qualities of the Denali Highway.The intent was to encourage
cooperative land management of lands adjacent to the highway to protect its
important scenic values.The Denali Scenic Highway Study will be published
in early 1983.DNR encourages APA to consider carefully the recommendations
of that report and to support a design which is consistent with the study
recommendations.
Finalll,we recommend re-routing of the proposed access road where feasible
to take advantage of the extraordinary vistas.Presently the r oad transects
a large wetland in the upper Brushkana drainage.Consultants l c .~onsible
for the aesthetics portion of Exhibit E re commended that this section of the
road be re-routed to higher ground to the west.We concur and support that
recommendation,which will also protect the wetland from the impacts of road
construction and should result in lower long-term maintenance costs because
of better soil conditions.
RECREATION AND AESTHETICS
We agree with the consultants'conclusions that recreation plans be focused
on those opportunities occurring elsewhere in the project area rather than
those directly associated ~.th the reservoirs.Because of fluctuating water
levels and steep shorelines,the reservoirs themselves will not present an
attractive recreation environment except for occasional use by speedboats.
The greater recreation opportunities will be associsted with the access road
and the many lakes,streams,and alpine hiking areas that can be reached
from that road.The consultant~identification of recreation resources on
Cook Inlet Region,Incorporated (CIRl)land raises the question as to how
these recreation opportunities might be realized .We recommend that the
Power Authority consider Bome sort of leasing or concession arrangement with
CIRI to facilitate public recreation use on Stephan Lake.At least one
public use site of a suitable size (40 acres or more)should be provided at
Stephan for camping,fishing,and as a staging area for those people using
the lake for float trips down the Talkeetna River.In addition,legal
access acrosp.vl11ag~and regional corporation lands should be secured and a
trail constructed from the reservoir to Stephan Lake.In order to most
effectively enhance the recreational potential of the proposed projects,we
would recommend that the recreational element of Exhibit E a dd three sites
adjacent to the Alaaka Railroad.These sites are Indian Rive r ,Gold Creek,
and Curry.Each of these sites would provide a destination point for
recreation users of the Alaska Railroad and would provide a greater
diversity of recreation opportunities.We recommend that management of the
off-aite recreational facilities associated with the access r~ad are best
met through the budgeting process of the Alaska Power Authority.If the
Division of Parks is expected to manage these sites,then we will have to
work closely with APA to ident Ify priorities for project fuuding.
In summary,we feel that the connultant has done an excellent job in
identifying the recreation opportunities and resources available in ~he
project area and would request that the scope of the study be expand~d to
look at the identified sites along the Alaska Railroad as described above •.
HISTORIC AND ARCHEOLOGICAL
The report on historic and archeological resources is well done and
addresses all the pertinent questions about mitigation.We concur with the
attigation plan as presented in the draft document.
We concur with and support the proposed education program described on Page
E.4.114.We consider such a progr83 to be a necessary and effective part of
any larg~construction project.If project personnel are adequately trained
and sitec are clearly marked,avoidance should be a viable ~tigative
.easure in many of the indirect and potential impact cases.
TRANSMISSION LINE
The Access Plan Recommendation Report dated August.1982 proposes routing a
transmission line through a non-roaded area south of the proposed road
between the d~sites.The line was well sited taking advantage of terrain
and v e ~e t a t i o n to m1nl~ze eDvl~onmental AI.d visual iapacta 8b well as
minimizing construction costs.We support the route proposed in the August
report.We have since been informally advised that APA has decided to route
the transmission line along the road between the daa sites to allow
year-round access for maintenance (winter over-land access via all terrain
vehicle is feasible without a road).If road access is determined to be
absolutely necessary,we agree with this decision;it would be inappropriate
to have two east-west road corridors through this area.However,
presentation by consultants at the APA sponsored workshop in Anchorage
during the week of November 29 to December 3,1982,indicated that there may
be excessive concern by maintenance engineers with year-round access.The
consultants argued persuasively that maintenance by helicopters is not only
feasible,but is cheaper than road maintenance and is a common practice in
states other than Alaska.Helicopter maintenance bas also proven itself in
more rugged terrain and extreme weather conditions o~southeast Ala8ka~
The need for road access in case of bad weather Is a concern,but it Is
important to clarify precisely what is gained in terms of minimizing the
risk of power outage by having road access.That gain should then be
compared with the costs.In this case the major cost is a strong negative
visual i.pact on the road between tl~dam sites.In contrast,the gain
seems to be ainimal.In short,the value of year-round access Is not
infinite and in this case may be significantly less than the costs.
SOCIOECONOMIC L~PACTS
The permanent townsite appears to have been located in an exceptionally wet
area.Apparently the major criterion for locating the townsite was land
status.A more appropriate location from the standpoint of land capability
and general a'lenities for the inhabitants of the townsite would be in the
Fog Lakes area south of the Sus1tna River on privately owned land.The
townsite 1s particularly 1mportant because,as indicated in the Exhib1t E,
the tendency for workers to reside on-site dep~nds on the qua11ty of housing
and nther ~~n 1 t i e s .Exhibit E emphasizes that a high amenity site will
minimize impacts on outlying communities by encouraging a higher perceutage
of workers to live on-site.We support this objective but do not think
siting the townsite as proposed will help achieve it.We strongly suggest
finding a more suitable 10cat1on for the towns1te.
Exhibit E projects minimal project impacts on local facilities and
8ervir ~s due principally to the provision of on-site housing for ~urkers.
The total Mat-So Borough population increase as a result of the project is
projected as 4.700 in 1990 (peak year).1.110 of whom are expected to live
off-site in rural communities.Should that projection be accurate.the
off-site impacts would.indeed.be limi t.ed.However.the projection assumes
absolutely no in-migration by unsuccessful workers.This is a misleadin~
assumption.In fact.in-migration by unsuccessful job seekers will probably
be considerable.Such in-migration is a likely result of decreases in job
opportunities in the lower 48 and has occurred in Alaska during construction
of the nil pipeline.Current economic conditions would stimulate extensive
in-migration to a greater extent than is predicted in Exhibit E.
If in-migration is seriously underestimated in Exhibit E.then a wide range
of socioeconomic impacta is underestimated as well.Past experience in the
state shows that boom conditions,such as the proposed dam construction
would create,have led to rent increases,~rollferation of sub-standard
housing and strain on public facilities and services.The potential impact
caused by unemployed in-migrants is particularly significant in light of
their tendency to be more of a disruptive influence on saall communities
than employed in-migrants.Unemployed in-migrants.for example.tend to
require more services such as public health and family assistance of various
forms.They pay fewer taxes and may have little stake in the community.
thus caring less about relatively minor issues such as yard maintenance and
the appearance of local parks.In the small.rustic communities in the
project area,these problems could create considerable tension between
current residents and the new in-migrants.We consider the socioeconomic
impact assessment to be inadequate without an attempt to estimate the
numbers and effects of unsuccessful job seekers and their dependents who
will move into the region.
It would be more accurate and useful tn provide a range of projected
population increases in affected communities rather than a precise number
such as 263 in Talkeetna by 1990 or 75 in Trapper Creek.These numbers
convey a precision not supported by the methodology or the probability o f
error inherent in such projections.More useful information for community
planning purposes would be a high-low range.A key consideration in
planning for public services is the populati,n threshhold which requires new
capital expenditures.For example.if a population increase of 300 would
require a ne~community well in Talkeetna.the city would be better off
knowing that it fac~s a probable incr~ase of 250 to 350.rather than knOWing
that someone has disaggregated a series of numbers to produc~an estimate of
263.
Exhibit E discusses generally the need for measures to ensure that the local
unemployed get a chance at project-related jobs.Assuming there will be
considerable competition for jobs by in-migrants and that the state's
objective is to encourage local hire.it will be necessary to develop a
clearly defined and legal program to achieve that objective.The measures
recommended by Exhibit E are vague and do not reflect the significance of
this i s.ue to the state or the borough.We suggest more attention be given
to developing a more comprehensive approach to address this issue in the
Exhibit E application to FERC.
ALTERNATIVE ENERGY
nee Exhibit E devotes about four and one half pag es t o the geothermal energy
alternat ive.This informat ion i s factual and provides general background
for the reader.The Exhi bi t E could be improved by noting tha t the
Department of Nat ura l Resour ces has a geothermal lease in the Mount Spurr
area planned fo r Hay.1983. The Exhibit E should ac knowledge thst
geothermal en ergy i s i mmu ne to f uel price escalation as is hydropower.We
agree with the Exhibit E statement that little is known about the geothermal
properties.Until exploration of the geothermal properties of Ht .Spurr has
occurred the viability of gpothermal power for the railbelt region is
unknown.We recommend that the Exhi bit E be revised to include this
information.
In summary.~~sppre ciate this opportunity to provide formal review comments
to APA on the draft Exhibi t E.
Slnce lely yours ,
L.h'<U/(!tJ~
Es t her Wunnlcke
Co..tss1oner
At tachJoents
cc :Division Directors
Special Assistants
Part 4 of SUS 347 (also SUS 10043)
Comments on Draft Exhibit E of Susitna Hydroelectric Project License
Application. Letter to Eric Yould from Keith Bayha, January 14, 1983.
• To Eric Yould, Executive Director, Alaska Power Authority
• From Keith Bayha, Assistant Regional Director, U.S. Fish and Wildlife
Service, Anchorage
• 7 p. with 112 p. attachment
u ·nited States Depanment of the Interior
I'N REI'l y RlFI .. TO;
WAES
FlSH AND WILDLIFE SEJt VICE
1011 E. TUDOR RD.
ANCHORAGE. ALASKA 99S03
(907) 276-3800
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Eric P. Yould, Exec:uthe Director
Aluk& Power· Authority
334 West 5th Avenue
Anchorage, Alaska 99501
De&r Mr. Yould:
1'4 JAI 1983
The Ffsh a.nd W11d1ffe Servfce (FVS) has been requested by letter cated 15
Novtllber 1982, fr011 Acres '-'"fc&n, Inc., to fo,...lly rev·few &nd c~t on
the Federal Energy Regulatory Ca.fssfon (FEAC) draft license applic&tfon
Exhfbit E for the Susitna Hydroelectric Pt-oject. This response is being
provided as parti&l fu1f111aent of your request &nd fs intended to be a
constructive evaluation in reg&rd to fish and wildlife resources. we hope
that our ca.ents will be of value fn drafting the final Tfcense application.
The following FWS letters were also provided in response to foral
pre-application requests on this project:
1. 2.3 June 1980, lett• to E.rfc You1d.
z. 17 Oecllllbel" 1981, letter to Er1c You.ld.
3. 30 Declllber 1981, letter to Erfc Yould.
4. 5 January 1982, letter to Eric Yould.
Since these letters were forully requested as part of the FERC
pre-application coordination proces.s we consider it appropriate that c;ur
responses be specifically addressed as p&rt of the E.xhibit E.
The following letters were ~rovfded as informal consultation to facn ftate the
Susftna Project planning procAss:
l. 15 November 1979, letter to Er1c Yould.
2. 16 April 1982, testi.,ny presented to the Alaska Power Authority
(APA) Board.
3. 17 August 1982, letter to Eric Yould.
4. 5 October 1982. letter to Eric Yould.
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we anticipated s•ing in the draft Exhibit E specific responses to the
concerns and rec~nciations raised in the letters and test180ny provided.
This 1s consistent with advice provided by the F'ERCl!. In that this did not
occur, we reco-.nd that the 11A re.spond in the Exhibit E to the specific
caa.nts and reca.endatfons wh fch &re contained fn these lett .. s and
testi110ny.
The response provided by this letter, our previous letters (both those
fonully and inforally requested), the testf.,ny .presented to the 11A Board,
and the letter recently provided to you on 19 Novelber 1982, constitute the
official position of the FWS on this pr?jeet. ·
The principal authority of the FVS to provide c.-rats and rec:a.endations
rests fn the Fish and Wildlife Coordination Act (48 Stat. 401, as ... nded; 16 u.s.c. 661 et seq. >Y. 11te Coordination Act requires that fish and wildlife
conservation be given ,~al consideration with oth .. project futures
throughout the Federal ead agencies' planning and decision-aking processes.
The Act also requires consultation with State and Federal fish and wildlife
resource agencies tD asca"'Uin what project fK11itfes, operations, or
...sures -.y be considered necessary by those agencies to •ftfgate and
COiilpensate for project-related losses to f1sh and wildlife resources, as well
as to enhance those resources. The reports and rec12nendations of the fish
and wildlffe resource agencies on the fish and wildlife aspects of such
projects wust be presented to action agency decision-akers and ewe. ...
applicable) to Congress. The Coordination Act requires ..-e than 1
consultative responsibility; it is &n afffr.ative .. ndate to action agencfes.
Like the National Enviro,..,.tal Polfcy Act (NEPA) (42 u.s.c. 4321 et. seq.), ft
requires early planning and post-construction coordination and full
consideration of reca .. endations made by resource agencies.
Our rec~dations, under the Coordinatf·on Act, •st be, •as speefffc as ts
practicable w1th respect to features r~nded for wfldlffe conservation and
devel~t. lands to be utflfzed or acquired for such purposes, the result~
expected, and shall descr-ibe the dlage to wildlife attributable to the
project and the .. sures proposed for •ftfg&tfng or ca.pensattng for Ulese
d-ges.•
Sf111lar language is found in NEPA • s Section 102 (2 )(B.) that agencies ident.ify
and de¥elop Mthods and procedures which will insure that presently
unquantiffed enviro,..,.tal a.enities and values -.y be gffen appropriate
consideration fn decfs1on..akfng, along with econo.fc and technical
considerations.
Y Appendix A. FERC Applfca.tion Procedures for Hydropower Licenses,
Exa.ptions and Prelf•1nary Permits. April 1982.
~ The Federal Power Act (16 U.S.C. 791a-825r; 41 Stat. 1603), as ... nded,
as interpreted in Regulations {F.R. Vol. 46, No. 219, 13 Novelber
1981) specifies requir..ents to satisfy the Coordination Act.
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Both the Coordination Act and NEPA, necessitate, c~surate with the scope
of a pr·oject:
(1) A description and quantification of the existing f1s~ and wildlife
and thetr habitat within the area of project 1~~pacts;
(2) A description and quantification of anticipated project i~~pacts on
these .-.sources; and
(3) Specific •1tfpt.1on •asures necessary to avoid, •in1•ize, or
CCJIIIMI'Sata for these 1~~p~cts.
we have revfwed the draft Exhibit E fn consfdwation, of these statutes. The
adequacy of the review doc.-at has been eu.1ned fn respect to .e.ether or not
the fnforution, analysts, and lrftfgation plan provided would allow the FERC
to be in c011pl1ance witt. the requtr..nts of these envfro..ntal .andates if
they tssuld a license to the applicant.
Our review has been undertaken tn light of our f~ correspondence,
includ1ilg the 16 Apr11 1982, testf•ny presented to the •A Board by Deputy
Regional Director LeRoy Sowl. Except for ft. (8) we find the testimny as
valid today u tt was at tllat tt•. It fs appVent that the consultation
process has fa111d tn so far as the intent of the FE~ regulations!!. We
have written nu.rous letters on this pro .Ject to assist M'A 1n planning
.usures to protect and enha_nce fish and wfldlife resources. Responses to our
lettrs have been non-existent, ar too late to deal with the prob1• of
concern (e.g., FWS letters dated 5 October 1982, and 19 Nov...,.. 1982). An
illustration of .e.at we havt found to be an inadequate level of consu1utfon
can be found in the 15 Oeclllber 1982. response to o":r 19 llov...,. 1982.
letter. Ve ~sidered our requests to be fully within the fntant of the FERC
regulatfons!!.
Attached to thfs letter are our for.l c~ts on the F"ERC draft license
application Exhibit E for the Susftna Project. C~ts are provided on
Chapters 2, 3, 5, 7, a. 9, and 10. We have also revfewed Chapters 1, 4, and
6. However, we do not at th 1 s t 1• have 1n1 c~ts to offer on these
chapters.
The c~ts provided are organized fnto general ca.ents and specific
c~ts for uch chapter. In our attapt to be as responsive as possible
w1thfn the 11•1ted tf• fr .. IIA has established for our review and ca••nts,
we have not been able to organize our ca..ents into 1 COiprehensfve lfstfng of
def1cfene1es, clarfffcatfons, fnforation needs, and reco.end&tfons. Many of
these ca.ents have been left W'fthin the context of the HCtfon wfthfn whfch
they are raised. We feel by c~tfng 1n this way it w111 assist you fn
consistently correctfng the def1c1encfes fdentffied.
Y See Footnote 1 • supra.
Y See Footnote 1, SUJ!'I•
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The following ca.ents are generally applicable to several chapt1rs and, tn
sa.. cases, are applfca~le to all of the chapters:
1.
2.
3.
It fs our under,undfng that the projections of future ~ needs used
tn the 11cenu •pp11at1on are generally agreed to be higtl!/ and are
being rHvaluated for sublltttal to the FERC after the license application
is subllftted {Acres -..ican Deputy Project Manager John Haydet1, personal
c~ntcation). The changes in the load forecasts a" dr-ttc. Ig the
Acres ,_,.tcan report evaluating econa.ic tradeoffs of flow regt.s!/
the ass-.ct .ad•ate load forecast for the year 2010 is 1 791
geptAtt-hours {&Wh). In the latest Battelle NewsletterTJ the -..ate
forecast is 4,986 , ... and the low forecast fs 3,844 &MI. The signtffcant
decline in pf"Ojected power d.ands has large illplfcatfons to .any of the
project USUIIptions .tlfch have constrained •1tigation planning, for
eXMple: available waw for downstre• flows; .ode, t1•1ng, and :•outing
of construction access; and sd•edulfng of work. The lfcense applfcatton
~ould fully discuss the tlplicatfons of the latest load forecasts.
The intent of the Coordination Act and NEPA is that envfro.-ntal
resources be given equal consfd•ation with project features. Consistent
with NEPA, as •11 u the IIA Mitigation Policy, avoid&nce of adYtrse
i11pacts should have b .. n given priority as a •itigation .. asure. we have
found thts generally not to be the ease, for ex.-ple: lOde, ti•ing, and
routing of construction access; sehedulfng of work;. type and siting of
the construction ca.p/vtllage; recr•ation develop~ent; tnstre .. flow
regt•; and filling schedule. Other ex111ples can be found fn our
Spec.ffic C~ts.
Engineering and environ.ental studies do not s ... to be tnteractfve. It
appears that the findings of enviorr•ntal studies have not been
integrated tnto the enytneerfng design. This ay be due fn part to the
short tt .. fr-estab fshed for project planning. An u•fnation of the
sequencing of the studies fllustrates thfs probl•. It is our
understanding that the Aquatic Studies Progr•, designed to be the basis
for determination of f11pacts to the aquatic syst• and associated
•1tigation ..uures, was established as a ffve year study. We are now
two years tnto this progr•. The analysis of the data to allow an
assesSIInt of i~~pacts and for.ulat1on of •1tfgat1on proposals .ay add
another year to thts pr-ocess. N'A elqMCt.s to obtafn a lfcense, and
!I Battelle. Nwsletter 14 (Final): Raflbelt Electric Power Alternatives
ll
Study. Dec:llllber 1982.
Acres ~fan. Energy St.ulatfon Stucfte.s to Select Project Drawdown
and Mit1gtt1on Flows. October 1982.
!J See Footnote 4, supra.
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blg1n construction fn late 1984, or early 198581. Obviously, this does
not alTON for an f~act analysts and mitigation planning bas4d on these
studies prior to licensing. Mitigation planning, and an ass~u581nt of
tht i~acts of different •itigatfve options needs to be undertaken in
regard to project costs, viability, socioeconomic consfderat1ens, and
•1t1gat1on proposed for potentially c01p1ting interests. This should all
be, cons1dered through the dtvelo.-nt of the enviro.,.ntal fapKt
stat ... nt, and clrta1nly prior to license issuance.
4. N.-,.ous tXIIIplts of Tack of coordination and/or ~nicat1on between
the groups responsible for the different study el..ents are evident.
~les can be found by e01p1ring discussions concerning lrtni.u.
downstr•• f1ow releases tn Chapters 4 and 10 to what 1s found in
Chapters Z and 3. Raservoir tellperature .odelfng discussions in Chapter
10 are not consistent with what is stAted fn Chaptws 2 and 3. Another
txJ111Ple 1s found fn the •1nf•l level of conc .. n expressed in Chapter 10
r~ socioecona.ic (Chaptw 5) considerations, such as illpKts of lfcen,se
den11"~. Mort specific ~nts are included in the attached doc-.nt.
Other ExiH~1 ts wwe not provided to us for rhiew although we requested
th• by letter d&ted 19 Nov-.r 1982.
5. Research of background uu .... tton is frequently inadequate and
inca~~plete. An exuple wouJ~ '"" the discussions concerning subsistence
(Chapters 3 and 5). ~1ore adeqaa"e research of this very illlpOrtant area
appears Justified. we have lfsttd s~vwal readfly avaflable refereacas
which would be of value in f~ovfng this discussion.
In Chapters 2 and 3 •int ... l inforation is brought into the discussions
concerning physical changes whfch have been observed at si•flfar
hydropower projects. We are sure that any of the potential i11pacts that
are discussed for Sus1tna (e.g., ta.perature concerns) art not unique to
thfs proJect. The State's experience with the Trans-Alaska Pfpelfnt
Syst• (TAPS) proJect could have been drawn upon .ore fully as an
1x111ple, particularly in regard to soctoecon011ic (Chapter 5)
discussions. Another ex.~ple is the discussion concerning natural gas
and geoth.,...l electric generation as alternatives to Susitna (Chapter
10). 'lery ltttle use was •de of existing 1nforut1on bases.
6. Speculation fs n~t alwaJS claa~ly d1st1ngu1shtd fro. data-based
conclusions. Thfs probl• 1s 110st apparent fn Chapters 2 and 3 and
shou 1 d be corrected.
7. Ladt of quantiffcatfon fs a recurrent probl• fn the Exhibit. Neither
b&st lfne data nor f~~pacts are appropTfateJy quantified (e.g •• Chapters
Z, 3, 5, and 10). Stat_..ts fn the doc.-nt let us know that, •"'ch of
the discussion is based on professional jud~t,• (page E-3-3), and,
•f:1any of the sute.nts are speculative ••• and ••• unsupported,•
(page E-3-56). Othlf' stat ... nts let us know that ongoing, or planned
studies, will fill these nu.erous data gaps to allow a quantification of
the resources and i11pacts .tlfch would let us go beyond, 'the conceptual
!I Alaska Power Auth,orfty. Request for Proposal No. APA-83-R-QJO
Construction Manag ... nt Services for the Wltana Phase of the SUsitna
Hydroelectric Project. 15 Novtlllber 1982.
8.
9.
-6-
•itigatfon plan,• (pa91 E-3-116). Recognizing a probl .. does not, in and
of itself, corr"~ ft. We were particularily concerned with this fn our
review of Chapt• 3. In the Exhibft E, the existing resources should be·
quantified. Tlle potential i11pacts to these resources ~hould be
quantified and then evaluated over the life of the project. Only at that
point can specific, effective •1tigat1on .. asures emerge. WI consider
quantification of existing resources and i~~pacts and a specific,
effective mitigation plan essential to the develo,.ent of an acceptable
env fror.ental i~~pact mu.nt.
The ongo f ng. and p 1 annld studies, _. fch ar-e f-req..,.t 1 y noted
(particularly in Chaptlrs 2 and 3) should be fully fdentfffed so • can
u.1ne th• fn regard to thefr scope. WI cannot, oth.,..fse, dlt ... 1ne
_.at needs to bl done and the tf• fr-for aceo~~plfsa..tlt. Frth•
discusnfon is provided fn our Chapt.rs 2 and 3 general c.-nts, and
throughout our specific ca.ents sections.
In several of the chapters (e.g., Chapte-rs 2, 3, and 5) we are faced w1th
•1tigatfon options to contend wfth identfffed (although frequently
wtquantfffld) advrse 111paC'ts. For eu~~ple, fn Chaptlr 3 th•e are
discussions on the potential value of spiking spring flows far sal-..
out-11fgration and the installation of a fifth portal on the •tt·f-level
1nUke structure to provide wa,..., downstr-t...,..atures during
fillfng. If these •itfgatfon proposals have validity, they should have
been incorporated into the project design and operational plan. The
docuaent does not provide an adequate •itfgation plan as required.
In addition, •itigation .. sures which are presented should have proven
successful in Alaska, or fn a si•ilar envfron.nt. If the proposals are
not proven, then they would need to M daonstrated effective fn the
project area. Furth• discussion is provided in our Chapter 3 t~Mral
c~ .. ants sections.
10. Tlle need for an, effect1ve 80nitoring progru through construction and tile
~ation phase fs discussed fn •ny of the chapters. However, the
progr• fs not adequtely described. we fully support the estab11st.ent
af a 80nitorfng progr•. WI believe the progr• should provide for
participation by representatives of appropriate State, Federal, and local
agencies and be financed by the project. Tbis panel should have the
authority to reca..end .o~1~ieation of how activities are conducted to
assure that •itfgation is ~.,fectfve. a.a-ndld changes in the
•ftigatfon progru should be adopted ~rou~ a 81Cfaanf• establfsMd 1n
the license, •tually acceptable to a.l concrned bodies.
11. Unfortunately the rush to a~~t the schedule for the license applfcat1on
has resulted tn poor quality control, i.e., countless typographical
errors, •issing Tines, •f~refereuced tables and figures, unclear
sentences, internal inconsistencies, inadequate doc.-ntation, •issfng
references fn bfblfographfes, etc. This should have been elf•inated in a
thorough edft1ng prior to release for agency pre-license application
review. Our rtvfew for bfologfcal ca.pleteness was s081What haapered by
th1s ~,.obl•.
-7-
In the previously referenced FVS Tetteos and testf.ony, any of the s ..
concerns discussed above and fn the attached c~ts were rafsed.. It fs our
vf• that unless the issues raised tn this lett.r are sat1sfactorfly resolved
we do not believe the application could provide the basis of an acceptable
envtron.ntal i11pact stat-.nt. In this respect we consider the license
application to bt deficient.
We ~nd that you strengthen the license application by including
fnfor~atfon resulting fra. a thorough evaluation of the btologfcal data
collected during the 1982 ffeld suson. This would enable an usesaent af
the adequacy wfth the data base to support a sufffcfentl.r quantified i~~p~ct
analysts and, in turn, a spectftc. effective •ttfgatfon plan. We believe a
realistic appraisal could then be .. o. as to ~•n any r ... infng deficiencies
could be satisfied.
Attadl.ent
cc: WAES
Yvonne Weber, WG-FVS c. Olbeltus/Acres Alerfcan
Quentin Edson/FEAC
NMFS, EPA, ,.S, USGS, BLM, ADEC, AEIOC • Andlorage
A 1 C1rson/ ADIIR. Anchorage
AIFI6, Hu. Dh •• Su Hydro Studies, Anchorage
Chapter 1. GENERAL DESCRIPTlON aF THE LOCALE: No eo.ents •
•
Chapter 2. WATER USE AND QUALITY
General Cogments
In exagininy Chapter Z we were c ~ncerned that sufficient scope and
quantifications are not provided to allow a quantified • pact evaluation of
the f t sheries and other bfoloyical resources. The infor.ation provided should
allow for the developgent of specific and effective .. asures whfch would fully
11itigate for all adverse imp•cts. We are left wfth the definite illlpl"essfon.
dlat the project would, through changes fn streua flow, water qualfty,
teaper•tures, fee conditions, vegetation, and slough habitats, have
significant effects upon the resources of concern to us, particularly the
fisheries. However, quantification of Ute potenti•T impacts is generally
lacking, as are specific eff'active mitigation •asures. Of course the latter
can not be accoe~plished prior to the foraer, despite the atte~~pts found in
this chapter.
A significant portion of the lack of specificity found in Chapter Z is due to
the fact that although two years of data have been gath .. ed (1981 and 1982)
the Exhibit E reflects only the 1981 data. We have consistently s~ated that
the 1982 data be analyzed and included in .the Exhibit E (SH Deputy Regional
Director LeRoy Sowl's 16 April 1982 statement to the APA Board, and our letter
dated 5 October 1982 to Eric Yould). Our position reaains the same.
The chapter does not identify what studies have been coap1eted, what studies
were ongoing 1n 1982, and what studies are proposed. Until this is provided
we cannot detergine what studies we would like to see QOdffi~. and what we
see as beiny cl'fssed. \lithout this type of infonaatior., the. resource agencies
are placed fn a reactive gode, i.e. we can only cogment on what should have
been eXIIi11 ned in COIIi1p leted. studies. Howev.,. 1 in so doing, we can bitter
faci11ute the applicant's efforts to plan a project we can support. An
exU1ple of a proposed study Vhich is not addressed fn this dtapter is the
Arctic Environlillntal Inform.at ion and Data Center (AEIDC) study. The following
fs a sugaary of this proposed study:
The A£1DC proposal is designed to (1) accurately and coaprehensfvely
predict systa-wide strea.flow and tS~pQrature effects of the dllil(s). and
(2) interpret effects of such changes in terms of aquatic habitats and
fish populations . To aCcOiilpHsh these general objectives, AEIOC proposes
using a linked systea of si11.1lation .odels which requires data fr011 other
project studies, available lfterature soatrce.s, and professional judg .. nt.
The study fs a result of the need to consider the special aquatic habitat
relationships fn the Susitna River basin and the need to account for the
interrelated effects of fee, sedil8nt, strea.flow, and teDperature changes
which will aCCOIIIMnY construction, filling, and operation of the selected
d&lil or daas.
Most assesslilents of hydroelectric projects are based upon impacts
associated with changes in mean 110nthly streamflows and temperatures.
However, the actual impacts of the project aay not be caused by the gean
events but through changes in the natural pattern of streamflow or
tegperature variation. Further, a single set of ;ean gonthly flows does
not actua tty reflect instantaneous flows ;n the river; the ac.tua 1
predicted .. an monthly discharge wfll probably not occur dur;ng a given
uonth because of expected anomalies in hydrologic statistics. Therefore,
;t 1s necessary to predict the range of mean 110nthly flows expected, based
on reservoir inflow, ~er yeneration requirements, and dovnstream demands.
The AEIOC model system would depend heavily upon a reservoir operation
model to generate an exhaustive range of feasfnle weekly or monthly flow
regfaes and the expected variation over a 30 year forecast period.
The IIIOdel systea would include provisions far fee and sedi..,.t modeling to
account for changes fn substrate distribution, bed elevation or Channel
configuration which might result fro. project operation. At a •int.u.,
fee and substrate modeling would support the assUiptions that hydraulic
boundary condftfons either remain stable ar change wfthfn predictable
lfmfts wfth project operation.
The al"l"ay of predicted weekly or 110nthly flows and temperatures IDlY be
bfologfcally interpreted fn several ways. The available habitat data base
fs heavily weighted at thfs tfae toward know chua and sockeye salliiOn
spawning areas fn sloughs and sfde channels fn the Susftna Rfver between
Talkeetna and Devfl Canyon. Access and spawning dynaafcs wfth respect to
.. fnsteg discharge are the .. jor simulation goals of several ongoing ffeld
studies. The AEIOC modeling system could provide a tfme-serfes approach
to deterg;ne effects upon crftfcal lffe history stages of these species.
It fs possible that the entire rfverfne lffe cycle of chua salliiOn afght be
simulated under various flow regimes to predict long-term population
trends. A sfgflar analysis of sockeye salmon mfyht be possible.
The prfaary concept, agafn, fs ffrst to credibly and c~rehensfvely
predict all project operations and thefr effect upon the habitat-related
physical parameters wfthfn the systea; secondly, those eff-cts wfll be
interpreted, through long-tara farecastfng, fn teras of thl :r influences
upon affected salaon populations.
We support the proposed AEIOC study. It should provide the bash for
determining project fnstre .. flow f~acts and a reasonable assessment of
mftfgatfve alternatives.
It fs a~parent that the proposed fnstream flow releases are designed for
liiUfliUII power production and do not reflect biological needs. The 12,000
cubfc feet per second (cfs) ffgure far August reflects the gaxfmu. agaunt of
wat..-that can be discharge without sfgnfffcant econe~~ic effects. It fs our
understanding that the project releases would be 10,000 to 12,000 cfs yaar
round. no consideration was given to the potential fapact of the project
during winter when flows of thfs aagnftude might prove highly detrfaental to
the fishery. The potential value of spfkfng flows during the spring to
facflftate smolt out-mfgratfon and flush the sloughs of fee and debris fs
discussed. However, these flows are not reflected fn the proposed releases.
We consider ft very important that the license application contain a specific,
detailed flow release schedule, whfch fs designed to mftfgate project impacts,
protect or enhance conditions for ffsh spawning, feeding, unrestricted ffsh
passaye, out-migration, and provide overwintering habitat for ffsh in the
Susftna Rfver. Thfs schedule should be developed through a quantified
instreag flow analysis vhich has been coordinated with the FYS, National
~~rine Fisheries Service, and the Alaska Departgent of Fish and Gage (ADF&G).
In response to the APA request of 2 September 1982, the FYS, by letter dated 5
October 1982, provided input specific to the draft Exhibit E. le had expected
our coaaents to be addressed in the draft Exhibit E. This is in cogpliance
with the FERC recoaaendation that inforaation. included at the initiation of
foraal consultation, • ••• responds to the preliminary comments and
rec~ndations of the agenci~s.•9/ Since this was not done, our 5 October
1982 letter should be made part of our for;al response on the draft Exhibit
E. As such, the points raised in that letter should be specifically addressed
in the Exhibit E submitted as part of th~ license application. ~~ny of the
points raised would be most appropriately responded to in Chapter 2.
Avoidance of adverse iapacts should, in compliance with the APA Mitigation
Polfcy document, and l~EPA guidelines, be given top priority in the license
application. In particular, our concerns as to the decisions vhich led to
such project features as the cawp/village, transmission line routing,
construction access routing, turbine configuration, filling regime, flow
regime, etc., with regard to avoidance of iap~cts should be addressed.
Specific Comments
2 -BASELINE DESCRIPTIONS
2.3 -Susitna River Water Quality
(a) Physical Parameters
(i) Water Temperature
-r1ainstem: Paragraphs 1 and 2: Those liiOnths which are being referred to by
winter and sugaer should be indicated.
-Sloughs: Paragraph 1: The first step in understanding the temperature
relationship between the ~instem and the sloughs is to geasure the teap~ra
tures of both sites. This has been done. The relationship between the
gainstem and the sloughs regarding temperatures (as well as other ~ater
quality paraaeters) then must be established. This process, apparently, is
just beginning. To this end, one slough (#9) has been examined. This exami-
nation has focused, correctly, on the groundwater relationship. According to
Tony Burgess (Acres Agerican), in his Susitna Hydro Exhibit E Uorkshop presen-
tation (12/l/82) on groundwater upwelling and water tegperature in sloughs,
the yroundwater regiae can be modeled, but locally the match is not very
good: The groundwater t51peratures near the surface do not &atch the predic-
ted temperatures. Continued study is obviously indicated for slough #9.
After an understanding is achieved for that slough, the program would need to
be expanded to other sloughs, possibly sloughs SA, 11, 19, 20 and 21. These
sloughs have been r.10re intensively examined than other sloughs in this reach
of the Susitna River. Ue rec~nd that this general pro~ram be undertaken.
21 FERC Application Procedures for Hydrop~er Licenses, Exemptions and
Preliginary Pergits. April 1982.
4: The difference in tegperatures of the Chulitna ~an~•a~~ee~n~a..;.,r.r-:-:v~er~s~s~o~u:-.-7 be referenced at least by raonth. It vauld appear
that the cooler tegperatures displayed by these rivers would be useful in ar.
assessaent of post·project tsperatures effects at the confluence and further
dawn strearo:~. Ue recOiil:lend th is be exm i ned •
J.iiUc!
... Freeze-u~: Parafaph 3: The iQpact of this process should be fully
explainidn regar to river raorphology and maintenance of the present
riparian zone.
(iii) Suspended Sedigents: The percent contribution, by season, froa the
llaJOr suspended sid1Dent sources should be indicated. An analysis of the
anticipated changes, by season, due to the project operation should be made.
(ix) pH: The pH range, from 6.6 to 8.1, is broad and should continue to be
aonitored. The potential exists for a lethal pH shock to occur to aquatic
life with a change of 1.0 pH. A dlange of this aagnitude lilight be poss fb le
frog a reservoir water release. A pH bel~ 6.6 gay be haraful to fish
depending on the ~unt of free carbon dioxide present in excess of 100 parts
per gillion. Egg hatchability and growth of alevins could be adversely
effected at a pH range between 6.5 and 6.0. The need for a predictive water
quality model is apparent given the toxic heavy metals that occur in the
drainage. We recommend that one be utilized.
(d) Other Par ... ters
(iii) Others: The railroad right-of-way that parallels the Susitna River has
been spr~ with various herbicides for vegetation control for a period of
years. Herbicides used include agitrole, Z-40, bromicil, and Garlon (tordon).
Streaas of prfaary concern are Chase, Indfan, Lane, and Gold Creeks. A spfll
of Garlon occurred in Lane Creek in 1977. Sloughs located along the railroad
rfght-of...,.ay could also be recfpfents of sOiiJI of the herbicide spray. flo ffsh
and/or wfldlffe tfssues have been analyzed for food chafn herbicide iapacts fn
the area. Due to the type of herbfcfde used, we are certafn that detectable
IQOunts will occur over a long period of ti~. Please incorporate thfs
information fnto your discussion.
2.4 • Baseline Ground Uater Conditions
z.s ... Existing Lakes, Reservoirs, and Streags
~-........;,;;,;~---.........,........,.......,........,. ....... .......,,.........,............,......-1: Project features include transaission
ne gafntenance roads, railroad staging
areas, etc. and should be exaained within the context of this section. The
proposed Recreation Plan would lead to the encouragegent of f~acts to
n...-ous lakes throu~out the upper Susftna basin. Secondary f&~pacts
resulting froa the project would expand impacts to addftfonal systegs.
Z.6 -Exfstfng Instream Fl~ Uses
(b) Fishery Resources: Reference should be lillde to burbot and Dolly Varden as
igportant resident speci~s.
2.7 -Access Plan
(a) Flows: Paragra~ 2: The use of regression equations fn calculations of
peik and 1~ fl~s n Ifeu of actual discharge data should not be a substitute
for the collection Of data, When sfzfng culverts for engfneerfng fntegrfty or
ffsh passage. washouts due to undersized culverts resulted on the north slope
haul road and, .ore recently, at the Terror Lake HYdro construction sfte.
2.8 -Transgfssfon Corridor: Base Tfne fnforgatfon on the trans.fssfon
corridor from tfie dllil s1tes to the Intertfe has been acknowledged as Tacking
wfthfn the Exhfbft. As wfth other project features, the Exhfbft E should
provide base lfne data, igpact assessgent, and aftfgatfve planning. We
recogmend that this be done for thfs project feature. For further comments
please refer to our letter dated 5 January 1982 on the Transgfssfon Corridor
Report. Ue provided this Tetter as forgtl pra-lfcense consultation and
continue to vfew ft as such.
3 -PROJECT It-PACT ON WATER QUALITY AliD QUAHTITY
3.2 -U&tana Davelo.-nt: Reference fs •de to Exhibit A. By Tetter dated 19
t40viiliir 1982 we requested a complete copy of all the Exhfbfts. Thfs
fnforaatfon has not be received.
(a) U&tana Construction
~f) Fl~s: Paraflaph 1: The sfgnfffcance of the Toss of the one lilfle reach
ue to construe on would more appropriately be assessed in Chapter 3, under
Fishery Resources.
(ii) Effects on Water Quality
-Sus~ended Sedfments/Turbfdfty/Vertical Illugfnatfon: Para15aph 2:
Antic pated suspended sidimen~and turbidity levels should \i coapared, by
month, to the .-bfent condition$. Thfs would allow an ev~Tuatfon and
understanding of potential project impacts. The amount 01 spofl whfch would
be generated and the extent to vhfch grading and washing of gaterfal would be
needed fs not addressed. Thfs has obvious igplications in regard to water
quality and spoil disposal. Ue do not at thfs tfme have sufficent data or
maps wfth whfch to provide specific input. Ue would recogaend to the extent
possible, barr~ gatarfal be obtained from wfthin the future impoundment area.
It fs stated that, •downstraaa, turbfdfty and suspended sediment levels should
reaafn essentially the saae as baseline condftfons.• This would not appear to
be the case during the wfnter, when the ambient condftfons are crystal-clear.
-Contamination by Petroleum Products: Spillage of petroleum products fnto
the 1oca1 grayling streau would have sfgnfffcant impacts on thfs fishery. An
oft spill contingency plan should be presented fn the •ftfgatfon plan whfch is
fn ca~:~plfance wfth State and Federal regulations •
... Canaete Contallinatfon: The types of potential praoleas usocfated wfth
tfi1s activity Should 6i fdentfffed and a pollution control contingency plan
should be developed as a COIIpOMftt af the proposed 11ftfgatfon plans. Such a
plan aast be fn COIIplfance wfth State and Federal regulations. The Yut.,.ter
l'T"Htalnt section (page E·Z-37) fs a .,ch liiOre appropriate level of analysis.
(iv) Igpact on Lakes and Streams fn I:yeundaent Area: Dfscussfons regarding
borrow and spofl 111teriats are extra. y general. The potential sftes,
quant fty of •terfal to be r..,ved, or deposited, extent af cleaning that
wo ;d be necessary, ana biological descrfptfon of the sftes to be disturbed,
should all be described. Hftfgatfve analysis should address such issues as
tfafng constraints an various operations and measures required to reestablish
pre-project conditions for those sftes whfch would not be ~ently lost.
(v) Instre• Flaw Uses: Antfcfpated iapacts for flaws greater than the one fn
5o-year event Should b8 described.
-Fisheries: Para¥tapt 2: The desirability of avofdiny thfs fishery toss by
yatfng the divers on unnel should be discussed.
(vf) Facflftfes: General fnput fs provided fn our comments an Chapters 5 and
to. the decisions regarding the type, admfnfstratfon, and sftfng·of the
construction caap/vfllage were lillde without fnput fr011 resource agencies. In
addftfon, the tfmfng constraints placed upon the construction of thfs project
are no longer supported by econc.fc studies •• (Chapter 10. General
Caaaents). The Exhfbft should be revised to reflect updated forecasts.
Reference fs made to Exhfbft F. Although we have requested thfs Exhfbft, it
has not been provided.
-Uater Supply: It should be noted whether or not the features described fn
thfs section were coordinated wfth the Alaska Department of Environmental
Conservation.
(b) Iapoundgent of Yatana Reservoir
(f) Reservoir Filling Crfterfa
... MinfiiUiil Downstream Tar et Flaws: Para ra 1: The factors that went fnta
s s ery vs econom cs a eo ana ys s or determining the appropriate
downstream flows should be discussed fn detafl. At the Susitna Hydra Exhfbft
E ~orkshop (conducted on 29 Nove&Der thrauyh 2 December) it was indicated that
the analysis consisted of determfniny at what su;ger flows economic beneffts
drop off. Given that the econoaic analysis upon which this is based is
generally considered out-of-date (Battelle Newsletter 14, Railbelt Electric
Power Alternatives Study), confidence in this analysis from an ecanoaic
perspective gust be law. From a fishery perspective, ft is unacceptable.
Para~Taph Z: Once we have an acceptable instream flow regime, several gauging
stat ons will be necessary to assure proper flows. It should be recognized
that at least eight sloughs are located above Gold Creek and that several of
these currently support fish. Flows to maintain or, if possible, enhance the
productivity of these sloughs should be provided .
Paragraph 4: The out-cafgrat fon of sal1110n in the spring is as 1 ikely re.lated
to i)hoto-period and development as the other factors 1 isted. Very low flows
in the spring could cause ~:~~ny of the juveniles to raaain trapped in backwater
pools that are noraally flooded under pre-project conditions.
Parafaaph 6: The proposed flows of 12,000 cfs have not been deaonstrated to
Ql1n\11n the integrity of slough gorphology and provide the flushing flows
needed to clean fines out of gravel . Also, the potential probl .. of beavers
colonfziny many of the sloughs, not being naturally controlled by flooding,
and therefore interfer.iny w·ith fish usa.ge of the sloughs should be addressed.
Cogpeting interests of aquatic and terrestrial project CQiilpOnents such as
sa h:10n !! beaver confHcts have been given· mini~al attention in the Exhitiit • .
Para~aph 7: Adequate fnstream flows for the winter period should be
estib 1Shed according to fish requiregents. This is a critical period for
fish and eve n e~inor dewatering ray have siynif icant de.leterious effects.
(fv) Effects on U&ter Quality
• Water T~erature: The tir;aing and consequences of the filling regime. on
downstrea&lecJperatures should be better defined. Just as modeling needs to
define operational thereaT changes, the thermal processes should be QOdeled
for the filling period. FrOG1 thh we ray be able to consider mitigative
lillasures •
.. Suspended Sediaents/Turbidity/Vertical Illugination
• Watana Reservoir: Paragraph 3: Discussion should be provided on the impact
of water quality Chanyes on the photosynthetic process downstrear;a of the
reservoir. ·
Paragraph 4: It is stated that, • ••• the river will be clearer than under
natural conditions.• This lillY be true durfny the suLitler, however, it is our
understand i ng that this wi ll not be the case during the winter •
• \olatana to Talkeetna: \ole believe the increase in winter turbidity r.Jight be
gore 1Qportant 1n terms of potential f i shery igpacts . Qua ntification of
potential changes should be provided. The methodology by which the suamer
turbidity leve l s were established and why it 1s not Applicable to predicting
winter conditions needs to be explAined •
• Talkeetna to Cook Inlet: AnticipAted chAnges during the winter should be
discussed.
i!l_Effects on Groundwater Conditions
-Iepacts on Slou9hs: Paragraph 1: The potential impacts on slough habitats
are not clearly descr16id. The discussion provides the impression that ther~
is a greater understanding of the groundwater relationship between the slo~ghs
and .. fnstea than is warTanted by studies to date. Please refer to our
c~nts under Section Z.l(a)(i) -Slou9hs.
Parasr:s 4: It is indicated that rt-uced ~ging would result from the
decrea winter flows. The potential 1~act should be addressed in regard to
the potential to diWater s.,_wnfng ud ruring hlbitats.
Para~a~ 5: Although the teaperature relationship of the 111inst• and
slou s oes not appear to be well understood, discussion should be included
on this potential i~act, particularly during the second year of filling when
the differences frCIII pTe-project conditions are grutest.
(vii) Effects on Instream Flow Uses: Please refer to our comments on Section
~(a)(i) -SfOu~s, and 3.2{b){v) -I~act on Slou~s. The statements of no
t8Dperature e~.C s are not supported ~ data or ci~tion. The reduction of
flows through these sloughs is not quantitatively defined. The loss of
scouriny flows to c'lean fines, r1110ve beaver dllils, and clear ice could result
in siynificant loss or degradation of slough habitat for fish.
(c) Wlt&na Operation
.. f~iniliUII Downstrelli1 Tar~et Flows: The criteria are not provided which led to
the development of the 1 arget1 flows. Apparently, no consideration ts
provided concerniny raxflilll flows, which may be a rJOre i1111portant consideration
during w-inter than estab 11shing a ~:~in f-.. flow leve 1.
Sigulations: Para ra 1: The potential igpacts of the
wa r year e lliJt rou s ou e fully addressed. The effect of this
naturally occuring event should be described 1n regard to Watana operations,
how downstrellil flows would be maintained and how it would effect the
biological resources. For exllilple, we suspect that higher downstreUIS flows
would be necessary to allow entran.ce to sloughs during this pertod •
• Daily Operation: In that the Devil Canyon deve.l'o,.ent ay not COfile· on-line
ro;:-rany years, if ever, consideration should be given to operations without
the Devil Canyon du. A greater level of concern and discussion should be
forthcoming on avoidance of potential ililpac:ts to the sloughs above Gold Creek.
-F'loocis
• Spring Floods: Para¥iaph Z: In that spring floods are part of the
pre-project regime, dscussion should be provided as to the igportance of thi's
pttenogenon and whether or not post-project simulated spring floods should be
il'cluded in the post-project flow regime.
(if) Rher l·lorphology: Parayraph 2: The discussion on ice process should be
expanded.
Parasraph 3: The discussion leads to a view that eventual loss of the slough
hib1tats 1s inevitable. The flow regilile proposed does not counteract this
potential problllil. Avoidance of this iapact through flow liiOdif'fcations is
consistent with the APA Hftigatfon Po 11cy document and NEPA. It illustrates a
low level of biological consideration in the formulation of the proposed
instreu flow regiGII.
(iii) Water Qualft.y
-Water T!!perature
• Reservoir and Outlet Water Tegperature: Para!]aph 2: 1982 data from Eklutna
Lake, Wh 1Ch Watana Reservoir is expectid to 111111 c, was presented at the -
Susftna Hydro Exhibit E Workshop. During the winter, Eklutna Lake showed
t1111peratures ranging froa oo to 3.60C 1n the upper 2 .. ters, dropping to
fsoth1r1111l conditions below this depth. If Watana Reservoir exhibits a
sf•flar shallow winter stratification ft would appear that Watana could not be
operated to, • ••• take advantage of the temperature stratification within the
re sel'V i or. •
ParaJlaphs 5 throuJ!!7: Given that the temperature 1010del has only been run
forve months an his only one year of data for that period (1981) this
discussion •st be, considered speculative. It is our understanding that input
for this uodel is lacking because previous data was tailored to an earlier
taperature liiOdel which is no longer considered applicable to thfs project.
It would seesa· prllillture to place liiUch faith in the new li10de1 based on the
mini1111l level of testing to date. We recomaend that data from two full years
be inputted to the model and the results be provided fn the Exhibit E.
Paragraph 8: This sugyests that winter outflow tegperatures between 10 and
40c can be selectively withdrawn through a multi-level intake structure.
This would be dependent upon the thermal proffle of the reservoir during the
winter, a. period which has so far not been .,deled. The statement suggesting
that one deyree water temperatures can be selectively obtained ~s
speculative. It is also in conflict with the information provided at the
Susitna Hydro Exhfbit E Workshop where Eklutna Lake was presented as a lilodel
for Watana Reservoir. Eklutna Lake showed winter temperatures between oo
and 3.60C within the upper two li18ters of the surface. If Watana Reservoir
shows a similar winter stratification one should not expect to be able to tap
tSJperatures other than 40C with the proposed 1111lti-level intake structure.
It would have been appropriate to reference the Eklutna study findinys here as
is done on page E-2-61 •
• Slough Water rr-eratures: Paragraph 1: Please refer to our coaants on
Section-2.3(a)(1 -Slouijhs.
-Ice: Paragra~ 1: It should be clarified as to what would be the impact of
the reduced con rlbution froa the upper Susitna River. Estitwltions of
post-project fee staginy should be c011pared to pre-project conditions and the
methodology by whfch the predictions were made should be explained, and/or
referenced.
Para~a¥h 2: How ice fs lost to the systeD, post-project, would draDatically
change ror.1 pre-project condUfons. The fgpact of this rajor change 1n ttlfs
riverine systesa should be thoroughly explored, not ~:~ereJy noted.
-Turbidity: Para~aph 1: Please provide 1n explanation as to why, •rurbfdfty
fn the. top TOO fee of the reservoir fs of prflillry intere.st. •
-Nitrogen Su~s.turation: Discussion should be provided specfffc to the
fixed-cone vaSVis. It fs stated that the valves would discharge spills up to
a one fn SO year event, but we have no fndfca.tfon of the anticipated ext.n.t of
their use. Withdrawing water frOiil the hypol1111ion they would often be
counterproductive to wt.~t is intended to be achieved through use of' the
aulti-level intake. Th~ potential for theraal shock in fishes, or shock due
to rapid shifts in other water quality paru.ters, should be evaluated . Rapid
water level changes would also be an obvious result of their use, particularly
be.tween the d11:1 face a.nd the powerhouse.
3 .3 De.v il Canyon Deve 1 Op!i!!!!t
Jii) Water Qua11tl
-Concrete Contaginatfon: Please refer to our comgents on Section 3.2(a)(1i)
-Concrete Contl£11n~tion.
(vi) Fac111t fes: Oe.cfsions regarding the Dev i1 Canyon support facflfties were
caade without input fr011 resource agencies.
appropriate
e described, and incorporated into the
(b) W&tana Operatfon/Dtvil Canyon Iapoundment
(ifi) Effects on Water Quality
-Water Temperature: The ability to contfnue to selectively reaove very
narrow tegperatures bands would depend upon numerous unknowns; aSSUiiling the
ab111ty e·xfsts with operation of Watana alone. Removal of such a sizeable
quantity of water fn so short a period of tfge certainly would have
fr.1plications for one's ability to select tegperature bands during certain
t1ras of the year. It should be stated that the: teaperature CIOde 1 upon which
this a 11 rests only has input frOlil five lilOnttls of one year.
-Support Facilities: Please refer to our cort1Dents on Section 3.3 (a) (vi) -
Construction, Operation and t-1afntenance.
(vi) Instreag Flow Uses: It is our understanding that significant losses to
the existing fisheries would result. ·the basis for the statP.r.aent that, •.
additional fishery habitat will becOL• available ••• • with Devil Canyon
Reservoir should be explained in detail.
(c) Uatani/Devil Canyon Operation
( 1) Flows
-Project Operation: It is indicated in the Feasibility Report Vol. 1, page
lJ:li, that compensation flow pugps would be installed. An explanation as to
the function of these devices, their purpose, the flows which they would
prov fde, whether or not they are to be insta Tled in one dm or both, how ~ter
froa this source wuld effect the wate-quality p&rllileters of the watw
released frOiil the powerhouse, and the basis for the flows which would be
provided ~roa this source should be provided. We would also 1 ike to Sft an
explanation of the fixed-cone values regarding their expected periodicity of
use (at least by gonth) and impacts on water quality pararaters and flow
levels.
(ii) Effects on Uater Quality
-Uater T~eratures: Since Devil Canyon Reservoir has not yet 'been liJOdeled,
the ratforile for this discussion should be presented. The therul fiJOdels for
Uatana. and Devil Canyon should pro.vide infonaati·on on the following:
(1) The tegperature profile, depth to isothergal conditions, and tiaing
of mixing;
(2) The timing of wint,er stratification;
(3) The extent of turbulence that would be generated at the reservoir
intake; and
(4) The capability of the intake structure to select fr01i1 one te~~peratu"
layer in a stratfffed reservoir.
This should be included in the Exhibit E.
-Ice: Please refer to our cOGI:Ients on Section 3.2(c)(i1i) -Ice.
Inforgation should be provided on the extent of scour in the sloughs under
winter and spring break-up conditions. Discussion should address where the
ice front would deve.lop under •worst case• conditions for post-project Watana
and Uatani/Dev11 Canyon operations. Fluctuating high power d1111nd in a record
co 1 d year and a record wana year should be d 1 scussed. Scenarios which wou 1 d
produce over-topping of rfver fee and ;ultfple break-ups which gay scour the
river channel should be described.
-N.itro~en Supersaturation: Please refet" to our ccaants under Section
3.3(c)( ) -ProJect Operation.
-Facil ft1es: Erosion control a.asures should be described and incorporated
into the aiti~ation pta~.
1 fcense
(a) Flows: Accurate dfsdhar~e 1nforaat1on on the creeks fs needed to insure
proper culvert sizing for fish passage. Ut111zat1on of culverts rather than
bridyes could result fn r.JOre blockages to grayling li11gration due to beaver
activity.
3.5 TranSiilfssion Corridor Inacts: Please refer to our letter dated 5 January
1982 reyard1ng the Tran~iss on Corridor Report.
5 • tUTIG.ATIOff, EfttAICEMErrr, AlfD PRO'TECTtVE JIEASURES
5.1 Introduction: Paraltaph 2: It fs stated that, • ••• •ftigatfve
iiiasures, 1 were 1ncorporaed, 1 ••• fn the preconstruct ion planning, design,
and schedu11ny,• yet we see construction Cllilps/vfllages which were ~tanned
wfth no outside coordination with resource agencies, or even consfd•ation of
.alternatives. The transaission corridor fr011 the 'latana diiiJ wu also planned
with essentially no resour~e agencies input. Ue see scheduling, (based on an
out-of-date econoaic analysis), deter~~fning access routing, tf•fng of
construction activities, and reservoir filling with no input fr011 reso-.rce
agenet•s. This hu precluded an objective ex•ination of a'lternat1ve
mitigation geasures.
IHn ili'IJr.l flows are proposed with the impress ion that they were arrived at
through an as yet undisclosed fisheries vs. econ01:1ic tradeoff. In the draft
Exhibit E we have an evaluation of econ011fcally determined flow release,s, the
basts for which are no longer accepted by the econOGJists that deve.loped theca
(Battelle Newsletter #4 (Final), Railbelt Electric Pow&r Alternatives Study,
December 1982), coctpet1ng against flow releases. The 12,000 cfs flow release
is apparently the rax1IUI d1scharge for August without significant economic
effects.
Ue suspect that the flexibility for providing 1nstreaa flows, once thfs issue
has been resolved, is highly dependent upon the hydraulic turbines which are
se 1 ectad for the project. We recCXi&llnd that a tradeoff ana lys fs be presented
to display the relationship of different hydraulic turbine configurations wfth
both a one daa and two dam configuration related to aaxi•fzfng flow release
options !! more fle,xiblt! turbine systeg alternatives. If tJte proposed
turbines, in either du, would adversely effect future instreaa flow options
then the, decision as to the preferred turbine configuration shou.ld .be deferred
until a specific, detailed flow re.leue schedule, developed throu~ a
quantified .nstreaa flow analysts, is ayreed upon whfeh would •1tfgate igpacts
or enhance conditions for spawning, feeding, passage, out-li1fyrat1on, and
overwintering fn the Susftna River.
The proposed 1i1Ult1-1evel intake structure would provide the flex fbi Hty to
se 1 ect a des 1rab 1 e tegperature reg 1• on 1 y if the tllilperatUl"'e bands exists in
the reservoir .of suff1ctent s1ze and of sufficient depth. It has not been
established that the wltf-level intake would provide sufficient tea~perature
control. At present, Watana Reservoir has been thermally modeled for five
1:10nths of one year. It fs our understanding that this fs insufficient to even
test the liiOdel for the five gonths for which ft was run. Devil Canyon
Reservoir has not been modeled, yet the recent incorporation of a 1i1Ultf-level
intake here leads one to believe the a'pplfcant expects this reservoir ~;ight
stratify. Ue recoggend that li10deling be carried out for both reservoirs,
throurout the year, and the resultant data be incorporated into .1 river
tegperature wodel. This sbould be based upon two years of data (e.g. 1981 and
1982) and pr~sented in the license application.
ReJerence is ade to the incorporat1or of fixed-cone values to prevent.
nitrogen1 supersaturation. The frequency, perfodic ·fty, and anticipated voluae
of use is not addressed. Since they would be drawing upon water very low in
the dag and then d~ing an unknown voluge of this water Into an essentially
ury riverbed we would expect potential ad~erse igpacts to the gftfgation flow
and tegperature regir;aes. The potential effects upon icing conditions and,
depending upon the tf• of year, salreaon ~mvements needs to be assessed. We
recog;end that these potential impacts be discussed in the Exhibit E.
Paragr~ 3: The 11!'portance of aon1tor1ng construct,fon practices, operation
and ga n enance and gonitoring of gftigatfon 1s recognized 1n the APA
Mitigation Policy docuaent. How this will occur needs to be exaafned 1n the
Exhibit E. "e recocaend that a panel of appropriate State, Fed.-al, and local
agency personnel be established, at project expense to roaonftor project
construction, operation and af ntenance. The .,~ :tori ng p&nel , randate, and
operat i onal mechanisms should be discussed in the license application.
5.2 -Construction: Please refer to our comaents above, Section 5.1 :
Paragraphs z and 3.
Paragraph 2: Please refer to our discussion of instreu flows undeT Sections
5.1 : Para~ph 2, 3.2(b)(i)-f·tiniiiiWil DownstTeu Target Flows, and 3.2{c)
-Minfgugnstream Taryet Flows. Additional pertinent coagents can be found
throuijhout. The statements contained fn Section 5.3 can only be considered
speculative, to date there are no studies to support thera. Only one slough,
identified as #9, has received detailed study. In the Noveri1ber 1982 draft
report 9rovided at the Susitna Hydro Exhibit E Workshop, Preliminary
Assessgent of Access b S awnfn Sallilln to Side Slou · Habitat atiove
a ee na, e au or no a un e e a a are ana yzed, any
statllillnts regarding stremf'lows necessary for ch• salliiOn access to the side
slou9hs are provisional. It should also be recognized that the examination of
slough access flows 1s not only without support, but one dimensiona l . Uo
analysis is put forth to examine other life phases of fish, or project related
changes in water qua lfty parUileters.
Paragr~h 5: 'Changes in downstream river· GIOrphology have no·t been fully
assess • It is presature to conclude that no mitigation would be necessary.
The lack of fee scour and flood flows .. Y cause sloughs to s11t in and ~Y
reduce natural cleaning processes necessary to u1ntain productive spawning
substrate and rearing areas.
Paraytaph 6: It would seeo appropriate to exa;ine, in the Exhibit E, gethods
of r&J 1gating the potential therral effects anticipated during the filliny
period, to include extending the filling period.
5.4 -rt1tigation of Uatana Operation Iepacts
(a ) Flows: Para~~h 2: Please ref er to our coggents under Section 5.1:
Paragraph Z and .ion 5.3: Paragraph 2.
Paragr:Sh 3: It is stated that, •watana, when it is operating al :,e, ~i ll be
operat prfgarily as a base load plant.• Pl ease discuss the extent to which
it is intended to be operated as a peaking facility. Of particular concern
would be how it gight operate under worst case conditions, such as fluctuating
hiyh power degand during a record cold year. The imp l ications of scenario s
lfke this should be explored in the Exhibit E if \latana is being proposed for
periodic peaking use.
(b) T!;!erature and D.O.: Pl ease refer to our ca.aents addressing the
cautti:eve.T 1ntike i&ucture and reservoir teaperature IIOdelfng fn Sections
5.1: Parayraph 2, and 3.3(:•i(ff1)-Water T§h:erature. We have provided
additiona C:Oiiants on thel:te subjects throu out. -
(c) Nitrogen SUpersaturation: Please· refer to our d1scussion of the
Trxed=ctlne valves una .. sections 3.2(c)(iii) -rutrogen Supersaturation and
5.1: Paragraph 2.
5.6 ~11tfgatfon of Devil Canyon/Uatana Operation
{b) Tegperature: Discussio. should be provided as to why ;ultf-level intake
ports are proposed a.t Devil Canycn. It would appear that ft has been
concluded, without benefit of a thermal reservoir ~del, that Devil Canyon
would. strat tfy.
Chapter 3. FISH, UILDUF£, AUD BOTAIUCAL RESOURCES
General Comaents
Fishery Resources of the Susitna River Drainage
Periodically in the Fishery Secti'on are dfsclairars such as, •Much of the
discussion is based on professional judgeaent,• (Section 1.2, page £ .. 3-3), or
·~~n~ of the statements are speculative ••• and ••• unsupported,• (Section 2.3,
page E-3-~6). Other statements let U$ know that ongoing, or planned studtes,
wt l l fill these nuaerous data gaps to al l ow a quantification of the resources
and igpacts (Sections 2.2(b)(11), 2.4(b)(ti), z.s, 2.5(c}(if), etc.} and let
us go beyond, "the conceptual •1t1gation plan,• (Section 2.5, page E-3-116)
which is provided tn this chapter. Recognizing a probls does not, in 111d of
itself, correct ft .• We are concerned that the Fishery Section generally fa 11i s
to quantify the existing resources, fails to quantify the potential igpa<:ts,
and fails to provide specific lilitigation aaeuures to dea.l with identified,
quantified, adverse igpacts. Once we have potential gitigation CIHsures ..
these pr oposals would need to be evaluated, for exagple, in regard to
potential fgpacts on: project costs, design, and feasibility; socioeconcGfc
considerations; and fish and wildlife resources other than those for Which the
gitigation is targeted. This type of evaluation would fona the basis of an
acceptable environGJental impact statement and should be provided as part of
the license application.
The ongoing and planned studies which are frequently cited (Sections
2.2(b)(ii), 2 .4, 2.4(b)(ii), 2.5, 2.5(c)(ii), etc.) showld be fully ident·ifted
so we can exmine them in regard to their scope. We cannot, otherwise,
deteraine what needs to be done and what is being done (with assurances that
it will be done).
Potential igpacts are frequently Identified in the Fishery Section, such as
loss of the apparently ililpOrtant high spring flows for out-migrations (Sec-tton
Z.3(a)(i1)), and 40C flows during the second sUiiiDer of Watana Reservoir
·filling (Section Z.J(a)(fi)). Potential r.~itigat1on to contend with these
anticipated adverse i'gpacts ar e suggested, such as sp~king ·spring flows
(Section Z.4(b)(ii)) and installing a fifth portal on the multi-level intake
structure (Section 2.4(b)(ii) [SIC, iii]). If these r.aftigation proposals nave
validity, then they should be incorporated into the design and operations
proposal.
~1itigation lileasures which are proposed should have proven succ.ess in Alaska :,
or in a s igflar env1rongent. If the proposals are not proven, then they WO\Ild
need to be degonstrated effective in the project area. For example, hatchery
propagation of grayling may need to be d~nstrated as an effective
alternative since grayling hatcheries have not been particalarly successful in
Alaska. Likewise, the proposed slouyh li:IOdifications are unproven and thus
should also be deliiOnstrated in the Susitna systs before project operation.
Ue support the establishlilent of a G'Dnitoring progrm funded by the project,
contai~in~ a board of representati~·s fro• appropriate State, Federal, and
local agencies. The board should ~.:ave the authority to recoalilend project
ri10dification raeasures to assure th •. t Qftigation is effective. The p~·ocedure
by which this would occur should be incorporated into the license as an
article. This type of gonitoriny prograg should be discussed in the
r.1 it i gat ion p 1 an •
Botanical Resources
At the recent Susitna, Hydro Exhibit E Workshop, 29 r~oveaber to 2 DecSiber, we
were pleased to learn of the recent efforts to coordinate botanical and
wildlife data needs •. Vegetation types within the project area are apparently
now being subcategorized and r1111pped on th.e bas·is of gore recent,
larger-scale photography and additional field work. Analyzing the value of
vegetation as part of wildlife habitat, an infonatian need we have
consistently cited (e.g. rws letter to Eric Yould, APA, 5 October 1982), w~ll
better allow quantification of project igpacts and the develo~nt of
r:~itigative r01easures. However, these efforts render the current Botanical
Resources Section at least partially obsolete.
Because there is no explanation of ongoing studies, the readeT fs left with
the perception thal vegetat.fon studies have been coe~pleted. \la reca.end that
descriptions of the following be provided in the Exhibit E: (1) current
regappfng efforts for both overall vegetation and wetlands; (2) plans for
sucger 1983 ground truthing of this data; (3) 1984 field work which gay be
necessar:~ for verifying wetlandsi (4) proposed productivity studies relative
to project moose studies (see Section 4.Z(a)(i), page E-3-204, paragraph ~and
Section 4.3(a)(i), page E-3-281, paragraph 3); and (5} schedules for
cogpleting these investigatio·ns and analyses in conjunction with overall
!:litigation and project planning. Such fnfon:atfon is provided, to some
extent, relative to the Aquatic Studies Program, Section 2.5.
In general, the description of vegetation types and potential project impacts
is tnorough. Still, a rajor probleg with th1 5 ~ection i~nvolves 1ncoe~plete
coverage of wetlands. Minor problegs involve the need for soae additional
raps and tables, and conflicting citations of f igures and tables (e.g.
referring to Figure Wl And Ta.ble W3 as. Figure E.3.Wl and Table E.3.WJ in the
text).
Wildlife
We found the \lildlife Section both too general and incDq)lete. Jud~ntal
stater.~ents are rarely referenced (e.g. page £·3-376, last paragraph)
qualitative ten.1s are seldOGI defined (e.g. page 'E-3-315, last paragraph; page
E-3-310). Perhaps QOst critical fs the ;;a1niral detail and coverage of the
mitigation plan.
Lack of quant1ficat ion is a serious prob Teaa throughout this section. \lh i le
baseline populations are occasionally estimated, impacts are typically
qualif1~~ only as ~:~ajar or r:~inor, and no values are provided for those
r:aitigation geasures which are. recocanded.
Ue are highly concerned with the lack of attention to habitat values, although
we have repeatedly cited the need for project evaluations to consider habitat
values as well as populations (please refer toFUS lette~s to Erfc Yould, 5
October 1982., 5 January 1982. 23 June 1980, and 15 r~o·veaber 1979; and
test it10ny of LeRoy Sowt, FWS, before the ~A Board, 16 April 1982.). We
a~preciate the initial efforts to evaluate habitats for furbearers and birds,
and the reported plans to godel carrying capacity for goose. Yet we see no
evidence of how such evaluations wi t1 be continued, expanded to other species,
and r.aost ir.Jportantly, used in developing tili1lly, coraprehensive lilitigation
r.M!asures, which are an integral part of projec.t plans.
Where population inforgation is pr~v1ded, it is for the curTent situation. No
accounting is given for long-term habitat potentials, for example, (1)
habitats ray be able to support greater populations over the long-ters (e.g.
pine carten near watana Creek); (2) habitat values ray decline a·s, through
suc~ession, vegetation proceeds to gore aature stages which are less
productive for GIOose; or (3) harvest manag-nt goals ray be liiOdified and
caribou popuh.tions allowed to increase to wttere available habitats are 110re
cogpletely stocked.
We recoaaend providing information on continuing studies (including habitat
GIOdeling) and how data gaps identified here, in previous agency cocments, and
the August 1982 Adaptive Environfillntal AssesSG1ent (A£AJ Workshop will be
answered. Our Specific Cor&1ents below, further address this need. Another
r.ajor probTs is that the Wildlife Section is not integrated, nor is ft
consistent relative to impact potentials and .mitigation options with other
sections in Chapter 3 or with other chapters in the Exhibit E. For exagple,
in Chapter 3 the impacts discussions are based on no access along the
transaission corridor; in Chapter 5, such access is assuced (Section
3.7(c)(i), page E-5-84).
rtot only do we l'"ecoa:~end tha.t this probler:a be corrected, but that evidence be
provided as to this section has been integrated into project designs and
scheduling. That integration is gost critical with regard to the mitigation
plan. Information should be provided on the mechanism for notifying project
engineers of key wildlife areas and at the sage time for the engineers to
notify the environgental consultants and resource agencies of design changes
or gitigation geasures they believe are unfeasible. Additional fnforgatfo~
should be provided on the process ta be followed for finalizing and then
irnplegentin9 mitigation requiregents.
Integration of the various report sections would be aided through an overview
discussion of overall project objectives for wildTife, fisheries, vegetation,
recreation, land use, and socioeconomics.
Presently we find apparent objectives of the Wfldlffe Section often contrary
to recreation or socioeconomics; within the ~ildlife Section, objectives for
one species ~Y conflict wi th tho~e for another species.
Because of the volurninous nature and cocaplex1ty of CJater1al involved, it is
difficult to assess population status, habitat values, impacts, and mitigation
for each s,pecies relathe to all other species. This 1s particularly
important where gftigation for one species may be at the expense of another,
as above. Thus we suggest sage type of sugmary chart which would show, by
species: (1) populations; (2) habitat types and values; (3) status (f.e.
1ncreas1ny/decreasfng, upper/lower basin, etc.); (4) values (comaercial,
recreational, and/or subsistence with ~netary figures where possible); (5)
past and present harvest effort, success, and lillnag~nt restrictions; (6)
iFSacts; and {7) mitivation alternatives. Please refer to our suggestions
•
under Section 3.4 for evaluating ~itigation alternatives as prioritized under
!~EPA guidelines. The schedule for fH ling resultant tJata gaps could then be
o~tlined; additional Qitigation needs or tradeoffs i~ benefits/impacts would
also be obvious.
We rec~nd quantifying the level of Qitigation to be achieved by different
measures. This is particularly important where ~nagement policies are
unclear (e.g. hou:ing and transportation of workers, harvest regulations, and
prohibitions on use of the access road pre-and post-construction will
determine the ~gnitude of project impacts).
Finally, we are concerned that although the fragmentation of project impacts
by project feature allows for a more comprehensible analysis, the report lacks
a broad overview. Cualative i~:~pacts are generally ignored. We recoaand
that such iupacts be cogpiled in conjunction with a list of unavoidable
adverse i~:~pacts.
Lack of key data has made it essentially impossible to QOre than outline the
types of Qtasures which shoijld be included in the mitigation plan. In many
cases, no evidence is provided for the proven success of recommended geasures
in Alaska or similar environments. For such unproven measures, demonstration
projects should now be established or back-up gitigation measures outlined for
i~pleaentation if unproven measures fail (e.g. blasting to enlarge the Jay
Creek mineral lick, provision of artificial raptor nests).
The wonitoring progr~ we recoggended under the Fishery Section should also be
extended to wildlife resources in the project area.
Specific Co.ments
1 • IrfTRODUCTIQfj
1.2-I 1: Please refer to our Fishery Section-Gener~a~~~~~~~~~~rii~Tc~ation and the status of the project
studies.
Paragraph 4: Several of these references do not appear in the bibliography.
1.3-Mitigation Plans: Para¥ta~h 8: Avoidance of adverse impacts rarely
appears to occur, particular y n regard to project features. For example,
missed opportunities to avoid adverse fish and wildlife resources impacts
exist in: project scheduling; mode and routing of construction access;
recreation planningi siting, administration, and type of construction
cagp/village; and instream flow regime.
The wonitoring program, which has been supported in several chapters, should
be fleshed out. The program should provide for participation by appropriate
representatives of State, Federal, and local agencies, be supported by the
project, and be able to recogmend changes in the gitigation proyrag to be
adopted through a gechanism established in the license, gutually ~cceptable to
all concerned bodies.
Z • FISHERY RESOURCES OF THE SUSITNA RIVER DRAituu;E
2.1 • Overview of the Resources
(d) Selection of Project Evaluation Species: Para!fa¥" 4: Igprovfng habitat
cond-ftions f\)r an evaluation ~~c!Cfes woutd be help u to other species wfth
sfgflar habitat requfsftes. However, we would expect other species, wfth
habitat requfreaents that conflict wfth evaluation species, to be adversely
affected. In lddftfon, we recaa:~end Dolly Varden and burbot be fnclucled as
evalutfon species for the Susftna Rfver downstream of Devil Canyon.
Para~~ 6: It fs stated that, •tgproved condftfons fn the rafnst• are
expeC to provide replacement habftat .•• Juvenfle overwintering habitats are
not expected to be adversely affected.• We are unaware of specfffc data to
support thase stataaents.
Para~aph 8: Evaluation species and lffe stages should be lfsted for the Cook
Inle to Talkeetna reach.
(e) Contrfbutfon to Comaercfal, Sport, and Subsistence Fishery
(f) ~omGercfal: Species specf~fc cogparfsons are ~de of cr~rcfal harvest
to escap~Gent. Perhaps a better gauge would be to provide estimated
contrfbutfon to the coararcfal harvest, as fs assessed fn Chapter 5 (page
E·5-70), or estf~a~ted contr;but;on to the run. This, howe'ter, also would
timplify the systems contribution, but would at least provide reviewer~ wfth a
better understanding of production.
(ff~ Sport .. Ffshfng: ParagraC 2: If 110re recent surveys are available, thfs
section should incorporate em.
(fff) Subsistence Harvest: The following three A~&G reports would allow for
a-gore ~xpansfve dfscuss1on of t~fs faportant topfc:
1. Foster, Dan. Noveaber 1982. The Utflfzatfon of Kfng Salaon and the
Annual Round of Resource Uses fn Tyonek, Alaska. ADFIG. 55 pp. +
appendices.
2. Stanek, Ronald, J1111s Fall and Dan Foster. March 1982. Subsistence
Shellfish Use fn Three Cook Inlet Villages, 1981: A Prelf•fnary
Report • AIF&G. 17 pp. + append f ces.
3. ~ebster, Kefth. Aprfl 1982. A Sumaary Repor~ on the Tyonek
Subsistence Salaon Fishery, 1981. Upper Cook Inlet Data Report
tlulilber 81-3. ADFIG. 16 pp. + appendices.
2.2 -Species SfJlogy and Habitat Utflfzaton fn the iusftna Rfver Drainage
(a) Species Biology
J)l!) Resident Species
-Arctic Grayling: Parayraph 8: The stateaent that, •Assugfng other
conditions ror spawning are favorable, ••• • should be expanded to allow an
understanding of what these other conditions are and why we should assuae they
would be favorable.
(b) Habitat Utilization
( 11) Ta Jkeetna to Dev f1 Canyon
• r.tainstaJ and Side Channels: References are ~ade to low flow and raxf .. now.-,. flows Should Iii quantified so that an understanding of potential ..
project igpacts and Llftfgative flows can be related to how it, would influence
h&bftat.
~ec ·fes Occurrence and Relative Abund.ance: The baseline infol"'l&t1on and
analysis should incorporate the 1982 field season data.
-Slou~ Habit~t: Paragraphs 2 and 3: The effects of various flow levels
Slioiild e riferenc:id by the nliibir of sloughs which would be iapacted by the
particular problea and the relative importance of the effected sloughs 1n
teras of salmon habitat.
P!ra~aSh 4: The basis for the intragrave·l tefi1Perature statements should be
prov e , Whether conjecture or based upon a study of X number of sloughs.
~Sjgnificance of Habitat
(liiOuths?) '!.S
(a)_ Anticipated Ilill!acts to Aquatic Habitat Associated with Yatana 0111
.!.!) Construction of Watana OM and Relateci Fac1iftfes
-Watana Ollil
.Chanwes in Water iuality: Although turbidity levels •Y be decreased, on the
average, througtiou the year, a r.JOre appropriate impact ev·aluatfon would be to
examine turbidity levels by season or month !! aquatic life stage.
Para~a~ 11: ExUiples of • ••. ;ood engineering practices, and a, thorough SPCC
pfan:ould be provided in .;~e •1tfgation plan. The abbreviation of the
plan ~hould be spelled out.
1: Haterfal sources should gene~-.~y~~e~co~n~n~e~.~un~e~s'="s-un~_~av~o~~~e~,-ro that area whfch would be
1nun~ated by the fgpoundlent, or upland sites. In that the Devil Canyon dlQ
fs not~ cert&1nty, rehabflftatfon of Cheechako Creek should be planned.
Joyce, Rundquist, and lloulton (1980) is referenced several tfr.Jes. ~e reque.st
that this reference be provided, and the pertinent discussions from this paper
be incor~orated into this section.
~ Uatana Car.ps, Vi flage and Airstrips
•• Indirect Construction Activities: We expect secondar'y i~acts, avoidable
and· unavofdible, to be li1UCh greater than that indicated by this discussion. We
provided coaants on this topic in respcmse to ippropriate Chapter 5 sections,
where this topic is also inadequately discussed.
i!i) Filling ~atana Reservoir
-Watana Reservoir Inundation
.t~insteg Habitats: Paragraph 4: Although overwintering habitat would be
lncreased, a •• overall igpaet would probably be a net loss of habitat value.
The disc.ussion does not identify what species might benefit frol'il this increase
in overwintering habitat.
Ptr~graph 5: The bas 1s for the statement, •Reservoir temperatures in the top
Too ft are expected to be in the range of 10 to zoe.· should be provided.
First, the reservoir temperature model has not been run for the period
r~ovember throu9h 1-~y. Second, the statement fs in apparent conflict with the
informtion provided at the Susitna Hydro Exnibft E Workshop in which Eklutna
Lake was presented as a godel for ~atana Reservoir. Eklutna Lake shows winter
tenperatur!s between oo and 3.60C within the upper two meters.
-Talkeetna to ~atana Dam
.~11insteGJ Habitats: Paragraph 1: In that the river would no longer be clear,
tne effect of this Change fn turbidity upon QOVement of juvenile salmon and
resident fish should be addressed.
Par~graph 4_: n.e arparent importance of the reced fng 11mb of h fgh spr fng
f1ows to stfli1Ulate Out-cafgratfon iS noted yet we SM no effort to SiCIUlate
th 1s fn the recoa:aended in stream flow regime.
Paragrafh 9: It is recognized that the outflow tegperatures during the second
open-wa er season could have substantial adverse ir.1pacts. This problllil fn
relationship to how ft was handled at other hydropower projects should be
discussed •
• Side-Channel Habitats : Paragra'h 3: Until an adequate instreag flow study is
conducted, these stat~nts w1l regain speculative.
Par!graph ~: It shuuld be stated whether or not rearing habitat is considered
Tlro~lted.
Paragraph 5: The decreased teaperatures expected would probably counteract
any Dinefits derived through decreased suspended sediments •
• Slough Habitats: The poten,t1a1 impacts during filling should be discussed.
Flows and teraperatures would be cha,nged from ambient. Until the ground water
relationship, in regard to flows and temperatures, fs adequately established
the potential for impacts should not be dismissed. Whether or not the colder
second year releases would have a delayed teaperature effect upon the sloughs
should be examined.
ParayraJ!!!..1: It should be explained that the basis for these stateaents 1s
preliminary results from an examination of one slough (19).
Para_gr-t~s 4 and 5: The slough which had a backwater fona abov·e 14,000cfs
should bi identified. It is not explained whether this is tYPical of all
slou~s. sOQI sloughs, or. even just that one unidentified slough. It is
apparent from this section that lZ,OOOcfs would hagper or restrict passage of
adults 1nto an undisclosed proportions of the sloughs cand wo"ld not create a
backwater effect for an unknown proportion of the sloughs. T~e biological
basis by which 12,000cfs was chosen as the preferred flow for August should be
explained in li9ht of the discussion of this section.
4: It is noted that some creeks naay become ..;.pe.:..;r~..;.e~u ... n-rer~:.r.-e~p-r...;op~o~s.;;;e...-..;"""'"ng schedu 1 e. The des irab ili ty and feas i b f1 tty
of altering the filling schedule to avoid this impact should be discussed.
-Cook Inlet to Talkeetna Reach: It has not been clearly established that the
project ~auld not adversely impact fisheries below Talkeetna during reservoir
filling and project operation •
• 1·1ainstem Habitats: It is our understanding that millions of eulachon spawn
1n the lower river. If this spawning run is stimulated hv certain
ter.Jperatures or peaking spring f'lows the project could :.ignfficantly impact
this species. Secondary impacts would occur to those species, such as bald
eagle and belukha whale, which feed on them. This potential problem should ba
discu,;sed •
•• Tributary Habitats: Paragraphs 2 and 3: A 10 percent reduction in flow$
could uean a zero reduction in hib1tats of concern or TOO percent reduction or
somethiny in between. We recoa:aend that these flow reduction percentages be
related to their effect on habitats of iQpcrtance to life stages of those
species of concern.
(1ii) Operation of Wata11a Dam
-Talkeetna to Watana Dam
.~~1nstem Habitats: Discussion should be provided specific to the fixed-cone
values. There 1s no indication of the anticipated extent of the,ir use. In
that they would be withdrawing water from the h(pOlimnion they would often be
counterproductive to what fs intended to be achieved through use of the
gulti-level intake. The potential for thermal shock, or shock due to rapid
changes in other water quality paraaeters, should be evaluated. Rapid water
level changes would also be a potential problem that should be explained.
Para~raph 8: Di'scussion appears to be in co.nflict with Paragraph 16 of this
secbon concern.ing suspended sediment transport.
Para~a~h 9: Sediment load and turbidity 1re not synonygous. Turbidity
shou ncrea.se substantfa.lly over Ulbient winter levels.
Para,ra~ 16: The observation that fish apparently overwinter in the turbid
Kena R ver allows. one to conclude that, over a long period of ti•, these
(unidentified) species can adapt to turbid conditions. The conclusion that
the Susitna stocks can, in one year, adapt to Kenai River like conditions is a
bfg step. Please 110re fully discuss this potential problem.
-Cook Inlet to Talkeetna Reach: Please refer to our comaents under Section
2.J.(a){ 11) -CoOk Inlet to Ta Tkeetna Reach.
(b) Anticipated Impacts to Aquatic Habitat Associated wfth Devil Canyon
1.1) Construction of Devil Canyon Dam and Related Facfl it ies
-Devil Canyon Da.
.Disturbance of Fish Populations: Please refer to our c~nts on Section
2.3\a)( f) -Watana bu . Direct Construction Activities.
--Devil Canyon Camp and Village
and Villa e: Para ra h 1: Reference is
made to E , c we reques • as no een provi ded. Ue have not
had input into the decisions regarding the type, ad•inistration, or siting of
the construction cmp/vfllaue. Avoidance of impacts to fish and wildlife
resources should have been a .. jar consideration fn these decisions. In that
we dfd not participate in these decisions and no alternatives to those which
are considered •preferred.• are examined fn Chapter 10 we can only conclude
that little, or no, consideration was given to this gftigation procedure.
(iii) Operation of Devil Canyon Dam
-Talkeetna to Devil Canyon Daca
.Hainstem Habitats: Paragraph 1: We assume that the SOOcfs flows in this reach
uou1d be provided by cogpensation flow pumps, discussion of which does not
anation should be ided as
to the function of these devices, their purpose, and how water fro. th;s
source would effect water quality parameters of the water released froa the
powerhouse and the fixed-cone values, and the basis for the flows which would
be provided from this source. Please provide the rationale for the stateaent
that a reduction in flows of the magnitude which would occur would not be
expected to adversely affect fish populations in this portion of the river •
• Stough Habitats: An explanation should be provided for the stata.ent that
changes fn streimflow during the open-~ater season are not expected to affect
s tough habitats. We consider the potential for s 1gn1f1cant adverse. effects to
this habitat type to be high.
• Cook Inlet to Talkeetna: S..ll changes in flows can have dr..atfc i~acts
on habitat. The relationship between flows and impacts on habitat must be
established before one can dis.iss s.atl changes in flows. We expect the
AEIDC instreaa flow study will suffic i ently define this relationship . ·
(c) Iepacts Associated with Access Roads and Auxiliary Roads
Jj)_Construction
• Construction of Watana Access Road and Auxiliary Roads: Once an acceptable
access routing is agreed upon, studies would need to evaluate the existing
resources. Only at that point can specific mitigative ~aasures be
satisf~ctorily addressed, based upon quantified fgpacts. We recOCJDend that
you prucede in th h manner •
• Alteration ~f Water Bodies: The potential problem of b~~vers daag1ng
culverts and thus interfering with fish passage needs to be addressed.
-Construction of Devil Can~on Access Road and Auxiliary Roads: Paragraph 1:
We asswa that APA has dec1 ed on a preferred access plan-toDev·fl canyon-
consistiny of road or rail access, or both. Whatever ft is should be stated.
Paragra~h 3: Althouyh we have previously expressed our preference for raft
access n lieu of road access, proper siting of raft fs highly important to
minimizing impacts, primarily through avoidance. Coordination specific to
this 1 ssue shou 1 d occur· when s 1 t 1 ng dec fs 1 ons are being raade.
(11) Operation and Maintenance of Roads
-Operation of Watana Access Road and Auxiliary Roads
In that • the increased
(d ) Transgfssfon Line Impact!
if) Construction of Transr.11ssion Line
-Uatana Dam: Para~aph 1: Base line information on the transmission corridor
TrOQ the daa .sites o the Intertie ha.s been adc.nowledged as la.ddng within the
Exhibit. As 'fith othar project features, the Exhibit E should provide base
line data, igpact assessgent, and attigation planning. Avoidance of adverse
iapacts would occur by a COIIIbined construction access/trans•iss ion lint access
corridor north of the Susitna River between the· two daa sites. This fs our
pr-eference. For further co••nts pl ease refer to our letter dated! 5 JanuaTy
1982 on the Tr&nSIIisston Corridor Report. Tb 1s letter was ,provided as fona 1
pre-ttcense1 consultation and we continue to view it as such.
(fi) Op!ratton of the TranSII1ss1on Line
-Wltana D•
.Alteration of waterbod1ts: Please refor to our coaaents under Section
2.31d)(f} -Witana o ...
• Dt~turbance tD Fish Po~lations: Please refer to our coa;ents under Chapter
~.Section 3.7(c){f} ~ _uatfc Species • Igpac!S_9f the Project
2.4 -Mitigation Issues and Proposed r1itigatiny Measures
Please
1i) Streaa Crossings and Encroachments
-Mitigation: Please refer to our coggents under Section 2.3(c)(i) -
Constructlan of Watana Access Road and Auxiliary Roads • Alteration of Water
BOdies.
it 1) Increased Fishing 'Pressure.
-I~act Issue: If the construction access and transmission line between the
two u sites were in !:Jte saae corrid.or the fiiiiPact could be partially reduced
or avoided. Please refer to our letter dated 5 January 1982 on the
TranSIIisson Corridor Report for additional coagents.
1iv) Material Removal
-t1itigation: Please refer to our COGiillnts under Section 2.3(a)(i) . Direct
Construction Activities: Paragraph 1.
Parairaph 3: Mfning should be scheduled to avoid conflicts with fish
r.afgratfons, spawning, or other i11port1nt occurrences.
Para~raph 6: Please refer to our cagwents under Fishery Section -General
e~maents ~eyardfng monitr~ing.
(vifi) Susitna River Diversions
-rHt.fiation: G.rating of the diver ·s~on tunnel would prevent losses to fish
and shouldDe considered as a r.11tigative measure.
J.!) C 1 earing the Impoundlaent Area
-t1it1gation: If it would cainimize these iiiJ)acts, then clearing should occur
during the winter.
(~)_Mjtigation of Filling and Operation Impacts
( i )_A~oach to ~11tigation: Although, •Avoiding ililpacts through design
1iatures or schidu11ng activities to avoid loss of resources,• is lhted as
top priority, in reality it has not received this type of emphasis.
(if) fHt.igat ion of Oownstreua Impacts Associated with Flow Regi1111: Under
General Cogments for Chapter 2 we have ~rovided i synopsis of the AEIOC
1nstreiGI flow proposal which has been contracted by NJA. We believe that this
proposal would provide the basis for a reasonable, quantified instream flow
impacts analysis which would allow an assess.nt of mitigative alternatives.
Since NJA has contracted this study, we assume that APA agree:s with our view.
The AEIOC proposal should be fully described in either Chapter 2 or 3. It
seems prllil&ture to discuss mitigative flows prior to quantification of
potential igpacts.
-Impact Issue: Paragraph 1: Re.ference is 1111de to Exhibit A. A 1though we
nave requested this, as well as other Exhibits, it has not been forthcoming.
-Measures to Minimize I~acts: Please refer to our coa:~ents under Sections
2:3(a)(f1) -Talkeeta to atana Dam. Slough Habitats: Paragraphs 4 and 5 and
2.3 (a)(11) -Talkeetna to Watana o ... Ma-rnstim Habitat: Para~h 4. It is
apparent. that the flow release sChidu1e neither rain fmizes loss OfCfownstreae~
habitat nor maintains normal timing of flow-related biological stimuli •
• Winter Flow Re~fme (November· April): Para~h 1 ~ Please refer to our
COCIDints un.dereetion 2.3 (a)( 11) -CoOk inlet t!! Talkeetna Reach • Tributary
Hab1t~~s: Paragraphs 2 and 3.
ParagraP!:!._l: We also feel strongly both ways.
3: Discussion should be ~-r---.,_,...,..._~~,._-r-~..-,..~-~,......;....;..!o.r-.~ch 1 ead to the cone 1 us ion that
to allow rectification of project icapacts.
-Rectification of 1r.1pact
.Winter Flows: We stronyly disagree with the conclusion reached in thfs
section. How this conclusion can be derived frOfil the inforlilltion provided in
this chapter and Ctapter 2 needs to be. fully explained •
• Su~r Flows: We fully ayree that the proposal must be dewonstrated
effective before it can be incorporated into a mitigation plan.
-Reduction of Ir.tpacts Over T11:11: Please refer to our cOGiiJellts under Sect·IJn
2.0l(a)(1V) -M1bgabon: Paragraph 6.
Para~raph 9: Discussion of the developraent of a hatchery should be expanced •
.If oller gftiyation alternatives prove not to be feasible then we will neui to
fully understand what could be achieved through hatcheries.
(if} Mitigation of Downst""tllll Impacts Associated with Altered W.ter
Temperature Regfge
-t1easure.s to t·11nimize Impacts
-t1easures to Rectify I111pacts: DocUC~entation should be provided on the
success on th1s tYPe of proposal in Alaska, or other sub-arct1c syst .. s.
Degonstration of the techniques would need to occur prior to incorporati~
into the mitigation plan. In that the sloughs are also utilized for· rearing
by chinook and coho juveniles, discussion should be provided on how chum
saloon (we have assuwed th~t chwa is the species which is being managed for
although it is not stated) would interact with the other species. Alsa, t1e
rnechanislils which gfght allow entrance to chinook and coho ulman into the
sloughs while holdiny the chums from eyress1ng needs to be explained .
. , Chdensation for Irraacts: Documentation should be provided on the SUCCI! S
of a chery propayat on of grayling.
(fi} Operation Mitigation
Z: Ue t~lly support the -s"""a...;.p...;er;ae....;....,&,n~ ........ a""''"",-... o-n...,....,_nu-....n_g--..re ... s'-e-r-vo ... ,'!'"'r""'""'"'""e~r .... ma...,._li10..-de ling w i 11 a i1 ow an
evaluation of available water temperatures throughout the year so that a
detailed release plan can be developed. The release plan will need to
consider both water temperature and volwae in order to e~inigfze impacts.• ~t!
recocmend that this be carried out and the proposed release plan be included
in the license application.
!I
~I
z.s -Aquatic Studies Prograg: Please refer to our coaments under F;shery
sect1on -General Co~nts.
Z.6 -llonitorin~ Studies: Please refer to our comDents under Section 1.3:
Paragraph 8.
3 -BOTANICAL RESOURCES
3.1 ·Introduction
{a) Regional Botanical Setting: A ~re complete description should be
provided for veyetabon north of the Susitna River to the Denal i Highway,
through which the proposed access road is to pass. The primary importa.nce of
botanical resources as a key component of wildlife habitat should be restated
here as the object of this report (s.t-: s~ctfo·n 1.2 , page E-3-3, paragraph 1).
{b) Floristics
{f) General: Paragraph 1: We suggest that the difference in numbers of plant
species between the upper and lower basins are a result of the following:
larger study area; greater time spent in sar.apling the upper basin , and the
numerous vegetation communities associated with elevation changes and
topographical diversity.
Parayra~h 3: Please explain the quantification of plant species for the
Willow-o-Cook Inlet and Healy-to-Fairbanks transmission corridors, when no
floristics work was done in that area. {Section 3.2{e){i) and (i i) and Tables
W24 and \125) •
(c) Threatened or Endan~ered Species : Since no plant species are officially
listed, we suygest addi ion of the word •candidate• prior to any dfscussf .on of
•threatened or endan9ered• plant species. In r.1any places the discus s ion would
be more accurate by referring to •plant taxa• rather than species since these
plants are generally varieties or subspecies rather than distinct species.
Please clarify that the ca1cfphi1fc plants referred to in paragraph 4 of
subsection (1) refer to Uurray•s, not FWS, categories for threatened or
endangered.
(d) Contribution to \Jildlife, Recreation, Subsistencet and Cor.aerce: Because
of their key functions both as habitat for fish and w1ldlife resources and in
maintaining water quality relative to drainage, high water energy dissipation,
flood storage, ground water recharge, filtering surface runoff, etc ., wetlands
and floodplains have been protected by Executive Orders (11990, 11998) and
national legislation (e.g. Clean Water Act as amended in 1977). Since
vegetation fs a characteristic c01:1pone.nt of any wetlands, we suggest addition
of a general section here on the prevalence of wetlands fn the project area
and their widely re·cog ni zed biological and water quality values (please also
see our following cor.r.Jen -t.s on Section 3.2(a)(vi), Wetlands.
(iii) Subsistence : Use ,f area tir.aber resources for buflding or heating h01i1es
is an additional subsfst~nce use which should be mentioned.
fro~:~
Para~aph 2: A brief description should be given as to sampling intensity.
Qhet~r vegetation do~inance within the project area and/or susceptibility to
project impacts were considered in study design should be explained. General
info~ation on elevation, slope, aspect, and land for~ should be briefly
rQlated here and in subsequent sections of the report to better define areas
and thefr vegetation cover. The prevalence of permafrost, a determining
factor in sorne project impacts (e.g. pages E-3-166, paragraph 2 and E-3-170,
paragraph 3), should also be considered.
Para~aph 3: Successive descriptions of vegetation types by project area
woul be clarified here by defining closed, open, and woodland forests, tall
versus low shrublands, and wetlands (also see c~t under Section
3.2(a)(vi)), rather than defining theg in the following sections (a) and (i).
The discussion would also be aided by including an overlay of project features
on the vegetation map, Figure ~1, as well as restating information on the
elevation range for each proposed impoundment area. Ye recommend the license
application ir.r.lude a laryer, more readable vegetation map and that
quantitative data on how co~n or uncogmon specific vegetation types are, as
well as the occurrence of various types relative to elevation or aspect, be
presented in the text as well as tables. In so describing the revised
vegetation classification, ft will be possible to better evaluate potential
project impacts on vegetation, and thus wildlife habitats, by project
feature. This recogmended level of effort also applies to the proposed access
and transmission corridors.
(a) Yatana Reservoir Area
(i) Forests: Please see comment under Section 3.2 re including quantified
information in the text as well as tables. Providing the range of elevation
fn which these types were sampled rather than one average would show the
extent and overlap in distribution of each forest type.
-S¥ruce Forest: Paragraph 5: Black spruce forests on poorly drained soils
wou d mcst likely also be classified as wetlands. Please refer to our
co~nts under Sections 3.1(d) and 3.2(a)(vi).
(fi) Tundra: Please refer to coaments under Section 3.2: Fara~aph 3 re
providing quantitative data on the prevalence of different tun~a types and of
ranges rather than average elevations. The wet sedge-grass tundra should also
be described as a wetland type, see Sections 3.1(d) and 3.2(a)(vi), as above.
(iff) Shrubland: Refer to c~nts under Sections 3.2(a)(i) and (ii) above.
(iv) Herbaceous: For consistency with the rest of the report, we recommend
describing common species within the referenced herbaceous pioneer
c~.runities. Corresponding tables on the herbaceous vegetation types are
missing.
(v) Unvegetated AJ·eas: Ayain, quantification of the extent, and thus
i~portance, of these areas should be provided.
(vi) Wetlands: Thfs section is significantly lacking in three areas. First~
the legislatively recognized i~portance and protection of wetlands should be
described, including the U.S. Army Corps of Engineers• (CE) definition of
wetlands and regulation of activities on these areas. (Please also refer to
our comgents under Section 3.1(d) regarding this concern.) Secondly, th~re
should be a discussion of how wetlands may be a second level of classiftcation
applied to the vegetation types previously d;scussed. Finally, as with other
ongoing studies, this section should cover the wetlands delineation schege
agreed to at the Z December 198Z wetlands session of the Susitna Hydro Exhibit
E Workshop. This agreement included the following: project consultants will
geet with the FijS and CE to identify the appropriate detail for wetlands
mapping; existing wetlands ~ps will be improved on the basis of additional
aerial photography and overall vegetation remapping; soils information will be
obtained from the CE; ground truthiny. in consultation with FijS and CE, will
be undertaken in sugmer, 1983; final ~ps should be available by fall, 1983;
and additional field checks gay be necessary in sugaer 1984 (see page 5 of
Wetlands ~~t;ng notes, received from John Hayden, Acres AYerican, Inc.).
Given the doubtful accuracy of existing wetlands maps~ it would be
inappropriate to include those maps in the license subaittal.
Redefinition of wetlands to properly include such types as black spruce bogs.
willow and poplar along watercourses, and herbaceous sedge-grass marshes, in
addition to the gore completely aquatic types now described under the wetlands
section. A definition of -wet tundra• (paragraph 6) should be included. The
final paragraph of this section would be a better opening statement to the
expanded discussion needed on wetland values and types.
(b) Devil Can~on Reservoir Area: Please refer to c~nts under Section
3.2(a) re nee for a brfef elevational and landform description. Again, there
will be need for an overlay of the impoundment area on the (revised)
vegetation type map. We appreciate inclusion of the percent of the
igpoundaent area covered by ~jor vegetation types. Please refer to our
previous comgents re need for a coaprehensive discussion and definition of
wetlands.
(c) Talkeetna to Devil Canyon: Clarification of this specific area is needed.
Again, refer to co~nts urider Section 3.Z(a)(i) and (ii), above. While
earll, mfd, and late successional stages appear a suitable categorizaion for
floodplain vegetation, these stages should be correlated with the forest,
shrub, tundra, wetlands, etc. classification previously used.
(d) Talkeetna to Cook Inlet: Please refer to comgents under Section 3.Z(a)(i)
and (11), above. we believe that existing data do not substantiate the
conclusion that the project will have mfnigal fgpacts on vegetation in this
area. Thus we recomgend mapping the area within the 10 year floodplain
downstream of Talkeetna at least to the Delta Islands. Further discussions on
expected igpacts should be initiated to better pinpoint the precise area which
should be covered.
(e) Transgission Stubs and Intertie: Again, we suggest adding a map, and
elevation 1nforaation, as well as quantifying the vegetat;on type, for each of
the following four subsections.
(ii) Uillow to Cook Inlet: ParagraGh 1: Here too, •wet sedge-grass marshes•
should more completely be rliscusse as wetlands, see Section 3.Z(a)(vi).
Paragraph 2: The first sentence is contrary to data provi~ed in Table W25,
please clarify.
Paragra~h 5: Placement of this paragraph between the first and second
paragraphs would be gore loyical.
(iii) Willow to Healf: The compatibility of vegetation tYPeS as mapped by
Commonwealth Assoc1a es, Incorporated (1982) with those mapped by McKendrick
et aT. (1982) should be described.
{iv) Darns to Intertie: We question the comparti)ility of vegetation types
mapped here at a scale of 1:250,000 with those 1~ all other transmission
corridors which were mapped at 1:63,360, e.g. Tables WZ7 and ~8 doc~nt
difficulties of ~pping closed birch and balsam poplar types at the 1:250,000
scale. This transmission corridor should be separately mapped during ongoing
mapping.
3.3 -I~pacts: Fragmenting this analysfs into a project feature by iQpact
issue format is useful for a first overview. However the section lacks a
comprehensive picture of cumulative impacts to vegetation. That cumulative
picture is essential for understanding overall i~acts of the project on fish
and wildlife species occupying areas within and beyond each project feature.
Although this section identifies the full ranye of vegetation ifl~act issues,
there is no attegpt to quantify areas which may be potentially affected by
chan~es in vegetation cover. A given change ~ay be both beneficial to one
spec es of wildlife yet adverse to another. By not completely prioritizing
mitigation in the previous Fishery Section and later Wildlife Section, the
report fails to identify the tradeoffs or objectives of a project-wide
mitigation plan or mitiyation plan alternatives. For exagple, information
should be provided here on the tradeoffs analysis relative to fish, wildlife
and botanical igpacts, as well as cost and design considerations in the siting
of project support facilities, roads and trans~ission lines. We remain
concerned that we were not consulted in the siting of project support
facilities.
(a) Watana Developement
{i) Construction
-Vegetation Regoval: Para¥Qaph 1: Again, we suggest restating the elevation
range within which vegetat on w111 be removed. Spoil areas should also be
described.
Paragraph 2: Please provide the percent loss expected fur birch forests as
shown 1n Tible W27. Loss of a vegetation type relative to its abundance
within the basin is half the issue relative to the loss of vegetation; however
the value of each tYPe relative to other tYPeS for selected wildlife species
should also be provided. In soae cases habitat factors would also be
considered; see our co~~nts throughout the Wildlife Section.
Paragra~h 3: So~ relatfonshfp should be ~ade between referenced possible
delays n snowmelt and vegetation tYPeS which may be affected. Similarly,
increases 1n cottongrass and decreases in mosses and lichens should be related
to thefr occurrence in vegetation types adjacent to impoundment and borrow
areas. Such relationships should be the basis for fully considering the
impacts of project-induced ch1~ges on vegetation relative to wildlife (see our
comments under Sections 4.3(a)(f), {ff}, (iv}, and (v)).
{if} Filling and Operation
• Ve~etation Succession Follo~ing Removal: In order to understand the
rnagn tude of vegetat1on alterations, sage quantification should be presented
for the areas of forest, shrub, tundra, etc. whfch will be rehabilitated
durfng project ff111ng and operation. A scenario should be developed
outlinfny potential acreages of each affected veyetation type and the various
successiona~ ~tages they will pass through during the life of the project •
• Forest Areas and Shrubland: Anticipated heights of each vegetation stage,
over tfQe, should be 1ncluded here •
• Tundra: The extent of pen~afrost should be described, please see our
corJment under Section 3.2.
Information fs needed on successional patterns in herbaceous vegetation types
and on wetlands withfn ~ach tYPe, for consistency with Section 3.2(a). An
additional concern is the nutritional qua~fty and quantity of plant regrowth
relative to wfldlffe.
and
y the aerial extent of
-Effects of Altered Downstream Fl~ws: Overall, this discussion is too
general. Consideration of dafly flow fluctuations in response to peak power
needs is neglected.
Several other potential project impacts are left unclear; especially those
related to wetlands and floodplains. For example, please provide the extent
of floodplain areas, (1} now subject to annual, 5 year, 10 year, etc.
flooding, 1nd (2} which will becoQe exegpt from flooding. Gfven the
successional fnforQatfon depicted in Figure W3 and revised vegetation ~aps, 1t
should be possible to quantify expected changes 1n vegetation, over tige, for
a variety of flow regimes. Such information 1s necessary to fully determine
project impacts to wildlife and gake mitigation recoQmendations. If existing
hydrologic or vegetation information is considered insufficient for developing
such models, additional studies should be initiated.
------------
• ~atana to Devil Canyon: A r.10re detailed treatment of the potential for
r 1rne1ce or fcefog formation is needed here. For example, ice buildu8 on
vegetation has been found to keep the soil surf&ce open in forests.l_/
Sapling tree stands heavily damaged by ice produced more brush whereas ice
damage in mixed-oak .tree stands resulted in loss of understory sapll?gs and
low tree branches ~nth herbaceous plant growth enhanced in sunaer.__. Such
changes fn understory or reduction in winter browse availability could be
particularly crit i cal to wi'ldl i fe subject to extensive adjacent habitat losses.
The types of vegetation wnfch may form, over the project life, on
•newly-exposed areas with adequate soils• should be described relative to
adverse or potential benefits fo!' various wildlife species •
• Devil Canyon to Talkeetna: Paragr~h 3: This quantified description of
expected vegetation type Changes ise type of detailed impact analysis
necessary for other project areas (e.g. preceeding sect ion on \Jatana to Devil
Canyon and following section on Talkeetna to Yentna River). Once the revised
ve9etation mapping and analysis is corilpleted, this type of analysis should be
the basis for exar.1ininy the positive and/or negative impacts to wildlife of
these vegetation changes, over the 1 ife of the project.
Paragraph 4: The statement that, •post-project ice fono1ation in this reach
will be si~ilar to present conditions,• appears to conflict with previous
descriptions whereby fee forgatfon will not occur until approximately river
mile 130, slightly more than half way to Devil Canyon fro~ Talkeetna (Section
2 .3(a)(iii), page E-3-90). In order to understand how area vegetation gay be
less-influenced under post-~roject break-up, it would be useful to explain
present flilpacts of break-up on the vegetation. Please address the change fr'lm
a bank-ful l flood interval of 1 to 2 years for this section of the river.
Quantification is needed of the area over which vegetation could be
established with this schedule for less frequent disturbances •
• Talkeetna to Yentna River: Para~aph 2: Again, the vegetated areas and
types which could become establish on the actfve gravel floodplain under
less frequent bank-full floods should be described.
Para~aph 4: \Je question the suggested vegetation changes between Talkeetna
and e Yentna River. Vegetat i on allowed to establish over a longer period of
tige (e.g. 5 to 10 rather than 1 to 2 years) would see11 le·ss likely to be
disturbed when the bank-full flood does occur. Given the annual flow
1Q! Butler, R.~-1., tl .H. Wooding, and E.A. Myers. Spray-Irrigation Disposal
of Wastewater. Special Circular 185. The Pennsylvania State
Un1ver·sfty, College of Agriculture Extension Service, University
Park, Pennsylvania. 17 pp.
11! \Jood, G.W., P.J . Glantz, H. Rothenbacher, and D.C. Krodel. 1975.
Faunal response to spray irrigation of chlorinated sewaye effluent.
Research Publication t•o. 87. Pennsylvania State University,
University Park, Pennsylvania. 89 pp.
variations over thfs stretch of the rfver, ft would seem possfble and
necessary to predict areas of vegetatfo~ change for maxf~ and minfgug flow
scenarios.
Para:laph 3: Ye recoamend calculating the potential vegetated area and types
there n within the referenced 2.5 km area downwind of the reservoir within
which air temperatures may be affected. Resultant 1apacts on timing of
veyetation yreen-up or leaf-drop could be important for area wildlife.
Para~~h 4: A more extensive treatment of foy bank development should be
1nc1~ here, please refer to our cougents under Section 3.3(a)(i1)-Effects
of Altered Downstreag Flows • Yatana to Devil Canyon.
Also see c~nt above re calculating the area within 3 km offshore which may
be affected by fee development.
-Effects of Increased Human Use: We have repeatedly cited the important
opportunity for m1n1~1zing project impacts on ftsh and wildlife by carefully
sftfng and regulating access (see FWS letter to Eric Yould, APA, of 17 August
1982). The potentials for off-road vehicle (ORV) use and accidental fires
with project access described here confirm that such use cay need to be
effectively controlled as fish and wildlffe rn1t1gat1on. Please refer to
co~nts under Section 3.4(c)(11) re our recommendations to eliminate the
Denali Highway access route and to restrict worker and public use of project
access routes.
we are concerned about 1nconsistencies wfth the first sentence here, re
greater access opportunities, and with points made fn the Yildlife Section.
That section appropriately contains repeated descriptions of (1) the
significant negative fgpacts from increased use and access; and (2) the need
to carefully control project area use and access (e.g. Sections 4.4(a)(i),
(fi), (iv), and (r) and 4.4(c)(ii)). Please clarify •
• Off-Road Vehicles: Para a 3: In view of previous incogplete coverage of
we an s see our caygen s un er Section 3.2(a)(vi)), we question the
definition behind use of the terg wetlands here. This discussion illustrates
the need for the improved wetlands .. P which 1s to be developed.
(b) Devil Canyon Development
(f) Construction: Other than quantifying direct vegetation losses frog
reservoir inundation, the section fails to provide any indication of the
relative magnitude of other potential losses or alterations in vegetation.
· Vegetation Removal: Please refer to our concerns under Section 3.3 re lack of consultation in siting camp, vfllage, and borrow areas.
-Vegetation Loss b~ Erosion: Again, a gap of peraafrost areas would be
useful. G1Yen the1kely ineffectiveness of replacing topsoil and
re~ontouriny (Section 3.3(b){i) • Indirect Cons~uences of Vegetation
Removal), we suggest that clearing gay be a sign1ficant source of erosion.
-Effects of Altered Oraina~e: We recor;aend that this section include the
area of lakes, ponds, and o her wetlands which gay be affected by proposed
borrow areas.
(fi) Fillfn¥ and Operation: Paragraph 3: The potential for GIOverant ~f the _____ _
large lands 1de at river Qlle 175, causing upstreag flooding and Toss o~ mTd-
and late-successional vegetation in valuable riparian areas, should be
described in IJOre detail. For example, the p\ltentfal .size of the area to be
impacted should be described.
• Vegetation Succession Following Clearing: Please refer to our previous
coggents, Section 3.3(a)(ii).
• DcM1stre11:1 Effects: The unknown consequences of frost buildup on vegetation
adjacent to the reservoir represent a significant potential change in
vegetation and thus impact to wildlife (see our coaments under Section
3.3(a)(ii)). These consequences should be the subject of continuing studies
and quantification.
(c) Access
(f) Construction: Paragraph 1: Please refer to our comgent under Sect)on 3.2
regarding or.tission of base line data on proposed access corridors. Beca.use of
this oc1ss1on, the exact areas which would be cleared within the 34 rater (&J)
x 67 KW access corridor 4escribed here are unclear. Please explain why this
description appears to conflict with earl f.er descriptions of road width and
length (Section Z.3(c}(1)). Inconsistent ~e of both getrfc and English units
within the same report adds further confusion.
(ii) O¥erat1on: Paragraph..!: Our cOGJaents under Section 3.3(a) (11) a.pply _
here a so.
ParaKaph 2: The potential for fee buildup on the ra.f'lroad tracks and
resu ant iGJpacts on vegetation should be examined.
(d) Transgfssfon Corridors
(i) Construction: Paragraph 1: Please clarify the differences among hectares
to be impacted by the transmission corridors as cited here and in Tables '"24,
W25, and W26. Moreover, referenced Table W29, has nothing to do with
trans~fss1on corridors.
Para~aSh 2: Wetlands, as used here, should be defined. Precalculation of
affec e vegetation types will need to be undertaken after the ongoing
yegetation remapping. rwtatfon should be gade that, (1} low-lying vegetation
types will remain largely undisturbed, and (2) beneficial iapacts of i.ncreased
browse productic,, will be realized, only if access and ORV use along
transr.Jfssion corridors are effectively controlled. Quantification of
pptsqt1e1 ipsreases tg brpwse shou14 be possible on the basis of succession
~~dels and continuing classification studies. Such quantification is needed
to ccx.1pare overall losses and thus li1ftigation requirero~ents for the project.
(if) Operation: Our comments above under Section 3.3(d)(i ) apply.
(e) IriNact ·SW'i51arf An explanation 1s needed for the process or criteria for
deterg n1ng 1mpac •priorities of i~ortance.•
(i) thou~ (v): This qualitative su.ary describes several data gaps which we
believe s outd be answered, e.g. the vegetated area ~J ieh may be l ost with
land sTumpage fr011 pen~~frost, changes in downstreua floodplain vegetation.,
etc. Overa 11, we are concerned with lack of' attention to caaalative f~~pac:ts,
an inattention gade gore acute by nonquantif1cation of most i~aets. The
nugerous •~;~in imaT• and •minor• 1mpac.ts for each project feature aay
CUJ:IUlltively represent significant alterations or Toss of vegetation. FrOiil
the standpoint of fish and wildl if'e habitats, project-related activities
throughout thfs primarily undisturbed area represent the first intrusions
similar to those which have Ted to significant and Tosses of fish and wildlife
throughout the contemfnous United States. A serious Olilission fn this section
is consideration of impacts to wetlands and floodplains.
(vi) Prioritization of Jg~act Issues: We concur with the evaluation of
acreage losses for a vege ation type relative to the proportion of' that type __ _
in the region. Since vegetation is a key coraponent of wildlffe habitats, the
basis f or evaluating whether c.011111unity changes are •good• or •bad• should
follow in the Wildlife Section of this chapter. However as discussed there,
an inteyrated evaluation of all species is lacking. There is Tittle basis for
makiny decisions on prioritizing spec.fes concerns or resultant tradeoffs in
project impacts or mitigation alternatives. Our pr-evious coc.nts on each
impact issue identified here apply. Addftfonally, we have a few specific
cOLDents.
-Direct Losses of Vegetation
Access Roads: While the act~al area covered gay be small relative to other
project fgpacts, access routes indirect l y impact a guch larger area because of
their linear nature •
• Transgfssion Corridors: We would like to be assured that the reference to a
1 iidfan strfp for transport of personnel and gaterials•, is consistent with
the environmental guidelines for transafssion corridors (Appendix AE -
Trans;1ssion Corridors, item 1) with whfch we concur. As with access roads,
above, tranSiil1ss1on corridors indirectly f111pact a very large area .
-Indirect Losses of Vegetation: The cumulative 1gpact of project features
mentioned previously, ;s Of particular concern here. ~~ny of the identified
losses wiTT be in riparian corridors which are of particular significance to
wildlife species.
-Alteration of Vegetation TyPes: We ayain recomgend that successional type
changes over the proJeCt );fe be quantified in the license application.
3.4-:1itit0tion Plan: We find the proposed plan incomplete and too general.
There are o main problems with this plan. First, because impacts are
incompletely quantified, it is not possible to determine the value of
recomgended/accepted mitigation measures or the magnitude of unavoidable,
adverse impacts whfch will not be mftfgated. Not integrating thfs plan wfth
the fish and wildlife mftigatfon plans fs the second main problem. Thus there
is no coaprehensive picture of overall project impacts, prforftfes for
gftfgatfon, potential for achieving those prforftfes, or tradeoffs among
~ftfgation options for various area resources.
An approach similar to that for the Fishery Section mftigatfon plan (pages
E-3-120 through E-3-144) would be ;ore appropriate. Ye recomaand restating
the full range of mftfgation alternatives here, prioritized fn accord vfth
NEPA guidelines: avofd, mfnfmize, rectify, reduce or eliminate over tiaa, and
finally, compensate. Thfs approach should be expanded to include reasons for
rejecting high prforfty mftfgatfon in lieu of lower prforfty measures (e.g.
proposing regulations on access rather than alternate siting or scheduling of
access). A mftf~atfon plan, incorporating specfffc, effective measures whfch
have been selected through thfs process. should then be presented.
~~ny of the identified fwpacts are not addressed fn the aftfgatfon plan
itself. In those cases, fapacts should be clearly fdentfffed as unavoidable,
short or long-teru, adverse ili1pacts. · Moreover, we ffnd the report lacks
information specfffcally required by FERC regulations (F.R. Vol. 46, No. Z19,
13 Novegber 1981), Section 4.41(f){3)(iv), f.e. there are no implementation,
construction, or operation schedules for recommended mftfgation ceasures;
which measures have actually been incorporated fnto project plans fs unclear;
and neither replacement lands nor habitat manipulations have been identified
as to either suitable sizes or locations.
Generalities of the plan are exempli~ied by references to using, •depleted or
non-operational upland borrow pfts ••• as overburden storage areas where
feasible• {page E-3-187) or reference to •a feasible haul distance,• (page
E-3-187). .
(a) W&tana Developsent
(f) Construction: Paragra~ 1: t1itfgat1ve fHtures whfch have been
incorporated fnto ~ngfneer ng design and construction planning should be
clearly stated. Reasons for rejecting our recoaaendatfons have never been
for~ally provided (e.g. access road siting). Location of the construction
camp and village on shrublands (per Table ~7) rather than forestlands may not
minimize igpacts, depending on the wildlife species of concern, erosion
potentials, proximity to construction and access facflitfes, etc. Again,
since we were not consulted in siting of those facilities and have not seen
Exhibit A, we cannot fully understand the situation. A aechanfsm for
enforcing the referenced prohibftfon of off-road or all-terrain vehicle use
should be included (see FERC regulations Sections 4.41(f)(3)(iv) in F.R. Vol.
46, tlo. Z19, 13 t4ovser 1981).
Paragraph 3: We suggest that facility siting to avoid wetlands be rerevfewed
fn consultation with the FYS and CE and proposed revisions to th~ wetland
~s. As with similar points about •minimizing• or •reducing•, there fs no
quantification, particular!y relative to the agount of wetlands, or other
irnpacts in other report sections, which will be iapacted and which can be
avoided.
Paragraph 5: We concur that spoils should be placed in the inundatio·n area as
long as such placeaent will not create a sediaentation probleca.
Parayraph 6: We recoamend explaining whether project engineers have confirmed
that floodplains or first-level t errace locations will not be needed for
borrow for ancillary project rae iT it ies.
Parayraph 7: We recoggend that siailar detailed inforgation be provided
throuyhout the report.
(if) Filling: Please refer to our General C~nts, Botanical Resources, re
identifying feasible habitat enhanceGJent 111easures or replacerJent lands. The
contention that 11100se winter browse •may be c01o1pensated• is useless, given
that (1) there is no guarantee in this plan that enhancegent or land
acquisition will ever occur; and (2) quantification for how lilUCh/where/what
type. of land must be enhanced or acquired is lack iny. Moreover, tradeoffs re
cogpensatio· for moose to the neglect or adverse impact of other species have
not been settled or even discussed.
Para~aph 3: Because of internal inconsistencies, the overall effect of
si1ti:ion is unclear.
Paragraph 5: Whether rectification will be one percent or 99 percent is
unclear.
Paragraph 7: We concur with revegetation plans to egphasize fertilization and
ainim1ze seeding where erosion will not be a problea.
Parafnaph 8: We strongly support plans to rehabilitate all sites by the first
yrowny season after they are no longer needed. A.ssurances s"ould be provided
that sufficient quantities of seeds would be stockpiled and regrowth
potentia 1s of available native strains will be tes i.ed prior to project
abandonment of disturbed sites. Choice of plants for site rehabi 11tation
should be in consultation with Federal and State natural resource ayencies.
(iii) Operaticn: Paragraph 1: We concur with the proposed aonitoring of
downstream veyetabon Changes but note that monitoring fn itself fs not
aftigation. Periodic controlled flooding to gafntain primary and secondary
successional stayes aust be coordinated with the Fishery Section and Wildlife
Section mitigation plans.
Parasraeh z: We have assumed that nonessential portions of the disturbed
areas w1ll be promptly rehabilitated. Please specify.
(b) Devil Canyon Development
(f) Construction: ParaJ1aTh 1: Our comgents relative to the Watana
developraent (Section 3. a {if)) mitigation apply here also. An additional
~itigation need fs monitoring and enforcement relative to ORV and unauthorized
access uses. Spoil disposal described here was not discussed or previously
covered in the igpacts Section 3.3(b)(i).
(if) Fillinf and Operation: Again, our c~nts under Watana Developaent,
Sect1on 3.4 a)(11) and (tli) apply.
(c) Access
(i) Construction: Paraflaph 1: Please clarify why avoidance of closed forests
was tiriiid as a mitiya ve ••sure in siting of the Denali Highway to watana
access road. Section 4.4(b), paragraph Z supports this siting re minimization
of project frapacts to pine lillrten. If this fs the reason, that reference
should be rade here and further infonatfon 1s necessary on other species
adversely affected by this siting and adverse/beneficial iapacts of
alternative sitings which were eliainated. Wetlands will need verifying per
our previous cogments (Section 3.4(a)(i)). At least one line of this
paragraph was omitted.
Paral}aph 3: We refer you to our previous coaaents on wetlands, Sections
3.2(a (vi} and 3.4(a)(i).
Para~aph 4: Information fs too general. We concur with the intent but do
not ~ve necessary specifics as to the extent of mitigation which will be
achieved.
(ii) ~eration: The referenced management provisions should be ~escribed here
1nc1u~ng busing of workers and restrictions on non-project-related uses.
Para~aph 2: The extent of ~itigation which can be achieved for gany project
fgpac s will depend upon the ~nageDent options under review by the APA. In
the APA f·1itigation Po lfcy docUiillllt and under NEPA guidelines, avoidance is to
be the first priority in i&plllillnting ~:aitigation. Threfore we refer you to
our previous correspondence on this tssue (letter to Eric Yould f~u. FWS, 17
August 1982) as part of our pre-license consultation. In brtef, th~ necessary
avoidance should include eli~:aination of the Denali Highway to Watan& access
road and prohibiting use of other project access routes for
non-project-related access. Instead, construction access should be by rail
from Gold Creek, along the south side of the Susitna River to Devil Canyon,
and access on the north between the two dams. Non-project-related use of
these access routes should be prohibited during project construction. A
thorough analysis should be provided here of public access from the standpoint
of adverse irapacts to fish and wildlife and their habitats in comparison to
any positive igpacts for recreational and subsistence fish and wildlife uses.
Ue note SOiill conflict betveen the statesaent that the IIA is reviewing a
variety of access management options with the suggestion that the project
access route from the Denali Highway may be eligible as a National Scenic
Highway. That designation would stimulate public access to the increased
detriment of fish and wildlife, effectively foreclosing soae mitigative
~nagement options.
Paragraph 3: Please refer to our gore extensive c~nts on the Recreation
Plan re consistency with fish and wildlife protection priorities. We strongly
concur with the proposal to gonitor fish, wildlife, and vegetation igpact but
again note the report•s deficiency in not describing how and by whom
gonftoring will be completed (see our General C~nts, Fishery Section).
t~reover, the process for modifying proJect operations or the Recreation Plan
to better effect r.1ftiyat i on is not described.
(d) Transgfssion
(f) Construction : Please clarify what criteria were used for siting of
transmission corridors. Assurance is required that project plans include
construction by helicopter or winter access.
Paragraph 2: Again, refer to our previous coaments on wetlands. ~· reca.aend
lilin11i1111 150 11 buffers between swan nests and any port.ions of the tranSiil1ss1on
corridor.
~if) Operation: ~e concur with this plan but are concerned that it 81Y not be
mplemented. We hope to avoid a repeat of the Intertie situation where
on-ground access was later guaranteed to the operating utilities contrary to
residents' and agencies• recoggendations. That guarantee already contradicts
this plan, given the dependence and interrelationship of the Susitna project
with the Intertie.
Since habitat manipulations, including fire, crushing, etc. (Section 4.4(a)(1)
and ( 1v)) are beiny suygested as a prfe~e mitigation geasure for w1Jdl ife, we
recor.E~end that potential effects of those activities on ve.yetation types
within different project areas be discussed here. The potential value for
rJitigation of various habitat manipulations should be explained similar to the
discussion on fire, Section J.Z(a)(ii).
Two additional iteas which should be covered in this r.1itigation plan are the
r.JOnitoriny and surveillance plans referred to earlier and an erosion control
plan specific to project features and schedules .
Specific comaents on tables and figures relative to the Botanfchl Resource .s
Section follow:
Table \13: Please change in accord with our reconaenda.tfons under Section
3.1(c), to •candidate endangered and threatened plant spec ies•, etc.
Ta.bles W5 throu~ W19: We suggest including a footnote or appendix briefly
descr161ng how ese data were collected with sOGte explanation of whether
sampling intensity was coaaensurate with the avaflabfHty of the vegetation
type wfthfn the project area and potentfa.l for that type to be impacted by the
project.
Ta.bles \121 through U23: The number of sites saapled 1n each type should be
included. As in our COiililents on the text. information should be provided on
how these categories compare with the vegetation categories Sllilplett within the
upper Susitna basin.
T'ab 1 es U24 throu~ '11126: P 1 ease c 1 arify whether the 400 to 500 foot
right-of-way orb foot cleared centerline area was used in these
calculations. Per our previous cogment on the trans~ission corridor, a similar
ta.ble for the Intert1e portion of the transmission corridor should be
included. We also suggest a SUiililary table showing the vegetation impacts fro~:~
a 11 seg~:~ents of the trans~:~ission corridor·.
Please refer to our cogments in the text on need for an additional table
showing vegetation types to be i~:~pacted by all access corridors, preliminarily
identified borrow areas (e .g. borrow area G is not included in Table W28) and
spoil areas. Where questions reaain on the size of borrow/spoil areas to be
used or the necessity of a 1? potentia.lly identified areas, notation should be
rade of potential maxilllllil and miniiiiUII sizes and any ordering re use of these
areas.
Figure Ul: Granted, it is difficult to reproduce such a ~ap at this scale.
However, we recoamend a larger reproduction be included fn the final
application. That •P should include an overlay showing reservoir inundation
areas, acce.ss roads, transmission corridors, and other project features. A
correspondfny map of downstream vegetation and overlay of transmission
corridors is also needed.
Figure W3: Once the reupped vegetation classification is completed it should
be correlated to this table tD quantify potential vegetation changes and types
over the 1 ife of the project.
Figure U4: As ahove, this figure should be a basis for analyzing downstream
successional trends given the projected longer times between floods.
Maintenance of habftat JDanipulations should be specified on the basis of this
figure. and mitigation objectives.
4 .. WILDLIFE
4.1 Introduction: Ue recoggend expanding this section to at least acknowledge
the ecological values of all wildlife species, as well as to ~re clearly
outline objectives of the report and resultant mitigation plan. we again
point out the need for an overall discussion of fish, wildlife, and botanical
resources, overall lilitigation plans, and tradeoffs in benefits to some
resources at the expense of others.
(c) Species Contributing to Recreation, Subsistence and COQg8rce: No~ only _
birds, but all wildlife species in the project area contribute to
non-consumptive forms of recreation. Incidental viewing of wildlife in
conjunction with other actfvfties fs an unquantiffable but well documented
value. For exaaple, the i!ilpOrtance of downstrea. fish and wildltfe habitats
to fish, wildlife, and the significant nUIIbers of people using tha has been
recognized by the State and agreed to by the Matanuska-Susitna Borough
Assembly. Fish and w11d11fe have been designated a priury use on every State
land Janagement unft on the east side of the Su$ftna River fro• Cook Inlet to
just below its confluence with the Kashwftna River. These managelillnt units
and state guidelines for protecting fish and wildlife are described in the
recent State report, Land Use Plan f~r Public Lands in the Ufllow SUb-basin,
October 1981, by the A1aska beparbient of hatura1 Resources (AbftR),
~~tanuska-Su~itna Borough, and ADF&G.
A discussion as to why the evaluation species were selected and prioritized as
described here is as applicable to terrestrial wildlife species as it is to
fish (Section 2.l(d)). we suggest referencing that discussion here. Such
inforgation is particularly important w1th regard to mitigation plans for one
species which conflict with another species. Ue also suggest noting values of
key bird species, i.e. bald and golden eagles have received national
protection (Bald Eagle Protection Act, 16 U.S.C. 668-668c); trugpeter swans
are highly valued because of their for•r endangered status; and other
gigratory birds are protected under international treaties and the Migratory
Bird Conservation Act (16 U.S.C. 7.Ql-718h).
Please note, all references to tables fn the wildlife section of the text are
to table numbers one greater than on the actual table. we have referred to
tables as they are actually nUGbered.
4.2 Baseline Description
(a) Big Gue
(1) l·1oose: rtiss1ng figures and values are a problem throughout this section.
-Distribution: Please document how moose are •one of the most economically
important wfldlffe species in the region;• also see our coments on Chapter 5,
Section 3.7(b) •
• Special Use Areas: In view of your repeated citations that winter range is
a key area for goose (e.g. Section 4.2(a)(1) • Seasonal ~~vegents: Parafia~h
6; Se.ction 4.2(a)(i) • Mortality Factors: Paragraph 5; and Section 4.3 a) f)
t1inter Use), we suggest including a section here on the use and avai1abil ity
of winter range 1n both stvere and mild winters, as well as the data gaps and
plans to overcOQ& them re1ative to this study. t-laps showiny use areas
described here relative to project features would clarify this section.
Calving Areas: Para~aphs 3 and 4: N~er·s of lilale and faraale 10100se radio -
collared in each ofe downstream study areas should be described here •
• River Crossings: To better understand how not only the reservoirs, but
ancillary project features such as the Devil Canyon camp and village, .ay also
influence 110ose crossf.ngs of the Susitna River, crossings both i.-diately up
and downstream of the impoun~nt areas should also be described (also see our
COCIIIents under Section 4.3(b)(i) -Interference with MoveMnts).
-Habitat Use: The rain problllil with this and the following section on
populations fs that there has, apparently, been no integration of moose and
vegetation data •
• Cover Requirements: Para~aph 7: Please describe the scope and schedule
for the necessary studies o habitat use, or reference the discussion under
Section 4.3(a)(i) -Quantification of Project Effects. Correlating aerial
observations to the remapped vegetation types should provide additional
inforwation on habitat use. Elevation, slope, or other habitat ~parameters may
also need to be incorporated in this analysis.
Habitat Use in the U~per Susitna Basin: Paragraph 3: Further info~ation is
needed on the unders or1es associatid with these hibitat types. -Please --
indicate when such information will become availabl~.
Para a h 2: For consistency, the .-n=..._e_r_o_..,......,._ema._,..e--QO_.o_s_e-ra.....,,...o""'-c"""o"-"""a.-.r .....,..._n_o .... r """"""""'o ..... •a-......-.eetna shou 1 d be provided, ---
also see our colllillnts under this section, Calvins Areas. The discussion fs
confusing due to frequent cOQbining of quantitat1ve data with qualitative
stategents such as •aost female use,• •at gost relocation sites,• etc. Where
it is available, we recoauend supplying quantitative inforlilition, with
qualifying discussions on limited sample sizes, periods of observations, etc •
• Food Habits: Paragraph 2: Again, please describe the scope and schedule of
ongoing analyses and~ow that information will be integrated in t o mitigation
planning in a timely manner. Reference to your Section 4.3(a)('f) -
Quantification of Project Effects w111 provide some of this information.
Paragra~hs 4 and 5: Ye suggest examining how browse avaflabflfty and
vegetation types utflized by liiOose correlate with r.10ose relocations in
reference to the remapped vegetation types.
• Hoe~e Ranges
The Upper Susitna Basin: The rational should be given for selecting an 8 kg
wide analysis zone adjacent to the fQpoundgent.
-Population Characteristics
Paragraph 2: Substantiating population and productivity data 1n Tables W32
through W34 should be referenced here •
. Po~ulation Estigates -Upper Susitna Basin : Plea$e describe what types of
hibf at correlations can 6e1Side from remapped vegetation types and other
habitat paru.ters for low, high, and liiOderate .aose density areas •
• t·lorta lity Factors: Paragraph 1: \ire rec011.1end describing how range qua 11ty
has been decreasing.
Parafaa~hs 2 throuJfl 4: Please describe the COiilparabflity of brown bear
popu~t ons and hib tat types between the Nelchina and Susitna -River basins.
We recocaend expanding the discussion to include hunting as a mortality
fac tor. Both recreational and subsistence hunting can affect population size
and structure. Hunting figures prominently tn Tater igpact discussions.
Historical hunting effort and success data relative to changing management
regulations should be described, and coordinated with Chapter 5. Please also
refer to our comments under Chapter 5, Section 3.7(b).
(ii) Caribou
-Distribution and Hovemert~ Patterns: Paragraph 6: Please describe how 1111ny
an1ufs were radio-cotlc:-.;! and the nUiibers of radio locations-liJide for each
one.
Figures \49 and WlO of caribou radio locations should include. the Tocat ions of
project features.
-Habitat Use: Please clarify whether aerfa.l observations or an overlay of
radio locations on ex 1stfng vegetation type .. ps were used to deter~ine
caribou use of different veyetat.ion types. A correlation should be provided
for the proportion of the basin which fs fn each type relative to the
proportion of radio-collared caribou sightings within each type (Table W36).
Please discuss whether vegetation regapping efforts will affect the
interpretation of caribou data.
Para~aph 10: Changes in the number of permits frog 1972 to 1981 should be
desc~bed and percents of the herd harvested, by year, included fn Table W38.
Para~raph 11: Please tabulate data on wolf population, wolf predation, and
car1 ou nUEbers froa 1957 to 1981.
( i i 1} Da 11 Sheep
Parafuaeh 5: ~e recoril:lend further justification be provided to ·support the
conc~s1on that iapacts frau the impoundsents will be •inor. Clarification of
where the sheep w f nter and of sheep IIIOVSIInts between seasona 1 ranges shou 1 d
be provided.
ParaYaa~h 6: Reference should be provided for the judgeaent that the sheep
popu at on has rsained stable or slightly increased.
P4ra!)aph 8: Please provide a gap of the Jay Creek mineral lfck, and probable
trave corridors to the area, relative to the ~atana impoundment. We
recogcend providing historical harvest data and explaining how project surveys
relate to area populations.
( fv) Brown Bears
-Distribution: We recommend providing data on the numbers of bears radio-
collared and radio locations ~de, as well as gaps of those radio locations
relative to project use.
-Habitat Use: Paragraph 2: Please describe whether aerial observations or
vegetation type maps were used to detergine vegetation types relative to brown
bear radio locations. An explanation should also be provided of how li10re
detailed vegetation data and the vegetation reaapping efforts will be
integrated with the analysis of brown bear habitat use •
• Hoge Range: Paravra~h l: Please correct the referenced Table W42 which
11sts dati from proJec studies in the Susitna, not the Uelchina basin. -
Paragraph 2: .An explanation. should be provided as tc why 1.6 km and 8 kliJ were
Chosen as the break: down for study zones around the fmpound&ents.
Paragra~ 4: Please describe data on bear radio locations relative to access
roads, ansmi'ssfon corridors and ancfllary project features.
(v) Black. Bears
-Distribution: We recoliDend including raps of bear radio locations relative
to project features.
-Habitat Use: Please •1escribe how further, vegetation studies and reGIIpping
wiTT be integrated witn the analysis of black bear habitat use.
-Food Habits: The scope, schedule, and integration of ongoing predation
studies relative to further project planning should be addressed here.
(viii) Belukha Whales: Please note that several of the references cited here
do not app~ar in the bibliography.
-Distribution and Habitat Use: Para~aph 5: We suggest integrating data on
chinook salmon from the fisheries stu ies in order to obtain so;e estigate of
the iL~ortance of that fi3hery and of project i~acts to th~ fishery on
belukha whales. Please also describe what data will be gathered on s•Tt for
better evaluating project i~apac,ts on belukhas.
(b) Furbearers
(f) Beavers: We recoamend including a ~P of the study area which details
specific Study sections, available density data, and representative .ain
channel, side channel, slough, and clear water areas. The dfseussion should
be expanded to cover the extent to which suitable beaver habitats are fully
utilized or explanations where they are not.
Para~raph 4: We recoggend investi~ating the extent to wtich bank lodges are
used by beaver and to which the activity levels reported in Table WS3 gay be
underestimated. An on-yround survey when beavers come out of their dens to
forage just before spring break-up could verify such use.
Paragraph 8: Further quantification should be provided on trapping effort and
success, see our conaents under Chapter 5, Section 3.7(c).
(ii) 1·1uskrat: Parafa~h 2: Please clarify whether the 106 lakes surveyed
contftute all the ~~s between the Oshetna River to Gold Creek impact area.
Please relate this discussion to the number of muskrats potentially inhabiting
this area.
Para~a~ 3: Please provide an indication of downstream aJSkrat populations
anda& at quality.
Paragraph 4: Please quantify present and h'fstorical trapping effort/success.
( v ) t·1arten
-Po~ulation Characteristics: Para~aph ': No data is provided to
subs antiate that pine marten aree •economically most important furbearer,• ------
or to relate densities to populations and habitat quality. Please also refer
to our c~nts under Chapter 5, Section 3.7(c) •
.. Habitat Use: Please refer to th,e co11101ent ilililldiately above.
(vi) Red Foxes
-Habitat Use
• Denning Habitats: Please provide fnforaation on the density of fox dens
re1attve to habitat quality, and to other Alaskan and/or tlorth American fox
populations.
Paragra~ 5: SaGe explanation should be provided for the disparity of .are
fox tra s on the south side of the river but aore dens on the north side.
-Food Habits: Paragraph 3: The postulated link between fox and hare
populations raay be overstated. Apparently hare nUiilbers have never been higfi -·
or an important food source for fox in th 1s area (Furbearer Study Coord ina tor
Phil Gipson, personal coamunicat ~on; also see Section 4.2(b)(vi1): Paragraph
! and Section 4.3(a)(xiii): Paragraph 5).
-Po,ulation Characteristics : P'lease refer to our previous co;aents under
Oenn ng Ribitits relat1ve to habitat quality (Section 4.2(b)(vi)-Habitat ·
Use). Again,~apper effort and success should be docuaented, also see our
Cciiillents. on Chapter 5, Sect ion 3.7 (c) •
(vii ) x Least Weasel: ~e understand that none of these species
were c osen as 1 pr or y or evaluating project 11i1p&cts . However, -_,e ---··-
recoamend providing some quantffic~t ion for the descriptfons of •fairly
numerous• but not •Jigited,• •locally abundant,• and •sparse,• in addition to
trapper effort/harvest; also see our cOCiiJents on Ch.apter 5, Section 3.7(c).
(c) Birds: Paraf.aph Z: Please note that waterfowl breeding pair surveys
have 6,~, conduc ld by FliS fn the lower Sus ftna R 1ver-·bas-fn-for over 20
years._. The F\IS has a }Jq conducted statewide surveys for truapeter swans
in 1968, 1975, and 1980.J!t
Para~ph 3: We recOIIill!nd further infomatfon be provided on how relatfve
ibun ces of bird species were deten~ined. Please clarify the difference
between 60 percent of the area being in shrublancls, as cited here, with the
just oveT 40 percent 1n shrub l ands, as cited in Table W4. At the August 1982
AEA Workshop on the project, much discussion centered on proble.s with
correlating the bird habitat classification scheae used by Kessel et al. for
project bird studies with the Oyrness and Viereck Alaskan vegetation
classification syste. used for project base l ine veget.ation .. ps. ~~ reca.gend
describing those problems here and how they will or will not be overcoge by
ongoing vegetation 'egapping. Throughout the bird sections of the draft
application we are concerned that source(s) for referenced data, or data
11/ The most current data is available in: King, J.G. and B. Conant.
1982. Alaska-Yukon waterfowl breeding pair ·survey, 18 t-~~y to 13 June
1982. USfijS, Juneau, Alaska.
~ The ca.puterized compilation of thi~ data is available at the FWS'
Alaska Regional Office, 101 1 E. Tudor, Anchorage 99503; please
contact Greg Konkel, (907) 263-3395; original data is available frOGJ
Jig King, USFWS, Juneau, (907) 586-7244.
ranipulations, uy not be fully doc~nted. Thus we recoa~end describing
where and how data froa gore than one source has been ganipulated forth 's
report. !n particular, the tables and figures should be aore completely
referenced, including explanatory footnotes.
(1 ) Ra tors and Raven: Para ra l : Ye are concerned that 1980 and 1982
rap or surveys were no con uc at the optigua time: i.e. sumger foliage
would Qake it difficult to initially locate nests (we note that SO percent
moro nests were found in 1981 than in 1980); according to Table Y&O, nestf r.g
raptors will have fledged their young by 30 Septelber .akfng it difficult to
deteruine nest activity 1n Oct~-. Please 1ndfcate the experience of
observer(s) conducting the raptor surveys and aethods used, (e.g. W.ethr
surveys were by hetfcopter or fixed-wing aircraft). We also reca.end that
.aps of actual nest locations be included. We note that goshawk nests are
often difficult to find by air and thus question whether the nuablr of nests
cited here is 1 thorough assess.nt . Please clarify in the text whether all
rap tor nests act he in 1980 were also active in 1981 •
Para~raph 3: Please expand the discussion to aore completely describe the
hibf at suftabilfty of the project area for golden eagles, given their
apparent hiyh density.
Paragraph 4: Refer to our comment under Section 4.2(c)(f): Paraflaph 1,
above, re the late t1mfng of 1980 and 1981 surveys f'or nesting bad eagles.
Please provide a description of the survey ;ethods used.
Paragraph 5: Ue recoggend that discussion be provided relative to h&bftat
va.Tues re how Susitna habitats COiilp&re with those a long the Tanana River where
slightly lower nesting densities are reported.
Paragraph 7: Due to the status of the arctfc peregrine falcon (Falco
pere17inus tundrius) as an endangered species under the Endangered Species Act
of 1 3. as aaendid (16 u.s.c. 1531-1543, as aaended), we are particularly
concerned with the adequacy of surveys for thllil, e.g. peregrines would have
already left the area by October when the 1982 survey was done. Thus, we
again recgggend describing how the surveys were conducted, for how tong, and
by wh011. iJe recOIIIillnd that peregrioe falcon surveys be conducted annually, fn
early July, throughout project studies and coftstruction, or until there is
sufficient evidence that peregrine falcons do not inhabit the project area.
Sufficient evidence would be. no sfyhtings over several years of helicopter
surveys, by a reputable observer during the proper tira of year. Observers
should be individuals who have worked with peregrine falcons . FVS r eview of
specific tiges and survey techniques would be approprfa.te.
Ue rec~nd the discussion be expanded to describe the area's importance in
raptor r:~igratfons as well as for breeding.
(ff) Vaterfowl and Other Large Waterbirds: Please provide sage quantification
for tergs used here, e.g. 'large' concentrat i ons of waterfowl (paragraph 1);
•t ittle used• (paragraph 4), etc.
Para~aph 3: We reca.mend you incorporate additional tru.peter swan data
Whic is available frc. the F\IS. Please refer to footnotes 12 and 13.
Paragraph 4: We agree with the conclusion, however we suggest that data frog
FQS annual surveys be included to quantify this st1tement (e.y. see footnotes
12 and 13, as well as Conant and King 1981 and King and Conant 1980 as
referenced in this section.).
~at ion: Para~aph 1: We recorutnd refel"encing the specific study( ies.)
~which conclus1ons ;n the CE reference are taken. Please note that
trugpeter swans are 110ving through the area fn increasing nUii1bers.
Para~aph 3: Please expafn the discrepancy between the statement here that
the ~pper Susitna Basin was less igportant to gigratory waterfowl in spring
than fall,• with d.ata in Table W62 which shows spring waterfowl densities over
twice that of fall densities.
1: Given the previously "Te~s~c~r-Tr-e~"""'"pr~o~~~~~~s~w'ift~r-e~w~e~a...,n~s ;.;c~a~ss~,.c~a~~on used for the project, and
reaapping efforts currently underway, please define ~etlands• as used here.
we suggest clarifying whether the reference is to 22.5 adult waterf2Wl/k~
and 22.5 adult gulls/km2 or to 22.5 adult (waterfowl and gulls) /k~.
Ue question the validity of only cogparing productivity of these wetlands to
the most productive wetlands in Alaska. Upper Susitna area waterfowl
productivity may be ~re typical of Alaska wetlands fn general and represent
average populations and productivity (F\IS Marine Bird Management Project
Leader John Trapp, personal comaunication).
Paragraph 3: Please clarify how •Importance Values• were calculated; also
refer to our cOGaents under Figures W19 and W20 and Table ~3. We sugyest
describing any consumptive use of waterfowl wfthfn the project area.
( ff i) Other Birds
-Grouse and Ptarwigan: We recommend mentioniny any cons~tive use of these
species within the project area.
-Woodpeckers and Passerines: We recoaaend providing s01:1e d'fscussion of the
importance of the trea to lilfyration, as well as, breeding activities of these
birds.
-U'per Basin Bird Coamunities: Please refer to our comments under Section 4.2 c) re the neid to identify here how 1981 and 1982 data were combined,
given that Kessel et al. (1982) only includes data froQ 1981.
Last ParaSf!€aph: P·lease describe how these habitat types do or do not
correlate o vegetation types as now being remapped.
(d) Non-glliJI (small) Marilals: We appreciate the thorough descript i on ·of the
ecolog1cal role of small gamaals in project area ecosystems.
(ii) Habitat Use: Ue su~gest updating the discussion to correlate with
ongofny vegetatfon and wetlands mappin~ efforts.
4.3 I!!!aCtS
(a) Uatana Development
( 1) I.Joose: Paragraph 1: Criteria for concluding that moose is one of the
11110st 1gportant1 species should be provided here.
Paragraph 2: We suggest that the proposed evaluation of carrying capacity
incorporate consideration of habitat values over the life of the project.
Please provide the referenced figure. Con!Sidering the severity of project
iapacts by spatial areas to be affected and numbers as in Ballard et at. 1982
(page 106) would fgprove the d1scussion.
ue are further concerned with the inadequacy of the fliiPacts deffnftfons fn rot
accounting for ililpacts to special concentration areas (e.g. breeding}, fn k•~Y
seasons of use (e.g. calving), and under infrequent but critical conditions
(e.g. severe winters}, and the overall interspersion and a·vailability of su."h
igportant habitat features.
P&ragr£eh 3: Lack of quantification prevents analysis of whether an fgpact fs
liilr, .ice, three times, etc. as severe as one of lower priority. lJe agah1
recOiililend integrating the an.alysis with that in Chapter 5 re also providing
and discussing data on hunting pressure and success here (see our comgents
under ~ction 4.Z(a)(f) • ~lortalfty Factors). Please note provision of acct~s __ · __
is a li1&JOr indirect impact; additional developments or settleaent stire~.~latec
by this access would b~ a seco.ndary f&~pact.
Parafhaph 5: Ue find the discussion entirely too general and inconclusive:
(1} ere fs no indication of the relative difference between •sa.~• mose
wh fch will disperse, adat)t, die, etc; (2) both overall cuaulatfve igpacts, a 1d
secondary igpacts frog ;oose dispersing to adjacent areas are ignored; (3)
1Qpacts on habitat values fra. increasecl use are not cons:fdered; and (4) no
explanation fs given for how and when ongoing studies wilY •refine this
assess..nt.•
-Construction: We are concerned that we have been. given no opportunity to
comment on siting and scheduling for camps, townsites, etc. The location and
use. of these ancfl tary project features will influence the tillgnftude of
·resu'Jtant iapacts. Alternative spoils sites have not been proposed, yet they·
should be part of the discussion. -
•. Habitat Loss: Paragraph 1: We recOiililend including a ClOre thorr·ough,
quantitative discussion of habitat loss in the text. The necessary
integration of vegetation and wildlife .studies should include a discussion of
(remapped) vegetation losses relative to their value as liiOose habfta~ i.e.
winter range, calving and breeding areas, etc. We also see no quant1ficat1~n
of these tosses over the life of the project, f .e. the area of each tYPe which
will be lost forever, vs the area which will be lost for sorae length of tira
during construction, vs-the areas in different successional stages throughout
reclagation. --
Para~aph 2: The paragraph is somewhat inconsistent with the Fishery
Sect1on. Given the mitigation proposed in that section of clearing areas just
before flooding, successional growth developwent appears negligible (Section
2.4(a)(x) -Clearing the Impoundment Area).
Pa-.·agra~h 3: Ongoing S'tudies should be fully described. Please describe when
the hall tat use ana lyses wi 11 be reevaluated O¥• the basis of remapped
vegetation and forage quality studies.
Winter Use: Parb!raph Z: Please clarify the first sentence and
fncons istencies tween that sentence and the prev 1ous paragraph.
Parair~ 3: It would be helpful to also express the number of moose in the
fgpoun nt area as a density and compare that density to areas outside both
the impoundLJent and project area.
Paragraph 4. We recommend that ongoing studies provide data for quantifying
the relative values (quantity and quality) of winter range within and outside
the igpoundLJent area. Such infonation is necessary for de"::enilinin~
raitigation requirecents.
Sprin~ Use: Paragraph 2: Quantification is needed for the _hab ~tat areas
descr bed here.
Paragra~h 3: We recOIIIil!nd tying this discussion to project iGipacts on, brown
be.ar Wh ch could cogpound the predation problem.
Sugger and Fall Use: Paragcaph Z: We are assuming that a heading for
1 -bisturbance 1 was omitted JUSt before this paragraph.
Para~aph 4: Since the lillgnitude of project impacts would appear to
sign 1carrtly vary, depending on whether hunting and haras~nt of moose are
effectively prohibited, we suggest providing •best• and •worse• case
scenarios. Those scenarios should be used to quantify potent.ia 1 losses of
habitat for cogparing impacts and detenilining .lilitigation needs.
Paragraph 5: Please refer to our previous comgents under Sections 4.3(a)(i)
AOose and 4.3(a)(i) -Construction • Habitat Loss re the gene.rality of this
discussion •
• ~~rtality: Please refer to ovr c~nts ~nder Section 4.3(c)(i) •
• Alteration of Habitat: We suggest this discussion be dropped as
inappropriate and unfoun~~. If this discussion only covers the construction
phase of the developraent, then we would assulill there would be no chance for
successional growth. Moreover, the suggestion that ~ose could utilize these
disturbed areas during construction conflicts with the previous discussions on
how disturbance and increased susceptability to predators would cause moose to
avoid r.11jor activity centers and large cleared areas. \Je also find the
suggestion that borrow pits may provide forage inconsistent with the Fishery
Section which proposes to gake fish ponds out of the pits (Section 2.4 (c)(i):
Para ra 2, Construction fHtifFtion). Please refer to our previous co..ents
un er ction 4.3(a)(i.) -Cons uction, • Habitat Loss re the unlikelihood for
forage developaent within the igpoundaent area. AOreover, under • Permanent
Loss of Habitat, page E-3-287, 1010ose use of the icpoundriJent area prior to
filling is discounted. The need to resolve conflicts between sections of the
4raft application is ~Qply illustrated by the latter two points above. As we
have recowmended elsewhere, sage ~anism should be instituted for resolving
these types of conflicts and analyz1n9 the tradeoffs of mitigating for one
species to the detriaent another.
-Filling and Operation
Paragra~ 2: We again refer you to our coments under Section 4.3(a)(i)
Constru 1on re necessary quantification, study description, and incorporation
of study findings fnto the quantificat i on of losses required under FERC
regulations {Section 4.41(f)(3){ii) in F.R. Vol. 46, No. 219, 13 November
1981) •
• Alteration of Habitat
Upper Susitna Basin: We concur with the points raised here. Please refer to
our colili1ents under Botanical Resources re the ililpacts of fee fog and rfrae ice
forut1on, as to well as need for· quantification. The discussion should also
con1sider the effective loss of an even larger area than described here due to
dust frOCI project activities "'hich would further retard snO\.Welt (see Sec.tion
3.3(a)(1) -Vegetation Oaaage by Wind and ~ust).
Lo~er Susitna Basin: Paragra~tJ 2: Given a mid-successional stage of
ap r.r oxfmately ZS years (see. F gure W4) and project life of 50 years -plus ____ -
pl4nnin~ and development, we question the conclusion that vegetation favored
by QOOSe w111 still be available at the end of the lfcense period. Please
refer to our co-..nts under Section 3.3(a)(i) -E'ffects of Altered Downstream
Flows re quantifying these and other 151pacts described 1n the reu1nde•· of
this section as well as discussing the potential for further alterations of
habitat because of fee fog and rfge ice formation •
• Blockage of t-~vements: Given the potential for goose to avoid clear cut
areas (see discussion under Section 4.3(a)(i) -Construction • Interference
with Seasonal ~1ovements, page E-3-286), we suggest aaapp1ng the effective area
which could be e11g1nated from use. SoQe discussion should be provided on the
likelihood of moose crossing the flowing narrow river as ca.pared to the w1oe
impoundQent, plus drawdown zone; .axfQUg and oinigum widths of the impound;ent
should be provided. Also refer to our coments under Section 4.3{a)( i) •
River Crossings. Inforaation presented here will be 1~portant to later -
considerations re choo~fng sites for habitat enhanceaents which .ay be
undertaken as part of mitigation.
Paragraph 5: Again, please detail ongoing studies •
• Disturbance: Once gore, we note the need to ( 1) cons is tent ly assess the
potential for increased access and hunting; and (2) integrate consideration of
this issue throughout the report. We again suggest 11stiny and analyzing the.
1upacts fr~ alternative access and use options •
• Mortality: See comments under • Disturbance, above, the previous discussion
for SiCt1on 4.3(a)(1) -Construction, and section 4.2(a)(1) • Mortality
Factors. Please define When postulated increases in hunting will occur ·------
relative to project developgent.
-Quantification of Project Effects: We appreciate thfs discussion of ongoing
studies but note that references to this section should be .ade throughout the
report. Once liiOre, we reca.end including a schedule and descrfb1ng how the
studies will be incorporated fnto the license application, project desfgn, and
Glitigat1on planning. Pleue note, references in t.':"'s section are not included
in the bibliography.
-watana: Su.aary of Il!acts: The su..ary is a useful, qualitative
descrfptfon of project lipacts, yet provides no quantification for gfnimal,
moderate, or severe iapacts. The definitions given under Section 4.3 (a)(i)
f·toose: Paragra~h 2, should be restated if they are to apply here. To better
evaluate the 1 fs 1 coaaon to the discussion, we again suggest analyzing an
array of igpact scenarios. Attention should also be given to the cuaulative
fgpacts of habitat loss, alteration, disturbances, etc. Ue disagree with the
conclusion that •because hunting li10rtality can be easily regulated, this wfll
not necessarily be a major igpact.• Because of tho politics involved and
independence frog project developgent of hunting regulations, there is no
guarantee that regulations consistent with project •itigat1on goals will be
igpleranted. Moreover, increasin~ hunter deaands for a d1•inished resource
will further affect haa·vests and hunter satisfa.ction.
(1i) Caribou
-Construction: Paragraph 2: We recaa.nd providing f1yures on the
proportion of the her~1Ch could be affected by borrow areas A, D, and F.
Althou~ these areas will be only taaporar11y used within the SO year project
life, that tegporary use involves several years.
,....;~~~~~~...;;;.;..p;.;.~~~~~ ... 3::.,: Consideration should be ghen to the
Para~Taph 7: ije recgggend also consideriny the COQPounding effect of
predation on ~aribou which biCOQe injured in crossing the reservoir or which
alter their govements due to the presence of the reservoir. Predation was
earlier cited as responsible for up to 30 percent of annual adult mortality
(Section 4.2(a)(ii)).
(iii) Oall Sheep: Paragraph 2: Please clarify the last sentenc~. _
Paragraph 4: Please provide infor~~~tion on when and how seasonal Oall sheep
rarl ~es will be defined and used to influence siting and scheduling of possible
borrow site c.
Paragraph 5: Please document other cases where reaote mineral licks have been
altered to r .. in available to wildlife; we are concerned ·with the unproven
effectiveness of enlarging the area if partial loss of the Jay Creek li1 'ineral
1 ick affects sheep. Thus there is a need to demonstrate the techiques to
ensure that sheep would use the mineral source if one were provided.
-Filling and Operation: The potential for disturbance frog increased
recreational or hunting use in the area should also be covered here.
{ iv) Brown Bear
-Construction: Parafaaph 5: Please de.scribe the scop! ~l!..d schedule of
ongoing studies and pans for inte~ratiny those results into project-designs--
and mitiyat ·:on planning.
Parayr{Ph 6: We are concerned that the discussion downpla.ys th.e importance of
projec ili1pacts frOiil both disturbance and loss Qf .additional food sources.
Original project studiesl!/ and other report~S/ emphasize that
disturbance fror.J project features and associated hUIIIn activiti ~es will cause
~ears to avoid those areas.
Para~aphs 7 through 9: Two other ili1pacts to vegetative food sources should
be a scussid here. Green-up of critical spring food plants may be delayed
because construction-caused dust ~ retard snowmelt on vegetation; at the
saae tilile, herbaceous growth in sUGar aaay be increased (see the Botanical
Resources Section and our comments, Section 3.3(a)(i) -Vegetation Oamag~
Wind and Oust and -Effects of Altered Downstream Flows.
Paragraph 12: We question the statement that, •No geasurable changes in the
number of li10ose or other important prey species are expected.• Previous lack
14/ t1iller, S.D. and D.C. McAllister. 1982. Susitna Hydroelectric Project
Phase. I Fina 1 Report: Big Game, Yo 1. VI -Black Bear and Brown
Bear. Prepared by th,e ADF&G for the PI' A.
Ji! Speric:~r, O.L. and R.J. Hensel. 1980. Envir,,nraental studies of the
proposed Terror Lake Hydroelectric Projec.t, Kodiak Island, Alaska.
Brown bear studies; goun~ain goat studies. AEIOC. Anchoraye,
Alaska too pp.
--------~-
of quantification and the ongoing nature ~~ salmon, moose, and caribou studies
Qlke 1t difficult to fully assess project imp•cts to brown bear. However,
prelicinary indications that up to 2,400 goose will be affected by the project
in the upper Susitna basin alone {Section 4.3(a)(1): Paragra~ 4, page
E-3-280}, and other report findings that •moose populations w 1 probably be
reduced•, (Section 4.3(a)(vi): Parallaph 5, page E-3-312) suggest that there
will be both losses and distribution& shifts fn brown bear prey, wfth
resultant igpacts to brown bear. Brown bear concentrations on already fully
utilized adjacent ranges ~ result in intraspecific conflicts and furthei·
decreases fn brown bear populations (Spencer and Hensel 1980, footnote 15).
-O~ratfon: Parayra~h 1: Our cocan.ts under-Constr.uction apply here too
{Si~1on 4.3(a){1).1ease discuss potential impacts to bears resulting from
fapacts to the salmon resource 1n greater detail.
Para~aph 2: Also refer to our cocaents under ·Section 4.3(c)(1) re tc~! need
to de 1ne access.
Paragra~h 5: Please see our comgents two paragraphs above (Section 4.3(a)(iv)
-Opera ion) on the need to better eval ua.te the fgportance of sa lliiOn to area
bears. Overall, we note the need to quantify impacts and discuss the
cumulative effects of project igpacts on brown bears.
(v) Black bears
-Construct fon: Paragraph 1: As in our c0111111nts under brown bears, above
(Section 4.3(a)(1v)}, we suggest that greater attention be given to fgpacts of
reduced ,prey, compounded here by the significant loss of black bear habitat
with the Watana development.
Paragr%2 2: We question the ability of habitats to the east and west of the
1mpoun nt area to support bears now inhabiting the iapoundQent areas. If
those areas are already fully stocked with black bears, resultant
intraspecific strife and stress would ultigately lead to lower populations.
Para~a~h 3: We again refer you to our comments under brown bear (Section
4.3(a( v)). Please describe ongoing studies and their integration with
project design and mitigation.
(vi) Wolf: Paragra¥h 3: Please refer to our c~nts under Section
4.3(a){x11) re fheikelfhood for wolf populations to decrease and coyote
populations to increase in the project area.
Last Paragraph: Given the increased access expected with project developiOM!nt,
an increased wolf harvest appears likely. ~e reCOIIQind tha.t a quantification
of project impacts should consider the effects of a.n increased harvest on wolf
popula,tion leveh. The clt!JiiJlative impacts of (1) wolves concentrated in a
s~aller area due to distu_rbance, (2 ) effects on territoriality and stress, (3)
relat ive values of igpacted as compared to reaaining habitats, and (4)
red:Jction in pr.:y, should als.o be considered here.
(i x) Beaver : ~· question the certainty of the statagents here, given the
undecided nature of the projec:t water anag .. nt regi•. If reservoir
re l eases are regulated to stabilize downstre111 flows, downstrea& beaver
habitats •Y be enh&nced. However, the extent to ..mfch that enhancaant w111
offset beaver losses in the upper Sus1tna River basin is not provided. SuCh
data fs necessary to evaluate the relative tradeoff 1n altern1the flow
regimes (f.e., for beaver, fish, moose, etc.) and thus the overall magnitude
of project ililpacts.
-Construction: We reca.mend that the location of beaver colonies be
considered, in conjunction with other wildlife values, in siti'i •g borrow area
access roads.
-Ffllfny and ~ration: Parasras:.l: Please quantify •few beavers•
currently suppor id by the igpoun nt area. ·
Para$<Tara 4: Refer to our cOCIIilents under Section 4.3(a)(ix), above; we
recoaae~ using hydrologic data in conjunction with th& revised vegetation
~ps and vegetation succession dynamics to quantify the areas which may be
affected under different flow regir~s. We find soQI inconsistency between the
stateaent here that, •Beaver habitat south of Talkeetna may also be enhanced
as a res,u lt of the increased occurrence of favored food plants (page
E-3-316),• and the statement in Section 4.3(a)(1) that, •few changes are
expected in channel morphology, frequency of flood i ng, or vegetational
succession• (page E-3-289, paragraph 1).
Paragr-aph 5: During the August 1982 W Workshop on the Susttna project,
access w&s considered as much of a li•ittng factor to trapping pressure as was
pelt price. This section justifies our mitiga,t1on recoaaendations under
Section 4.4(b) for alternate access routing, restrictions on use of access
routes, and prohibition of trapp1ny by construction workers.
(x) Muskrat: Parayra~h 1: We find no section correlating to the referenced
section 3.3(a)(1x). tease define ••inor• impacts.
Parayraph 2: Please refer to our previous c01a•nts on quan t ifying
igprov .. nts in downstreu habitats under Section 4.3(fx). Accordingly, we
question the contention that, •Improved downstreag habitat wtll probably
c011pensate for this loss.•
Paragra~h 4: Again, refer to our ca.ments under Section 4.3(ix), re
~1t1gat on of ~rapping igpacts .
(x1) ~ink and Otter
-~stream Effects: We recomaend defining •moderatel y abundant• and
•s stant1a1 igpacts. • Other than lack 1ng quantification, the di'scussion
thoroughly describes potential project icapacts to min~ and otter. Please
s l eri(y the rrtrrens· tg .,,,. 1p eer•er•ph 32
• Oownstre.a Effects: We suggest the discussion be expanded to better explain
the relative r.aagnitude of project irapacts to lilfnk and otter. Sfnce there was
no previous quantification of those populations, we find it difficult to
evaluate the significance of these i~acts.
(xii) Red Fox and Colate: Where hUiilln activities have developed in a
previously undisturb area, coyotes have become abundant while fox nUibers
have decreased (Furbearer StudY Coordinator Phil G1psan, personal
cCXIilunication). For exa~~ple, fn the Cantwell ·to Healy corridor there has been
1 a.rked increase in coyotes with increasing nUIDers of people and area
developments. Researchers believe there has been a corresponding decrease fn
both fox and wolf n.eers, although both those species pass through the area
from undisturbed hlbft&ts fn the adjacent Denali National Park.
Per our c~nts on other furbearers, quantification of relative area
populations, habitat quality, and trapper d.-and and harvest is necessary to
fully evaluate project flilplcts.
(xiif) Other Furbearers: Again, quantification is needed re base line
populations, hibitat qua tfty, and use, in order to ful' ly evaluate project
ir.ap&Ct$.
Para~aph 3: ~'.!te should be rade of the previous year·s' trapping activity
whfc ~ay be responsible for low trapping success of pine rarten near Wat.ana
Creek (Furbearer Study Coordinator Phfl Gipson, personal COIID.Inication).
Par&!fr&Kh 4: We suggest considering additional paraaeters for evaluating pfne
rarten ib1tat quality (e.g. the. av·aillbil1ty of berries fs f11portant as la.te
sugper/fall food) fn conjunction with re.apped vegetation types to reevaluate
i&~pact estimtes •
. Paragr~h 6: Lie question the extent to which snowshoe hare habitat. IDlY be
igprov by revegetation of disturbed areas, given the auch larger ~unt of
habit1t which will be destroyed by the project and h1storically low hare
populations in the. basin.
Paras;:aph 8 : No correlation fs ude between •r.JOderate• levels of disturbance
fro. ogg1ng and diff erent levels of dfsturbance from the project re the
applfcabflity of these references to project f11pac:ts.
(xfv) Raptors and Raven
• Habitat Loss: Parasuaphs 2 and 5: Please refer to our comaents under
section 4.3(a}(xiv} • 1sfur6Jnce, below concerning the takfng of eagle nests.
Para~aph 4: In order to understand the relative magnitude of project
igpa~s. we recoaaend discussing the estigated loss of golden eagles in terms
of project area populations and habitat values.
Parafaaph 5: Please clarify the statment that potential downstream nesting
hi61 ats aay becoge gore 1gportant as upstreag h bitats are lost wi th project
development. Uhether downstrellil habit:sts are t J 1iy ut 1lized, their value
compared to upper basin habitats, and potential disturbances froa other
project activities should be described.
Para~aph 9: Please clarify whether downstre151 raven habitats could absorb
use y ravens displaced frog upstreag habitats.
Para~raph 10: The blowdown of trees near cleared areas represents an
iddi ional source of habitat loss (e.g. see Section 3.3(a)(i) -Vegetation
Daaage by Wind and Dust).
3: We recOIIilend desa i b 1 ng the over& 11 illlp&cts of ~e=.;.pr.;;.o~e~;.:;;o.;.n_s..;.a-.I:IO~n~an~~other fish wn ich serve as bald eagle food. Such
consideration should include potential i.,acts to s-elt runs near the aouth of
the Susitna River. Any impacts to these resources could affect eagles nov
depending on thea as food.
~&ph 4: We question the significance of any ca.pensat1on for lost eagle
Tiidlng-nib1tat through attraction of waterfowl to the impoundgent. Please
quantify the potential for such coapensation and/or provide an explanation of
why waterfowl aay be attracted to the reservoir without a concogftant inaease
fn their food sources (also see our c01aent under Section 4.3(a)(xv) .
~aterbirds, below).
-Disturbance: Paragraph 1: We appreciate the description of protection
affordid eagles under the Bald Eagle Protection Act (16 U.S.C. 668-668c).
·However we are concerned that the intent of this act relative to project
design has not been adequately acknowledged or incorporated, as explained
below. -
Para¥riaph 6: Under a recent ar.Jendment to the Bald Eagle Act, the Secretary of
the nterfor ~Y pergit the taking of golden eagle nests which interfere with
resource c11velopaent or reco~ery operations (16 u.s.c. 668a). Regulations for
implegenting this agendment should be available within the next couple of
GaOnths.
Paragraph 7: The Bald Eagle Protection Act does not authorize the taking of
bald eagle nests whfch interfere with resource developaent or recovery
operations. The Act does prov ·ide for the taking of nests for scientific and
certain specific exhibition purposes when compatible with the preservation of
this species. Service eagle pergit regulations, 50 C.F.R. 22.21, implement
this section of the Act. Secretarial approval 1s not required for the taking
of bald eagle nests in Alaska provided no eagles are killed and the nest fs
not exported froa the United States. Autl'IOI"ity to take sudt nests has been
delegated to the FWS Regional Director. Ue suggest that the applicant
prCiilptly consult with the M to reach a •tually satisfactory solution to
this potential conflict.
(xv) ~at•rbirds
Para a 2: Please substantiate that •fish ~po~p~u~ar-r.:o~n~s""':-w~~p~r~or-="l:~y~r~s~M~n~sufficient• to support birds such as
meryansers. According to l~ting Summary notes frog the 2 December 1982,
Susitna Hydro Exhibit E Workshop on water Use and Quality and Fishery
Resources, liiOSt of the grayling population (estiuted to be at least 10,000 in
Section 2.3(a)(1i) -~tana Reservoir Inundation) wilt be lost and any
production of lake trout fs expecte1 to be 1i~ited.
Paragraph 3: ue suggest quantifying the nu.ber of lakes, mi1es of stre~s,
and acres of wetlands (per revised wetlands typing) whfch may be affected by
project borrow areas, spoils sites, etc., as well as those which will be
cocapletely lost. ~e reca.end including those habitat typel 1n Table W78a.
This 1nforQition will allow better quantification of project igpacts.
Paragra~ 4: Please substantiate further the value of the reservoir as
hibttat or afgrating birds. Sfnce existing resident fish populations are
expected to be severely f~cted by reservoir developgent and no biolo~~cally
productive neai·$hore zone will be developed, we question that there would be
food necessary to support birds attract4d to the reservoir. ~oreover, winter
open water areas could attract waterbirds to their detriment, particularly
since food supplies are already limited. Swans attracted to open water at Red
Rodes Lake Nat1ona 1 Wildlife Re.fuge fn Montana wst now be fed during winter·;
similar problegs have occurred in other areas of the conterginus United States
(F\lS Migratory Bird f·lanager.nt Project leader Rod King, prsonal
cOIIIIUn i cat ion ) •
-~isturbance: Paragraph Z: We suggest that greater lllphasis be placed on
the potential for the project to disturb trumpeter swans. Recent increases
and overstocking of swans in the Gulkana Basin lillY result in li1Dre swans IIIDVing
into the upper Susitna Basin (FWS f.Ugratory Bird ~lanagelilent Leader Rod King,
personal COIIi'IJn~':ation). Yet those habitats wilT become less suitable with
the huun actfvfties and disturbances cause by the projec.t. As areas in the
Cook Inlet Basin and Kenai Peninsula have been affected by huraan use and
~:v:~~~J!;swan use of those areas has shifted to areas larg~ly inaccessible
(xvi) Other Birds
-Construction
• Habitat Loss: We appreciate the thorough, quantitative discussion included
here •
• Habitat Alteration: We sug9est that species and their relative abundance be
correlated to the postulated negative and positive ef·fects of habitat
alteration. Thfs would provide sa. indication of net project 111Pacts. toss
to the Uatana igpoundment of existing natural edge, e.g. rivers, ridgetops,
etc., will undoubtedly be far greater than the increases in edge suggested
here.
-O~at1on: We question whether any feeding habitat for spring migrant
shor1rds will be created in the drawdown zone. The reservoir drawdown zone
will remain an unvegetated gudflat. If current low bird populations indicate
lack. of hfyh quality habitat, it stills doubtful that food organisms would
suddenly proliferate with reservoir developgent.
16/ King, J.G. and B. Conant. 1981. The 1980 census of trumpeter swans on
Alaskan nesting habitats. Agerican Birds 35(5): 789-793.
( xvii) r4on-g~~t~e (saa 11) Malza 1s: For Sill 11 e~~~:~~~~l species wh fch inhab ft
1dent1t1able vegetat1on types, we suggest describfny whether the percent of
the habitat to be lost fs proportionately ~eater or less than the occurrence
of the type within the entire basin.
(b) Dev i 1 Canyon De vel opg !!
(f) Moose: Converting the nUiber of goose in the Devil Canyon fapoundGent to
.-ainiltY figure and then ca.paring that to a si11ilar figure for ~~~ Watana
f~oundment ~uld allow a better qua~titatfve ca.parison of impacts. ~ are
concerned w1th the judgeaental nature of the discussion in stating that
i~~pacts •are of less concern• and suggest that, -will be of SMller •gnitude•
might fgprove the stateaent (pge E-3-338). The sgaller area of the Devil
Canyon as c011pared to watana, area should also be •ntfoned, although we do
note 1:1\at riJOOse density here is about half that of the W&tana area. An
evaluation of relative habitat values of the adjacent areas which will be less
directly 1Qpacted, and any lands proposed for acquisition or enhanc-nt, 1s
necessary for a complete f~~pact and llftfgatfo·n anaysis.
-Construction: Again, spoils disposal is an additional f~~p~ct which should
be descr ibid •
• Habitat Loss: Our eo;aents under this heading (Section 4.3(a)(i)), for the
Watana development also apply here •
• Interference with Movements: The discussion should consider whether a 1.6
ki crossing would also be a barrier to CIDo .se in that area or li10ose diverted
frOII upstreua crossings because, of the Watana iiiiPoundlilent. Quantfffcat ion
should also be provided of the additional distances which •ight have to be
trlveled and consideration given to additional energy expenditures relative to
foraye quality should .aose alter their mov ... nt patterns. Also refer to our
coggents under this heading, Section 4.3{a)(f), for the Watana developgent •
• Disturbance: Please refer to our comments under this heading, Sect i on
4.3(a}(1), f~r the Wlt &na development.
-f.1ortalfty: As above, our previous cOiilillnts under Section 4 .z (a)( i)
• MOrality Factors; 4.3(a)(f) -~flling and Operation, • Disturbance; and
4.3(c}(i) -MOrtality apply.
-Fflltnv and Operation
• Alteration of Habitat: Please refer to our c011ents under this heading,
section 4.3(a)(1), for the Watana development. ~e are concerned that
increased water te.perature could result fn a larger area being affected by
fee fog and rfge ice formation, also see our coaaents ynder Section
3.3(a}(f). We again reca.aend quantifying several impact scenarios re
successional vegetation ~1nges fro. any of the f~acts discussed here •
• Interference with r~vements: By reducing browse availability due to r;~
ice formation, the presence of fee fog could be a compounding impact to moose.
Moose ;oveaents .. Y already be fnhfbfted because of greater visual exposure to
predator~ fn tht vicinity of the reservoir. Ue refer yoa to our cOWDents
nt·z et· "·tan ts: nh • '& 01 1
" )(¥ PtZ' I I a
2 2
• Disturbance: Again, our comgents for ~atana (Section 4.3(a)(i)) apply •
• f·1ortality: Please refer to our previous coCJJents on hunting (Sect i on
4.Z(a)(1) • nortality Factors, and Disturbance and f4ortalfty discussions under
Section 4.J(a)(i)) •
• Devil Canyon: SUio&lary of Ii¥acts: As we cOI:IiJe.Jted on the ~atana impacts
sugmary, quantification and b~ter definition of impacts 1s needed here. Ue
are also concerned about inattention to cuaulative impacts. While habitat
alterations, disturbance, or blockage of movegents m&Y each be a •minimal•
i1e1pact, together they -.y be sufficient to severely stress nmose or reduce.
moose use of the project and adjacent areas.
i f ) Caribou: Oe.ffnitions for the qualitative terms used here should be
prov e.g. •Tittle use•).
(iv) Brown Bears: Lack uf quantificati·on here, as in Section 4.3(a)(iv)
preclUdes evaluating even relative impacts frOD each aajor project feature.
(v) Black Bears: As in Section 4.3(b)(1v) above, lack of quantification
prevents a thorough analysis. Consideration should be given to the c~lative
effects of disturbances, loss of habitat, decrease in habitat value, and
increased gortalfty frog hugan/bear conflicts from the Devil Canyon
developgent in conjunction with the ~atana development.
lvi) Wolf: Please refer to our comaents under Section 4.3(a)(vi) re the
mportance of disturbance and cumulative fli1pacts.
(ix) Beaver: Refer to our COiilments under Section 4.3(a)(ix) re the need to
quantify the amount and quality of downstream habitat fgpr~vegents which could
offset upstre111 hab-itat losses and the dependence of any habitat improve.ent
on the operating flow regime. We s 'Jgest describ iny impacts under a variety
of potential flow regimes.
(x) ~~skrat: Please refer to our previous comments under Sections 4.2(b)(1i)
and 4.3(a)(ix) -Fi11in¥rand Operation re quantifying and controlling
petential increases fn apping.
(xi) Mink and Otter: Again, we recomaend providing soae quantification,
de¥1n1t1on, or relative correlation uong species and project areas for the
qualitative impact descriptions.
(vii) Coyote and Red Fox.: We would expect an increase in coyo.tes per our
previous cogments (Section 4 .3(a)(xii)).
(xiii) Other Terrestrial Furbearers: Our coaaents under Section 4.3(a)(xi11)
apply here too.
{xiv) R~ptors and Ravens
-Construction and Filling
• Habitat Loss: Paragraph 1: Refer to our comments under Section 4.3(a)(xiv)
-Disturbance.
Paragra~h 2: Should any eagle build a nest, between now and filling of revfl
Canyoneservoir, which would subse,quently be lost in construct i on and/or ·
filling of Devil Canyon, please refer to our comaents under Section
4.3(a)(x1v) -Disturbance.
Paragraph 3: Please clar,ify what is meant by the first' sentence.
Para~a~n 4 : Please refer to our comments under Sect fon 4.2(c)(i) re the
diff\Cu ties fn locating goshawk nests.
Paragraph 5: Please clarify the d fscussion and consider whether the clfffs
and trees Which ray increase i n nesting i111portance are as suitable as ufst'fng
nest habitats •
• Disturbance: Paragra'h 1: Again, please refer to our colilillnts under
Section 4.3(a)(xiv) - D sturbance.
Paragra~h 2: See our c0111i1ents under Se.ction 4.3 (b) (xiv) this section, ~abitat
Loss: arayy:aph 2, above.
(xv) Waterbirds: Please refer to our' cOGIIIents under Section 4.3(a)(~v) as to
the questionable value of the reservoir area, f .e . yenerally birds wiTT not
appear in the ar-ea any earlier; birds which remain in the area longer ~Y have
problegs fi nding food when encountering frozen waterbod1es once they do leave;
no data has been provided re any supplemental food value in the reservoir area.
(xvi) Other Birds: Paragraph 2: Please clarify the last sentence .
Paragraph 3: Please quantify the extent to which open water in the rt!sm-voir
will c011p1nsate for Toss of dipper breeding habitat· and describe what fet!dfng
habitat would be avaflable in the rese-rvoir.
( xv fi ) r~on-gue ( Slill11 ) Mali1a 1 s: P 1 ease refer to our caa.ents under Sect 1 on
4 .J (a}( XV i) •
(c) Access
(1) r-toose: The qualftative, general clfscussion precludes any definitive
analysis of potential impacts. We suggest quantifying current and potent i al
hunter demand and harvests, area lilOose populations and habitat quality for
access route areas. Varying deyrees of winter severity and the length of each
access link should then be considered in conjunction w ~th the inforgation
described above and data on vehicle/goose collisions i n other areas of the
state to assess the potential for railroad or autogobile collisions with aa~se.
Since access is a key feature to any •itigation plan for the project, we agtin
recomcend evaluating the range of iQpacts which would result froa a variety of
access/use options and coordinating this with the Socioeconogics and
Recreation Chapters. Please refer to our 17 Augus t 1982 l etter to Eric You ~d
re access alternatives; our coL~nts there remain appl1cable.
Please correct internal inconsistencies in this paragraph: loss and
alteration of habitat, disturbance, and cortality are certain, not •possible•,
impacts as verified in subsequent portions of this section (page E-3-350).
naps of proposed access routes should also be included.
-r~rtality: Paragraph 2: Before discussing impacts from access, please
specify any public access and hunter take restrictions assURed to be in effect
for planning, construction, and operation phases of the project. Impacts will
vary from severe with no restrictions to miniaal with strong restrictions on
access. In this respect, we find Chapter 3 confusing. The potential i.,acts
frog pubiic access and huntiny along project access routes are discussed here
and then the suggestion is gade that these i.,acts will be minimized by
prohibitin5 worker access and hunting, yet the chapter never consistently
describes what restrictions actually will apply. Project igpacts, such as
h~itat degradation and population disturbance associated with increased
access, could be further minigized by controlling public access {through
restrictions on ORVs, seasons or times of day of use, etc.).
Please substantiate the conclusion here that •carefully aanaged hunting may
effectively Gitigate for some indirect project effects.• ~e iapact of
diminished hunter opportunities is not fully described here or 1n Chapter 5
(see our comments there, Section 3.7{b)(ii) -Impacts on the Hunter).
Paragra~ 4: Please define use of the terms •small• and •negligible.• During
severe winters, moose may seek cleared roadways as travel corridors and be
subject to collisions. Since the Denali Highway is not kept open during the
winter, it is not possible to fully compare the collisions on that road with
the potential for collisions on project access roads. However, we suggest
that a better understanding of the subject could be gained with information as
described under Section 4.3(c)(i), above. Ue also note that if workers are
allowed to commute to the project site or have free access in and out of the
project area, the volumes of road traffic would be significantly higher. The
analysis should be coordinated w1th that in Chapter 5. Consideration should
be given to the times of year and day for recorded collisions and utilized in
scheduling access if patterns exist in that inforgation.
Parayra:a 5: Please describe current railroad use as compared with the
project idditional aight round train trips each week. We believe that
project railroad use QlY be a significant impacts to wildlife in view of
present winter use of four round trips each week.
The length of additional track, as well as existing track, should also be
yiven for comparison with the mortality fiyures given here. Information on
uoose densities and habitat values in the area of the new as cogpared to
existing railroad would also be helpful in quantifying potential impacts, as
described above. Ue are concerned that in severe winters the loss of winter
range gay be co~pounded by the potential for nuaerous vehicle/moose collisions •
• Loss of Habitat: Ue concur with the analysis but suggest soge
quantification be made of areas and vegetation types which could become
unuseable in a worst case scenario where disturbance causes goose to avoid
usin~ the road corridor area •
• Interference with Seasonal t~vegents: With respect to the seasonal
gfgratfons descr1bid heTe, please refer to our· CCDlents under Section
4. 3 (c) ( i ) -r.Jorta 11 t~, re the cggpounded potentia 1 for even greater nUii1bers of
vehicle/AOose collfs1ons.
(ii) C•ribou: Para a 1: We reiter•~• ~ur recoa;end&tion to eliQinate the
Denall way o a na access route (also se~ Section 3.4(c)(ii)) which, as
documented here, is •likely to have a substantial effect on caribou QOVeGents.•
P·aragr9Kh 6: Please provide substantiating data for the juds-nt that
althou cows calving in the area .ay avoid the road, there will not be an
effect on herd productivity. \le recOGID&nd quantifying the portion of the herd
vtilizing this area.
Para~aph 7: Please prov·ide further infonation on tiEs of day or seasonal
va.rfafons expected for truck traffic. An additfona 1 concern fn considering
the potential severity of access-related impacts is the question of wor~er
access. If project workers are all housed on site, the intensity of road ~se
will still be greater than described here; workers traveling to and from the
site at the beginning and end of their times off represent a subs.tantial road,
or even airstrip, use. Moreover, if workers are allowed to individually
coGJDute, or even if buses are used on a daily or weekly bas is, road use will
be even gore sfgn1ficant.
Para~aeh 9: Our previous coggents on herd manageCJent apply (Section
4.2(~(11)). \le recoamend quantifying 1gpacts described throughout this
section.
(iii} Oall Sheep: Paragraph 1: The issue of disturbance frog air access to
the project should be covered here; as described in Section 4.3(a)(1i1).
Please provide infonoaation on the expected intensity of aircraft use for the
period of construction.
Para~a~ Z: Consideration should be given to increased recreation and other
activ t es which li1IY cogpound habitat loss iapacts near the critical Jay Creek
~;~ineral lfck. Please restate those igpacts as described in Section
4.3 (a}( iii).
( iv) Brown Bears: We concur with the a.ssessgent but recoaaend that
quantification of igpacts be provided.
(vi) Wolf: Our previous coaaents under Section 4.J(a}(v1) apply.
(vii) Uolverine: Paragra~h 2: 1uantifiC6"ion of trapping effort and potential
increases relative to wo verine populations should be given. Please justify
the inference that egigration from other areas will ~itigate for ioss of
wolverfne to trappers yet not affect overall populations.
(viii} Furbearers: In general, we find the discussion soaewhat inconsistent
with other sections, with no clear objectives outlined for ~itigation (see
parayraphs 2,8, and 9 of this section}. Please also refer to our coagents on
the socioeconomics (Chapter 5, Section 3.7(c}(i) -Impacts of the Proiect}
and our recomgendations under the wildlife mitigation plan (section 4. (b)).
~e recommend you then ensure these sections are consistent with each other and
with overall project objectives and mitigation goals. Specific coaments
follow.
Paragraph 1: Please provide further data to substantiate the conclusion that
pine lillrten ho.a ranges ray b8(0iill realigned along the access roa.d. Although
we appreciate the thorough discussion of potential projec.t iiiPacts, we are
concerned that repeated lack of quantification makes if difficult to assess
the re 1 at 1ve i111portance of such •minor• i111pacts as compared to the 1110re severe
iQpacts of direct habitat losses i!ind increased trapping 1:10rta lfty.
Paragraph 5: The welt-docu.ented likelihood of beavers using bridges and
culverts for dusites G10re probably represents further negative impacts to
beaver than a source of habitat improvement. Beaver use of those structures
would conflict with project access, undoubtedly resulting in road maintenance
to ree10ve. beaver dams. If that reooval occurs at the wrong time of year, i.e.
autur.m, beaver in the area J'ii&Y be effectively eliminated (Furbearer Study
Coordinator Phil Gipson, personal comgunication).
Paragraph 9: ~e are concerned with use of the word •desirable.• Thus we .
suggest modifyiny the last sentence to say that to date, trapping pressure on
mink and otter has been low in this part of Alaska (Furbearer Study
Coordinator Phil Gipson, personal communication).
(ix) Raptors and Ravens
-Denali Highway to Watana Damsite: Paragraph 1: We recomaend describing how
this area was surveyed.
Parayaaph 2: Our comgents under Section 4.3(a)(xiv) -Disturbance would apply
shou golden eagles subsequently nest along the access road.
Par,\gra~h 3: Refer to our coaaents under Section 4.3(a) (xiv) -Disturbances
re the 11 ega 11 ty of destroy i ug a ba 1 d eag 1 e nest.
-Watana Dam Site to Devil Canyon Dam Site
• Disturbance: We again refer to you to our comgents under Section
4.3(a)(xiv} -Disturbance.
-Devil Canyon Dam Sfte to Gold Creek
• Disturbance: We recoGDend that the conclusions of minir.1al disturbance· here,
be con~istent with those in Table W76 which says that •construction and
operation activities r.liY result in considerable disturbances.• If the nest is
active, we will recor.waend tiJ:Jing constraints on the construction activities
near it (see Section 4.4(c)(i)).
(d ) TransCJission Lines As with the previous Section 4,.3, (c) Access, the
severity of 1~acts froa the transmission Tines will depend on restrictions on
access (e.g. by siting, access to the lines, and/or access along the lines) as
well as the gethods of construction and .aintenance (e.g. helicopter, winter,
and/or onground). Please clarify what methods and schedule for construction
and maintenance will be utilized and what restrictions, if any will be placed
on access; we find the Exhibit E inconsistent on these points. The reference
here is to helicopter and winter construction and only selective clearing of
vegetation; in Chapter 5, reference is made to increased hunter access along
the lines which infer greater clearing and road access (Section 3.7 (c)( 1) •
Impacts of the Protect). Increased snowmobile and ORV access and their -
disturbance atonghe tran~1ssion corridors should also be addressed here.
Our COiiliJents under (Section 4.3(c)) Access on the need to quantify expected
additional harvests also apply here.
Please refer to our trans•ission corridor cougents under Botanical Resources,
Sections 3 .3(d) and 3.4(d). We refer you to our 5 Jan~ary 1982 revf~ tetter
on the 9 Noveaber 1981 Transgissfon Corridor Report. Our coggents there
reaain applicable. In particular, we recoamend incorporating into project
plans: (1) an-y-round evaluations with representatives of the FWS, ADF&G, and
the Alaska Plant Materials Center regarding the appropriate managegent along
various lengths of the transe~ission lines (e.g. the extent of clearing,
maintenance, possib 1 e seeding. etc. should depend on the wildlife species of
concern and vegetation types present; (2} coordinated access to the
transGJis ,sion lines with access to other project facilities; (3) controls on
public access to the transmission lines during and post-construction to reduce
habitat degradation and population disturbances; and (4) controls on access
along the length of the lines. We would appreciate your response where
project plans QIY be in conflict with either these points or the five specific
rec0Gii1endations in our January let.ter.
~e are concerned with the generality and lack of quantification of this
section. Using the vegetation reupping, a successional •del should be
applied; the selective clear·ing and 1i111ntenance to be used along the
transmission lines should be factored fnto that model. Areas within each type
to be ililpacted and vegetation type changes over the project life can then be
calculated. ~~ps of the proposed tran~ission line corridors should also be
provided.
lj) Bf!.t Game
-Coo~ Inlet to ~i1 1 ow: Paragraph 1: Again, the degree of impact will depend
on-tn~ type of clearing and gaintenance and thus, habitat alterations which
result. ~e have recommended selective clearing, winter and helicopter
construction and Qlintenance and controlled access along the line.
~~intenance should involve selective clearing and topping of trees and tall
shrubs to help ~aintain increased forage production .. Ue agree that
transe~ission line clearing ray· increase goose and black bear carrying
c'pacf ties if vegetation types which can be enhanced are present along the
line. Thus we recoagend quantifying the types present and their value to big
gar.~e.
Paraeeaph z: Please describe the presence or absence of c:oose calving grounds
and ear dennfng sites. The CWiNlative fgpacts of the tranSiilissfon lines in
conjunction with existing disturbances should be discussed.
-Healy to Fairbanks: Again, quantification of types to be impacted and
successional Changes over the project life should be provided.
-~illow to Healy: Please refer to our 5 January 1982 letter regarding the
dependence of the Susitna project on the Intertie. Thus, we recogmend full
consideration of impacts from the Intertfe within this analysis.
Quantification of impacts is needed, as above.
-~atana Dag to the Intertie: Please provide a quantification of impacts,, as
ibove.
(ii) Furbearers: Parar;aph 3: Please refer to our comaents under Section
4.3(c)(v11i) re fncons~tenciel be · ~een Chapters 3 and 5 in presenting
impacts. ~e are also concerned with inconsistencies between the increased
access acknowledged here and ~:~itiga.tion guidelines to prohibit such access
(Appendix EE, iteGI 1); please clarify. Our previous recOGmendations to
quantify impacts apply here too.
(iff) Birds: Paragraph 1: ~e recogmend providing references for the broad
conclusion that species diversity aay increase near the transmission lines.
Removal of nest and forage trees will decrease available habitat for species
such as pine grosbeak and boreal chickadee.
Parag}a~h 2: We concur. Please also refer to our caggents under Section
4.2(c ( ) re continuing peregrine falcon surveys.
Parawra~h 4: Powerlines are particularly deadly to swans.16/ However,
r~rta11 y frog collisions, not electrocution, is the gajor adverse impact to
swans. Locating and marking lines is the key to mini~fzing that igpact (see
our co~Jents under Section 4.4(c).
We recor.EJend expanding this discussion to describe: (1} the potential for
swan collisions; (2) mi~Tatfons of sw·ans throuyh the project area; and (3)
swan use of rer.10te lakes, including those 1n the natanuska-Susitna Valley, for
nesting and rearing. Refer also to our c011:1ents on increasing developments
and disturbances which have caused swans to abandon areas, Section 4.3(a}(xv)
-Disturbance, and our 5 January 1982 letter to Eric Yould, as above.
(e) Iepact Sugmary
We are concerned with the emphasis of this suaar·y on impacts which can be
most easily mitigated. Consideration should also be given to documenting
unavoidable, adverse iQpacts, cumulative project impacts, and differences
between long v~rsus short-term impacts. The uncertainty if predicting proJect
1r.rpacts on the basis of existing inforaation are clearly apparent here.
18/ Avery, H.E., P.F. Springer, and n.s. Dailey ~ 1980. Avian mortality at
man-made structures: an annotated bibliography (revised). U.S.
Departcent of the Interior, FWS/OBS-80/54.
Paragra~ z: We c~ncur that increased human use 1s positive, but the habitat
alterat on and disturbance which may also result from increased access are
often a significant negative igpact to wildlife populations. There is a need
to integrate this discussion with those in the Socioeconogic and Recreation
Chapters of the Exhibit.
Para~a¥h 3: We recoggend also considering habitat values and how they relate
tow a ife populations over the life of the project.
( i) Big Game: Paragraph 1: As above, the increased access afforded to
hunters 1s GlOre of a concern from the standpoint of resultant population
disturbances and habitat alterations; assuming that harvest is regulated to
protect population levels.
Paragra~ 3: We are concerned with the subjectivity of the first sentence
here. ease provide quantitative data for cogparison with the previous
paragraph to justify the relative magnitude of project igpacts.
Mention should also be made that project impacts will be particularly critical
during years of severe winter. During such years., an additional igpact to be
considered would be goose/vehicle collisions. Cuaulative igpacts are also of
concern with moose.
Parayraph 4: Inability to predict major iLJpact on caribou, as cited here, is
a ser1ous data gap. Ue recowmend describing additional inforgation to be
gathered to help ~:~~ke such predictions . Best and worst case irJpact scenarios
should be described to provide at least an indication of ~~w caribou could
suffer frog increased disturbance, impacts near calvin~ areas, and alterations
in seasonal mov~nts.
Paragraph 6: Again, cuwlative igpacts are a concern in evlluatin9 overall
project impacts to both brown and black bear.
Para~a~h 7: Disturbance from increased access and the presence of hucan
activt es should be the more direct concern here (please see our cor.nents
und~ Section 4.3(a)(vi)).
{ii) Furbearers: Paragraph 1: We again note the potential for red fox
populations to decrease as coyote populations increase {please see our
cOiiiDints under Section 4.3(a)(xiii).
Parafoaph z: We suggest clarifying these conclusions to be consistent with
prev ous impact descriptions, e.g. Section 4.3(a)(ix), paragraph 1, page
E-3-315, says beaver populations are likely to increase, this paragraph says
they •may increase,• downstreag (page E-3-371). Ue again reco~nd describing
the water management regiges under which furbearer populations will ~st
likel y benef ·it. Overa 11, we are concerned with the uncertainties expressed in
this discussion and re.coGJJend that additional furbearer work to satisfy these
uncertainties be considered (e.g. we suggest focusing on beaver and pine
marten per our co~nts under Section 4.4(b)). Since i~pacts to valuable
habitat in the vicinity of Deadman Creek can be mitigated, .by alternative road
siting, they should .be described here.
(iii} Birds: ~e recoggend also describing the negative impacts from swan
collisions and raptor electroc\ltion with transril1ssion line developsaent.
Similarly, disturbance to nestiny swans and raptors is another negative impact
which should influence aitigatfon planning.
4.4 ~1itigation Plan: As was the mitfgat,ion plan for Botanical Resources, we
find the aitigation plan for wildlife incomplete and too general. Our
detailed colii:Jents on lack of quantification, lack of integration with other
resources evaluated, and need to consider the full range of mitigation options
possible should be considered he·re as well (see Section 3.4).
Because the wildlife analysis is much more qualitative than quantitative, we
commonly found the egphasfs on minor iapacts rather than on uajor ones. A
sic1ilar 1t1iseaphasis is fn the gitigation plan, where attention is often
focused on small, gore easily mitigated impacts. Alternatively, severe
impacts are left to undefined and uncertain gitigation measures such as later
habitat enhance;ent and/or lana~ acquisition. Please refer to our earlier
comments on the need to clarify overall project mitigation objectives (Section
4.1).
This section should clearly explain why ~itigation measures already
recOGaended by FWS and other resource agencies have not been adopted. For
example, neyative impacts to wildlife from the Denali Highway to Uatana
developGent access route are consistently docugented throughout the report:
the road will result 1n substantial disturbanc e~; the Deadman Creek area
paralleling the road is particularly igportant habitat to nUQirous wildlife
species (e .• g. calviny GJOose, Section 4.2(a)(i}-Distribution. S~ecial Use
Areas: Calvin ~reas: Para a h 2; brown bear denning, section 4. {a) (1v) -
ons uc on: aragrap ; car ou govegents, Section 4.3(c)(ii}; wolf
dennfng, section 4.3 (c){vf); valuable beaver habitat, Section 4.3(c}{viii};
bald eagle nesting, Section 4.3 (c)( ix), etc.). f·litigation of these ir.1pacts
can be effectively accomplished by completely avoiding the impact, that is,
alternative siting as recommended in our 17 August 1982 letter to Eric Yould
and further detailed in our comments on t:he Botanical Resources &litigation
plan, Section 3.4(c}{ii).
We also request that you (1) confirm the inclusion of recor.~:~ended r.~easures in
project design, and (2) clarify the extent of public access and uses in the
project area throughout planning, construction, and operation of the project.
For example., please specify the extent to which the environmental guidelines
in Appendices EA to £E have and will be guaranteed in project design and
operation.
Establish~ae·nt of a raonitoring and follow-up program for all phases of project
construction and operation is an essential feature of the mitigation plan..
Key couponents of this progr1r.1 are that it: (1) include appropriate Federal,
State, and local ayency participation; (2) be fully supported by project
funding; and (3) be utilized to r.10dify, delete, or add to the mitigation p~dn
in response to both information fr~ ongoin~ studies aod needs which becor.1e
apparent as project iupacts are realized. ~hile r.10nitoring by itself is not
mitigation, actions taken as a result of that uonitor1ng c~n ensure the
effectiveness of the implemented mitigation pl~n.
-71-
Our final general recOI'IIIendation on the 13itigation plan is that continuing
consultation between the license applicant and resource agencies include
initiation of working sessions with project design engineers to fully
incorporate wildlife gitigation plans.
(a) Big G1111
(i) t»ose: Para¥ia~ 3: ~e concur with the processes now being used to
quantify pr06ab\lijpacts of habitat loss and to develop selection criteria
for replacegent lands. Our previously described concerns for the need to
evaluate habitat values are. of pa_rt1cular note here; habitat qualfty ;aust be a
factor in quantifying the areas of specific land parcels which are to be
enhanced or acquired as mit1yat1on. A schedule for the availability and
incorporation of this data into project plans is also needed. Some assessgent
should be made of the locations and potential sizes of such areas.
ParagraS 5: Further details should be provided on the schedule, potential
size, h itat types, and studies, wmfch would be involved in the Alphabet
Hills burn. Land ownership, vegetation types, and other constraints to the
potential value of burning or other ~nfpulations to enhance habitat should
also be described.
Para~aph 6: Please clarify the criteria to be used in replacegent land
sele~ion. ~e caution that replace~:Jent lands only contribute to offsetting
unavoidable habitat qua 1 ity losses elsewhere when: (a) habitat value of the.
replace.ent land would be degraded by soge predictable means other than the
project during the life of the project but, through management for fish and
wildlife that de.gradation could be prevented; or {b) replacement liands are
currently degraded and through management for fish and wildlife, productivity
could be increased over the fife of the project; or (c) through management of
fish and wildlife, the productivity of an existing natural unit of habitat
could be increased by reducing or eliminating one or more factors lie~iting its
productivity. Identified replaceaent lands caust be a manageable unit.
Para¥daC: 7: To raint.ain the increased value of ~anaged habitat, prov·fsions
shou e included for ongoing ganagegent of th~ until such tige as the
project area is returned to the pre-project state.
Para~aph 8: The raximum design speed of 40 miles per hour referred to in
Appe~ix EC, item 1, should be assured here as one means of minimizing the
potential for goose/vehicle collfs1ons.
Parayraph 9: ~e strongly support the proposa 1 Env1ronr.Jenta 1 Briefings Pro~Taa
and recommend that it be a gandatory requirement for all project personnel
before they begin work on the project.
Paragraph 10: Assistance from PPA in regulating access should also be for the
purposes of ginimizing habitat degradation and unnecessary disturbances.
(ii) Caribou: Provisions to QOnftor and regove logs and other debris frorn the
;~oundiients should be included 1n the overall project 1110nitorin9 prograc,
this will ensure that such debris does not ·inhibit caribou QOVeGients (see
Section 4.3(a)(ii) -Filling and Operation, paragraph 9).
-72-
(iii) Dall Shee~: Please describe how the prohibition on visits to the Jay
Creik li1inera1 1 ck is to be enforced. We reca.Jend tha.t the portion of the
reservoir adjacent to the lick be closed to boat and flo•tplane use. We
suyge,st that the effect ivene.ss O·f any lileasures to expose new port fr.ns of the
mineral lick be degonstrated and then incorporated into the aitigation plan if
effective.
( iv) Brown and Black Bear: Para 1 2: We strongly concur with
recOiililen a ons o pror.ap y nc nera e garbage and fence caaps. Experience
fr01:1 other projects (e.g. Terror Lake hydroelectric project) shows the need to
clearly siyn and monitor gate closures to Rinta1n the effectheness of
fencing. The Environmental Briefings Progru referred to under Section
~.4(a)(f), paragraph 9, 1s ~rtfcularly applicable h.re.
Paragri§h 3: The habitat values to be gained fr~ git1gat1on geasures
referr to here ;ust be quantified before any mitigation for bear impacts can
be claililld.
{v) Wolf: Please refer to our c~nts in the previous paragraph about
quanf1fying reca.ended. !litigation •asures.
Beaver and pine garten are both ecologically and econoafcally important;
11iti~tion of SOii1e project impacts is possible. We recoaand revising the
first sentence to describe what process and/or criteria were used here fn
deciding to eaphasize beaver and pfne QBrten in lilitigation planning.
Potential benefits to other species frOGJ beaver activities is the type of
~:~inor-impact we believe to be OV'erernphasized while 1:10re significant, and
difficult to li1it1gate, impacts are not treated as thoroughly. For example,
beaver actfvit1es lillY eonflict with s tough 111nagement plans for sal1110n.
f.1oreover, benefits frOGJ beaver activities may ultir;ately be negated by
increased trapping which will be facilitated by project access and
transmission corridors. The consistent lack of quant.ifica.tfon in the draft
Exhibit E precludes eva luting the significanc~ of any such ben,efits relative
to overa,ll project impacts and recOIIilended 11itigat1on ~~easures.
Paragraph 2: ~e recog;end discussion be provided on how proposed mitigative
siting Of the transmission corridor for pine .. rten will conflict with, or
benefit, other wildlife species.
Paragra~ 3: Per our previous ca..nts, W(;. recOIIIilend coordinating the
dfscuss\Ons of impacts and aitigatfon measures between Chapters 3 and 5. We
see 1.. need to clearly and consistently state project objectives in both
chapters. We concur that workers and their families be prohibited froQ
trapping or hunting while working fn the project area and request assurance
that such prohibitions will be part of project plans.
Although increased access way be viewed as a net benefit to trappers, habitat
degradation, disturbances to the population, and conflicts with project
lillnagegent (e.g. regoval of beavers which conflict with road culverts) wculd
result in less than expected benefits to these groups. Thus we recocaend
continued monitoring to assess that potential . ~e also then recogaend that a
process be oeveloped for igplsaenting further citigation (e.g. recor.r.Jenda 'tions
-73-
to the Gage Board on greater harvest restrictions, habitat ganipulations,
alternative flow regiges, etc.) sho~ld these efforts fail or impacts be found
more severe than initially evaluated.
Para~aph 4: We request confirgation that project design plans will not
inclu e gravel extraction from Deadgan Creek. Please provide further
inforgation on how disturbance of riparian vegetation will be minimized .
Para~Ja~h 5: Please refer to our comments under Sections 4.3(a)(ix) and 4.3( ( x) re the need for quantified data to support the conclusions here.
Ue strongly support the proposed monitoring and model development programs.
These programs should also be the basts for verifying impact predictions.
Although by itself .anitorfng does not aitfgate project iapacts, it should be
the basis for detergining additional mitigation needs.
Paragraph 6: We concur. To aaaximize the effectiveness of the aaitigatfon
plan, we recoaaend continuing studies to fill data gaps, quantify conclusions
given her~. and cogplete habitat models for beaver and pine marten.
(c) Birds
( 1) Ra tors and Ravens: Para a 1: We recor.nend expand ·fng the list of
1i11JOr gpac s o nc u e oss o unting habitat, a corollary iJ61Pact to the
loss of nestfn'g habitat identified here. A lilitiyation need we have repeatedly
recor;anded is realignment of roads and transm~ssion corridors away frog
riparian corridors and other wetlands va.luable in r.Jigratfon as well as
breeding (e.g. letter froaa FWS to Eric Yould, 5 January 1982).
Furthergore, we rec010111end that the liiOnitoriny pro~rllil include continuing
surveys for peregrine falcons (see Section 4.Z(c)(i)) as well as other raptors
(see Sections 4.3(b)(xiv) • Habitat Loss), to confirg their absence in
construction activities areas.
ue are concerned with the emphasis on creatfny artificial nests. That
emphasis is based on the assumption that nest sites are the lirilit1ng factor to
raptor use of the project area. Th1s has not, to date, been adequately
supported by ongoing studies. For exaaple, overall loss of feeding habitat
may negate potential benefits froaa such structures.
-Creating Artificial Cliff-Nestin~ Locations: ue concur with the
reca.endat1ons to continually 110n tor for nest destruction and to provide
additional CJitigat1on later, if found necessary.
-CreatitR Artificial Tre ... Nesting Locations: Paragraph 1: Please provide or
correct e complete reference for creatingsuccessful bald eagle nests; it
was apparently omitted from the bibliography. Ue question the suitability of
presently unused habitats cited here as potential .nest sites. Since eagles
are not using these areas, fo.od or some oth.er habitat paraCleter may be
lililfting.
Paragrieh 2: We suggest expanding the discussion to describe tbe
compar ifity of habitats, circu111stances, and species of birds using
artificial nesting platforms as listed in Table UBl. The success of those
efforts liJIY not be directly applicable to the project area, gfven the
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different habitats and species involved. Please include inforgatian on
whether such structures have ever been successful in A 1 aska.
-Seasonal Restrietions: Ue strongly support the measures included here with
the addition of three points. First, we recOiillend coordinating with project
design engineers to ensure that such timing and siting restrictions are fully
incorporated into project designs, schedules, and cost estir11ates. Secondly,
our previous coaments on the need for follow-up gonitoring of raptor nesting
in responsP. to construction activities are critical here. Finally, for bald
eagles, we reca.nend there be no blasting with1n 0.5 milPs of nests.
(if) Wlt•rbirds: Paragraph 1: We recoamend revising this paragraph to
describe factors WhiCh may limit benefits outlined here (see our cogments
under Section 4.3(a)(xv)). An additional concern we believe should be
described here is the potential for collisions of swans with transgfss1on
lines.
Para¥aa~ 2: We recommend that the ggnitoriny program described prev~ously
shou \i coordinated with ongoing FYS surveys for trumpeter swans and other
waterfowl, with ptrticular attention to the ililpacts of project disturbances on
truapeter swans. Je again note the importance of carefully siting all project
facilities, roads, and transmission lines away frolil wetlands {as being
r-pped), including strem corridors and lakes. Since trurilpeter swans and
other waterbirds frequently f:1i1J"ate aTony strear.J corridors, sitiny and lillrkin~
of transgission Tines is part1cularly critical to avoid collisions and
electrocutions in those areas.
(iii) Other Birds: We again note the ecological importance of these species.
We recommend that nest and roost boxes be considered as mitigation for
passerines. Hairy woodpecker, boreal chickadee, and brown creeper would all
adapt readily to such structures. These three species populations would be
reduced by 10.1, 7.4, and 19.9 percent, respectively. The hairy woodpecker is
on the National Audubon Society's •Blue List• and is thought to be declining
in the Pacific f4orthwest. We also recoaaend that all unavoidable adverse
impacts from the project be fully acknowledged.
(d) Sr.lall (non-game) t4acaals: We refer you to our cOiiiJents, above, re fully
aCknowledging unavoidable adverse project impacts.
Comaents on Tables and Figures for Section 4 -Wildlife
Overall, many of the tables and figures are incogpletely footnoted and
referenced. Few will stand on their own and many are confusing or
inconsistent even when referring to the text. We recoggend cleaning up the
tables and figures to a lle.viate these problems in general, as described fn our
c~nts on the text of the report itself, and as specified below. Rather
than cagmenting on all editiny or corrections needed, we have focused on major
problems or points iwportant in understanding our coL~nts on other portions
of the docwaent.
Table U21, WZ2 and ~3: Please include the number of sites, sampled in each
COr.IIIUnlty.
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Table W64: ~e recoggend footnoting a brief definition of •iaportance value
ratings.• Please provide dates for the suGiilel"' 1981 survey.
Tables W&S, W66, W68 and U78a: Please clarify how habitat types as ctassifi!d
nere do or do not coordinate with the revised vegetation classification
scheme. We are concerned that data ganipulations not obvious frog the
original references be fully described here (see Section 4.2(c): Paragr.~).
figure Wll: We suggest adding reservoir elevation levels.
Figures W19 and W20: We rec~nd including some description of how •relative
importance• was deter101ined and •tCipOrtance Indices• were calculated. Souro!s
for this data should be cited here.
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Appendices EA to EE
General Co~nts
Overall, we concur with the environgental guidelines to the extent that they
are presented here. However, we are concerned that the yuidelines are
souewhat incOGplete and lack specifics needed for effective igplegentation.
Please specify the degree to which these guidelines are being incorporated
into project planning. We recomgend that you explain any situations where the
guidelines will not be followed. In order to most effectively iQplegent these
guidelines,, a. 1 thus, to achieve greater Jilitiyation of project igpa,cts to fi ·sh
and wildlife, we recoggend ate~ approach between project env1rongental
specialists and design engineers throughout design, siting, and construction.
The interagency raonitoring group recOGDended previously should be part of this
effort (see our coGDents on Section 4.4: Paragraph 5) •. Problss with lack of
integration between project studies and different Chapters in the Exhibit E
would then be filOre easily overca.e. Following are our Specific COGlilents on
individual items in the environmental guidelines.
Specific Comments
A-All Facilities
1. The referenced buffer to waterways or wetlands should be a 500-foot
CJiniraum width, not r.~aximuGJ width as presented here.
7. Please define project •facility• as used here. We suggest the definiticn
include project car.tps, access roads both to and within the project site,
and any construction areas (includiny the dams, borrow areas, disposal
sites, etc.).
Trugpeter swan nests and caribou calving areas should be added to the
list of areas to which the guideline is to apply.
8. Blasting deterc~inations should be r.~ade in consultation with the resource
agencies. Such deterQinations ~auld be incorporated into the previously
recomgended gonitoring program (see our co~nts on Section 4.4:
.Paragraph 5).
9. Please discuss the feasibHity of disposing of part, or all, of project
spoils within the impoundltlent area in accord with project scheduling. An
estimate should be provided of the quantities which may be involved, or
when those quantities will be determined. Stockpiling needs, and
reclamation considerations should also be provided. We suggest this ite1.1
be. expa.nded into an additional appendix section similar to Appendix AD -
Material Sites.
11. P 1 ease refer to our previous cor.J:Jents on the need to map perr.tafrost areas
(Section 3.2 and 3.3{a)(ii)-Effects of Erosio~ and Deposition).
13. We reco~nd specifying that fertilization and seeding be initiated in
the growing season iJji;Jidiately followin!: site disturbance. The
interagency r.10nitoring prograr.1 referred to in itec S, above, should
review and concur with species chvsen for revegetation.
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14. Pleas.e refer to our coCitlents under iter.1 13, above.
15. ~e concur; again please refer to our coggents on itern 13. Initiating
test plots as part of continuing project studies would prov·ide
inforcation on which successful site restoration can be based. Plantings
to provide wildlife food and/or cover should also be considered in
developing restoration plans.
16. We strongly endorse both programs outlined here. Reference should be
made to U.S. Coast Guard (C.F.R. 33, Part 154(b)) and Environmental
Protection Agency (C .f'.R. 40, Part 112) regulations which require use of
a Petroleurn and Hazardous Substance Plan a .nd Manual with such
developaents. It should be r.~andatory for all project personnel to take
part in the Environmental Safety Program prior to starting work on the
project.
17. We suggest that storage containers for fuels and hazardous substances
also be located at least 1,500 feet frOIJ wetlands. All personnel
inv·o lved in tran.sfer and handling operations for such materia 1 s should
carry portable spill containment/absorption r.aaterials. Impervious
JJ&terial used to line containment areas should be securely tacked in
place and frequently monitored for tears; such tears should be promptly
repaired and water which may collect in the areas should be pror.aptly
removed. ·
18. Please specify the degree to which this recoaJendatiun is bein~ followed
as described un:ier our Ge.neral Coliltaents for thes.e appendic,es.
19. We recor.T.Jend addition of an iter.a outlinin~:~ the need for the contractor to
train per so nne 1, prepare, and fo 11 ow an eras ion contra 1 p 1 an which is
subject to resource agency review and corililE!nt (see our coiiU!nts on
Section 3.4(d)(ii)). That plan should then be incorporated into these
guidelines.
B -Construction Camps
l. and 2. We concur and reco11111end that there be no trucking of garbage
between camps; each camp should have its own incinerator capa.b 'le of
burning that day• s wastes.
3. ~e concur; please refer to our co.r.Jilents under Section 4.4(a)(i't') on the
need to clearly sign and lilOnitor all gates to ensure they remain closed.
We recoomend the interagency monitoring group review and concur ~lth the
fencing specifications.
4. We suggest that the recolir.lE!nded effluent sacpling and testing prograr.1 be
outlined in construction camp design plans.
5. Again, resource a~ency rev·iew and concurrence should be involved.
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C -Access Roads
3. Ue concur and recoggend that the proposed program for identifying
wetlands in consultation witP the CE and FWS be used in access route
siting (see Section 3.2 (a)(vi)).
5. Instrem work should be scheduled to avo1d critical spawning tir.1es and
minimize sedicaentation of downstreaa habitats.
6. throu~ 10. Criteria should be included for deterr.tin ·ing when a culvert
rather t)\an a bridge can be used for strear.J crossings. Resource agencies
should be consulted in the developgent of such criteria.
13. We suggest. adding, •as well as after significant sto·rg events• at the end
of this iter.~ This issue needs further definition.
0 -l-laterial .Sites
1. We concur and recoe&end that the interagency QOOitoring. prowar.1 ~e
integrated with the i.nterdiscipl i ·nary team effort so that resource
agencies are consulted in the deve1opgent and fgpletJentation of gining
plans.
2. a.nd 3. Please ident i fy the extent tJf uorrow e1ateria.ls needed for projact
constru.ction which tllY be available within the ir.1poundment area, relative
to the ex.tent of borrow which will have to come from other sites. Our
ca~Z~ents under ~pendi.x EA-All Fa~i.lities, iter.1 9, on stockpiling and
reclar.1a'tion, ana under Appendix EC -Access Roads, items 6 through 10 re
crfteria for determining when to use the lower priority lilitigation
measure (e.g. culverts instead of bridges; first-level terrace sites over
~ell-drained uplands) apply here also.
7. We suggest that construction schedules be e.va.luated in order to determine
optimum coordination and use of ma.ter ia 1 and d i st~:rbance sites.
E -TransQis.s:ion Conidors
1. We recomGend addition of the phrase •and Qiintained• after the word
•constructed• in line Z of this item. Our text cor.Elents on the need to
fully integrate Intert ie deve loprnent with a 11 other project transrJiss ion
lines apply here (see Sections 3.4(d)(ii} a.nd 4.4(d)(i) -Willow to
Healy). ---
3. Transgission towers should not be placed in wetlands, as defined by
ongoing remapping efforts. ·
4. We concur, and suggest that selective cutting be used to control
vegetation along transmiss i on corridors.
Appendix EG: Please provide the so urce for data cited which was not provided
~Y the OnlVersity of Ala.ska f.tuseur.t.
-79-
Chapter 4. REPORT ON HISTORIC AND ARCHEOLCXilCAL. RESOURCES: No coaaents.
-80-
Chapter 5. SOCIOECOrmmc It_., ACTS
2e!J~ral Coaae!!t~
Ue see this socioeconomic igpact evaluation as an integral co~onent of the
overall evaluation of alternative means of satisfyiny eneryy needs in the
least environmentally damaginy way. Accordingly, we offer the following
coggents for consideration in the evaluation of this alternatives.
Evaluation of a proposal must exagine iapacts. positive and negative, and
miti;ation over the life of the proposal. Data bases provide the point from
which this evaluation ~st progress. How this project could effect fish and
wildlife resources over its life is strongly dependent upon how the project
influences future user deaand of those resources. This evaluation should
incorporate: (l) a widely accepted projection of future population and
economic growth (increasing user yroups) or, if there is substantial
uncertainty as to the validity of key assumptions (as we believe th~re is),
then a multiple scenario model should ~e pursued examining at least high,
medium, and low projections; and (2) a tradeoff analysis examining the
competing mitigation proposals for the different interests. Chapter 5 fails
in respect to both points.
The Base case, as expressed in this document, is a miniuug project igpacts
scenario. Ue are led to this conclusion by th~ following:
1. The recent downturn in State oil revenues directly leads to a
downturn in State spending. Increased State expenditures result in
economic expansion which then attracts and supports the ne\1
population (Departgent of Policy Development and Planning (DPDP}
Policy Ana lysis Paper No. 82-10). The expected lower level of State
spending should be reflected in decreased econogic expansion and
population. One could deduce fro~ this that the without project
econogic and population Base Case should b~ substantially lowered
frOLI what is presented in this docur.aent. Since this turn of events
obviously does not i~act the cost of the project, the project
socioeconoQic igpacts would be accentuated.
2. Uith less oil revenue the State would need to concentrate a greater
percentage of its income and/or bonding capability on this project.
The State would then not be able to afford projects in other areas of
the State. We, therefore, believe a closer look at State-wide
impacts is necessary.
3. The power which this project would provide could act as an attractant
to various industries, to the detriQent of other areas of the State.
4. Potential impacts due to the seasonality of the workforce is not
fully addressed in this document. Other hydropower projects in
Alaska, such as Terror Lake, and those constructed in other rern~~ely
situated areas should be examined to explore this potential impact.
5. Ir.~pacts result from the nur.mer of people attracted by potential jobs
not by the number of jobs created. either directly or indirectly.
This is supported by the letter to Eric Yould dated 27 ~~rch 1982
fro~ the Alaska Department of Corogunity and Regional Affairs (ADCRA}.
6. The implicatior.s of it~ 5 above regarding local and regional hiring
assumptions and iQpacts to local communities.
We have not previously had input into many of the decisions which were reached
regarding the construction camp/village such as siting, type of camp. and
administration. These decisions have large implications for the fish and
wildlife resources and users. Consideration of a Prudhoe Bay type ca~ should
be given. We are not aware of any construction c~ alternatives having been
discussed in tergs of minimizing adverse impacts to fish and wildlife
resources, and their use.
As illustrated by many of our c~nts, we are concerned that not only were
the resource agencies not consulted previously on many of the actions
described herein but that comaunication and coordination between the
socioecono~ic component and the fish and wildlife resources cogponents has
been insufficient.
It is stated several times in this chapter that monitoring of impacts is
proposed and that this progr~ would add flexability to the mitigation
progr~. We concur. However, we believe this ~nitoring team should better
reflect the spirit of the APA Mitigation Policy document. Ue believe a
monitoring program should be established. at project expense, consisting of
representatives of appropriate local, State, and Federal agencies, to carry
out the function of assessing the extent of actual impacts and reco~.~nding
~difications to the mitigation program. Modification of the mitigation plan,
as represented in the license, would then be through license acendment.
Modification of the Base Case to accomodate the concerns raised in the ADCRA
letter of 27 May 1982 and ~n our comments would dramatically change the
impacts predicted and ultimately the mitigation requirement. Additionally, an
assessgent of socioeconomic impacts must be reactive to other study
components. For exa~ple, to evaluate i~acts to user~ of fish and wildlife
resources, the impacts to the resources gust first be assessed. in that many
of these resource impacts hav~ not been sufficiently quantified, one could not
expect an acceptably quantified socioeconomic analysis. This co~ld only have
lead to a highly general mitigation plan, which is what w~ find here. In
fact, reference is made to certain actions which (Section 4.Z(a), page
E-5·91), • ••• will be considered in the mitigation plar.•. A rnftigation plan
should be a part of this docugent, and be specific to the anticipated impacts
based upon a broadly accepted data base. The burden of formulating an
acceptable ~itigation plan is the applicants.
Specific Comments
2 -BASELINE DESCRIPTION
2.1-Identification of Socioeconomic Impact Areas
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(c) State: We concur that inentifiable igpacts would be concentrated at the
lOcal level, and most difficult to evaluate on a state-wide basis. It should
be recognized that how this project fs approached economically has tregendous
implications for the State. If the State provides a grant of billions of
dollars, that money can't be spent on other programs. Bonding of the project
would have a large igpact on the State's ability to bond other projects.
Additionally, the relationship between large ~rejects and population growth
should be given greater eaphasis. Increased State expenditure results in
economic expansion that attracts and supports the new population (DPDP Policy
Analysis Paper r~o. 82-10). The State would be igpacted through services
provided to this project caused higher population level.
(a) Local
(ii) Po~ulation: Para¥aash 3: Acceptance of the projected Mat-Su Borough
populat on figures woue on the basis of a review and acceptance of the
underlying ass~tions. ~ithout these we are left with what appears to be
relatively high projections which apparently coae from a single source, the
Hat-Su Borough, which could be viewed as having a vested interested in the
project, and a high probability that the projections rest upon by the
original, outdated project ~conornic analysis. The iQPacts analysis and
mitigation planning is strongly tied to population projections with and
without the project. ~e reco~nd that the data base be broadened and
projections updated.
Para£haph 4: ~e recently received a Seeping Oocu~nt (dated 29 Nove~er 1982)
ror e Knik Arm Crossing fro~ the Alaska Department of Transportation and
Public Facilities (ADOT/PF). In that ADOT/PF is just beginning to evaluate
the desirability of this project it would be premature for APA to view it as a
foregone conclusion.
Parasraeh 5: Please discuss the assumptions upon which these population
project1ons are based.
(b) Regional
(ii) Population: ~ar~!tfiPh 2: We accept the underlying assucption that, in
Alaska, population gro 1s strongly associated with natural resource
development projects. Please identify the developgent projects that have been
assumed to be yoing forth. The recent downturn in State income, due to
weakening of oil prices, should be factored into this ana1ysis.
3 -EVALUATION OF THE I~ACT OF PROJEC i
3.1-I act of In-~i ation of Peo leon Governgental Facilities and
rv ces: aragrae : e un er y1n~ assumptions which lead to the
C:unc1us1on that th1s project would have miniual 1gpacts to the tat-Su Borough
should be discussed in greater detail. Peak project empJo~nt would be 3,498
(pag~ E-5-37) and 95 percent of these workers would have dependents, with an
averitge of 2.11 dependents (page E-5-44). This would lead one to believe
direct project worker impacts would be gore than 10,000 people. If all these
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people were housed at the constr~ction site we would have a city approxi~ately
three tir~s the size of Palger, with all the encumbent needs of this size
c~.Gunity. This figure would be substantially inflated by secondary and
induced jobs resulting frog the project. Spreading these n~.Mers out over the
s~ll, local c~~nities would be expected to result in significant adverse
H:~-~=t~. In the 27 ~1ay 1982 letter from the AOCRA to Eric Yould it was noted
that, • ••• given the current state of the econo~, it seems reasonable to
expect a sizeable influx of people from the Lower 48 seeking highly-paid
emplo~aent, therefore co~eting directly with the local labor force. This was
the State•s experience during the Trans-Alaska Pipeline project (TAPS) and, in
fact, just recently for the as-yet to be started Alaska Natural Gas
Transportation System. Yet this proven phenomenon apparently was not
considered in the analysis. This influx of people seeking instant riches in
Alaska during major construction projects has historically contributed to
impacts far in excess of what ~therw1se mights normally be expected.•
In reference to, • ••• the buffering effect of the expected continued
increase of the population,• please refer to our Chapter 5 General ComGents.
(a) Watana -Construction Phase
(i) Local
-~~t-Su Borough: As stated in our Chapter 5 General Comments we find it
difficult to accept that, •In gost areas of the t~t-Su Borough, the population
influx related to the project will only add slightly to the substantial
increases in need for public facilities and services that will be resulting
from the population growth projected under the Base Case.• It is stated in
the previously referenced 27 r.tay 1982 letter fror:J AOCRA, •The State•s
experience has been that the impacts from large construction projects (most
notably TAPS) are far in excess of what were originally anticipated. Those
impacts were due to a substantially greater inr:~iyration [SIC] of people than
those anticipated based solely upon the size of the required construction and
support work force. This was due in part to a larye nur.Jber of people who
migrated to Alaska with no intention whatsoever of seeking employment, at
least on the construction project. Another unforeseen impact was in the
secondary job market. Inr:~iyrants [SIC] competed for, and filled, secondary
and induced jCJS, many of which were vacated by local residents obtaining
employment on the high-paying construction project. This situation only
exacerbated the local unemplo~.~nt situation.
•certain public services were severely taxed as a result of the larger than
expected influx of people. The public safety and public health were
jeopardized by increased •people problecs•; too few public safety officials
and inadequate or non-existent facilities delayed the State•s ability to
adequately respond. Lack of adequate housing led to overcrowded living
conditions and sanitation problems. Increased vehicular traffic devastated
the roads and at times created safety problems as well. Utilities, such as
power and telephone, were overtaxed. Heightened dernand for housing produced
rent gouging, displaced families, hastily and poorly construct~d housing, and
use of substandard or even non-residential units as places of residence.
•I·, seems, therefore, that the potential exist~ for the types of i~pacts
described above to occur as a result of the Susitna project, and to occur ir.
-84-
larye part in the t·1atanuska-Susitna Borough. Simply put, we believe that t>ast
experience h as shown that 1110re people will show up than originally
anticipated, bringiny with them all the probler.~s att endant to a •bool.t-town•
situation. We do not feel that t his was adequately ad\Jressed in the draft
fea.sibil ity report, nor that the State1 s prior experience with TAPS was taken
into account.•
We would expect that a high percentage of those attracted to the area would
becor.Je fish and w i 1 d 1 i fe. resource user·s. This wou 1 d 1 ead to increased demand
for these resources at the same tirae and in the vicinity of liiOre direct
project related impacts to· these resources. Additionally, because the project
work force would be highly seasonal ., (page E-5-37) the impact of these
employees on the. fish and wildlife resources would be greater than othe.r area
residents •
. Public Recreation Facilities: Pa.ra~aph 1: Please clarify whether the
assWt~pbon that fu 11 pub 11c access woud be provided bY the project through
the upper Susitna Basin has been made . ~e understood this was not the case
(see page E-5-24, Transportation).
Use pro j ections and anticipated fish and wildlife resource impacts should be
examined •
. Tra~sportation: Parawa~~ 1: We concur ~hat, •The ultima~e status of the
road 1s unsettled at th1s llile. • The road 1s a proposed prOJect feature and
as such the ultimate resolution or mechanislils for resolution of this issue
needs to be provided in the FERC license, if i o fact we do still have road
access at that t ·ime as a project feature . We have not concurre.d that road
access is either necessary or desirable.
Paragraph 3: Reference is gade to. •schedulin9 of coa.1uting workers•. Yet,
on paye E-5-91 it is stated that, • .•• there wi 11 be no daily cor.T.JUting
• and workers will not have the opportunity to drive personal vehicles to the
camp/village •••• • These conflicts nee.d to be resolved.
-Cantwell
( i i) Reg iona 1: P 1 ease refe.r to our Chapter 5 Genera 1 Cor.Jitents and to our
coments regarding Sections 3.1 and 3.1(a)(i). -t·1at-Su Borough.
(b) Watana-Operation Phase and Devil Canyo!!_-Construct i on Phase
( i) Loca 1
-f·1at-Su Borough: P 1 ease refer to o•Jr cor.T.Jents ir.t.Jed i ate Ty a.bove (Sect ion
3.1(a)(ii)).
3.2 -On-site t1anpower Regu irernents and Payro 11, by Year
-85-
.rp ) Seuona lit~ of Manpower Require~;~ents: P laase refer to our CQCII;lents
regarding sectfon 3.1(a){i)-r~t-Su BOrough. The seasonality of the project
work force could, if they reQ&in in the State, result in significantly higher
use levels of fish and wildlife resources, and recreational resources than
that found for residents employed year-round. Ye recor.LEnd that this should
be exagineG. The TAPS project and in-state hydropower proJect~, such as
Terror Lake, should provide valuable infonaation.
3.3 -Residenc~and Move~~~ent of Project Construction Personnel: Paragraph 3:
The proposed a inistration of the construction c~p/village appears to
siro~plify probleas by r.~inigizing constraints on the work force. Given the N'A
Mi t igation Policy, which is consistent with NEPA and our Mitigation Policy, to
first avoid adverse igpacts to fish and wildlife resources we find it
difficult to accept the construction site cagp/village plan or administration
of it. In ran.y ways it tends to caxiaize adverse impacts to fish and wildlife
resources, in d lrect conflict with APA's stated mitigation goals. It appears
that plans other than that proposed have not been evaluated as none appear in
Chapter 10. \,le. rec013Dend that a Prudhoe Bay type cagp be exGined as an
alternative whicn could r.~inimize project-related impacts to fish and wildlife
resources and socioeconCMilic impacts to the local coiiiDllnities. Our position
concernin~ rail vs road access to the construction camp/village has been
previously statea-(FWS letter to Eric Yould dated 17 August 1982).
(a) Region
{ i) Regiona 1 York Force: Paragrat 4: The as_swapt ions :stated for the on-site
construct1on work force were ques ioned in the previously referenced 27 May
1982 letter frolil AOCRA, •Although there are currently enou~h unelilployed in
Southcentral Alaska to more than fulfill the project's labor demands, in terms
of numbers, that does not necessarily mean that the appropriately skilled
people are locally availaole. Also, ~iven the current state of the econor.~y,
it seegs reasonable to expect a sizeable influx of people frOQ the Lower 48
seeking highly-paid er.1ployment, therefore cogpeting directly with the local
'labo·r force. • In addition on paye E-5-94, it is stated, •There are at least a
couple of reasons to believe that local labor might have a ciifficult tice
obtaining construction jobs.• This would appear to support the r..ontention
that hiring assugptions are overstated, and thus the ir.1pacts of
project-induced population increases are understated.
liv) Relocatin~ Workers and Associated PopuJation Jnf1ux: Concerning
secondary and 1nduced population please refer to our co~ents under Section
3.1 and 3.l(a)(i} -Mat-~u Borough.
3.4 Adequacy of Available Housing in Impact Areas
la) Watana -Construction Phase
( i) Loca 1
-t·tatanuska-Susitna Borough: Parasraph 1: It is stated that, •The r.1ajority
of construction workers on the prOJeCt are expected to use the on-site r.ousing
facilities . These workers wi11 not be in-rJigratin~ into established
cor.r.1unities and ther·efore wi11 have no iGapact on the housin~ r.Ja ·rket in the
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r~t-Su Borough.• Could we not conclude fr~ the above that a ~inority of soge
unknown number of workers would not be housed on-site? This would lead one to
expect workers cogmuting, and impacts to the housing ~rket. Please quantify
these potential icpacts. Concerning co~ting workers please refer to our
COQQents on Section 3.1(a)(i) ~Transportation: _Paragrap~ 3. In addition, in
the previously referenced 27 r.1ay 1982 letter fror.1 AOCRA, the following
statement is provided:
•The key supposition in support of the r.1iniro1a 1 impacts described is that
the majority of the labor force and their f~ilies will live on-site and
largely regain on-site throughout the duration of the project. This
presu.s affiniiAtive actions a~·e taken to preclude or limit r.10bility,
particularly by private automobile, and to provide sufficient incentives
~or workers to locate their f~ilies on-site rather than fn the more
attractive and urban settings of Anchorage, Palmer, or Wasilla. If those
conditions do not occur, workers and their fagilies in some undetergined
numbers will reside elsewhere, and the workers will comQute. If that
occurs, impacts on the Borough will increase dr~tically.•
3.5 -Cisplacegent and Influences on Residences and Businesses
(b) Businesses: Paragra~ 2: It would follow that if, •Most businesses in
the upper basin are depe~ent upon abundance of fish, big game, and furbearer
species,• and the project holds the potential to severely impact these species
through elimination of their habitats, then most of the businesses would
suffer severe adverse impacts. This para~aph illustrates a possible probleg
relating to coordination or co~nication of Exhibit E study programs.
Paragra~ 3: Please refer to our comments indediately above (Section 3.5(b):
Para_a_ 2).
Parasgaph 4: Please refer to our 'o~nts above (Section 3.5(b): Paragraph
2). e cannot disciss impacts to fish and wildlife resource users as
Tnsignificant. The existing user levels must be established in addition to
fish and wildlife resource levels with and without the project. Proposals
designed to ~itiyate for unavoidable fish and wildlife resource losses should
then be ex~ined as to potential impacts on these user groups.
3.7 -Local and Re~ional Ir.1pacts of Fish and \Jildlife User Groups
(a) Fish
(i) ~~thodology: The work which was cogpleted for 1981 did provide point
estimates. The capability of the syste; to produce salgon is dependent upon a
nu;ber of factors which are being exagfned as part of the Aquatic Studies
Progr~ (e.g. winter water te~perature, availability of spawning gravel, flow
regir~, etc.). The numoer of fish that pass a point along the river does
little to establish a river's production capability other than to establish a
botto~ figure for ft.
A co:uparfson of point estimates of 1981 vs 1982 demonstrates the great
variability that exists in this system. ~oth years are •representative•.
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iiJ.l.. The Cor.raercial Fishery
~Specific l~pacts: Paragraph 1: Ue concur.
~aragra~h 2: G.iven the qualifications stated in the first Paragraph, this
discuss1on fails to recognize the potential of the project to iQpact fisherie!;
downstreaQ of Talkeetna, the potential of the river above Devil Canyon to
support salr.10n {future opportunities lost), the igportance of COIID!rcic.l
fishiny as a way of life, the igportance of co.....ercial f~shin~ in tera; of
secondary and induced job creation, value of the fishery lost over the life of
the proJeCt (based upon the sage econooic assugptions as the r~:~t of t ,le
project), the cost of various mitigation proposals over the life of th!
project, etc. We recomQend that a more detailed discussion be providei in the
Exhibit E takiny into account at least the factors lfs.ted above .•
4: We concur tha.t the ~ype of research
~e-s.;...c...;.r....,..;-e.....,__,,,.s...;......ne_c_e_s_s-ar_y .... ~,...,.T",PT"'9,.;...o"""'n a!O.oor--rnf orna t ion on the scope and sch ea u 1 e for
completing this work should be provided here. Ue would appreciate fu1ure
coordination on this research as we had not been contacted previously.
(iv) Subsistence Fish in~: The impact of the project on this is~ue ha! not
been evaluated and rerna1ns a large data and analysis gap. The Hilport2nce of
the Su~itna systeg to subsistence, potential losses, and how rnitigati<n
proposals affect subsistence use should be addressed in the Exhibit E. The
data provided is not applicable to the project. EnactCJent of a State
subsistence law in 1978, subsequent 1 itigation, and changes to that law in
1982 invalidate direct cor.~parisons of permit nulilbers for different ye~rs.
Additionally, we do not consider the price of sa 'loon at the superr.1arkEt an
adequate r~flection of the iQportance of the resource to this life st}le.
Cultural, social, ar.d recreational values should also be considered in this
analysis.
(b) GaL~: The prigary deficiencies of the Socioeconor.1ics Chapter are
prevalent here: (1} inconsistency with Chapter 3, Fish, Wildlife, and
Bot•nical Resources; (Z) lack of coordination such that miti~ation
recOGJDendations from Chapter 3 are not eva1uated in Chapter 5 and vice versa;
in several instances assumptions in Chapter 5 directly conflict with
recolir.M!nded citiga.tion rneasures; and {3) data gaps and incor.~plete anal~·ses
which prevent full evaluation of socioeconolliic issues (e.g. payes E-5-iS,
paragraphs Z and 5; E-5-76, paragraph 1; E-5-81, paragraphs 1 and 4; ard
E-5-82 to S3 discussion under Section 3.7{c)(i)-Data Limitations ).
(i) ColiEiercial
-Gu1des and Guide Services: Paragraph 7: Please refer to our cement:: on
Section 3.5(6). In that •worst case 0 potential loses were examined in ~ection
3.7 (a){ii) we r ecommend that a si~ilar ~xa~ination be provided here,
particularly since coose estir.tates have previously been furnished by the
ongoing Big Game Study Progra~.
Discussion should be included on the possible decrease in t~e area's
attractiveness for re~otE, wilderness hunting given the increase in acce~s and
human activities with project development. By definition. guided hunting
involves a more remote type experience. Loss of this rer.1oteness and pote1tiai
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icpacts to the guidiny industry should be ccnsidered here. Ongoing data
collection/analysis regardi~g this issue needed to be fully described.
iii) Recreational
-Resources: We recorngend expanding the discussion to consider relative
demands aiUf values for co~rcial, recreational, and subsistence hunting for
each species in comparison to other species.
Including a section on ·~anagegent• would clarify the remaining discussion on
recreational hunting. The section should briefly describe ADF&G ganagement
responsibilities and the Game Board; and include a ~Po~ Gage Management
Units in relation to gajor project features and access routes •
• Caribou: Including the map rec~nded under Section 3.7(b)(ii) -Resources
ibove, would clarify the discussion. -
Resource Status: The present permit system is designed to under harvest the
herd so that it can continue to grow. This section should reflect the present
and future management plans for this icportant resource, see similar co~ents
under Chapter 3, Section 4.Z(a)(ii) Population Characteristic~.
The Ex erience Sou t b Hunters: Please cla,ify by identifying the other
area or resource o 1 un 1ng of the Nel~hina herd by nearby Anchorage,
Fairbanks, etc. residents is being co~ared.
Transportation to and fr~ Hunting Grounds: Project impacts on hunter access,
and indirectly, to the caribou herd should be discussed. We suygest
coordinating the discussion with that in Chapter 3, paye E-3-356, paragraph 3
and page E-3-371, paragraph 1, and our comGents on those sections.
Hunti~Pressure: Management changes invalidate direct comparisons between
the n er of hunters in 1980 and 1970. Increases of human populations should
also be described. If it were not for the pergitting systeQ the hunting
pressure would be rnuch higher. Although the number of permit applicants
provides a clearer picture of the importance of the herd we consider this
figure to also underestigate the i~ortance of the herd. Since the chance
that an applicant would obtain a permit is low, many people are discouraged
frog applying. If warranted, a survey could pro~ide an estimate of the nugber
of people who would hunt the Nelchina herd if the permit system were removed.
To adequately evaluate potential project impacts to the herd on~ would need to
examine ADF&G present and future managment plans, projected d!Qand forecasts,
gost likely behavioral responses to the reservoirs, access routing and
control, alternative reservoir filling and operation schemes, construction and
public use of the access mode and routing alternatives, the tradeoffs involved
in conflicting mitigative proposals, irnpacts of mitigative proposals on user
groups, etc. ~e rec~.~nd that the i~acts evaluation examine the
aforementioned factors.
Supply and Demand f(,r Hunting Oe£ortunity: Again, the situation is not fully
discussed. Data should be prov1 ed cocparin~ rates of increase for both
pergit applications and human area populations.
Success Rate: The iQpact of hunting on caribou populations should be
described here (e.g. see Chapter 3, pages E-3-220 to 222). Increases in herd
nUGbers may have also contributed to the increased success rate. A map of
take relative to existing and proposed project access points may aid in
evaluating project impacts. An analysis of those impacts on existing supply
and demand for caribou should be provided •
• Moose: Since the subject of this chapter is socioeconomics, we recommend
expanding the discussion to include information on goose being the gost
economically iQportant wildlife species in the region, per Chapter 3 (see page
E-3-197).
Resource Status: The paragraph is inconsistent with Chapter 3 which includes
1981 data and an estimate of 4,500 moose in the upper basin. Recent and
long-terg ADF&G management plans for moose, as well as a ~P of applicable
Game Manayegent Units would help relate igpacts described here to potential
mitigation measures.
Trans~ortation To and From Hunting Grounds: The discussion describes the type
of da a available yet fails to provide any quantification. Figures
delineatiny present and project-related access points should be included and
correlated to current huntin~ intensities.
Hu~ting Pressure: Please explain the hunting perQit and/or habitat chanyes
responsible for the significant decrease in hunters and harvest while area
human populations have substantially increased. Reference to 2,859 hunters in
1981 is the same number of hunters as for 1980 in Table E-5-42. Please
correct ff this is not the case.
Success Rate: Refer to comment above, local human populations, permit
regulations, and area goose populations are critical factors in the success
rat~ which should be discussed •
• Other Species: ~e concur that a large data gap exists. The schedule for
acquir1ng these data and incorporating them into project planning should be
discussed. Once socioeconomic mitigation proposals are established, they ~st
be ex~ined in regard to impacts on fish and wildlife resource user groups. A
tradeoff analysis would then be needPd to examine conflicting mitigative
proposals. Because coordination among project studies has been lacking, each
study described impacts relative to optigal project manageaent for the subject
of that study, e.g. recreation, fish, moose, subsistence, power, etc. ~e
rec~nd alternative ganagement scenarios be evaluated within each study
before the necessary tradeoff analysis is completed •
• Importance of Regulations: Paragra~h 1: Access routes, restrictions on
access, and construction sChidutes w1 1 also greatly influence opport•jnities
to hunt in the project area. Quantification should be provided for possible
impacts under at least two·scenarios-severely restricted access and pergfts
and open access without permits. Such analysis should be fu~ly coordinated
with ongoing big gage studies and also discussed in Chapter 3. Given the
substantial agency recommendations to ogft any project access from the Denali
Highway, and the igportance of that recogmendation as a wildlife mitigation
geasure, we recomcend your analyzing the impacts on hunter access both with
and without that road corridor. Additional discussion should also be provided
-90-
on impacts both with and without restrictions on worker access and hunting.
Again, regulation of such use is a significant ~itigation measure .
Quantification of possible use levels is necessary for full quantification of
project i mpact s on ooose populations in Chapter 3.
Par agr~~: Consideration should be given to the greater losses expected for
black bear than for brown bear habitat in view of the harvest regulations
described here •
• !~acts on the Hunter : Factors contributing to a hi gh quality hunt should
be ~fined here. AViiTability and accessabflfty of ani~als are key factors
which will be affected by the project. Again, the schedule for c;uantifying
recreation a 1 project impacts shou 1 d be. described. The present i nab i 1 i ty to
quantify economic effects of the project is recognized as a major proble~ and
should be resolve.d in the license application. The econo~ics anal ysis should
occur after quantification of wildlife impacts and formulation of ~itiyation
proposals. Please refer to our co~nts under Sections 3.7(b)(i) and
3.7(b){ii).
(iii) Subsistence Hunting: This section should be rewritten to oore
accurately reflect current laws and regulations. For exagple, non-resi dents
cannot qualify as subsistence users. A complete, rather than partial ., , .sting
of all qualifications for subsistence use should be included here. The first
sentence of the second paragraph pertains to a one-time only re'gu1ation which
is no longer in effect . The last sentence of this paragraph is an editorial
colllilent which should be deleted. f·1ention of the controversial nature of
subs i ·stence use would be appropriate. The referenced future data compi Tat ion
and analysis should be provided in the Exhibit E. At a minigurn, scope and
scheduling of this work should be fully discussed. The concerns expressed
u~der Section 3.7(a)(iv} Subsistence Fishing would apply to this section in
regard to hunting. Please refer to Secbon 810 of the Alaska National
Interest Lands Conservation Act (Pub 1 ic La\J 96-487, 2 DeceliiJer 1980} for
guidance.
(c) Furbearers
(i} Cor.Llercial Users: During the August 1982 AEA Workshop on the Susitna
project, trapping was considered the prigary mortality facto r affecting beaver
in the project area. Access, in addition to species abundance and pelt
prices, is a l so a key deterginant of trapping intensity.
-Data Limitations: Given that there are problems with available trapping
data, the r ecords which are available should be described h·ere as a genera 1
indication of area trapping act 1v1t 1es. We are. conc·erned about the apparent
lack of coo·rdination with project furbear·er studies which do provide some
population and trapping data (see Chapter 3 , pages E-3-250 to 251; E-3-253 to
256; E-3-315 to 317; E-3-321 to 322; E-3-344 to 346; E-3-361 to 362.; and
E-3-368 .}
-Trapping Activity: Para~raph 1: Any examination of project i mpacts needs
to examine future opportun ties lost. Again, please provide whatever
quantification of trapper numbers and harvest values is available .
Consideration should be given to the nulilber of additiona1 trappers the area
-91··
could support under alternative project access location and regulation
alternatives.
Phra~aphh3: Ba~ed on the suggested 25 mile trap line length, it is doubtful
~r t e project area, with projected access routes, could support core
thdn an additional dozen trappers. There is soge indica~ion that the area may
be near trapping saturation now {Furbearer Study Coordinator Phil Gipson,
personal cogmunication).
-Aquatic Species
• Baseline: Para~aph 2: To co~,pliment and parallel the ~eaver discussion,
information shoul be included on muskrat populations and habitat utilization;
please refer to our comments under Section 3.7(c)(i) -Data Limitations,
above.
Paragraph 3: Subsistence value of furbearer ~pecies should be identified.
Para~aeh 4: References such as •abundant• and •cOGGOn• should be deleted.
Quan f1cation should be available from the 1981 and 1982 field seasons for
those species. Please incorporate these data into the discussion and analysis •
• Icpacts of the Project: The conclusion that the access road and
transmission lfnes would provide increased harvest opportunities through
increased access appears to be in conflict with conclusions and statements
offered in other ch£pters and sections (e.g. Chapter 3, pages £·3·317 to 323;
E-3·345 to 346; E-3-360 to 363; E·3-368; and in particular, £·3-377). The
state~nt offered in this section would lead one to conclude that open access
is expected to be provided by the preferred access road and through a
maintenance road for the transmission line from Watana damsite. It has been
our understandiny that the former has not been established and the latter was
not to occur. Please refer to our cotnents on Sections 3.1(a)(i) -Public
Recreation. Facilities: Para a h 1 and 3.1{a)(i)-Trans~ortation:
ara9rap • e ost u ure oppor unities and the potential impact that
cou1 occur to trappers due to the expected ice-free winter condition of the
Susitna River above Talkeetna should be fully described in this section. The
potential f'r furbearer populations to be trapped out, if open access is
provided, should also be considered here.
-Pine Marten
Please refer to cogments under Section 3.7(c)(i) -
-Lynx: Paragraph 2: Again, quantification shoul~ be given to this trapping
pressure and success rate relative to other area furbearers.
-Fox: Please refer to our co~nt under Section 3.7(c){i) ·Lynx, above.
Consideration should also be given to project impacts on fox, as they gay
relate to the fox trapper (also see our comoents under Chapter 3, Section
4.3(a)(xii)).
-Secondary Industries: In order to fully assess project i~acts on secondary
industr1es, the •relatively sgall percentage of Alas~an trappers who operate
in the igpact area• should be quantified here.
(ii) Recreatior.~l: Inadequacy of data base is identified. Information on
this user group Should be accuwulated, igpacts analyzed, miti~ation proposed
an..: then re-evalt~ated to assess effectiveness and impacts in the Exhibit E.
The impact due to the loss of access across the upper Susitna River resulting
from the probable loss of winter ice cover requires examination in this
section.
We suggest addition of a paragraph (iii) Subsistenc~ to complete this
section. Information under paragraph 3, page E-5-84 would apply, see comment
under that section (Section 3.7(c)(i)-Pine ~1arten o Impacts).
4 -MITIGATION: Paras;a~h 1_: The definition shou1d reflect that established
;n the APA Mitigation o icy document and the NEPA definition.
Paragraph 4: Without proper coordination between Susitna study coaponents,
actions desiyned to ainiaize one component's adverse igpacts can unwittingly
adversely effect the ability of another component to Qitigate. The major
gitigation proposals offered here are often in conflict with the ~itigation
goals of the fish and wildlife resources components. Greater comGUnication,
coordination must result in an open process to exa~ine the tradeoffs when
mitigation p~oposals are offered which gay pose impacts to oth~r cm~onents.
Please refer to our co~nts concerning Section 3.7(c)(i) Aquatic Species
which appears to indicate a lack of co~ponent coordination.
Par~aph 5: Appropriate local, State and Federal agencies need to have input
to th s process. Continued gonitoring of changing mitigation needs in regard
to coL~atability with ~itigation yoals of other components is very important.
4.2 -f·11tigation Alternatives: How the goal of lilitigation as expressed in
this section conforms to the goals of r.1itigation in the IV'A r1ftigation Policy
document and the NEPA definition of mitigation should be explained.
{a) Toois that Influence the J~ nitude and Geo a ic Distribution of
Project-n uce anges
Para~aph 3: Scheduling constraints need to be reassessed in light of the
late~ power needs forecasts. Ue recomgend that the extent to which igpacts
could be mitigated in each study component be examined through a tradeoff
anal~sis of the timing constraints which have been imposed.
Parasra¥h 4: l~pacts to fish and wildlife resources, and thus indirectly to
users o these resources, are related to the type of construction cagp
established, access provided {route and mode), and the adginistration of these
facilities. We perceive little coordination designed to ~inimize impacts to
fish and wildlife resources as a part of the socioeconomic analysis.
Para~aph 5: It appears as if management of the construction site is to be
pass~e. That is, ~rkers can c~.~ and go without restrictions. This appears
to be in conflict with the stateL~nt on page E-5-91, •For this project, there
will be no daily comauting.• Also, the assugption that workers will maintain
-93-
their existing residences would follow only if the assugption that the workers
would carne algost entirely frog the local and regional areas households. This
was strongly questioned in the previously referenced letter dated 27 t~y 1982
fro~ ACCRA, and on page E·5·94, •There are at least a couple of reasons to
believe that local labor gight have a difficult time obtaining construction
jobs.•
Paragraph 8: This paragraph suffers fro~ internal inconsistences concerning
dilly co~uting and use of personal vehicles. Please clarify the discussion.
Paragr_!Ph 9: This section is supposed to be the ~itigation plan.
Para,raph 12: The referenced studies should be coordinated with fish and
wild ife resources analyses and ~itigation planning. Please refer to Section
4: Paragraphs 4 and 5 for additional co~nts.
(b} Tools that Help Communities and Other Bodies Cope with Disruptions and
Budyet Deficits
Para~aeh 2: In accordance with the APA Mitigation Policy document, a
moni\Or1ny panel would need to be established, at project expense, consisting
of representatives of appropriate local, State, and Federal agencies to carry
out the function of assessing the extent of actual icpacts and recoggendin~
modifications t~ the gitigation progr&Q. Modification of the ~itiyation plan
in the license would be through license arnendL•nt.
Paragyaph 10: Please refer to the cor.L•nts imcediately above {Section
4.2( : Paragraph 2}.
Paragraphs 13 and 14: The question of whether or not the labor needs of the
project could be fulfill~d largely through local hire (page E·S-44} or not
obviously is going to substantially effect socioeconocic impacts. In that
uncertainty exists, as expressed in these paragraphs and in the 27 May 1982
AD:RA letter to APA, we recommend a re-evaluation be carryed out as indicated
in Section 4.3 (on page E·5·95} and incorporated into the Exhibit E.
Item 2: Please refer to our co~nts on Section 4.2(b}: Paragraph 2.
Item 3: Please refer to our comments on Section 4.2(b}: Paragraph 2.
IteLl 4: Please refer to our co~nts on Section 4.2(b}: Paragraph 2.
Paragraph 5: Please refer to our co~nts on Section 4.2(b}: Paragraph 2.
Table E-5·42: We reco~nd the addition of population esti~tes and any
Changes in per~it regulations from 1970 to 1981. The nugber of hunters fn
1980 is attributed to 1981 on page E-5-79.
Chapter 6. GEOLOGICAL AUD SOIL RESOURCES: No cor.r.~ents.
-95-
Chapter 7. RECREATIOriAL RESOURCES
General Cowments
Prigary objectives of the Recreation Plan should be: a) to identify and
~itiyate the project related adverse iQpacts to the existing uses of fish and
wildlife and other resources and, b) to Qaximize additional recreational
opportunities that are not in conflict with existing uses and the resources
they are based upon. This should be acc~plished in the context of projected
d!Qand during the construction and operation phases of the project.
In general we find this chapter suffers from 1 Tack of necessary information
which would achieve these objectives. In particular, the chapter fails to
outline alternative recreation options; evaluate the recoggended plan and
alternatives over the entire economic project life; distinguish between
specific recreation users; recognize and identify specific responsibilities
with regard to iQpleDentation and operation of the plan; and lacks specificity
necessary to influence project developgent for the betterment of recreational
opportunities.
To allow the maximum flexibility for meeting recreational demands, it is
important that an array of alternative options be evaluated. This is
•~hasized by the lack of definitive d~nd projections and potential for
access during the construction periods. Furthermore, we vie1 the tremendous
influx of people during the construction period as a ~ajor cnnsideration for a
recreation plan. Specific measures ~ust be identified which will not only
satisfy degand but also act as controls on overuse. The plan must also
recognize the liwited recreational carrying capacity of the area and deal with
the fact that all demands gay not be satisfied.
Identification of specific responsibilities for iQpleaentation and operation
of the Recreation Plan should be included. It does not suffice to place the
responsibility on the •aanayeaent agencies,• without a detailed coordinated
effort with the agencies prior to issuance of the license. The plan must
clearly identify the applicant's responsibility, the agencies' responsibility,
and clearly outline the procedures to be followed. The plan must recognize
the inherent restraints placed on the agencies and include as a project cost
c~ensations of them as appropriate for mitigation of project-induced impacts.
The plan clearly fails to recognize the differences between sport, trophy, and
subsistence use of particular wildlife resources. The tendency has been to
luap these ~sers as hunters with a major objective of bagging gaae. We submit
these are clearly distinct groups and should be so recognized. Cultural
differences regarding recreational pursuits have also been totally ignored in
the plan.
Lastly, the plan appears to have been written in a clearly reactive mode.
There is no recoynition of any recreational planning initiative that has
influenced the physical layout of the project. Thfs lack of initiative has
precluded developgent of recreational opportunities which could have avoided
some igpacts while Qaintaining a higher aesthetic quality to the recreational
experience.
Specific Comments
3 -PROJECT Uj)ACTS ON EXISTIUG RECREATIOU
3.1-Watana Development
(a) Reservoir
(1) Construction: The discussion fn this section needs to be expanded to
address non-consumptive and subsistence recreational users as veil as sport
and trophy hunters. Furthermore, the section needs to address the eminent
competition between existing recreational users and construction workers.
(if) Operations: Discussions should be provided to address a new recreational
opportunity717e., boating on the reservoir, primarily for access to other
areas.
(b)_Talkeetna to Devil Canyon Fishery
(if) Construction: Since a ~lan for flow releases during the construction and
filling period has not been finalized, we do not know what effect flow wfll
have on fishing opportunity. Mit1yat1on measures will be aimed at maintaining
existiny fishing opportunities.
i!i) Operations: Since the proposed operational flow regime will likely
reduce water quantity in the sloughsr ve anticipate a reduction in fishing
opportunity that ~ust be ~1tigated, the potential for this adverse igpact and
appropriate gft1yation should be addressed.
(d) Other Land Related Recreation
(f) Construction: Paragaa~ Z: Please expand and clarify the discussion. It
is our understanding t at he area will be open to the recreating public.
Paragra~h 3: The discussion fails to address whether or not existing use
shiftso other areas fs dependent upon several factors; e.g., species
involved, availability of and restrictions on use of those species elsewhere,
existing demand already present in other areas. and cultural association wfth
those species.
(ff) overations: It is the responsibility of the project sponsor to identify
specff c rnitfyatfon measures and develop a comprehensive plan which wftl
address this igpact. •proper control by landowners and managers,• is not a
mitigation measure without appropriate compensation to implement and operate
the recreation plans. This cost should be identified and evaluated over the
economic project life and included as a project cost.
3.!.3~C.£!!!_
J!} Watana Access Road
(i) Construction: ParajraRh 2: Estimated recreational vehicle traffic both
prior to and after 199 s ould be presented.
( tJ) Dev i1 Canyon Access Roa.d
01 Construction: Paretgraph Z: Mitigation for excavation of the borrow areas
could include the future use of these areas for recreation developc;Jent. These
oeasures should be specifically identified and incorporated as part of the
Recreation Plan.
(fi) Operations: These •careful plans• should be a part of this document, if
not, who will develop these plans and whe·n? The associated costs should also
be discussed and displayed as project costs. Also, manageQent
responsibilities during construction should be identified and discussed al.ong
with associated costs.
(d) Other Land-Related Recreat i on
(ii) Operatio;,: Ue feel this will be a significant impact and specific plans
should be identified and discussed in this document.
3.5 -Indirect Ililpacts --Project-Induced Recreation Demand
~Assumetions: Para~aph 1: This paragraph is very confusing and needs to
be clarifled. In part1cular, that part dealing with mitigation. Ue would
suggest, •rhe proposed recreation plan is designed as r.~itigation for
recreation opportunities lost due to project development •••• •
Par~gra~h 3: Assumption 6: We would suggest. that a likely scenario associated
with th s development. will be a road access provided to the area without the
project. This scenario could drastically affect your evaluation.
(c) Estimated Recreation Demand
J i) Per Capita Participation ~~thad: Parasraph 8: This paragraph needs to be
expanded to discus.s how subunits were consldered, since you rely on the
•man&Jet:lent agency• to control project demand, and this wi11 be done on a unit
and subunit basis.
Paragra~h 17: The simplification of your methodology also does not consider
that ot er recreation opportunities may bec01.1e saturated, hence areas of l.ow
use (project area) r*ly become liiUCh ~re important for future use and receive
an intrease in de~and.
Chapter 8. AESTHETIC RESOURCES
General Comments
Ue find the chapter deficient in the following areas: l) it lacks the detail
necessary to distinguish the various user groups within the category •hunters
and fishermen,• e.g., the chapter characterized this group as only subsistence
users; 2) avoidance has not been acknowledged as a mitigation n~easure, which
could significantly reduce potential ir.tpacts; and 3} the chapter does not
reference the incorporation of any mitigation measures into the project plans.
Specific Co~nts
3 -EXISTING ENV I RON~tE14T (STEP 3)
3.2 -Viewer Sensitivity (Step 4)
T.Ypes of Viewers
(A) Hunters and Fishermen: Your categorization of hunters and fishermen lacks
thenecessary depth to allow meaningful analysis. There are three distinct
group .s which must be identified and di~cussed, i.e .. sport, subsistence, and
trophy users. ~e submit that they are unique in their appr·eciation of
aesthetic quality.
{D) t4onresident Outdoo.r Recreation Enthusiasts: Trophy hunting and fishing
are readily identifiable user groups, especially in the Stephan Lake area.
This should be identified and evaluated.
Expectation of Views (A): The prime concern of soge users is not bagging
their game or catching their limits. This distinction should b~de.
5 -PROPOSED f·11TIGAT10N t·1EASURES (Step 9): The mitigation measures you have
identified are corngendable. However, there is no indication in this section
that these measures have been addressed and incorporated into the project
plans. Pertinent sections of the license application should be cited to show
where these measures are addressed and/or reasons why they were not
addre.ssed . ~e are a 1 so concerned th~t •avoidance, • as a ~~litigation liJeasure
has not been addressed. ~e refer specifically to project features which could
be located elstM~ere as a mftfyation measure or be li10re easily mitfgable in
another location. Acce :ss routes and town sites would fall into this category.
Chapter 9. LAND USE
General Coaments
With regard to Section 2.2.(d}(i}, we find the chapter suffers from a lack of
definitive information regarding wetlands and floodplains. These areas should
be graphically displayed by tyPe in the document. Furthergore, the chapter
should discuss the specific values of these areas, their relationship with
other vegetative tyPes, and specifically address the effects of the projects
on wetland and floodplains.
11itiyation r.~easures recoamended to lilinimize fmpacts to wetlands and
floodplains should be discussed including alternative site locations.
This analysis is extremely important to avoid any delay necessitated to insure
coapliance with federal requirements with Section 404 of the Clean Water Act
as amended (86 Stat. 884, u.s.c. 1344), associated regulations, guidelines and
Executive Orders (11g8a, 11990).
Specific measures to lilitigate iapacts from the transmission line should also
be addressed, including right-of-way ganag~nt techniques.
Chapter 10. AlTEIU~TIVE LOCATIONS, DESIGNS, AtiD ENERGY SOURCES
General Cogments
rtr. John Lawrence of Acres .Aiilerican, by letters dated 9 r~veaber 1981,
requested that the F\IS review the Development Selection Report and the
Transmisson Corridor Report. These requests were ~de for the purpose of
fulfilling the FERC requireaents of formal pre-license application
coordination. Ue responded to the first review request by letter dated 17
Decel:lber 1981 and to the second by 1 etter dated 5 January 1982. In that th•tse
letters were requested as part of the formal coordination pr~ess, they shoJld
be responded to at this time.
~e have been requested to review the draft Exhibit E without benefit of the
other draft license Exhibits. In Chapter 10 nugerou~ references are made tl
other Exhibits (pp. E-10-1, E-10-1, E-10-14, E-10-16, E-10-23, E•l0-28,
E-10-32, E-10-38, E-10-62, E~l0-81). Since we are unable to exagine the ot1er
Exhibits we view this pre-license coordination as unsatisfactory.
Additionally, in our exagination of the Exhibit E chapters we have seen
nugerous examples of insu~iJCient internal coordination and/or com1Unicatio1.
In that this appears to be a problem within the Exhibit E, we can only ass~Je
that this problem occurs between the Exhibit E and the other Exhibits.
Exagples of lack of coordination an,/or c~unication between Chapter 10 anti
Chapters 2 and 3 are apparent in the discussion concerning mini~u flow
releases (pp. E-10-28, E-10-30), temperature modeling (pp. E-10-30, E-10-31 1
and socioeconomic consideration between this chapter and Chapter 5 _(pp.
E-10-138). These concerns are discussed within the text of our Specific
C oaaen ts •
There is ess~ntially no atte.pt in this chapter to assess the possibility of
no Susitna project or how the Railbelt should contend with time delays of
various lengths. Just listin~ various types of alternative energy sources
does not allow an evaluation of what would, or should occur in the event that
Susitna is delayed for a period of years, or is never built. Ue reca.;end
that this type of planning effort be carried out to exaaine the effects of
short-term delays and to examine long-term alternatives.
Any assessment of alternatives, needs to take into account the most current
power needs projections. It is our understanding that the power projections
which are beiny used in the license application are generally agreed to be
hfgh and are being reevaluated for submittal to FERC after the license
application is subgitted (Acres .Aiilerican Deputy Project Manager John Hayden,
personal communication). The environmental implications are rather evident.
Alternatives to Susitna should be ex~ined on the basis of fulfilling future
power needs rather than matching the power production of Susitna. Under
previous projected power needs, it probably would have taken a coabination of
a greater nu;Der of individual power yenerating stations than under ~~e latest
projections. Several, smaller fndfvidual generating facilities should lead to
greater flexibility in potential combinations and fewer adverse environaental
iti1pacts. We rec~nd that this be exagined.
In the assessments provided on hydropower alternatives, Susitna as proposed
___ .;;a,;.;.nd;..;;a;.;.l.;te;rn~a;;t.;.iY;;.;e;..;b;as;.l~·n-de;.v;.iei.il•o~pta~-nliiit•s•aiirliel.niiioilti.iievilailliiuiiiaitediillioiinlllianiilieqiuiilfiitiiabi1ii'eilibiasiilii.sii.•••
Tables are displayed which contrast the weak and strong points of these
alternatives yet we never see how the Susitna project ranks. This is
particularly unfortunate since Susitna would leave one with the initial
iupression (which is the level to which the alternatives are examined) that it
would have significant adverse iapacts to many of the environgental criteria
{page E-10-4), includiny: {1) big gaae, {2) anadroaous fish, (3) de facto
wilderness, (4) cultural (subsistence), (5) recreation {existing), {6)
restricted land use, and (7) access.
There is no attempt in this chapter to examine the environmental tradeoffs of
the differen~ power generation alternatives, including Susitna. Therefore, an
assessgent as to what would be the •best• power development for the Railbelt
fs not possible. Additionally, in that no single alternative source of poNer
fs contemplated to provide the same level of power as Susitna (assuming the
updated future power deaands projections assert that this power generation
capability is needed) various power generation aixes should be examined.
These alternative cODbination plans should then be compared to Susitna in a
tradeoff analysis.
One obvious alternative power generation mix (which fs further discussed in
our Specific Co~nts) should center on the power generating capability of the
West Cook Inlet area. In close proximity to eaCh other and existing
transmission lines we have Chakachamna hydropower, Beluga Coal fields, Mt.
Spurr geothermal, and the West Cook Inlet natural gas fields.
Natural g,~ is considered by many to be a highly attractive alternative to
Susitna.l_f, ~ Yet the coverage devoted to this subject was
disappointing, particularly when compared to other alternative poNer
generating technologies. Three tices as much space is devoted to nuclear
power which is not generally considered as a socially acceptable alternative
to Susitna. Biomass, as an energy source, received twice the coverage of
natural gas, and wind power received more than four times the coverage devoted
to natural gas. This confirms what ve perceive as misappropriation of
emphasis. Numerous reports have been issued over the last three years on the
natural gas alternative, including the two footnoted below. Few reports are
referenced in Section 10.3{c){i) yiviny the i~ression that a very li~ited
effort was expended in researching this section.
Section 10.3{f) fails to recoynize the most attractive geothermal alternative,
Mt. Spurr. Further discussion on this alternative is furnished in our Section
10.3(f) specific coaaents.
17/ Erickson, G.K. Harch 1981. Natural Gas and Electric Power Alternatives
for the Railbelt. Legislative Affairs Agency, State of Alaska. 9 pp.
18/ Tussing, A.R., and G.K. Erickson. August 1Y82. Alaska Enersu' Planning
Studies: Substantive Issues and the Effects of Recent Events {Draft).
Institute for Social and Econoaic Research, University of Alaska. 15 pp.
Apparently no attempt has been made to assess alternatives to the proposed
construction camp/village such as sitfng, type of camp, and admfnfstratfon of
th~ cagp. Alternatives to those proposed in the draft application obviously
exfst and need to be openly ex~ined. These fmplfcft decisions have large
fmp11catfons for the ffsh and wildlife resources and users. Considerations of
a Prudhoe Bay type camp should be gfven. Construction camp alternatives
should be discussed in terms of ~fnfmizing adverse fgpacts to fish and
wfldlffe resources and thefr use. ~e are concerned that not only were the
resource agencies not consulted previously on these actions but that
c~nicatfon and coordina•fon between those responsible for thfs chapter and
those involved fn the socfoeconaafc, and the ffsh and wfldlffe components dfd
not occur to a satisfactory level.
Due to the nugerous inadequacies mentioned above the •concluding• Sectfon 10.4
should not be expected to provfde enlightenment regarding the consequences of
license denfal. It does not. Additional inadequacies are discussed fn the
Specific Com~ents which fallen~.
Specific Comments
10.1-Alternative Hydroelectric Sftes
(a) Non-Susitna HKdroelectric Alternatives: Paragraph 1: Reference fs made
to EXhibit B whfc was not provided, although we requested ft.
J!). Saeenj_~g of Candidate Sites: Para~aph 1: Reference is rade to Exhibit
8, which has not been furnished, althoug we requested it.
• Second Iteration: Paragraph 2: The criteria should reflect that: (1) just
because salgon migrate above a site doesn•t mean losses to anadrogous ffsh are
unavoidable (e.g. Chakachamna); and (2) just because anadroaous fish are not
found above a potential site, adverse fmpacts are avoidable (e.g. Susftna).
(if) Basfs of Evaluation: It would appear appropriate to fnclude Susftna and
w1thfn Susitna basin alternatives fn the evaluation gatrfces.
(iif) Rank Weighting and SCoring: Para¥ii9h 1: The interrelationships of the
env1ron~nta1 criteria should be recogn~ and assessed. Dramatic Changes fn
any one ftem would have repercussions to all others.
(fv) Evaluation Results: We recomgend that all evaluation gatrices fnclude
Sus1tna and within Sus1tna basfn alternatives.
(v) Plan Formulation and Evaluation: We recom~end that all evaluation
matrices include Susitna and w1thfn Susftna basin alternatives.
This evaluation should be reassessed in terms of current pr~jections for
future power needs. The present examination apparently is geared toward
lookfng at various power generation alternatives (whfch are not specifically
described) on the basis of providing an equal amount of generating capacity to
what Susitna would provide. We recommend that these alternative plans be
reassessed in lfght of current power projections.
(ii) Site Screening
-Ener~ Contribution: Reference is gade to Exhibit 8, which has not been
furnis ed, although we requested it .
{v) Comparison of Plans
-Enar~ Contribution: Paragra~h 2: Reference is made to Exhibit B, which _
fias nooeen furnished, althoug we have reque ·sted ft.
10.2 -Alternative Facility Defsgns.
J!) Watana Facility Design A lternat fves
It is stated that, •Tables 8.61 and 8.62 of Exhibit B show the li1inili1Uil'l flow
releases frog the Watana and Devil Canyon dams required to maintain an
adequate flow at Gold Creek. These release levels have been established to
avoid adverse affects on the Salmon [SIC] fishery downstream.• Perhaps a li10re
accurate appraisal can be found in Chapter 4 (page E-4-3), •The iliJpact of ••
• upriver and downriver chan9es in hydrology ••• cannot be assessed at this
time due to the lack of information concerning the agount, tYPe and location
of disturbances associated with these activities. • In Chapters 2 and 3 it is
stated that the reduced flows could impair fish li1igration, de-water spawning
and rearing habitat, prevent access to slouyh and side channel habitats and
lower or elili1inate intragravel flows to slough and side channel spawning
grounds. The minimum flows proposed were not developed using any recognized
instream flow methodologies, and lack any biological basis other than the mst
rudimentary. In fac.t, no explanation is offered in the Exhibit E as to how
the 12,000 cfs Qinimum operating flows for August and into September were
arrived at.
(iii) Power Intake and Water Passa es: Para a h 2: The statement is made
that a mu t -nt e struc ure wou e us , ••• in order to control the
downstreua river temperatures within acceptable lir.aits.• The \latana and Devil
Canyon darns will cause changes to the existing water temperature of the
Susitna River, generally releasing cooler water during s...er 1110nths and
warmer water in winter. This, ir. turn, may present s igni f fcant impact to the
downstream riverine environment. Teaperature variations ma y affect the
ability of fish to migrate, spawn, feed, and develop in the Susftna systect.
Ice fomation ClaY be delayed or possibly not occur above Talkeetna. This
issue is discussed at length in Chapters 2 and 3 although an accurate
description of post-project temperature impacts is not presented. The model
which was developed to describe reservoir outflow tempe :·atures contains input
data frorn only fhe li10nths (June through October) of one year ( 1981). The
Devil Canyon Reservoir was not godeled, but in Chapter 2 it is stated that the
location of ice formation (above Talkeetna) will depend on the outflow
telfJperature frorJ Devil Canyon da.Gt (paye E-2-83).
Paragraph 3: Please reference our comments on Section 10.2(a)(i) concerning
li11n1wa flows.
(b) Devil Canyon Facility Design Alternatives
Para~r~ 3: It should be clarified what •nonally• and •the requfreaents of
no s gri fcant daily variation fn power flow• aean, particularly in regard to
ffsh and wildlife resource 1-,acts.
{c) Access Alternatives
(f) Plan Selection: Para~ 2: Although input was solicited fr011 resource
agencies and the SUs1tna; o Steering Ca.ittee {SHSC), the selection
certainly did not reflect this fnput. Please reference the SHSC letter dated
5 November 1981 •. In addition, we wish to incorporate fnto our comments, by
reference, our letter dated 17 August 1982 to Eric Yould on thfs subject. As
such, APA should respond to this letter as a part of our formal pre-license
coordination.
(ff) Plan Evaluation: Paragraph 1: Reference fs gade to Exhibit B, which has
not been furnished, although we requested ft.
Item Nu~er 5: Paragraph 1: It is acknowledged that a problem exists in the
potential of the access road and traffic to affect caribou moveaents,
population sfze, and productivity. Avoidance of the problem by eliminating
the Denali Highway to Yatana access segment would be consistent with the APA
f.lftigatfon Policy document, the recOIIillndatfons of the resource agencies, and
NEPA. As fs stated fn Appendix 8.3 of the Susftna Hydroelectric Project
Access Plan RecOGaendatfon Report {August, 1982), •from a caribou conservation
viewpoint, the Denali access route fs far less desirable than proposed routes
originating on the Alaska Railroad and Parks Hfgh~ay. The Denali route would
~st certainly have igmediate detri .. ntal impacts on the resident subherd and
future negative fq~acts on the •in flelchfna herd although these fr;Jpacts
cannot be quantified.•
Itera riUiilber 7: Parana£: 5: Both the MIA l·titfgation Policy docUIIIent and HEPA
aCknowledge that ft s tter to avoid an adverse impact than to try to
afnigize ft, •through proper engineering design and prudent manageaent.•
APA's approach should better reflect thfs in their decfsfons concerning access
routing. In addition, reference fs .. de to discussion •in Exhfb~t E.• Thfs
fs the E~ibit E.
{d) Transmission Alternatives: By letter dated 9 November 1982, Mr. John
Lawrence Of Acres Aiirican requested our review of the Transmission Corridor
Report as part of the foraal pre-license coordination process. We responded
by letter dated 5 January 1982. In that ft was requested as part of thfs
formal pre-license coordination process and we responded with this
understanding, the issues raised and recommendations made in that letter
should be addressed at this ti~.
(vi) Screening Results
-Central Study Area
Corridors Technically and Economically Acceptable
is made to Exhibit
o corridor One (ABCD) -Watana to the Intertie via South Shore of the Susitna
1Ver
• Environmental: Given the APA decision to have road access for the Watana
dams1te to the Devil Canyon damsite along the north side of the river, we do
not understand how it can be conside.red best environmenta 1 fy (rating of •A•)
to have the transmission line along the south side of the Susitna River. In
our 5 January 1982 letter we stated, •How construction -and maintenance-
related access is obtained to a great extent determines the project-related
wildlife and socioeconomic impacts. Construction and maintenance of
transmission lines should not provide for additiona 1 pub 1 ic access over that
provided by the dam access route .• and, •Access to the dams should be fully
c-oordinated with transmission line routing. Access corridors which serve a
dual purpose in regard to project access needs would be highly desirable from
several decision-making criteria.• This poten t ial for increased access
provided by the transmission line routing is readily acknowledged elsewhere in
the Exhibit E (page E-5-84). This apparent inconsistency needs to be
clarified.
o Corridor Thirteen (ABCF) -Watana to Devil Canyon via South Shore, Devil
canyon to !ntertie via North shore, susitna River
. Environmental : Please refer to our connents above on Corridor One (ABCD).
(ix) Results and Conclusions: Paragraph 3: Reference is made to Exhibit G
which was not provided, although we requested it .
(e) Borrow Site Alternatives: Unless unavoidable, borrow sites should be
restricted to within the. future impoundments and/o r to upland sites.
Selection should be coord ~nated with access and transmission line routing and
with resource agencies. We have not previously been contacted for the purpose
of providing input an~ ~e do not have any project plans or assessments upon ~
which to provide specific i nput.
No attempt is offered to assess the environmental tradeoffs that would be made
by selecting one borrow site alternative over another. We have assumed this
is the underlying intent of including this type of alternatives comparison in
the environmental Exhibit E. We reconnend that this be undertaken to an equal
level for alternative borrow sites, access routes, transmission rou t es, and
other alternative project features.
10.3 -Alternative Electrical Energy Sources
{a) Coal-Fired Generation Alternative
There are three main deficiencies in the discussion of Beluga Coal development
as an alternative to the Susitna project:
1. No quantitative esti.ates of the areas or resources to be affected by
coal develo~nt are included. We recommend you include a description
of: {a) schedules for development; (b) area fish and wildlife
populations; {c) habitat types and areas to be disturbed, altered, or
destroyed; {d) construction and operation work forces necessary for
project development; (e) .. gnitude of commercial, recreational, and
subsistence use of Beluga area fish and wildlife resource; and (f)
numbers of fish and wildlife ~ich -.y be impacted by project develo~nt.
Ye realize that such inforaation is still very tentative for the Beluga
project and project i~acts have barely been evaluated. However, recent
field studies should allow you to approximate the magnitude of the
resources involved and potential for impacts to them.
2. A direct comparison with Susitna development plans and anticipated
i~acts is lacking. Comparison of the info~tion identified in 1.,
above, with similar information for the Susitna project should be
provided. For example, the c~rcial, recreational, and subsistence
harvests and pressures for use of the Beluga area should be ca.pared to
Susitna area resources. Acreages and habitat types that would be
impacted by alternative development scenarios should be compared. The
magnitudes of project impacts relative to fish and wildlife needs to be
analyzed. Also, the work force and time frue which would be required
for Susitna should be compared to Beluga developments, for the same power
needs.
3. Reasons for rejecting Beluga coal-fired generation or Beluga coal in
combination with smaller hydroelectric projects or other energy sources,
as an alternative to development of Susitna hydropower are not given.
Paragraph 1: Since we were not provided with a copy of Exhibit B, we cannot
com~ent on the adequacy of the referenced analysis of the econa.ic feasibility
of Beluga Coal. We would hope the analysis includes ~iscussion of private
financial backing for Beluga Coal developaent as compared to State financing
involved with the Susitna project. Further discussion of the feasibility of
alternative Beluga development schemes may be found in a State report by Gene
Rutledge, Darlene Lane, and Greg Edbla., 1980, Alaska Regional Energy
Resources Planning Project, Phase 2, Coal, Hydroelectric, and Energy
Alternatives, Volu.e 1, Beluga Coal District Analysis. Current soft foreign
market conditions are exemplified by recent slow downs of the most active
Beluga coal lease-holders in ca.pleting ongoing environmental studies
necessary for permitting. It would be helpful to know to what extent the
State is working with the private leaseholders to consider State use of any
portion of Beluga Coal production. We understand that the lease holders do
not expect to complete financial feasibility studies before the second half of
1983.
Paratia¥h 2: Although specifics o~ plant design and location are not yet
avai as e, more detailed information can be provided on the .agnitude, and
probable initial development alternatives, including export of Beluga coal to
Pacific Ri~ countries. We recommend addition of an area ~P with locations of
existing leases, potential camps and development facilities, and alternative
transportation and transmission corridors.
Para~a~h 3: We recaa.end expanding this paragraph to consider the
ava1~6 11ty and probability of coal developaent in Southcentral Alaska.
According to current industry plans, Beluga coal resources are sufficient to
allow mining for export of 5 million tons per year (with possible expansion to
10 million tons) on Beluga Coal Company leases and 6 to 13 million tons per
year fr~ the ZO,SOO acre Di.-ond Alaska Coal Company lease for at least 30
years~ The availability of this or other develo~nts as an energy
source for Alaska has been increased with recent State pr08Dtions of
additional coal exploration. The State has proposed a ca.petitive coal lease
sale during the first half of 1983 for ZS,OOO acres near Beluga Lake. Also
under consideration is a non-ca~petitive coal rights disposal west of the
Susitna River. Moreover, Bering River coal development has been the subject
of recent proposals for exploration and environmental studies.
(i) Existing Environmental Condition: As described earlier, the qualitative
discuss1on provided here allows no ca.parison with the Susitna project. We
recaaaend describing detailed U.S. Forest Service and Soil Conservation
Service data for .the area and ongoing studies which should result in a more
detailed classification of area vegetation.
The predominance of wetlands, particularly near the coast, are discernable on
FWS' National Wetland Inventory maps available for the area. Those wetlands
are particularly important habitats for the dfverse bird life described in
later paragraphs. ·
o Fauna, Paragraph 1: Clarfffcation is necessary regarding the referenced
•selvon fishery•.
Paragraph z: We recommend describing numbers of bald eagle and trumpeter swan
nests relative to numbers in the Susftna project area.
-Aguatic Ecosystem: Addftfonal information should be provided on the
quantity and quality of this syst.-(e.g. the extent to which spawning,
rearing, and overwintering areas have been identified withfn and downstream of
the lease areas).
-Marine Ecos,stem: Although species presence is described, there is no
quantftativenformatfon on thefr relat1~e abundance, or habftat qualfty.
Figures cfted for the referenced Cook Inlet fishery is dependent upon Beluga,
Susitna, and other area syste.s. An assessment of the proportion of that
fishery which depends on the Beluga systa. ca~pared to the Susitna system
should be provided.
19/ Beluga Coal Company and Diamond Alaska Coal Company. January 198Z.
OVerview of Beluga Area Coal Deve1o,.ent Projects.
-SocioeconOiiliC Conditions: The di scussion ~hould be expanded to cover
current levels of c~.~rc1al, subsistence, and recreational fish and wildlife
use.
(ii} Environmental IQpacts
-Air Quality: The potential for mitigating the air pollutants described here
should be d1scussed.
-Terrestrial Ecosystems: The range of terrestrial habitat to be annually
impacted should be quantified and c01npared with Susitna devel.opment plans. In
addition to habitats dhturbed by mining, project features such as roads and
tra.nsraission corridors which could be expected with coal developcaent should be
described. While the road systs required for coa 1 developgent should be
substantialy less than that for the Susitna project, the potential for
restoring mined lands to or'ig1nal habitat values is untested for the area.
Paragraph 2: ADF&G harvest data should be included here. The correlation
between hunting pressure and current access should also be discussed in
quantifying roads and human population increases anticipated from Beluga Coal
developaent. HuG~an/wi ldlife conf'l ic.ts (e.g. bears shot in defense of life or
property, wildlife gortality from additional vehicle traffic and roads) is
another critical i~:~pact not mentioned here.
-Aquatic and ~arine Ecosysterns: Sorne quantification of anticipated impacts
can be made and should be ;ncluded here. Developgent of both Beluga Coal
Company's and Diamond Alaska Coal Company's lease holdings could e.liminate
nine strealil-miles of existing anadromous and resident fish habitat. Stream
restoration to original habitat quality will be difficult, to impossible, to
attain. According to preli~:~inary flow information, nearly half the total flow
in the Chuitna River oriyinates in or flows throuyh the proposed mine pits.
Assuging that half the anadrOIDOus fish production is lost frog the Chuitna
system, ADF&G estima.tes the annual loss of fish available to Cook Inlet
fisheries will be within the following ranges:
Pink Salmon 70,000 -650,000
mean • 275,000
Coho Sa lmcm 5,250 -48,750
mean • 20,625
King Salaaon 2, 100 -19 ,500
mean • 8,250
ChUG Sa l1:10n 700 -6,500
mean • 2,750
Total Salr.10n 7s,oso -724,750
mean • 306,625
~e recocoend contrasting this information with prelfQinary i~act assessments
for Susitna and other alternative project developments in the license
application. The cOClparison should also cover resident fish spec 'ies, big game
and furbearer populations and harvest levels, and areas and types of habitats
to be altered or destroyed. Data gaps and uncertainties should be cl ;riffed
in an accogpanying discussion.
-Socioeconogic Conditions: Recently published reports by the ADF&G docu~aent
the magnitude of subsi~tence hunting and fishing by Tyonek area
residents.fQ/, £!/, 22/ Ue recoamend that you discuss these findings in
assessing fish and wildlife resource uses which ~ay be affected by Beluga coal
develop~t~ent.
A general discussion of the socioecon01i1ic impacts on Tyonek from developing
Susitna or Chakachagna hydropower projects, as compared to Beluga coal
development is given in a recent report for the ADCRA.23/ Tyonek apparently
supports coai development as long as it does not inhibit their ability to
subsistence hunt and fish. Consideration should be given to similar local
support or opposition to the Susitna project.
Although the purpose of this section is to describe Beluya as. an alternative
to Susitna, Beluga coal development would undoubtedly include additional
mining for export. Thus while the discussion appropriately describes the
incremental workers associated with the power generation facilities only, the
entire deve 1 opCJent w i 11 1 nf 1 uence the permanence of the workforce. -The report
is confusing in the disc~ssion on whether a fly-in construction camp or
perQanent townsite is to be established (see pages E-10-81(a) paragraph 3,
E-10-88, last two paragraphs, and E-10-89, paragraph 1). Some discussion is
needed of both alternatives, resultant impacts on fish and wildlife uses, and
the potential for mitigation.
20/ Foster, Dan. November 1982. The utilization of .king salmon and the
;J.nnual round of resource uses in Tyonek, Alaska. ADF&G, Division of
Subsistence, Anchorage. 62 pp. (see page 36 for data on fish and
wildife harvest).
W . t·1arch 1982. Tyonik moose utilization, 1981. ADF&G,
biv1sion of Subsistence, Anchorage. 29 pp. + appendices.
22/ Stanek, Ro.la Jd T., Jactes Fa 11, and Dan Foster. t1arch 1982.
Subsistence shellfish use in three Cook Inlet Villages, 1981: A
prelir.Jinary report. A[f'&G, Division of Subsistence, Anchorage. 28
pp.
23/ Darbyshire and Associates. Decertlber 1981. Socioeconomic ililpact study
of resource deve1opgent in the Tyonek/Beluga coat area. ~nchorage,
Alaska.
(c) Thermal Alternatives other than Coal
(i) Natural Gas: In that natural gas is con~idered by many to be the best
single source alternative to Susitna 24/, 25, it is disconcerting to see
so cinigal an effort expended exaoinin~ this alternative. The effort should
be at least equal to that provided to the assessment of altern~tive hydropower
sites and coal. Anything less must be considered inadequate. No examination
specific to natural gas in regard to potential environmental impacts is
provided nor is a tradeoff examination of natural gas, and other
alternatives. Without this, one cannot detergine whether or not a proposal is
the best of all alternatives.
Discussion should be provided on the potential impact of the recent signing of
natural gas supply contracts between the Enstar Corporation and Marathon and
Shell Oil Companies. Discussion should focus on the impacts of these
contracts, if approved, not only on allocated natural gas reserves, but also
on predicting future use, pricing, potential future deaand of electricity for
home heating through the ~atanuska-Susitna Borouyh, and future availability
an~ pricin~ of natural gas for electrical energy generation.
(iv) Environmental Considerations: It is unclear as to what this section is
in reference to. If ft is meant to cover all types of fossil fuel burning
power plants, it is insufficient. We do not consider the potential
environmental impacts of burning natural gas to be the same as for diesel,
oil, or coal. We recoamend that environmental considerations be examined
separately for each of these fuel alternatives. Then they should be examined
through a tradeoff analysis which would include Susitna, as proposed, other
hydropower projects, and alternative within basin alternatives, and other
alternatives to Susitna.
nuch of the section centers on the potential icpacts/probleas which would
occur with increased dependence on coal for power generation. Given that the
section is entitled (c) TherQal Alternatives other than Coal this would seerJ
inappropriate.
(f) Geothergal: This section fails to recognize, other than parenthetically,
the most attractive geothermal alternative, Mt. Spurr. We therefore,
recoggend that APA exagine the feasibility of geothermal energy development at
this site as an alternative to Susitna. ~lt. Spurr is being considered by the
Ohfsion of Uinerals and Ener~ Manager.Jent of the ADNR as their first
24/ Erickson, G.K. l·farch 1981. Natural Gas and Electric Power
Alternatives for the Railbelt. Legislative Affairs Agency, State of
A 1 aska. 9 pp.
25/ Tussing, A.R., and G.K. Erickson. August 1982. Alaska Energy Planning
Studies: Substantive Issues and the Effects of Recent Events
(Draft). Institute for Social and Economic Research, Uriversity of
Alaska. 15 pp.
geother~~l lease sale area. They concluded it is the best potential
yeothennal developgent site within their jur isdiction. It is. bein~ proposed
because: (1) it has high ~otential; (Z) it is located on State land; and (3)
it is close to existing transmission lines (Beluga Station). In addition, it
is in an area already being explored for power developraent, being located
between the Chakachatna River and the Beluga Coal fields, and the area is
crisscrossed by log!:fing roads. It would also seer.1 logical to explore the
possibility of a \Jest Cook Inle.t power gene.ration alternative to Susitna.
This coamination would be coq>osed of ~1t. Spurr geot.herr;aal, Chakachalil1a
hydropower, Beluga coal, and West Cook Inlet natural gas. Obvious advantages
would be found in the isolation of adverse environgental impacts to a
relatively small area which already has transmission facilities.
10.4 Environmental Conse uences of License Denial: This section provides
t e 1ns1 as to w a m1 t occur 1 us1tna were not built. We hope that
a greater planning effort is ongoing to allow the State to adequately address
this issue. It ~ould seem that the first approach to this problem would
involve a tradeoff analysis, looking at environmental as well as other issues,
to examine appropriate alternatives to the Susitna project. The ~~alysis
should be directed at: (1) short-term planning, in the event that Susitna is
delayed for various lengths of time; and (2) long-term planning so that we do
have a fall back plan in the event that Susitna is not licensed. We reco-.1end
that this be un c'ertak.en.
There is no ex~~:~ination of socioe.conor.~ic impacts in the event that the Sus.itna
project license is denied. We consider the potential for a boom-bust
occurrence to be great with construction of Susitna. Without Susitna we,
therefore, would consider this as r.auch less likely. In the event we do not
have Susitna, we would expect the construction of much s~aller powe r
generation units which would come on-line over a guch longer period of tiae.
We reco10101end that the socioeconOGiic i~lications of license denial be assessed.