HomeMy WebLinkAboutSUS10042TK
1425
.S8
S9
no. 10042
SUS 10042 (also 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.
• To Eric Yould, Executive Director, Alaska Power Authority
• From Esther Wunnicke, Commissioner, Alaska Dept. of Natural Resources
• 6 p.
This document is one of four agency memorandums addressed sent in January
1983 to Eric Yould. These memorandums are assigned individual SUS numbers
10040, 10041, 10042, and 10043.
These memorandums appear also in a collected document: Agency Comments on
Draft Exhibit E of Susitna Hydroelectric Project License Application : Comments by
NMFS, DEC, DNR, USFWS. -- SUS 347.
These submitted comments are in reference to: Susitna Hydroelectric Project FERC
License Application. Exhibit E / prepared by Acres. Draft. -- APA Document nos.
157-161.
(This explanatory sheet is supplied by Alaska Resources Library and Information
Services. Titles of memorandums are supplied from Susitna Aquatic Impact
Assessment Project Bibliography with corrections made by the cataloger.)
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:.'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