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Susitna-Watana Hydroelectric Project Document
ARLIS Uniform Cover Page
Title:
Appendix 1, Comment response table of FERC-filed comments
SuWa 77
Author(s) – Personal:
Author(s) – Corporate:
Alaska Energy Authority
AEA-identified category, if specified:
Revised Study Plan
AEA-identified series, if specified:
Series (ARLIS-assigned report number):
Susitna-Watana Hydroelectric Project document number 77
Existing numbers on document:
Published by:
[Anchorage, Alaska : Alaska Energy Authority, 2012]
Date published:
December 2012
Published for:
Date or date range of report:
Volume and/or Part numbers:
Final or Draft status, as indicated:
Document type:
Table
Pagination:
493 p.
Related work(s):
Comments to:
Alaska Energy Authority. Proposed study plan (SuWa 82)
Appendix 1 to:
Alaska Energy Authority. Revised study plan (SuWa 76)
Pages added/changed by ARLIS:
Notes:
All reports in the Susitna-Watana Hydroelectric Project Document series include an ARLIS-
produced cover page and an ARLIS-assigned number for uniformity and citability. All reports
are posted online at http://www.arlis.org/resources/susitna-watana/
Revised Study Plan
Susitna-Watana Hydroelectric Project
FERC No. 14241
Appendix 1
Comment Response Table of FERC-filed Comments
December 2012
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 December 2012
Appendix Arrangement: The comments and responses in this appendix are arranged by
resource area, following the order of the RSP sections.
Comment Code, RSP Study Title, and RSP Section Number Key
Comment
Code1 RSP Study Title (Resource Area) RSP Section Number
GEN General Comment No Particular Section of RSP
GS Geology and Soils 4.5
WQ Baseline Water Quality Study 5.5
WQMOD Water Quality Modeling Study 5.6
MERC Mercury Assessment and Potential for
Bioaccumulation Study 5.7
GEO Geomorphology Study 6.5
FGM Fluvial Geomorphology Modeling below Watana
Dam Study 6.6
GW Groundwater Study 7.5
ICE Ice Processes in the Susitna River 7.6
GLAC Glacier and Runoff Changes Study 7.7
IFS Instream Flow Study 8.5
RIFS Riparian Instream Flow Study 8.6
FISH Fish and Aquatic Resources General to Section 9 of RSP
FDAUP Study of Fish Distribution and Abundance in the
Upper Susitna River 9.5
FDAML Study of Fish Distribution and Abundance in the
Middle and Lower Susitna River 9.6
ESCAPE Salmon Escapement Study 9.7
RIVPRO River Productivity Study 9.8
AQHAB Characterization and Mapping of Aquatic Habitats 9.9
RESFSH The Future Watana Reservoir Fish Community and
Risk of Entrainment 9.10
PASS Study of Fish Passage Feasibility at Watana Dam 9.11
BARR Study of Fish Passage Barriers in the Middle and
Upper Susitna River and Susitna Tributaries 9.12
AQTRANS Aquatic Resources Study within the Access
Alignment, Transmission Alignment, and
Construction Area
9.13
GENE Genetic Baseline Study for Selected Fish Species 9.14
FHARV Analysis of Fish Harvest in and Downstream of the
Susitna-Watana Hydroelectric Project Area 9.15
EUL Eulachon Run Timing, Distribution, and Spawning
in the Susitna River 9.16
CIBW Cook Inlet Beluga Whale Study 9.17
WILD Wildlife Resources General to Section 10 of RSP
MOOSE Moose Distribution, Abundance, Movements,
Productivity, and Survival 10.5
CBOU Caribou Distribution, Abundance, Movements,
Productivity, and Survival 10.6
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 December 2012
Comment
Code1 RSP Study Title (Resource Area) RSP Section Number
DALL Dall’s Sheep Distribution and Abundance 10.7
LGCAR Distribution, Abundance, and Habitat Use by Large
Carnivores 10.8
WOLV Wolverine Distribution, Abundance, and Habitat
Occupancy 10.9
TERFUR Terrestrial Furbearer Abundance and Habitat Use 10.10
AQFUR Aquatic Furbearer Abundance and Habitat Use 10.11
SMAM Small Mammal Species Composition and Habitat
Use 10.12
BAT Bat Distribution and Habitat Use 10.13
RAPT Surveys of Eagles and Other Raptors 10.14
WTBRD Waterbird Migration, Breeding, and Habitat Use
Study 10.15
BREED Landbird and Shorebird Migration, Breeding, and
Habitat Use Study 10.16
PTAR Population Ecology of Willow Ptarmigan in Game
Management Unit 13 10.17
FROG Wood Frog Occupancy and Habitat Use 10.18
WLDHAB Evaluation of Wildlife Habitat Use 10.19
WHARV Wildlife Harvest Analysis 10.20
VWHAB Vegetation and Wildlife Habitat Mapping Study in
the Upper and Middle Susitna Basin 11.5
RIP Riparian Vegetation Study Downstream of the
Proposed Sustina-Watana Dam 11.6
WETLND Wetland Mapping Study 11.7
RARE Rare Plant Study 11.8
INVAS Invasive Plant Study 11.9
REC Recreation Resources Study 12.5
AES Aesthetic Resources Study 12.6
RECFLW River Recreation Flow and Access Study 12.7
CUL Cultural Resources Study 13.5
PALEO Paleontological Resources Study 13.6
SUB Subsistence Resources Study 14.5
ECON Regional Economic Evaluation Study 15.5
SOC Social Conditions and Public Goods Study 15.6
TRAN Transportation Resources Study 15.7
HEALTH Health Impact Assessment Study 15.8
AIR Air Quality Study 15.9
FLOOD Probably Maximum Flood Study 16.5
SEIS Site-Specific Seismic Hazard Study 16.6
1 Code corresponds to Appendix 2 coding of comment letters.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 December 2012
Commenter Acronym Key
Commenter
Acronym Commenter
ADEC Alaska Department of Environmental Conservation
ADNR-ADF&G Alaska Department of Natural Resources - Department of Fish and Game
ADNR-DF Alaska Department of Natural Resources - Division of Forestry
ADNR-DGGS
Alaska Department of Natural Resources - Division of Geological and Geophysical
Surveys
ADNR-DMLW Alaska Department of Natural Resources - Division of Mining, Land and Water
ADNR-DPOR Alaska Department of Natural Resources - Division of Parks and Outdoor Recreation
ADNR-OHA Alaska Department of Natural Resources - Office of History and Archaeology
AHP Alaska Hydro Project
AHTNA Ahtna, Inc.
AS Alaska Survival
BLM United States Department of the Interior – Bureau of Land Management
CCA Copper County Alliance
CCC Chase Community Council
CIRI Cook Inlet Region, Inc.
CSDA Coalition for Susitna Dam Alternatives
CWA The Center for Water Advocacy
EPA United States Environmental Protection Agency
FERC Federal Energy Regulatory Commission
HRC Hydropower Reform Coalition
NHI Natural Heritage Institute
NMFS
United States Department of Commerce – National Oceanic and Atmospheric
Administration
NPS United States Department of the Interior – National Park Service
NRDC Natural Resource Defense Council
TCCI Talkeetna Community Council, Inc.
TNC The Nature Conservancy
TU Trout Unlimited
USFWS United States Department of the Interior – Fish and Wildlife Service
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 1 December 2012
Appendix 1
Alaska Energy Authority’s (AEA) Response to Comments on the Proposed Study Plan (PSP) and Interim Draft Revised Study Plan (RSP)
(Letters filed with FERC November 1 through 14, 2012)
General / Global
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
GEN-01 NPS 11/14/2012 “AEA could be doing more to meet the requirements of
18 CFR 5.11 (b )(3), which requires applicants to
include, for each study in its PSP, "Provisions for
periodic progress reports, including the manner and
extent to which information will be shared; and
sufficient time for technical review of the analysis and
results.” – pdf page 2
As explained in Section 1.2 and in each individual study plan in the RSP,
AEA will be meeting requirements of 18 CFR 5.11(b)(3) through periodic
TWG meetings scheduled quarterly through 2013 and 2014. The purpose of
these meetings will be to update licensing participants with information on
study progress and initial results, as available. In accordance with the
Communication Protocol, AEA will strive to make meeting summaries
available on its website within 15 days of these quarterly meetings, with
comments provided within 15 days of posting.
GEN-02 TU 11/14/2012 A two year study is inadequate to understand the
potential impacts and make informed decisions
regarding the project. – pdf page 2
AEA believes that the study plans set forth in the RSP will provide sufficient
information to make informed decisions regarding the proposed Project.
Depending on information needs, each study plan in the RSP proposes one
or two years of study. These study plans have been developed to
supplement the existing information summarized in the PAD and baseline
data collected during the 2012 field season. The proposed Project has been
the focus of many years of study dating back to the 1950s, and a wealth of
information already exists related to the Project and its environs. Historic
information is being used, where appropriate, to help assess the issues
raised during scoping.
Specific resource information will be collected in 2013 and 2014. In so doing,
these study plans adequately address issues associated with construction
and operation of the proposed Project. By properly utilizing existing data,
2012 baseline information, and results of the 2013-2014 licensing studies,
AEA’s License Application and state and federal regulatory agencies’
environmental analyses will make well-supported, informed impact
assessments and decisions related to the proposed Project.
AEA understands, however, that assessments related to data adequacy must
be addressed on an individualized, study-specific issue. For this reason,
where licensing participants’ comments raised questions related to length of
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 2 December 2012
General / Global
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
the proposed studies for specific resource areas, this comment response
table provides a resource-specific response to this issue in the applicable
sections of this table.
GEN-03 TU 11/14/2012 The PSP fails to “adequately evaluate and synthesize
the existing data and information already available
about the affected area.” – pdf page 3
A goal of the RSP is to provide a summary of the existing information to
assist the reader in understanding the study plan itself. Each section of the
RSP includes a detailed summary and evaluation of existing data and
information, as required by FERC’s ILP regulations. 18 CFR 5.11(d)(3). In
addition, the Pre-Application Document (PAD) provides a synthesis of the
existing information for each resource. In light of the wealth of information
collected in the 1980s, as the studies move forward in 2013 and 2014, AEA
will continue to integrate historic information into each study, as appropriate,
as the data is analyzed.
GEN-04 NRDC 11/14/2012 Request that AEA is required to conduct over two years
of study. A minimum of five years is suggested. –pdf
pages 4-7
See AEA’s response to comment GEN-02.
GEN-05 NRDC 11/14/2012 Data collected in the 1980s is outdated and inadequate
when using to describe existing environmental
conditions. –pdf pages 7-8
FERC’s ILP regulations specifically recognize the value of existing
environmental information regarding a proposed project. At the very
beginning of the licensing process, a prospective applicant such as AEA is
required to prepare a PAD that assembles “existing, relevant, and reasonably
available information,” and to provide the PAD to resource agencies and
other licensing participants for purposes of identifying issues and developing
study needs. 18 CFR 5.6(b(1). When preparing its study plan, moreover,
the prospective applicant is required not only to describe existing information,
but to explain “the need for additional information.” 18 CFR 5.11(d)(3).
Indeed, there is no scientific justification for disqualifying information as
“outdated” and “inadequate” simply because it exists—particularly where
baseline conditions have not changed since the collection of the data.
FERC’s ILP regulations recognize this by requiring prospective applicants to
devote considerable resources in identifying existing, relevant information
instead of completing an entirely new, comprehensive suite of studies in
every licensing proceeding.
With regard to this proposed Project, AEA believes as a general matter that
use of the 1980s data provides context for data collected in 2012, 2013 and
2014. Further, historic data is useful to ascertaining environmental baseline
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 3 December 2012
General / Global
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
and assessing longer-term trends.
This does not mean, however, that AEA plans simply to revive and re-
package the 1980s-era data. As explained in each of AEA’s proposed 58
individual study plans, AEA proposes not only to use the 1980s-era studies,
but to build upon this wealth of existing data with additional studies and
analyses.
See also AEA’s response to comment GEN-39.
GEN-06 CWA 11/14/2012 There is a “lack of coordination in the Study Plan
process, as illustrated, in part, by AEA’s failure to
produce a "Critical Path" document showing how the
data collection and analysis components of the various
studies are intended to interrelate.” – pdf page 2
A detailed overview of the study plan process appears in Section 2 and
includes a detailed study plan schedule at Attachment 2-1, which has been
prepared at FERC’s request. See AEA’s response to comment GEN-41.
In addition, for each of the 58 studies proposed in the RSP, AEA has
included a section entitled “Relationship with Other Studies.” This section
provides a detailed narrative on how the study uses outputs from other
studies and/or provides inputs to other studies. These interdependencies
also are illustrated graphically in each study plan. Although this level of
detail is not required by FERC’s ILP regulations, AEA believes it important for
all licensing participants to understand the relationships within the RSP and
stay coordinated on these matters.
GEN-07 CSDA 11/14/2012 Request for a biometric review of the 1980’s Susitna
Hydroelectric Project. – pdf page 4
AEA is not conducting a biometric review of the data collected in the 1980s
for the Project. Instead, each study plan in the RSP describes the extent to
which—if any—AEA is relying upon the1980s-era data and how that data will
be used to meet the goals and objectives of the study plan.
See also AEA’s response to comment GEN-39.
GEN-08 CSDA 11/14/2012 CSDA expresses concerns about the relationship
between the wildlife resources investigations and the
application to project impacts on the ecosystem,
asserting that “there are not adequate impact
assessment analyses to understand the ecological role
that species have in the ecosystem.” CSDA asserts
that “[t]here needs to be knowledge of complex
ecological relationships between fish, wildlife, and
AEA’s RSP has been prepared in accordance with FERC’s ILP regulations,
following consultation with CSDA and other licensing participants. While the
58 individual study plans are drafted separately to facilitate fieldwork across
several disciplines, AEA recognizes that the impacts analysis related to the
Project must be multi-disciplinary. AEA’s Environmental Exhibit component
of its License Application, upon which will be supported by the studies
prepared during the licensing process, will conform with FERC’s “Preparing
Environmental Assessments: Guidelines for Applicants, Contractors, and
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 4 December 2012
General / Global
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
vegetation from field studies.”– pdf pages 6-7 Staff.” 18 CFR 5.18(b).
While many of the ecological relationships of fish, wildlife and vegetation will
be explored in AEA’s License Application, several of the study plans in the
RSP contemplate ecological-based investigations that cut across multiple
disciplines. For example, the IFS Analytical Framework integrates the
analysis of Project effects on riverine processes. Project effects on
geomorphology, ice processes, water quality and groundwater/surface water
interactions will be used to quantify changes in fish and aquatic habitat and
riparian indicators (Section 8.5.4.1). The Evaluation of Wildlife Habitat Use
will use information from the botanical and terrestrial studies to provide
Project-specific habitat evaluation information for birds, mammals, and
amphibians (Section 10.19.4). The River Productivity Study will investigate
the contribution of marine-derived nutrients from spawning salmon to
freshwater ecosystems (Section 9.8.4.5.2).
GEN-09 CSDA 11/14/2012 “The ILP study plan process must be transparent. The
data at every stage must be available to the public. We
request that the studies be peer reviewed. The global,
national, and regional environmental consulting firms
AEA is now using are big for-profit businesses. Peer
reviews of the completed studies will give the public
confidence in the study data and results.” – pdf page 7
As explained in Section 1.1 and demonstrated by Appendices 1 through 4 of
this RSP, the ILP study process has been open and collaborative. During
the study implementation phase, AEA is required under FERC’s ILP
regulations to provide periodic progress reports during the study phase, and
as explained in Section 1.2 and each of the individual study plans, AEA plans
to convene quarterly TWG meetings in 2013 and 2014. See also AEA
response to comment GEN-01.
AEA has not adopted the request to obtain formal peer review of licensing
studies. FERC’s ILP regulations do not require study reports to be peer
reviewed, and the study reports in this in this process will be subject to expert
review and scrutiny by all licensing participants, including AEA, AEA’s
technical consultants, FERC, FERC’s third-party contractor, federal and state
resource agencies, agencies’ technical consultants, Alaska Native entities,
and the environmental community.
GEN-10 Various
Individuals
11/07/2012
–
11/14/2012
Request for all data and conclusions to go through a
peer review process.
See AEA’s response to comment GEN-09.
GEN-11 Long, Becky 11/13/2012 Two years of study is inadequate. –pdf page 1 See AEA’s response to comment GEN-02.
GEN-12 Long, Becky 11/13/2012 A Biometric Study of the historic studies has been See AEA’s response to comment GEN-07.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 5 December 2012
General / Global
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
requested by the federal agencies. This needs to
happen.” –pdf page 2
GEN-13 Various
Individuals
11/07/2012
–
11/14/2012
Two year study is inadequate; studies should be
completed over request 5 to 7-year timeframe.
See AEA’s response to comment GEN-02.
GEN-14 Various
Individuals
11/07/2012
–
11/14/2012
Consider impacts and merits of dams on other rivers. Where relevant, the study plans in the RSP have considered the effects and
merits of dams on other river systems. For example, the river ice model was
developed in part on other river systems that have load-following (Section
7.7). At the same time, the study plans in the RSP—as required by the
Federal Power Act (FPA) and National Environmental Policy Act (NEPA)—
are designed to identify and analyze effects of the proposed Project.
GEN-15 Various
Individuals
11/07/2012
–
11/14/2012
Given thirty years in climate, population, data gathering
techniques and the river, use of the 1980s data is
inadequate in decision making.
See AEA’s response to comment GEN-05.
GEN-16 Various
Individuals
11/07/2012
–
11/14/2012
Consider impacts and merits at a national and global
level.
AEA does not believe it appropriate to establish a national or global scope for
the study plans in the RSP. As detailed in Section 3.1.5, the FPA requires
FERC to ensure that a proposed project “is best adapted to a comprehensive
plan for improving or developing a waterway,” and does not require a broader
public interest evaluation. 16 U.S.C. 803(a)(1). The study plans in the RSP
are appropriately scoped to allow FERC to fulfill its FPA and NEPA
responsibilities.
GEN-17 Teich, Cathy 11/14/2012 “Viable energy alternatives have not been considered
in your studies and should be. Dams are archaic and
many of them are being torn down in the lower 48. You
need to offer a no-action alternative.” –third paragraph
for Teich, Cathy (2) file –pdf page 1
AEA will include an alternatives analysis in its License Application, and
FERC’s NEPA document will include Project alternatives, including a no-
action alternative. However, specific studies are not needed for these
alternatives analyses, as AEA believes that existing information and the
studies in the RSP will support alternative analyses.
GEN-18 CCC 11/15/2012 “Lack of Integration and Coordination among Study
Plans” –pdf page 2
See AEA’s response to comment GEN-06.
GEN-19 CCC 11/15/2012 “The two-year study period proposed for studies is
inadequate” –pdf pages 2-3
See AEA’s response to comment GEN-02.
GEN-20 CCC 11/15/2012 “There is no discussion of the potential impact from
emergency actions.“ –pdf page 3
Should FERC issue a license for the proposed Project, FERC will require
AEA to develop an emergency action plan (EAP). This is standard practice
at large FERC-licensed hydropower projects. AEA will be required to
conduct annual functional exercises with local authorities. As required by
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 6 December 2012
General / Global
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
FERC’s project safety regulations, specifics of the EAP would be developed
with FERC and the local and State authorities.
In addition, as detailed in Sections 16.5 and 16.6, AEA will be conducting
Site-Specific Seismic Hazard Study and Probable Maximum Flood Study to
ensure that the dam is designed and operated in a safe manner.
GEN-21 CCC 11/15/2012 “It appears that assumptions regarding costs and rates
are based only on power optimization scenarios.“ –pdf
page 3
As detailed in Section 8.5, AEA will be conducting studies to assess various
operational modes. AEA is using the environmental flows proposed in the
1980s as a starting point for assessing project operation scenarios. AEA
plans to investigate full load-following, partial load-following based on primary
use of load-following from other existing hydro power projects like Bradley
Lake, Eklutna and Cooper Lake. AEA recognizes that maintenance of
ecosystem functions may require an assessment of other operational
scenarios. These will be developed as resource needs are identified through
the environmental resource assessments.
GEN-22 FERC 11/14/2012 “We recommend that [AEA’s] RSP clearly track all
differences between [its] study proposal and the
requested studies, as well as any future comments
[AEA] receive[s] on the draft RSP. [AEA’s] filing must
include an explanation of why any components of the
study requests are not adopted.”— pdf page 22.
As detailed in Section 1.1, AEA has been working closely with federal and
state resource agencies and other licensing participants over the last year to
develop this study plan. Following AEA’s development of the PSP, AEA
continued to consult with licensing participants on the PSP, which led to
AEA’s release of an interim draft RSP at the end of October 2012. AEA’s
response to comments received during the numerous TWG and other
meetings held during this phase appear in Appendix 3, and documentation
supporting these comments (e.g., meeting summaries, e-mail messages)
appear in Appendix 4.
With regard to the RSP, this Appendix 1 sets forth AEA’s response to
licensing participants’ written comments filed with FERC after November 1,
and participants’ written comments appear in Appendix 2.
Finally, at the request of USFWS and NMFS, AEA has prepared a written
“crosswalk” table that compares these agencies’ original study requests and
the RSP. AEA is providing this “crosswalk” table to these agencies and
FERC concurrently with its filing of the RSP.
GEN-23 FERC 11/14/2012 “Adaptive Study Implementation. In multiple study
plans, you propose to modify the methods or
The individual study plans in the RSP have been modified and expanded
considerably to clearly describe any future decision making. In each
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 7 December 2012
General / Global
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
geographic scope of the study in response to
preliminary study results (e.g., Geomorphology
(Section 5.8), Fluvial Geomorphology Modeling
(Section 5.9), Water Quality (Sections 5.5, 5.6, and
5.12), Fish and Aquatics Instream Flows (Section 6.5),
and Fish Distribution and Abundance (Sections 7.5,
7.6)). For each of these studies, the RSP should clearly
describe any decision-making process or schedule by
which study methods would be refined or adapted in
consultation with agencies and other stakeholders
during the study implementation period, including any
criteria that will trigger changes in the study plan.” –pdf
page 4
instance in which a future decision is necessary, the study plan includes a
process, schedule and criteria that will govern the decision.
GEN-24 FERC 11/14/2012 “All individual study plans within your RSP should use
consistent language and terminology throughout the
document for terms such as: study site, intensive site,
habitat type, study area, focus area, reach, and river
segment. Provide a clear description of the relationship
between studies. Figures depicting study
interdependency should refer to applicable study plan
sections or subsections where appropriate, and the
respective study plan sections should describe
interdependencies so that the reader understands what
specific information is being used in what studies,
where it comes from, how results will be presented,
how they will be used, etc.”–pdf page 5
When preparing the RSP, AEA has taken great care to use consistent
language and terminology across all 58 individual study plans. A List of
Acronyms and Scientific Labels appears after the table of contents to the
RSP. While AEA has made a good faith effort to be consistent with language
and terminology, it notes that this RSP spans over 2,000 pages and
represents the work of dozens of professionals. Given the scope of this
undertaking, some minor inconsistencies are inevitable.
With regard to independencies between study plans, please see AEA’s
response to comment GEN-06.
GEN-25 FERC 11/14/2012 “In some cases, you have developed plans for and are
carrying out studies in consultation with stakeholders to
voluntarily collect information in 2012 that will help you
prepare or refine a study plan. Please describe how
these 2012 efforts were or are being incorporated into
the RSP.” -pdf pages 5-6
Section 1.4 and Attachment 1-1 detail AEA’s 2012 study efforts. Where AEA
proposes to use the results of the 2012 studies to inform the 2013-2014
studies in the RSP, the individual study plan explains how the 2012 studies
will inform or be incorporated into the 2013-2014 study effort.
GEN-26 ADNR-DF 11/14/2012 “The DF requests an inventory of the trees and
biomass in the impoundment area and an evaluation of
the potential for salvage. If viable, the project should
AEA has not adopted this information request in any study plan in the RSP,
as this requested information is not needed for purposes of FERC’s licensing
of the Project. AEA anticipates working with ADNR-DF and BLM on this
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 8 December 2012
General / Global
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
ensure salvage is undertaken. The DF is available to
offer assistance with this assessment of the
impoundment area.” –pdf page 4
issue separately, outside the FERC process, prior to the clearing of the
reservoir.
GEN-27 ADNR-
ADF&G
11/14/2012 “Study plans need to stand alone. Methods in these
plans often refer to other studies which often do not
provide specific information to the topic under
discussion or repeat additional information already
summarized in the lead study. It is preferable that
studies describe what data is needed from other
studies and how it will be used without repeating the
methods for obtaining the data – that information
should remain within the originating study.” –pdf page
18-19
AEA has decided to organize study plans by resource area, to take
advantage of common background issues related to all studies in each
resource area.
When preparing the RSP, AEA took great care to explain the
interdependencies of all proposed studies. See AEA’s response to comment
GEN-06.
GEN-28 ADNR-
ADF&G 11/14/2012 “Sampling plans need to include a thorough description
of methodology, sampling and QA/QC procedures, etc.
In general, more information is needed on sampling
protocols, timing, location(s) and site selection criteria.”
– pdf page 19
When preparing the RSP, AEA significantly expanded discussions on
proposed methodologies, federal and state protocols, sampling and quality
control procedures, schedules, and decision-making criteria. Many of these
changes are based upon consultation among AEA, ADF&G, and other
licensing participants.
GEN-29 ADNR-
ADF&G 11/14/2012 “include a list of definitions of key terms for each study
plan. We understand different specialties often have
their own terminology and a list of definitions would
help to better understand differences.” –pdf page 19
A List of Acronyms and Scientific Labels appears after the table of contents
to the RSP. In addition, each resource area has an individual glossary,
where necessary. For example, Hydrology-Related Resources (Section 7),
Instream Flow (Section 8), and Fish and Aquatics (Section 9), all have an
attached glossary.
GEN-30 ADNR-
ADF&G 11/14/2012 “Protocols for sampling methodologies should not
simply reference state or federal protocols. Many of
these may not exist. Citations should refer to specific
scientific methods, references or manufacturer
instructions.” –pdf page 19
See AEA’s response to comment GEN-28.
GEN-31 EPA 11/14/2012 EPA comments that the PSP/RSPs lack the five crucial
steps for developing a conceptual ecological models
with linked indicators for important resources:
1. Identify the biological and ecological resources of
concern;
2. Identify key attributes of each resource that
characterize or shape its integrity, including natural
AEA believes that the FERC licensing process, prescribed by regulation,
adequately satisfies the steps identified in EPA’s comments related to the
development of ecological models. Early in the process, during the
preparation of the PAD, the prospective applicant must reach out to federal
and state resources and gather existing relevant information of the project
and its environs. 18 CFR 5.6(b). Using this existing information, the PAD
describes the existing environment and resource impacts, including geology
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 9 December 2012
General / Global
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
driving processes and natural environmental
constraints;
3. Identify indicators with which to measure the status
(integrity) of each resource and its key attributes, and
potentially also to model the likely impacts of the
proposed project;
4. Identify the natural or acceptable (aka reference)
range of variation for each indicator; and
5. Establish a scale for rating the implications for
resource integrity associated with departures from
these reference ranges. -pdf pages 8-9.
and soils; water resources; fish and aquatic resources; wetland, riparian, and
littoral habitat; rare, threatened and endangered species; recreation and land
use; aesthetic resources; cultural resources; socioeconomic resources; tribal
resources; and a description of the river basin. 18 CFR 5.6(d)(3). The PAD
also includes a preliminary issues list, and federal and state resource
agencies and other licensing participants have an opportunity to comment on
the PAD. 18 CFR 5.6(d)(4), 5.8(b). FERC then issues a scoping document,
convenes an environmental scoping meeting and site visit, and solicits
comments on the scoping document. 18 CFR 5.6. Following the scoping
process, the prospective applicant develops a proposed study plan—a
process that, as described in Section 1.1, has taken AEA nearly a year to
complete, in close consultation and collaboration with licensing participants.
As a result of this iterative, consultative process, AEA believes that the FERC
ILP process unquestionably develops ecological models and an integrated
framework for evaluating resources, as illustrated throughout the RSP. For
example, the Fish and Aquatics Instream Flow Study—one of the few studies
EPA reviewed in detail—clearly shows and describes the development of a
number of flow sensitive models that are linked to important ecological
processes related to fish and aquatic biota (Section 8.5.4.1; Figure 8.5-10).
The framework represents a measurement-oriented approach to assessing
the relationship of hydrologic and geomorphic variables to the biological and
ecological resources of concern. Stressors associated with Project effects
include changes in the volume, timing and quality of instream flow, and
changes in ice processes and sediment and large woody debris transport.
The effects of these stressors on resources of concern will be evaluated
using indicators that measure changes in habitat suitability, quality and
accessibility. Reference conditions establish the range of variation for each
indicator and will be defined by analysis of unregulated flows under average,
wet, dry, hydrologic conditions and warm and cold Pacific decadal oscillation
phases. Project effects under alternative operational scenarios are defined
as departures from the reference conditions. This framework—and the
numerous others throughout the RSP—provides the tools to identify
operational scenarios that balance resource interests and quantify any loss
of aquatic resources and their habitats that result from Project operations.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 10 December 2012
General / Global
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
See also AEA’s response to comment GEN-08.
GEN-32 EPA 11/14/2012 EPA comments that in addition to the two key variables
affecting fish utilization of the river system identified in
AEA’s PSP (microhabitat and macrohabitat), “[a] review
of the PSP/RSP information on other aspects of the
aquatic ecosystem – e.g., primary production; benthic
macroinvertebrates; non-economic fishes; use of the
river and its floodplain by insets, birds, and mammals;
etc. – would result in the identification of other key
ecological attributes for the aquatic (or aquatic +
riparian) ecosystem as a whole.” – pdf page 10
The RSP proposes to study key variables identified in EPA’s comment, as
well as others, that affect fish utilization of the river system, including the
following: Baseline Water Quality Study (Section 5.5); Water Quality
Modeling Study (Section 5.6); Mercury Assessment and Potential for
Bioaccumulation Study (Section 5.7); Riparian Instream Flow Study (Section
8.6); Study of Fish Distribution and Abundance in the Upper Susitna River
(Section 9.5); Study of Fish Distribution and Abundance in the Middle and
Lower Susitna River (Section 9.6); River Productivity Study (Section 9.8);
Aquatic Resources Study within the Access Alignment, Transmission
Alignment, and Construction Area (Section 9.13); Genetic Baseline Study for
Selected Fish Species (Section 9.14); Distribution and Abundance, and
Habitat Use by Large Carnivores (Section 10.8); Aquatic Furbearer
Abundance and Habitat Use (Section 10.10); Riparian Vegetation Study
Downstream of the Proposed Watana Dam (Section 11.6); and Wetland
Mapping Study (Section 11.7).
GEN-33 EPA 11/14/2012 EPA comments that neither the Geomorphology Study
and Fluvial Geomorphology Modeling below Watana
Dam Study “provides a ‘map’ of how the variables they
propose to measure provide information on the actual
key microhabitat and macrohabitat variables of interest,
let [alone] support this map with a review of the
literature on how these relationships operate. Without
such a map, stakeholders cannot reliably assess
whether the proposed surrogate indicators are the right
ones to study.” EPA expresses the view that
“developing such conceptual models should be the
responsibility of the teams developing the PSP/RSPs
and their partner Technical Working Groups.” -pdf page
11
A conceptual model ‘map’ of how geomorphic variables are used to develop
key microhabitat and macrohabitat indicators is now provided as Figure 6.1-
1. As described in RSP Section 6.6.4.3.2.2, the Fluvial Geomorphology
Modeling below Watana Dam Study includes both reach-scale and focus
area scale analyses to provide input to Fish and Aquatic and
Riparian Instream Flow Study indicators. The process includes the
evaluation of unregulated flows and alternative operational scenarios under
existing channel conditions and analyses at future time steps to reflect
potential future changes in channel morphology.
GEN-34 EPA 11/14/2012 EPA comments that the PSP “does not ask nor attempt
to answer any questions concerning the acceptable
range of variation with respect to any of the hydrologic
and geomorphic variables that are proposed for study.”
EPA requests AEA to consider using Amy Corps of
As described in Section 8.5.4.4, an acceptable range of variation in indicator
condition will be identified by evaluating existing, unregulated flows over
individual water years selected to represent average, wet and dry hydrologic
conditions and warm and cold Pacific decadal oscillation phases. In addition,
a multi-year, continuous flow record will be evaluated to identify year-to-year
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 11 December 2012
General / Global
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
Engineer HEC EFM (Ecosystem Functions Model)
program. - pdf pages 13-14
variations independent of average, wet or dry conditions. The selection of
representative hydrologic conditions and the duration of the continuous flow
record will be developed in consultation with the TWG in Q4 2013. The
IHA/EFC type statistics described in Section 8.5.4.4.1.3 represent one
approach to developing comparative evaluations between existing conditions
and alternative operational scenarios. The USACE HEC-EFM is another
planning tool that aids in analyzing ecosystem responses to changes in flow.
The merits of these planning tools will be discussed with the TWG in Q3
2013, and if HEC-EFM is deemed preferable by the TWG it will be used to
support the evaluation of potential Project effects on resources of concern.
GEN-35 USFWS 11/14/2012 “Study Plan/Study Request Crosswalk: As stated
above, the Service submitted 21 study requests. AEA's
PSP contained 58 individual study plans, organized into
11 natural resource sections, and by topic within each
section. Following a comprehensive review of the plan,
the Service found 27 of the individual study plans from
5 natural resource sections addressed elements of the
study requests that we provided. It has been previously
recommended that AEA provide a comparison of
agency study requests and AEA proposed study plans
and identify any unaddressed study request or study
request components to assist our review of the PSP.
FERC has affirmed AEA's need to provide this cross-
walk comparison of study requests and the PSP. This
study request PSP comparison is necessary in part due
to the altered organization of AEA's PSP which differs
significantly in organization from the Service's study
requests. The issue will gain significance as we
continue our review of the draft RSP, as again, the
individual study plans are reshuffled and renumbered
adding more confusion about which study plans now
address our study requests.” –pdf page 2
As noted in Section 1.1.4, AEA has prepared the requested crosswalk table
and is providing it to USFWS, NMFS, and other licensing participants under
separate cover, concurrent with the filing of the RSP.
See also AEA’s response to comment GEN-22.
GEN-36 USFWS 11/14/2012 “[T]he Project would benefit if there was a clear plan
describing the strategies for information exchange and
integration between the various studies and their
respective Principal Investigator(s). This integration
See AEA’s response to comment GEN-06.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 12 December 2012
General / Global
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
plan should discuss how model results will be
documented and how the information will be provided
in a format that is clear and accessible to the other
studies. The plan should acknowledge the potential
challenges that may be encountered and strategies for
dealing with these challenges.”
“We recommend that AEA develop a cross-walk for all
the studies to help clarify their inter-relationships, and
then clearly describe how each study may depend on
other studies.”-pdf page 3
GEN-37 USFWS 11/14/2012 “Study methodologies: The study methods should be
described in sufficient detail so others can duplicate the
study. Citing methods from other studies or accepted
industry standards is encouraged, but not in lieu of
providing sufficient detail so the methods can be
evaluated without having to refer to the citation. The
July 2012 PSP provided few referenced methods;
some methods with references lacked citations in the
Literature Cited so their appropriateness could not be
evaluated, and some methods lacked focus or
duplicated methods from other objectives.
Since the PSP, AEA hosted TWG meetings and site
visits, including the most recent 24 October 2012 TWG
meeting, which provided additional opportunities for
discussion and clarification. We look forward to seeing
these improvements in the RSP and subsequent
iterations.” –pdf pages 3-4
See AEA’s response to comment GEN-28.
GEN-38 USFWS 11/14/2012 “Botanical studies: There is much overlap in the
methods and study areas for the Botanical Studies.
This is somewhat confusing when considering these
studies together, but a little less so when the studies
stand alone. AEA should be concerned that they could
potentially be headed toward duplicative and
contradictory work, and need to consider how to
The two riparian studies (Riparian Vegetation Study Downstream of the
Propoased Watana Dam (Section 11.6) and Riparian Instream Flow Study
(Section 8.6)) have been revised significantly since the PSP to, among other
things, improve the coordination between the individual study plans. In the
Riparian Vegetation Study Downstream of the Propoased Watana Dam
(Section 11.6), detailed data will be collected on existing vegetation and
soils, existing riparian vegetation in the Susitna River floodplain will be
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 13 December 2012
General / Global
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
coordinate the Service's study request to quantify the
frequency, timing, and duration of surface and
groundwater required to maintain riparian communities.
The responsibility for this product seems to be
scattered among at least three studies and their
principal investigators (Groundwater, Riparian ISF, and
Riparian Botanical). The result is a confusing strategy
within the PSP; these resource questions have not
been appropriately addressed in an integrated manner.
The Service is unclear about how our request will be
addressed, and it seems that AEA is confused about
how to tackle it. To date, the TWG meetings have failed
to entertain meaningful discussion on this topic. We
reiterate the need for the TWG meetings to be less
focused on PowerPoint presentations and more
interactive which may allow for more meaningful
discussions of these interrelated botanical studies and
their relationship to the groundwater study.” –pdf page
4
mapped, and vegetation succession will be modeled. The data collected in
Focus Areas (previously Intensive Study Reaches) and the successional
modeling results from the Riparian Study will then be used by researchers in
the Riparian Instream Flow Study (RSP Section 8.6) to prepare a spatially
explicit model to predict Project-influenced changes in riparian vegetation
across the floodplain study area. Researchers in the Instream Flow Study
also will be responsible for incorporating information from the Groundwater
Study (Section 7.5), Fluvial Geomorphology Modeling below Watana Dam
Study (Section 6.6), and Ice Processes in the Susitna River Study (Section
7.6) in their modeling to predict Project-influenced changes in riparian
vegetation. More details on the collaboration between the various studies are
provided in Sections 11.6.4.2, 11.6.4.4, 11.6.7, and 8.6.
GEN-39 USFWS 11/14/2012 “Historic Data and Study Results: The Service remains
concerned that AEA has not yet adequately evaluated
and characterized all available historic (1980s)
information relevant to the existing Project
environment. As we move forward with the current
study plan, lack of an evaluation of the previous studies
is problematic for several reasons.
First, the historic and contemporary studies have not
been comprehensively synthesized, so it is difficult to
fully understand where we are and where we need to
proceed in evaluating this Project proposal.
Second, the statistical validity of study results from the
1980s investigations remains unknown. (See our
comment letter (December 20, 2011) requesting a
biometric review of the data.} Third, we are concerned
As contemplated by FERC’s ILP regulations, AEA has expended a significant
effort to synthesize the 1980s data. The results of the initial synthesis were
presented in the Pre-Application Document (PAD). See AEA’s response to
comment GEN-05.
AEA notes that over 3,000 documents were produced during the intensive
studies of the 1980s. AEA will continue to review this information and
include relevant information in the currently proposed studies. This effort will
continue through 2013 and 2014.
Although the proposed APA project in the 1980s was different than the
anticipated RCC proposed Project today, the historic environmental
information remains relevant, including from an historic and trends
perspective. Further, the impacts assessment should not be discounted.
Much of the assessment contained in the 1983 application, FERC’s draft EIS,
and the 1985 amended License Application may be useful for comparison of
the impact assessment to be completed for the 2015 License Application.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 14 December 2012
General / Global
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
that the scope of studies conducted in the 1980s, when
the Project design was quite different, is not adequate
to assess potential environmental effects of the
currently propose Project. Past studies only
concentrated on a few fish species and potential effects
to their macrohabitats; additional data are needed to
evaluate potential Project effects on downstream
habitats.
Moreover, technological advancements since the
1980s in the areas of tracking fish, genetics, and study
methodologies can now be used to better understand
relationships between fish and their habitats, in order to
better inform the design of a Project with fewer,
environmental impacts, and to better assess those
potential impacts. Finally, the 1980s project studies
were discontinued, therefore those study results were
never evaluated or completed to develop final
recommendations.” –pdf page 4
AEA concurs that supplemental information should be collected and has
included objectives and methodologies for collecting additional habitat and
fisheries data in the RSP. AEA also agrees that technological advancements
have been made since the 1980s and the RSP has been developed to
capitalize on those advancements. The 2015 License Application will utilize
the current studies and the historic information to develop protection,
mitigation and enhancement measures, as appropriate.
GEN-40 USFWS 11/14/2012 “Adherence to the [process plan, schedule and
communications protocol] is essential for guiding the
application development process in a collaborative,
structured, complete and timely manner. Sharing that
goal, the Service requests that FERC and AEA comply
more fully with this plan, including maintaining and
improving the Su-Watana project website and following
the guidance laid out for technical work group
meetings.” –pdf pages 4-5
AEA agrees with this comment. As explained in detail in Section 1, AEA has
exceeded the requirements in FERC’s ILP regulations in its efforts to
collaborate and consult with licensing participants. AEA recognizes the
importance of working closely with licensing participants in the development
of licensing studies that will support AEA’s License Application, inform
protection, mitigation and enhancement measures, serve as a foundation to
environmental review under NEPA, and support all needed state and federal
permits including FERC’s licensing determination under the FPA.
While AEA endorses the Communication Protocol and will continually assess
and improve its efforts to the ideals expressed therein, it does not intend to
allow strict adherence to the Communication Protocol unintentionally to stifle
the frequent dialogue, informal communications, and exchange of ideas that
AEA believes are essential to resolving disputes and achieving consensus on
the many complex issues related to this licensing effort.
GEN-41 FERC 11/14/2012 “To avoid future coordination and reporting concerns
expressed by the National Marine Fisheries Service in
A detailed overview of the study plan process appears in Section 2, and a
comprehensive master schedule appears at Attachment 2-1. In addition,
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 15 December 2012
General / Global
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
their October 31 filing, we recommend that your revised
study plan include a master schedule that includes the
estimated start and completion dates of all field studies,
when progress reports will be filed, who will receive the
progress reports and in what format, and the filing date
of the initial and updated study reports.” –pdf page 1
each of the 58 individual study plans contains a “Schedule” section, which
discusses (and charts) the estimated start and completion date for field
studies, provides the date for filing the Initial Study Report and Updated
Study Report, and a discussion of regular progress reporting. Each study
plan also includes a section entitled “Relationship with Other Studies,” which
provides a detailed narrative on how the study uses outputs from other
studies and/or provides inputs to other studies. These interdependencies are
illustrated graphically in each study plan.
With regard to regular progress reporting, please see AEA’s response to
comment GEN-01.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 16 December 2012
Geology and Soils Characterization Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
GS-01 CSDA 11/14/2012 “The study appears to be confined to the immediate
area of dam construction and access road only.” –pdf
page 10
As explained in RSP Section 4.5.3, the Geology and Soils Characterization Study
will include extensive investigations to characterize the geologic, geomorphic, and
seismic conditions in the Project area, including the dam site, reservoir, and
proposed access and T-line corridor areas. Although there is a focus of the
investigations is on the dam site, a comprehensive regional investigation is also
planned for the Project “region or area” to better understand and characterize the
geology and soil resources of this remote region as well as to identify potential
impacts and the development of appropriate mitigation measures for the project
These studies include review and evaluation of previous geologic, geomorphic and
seismic reports for the area and region; plan and implement comprehensive field
investigations and testing in the project area to characterize the surficial and bedrock
geology and soils materials, groundwater, slope stability and permafrost conditions,
make assessments of the dam site foundation area, mineral resources including
construction material and minerals, seismic hazards, slope stability and erosion
potential including along the proposed reservoir rim; reservoir triggered seismicity;
and establish a network of seismic monitoring stations to augment those of the
Alaska Earthquake Information Center reservoir triggered seismicity.
GS-02 CSDA 11/14/2012 “Identifying soil conditions and geologic features
should not be confined to only the dam site, but to the
whole reservoir especially in a periglacial area.
Solifluction and gelifluction, the downslope movement
of waterlogged sediments over impermeable rock or
permafrost, respectively, are important considerations
for assessing the potential for sloughing of the
sediment into the reservoir, especially during any
seismic activity. . . This ‘and other lands’ implies that
there was a FERC directive to investigate the whole
area of the potential reservoir, rather than limiting the
study to the site area, as this chapter does. The
whole reservoir region should be studied.”–pdf page
11-13
As explained in RSP Section 4.5.3, the Geology and Soils Characterization Study
includes extensive investigations to characterize the geologic, geomorphic, and
seismic conditions in the project area including the dam site, reservoir, and proposed
access and T-line corridor areas. The use of the term “geologic features” refers to
structural geologic features here. Mass wasting features are being studied and an
assessment will be made in the Project area – dam site, reservoir, and corridor
areas.
Details of the investigations and studies of the geologic, geomorphic, and seismic
conditions are in development as AEA employs ongoing and thorough evaluations of
project data based on the findings and assessments made while building on the
1975-1986 and 2011-12 data and studies. AEA employs a phased, flexible
approach to planning and implementation of field investigations, testing, and
instrumentation and to thorough evaluations of geologic, geomorphic and seismic
conditions hazards for the Project.
See also AEA response to comment GS-1.
GS-03 ADNR-
DGGS 11/14/2012 Page 4-4 of PSP section 4.5 “Necessary laboratory
tests of physical and strength properties of rock and
Section 4.5.4 provides that both physical and chemical testing as well as
petrographic analysis will be undertaken in order to characterize the geology and
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 17 December 2012
Geology and Soils Characterization Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
soil should include solubility testing of component
minerals.” –pdf page 12
soils materials.
GS-04 CIRI 11/14/2012 Conduct a Mineral Resource Assessment Study
including a detailed description of known or
exploitable mineral resources within and outside of
the Project boundaries. The proposed study appears
to be limited to the project footprint. FERC
regulations require geology and soils evaluation to
include impacts to non-project lands that would be
directly or indirectly impacted by the project (citing 18
CFR 4.41(f)) and FERC SD2 requires study to
include assessment of access to proven or probable
mineral deposits. –pdf page 2
CIRI’s reliance on 18 CFR 4.41(f) is misplaced, as this regulation expressly does not
apply for applications prepared pursuant to FERC’s ILP regulations. 18 CFR
5.18(b). Instead, AEA’s Exhibit E (Environmental Exhibit) will follow FERC’s
“Preparing Environmental Assessments: Guidelines for Applicants, Contractors, and
Staff.” Id. FERC’s ILP regulations, moreover, require the application to analyze any
effects identified in FERC’s environmental scoping documents. 18 CFR
5.18(b)(5)(ii)(A). Here, FERC’s Scoping Document 2 (SD2) states that its EIS will
include evaluation of the “effects of project construction and operation on access to
proven or probable mineral deposits.” SD2, Section 4.2.1.
Consistent with these requirements, AEA’s Geology and Soils Study plan will identify
impacts “in the Project area, including the dam, reservoir, and access and T-line
corridors.” Section 4.5.1. The Regional Geologic Analysis and Mineral Resources
Assessment will include a survey to identify proven and probable mineral
resources using existing data to assess mineral potential and mining activity in the
impoundment area (Section 4.5.4). Moreover, the study area is not limited to the
footprint of the impoundment, but includes the area in the general vicinity of the
impoundment, as this is the area where access to mineral resources is most likely to
be affected (Section 4.5.3). The survey will include mapping of known deposits,
identification of likely areas of mineral resources, plus field reconnaissance of
selected areas of high mineral potential, and analysis of mineral potential from
borings and other sampling work undertaken in connection with geotechnical
investigations.
The purposes of these investigations are to support development of Project design,
as well as to assess impacts of Project construction and operation on geologic, soil
and other environmental resources. These investigations, however, are not
intended to assess the value or exploitability of mineral resources, as these issues
are beyond the scope of the FERC licensing process.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 18 December 2012
Baseline Water Quality Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
WQ-01 CCC 11/15/2012 “The water quality studies seem to focus exclusively on tributaries and
slough that work well. There should be equal emphasis put on learning
from the drainages, sloughs and tributaries that are not supporting fish
so that we can better understand the conditions that don't work. This will
help to better understand what kind of conditions need to be avoided.” –
pdf page 5
Extensive water quality data will be collected at non-productive
areas of the river, including sloughs. This will be performed
primarily during the focus study area sampling. A description for
the Focus Areas (Section 8.5) can be found in Table 8.5-7
including a site description and rationale for selection.
WQ-02 FERC 11/14/2012 “Clearly describe the exact number, location, and spatial extent of your
proposed focus areas for each proposed study. Provide justification for
the number of proposed sites selected for detailed 2-D hydraulic
modeling and other intensive study elements. Include criteria to be used
for selecting focus areas and study-specific rationale for co-locating
sites.” –pdf page 5
The sites selected for detailed 2-D hydraulic modeling are fully
described in Section 6.6.3.1 of the RSP including rationale for
selection. Please also see response GEO-06 for more detailed
information.
Focus Area selection is based on representative mainstem
Susitna River reaches, side channels, and sloughs where
important fisheries habitat has been identified (Seciton 8.5.4.2 of
the RSP). The results for this study will be used in Study 8.5
(IFIM) and monitoring of the water quality parameters listed in
Section 5.5.4.5 in the Baseline Water Quality Study. Other
considerations for representative Focus Area reach selection
have been the influence on groundwater on surface water quality
conditions.
Resolution for modeling select water quality parameters in Focus
Areas will be finer (100 m) than for the mainstem Susitna (250 m
to 1 km) modeling effort. The Focus Area model will be nested
within the mainstem model framework coupled with the same
hydraulic routing model. The objective is to determine how water
quality conditions may change with surface elevation changes
due to alternative Project operational scenarios.
A description for the Focus Areas (Section 8.5 of the Revised
Study Plan) can be found in Table 8.5-7 inlcuding a site
description and rationale for selection.
WQ-03 FERC 11/14/2012 “In section 5.5.4.2, Meteorological Data Collection, please explain or
address the inconsistencies between the text and Table 5.5-2 regarding
river miles associated with meteorological stations.” –pdf page 6
Inconsistencies between the text and Table 5.5-2 regarding river
miles associated with meteorological stations have been
addressed in Section 5.5.4.3. River miles reported in Table 5.5-2
reflect actual locations where MET Stations have been
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 19 December 2012
Baseline Water Quality Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
established in 2012 and are currently collecting continuous data
at 15-minute intervals.
Currently, 3 new MET Stations have been established below the
proposed dam site (riverine), at the dam site (forebay of the
proposed dam), and above the upstream end of the proposed
reservoir. Additional potential locations for updating existing MET
Station sites have been examined, but not yet established. The 3
new MET Stations are necessary for providing input in
constructing the virtual reservoir model and for use in constructing
the riverine model.
WQ-04 FERC 11/14/2012 “In section 5.5.4.8, Technical Report on Results, you state that water
quality conditions will be described in greater detail at the Focus Areas
(section 5.5.4.5), but descriptions over shorter time intervals will not be
possible for general chemistry and metals because site visits and
sample collection will be limited to monthly sampling due to the
remoteness of the Focus Areas. However, section 5.5.4.5 states that
sampling will occur every 2 weeks for 6 weeks. Please resolve this
apparent inconsistency.” –pdf page 6
The reference to monthly site visits at Focus Areas (Section
5.5.4.8) has been revised to reflect the same sampling frequency
stated in Section 5.5.4.5 of the Revised Study Plan. Sampling for
water quality conditions at Focus Area reaches will be conducted
every two weeks. Continuous monitoring of water temperature
and dissolved oxygen will be conducted continuously using
datalogging probes (Section 5.5.4.8 of the RSP).
WQ-05 FERC 11/14/2012 “In section 5.5.4.9, you propose to conduct a pilot thermal imagery study
to evaluate the availability of thermal refugia for fish. The objective of
the study is to determine whether thermal imagery can be used to
identify thermal refugia throughout the project vicinity. Please clarify the
criteria that would be used to make the determination on whether to
expand the assessment, and provide a schedule for reporting the
results of the pilot study. Your RSP should also include any alternative
methods that you would use to identify thermal refugia in the event the
pilot study is unsuccessful. If you do not propose any alternative
methods, then please state that to be the case and provide an
explanation for why no alternative methods are proposed.” –pdf page 6
Thermal imagery will be calibrated with select temperature probes
currently located on the mainstem Susitna River and have been
logging temperature data at 15 minute intervals in the middle river
(the extent of the thermal imagery data). The in situ probe data
will be matched by time and location on the river with thermal
imagery recorded at the same time and location. The coupling of
these data using actual temperature data with spectral patterns in
the digital imagery will be analyzed for consistency of the
relationship and spatial extrapolation to other areas of the river
will be made (Section 5.5.4.9).
If the thermal imaging is not successful, the study component will
be reevaluated (RSP Section 5.5.4.9). Future actions will depend
on the causes of the failure. Potential solutions would include:
• Hand held FLIR meters that could be used during
stream side studies, and a more focused thermal
mapping task within Focus Areas using hand-held
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temperature meters and probes may prove useful.
• Use of documentation of open water leads as a
substitute.
• Outfit the R44 helicopter to take advantage of regular
field presence. Thermal imagery could be shot all
summer long and brief intervals of ideal conditions
could be used.
• The Focus Area results represent habitat identified as
representative of the most important for fisheries use as
described by the rational for site selection in Section
8.5.4.2 of the RSP. These results can be extrapolated
to similar reaches, side channels, and sloughs in other
areas of the Susitna drainage not directly monitored in
this study to determine thermal refugia for fish.
Thermal imagery data is currently being calibrated with
continuous temperature monitoring collected during the same
time frame during 2012 from the Middle River sites beginning RM
98.5 through RM 165 (below the beginning of Devils Canyon).
WQ-06 FERC 11/14/2012 “In section 5.5.4.9.2, Calibrating Temperature, please describe how
water temperature monitoring instruments will be calibrated, or refer to
the SAP/QAPP, as appropriate.” –pdf page 6
Temperature probes were calibrated in the office by first
identifying 4 units that would serve as controls and not be
deployed in the field. These probes and the field deployed probes
were submersed in room temperature water bath and then an ice
bath in the laboratory and the times and temperature for each
bath recorded using a NIST calibrated thermometer. Once probes
are retrieved from the field and re-submersed into similar bath
tests, battery power and temperature measurements are
compared for measurement drift and battery power. A correction
factor for field probes will be developed based on this relationship
so that all field data can be corrected, if necessary.
Interim temperature measurements are made using a NIST
calibrated thermometer during each download interval at the field
sites. Surface water temperature is measured prior to removing
the temperature probe from the water and time of measurement is
made. A comparison between the instantaneous site temperature
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and the probe temperature determines interim correction factors.
Calibration procedures as outlined above are included in the 2012
Water Temperature Monitoring QAPP (Section 5.8, Attachment 5-
1, B8.0 of the RSP).
WQ-07 FERC 11/14/2012 “Section 5.5.6, Schedule, presents a schematic entitled
Interdependencies for Water Resource Studies and indicates that
additional detail will be provided. Please provide the additional detail in
your RSP.” –pdf page 6
Additional detail describing content of the Interdependency Chart
is provided in Section 5.5.7 of the Revised Study Plan.
WQ-08 FERC 11/14/2012 “In section 5.6.4.8, Reservoir and River Downstream of Reservoir
Modeling Approach, you use the term “initial reservoir condition” to
describe baseline conditions without the project. It would improve clarity
if you removed the term reservoir and referred to a without project
scenario as initial condition or existing condition.” –pdf page 6
Agree. AEA has revised RSP Section 5.6.4.8 in response to this
comment.
WQ-09 FERC 11/14/2012 “It appears as though there are inconsistencies between the river miles
noted in the text and those presented in Table 5.5-1; please address
these inconsistencies in your RSP.” –pdf page 7
AEA has revised the plan to address inconsistencies in
referencing of river miles. The updated river mile list reflects shifts
of some monitoring sites upstream/ or downstream in order to
have access to current temperature monitoring sites and future
water quality sampling sites.
WQ-10 FERC 11/14/2012 “In section 5.6.4.8, please clarify what is meant by the statement:
measuring additively or synergism of toxics effects from multiple
stressors is simplistic and is determined by identifying the single, worst,
or dominant stressor (simple comparative effect model). If this statement
is consistent with current scientific understanding, then please provide a
citation to support the statement.” –pdf page 7
AEA has revised the plan in response to this comment. The
revised statement reads as follows: “Measuring additively or
synergism of toxics effects is possible using laboratory bioassays,
but may not be adequately predicted by a model. The level of
uncertainty in extrapolating results from laboratory to field
conditions is large and potentially unreliable.” Mumtaz et al.
(1998) describes a weight of evidence (WOE) approach that
estimates potential toxicity of mixtures using a weighting factor to
modify chronic or acute toxicities. This is a qualitative approach
that address additive or synergistic effects of metals mixtures.
Additional explanation for how a mixture of metals and resulting
toxicities to aquatic life will be addressed is found in AEA’s
response to comment WQMOD 06.
WQ-11 FERC 11/14/2012 “Section 5.6.6, Schedule, contains two different versions of the
schematic titled Interdependencies for Water Resource Studies. Please
Outdated version of the Interdependency Table removed. See
Figures 5.5-3, 5.6-2 and 5.7-3. A single updated Interdependency
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remove the outdated version. The schematic and associated discussion
also appears in sections 5.5.6 and 5.7.6. Please present the material in
just one section and cross-reference to it in subsequent water quality
studies.” –pdf page 7
Chart is used for all three studies.
WQ-12 FERC 11/14/2012 “Section 5.7.1, General Description of the Proposed Study, provides a
general summary of the technical information presented in Section
5.7.2, Existing Information and Need for Additional Information, as an
introduction to the key questions and study objectives. It would be
helpful to include a few relevant literature citations from section 5.7.2 in
this summary, particularly following the sentences beginning with “Many
studies…” and “Based on several studies…” –pdf page 7
Relevant literature citations have been added to Section 5.7.2 to
accompany the statement made in Section 5.7.1 (“Based on
several studies…”) in the RSP following the sentence beginning
with “Many studies…”
WQ-13 FERC 11/14/2012 “Please review the list of mechanisms for mercury bioaccumulation
presented in section 5.7.2., Existing Information and Need for Additional
Information, for accuracy. Is the focus of methylmercury production on
water-column bacteria rather than sediment bacteria? Are anoxic
conditions always created by decay of organic material in the water
column? Is inorganic mercury used by bacteria to “continue the decay
process” or is its use a byproduct of cellular respiration? Do “larger
predators” (please define) actually consume bacteria? What about
uptake of water column methylmercury by algae and subsequent
transfer to higher trophic levels? Please provide citations for the
mechanistic processes you are describing.” –pdf page 7
The list of mechanisms associated with the production of
methylmercury in freshwater has been revised in Section 5.7.2 to
reflect the toxics Pathway Diagram for mercury. Relevant
environmental condition factors and transfer mechanisms will be
visually described with companion explanation for how the
production and transfer mechanisms are activated.
The focus for methylmercury will be on production in the
sediments and mobilization in the water column. The
bioaccumulation of methylmercury in aquatic life will be examined
using two transfer mechanisms: 1) direct contact and absorption,
and 2) consumption of food with adsorbed toxics. Detail has been
included in the study plan as part of the description for how
methylmercury is cycled in the aquatic ecosystem.
The focus for methylmercury production is on sediments and
sediment boundary layer conditions that would promote
methylization of mercury. Once methylmercury is produced and
released from sediments, contact with aquatic organisms’ tissues
in the water column will be the primary pathway for
bioaccumulation.
Anoxic conditions in the water column occur as a result of two
activities: 1) cellular respiration by bacteria and dark cycle
phytoplankton metabolism, and 2) bacterial demand of oxygen in
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the water column as suspended organics are used for growth and
division into multiple cells.
Inorganic mercury is used as a carrier in cellular metabolism and
is associated with organic by-products before depuration, or
release, as a metabolic by-product.
Bacteria are consumed by lower trophic levels like benthic
macroinvertebrates that scrape foodstuffs from hard substrate.
The biofilm that forms on hard substrates are comprised by
bacteria that create a microenvironment promoting proliferation of
the bacterial community and use organics that settle out of
suspension from the overlying water column. The benthic
macroinvertebrates (BMI) are consumed by predatory BMI and
grazing fish. The biofilm on hard substrates have methylmercury
and other toxics in it and has been demonstrated as the way in
which toxics re transferred up the food chain. Larger predators
accumulate mercury by indirect means and biomagnify the toxics.
Methylmercury will strongly associate with organic particles
suspended in the water column. The consumption of these
particles may be consumed by zooplankton, free-swimming or
adsorbed to respiratory tissue from any aquatic organisms.
WQ-14 FERC 11/14/2012 “In section 5.7.3, Study Area, please describe how construction-related
impacts from road crossing sites affect mercury concentrations. This
section also indicates that additional details regarding mercury sampling
sites will be added in the RSP. Please provide this additional detail in
the RSP.” –pdf page 7
The proposed study will describe impacts from road crossings on
mercury concentrations. Several access road corridors are
currently under consideration. One road will be constructed in
order to access the proposed dam site. Road crossings
constructed are expected to impact streams at each of the
crossings and these locations will be surveyed for toxics
concentrations above background in sediment and surface water.
This information has been added to section 5.7.3. of the RSP.
Additional details regarding proposed mercury sampling sites is
described in section 5.7.4 and Table 5.7-5 in the Revised Study
Plan.
WQ-15 FERC 11/14/2012 “Section 5.7.4.2, Collection and Analyses of Soil, Vegetation, Water,
Sediment, Sediment Pore Water, Avian, Terrestrial Furbearer, and Fish
Section 5.7.4.2 of the Revised Study Plan provides greater detail
for sampling bioaccumulated mercury in tissue media (e.g., birds,
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Tissue Samples for Mercury, states that data will be collected from
multiple aquatic media including surface water, sediment, avian,
terrestrial furbearer, and fish tissue. This statement is not consistent
with comment responses in Table 5.4-1, which indicate that the mercury
study is limited to predicting impacts related to water, sediment, and
fish. Sections 5.7.4.2.5, Avian, and 5.7.4.2.6, Terrestrial Furbearers,
indicate that additional information will be provided in the RSP. Please
provide the additional information and ensure that it is consistent with
comment responses in Table 5.4-1 and addresses both NMFS’ and
FWS’ study requests related to mercury.” –pdf page 8
mammals, and fish) and environmental media (e.g., terrestrial
soil, water sediment, and pore water).
WQ-16 FERC 11/14/2012 “Please clarify the reference to “sex and sexual” data collection for fish
tissue in section 5.7.4.2.7, Fish Tissue. The reference was possibly
meant to be “sex and sexual maturity.” –pdf page 8
Study Plan has been revised in the appropriate section.
WQ-17 FERC 11/14/2012 “The comment responses in Table 5.4-1 indicate the possible addition of
macroinvertebrate sampling in section 5.5.4.7, Baseline Metals Levels in
Fish Tissue, and section 5.5.4.7 states that macroinvertebrate sampling
may occur if mercury is detected. However, this is not discussed in
section 5.7, Mercury Assessment and Potential for Bioaccumulation
Study. Please ensure that the water quality studies are consistent with
one another.” –pdf page 8
Please see AEA’s response to comment MERC 07.
WQ-18 ADEC-
Division of
Water
11/14/2012 Page 5-14 in PSP section 5.5.4.3.1 “states ‘Water quality parameters
above that do not exceed Alaska Water Quality Standards will not be
collected in succeeding months; the exception are those parameters in
Table 5.5-4 associated with monthly sample collection from surface
water.’
Replace this language with, ‘Table 5.5-4 lists the water quality
parameters to be collected and their frequency of collection.’” –pdf page
15
AEA has revised language in the RSP Section 5.5.4.4.1 in
response to this comment.
WQ-19 ADNR-
ADF&G 11/14/2012 “Information is needed on preliminary results from the thermal imaging
assessment that was scheduled to be conducted in the fall 2012. An
assessment on the feasibility of this investigation is needed and if it is
determined feasible, how additional thermal imaging data will be
collected and calibrated.” –pdf page 19
Calibration of thermal imagery and products completed in winter
2012 are addressed in AEA response to WQ-05.
WQ-20 ADNR-
ADF&G 11/14/2012 “Information is needed on the availability of the “Sampling and Analysis
Plan” and the ‘Quality Assurance Project Plan’.” –pdf page 19
SAP/QAPPs have been prepared and are included in the RSP as
Section 5.8: Attachments 5-1, 5-2 and 5-3.
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WQ-21 ADNR-
ADF&G 11/14/2012 “All field sensors and equipment should be calibrated pre- and post-
monitoring according to accepted industry or manufacturer protocols
and field measurements collected for post monitoring
calibration/processing.” –pdf page 19
SAP/QAPPs (Section 5.8: Attachment 5-1) include language on
calibration of field sensors and equipment as suggested.
WQ-22 ADNR-
ADF&G 11/14/2012 “Monthly measurements will not adequately characterize water quality in
the Susitna River because some parameters are highly variable. We
suggest more frequent measurements of basic water quality parameters
(e.g. dissolved oxygen, turbidity, conductivity, and pH) at select sites.” –
pdf page 19
At least three monitoring strategies are currently implemented or
proposed: 1) continuous temperature monitoring (currently
implemented in 2012), 2) monthly site visits for water quality
(2013 through 2014), and 3) Focus Areas (intensively sampled
water quality with continuous temperature and dissolved oxygen
monitoring probes installed 2013/2014 and sampling every two
weeks for all other parameters).
To adequately characterize basic water quality parameters within
the Susitna River frequent (continuous) measurements of
temperature and DO will be collected at 15-minute intervals within
the Focus Areas (Section 8.5; Table 8.5-7). Continuous
monitoring has already been implemented for surface water
temperature at mainstem sites from RM 15.1 through RM 233.4.
Continuous measurements of conductivity, pH, and turbidity
require use of multi-parameter probes that are easily damaged
and lost under conditions in the Susitna River. Because of the
unfavorable conditions within the Susitna River, continuous
measurements of conductivity, turbidity, and pH will not be
collected. However, measurements of these parameters will be
collected every 2-weeks within the Focus Areas and will be at a
frequency adequate for description of dynamic water quality
conditions in each area.
Monthly site visits are adequate at all other sites in terms of
characterizing general water quality conditions (nutrients, metal
concentrations, etc).
WQ-23 ADNR-
ADF&G 11/14/2012 “Baseline metals and mercury assessment are not the same. What is
being sampled and to what standards? What metals are being studied?”
–pdf page 22
Metals and mercury assessment are being studied on a broader
scale as input to the water quality model. The separate mercury
assessment study (Section 5.7 of the RSP) is focused on
tributaries and mainstem of the Susitna below and above the
proposed dam location. Multiple media like surface water,
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sediment, and fish tissue analysis will be used to determine
potential for bioaccumulation in fish from this area.
The metals being sampled in these media can be found in Table
5.5-3 of the RSP.
Fish tissue sampling is described in Section 5.7.4.2.6 of the RSP
including species, age, and field procedures suggested for
describing potential for bioaccumulation of methylmercury. This
information coupled with results generated from Section 8.5.2.1.2
in the RSP (Fish Distribution and Abundance in the Upper Susitna
River) will be used to determine the risk of potential for
bioaccumulation of methylmercury to existing fisheries.
Metals to be analyzed in fish tissue are listed in Table 5.5-3. of
the RSP.
WQ-24 TNC 11/14/2012 “Lower River Studies
Many of the study plans assume no effects from the project and its
operation below Talkeetna (Mile 97) and do not include the Lower River
in their scope. As noted in our comments on Climate Change impacts
above, the cumulative impacts of this project with other anticipated
changes to the basin could affect salmon and salmon habitat in the
Lower River. Load-following operation, which will essentially flip the
hydrological pattern between winter and summer, must be modeled for
effects on the Lower River. The hydrological model has been extended
to Mile 84 in the upper Lower River, and the study plan notes that the
model will be extended further into the Lower River if project effects are
seen at Mile 84. It is not clear what the trigger will be to extend the
model and how or when that will be decided. The Revised Study Plans,
including those for geomorphology, instream flow, and ice processes,
should include the Lower River. If they do not but leave the possibility
open depending upon early results, the plans should be explicit about
why they assume no effect on the Lower River and what criteria will be
used to revisit the need to extend models when early results are
available.” –pdf page 3
Currently, water quality sampling and temperature monitoring is
proposed to extend down to RM 10.1. We are collecting
temperature data as low as RM 15.1 for the 2012 Temperature
and MET Station Study.
WQ-25 USFWS 11/14/2012 “In general, the PSP adequately addresses the water quality issues. The
Service recommends specific improvements, as follows:”
AEA appreciates USFWS concurrence with the RSP and
appreciates USFWS participation in study plan development.
WQ-26 USFWS 11/14/2012 “Standard Operating Procedures: The RSP has been revised to address this comment in Section
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The baseline monitoring program should include a more detailed and
uniform level of information concerning the approaches and techniques
to be employed during water quality sampling such as a Quality
Assurance Project Plan (QAPP). For example, based on the importance
of mercury in the future reservoir conditions, an explicit discussion and
development of standard operating protocols (SOP) for sampling low-
level mercury concentrations (“Clean Hands/Dirty Hands”) to limit
sample contamination during collection, shipping, and handling should
be included. Example SOPs for this technique can be found in EPA
1996 and Lewis and Brigham 2009.” –pdf page 6
5.5.4.4.2 and Section 5.7.4.2. SAP/QAPPs have been prepared
and are included in the RSP as Section 5.8: Attachments.
SAP/QAPP documents describe appropriate techniques and
SOPs to be implemented during water quality sampling.
WQ-27 USFWS 11/14/2012 “Sampling Timing and Location
The baseline monitoring program should include sample collection
efforts and dates to correspond with important climatological events
which may or may not be captured in the once monthly program
presented in the PSP. Events such as early summer snow melt and late
season glacial melt can be associated with significant inputs of
constituents (e.g., solids) which need to be incorporated in the modeling
exercise.” –pdf page 6
The RSP has been revised to address this comment in Section
5.5.4.4.2 of the RSP. Months when sampling will occur are stated
in this section of the RSP and samples will likely be collected in
the middle of each month. The initial sample event will be
launched to reflect conditions during early summer snowmelt and
late season glacial melt. The intervals when these events occur
are at least two weeks in length and will be captured by the
monthly water sampling effort.
WQ-28 USFWS 11/14/2012 “Sampling timing and location.
For constituents that get sampled monthly, such as TSS, turbidity and
some other chemical constituents, the sampling should occur in a
synchronized manner across a range of habitat types (main-stem, side
channel, slough, clear-water tributary, glacial tributary) at multiple sites
on Susitna River between RM 0 and RM 250.” –pdf page 6
The RSP has been revised to address this comment in Section
5.5.4.4.2.
WQ-29 USFWS 11/14/2012 “Dissolved Organic Carbon
The baseline monitoring program should consider developing an
additional and detailed study of dissolved organic carbon (DOC) in
addition to what is already included in the PSP. This component of
water quality has a determining role in the levels of mercury methylation
and in the bioavailability and toxicity of metals. Understanding and being
able to predict DOC in the future river and reservoir will be a critical
element of the utility and accuracy of predicting future water quality and
toxicity for aquatic life, wildlife, and humans.” –pdf page 6
DOC is included in the RSP as a parameter to be analyzed for the
baseline WQ-monitoring program. See Table 5.5-3. This table
has been revised to reflect monthly collection of DOC whenever
surface water samples are collected for metals analysis.
This revision is also reflected in the SAP/QAPP (Section 5.8;
Attachments).
WQ-30 USFWS 11/14/2012 “Water Quality Standards
The PSP should develop and present evaluation criteria specifically
Human health will be protected using existing EPA and state
guidelines for fish consumption and water quality. We will also be
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protective of aquatic life, wildlife, and human fishers (recreational,
commercial and subsistence), rather than just using state water quality
standards that are designed to be protective of aquatic life. For
example, waters complying with the Alaska Department of
Environmental Conservation (ADEC) standard for the protection of
human health (0.050 μg/L) could easily exceed the EPA (1997) criteria
for the protection of various fish eating wildlife (kingfishers, loons,
ospreys, and bald eagles) by a factor of 50-150 times (presuming that
10% of the mercury in the water column is methylated). Standards for
each receptor class should be used in the evaluating the results of the
baseline water quality sampling effort.” –pdf page 7
looking at NOAA SQuirT tables (RSP Section 5.7.4.5) for
guidance.
Ecological receptors will have individual calculations of risk using
an exposure and toxicity assessments to link a chemical of
potential concern with adverse ecological effects (known as the
toxicity reference value or TRV). The hazard quotient (HQ) is the
ratio of average anticipated concentration of being ingested to the
known concentration where adverse effects may occur. It will be
calculated for all species for which significant samples are
available (RSP Section 5.7.4.2.5.4).
WQ-31 USFWS 11/14/2012 “Page 5-9, paragraph 3, the PSP reads: “An initial screening survey has
been proposed for several other toxics that might be detected in
sediment and tissue samples (Table 5.5-4). The single surveys for
toxics in sediment, tissue, or water will trigger additional study for extent
of contamination and potential timing of exposure if results exceed
criteria or thresholds…”
More detail is needed here. How many samples, at how many sites?
The study plan must identify the specific comparative standards for each
analyte and matrix, and get agreement on them up front” –pdf page 7 –
pdf page 7
Included in the SAP/QAPP for Study 5.5; Section 5.8, Attachment
5-1; B1.0 and B2.0. Table B1-1 in the SAP/QAPP for Study 5.5
lists all parameters to be analyzed as part of the baseline WQ-
monitoring program by sample type (media type) and the
frequency of collection. The SAP/QAPP for Study 5.5 can be
found in Section 5.8 of the RSP.
For the Baseline WQ-monitoring study sediment samples for
mercury/metals analysis will be collected just below and above
the proposed dam site. Additional samples will be collected near
the mouths of tributaries near the proposed dam site, including
Fog, Deadman, Watana, Tsusena, Kosina, Jay, and Goose
creeks, and the Oshetna River. Sediment samples will be
collected during one sampling event during the summer.
For the Baseline WQ-monitoring study fish tissue samples for
mercury/metals analysis will be collected near the vicinity of the
Susitna-Watana Reservoir in late August or early September.
A table will be developed for the Technical Report that will
summarize comparative standards for each analyte and matrix
analyzed.
WQ-32 USFWS 11/14/2012 “Our study request indicated that “Additional temperature monitoring
locations will be identified in cooperation with Fish Studies, the
AEA has added to the RSP continuous temperature monitoring to
be conducted within the Focus Areas (Section 8.5 of the RSP;
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Groundwater Study, and the Instream Flow study to identify areas of
thermal refugia for fish”. This does not appear in the study plan.” –pdf
page 7 –pdf page 7
Table 8.5-7). Temperature probes placed within the Focus Areas
will generate temperature data at 15-minute logging intervals.
The Focus Area monitoring locations were identified in
cooperation with Fish studies, the Groundwater study and the
instream flow study (see Section 8.5.4.2 in the RSP). The
continuous temperature data collected in the Focus Areas help
will to determine areas of thermal refugia.
WQ-33 USFWS 11/14/2012 “We have requested water temperature data collection throughout the
year. The study plan only includes temperature data collection between
late June and late December of 2012, 2013 and 2014. Temperature
data is critical during winter and spring seasons, as Project operations
are expected to significantly alter conditions during these seasons.” –pdf
page 7
Continuous temperature data is currently being collected at 33
Susitna River and tributary sites. Recovery of data from winter
months may be compromised by loss of equipment due to
physical conditions at each site (see Section 5.5.4.1 of the RSP).
WQ-34 USFWS 11/14/2012 “There are a number of differences, both in total number and in
locations, between the proposed meteorological stations specified in the
study request (Table 2) and the study plan (Table 5.5-2). The Service
recommends further discussion on this topic.” –pdf page 7
Upgrading existing MET Stations is currently being explored and
permission from station owners is being sought. If permission to
add monitoring equipment is granted by the owner of an existing
MET Station then the location and types of monitoring data will be
included for use in calibrating the reservoir and riverine water
quality models (see Section 5.6.4.8 of the RSP).
WQ-35 USFWS 11/14/2012 “The Service Study Request, page 10 (compared to study plan page 5-
11, paragraph 4): many of the specifics added by federal hydrologists
regarding MET station placement were not included in the Study Plan.”
–pdf page 7
Federal hydrologists requested a minimum of 12 MET Station
placements. AEA responded, with consultation from Tetra Tech
modelers that fewer were adequate in calibrating both the riverine
and reservoir models. New MET Stations installed in 2012 collect
data from the uppermost extent of the reservoir, the conditions at
the site of the proposed dam, and a riverine location typical of the
Susitna River mainstem corridor. These representative locations
for collection of meteorological data will be adequate for
determining influence of localized climate conditions for the EFDC
model.
One strategy for adding to the pool of MET Stations is to attempt
to upgrade existing MET Stations operated by other agencies with
equipment that would generate any missing measurements not
currently installed at individual stations.
WQ-36 USFWS 11/14/2012 “The Service’s study request included three MET station parameters The following are in the RSP: Solar radiation and
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which were not included in the Study Plan. These are solar radiation
(long and short consistent with ice process study needs), snow depth,
and evapotranspiration.” –pdf page 7
evapotranspiration. Snow depth and precipitation are currently not
included. Snow depth and precipitation are measured using the
same apparatus, however, MET Stations must be visited routinely
in order to make measurements and service the tipping bucket to
ensure accurate readings. Some of the MET Station sites are
inaccessible during the winter months. The current data
generated at 3 new MET Stations installed by AEA contractors
are adequate for use in calibrating and running the riverine and
reservoir models (see Section 5.5.4.2. of the RSP).
WQ-37 USFWS 11/14/2012 “Page 5-13, paragraph 1: Our study request included a requirement for
a Quality Assurance
Project Plan (QAPP) for water sampling and analysis, and a
requirement that all studies be conducted in accordance with applicable
USGS and EPA methodology. None of this language appears in AEA’s
study plan, which only specifies that the analytical laboratory will be
NELAP-certified.
Useful, quality data cannot be assured by a quality analytical laboratory
alone. Other aspects of the study, including sample locations and
timing, sample collection methods, sample preservation and shipping
methods, etc., are critical to study plan. We reiterate our request for a
project QAPP and compliance with applicable USGS and EPA
methodology, as cited in our study request.” –pdf page 8
SAP/QAPPs for each study have been prepared and included in
the RSP as Section 5.8: Attachments. Language requiring a
SAP/QAPP has been added to the RSP (Section 5.5, Section 5.6,
and Section 5.7). Sampling details associated with each
proposed study are included in the appropriate SAP/QAPP. The
SAP/QAPPs were prepared according to Alaska state guidelines.
WQ-38 USFWS 11/14/2012 “Page 5-13, paragraph 2, the PSP reads: “The initial sampling will be
expanded if general water quality, metals in surface water, or metals in
fish tissue exceed criteria or thresholds.” The applicable criteria and
thresholds for each analyte and matrix must be specified and agreed to
up front, before sampling occurs. This information should be contained
in the study plan QAPP.” –pdf page 8
The thresholds and criteria are currently incorporated by
reference into the document (RSP Section 5.5.4.8 and 5.7.4.5 for
NOAA SquiRT; ADEC, 2003) These thresholds will be defined
based upon input from USFWS and other state and federal
agencies.
WQ-39 USFWS 11/14/2012 “Table 5.5-3: AEA’s study plan differs from our study request in the
number of elements to be analyzed in sediment samples. AEA proposes
far fewer elements; specifically barium, beryllium, cobalt, magnesium,
manganese, molybdenum, nickel, thallium and vanadium are all absent
from AEA’s analyte list for sediment.” –pdf page 8
Parameters listed in comment have been added to Table 5.5-3 in
the RSP and samples will be analyzed for those parameters
according to methods listed in Table 5.5-3 of the RSP.
WQ-40 USFWS 11/14/2012 “Page 5-13, paragraph 3, the PSP states: “Metals monitoring for total
and dissolved fractions in surface water include the full set of
The requested information has been added to Section 5.5.4.7 of
the RSP (Baseline Metals Levels in Fish Tissue). The elements
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parameters used by ADEC in fish health consumption screening”.
This needs clarification: Does it refer to the elements ADEC measures
in fish fillets in its Fish Monitoring Program? In that program, ADEC
shares the fish tissue data with the state health department, which uses
the data to develop fish consumption advice. This doesn’t make sense
in this context, because water levels do not relate directly to fish levels.”
–pdf page 8
analyzed are measured in fish filets by ADECs Fish Monitoring
Program. The information may be shared by ADEC with the State
Health Department to develop fish consumption advice, if
necessary.
Some of the toxics proposed for monitoring in surface water may
be bioaccumulated in fish in two ways: 1) through respiratory
tissue like gill filaments, and 2) by consumption of food that has
adsorbed toxics associated with particles. The sampling data will
consider the type of toxic and the pathway for bioaccumulation by
aquatic organisms.
WQ-41 USFWS 11/14/2012 “Page 5-13, paragraph 3, the PSP states: “The criteria that will be used
for comparison with sampling results are the drinking water primary
maximum contaminant levels”.
That may be acceptable for the purpose of protecting human health
from drinking water contaminants. But it does not address drinking water
aesthetic issues (ADEC secondary standards), nor does it protect
ecological receptors. Results must also be compared to NOAA SQuiRT
tables for surface freshwater, to assess whether metal levels exceed
acute and/or chronic toxicity benchmarks for aquatic organisms.” –pdf
page 8
Besides comparison of water quality results with drinking water
primary maximum contaminant levels, NOAA SQuiRT tables have
been included in Section 5.5.4.8 of the RSP for use in determining
protection of ecological receptors and whether chronic or acute
toxicity to aquatic organisms is present.
WQ-42 USFWS 11/14/2012 “Page 5-14, Section 5.5.4.3.2 Sampling Protocol, paragraph 3 in total:
Our study request called for monthly sampling year-round. We are
especially interested in winter data, and coordination with the Ice
Processes study. AEA’s study plan is a major departure from this
recommendation, as it calls for 4 monthly samples during the summer
months, and only 2 other samples collected during the winter months.” –
pdf page 8
Current language in RSP states that sampling will be conducted
once a month from June through September and twice in the
winter (once in December and March). The limited winter
sampling was proposed due to a review of existing data that
shows few criteria exceedences occur during winter months.
Section 5.5.4.4.2 of the RSP states “If the 2013 data sets suggest
that metals and other general water quality parameters exceed
criteria or thresholds, then an expanded 2014 water quality
monitoring program will be conducted to characterize conditions
on a monthly basis throughout the winter months.”
WQ-43 USFWS 11/14/2012 “Page 5-14, Section 5.5.4.3.2 Sampling Protocol, paragraph 4 in total:
This paragraph calls for using specific conductance as a surrogate
measure for transfer of metals from groundwater to surface water. This
might have some utility for major ions such as iron, but would be
In response to this comment, the following language has been
added in Section 5.5.4.4.2 of the RSP: “Water quality indicators
like conductivity (specific conductance) have been suggested as a
surrogate measure for transfer of metals from groundwater to
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completely ineffective for toxic inorganic elements present in relatively
“trace” concentrations.” –pdf page 8-9
surface water or in mobilization of metals within the river channel.
Should the one-time survey for metals at each of the sampling
sites show elevated concentrations of select parameters, then a
full list of metals sampling will be conducted one time that
analyzes groundwater concentrations in order to adequately
characterize current conditions. Available USGS data from select
continuous gaging stations will be reviewed for increases in
specific conductance during monthly and seasonal intervals, and
these results will be used to determine if further metals sampling
is warranted during additional winter months.”
WQ-44 USFWS 11/14/2012 “Page 5-15, paragraph 2, the PSP states: “It is possible that a flow-
integrated sampling technique…..will be used”. This a study plan; the
plan should definitively state whether this will happen or not.” –pdf page
9
A flow-integrated sampling technique will not be used as data
generated using this technique will not answer how representative
the single location grab sample at a site is of the Susitna River
cross-section. Section 5.5 of the RSP includes language
describing the sampling approach proposed for the 2013
sampling period. Water samples will be collected at each
monitoring location along a transect. Samples will be collected at
3 equidistant locations along each transect and at 2 discrete
depths for a total of 6 samples per site. Section 5.5.4.4.2 in the
RSP has been revised to include this transect sampling approach.
Specific sampling details are included in the SAP/QAPP which is
in Section 5.8: Attachments.
WQ-45 USFWS 11/14/2012 “As a general note, reference to USGS guidance for conducting water
quality sampling has been deleted throughout the AEA PSP.” –pdf page
9
Protocols for collection of water, sediment, and fish tissue
samples will be following ADEC and U.S. EPA Guidance included
in Section 5.5.4.4.2 of the RSP. The USGS flow-integrated
sampling technique was removed from the RSP because it would
be extremely difficult to use under the conditions and setting of
the Susitna River. In addition, the objective for collecting data
from several locations along a transect is to characterize how
variable water quality is along a cross-section of the river versus a
single grab sample at one location on the transect.
WQ-46 USFWS 11/14/2012 “Page 5-16, paragraph 6, the PSP states: “Toxics modeling will be
conducted to address potential for bioavailability in resident aquatic life.”
More detail is needed here. Which model; how?
Toxics modeling must also evaluate the potential for direct toxicity to
Section 5.5 of the RSP includes a description for how tocis
pathways analysis and toxics modeling analysis will be completed
(see Section 5.5.4.6 of the RSP. In addition, strategy for how
modeling of toxics using EFDC and secondary modeling tools
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aquatic life, and for mixture toxicity (the elements are not present in
isolation). Metals do not have to bioaccumulate to have a toxic effect.” –
pdf page 9
(e.g., limited use of the Biotic Ligand Model) is described in
WQMOD 06 in the Section 5.6 Comment/Response Table.
WQ-47 USFWS 11/14/2012 “Page 5-16, paragraph 6, the PSP states: “Comparison of
bioaccumulation of metals in tissue analysis with results from sediment
samples will inform on potential for transfer mechanisms between
source and fate”.
AEA will not likely acquire this information from fish sampling, unless it
is a very resident/non-mobile fish. Sessile organisms such as mussels
or plants would be far more useful to assess transport from sediments to
biota.” –pdf page 9
Section 5.5.4.6 of the RSP fully describes a strategy using
pathways analysis that identifies transfer gradient of toxics by
means of direct contact with of respiratory tissue or by
consumption of food with adsorbed toxics.
WQ-48 USFWS 11/14/2012 “The Service’s study request Page 19, paragraph 1, calls for sediment
metal data to be compared to appropriate NOAA SQuiRT values to
assess whether metal levels exceed acute and/or chronic toxicity
benchmarks for aquatic organisms. This does not appear in the AEA
study plan.” –pdf page 9
Please see AEA’s response to comment WQ-41. Language
addressing comment included in RSP Section 5.5.4.4.8.
WQ-49 USFWS 11/14/2012 “Page 5-17, paragraph 2 in total, the PSP states: “Body size targeted for
collection will represent the non-anadromous phase of each species life
cycle (e.g., Dolly Varden; 90 mm – 125 mm total length to represent the
resident portion of the life cycle.)”
The Service agrees if this is limited to understanding the amount of
mercury in the fish that is clearly attributed to the local environment.
However, for risk assessment purposes it is also important to sample
fish that are representative of those taken for consumption by humans
and wildlife receptors. Specifically, large adult fish that are targeted by
anglers (and bears) should also be sampled, to determine how much
additional mercury can “safely” be added from the project before
consumption advisories are warranted. Similarly, for ecological risk
assessment purposes it is important to sample fish representative of
those in the diet of avian and mammalian piscivores in the project area.
Our study request (Page 19 paragraph 3) contains a more robust
description of the types and sizes of fish that should be sampled.” –pdf
page 9
Please see AEA’s response to comment MERC 20.
WQ-50 USFWS 11/14/2012 “Page 5-17, paragraph 4, the PSP states: “Results will be reported with
respect to applicable Alaska State and federal standards”.
AEA has revised Section 5.5.4.7 and other portions of the RSP
that reference protective criteria for beneficial uses. The primary
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The comparison values must be specified and agreed to up front. For
human risk assessment purposes, US EPA guidance for fish
consumption advisories is most appropriate. For ecological risk
assessment purposes, risks should be interpreted using published
scientific literature, based on both field observational studies and
controlled laboratory experiments, using the same or comparable
piscivorous avian and mammalian species.” –pdf page 9-10
approach for evaluating acceptable concentrations of pollutants in
surface water will be comparison against Alaska Water Quality
Standards (18 ACC 70.020(b)). Other thresholds will be used as
guidance for interpreting condition of water quality and other
media (please see AEA’s response to comment WQ-41).
WQ-51 USFWS 11/14/2012 “Page 5-17, paragraph 5, the PSP states: “Results from fish tissue
analysis will also be used as a baseline for determining how the
proposed Project may increase the potential of current metals
concentrations to become bioavailable”.
Results from fish tissue analysis will be used as a baseline for fish metal
concentrations prior to development. In order to understand how the
Project may increase the potential for current metal concentrations to
become bioavailable, AEA will need to predict how mercury methylation
rates may change in response to the Project. This would entail
prediction of organic carbon stores, amount of wetland or peat surface
area inundated, and the pH, calcium concentration and water hardness
of the reservoir…among other factors.” –pdf page 10
Please see AEA’s response to comment MERC 08. The potential
for biomagnification of mercury in fish tissue will be determined
prior to Project development. Current conditions for mercury
transfer to fish tissue will be compared with post-dam construction
conditions to determine the likelihood for mercury
bioaccumulation.
WQ-52 USFWS 11/14/2012 “Page 5-19, section 5.5.6 Schedule: Several needed elements are
missing, including the collection of geomorphology, geology, vegetative
type and quantity, etc. These parameters are necessary in estimating
mercury inputs to the reservoir. Then modeling is needed to incorporate
baseline conditions, estimate new mercury inputs and rates of
methylation, and predict mercury levels in biota post-impoundment.
Several study plans point to each other regarding this topic, but none
actually undertake these tasks.” –pdf page 10
Please see AEA’s response to comment MERC 06. Several
media will be sampled based on the potential of transfer of
mercury during and after flooding of the reservoir.
WQ-53 NMFS 11/14/2012 “In general, the PSP adequately addresses the water quality issues, but
there are several areas that require improvements, specifically:” -pdf
page 28
Thank you. Please see AEA’s response to comment WQ-53.
WQ-54 NMFS 11/14/2012 “The baseline monitoring program needs to include a more uniform level
of information concerning the approaches and techniques to be
employed in the baseline monitoring program. A discussion and
development of standard operating procedures for sampling low-level
mercury concentrations ("Clean HandslDirty Hands") to limit sample
The RSP has been revised to address this comment in Section
5.5.4.4.2 and Section 5.7.4.2. SAP/QAPPs have been prepared
and are included in the RSP Section 5.8: Attachments.
SAP/QAPP documents describe appropriate techniques and
SOPs to be implemented during water quality sampling.
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contamination during collection, shipping, and handling should be
included. Example standard operating procedures for this technique can
be found in Environmental Protection Agency (EPA) 1996 and Lewis
and Brigham 2009.” -pdf page 28
WQ-55 NMFS 11/14/2012 “The baseline monitoring program should, but as proposed does not,
include sample collection efforts and dates to correspond with important
climatological events which may or may not be captured in the once
monthly program presented in the PSP. Events such as early summer
snow melt and late season glacial melt can be associated with
significant inputs of constituents (e.g., solids) which need to be
incorporated in the modeling exercise.” –pdf page 28-29
Please see AEA’s response to comment WQ-27.
WQ-56 NMFS 11/14/2012 “For constituents that get sampled monthly, such as total suspended
solids, turbidity and some other chemical constituents, the sampling
should occur in a synchronized manner across a range of habitat types
(main-stem, side channel, slough, clear-water tributary, glacial tributary)
at multiple sites on Susitna River between river mile (RM) 0 and RM
250.” –pdf page 29
The RSP has been revised to address this comment in Section
5.5.4.4.2.
WQ-57 NMFS 11/14/2012 “The baseline monitoring program should include an additional and
detailed study of dissolved organic carbon (DOC) in addition to water
quality components already included in the PSP. This component of
water quality has a determining role in the levels of mercury methylation
and in the bioavailability and toxicity of metals. Understanding and being
able to predict DOC in the future river and reservoir will be a critical
element of the utility and accuracy of predicting future water quality and
toxicity for aquatic life, wildlife, and humans.” –pdf page 29
Please see AEA’s response to comment WQ-29.
WQ-58 NMFS 11/14/2012 “Atmospheric deposition of mercury should be quantified as an
additional source to the future reservoir, and as such should be included
in the sampling effort associated with the meteorological stations.” –pdf
page 29
Please see AEA’s response to comment MERC 05.
WQ-59 NMFS 11/14/2012 “The PSP should develop and present evaluation criteria specifically
protective of aquatic life, wildlife, and human fishers (recreational,
commercial and subsistence), rather than just using state water quality
standards that are designed to be protective of aquatic life. For
example, waters complying with the Alaska Department of
Environmental Conservation's (ADEC) standard for the protection of
Please see AEA’s response to comment WQ-30.
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human health (0.050 ~g/L) could easily exceed the EPA (1997) criteria
for the protection of various fish eating wildlife (kingfishers, loons,
ospreys, and bald eagles) by a factor of 50-150 times (presuming that
10% of the mercury in the water column is methylated). Standards for
each receptor class should be used in the evaluating the results of the
baseline water quality sampling effort.” –pdf page 29
WQ-60 NMFS 11/14/2012 “If these improvements are made to the water quality monitoring
program/study, then NMFS will be able to assess the project effects
compared to a baseline understanding. This will be important for NMFS
to consider when developing conservation recommendations to protect
fish and their habitats.” –pdf page 29
AEA believe that results from the implementation of the RSP will
enable NMFS to assess the project effects.
WQ-61 NMFS 11/14/2012 “The description of the models to be used in characterizing future
conditions following the construction and operation of the future dam
should include a separate and detailed description of the approach to be
followed in parameterizing and initializing the final selected model. This
should include a description of how terrestrial conditions will be used to
develop boundary conditions outside of the current riverine conditions.
Model initialization and calibration are important components of
establishing model credibility and accuracy and as such should be
described in sufficient detail to allow reviewers to evaluate the approach
and water quality data needs for each model.” -pdf page 30
Please see AEA’s response to comment WQMOD-04.
A QAPP has been prepared for the WQ-modeling Study and is
included in Section 5.8: Attachments. The QAPP describes
model initialization and calibration procedures that will be
implemented.
WQ-62 NMFS 11/14/2012 “The PSP should consider (in model selection) the geometric and
topographic complexity of the river system in model selection. This is
important for the potential extension of model boundary down to the
three river's confluence (Susitna, Talkeetna, and Chulitna). The long
downstream river has many meandering braided channels with
numerous tributaries. This river system will be inundated during summer
snow melting seasons. These factors will require the flexibility in model
grid generation (e.g., unstructured grid model), robust wetting and
drying algorithm, and computational efficiency (e.g., high resolution grid
only in zone of interest, parallel computing capability, etc.) for long-term
simulation of water quality. The selection of structured grid model such
as EFDC or CEQUAL-W2 may be difficult to represent the complex river
system accurately. This can degrade the prediction capability of model.
The PSP should provide an explicit plan in the worst case scenario and
Please see AEA’s response to comment WQMOD 03.
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consider also other unstructured type of model such as MIKE
(hydrodynamic + water quality). Other possible approach may be an
external coupling of an unstructured grid hydrodynamic model with a
similar grid frame of water quality model such as CEQUAL-ICM.” -pdf
page 30
WQ-63 NMFS 11/14/2012 “The PSP should include an explicit description of the modeling
approach to be used for determining toxicity of future water quality to
aquatic life, wildlife, and human fishers. This model or models should be
able to address the toxicity of mixtures of metals, and include a
discussion of how the potential interactions of toxins (additivity,
synergism, antagonism) will be evaluated in the selected model.” -pdf
page 30
Please see AEA’s response to comment WQMOD 06.
WQ-64 NMFS 11/14/2012 “The PSP should also discuss approaches to determining and
evaluating the bioavailability of metals in the future reservoir and river
such as the Biotic Ligand Model (BLM).” -pdf page 30
Please see AEA’s response to comment WQMOD 06.
WQ-65 NMFS 11/14/2012 “The PSP should consider expanding the analytes (i.e., anions and
cations) to be sampled in the baseline monitoring program based on the
review and utility of the BLM model in evaluating the future toxicity in
reservoir and downstream rivers.” -pdf page 30
Please see AEA’s response to comment WQMOD 06.
WQ-66 NMFS 11/14/2012 “Example studies that can be evaluated in the design of modeling the
toxicity of metal mixtures can be found in Altenburger et al. 2003;
Borgmann et al. 2008; Jho et al. 2011; Kamo et al. 2008; Khan et al.
2011; Kortenkamp et al. 2009; Mumtaz et al. 1998; Sasso et al. 2006;
Schmidt et al. 2010; Stockdale et al. 2010; Van Genderen et al. 2012;
Vijver et al. 2011.” -pdf page 31
Please see AEA’s response to comment WQMOD 06.
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WQMOD-01 TNC 11/14/20
12 “Lower River Studies
Many of the study plans assume no effects from the project and its
operation below Talkeetna (Mile 97) and do not include the Lower
River in their scope. As noted in our comments on Climate Change
impacts above, the cumulative impacts of this project with other
anticipated changes to the basin could affect salmon and salmon
habitat in the Lower River. Load-following operation, which will
essentially flip the hydrological pattern between winter and summer,
must be modeled for effects on the Lower River. The hydrological
model has been extended to Mile 84 in the upper Lower River, and
the study plan notes that the model will be extended further into the
Lower River if project effects are seen at Mile 84. It is not clear what
the trigger will be to extend the model and how or when that will be
decided. The Revised Study Plans, including those for
geomorphology, instream flow, and ice processes, should include the
Lower River. If they do not but leave the possibility open depending
upon early results, the plans should be explicit about why they
assume no effect on the Lower River and what criteria will be used to
revisit the need to extend models when early results are available.” –
pdf page 3
Water Quality Baseline monitoring extends to River Mile 15.1
(above the Beluga Line) in order to avoid any contact with critical
stages of the Beluga’s life cycle that occurs in the Lower River.
The Middle River and Upper River water quality monitoring sites
will be monitored at the same time as the Lower River so the
synchrony between these sections can be further examined for
changes in water quality between these sections and the
influence of major tributaries in the Lower River.
The water quality modeling will be limited to the furthest
downstream the hydraulic routing model extends. The complexity
of the Susitna River channel below confluence of the major
tributaries may preclude construction of a reliable hydraulic model
which will limit the use and future development of a water quality
model for the Lower River. The prediction of water quality impacts
from dam operations at the lowermost section of the Middle River
will be compared with conditions absent the dam at this point.
The difference between the pre-dam and post-dam scenarios at
the lowermost point of the Middle River will be compared with
pre-dam water quality conditions in the Lower River and a
determination made to extend water quality modeling if there is a
difference in conditions that represents significant change.
WQMOD-02 TNC 11/14/20
12 “Operation Scenarios
The various models that are developed for the study plan should look
at three scenarios: existing (non-project), proposed load-following
operation, and base load operation. Early introductions of this current
project proposed base load operations. With current power
generation dependent upon natural gas supplies, it is foreseeable that
in the future this project could be operated to supply base loads. In
case of that operational change in future, the base load case should
be included in the models. This would also provide the opportunity to
gage the impacts of a wider range of operation regimes.” –pdf page 3
Load-following operations reflect predictable power demands
throughout the year and are accompanied by pool elevation
fluctuations as well as riverine fluctuations based on routine
releases from the project. Influence on water quality conditions in
both the reservoir and riverine models during power demand
scenarios will be modeled on an hourly time-step and so will
reflect influence of power demand releases.
Section 6.6.4.2.2.1 and Section 6.6.4.2.2.2 describe four
operations scenarios that will be used for modeling. The initial
operations scenario will reflect “Existing Conditions-Base Case
Modeling (see Section 6.6.4.2.2.1 of the RSP for a more detailed
description of this scenario). The remaining scenarios are “Future
Conditions-with Project Scenarios” and represent maximum load-
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following, intermediate load-following, and base-load scenarios
(see Section 6.6.4.2.2.2 of the RSP for additional details).
WQMOD-03 USFWS 11/14/20
12 “Water quality model selection
AEA’s model selection should consider the geometric and
topographic complexity of the river system for potential extension of
model boundary down to the Susitna-Talkeetna –Chulitna confluence.
The long downstream river has many meandering braided channels
with numerous tributaries. This river system will be inundated during
summer snow melting seasons. These factors will require the
flexibility in model grid generation (e.g., unstructured grid model),
robust wetting and drying algorithm, and computational efficiency
(e.g., high resolution grid only in zone of interest, parallel computing
capability, etc.) for long-term simulation of water quality. The selection
of a structured grid model such as EFDC or CEQUAL-W2 may not
accurately represent the complex river system. This can deteriorate
the prediction capability of the model. AEA should provide an explicit
plan in the worst case scenario and consider other unstructured types
of models such as MIKE (hydrodynamic + water quality). Another
approach to consider may be an external coupling of an unstructured
grid hydrodynamic model with a similar grid frame of water quality
model such as CEQUAL-ICM.” –pdf page 12
The selection of EFDC for use in predicting water quality
conditions under various operational scenarios for both riverine
and reservoir environments was finalized in the Technical
Workgroup (TWG) Meeting on August 17, 2012. The TWG
agreed that EFDC would be selected for the Water Quality
Modeling Study (Section 5.6 of the Revised Study Plan).
Rationale for choosing the EFDC model is included in the RSP in
Section 5.6.4.6. Table 5.6-2 in the RSP provides a direct
comparison between EFDC, H2OBAL/SNTEMP/DYRESM, and
CE QUAL W2. Table 5.6-2 evaluates all 3 model options based
on technical, regulatory, and management criteria.
EFDC is capable of evaluating the impact of dam/reservoir
operations/climate change on reservoir stratification as well as
simulating dynamic interactions between nutrients and algae in
reservoirs and interactions between nutrients and periphyton in
riverine sections. EFDC is fully capable of predicting sediment
erosion, transport, and settling/deposition processes, as well as,
simulating fate and transport of metals in association with
sediments in both riverine and reservoir environment. EFDC will
be coupled with an external ice model with a properly designed
interface to communicate temperature results during seasonal
boundary conditions (e.g., winter to spring and fall to winter).
EFDC is also a three-dimensional model that can be configured
at nearly any spatial resolution to represent local effects. The grid
will be auto-generated by one of the EFDC modules to capture
complexity of local terrain and complexity in channel geometry.
These conditions have been successfully modeled in similar
riverine environments; most recently in the Athabasca River. The
successful use of EFDC in a similar riverine system as the
Susitna River provides verification that the model will meet the
challenges of a worst case scenario. The model evaluation
described in Section 5.6.4.5 of the RSP and criteria for model
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selection outlined in Table 5.6-2 account for the worst case
scenarios.
EFDC meets all the technical, regulatory, and management
criteria as outlined in Table 5.6-2 including a worst case scenario.
WQMOD-04 USFWS 11/14/20
12 “Modeling parameters
In characterizing future conditions following the construction and
operation of the Susitna Watana dam, AEA’s water quality modeling
determination should include a separate and detailed description of
the approach to be followed in parameterizing and initializing the final
selected model. This should include a description of how terrestrial
conditions will be used to develop boundary conditions outside of the
current riverine conditions. Model initialization and calibration are
important components of establishing model credibility and accuracy
and as such should be described in sufficient detail to allow reviewers
to evaluate the approach and water quality data needs for each
model.” –pdf page 12
The EFDC model is described in the RSP Section 5.6.4.4.
Technical considerations for the EFDC model are summarized
briefly in the RSP in Section 5.6.4.6. Input variables are fully
described in the EFDC Guidance (Tetra Tech 2002) and listed as
“Card Images” where there are 90 such examples.
The reservoir representation will be developed based on the local
bathymetry and dimensions of the proposed dam. A three-
dimensional model will be developed for the proposed reservoir
to represent the spatial variability in hydrodynamics and water
quality in longitudinal, vertical, and lateral directions. The model
will be able to simulate flow circulation in the reservoir, turbulence
mixing, temperature dynamics, nutrient fate and transport,
interaction between nutrients and algae, sediment transport, and
metals transport. The key feature that needs to be captured is
water column stratification during the warm season and the de-
stratification when air temperatures cool down. The capability of
predictively representing the stratification/de-stratification period
is of critical importance for evaluating the impact of the dam
because this is the critical water quality process in the reservoir.
Downstream of the proposed dam location, a river model will also
be developed to evaluate the effects of the proposed Project. It is
anticipated that the same model platform used for the reservoir
model will be implemented for the river model (at a minimum, the
two models will be tightly coupled). The river model will be
capable of representing conditions in both the absence and
presence of the dam.
Flow, temperature, TSS, DO, nutrients, turbidity (continuous at
USGS sites and bi-weekly at additional locations required for
calibrating the model), and chlorophyll-a output from the reservoir
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model will be directly input into the downstream river model. This
will enable downstream evaluation of potential impacts of the
proposed Project on hydrodynamic, temperature, and water
quality conditions.
WQMOD-05 USFWS 11/14/20
12 “Model calibration
The PSP should include an explicit hydrodynamic model calibration
plan to be fed for water quality modeling. The calibration against
water surface elevation and velocity is a crucial and basic process for
the development of baseline hydrodynamic modeling and application
to the proposed condition.” –pdf page 12
Because the dam is not in place when the reservoir model is
constructed, proper calibration of the model using actual reservoir
data is not possible. To achieve reasonable predictions of water
quality conditions in the proposed reservoir, a literature survey
will be conducted to acquire parameterization schemes of the
model. An uncertainty analysis approach will also be developed
to account for the lack of data for calibration, therefore enhancing
the reliability of reservoir model predictions.
The river model will be calibrated and validated using available
data concurrently with the initial reservoir condition model
(representing absence of the dam). Output from the models will
be used directly in other studies (e.g., Ice Processes,
Productivity, and Instream Flow studies).
The development of a baseline hydrodynamic routing model is
discussed in Section 8.5.4.3 of the Revised Study Plan.
The EFDC model will be calibrated in order to simulate water
quality conditions for load-following analysis. Organic carbon
content from inflow sources will be correlated with mercury
concentrations determined from the Baseline Water Quality Study
discussed in Section 5.5. Predicted water quality conditions
established by Project operations and that promote methylation of
mercury in the bioaccumulative form will be identified by location
and intensity in both riverine and reservoir habitats.
WQMOD-06 USFWS 11/14/20
12 “Toxicity modeling
The study plan should include an explicit description of the modeling
approach to be used for determining toxicity of future water quality to
aquatic life, wildlife, and human fishers. This model or models should
have the capability to address the toxicity of mixtures of metals, and
the model determination should also include a discussion of how the
The Biotic Ligand Model (BLM) is focused on determining toxicity
of individual metals to binding sites on tissue like gill filaments of
freshwater fish while considering other factors that compete for
the same binding sites. The BLM is restricted to predicting
potential toxicity of copper, silver, cadmium, zinc, nickel, and lead
to aquatic life.
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potential interactions of toxins (additivity, synergism, antagonism) will
be evaluated in the selected model. The PSP should also discuss
approaches to determining and evaluating the bioavailability of metals
in the future reservoir and river such as use of the Biotic Ligand
Model (BLM). The water quality modeling plan should consider
expanding the analytes (i.e., anions and cations) to be sampled in the
baseline monitoring program based on the review and utility of the
BLM model in evaluating the future toxicity in reservoir and
downstream rivers. Example studies that can be evaluated in the
design of modeling the toxicity of metal mixtures can be found in
Altenburger et al. 2003; Borgmann et al. 2008; Jho et al. 2011; Kamo
et al. 2008; Khan et al. 2011; Kortenkamp et al. 2009; Mumtaz et al.
1998; Sasso et al. 2006; Schmidt et al. 2010; Stockdale et al. 2010;
Van Genderen et al. 2012; Vijver et al. 2011. –pdf page 12
The other (water quality) factors used in the biotic ligand model to
predict potential toxicity to aquatic life will be generated by the
EFDC water quality model and so can input information in order
to use the BLM. However, the BLM will be restricted from use if
the combination of water quality monitoring results for metals
concentrations in sediments and surface water show little or no
detectable concentrations and the water quality model shows that
changes, if any, to water quality conditions that mobilize metals
does not occur. This is part of the pathways analysis for individual
metals toxics and is where decisions for use of secondary models
(like BLM) in addition to the EFDC primary model will be made.
Please see Section 5.6.4.6.5 in the RSP.
Borgmann et al. 2008 outline several assumptions under which
toxicity of metals concentrations at sites of bioaccumulation
interactions are additive. The use of the BLM to estimate a toxic
effect from mixtures of metals must satisfy several unknowns
and, as stated by the authors, should be used with caution and
other strategies for these toxicity estimates considered.
This comment response has been included in Section 5.6.4.6.5.
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MERC-01 USFWS 11/14/2012 “Objective 3 – Mercury Risk Assessment: Support other
related Susitna-Watana Project studies as needed,
including the Piscivorous Wildlife and Mercury Risk
Assessment. This objective is not being met at this time,
which is of considerable concern to the Service.” –pdf page
146
The RSP includes additional detail toward addressing Objective 3. The
RSP includes sampling for piscivorous birds and aquatic mammals
(Section 5.7.4.2.5), a predictive risk analysis of possible impacts (Section
5.7.4.2.5.4), fish tissue sampling (Section 5.7.4.2.6), and three modeling
methods (Section 5.7.4.3).
MERC-02 USFWS 11/14/2012 “The Service has requested that feathers of piscivorous
birds using the Project area, including Belted Kingfisher and
other species, be collected to provide the baseline
information on current levels of mercury critical to a wildlife
and mercury risk assessment.
The Service has also requested that a study be conducted
to determine enough details of these birds’ diets (e.g.,
amount or percent fish) to sufficiently inform this risk
assessment. We are not yet aware that these studies are
being planned by AEA.” –pdf page 148
The RSP includes feather sampling from piscivorous birds, including the
belted kingfisher, in the proposed inundation zone (see Section
5.7.4.2.5). Please refer to AEA’s response to comment RAPT-03 in the
Comment/Response Table for collection of feathers for mercury analysis.
AEA will be conducting a literature review on the diet of the birds in
question (Sections 10.15.4.3 and 10.14.4.1). Information on species diet
is well developed in the literature.
MERC-03 USFWS 11/14/2012 “Mercury toxicity The most important issue that remains to
be addressed is that there has been no intent reflected in
any of the Migratory Bird study plans, including the Raptor
study plan, to collect feathers and dietary information about
Project-area fish-eating birds, including Bald Eagles, a
species that may be at risk from accumulation of mercury.
See PSP Section 5.12. Mercury Assessment and Potential
for Bioaccumulation Study.” –pdf page 149
The RSP addresses this issue in Section 5.7.4.2.5.1. Feathers will be
collected and analyzed from several species of birds including eagles.
Please see AEA’s response to comment RAPT-03 in the
Comment/Response Table for collection of feathers for mercury analysis.
MERC-04 USFWS 11/14/2012 Piscivorous Wildlife and Mercury Risk Assessment.
The Service has requested that feathers from piscivorous
birds using the Project area, including Belted Kingfisher and
other species, be collected to provide the baseline
information on current levels of mercury critical to a wildlife
and mercury risk assessment. The Service has also
requested that a study be conducted to determine enough
details of these birds’ diets (e.g., amount or percent fish) to
sufficiently inform this risk assessment. We are still in the
Please see AEA’s response to comment MERC-04.
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process or working with AEA to adequately develop this
study. –pdf page 153
MERC-05 USFWS 11/14/2012 “Mercury Atmospheric deposition of mercury should be
quantified as an additional source to the future reservoir,
and as such should be included in the sampling effort
associated with the meteorological stations.” –pdf page 7
AEA has not included quantification of mercury atmospheric deposition
within the RSP because, as illustrated in RSP Figure 5.7-1, mercury
cycles between the water soil, and atmosphere, net accumulation rates
are very low. Also, the rate and amount of atmospheric deposition
doesn’t depend on whether the water body is a natural lake or reservoir.
As explained in RSP Section 5.7.2, previous studies have found that
increases in methylmercury concentrations in a reservoir after filling are
not related to atmospheric deposition. While inorganic mercury
deposition from the atmosphere is not a significant source of mercury
concentrations that are elevated above background, it can be a source of
background mercury concentrations (see Section 5.7.2). As explained in
Section 5.7.1, the goal of the Mercury Assessment and Potential for
Bioaccumulation Study in relation to the inundation zone is to quantify
mercury resulting from filling the reservoir, not necessarily background
mercury.
Background mercury concentrations are better predicted from studying
mercury levels in nearby natural lakes, not quantifying atmospheric
deposition. Background lake studies are included as part of the fish
tissue sampling (see Section 5.7.4.2.6).
As explained in Section 5.7.2, mercury in reservoirs typically isn’t source
limited, but is related to methylation rates in the reservoir. The water
quality model will predict methylation rates in the reservoir (Section
5.6.4.8).
MERC-06 USFWS 11/14/2012 “Page 5-17, paragraph 5, the PSP states: “Detection of
mercury in fish tissue and sediment will prompt further
study of naturally occurring concentrations in soils and
plants and how parent geology contributes to
concentrations of this toxic (sic) in both compartments of
the landscape”. The study of “naturally occurring
concentrations of mercury in soil and plants and how parent
geology contributes to concentrations of this toxicant” must
This work is planned to be done regardless of whether methylmercury is
detected in the sediment or water (see Section 5.7.4.2). It should be
noted, however, that mercury concentrations in soil and vegetation are
poor predictors of methylmercury concentrations in a reservoir after
impoundment, given that methylmercury production is rarely source
constrained.
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be undertaken by AEA, regardless of whether it is currently
present in fish and sediment. Vast surface areas and
vegetation will be inundated, that are not currently part of
the system. There is no need to prove current presence
before proceeding to predict the addition from the Project.
In any case, if adequate detection limits are used it is a
given that fish and sediments will contain mercury, as they
do everywhere. There is no reason to delay this “further
study”, particularly as the ILP process is so compressed.
This study needs to be planned and implemented now. –pdf
page 10
MERC-07 USFWS 11/14/2012 Likewise, macroinvertebrates need to be added to the
current study plan.” –pdf page 10
There are no plans for macroinvertebrates sampling at this time (Section
5.7.4.2). As with soil and vegetation, current mercury concentrations in
macroinvertebrates are poor indicators of the potential methylmercury
concentrations in fish and wildlife, and most methylmercury models do
not utilize this data for that reason.
Fortunately models for predicting methylmercury concentrations in fish
are well advanced and fairly accurate (Harris and Hutchison, 2008, Hydro
Quebec, 2003, etc). Methylmercury in fish tissues is generally higher by
an order of magnitude than that of their food (Rennie et al, 2011).
Therefore predictive models for fish can be generally applied to
macroinvertebrates. In addition, impacts on other species are going to be
evaluated (see Section 5.7.4.2.5.3).
MERC-08 USFWS 11/14/2012 “Adopt the concept of mercury with dynamic background.
The PSP needs to adopt an approach of documenting and
assessing the dynamic background concentrations of
mercury and methylmercury (MeHg), particularly in fish and
biota over time (not just in the landscape prior to
construction). In other words, it is stated that enhanced
formation of MeHg in reservoirs has been documented
(section 5.12.2). The PSP should acknowledge and expect
that a response in fish mercury will occur. For mercury, it is
not enough to rely on models for the primary method of
predicting impacts (5.6.5. “Models will be the primary
The Mercury Assessment and Potential for Bioaccumulation Study scope
does not include detail regarding the management of a problem that has
not yet been measured or predicted. Implementing the RSP will
generate information that AEA will rely upon in its environmental analysis
supporting its FERC License application.
There are many ways to manage methylmercury, and how the issue is
managed, or whether it needs to be managed, is something that will need
to be assessed based upon the outcome of that environmental analysis.
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method used for predicting potential impacts to water
quality conditions in both the proposed reservoir and the
riverine portion of the Susitna basin.”). –pdf page 46
MERC-09 USFWS 11/14/2012 The AEA plan should assume the increase in fish mercury
will happen and detail how this risk will be assessed,
monitored, and managed as a public health issue. There
will be significant concerns regarding human and ecological
health and risk assessment and the proposed study needs
to outline clearly how these risks will be documented,
assessed, and managed.” –pdf page 46
Predictive risk analyses (Section 5.7.4.2.5.3) will be used to estimate
risks to wildlife. Human health will be protected utilizing ADEC and EPA
standards for fish consumption.
The Mercury Assessment and Potential for Bioaccumulation Study scope
does not include detail regarding the management of a problem that has
not yet been measured or predicted. See AEA’s response to comment
MERC-08.
MERC-10 USFWS 11/14/2012 “Mercury modeling is essential, and is currently not
addressed in any of the PSPs. In order to determine the
risk posed by project-related mercury inputs to the aquatic
system, AEA must quantitatively model mercury inputs to
the reservoir, the amounts and rates of mercury
methylation, uptake and biomagnification of MeHg in
reservoir organisms including concentrations at each
trophic level, and transport of mercury downstream from the
reservoir, from the date of initial flooding until 20 years
post-impoundment. These mercury inputs and dynamics
must be quantitated in order to predict project-related risks
to ecological receptors in the project area.” –pdf page 46
Mercury modeling is addressed throughout the Mercury Assessment and
Potential for Bioaccumulation Study Section 5.7.4.3.
The source of the mercury above background in reservoirs is not typically
the geology, atmosphere, or woody plant debris. Otherwise, mercury
concentrations would not decrease to background after only 20-30 years.
Green vegetation (leaves of trees and shrubs) and the top centimeters of
humus are the primary source of mercury in newly filled reservoirs. This
is well researched and generally accepted science (Meister et al. 1979;
Hydro Quebec, 2003, etc.).
As explained in Section 5.7.2, methylmercury is significantly more toxic
than inorganic mercury, and unlike inorganic mercury, bioaccumulates in
the ecosystem. The water quality model (see Section 5.6.4.8) will focus
on modeling methylization in the reservoir.
MERC-11 USFWS 11/14/2012 “In order to quantify new mercury inputs to the reservoir,
the study must obtain information about the pre-
impoundment surface area to be flooded and characterize
the underlying geology, soil type and biomass types and
amounts in the zone to be flooded, and then translate that
information into quantitative amounts of mercury inputs and
quantitative rates of mercury methylation using modeling.
The PSP begins to address this need, by “gathering
information” about these factors and “assessing mercury
a) The primary source of mercury to reservoirs is inundated fine
organic material. This material is being sampled and analyzed
(Sections 5.7.4.2.1 and 5.7.4.2.2). However, the concentration and
type of mercury inputs are not good indicators of whether a
methylmercury problem will occur in a reservoir, because the
amount of inorganic mercury available does not control
methylmercury production. Some mercury reservoir models (Harris
and Hutchison, 2008, Hydro-Quebec 2003) do not incorporate
mercury sources into methylmercury predictive equations for this
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components”. However, the PSP does not necessitate the
following:
a) It does not attempt to quantify mercury inputs to the
system.
b) It does not attempt to quantify rates of mercury
methylation post-impoundment.
c) It does not attempt to quantify uptake and
biomagnification of MeHg in reservoir
organisms.
d) It does not attempt to quantify levels of MeHg at any
trophic level of the reservoir food chain post-impoundment.
It is essential that the PSP both commit to these objectives,
and also specify methodology to accomplish each of these
objectives. A methodology to model mercury over time
within the system must be specified, and the specific
parameters needed for the model must be identified, to
ensure that the necessary data are collected in an
appropriate way.” –pdf page 46
reason.
b) Mercury methylation rates will be determined using the EFDC
modeling (see RSP Section 5.6.4.8).
c) Uptake and biomagnification will be addressed by fish, bird, and
mammal sampling, and application of a predictive risk analyses for
all species which significant samples are available, as well as
mercury modeling in fish (see RSP Section 5.7.4.3).
d) The proposed study quantifies methylmercury impacts at the
chemistry/bacterial level, with fish, and terrestrial wildlife that may be
susceptible to exposure (birds and aquatic mammals).
We believe that the RSP satisfies these concerns.
MERC-12 USFWS 11/14/2012 “Document mercury increases at other hydro projects in
boreal forested landscapes. Attempts at modeling mercury
methylation in surface waters are constrained by numerous
required assumptions (e.g. methylation and demethylation
rates, carbon limitations, sulfate and sulfide limitations,
microbial community dynamics, parent geology and
mercury content/leachability, hydrologic controls,
aerobic/anaerobic boundary layer controls, etc.). The costs
associated with developing and applying a modeling
framework are still met by the need to validate the model
with actual site-specific field data (e.g. MeHg in fish over
time). To obtain an upper-bound on what the potential
increase in MeHg in fish might be as a function of reservoir
formation, the resulting increases in MeHg in fish from other
Documentation of mercury methylation at other hydro projects in boreal
forested landscapes is presented in RSP Section 5.7.2. It has been
documented in studies of other reservoirs (Hydro Quebec, 2003, Harris
and Hutchison, 2008, Schetagne et al., 2003, etc.) that most of the
“required assumptions” listed are not necessary to predicting
methylmercury concentrations in fish and wildlife as a result of inundating
of the land with a reservoir.
Publications of most of the authors listed to be reviewed are included as
the references in the RSP.
EFDC will incorporate known dynamics of methylmercury generation
from terrestrial sources that would be inundated to form the reservoir as
part of the model (see RSP Section 5.6.4.8).
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Hydro sites needs to be documented. This requires not only
reviewing peer-reviewed literature, but contacting directly
agencies such as Quebec Hydro, Manitoba Hydro,
Environment Canada, and authors of noted peer-review
articles on the issue of enhanced MeHg in fish from
reservoir formation. These include Vince St. Louis, Mariah
Mailman, Britt Hall, K. Kruzikova, Reed Harris, Carol Kelly,
John Rudd, S. Castelle, Dave Krabbenhoft and Drew
Bodaly among others. There have been many lessons
learned on how MeHg increases in fish upon flooding and
impoundment and AEA’s study plan needs to demonstrate
that that knowledge base has been incorporated into their
plan. Additional topics that would benefit from this level of
communication would be documenting whether the EFDC
model (or any other model) has been developed and
calibrated for mercury in the context of reservoir formation.
Also, Scandinavian countries may have addressed this
issue in detail and contacting the list above may provide
access to individuals in Sweden, Norway, and Finland who
could advance the Project’s knowledge base.” –pdf page 47
MERC-13 USFWS 11/14/2012 “Do not assume mercury to be a simple, conservative
behaving metal. It is known that mercury transforms into a
more bioaccumulative neurotoxin, MeHg, as waters are
flooded in boreal forested landscapes (St. Louis et al.,
2004; Mailman et al. 2006; Porvari and Verta, 1995).
Incorporating the knowledge base on the key parameters
affecting methylation at high latitudes needs to be
addressed in detail by AEA’s study plan well before
construction. The reason for this importance is that
watershed-scale amendments (e.g. tree removal,
vegetation burning), may be worthwhile for mitigating the
MeHg risks. Mailman et al. (2004) identify several
strategies that need a thorough review by the proposed
study relative to MeHg formation: “Possible strategies
reviewed in this article [Mailman] include selecting a site to
minimize impacts, intensive fishing, adding selenium,
No assumption was made regarding the simplicity of mercury in the
ecosystem, and the references in the comments are largely incorporated
into the text of the RSP (Section 5.7.2).
Consideration of potential mitigation, such as those strategies identified
by Mailman et al. (2004), is outside the scope of the RSP, and is
premature prior to data collection and analysis. However, as explained in
RSP Section 5.7.4, data collected will be used to provide background
concentrations for mercury, and will also help evaluate potential
mitigation methods (e.g., soil and vegetation removal) should that
become necessary.
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adding lime to acidic systems, burning before flooding,
removing standing trees, adding phosphorus,
demethylating MeHg by ultraviolet light, capping and
dredging bottom sediment, aerating anoxic bottom
sediment and waters, and water level management.” It is
acknowledged that excluding as many wetlands from the
inundated area may be a recommendation (following
findings from ELA, Ontario), but that may not be possible
given the site topography.” –pdf page 47
MERC-14 USFWS 11/14/2012 Baseline mercury levels should be determined in fish-eating
birds from the study area, by measuring mercury in
feathers.
The Service’s study request includes an objective to
document baseline mercury levels in piscivorous wildlife in
the reservoir area, as measured in fur (for mink and river
otter) and feathers (avian piscivores).
Bird feathers are an excellent tissue for determining
mercury body burden in birds, and feathers can be
collected non-invasively.
Mercury levels should be characterized in as many
piscivorous bird species as possible in the study area, with
a focused effort to include representative species for all
relevant guilds. Raptors such as eagles and osprey,
waterfowl such as loons and mergansers, and smaller birds
such as kingfishers should all be assessed. Risks posed by
mercury are likely to vary among piscivorous avian species,
due to different exposure and dosage rates based on diets
and body sizes. There may also be differing thresholds of
mercury toxicity among species based on species-specific
sensitivities to mercury. –pdf page 48
Agreed.
Section 5.7.4.2.5 discusses the collection and use of feathers from fish-
eating birds, including eagles, osprey, loons, and kingfishers to
determine baseline mercury levels. Non-invasive feather sampling will be
conducted for as many specimens of piscivorous species as possible in
the area.
Aquatic furbearers (mink and river otter) that eat fish are included in the
sampling program as well (Section 5.7.4.2.5).
MERC-15 USFWS 11/14/2012 The PSP should perform an ecological risk assessment for
mercury toxicity in piscivorous wildlife in the study area.
The AEA’s PSP misses the mark in saying that “detection
Samples from piscivorous fish, birds and aquatic mammals will be
collected and tested for mercury as part of the study (Section 5.7.4.2).
Predictive risk analyses (Section 5.7.4.2.5.3) will be performed for
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of mercury in fish tissue and sediment will prompt further
study of naturally occurring concentrations in soils and
plants and how parent geology contributes to
concentrations of this toxic (sic) in both compartments of
the landscape.” Abundant scientific literature cited in our
study request documents that flooding previously terrestrial
environments creates conditions for substantial NEW
INPUTS of mercury into the system, and NEW
CONDITIONS for methylation of mercury and subsequent
bioaccumulation – especially in Northern environments.
Therefore, CURRENT mercury content of fish in the
Susitna River is not a necessary pre-condition for the need
to study future, project-specific impacts of NEW mercury
inputs and dynamics.
In order to characterize the mercury-related risks to
ecological receptors posed by the project, AEA must
perform an ecological risk assessment for each piscivorous
species in the project area.
The amount of mercury ingested by individuals of each
piscivorous species must be estimated based upon dietary
information and modeled mercury levels in food items post
impoundment. –pdf page 48
sensitive piscivorous birds and mammals (Section 5.7.4.2.5.3). This EPA
approved method determines the ratio of the potential exposure to the
substance and the level at which no adverse effects are expected.
Species selected are those most likely to be impacted by methylmercury
in the Project area. EPA suggests that a predictive risk analysis is a
better indicator than a risk assessment for potential impacts on the
terrestrial wildlife, since the number of samples that may be collected will
be low due to low wildlife density (US EPA, 1997). The predictive risk
analysis includes dietary estimates.
Human exposure to methylmercury is predominately via consumption of
impacted fish. EPA and ADEC have extensive guidelines to protect
human health from this source of methylmercury, and no risk assessment
for human health is necessary.
Screening level models have been reasonably accurate in predicting
future methylmercury concentrations in fish based on current
methylmercury concentrations in fish. These models are based on 35+
year studies in dozens of reservoirs in northern climates (Harris and
Hutchison, 2008).
There is significant value in establishing background methylmercury
concentrations in the study area prior to reservoir development, given
that naturally occurring elevated methylmercury have been previously
reported in the area (ADEC 2012).
MERC-16 USFWS 11/14/2012 A one-time, late-summer fish survey is inadequate to
monitor dynamic background mercury concentrations. –pdf
page 49
Fish were captured in 2012 as part of this study and will be used in
addition to the samples collected in 2013 The “one-time” survey of 2013
involves collection of dozens of samples from multiple species over a
period of two months in 2013. AEA anticipates collecting and analyzing
as many as 100 individual samples. In addition, ADEC has been
collecting background data on methylmercury in fish on the Susitna
River, and that data will be incorporated into this study as well (see Table
5-7.4 of the RSP).
For comparison purposes, Hydro-Quebec, in their extensive study of
methylmercury impacts from existing reservoirs, collected 131 lake trout
from 7 lakes over a period of 22 years (Hydro Quebec, 2003). This
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comes to less than 1 fish per water body per year. AEA is proposing
collecting many more fish over a shorter period of time.
Methylmercury concentrations in fish vary far more by species, age,
reservoir size, and location, than they do “dynamically” (Section
5.7.4.2.6). The proposed collection time (mid to late summer)
corresponds to the time when most fish in the reservoir may be
harvested by humans and wildlife, and is therefore representative of
exposure conditions to other trophic levels. Studies have shown that
methylmercury in fish peaks with shallow water temperature in northern
climates (Section 5.7.4.2.6), therefore the timing should correspond to
maximum methylmercury concentrations and exposure.
MERC-17 USFWS 11/14/2012 Toxics modeling is cited (5.5.4.4), but this cannot be done
on the basis of “…will be conducted…” The toxicity of
MeHg in fish and biota must be more pro-actively
addressed in terms of:
a) How much increase in MeHg in biota and fish can
be expected? (i.e., what has been the range of
MeHg increases at other reservoirs?)
b) Studies have acknowledged that MeHg toxicity
may be reduced by a number of possible
management strategies, many of which would
need considered and implemented before
construction. These need addressed.
c) How will human and ecological health be
considered (i.e. maintaining public health) in light
of the likely increase in MeHg in fish?
In summary, AEA’s study plan must assume that there will
be an increase in fish mercury concentrations as a result of
the formation of the reservoir. Managing this risk, modeling
it, and monitoring it should be developed in accordance
with what has been found at other similar landscapes –pdf
page 49
a) The proposed modeling will estimate increases in
methylmercury production in the reservoir as a whole, fish, and
piscivorous wildlife. See Section 5.7.4.3
b) The Mercury Assessment and Potential for Bioaccumulation
Study scope does not include development of any detail
regarding management of a problem that has not yet been
measured or predicted, see AEA’s response to comment
MERC-08.
c) .For a response on how human and ecological health will be
considered, see AEA’s response to comment MERC-27.
For a response to USFWS’s summary comment, see AEA’s response to
comment MERC-28.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 52 December 2012
Mercury Assessment and Potential for Bioaccumulation Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
MERC-18 USFWS 11/14/2012 PSP “Page 5-164, first paragraph: discussion does not
make sense. The State of Alaska (SOA) measured total
mercury in salmon and other freshwater fish species from
the Susitna River drainage. Contrary to the discussion, the
SOA does not compare fish mercury concentrations to
water quality standards. Unlike some other states such as
Oregon, SOA does not base mercury water quality
standards on fish concentrations. Table 5.12-1 reveals
mean concentrations of mercury in several fish species
from the Susitna Drainage (arctic char, northern pike, pink
salmon and lake trout) that are above levels deemed safe
for unlimited consumption by women of childbearing age,
as determined by the Alaska Division of Public Health
(Verbrugge 2007).” –pdf page 49
In response to this comment, the Mercury Assessment and Potential for
Bioaccumulation Study does not include the reference paragraph.
MERC-19 USFWS 11/14/2012 PSP “Page 5-163, paragraph 5: The report states “At
Costello Creek only 0.02 percent of the mercury detected
(in what – sediments?) was found to be methylated. This
study suggests, based on limited data, that mercury
concentration varies significantly between separate
drainages, and that methylation is also tributary specific”.
This may be true for sediments, but is very unlikely to be
true for fish. As a general rule, mercury in fish tissue is
nearly 100% methyl mercury (Bloom 1992).” –pdf page 49
Mercury concentrations in fish are typically nearly 100% methylmercury,
however, the Susitna River system is very large, and there are notable
variations in methylmercury concentrations between species in different
parts of the drainage. Mercury methylation in natural systems is
dependent on the amount of wetlands connected to those drainages, and
the migration patterns of fish. Previous studies (St. Louis et al. 1994)
have shown that methylmercury occurrence is positively correlated with
wetland density. The Deshka River has significantly more wetlands in the
drainage than other tributaries to the Susitna River, thus resident fish
may display higher methylmercury concentrations (Frenzel, 2000). See
Section 5.7.2.
MERC-20 USFWS 11/14/2012 PSP “Page 5-168, Section 5.12.4.3.2 Fish Tissue: The
report states, “Body size targeted for collection will
represent the non-anadromous phase of each species life
cycle (e.g., Dolly Varden; 90 mm – 125 mm total length to
represent the resident portion of the life cycle.)” This makes
some sense, in order to understand the amount of mercury
in the fish that is clearly attributed to the local environment.
However, for risk assessment purposes it is also important
to sample fish that are representative of those taken for
consumption by humans and wildlife receptors. Specifically,
Section 5.7.4.2.6 identifies the collection of adult specimens, which
should represent the highest mercury concentration for each species.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 53 December 2012
Mercury Assessment and Potential for Bioaccumulation Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
large adult fish that are targeted by anglers (and bears)
should also be sampled, to determine how much additional
mercury can “safely” be added from the project before
consumption advisories are warranted.” –pdf page 49
MERC-21 USFWS 11/14/2012 PSP “Page 5-170, Section 5.12.4.5: “Pathway assessment
of mercury into the reservoir…” The water quality modeling
this section refers to (from Section 5.6) does not have the
capacity to predict mercury inputs from inundated bedrock,
soils and vegetation, mercury fate and transport, mercury
methylation, or mercury uptake by biota. Studies 5.6 and
5.12 point to each other, but neither actually does this
critical mercury modeling work. A concerted, specific
mercury modeling component is essential and must be
added.” –pdf page 50
Section 5.7.4.4 contains a discussion of methylmercury sources and
migration pathways. Mercury modeling is discussed in detail throughout
Section 5.7.4.3.
MERC-22 USFWS 11/14/2012 PSP “Section 5.12.6 Schedule: Two additional monitoring
activities needs to be added to this table and scheduled: 1)
Quantitative modeling of mercury inputs, rates of
methylation, and uptake by biota; and 2) Ecological risk
assessment for mercury exposure to avian and mammalian
piscivores in the study area” –pdf page 50
Quantitative modeling of mercury inputs is not included in the Mercury
Assessment and Potential for Bioaccumulation Study RSP. Mercury
inputs are acknowledged to exist. Mercury is not necessarily the problem,
methylation of mercury is the principal concern. Methylation will be
modeled as part of the EFDC modeling (see Section 5.6.4.4).
A predictive risk analyses will be performed for sensitive piscivorous
birds and mammals (Section 5.7.4.2.5.3). This EPA approved method
determines the ratio of the potential exposure to the substance and the
level at which no adverse effects are expected. The standard exposure
level is calculated over a similar exposure period and is estimated to
pose no appreciable likelihood of adverse health effects to potential
receptors. Species selected are those likely to be impacted by
methylmercury in the Project area.
EPA suggests that a predictive risk analysis is a better indicator than a
risk assessment for potential impacts on the terrestrial wildlife, since the
number of samples that may be collected will be low due to low wildlife
density (US EPA, 1997). The predictive risk analysis includes dietary
estimates.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 54 December 2012
Mercury Assessment and Potential for Bioaccumulation Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
MERC-23 NMFS 11/14/2012 “The adoption of the concept of mercury with dynamic
background. The PSP should adopt an approach of
documenting and assessing the dynamic background
concentrations of mercury and methylmercury, particularly
in fish and biota over time (not just in the landscape prior to
construction). In other words, it is stated that enhanced
formation of MeHg in reservoirs has been documented
(section 5.12.2). The ABA plan should assume the increase
in fish Hg will happen and detail how this risk will be
assessed, monitored, and managed as a public health
issue. There will be significant concerns regarding human
and ecological health and risk assessment and the
proposed study needs to outline clearly how these risks will
be documented, assessed, and managed.” –pdf page 58
The Mercury Assessment and Potential for Bioaccumulation Study scope
does not include development of detail regarding management of a
problem that has not yet been measured or predicted. The RSP will
provide information that AEA will rely upon in its environmental analysis
supporting its FERC License Application.
There are many ways to manage methylmercury, and how the issue is
managed, or whether it needs to be managed, is something that will need
to be assessed based upon the outcome of that environmental analysis.
Predictive risk analyses (Section 5.7.4.2.5.3) will be used to estimate
risks to wildlife. Human health will be protected utilizing ADEC and EPA
standards for fish consumption.
MERC-24 NMFS 11/14/2012 “The PSP should document mercury increases at other
hydro projects in boreal forested landscapes. Attempts at
modeling mercury methylation in surface waters are
constrained by numerous required assumptions (e.g.
methylation and demethylation rates, carbon limitations,
sulfate and sulfide limitations, microbial community
dynamics, parent geology and Hg content leachability,
hydrologic controls, aerobic/anaerobic boundary layer
controls, etc.). The costs associated with developing and
applying a modeling framework are still met by the need to
validate the model with actual site-specific field data (e.g.
MeHg in fish over time). To obtain an upper-bound on what
the potential increase in MeHg in fish might be as a function
of reservoir formation, the resulting increases in MeHg in
fish from other Hydro sites needs to be documented. This
requires not only reviewing peer-reviewed literature, but
contacting directly agencies such as Quebec Hydro,
Manitoba Hydro, Environment Canada, and authors of
noted peer-review articles on the issue of enhanced MeHg
in fish from reservoir formation. These include Vince St.
Louis, Mariah Mailman, Britt Hall, K. Kruzikova, Reed
Harris, Carol Kelly, John Rudd, S. Castelle, Dave
See AEA’s response to comment MERC-12.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 55 December 2012
Mercury Assessment and Potential for Bioaccumulation Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
Krabbenhoft and Drew Bodaly among others. There have
been many lessons learned on how MeHg increases in fish
upon flooding and impoundment and the ABA plan needs to
demonstrate that that knowledge base has been
incorporated into their plan. Additional topics that would
benefit from this level of communication would be
documenting whether the EFDC model (or any other
model) has been developed and calibrated for mercury in
the context of reservoir formation. Also, Scandinavian
countries may have addressed this issue in detail and
contacting the list above may provide access to individuals
in Sweden, Norway, and Finland who could advance the
project's knowledge base.” –pdf page 58
MERC-25 NMFS 11/14/2012 The PSP should not assume mercury to be a simple,
conservative behaving metal. If the revised study plan
assumes that mercury behavior is complex, then NMFS will
have better information to make recommendations to
minimize the project effects. The PSP should include
continuous mercury level monitoring.
Incorporating the knowledge base on the key parameters
affecting methylation at high latitudes needs to be
addressed in detail by AEA' s plan well before construction.
The reason for this importance is that watershed-scale
amendments (e.g. tree removal, vegetation burning), may
be worthwhile for mitigating the MeHg risks. Mailman et al.
(2004) identify several strategies that need a thorough
review by the proposed study relative to MeHg formation. –
pdf page 58
See AEA’s response to comment MERC-13.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 56 December 2012
Mercury Assessment and Potential for Bioaccumulation Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
MERC-26 NMFS 11/14/2012 A one-time, late-summer fish survey is inadequate to
monitor dynamic background mercury concentrations.
Study methodologies for toxics modeling is cited (5.5.4.4),
but more explanation is necessary to determine the
adequacy of the study. –pdf page 59
See AEA’s response to comment MERC-16.
MERC-27 NMFS 11/14/2012 How will human and ecological health be considered (i.e.
maintaining public health) in light of the likely increase in
MeHg in fish? –pdf page 59
Human and ecological health will be protected using the following:
1) Establishing baseline conditions for methylmercury in the
environment and sensitive eco receptors (Section 5.7.4.2).
2) Predicting methylmercury formation in the reservoir using
EDHC (Section 5.6).
3) Predicting methylmercury concentrations in sensitive fish,
birds, and aquatic mammals using two models (Section
5.7.4.3).
4) Predictive risk analyses (Section 5.7.4.2.5.3) will be used to
estimate risks to wildlife. Human health will be protected
utilizing ADEC and EPA standards for fish consumption.
5) Monitoring the reservoir post-impoundment to make sure
resulting methylmercury concentration are consistent with
model predictions and managing the resources going forward
based on the risks identified in steps 1 to 3.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 57 December 2012
Mercury Assessment and Potential for Bioaccumulation Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
MERC-28 NMFS 11/14/2012 “In summary, the AEA plan needs to assume that there will
be an increase in fish mercury concentrations as a result of
the formation of the reservoir. Managing this risk, modeling
it, and monitoring it needs to be developed in accordance
with what has been found at other similar landscapes.
Studies have acknowledged that MeHg toxicity may be
reduced by a number of possible management strategies,
which must be considered and implemented before
construction. With the improvements we suggested and
providing an analysis of project design management
strategies will allow NMFS to make recommendations on
project operations and construction to minimize effects to
water quality, and to fish and their habitats.” –pdf page 59
Section 5.7.4.3 outlines three methods for modeling methylmercury
production and impact from the reservoir. Two models predict fish tissue
concentrations of methylmercury for piscivorous and non-piscivorous fish
species; one predicts methylmercury formation in the reservoir.
The Harris and Hutchison model used over 35 years of fisheries studies
in reservoirs and a regression equation to develop a model to predict
peak mercury concentrations in fish in reservoirs, based only on the
flooded area, total reservoir area and mean annual flow (Harris et al.,
2008). The phosphorus release model is being used by both Hydro
Quebec and Manitoba Hydro, and this model was calibrated against data
from whole-ecosystem reservoir experiments at the Experimental Lakes
Area (ELA) in Ontario, Canada (Bodaly at al, 2005). It predicts peak fish
mercury levels and the timing of the response to flooding.
The Mercury Assessment and Potential for Bioaccumulation Study scope
does not include the development of detail regarding the management of
a problem that has not yet been measured or predicted. The RSP will
provide information that AEA will rely upon in its environmental analysis
supporting its FERC License Application.
There are many ways to manage methylmercury, and how the issue is
managed, or whether it needs to be managed, is something that will need
to be assessed based upon the outcome of that environmental analysis.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 58 December 2012
Geomorphology Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
GEO-01 ADNR-
DGGS 11/14/2012 Page 5-69 in PSP section 5.8.4.3.3 “Will there be an
opportunity to comment on the Geomorphology report?” –pdf
page 13
Yes. There will be opportunities to comment on the Initial Study Report
(ISR) and the Updated Study Report (USR). There will also be
opportunities to provide input on technical memorandums within the
context of the Technical Workgroup meetings. See the Geomorphology
Study and the Fluvial Geomorphology Modeling below Watana Dam Study
(Table 6.5-5 and 6.5-6) indicate numerous intermediate Technical
Memorandums as well as the ISR and USR.
GEO-02 CWA 11/14/2012 Scope is insufficient in studying the Lower River based on
AEA’s apparent assumption that Project effects will not
significantly affect the Lower River geomorphology. –pdf
page 7
AEA is not assuming there are no Project effects on instream flow or
channel morphology in the Lower River Segment. The downstream study
limit for the Fluvial Geomorphology modeling effort has been identified as
RM 75, which includes 23.5 miles of the Lower Susitna River Segment
including all 14.5 miles of Geomorphic Reach LR-1 (RM 98.5 to RM 84)
and the upper 9 miles of Geomorphic Reach LR-2. The downstream limit
for the Fluvial Geomorphology Modeling below Watana Dam Study will be
confirmed or adjusted based on review of study results at several stages.
This process and criteria for modifying the lower extent of the study area
are presented in Section 6.6.3.2 of the Fluvial Geomorphology Modeling
below Watana Dam Study Plan and Section 8.5.3 of the Instream Flow
Study. The first review will be conducted in Q1 2013 as initial results of
study component 6.5.4.6. Reconnaissance-Level Assessment of Project
Effects on the Lower and Middle Susitna River Segments and Open-Water
Flow Routing Model are available (Section 8.5.4.3) and the Operations
Model (Section 8.5.4.3.2). A second check-in will occur after the results of
the initial runs of the 1-D bed evolution model become available. Several
of the efforts in the Geomorphology Study extend to either RM 28 or RM
00 such as the mapping of geomorphic features and comparison of current
and historical channel locations (Section 6.5.4.4).
Also see AEA’s response to comment FGM-26.
GEO-03 NMFS 11/14/2012 “The study plan includes several locations where additional
data will be collected to supplement historical data (to be
performed by the USGS). These locations are on the Susitna
River mainstem (near Tonsina Creek, at the Susitna River
Gold Creek gage, and the Susitna River at Sunshine, the
Chulitna River near the mouth). The PSP proposed to use
Section 6.5.4.2.2 describes review and assessment of the adequacy and
applicability of the historical sediment transport data for the Susitna River
at Gold Creek, the Susitna River at Sunshine and the Chulitna River near
Talkeetna. Based on review of the historical data collected by the USGS
(USGS 1987), AEA has decided to include collection of sediment transport
data at the Talkeetna River near Talkeetna gage in 2013.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 59 December 2012
Geomorphology Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
this information with other available data to calculate the
sediment input from major tributaries. The sediment transport
data collected at the Chulitna and Talkeetna Rivers are
necessary to reduce error and increase understanding of
sediment transport associated with the large and small
tributaries and dispersed sediment input associated with
hillslope and mass wasting processes. In view of this, NMFS
requests that the study review the available and collected
sediment transport data for adequacy to geomorphology
models and characterize sediment transport in the Susitna
River system.” –pdf page 42
GEO-04 Teich, Cathy 11/13/2012 Request for studies to determine if changes in the flow of the
Susitna would affect the flow of the Chulitna and Talkeetna
rivers, given the floods of 2012, would the project increase
erosion and put the town of Talkeetna or other settlements at
risk. –pdf page 1
To address this potential Project effect a concurrent flow/stage analysis for
the Susitna, Chulitna and Talkeetna rivers using the existing hydrology
and with-Project hydrology to ascertain the influence the Project may have
on the flow characteristics of the Susitna in the Talkeetna area has been
added to Section 6.5.4.6.2.1 of the RSP. If this analysis shows a
significant change in the relationship during peak flows, then a hydraulic
model would be developed for several miles of the Talkeetna River and
possibly the Chulitna, so that Project effects on the hydraulics of the
Talkeetna River (and possibly the Chulitna) near its confluence with the
Susitna River can be quantified. This would include evaluation of hydraulic
parameters that influence erosion including stage, depth, velocity and
shear stress.
GEO-05 CCC 11/15/2012 “There does not appear to be any significant study of the
Chulitna.”
The Chulitna River is studied in terms of its contribution of sediment and
water (flow) to the Susitna. This includes the development of a 61 year
extended record of daily flows on the Chulitna River, collection of sediment
transport data in 2012 and 2013, and the determination of the various
components of the sediment supply from the Chulitna River (fines, sand
and gravel) (See Sections 6.5.4.2 and 6.5.4.3). In response to other
comments received on the PSP, a concurrent stage and flow analysis has
been added to the Streamflow Assessment (Section 6.5.4.6.2.1) to identify
the potential for the Project to affect flow patterns during periods of high
flow on the Chulitna and Talkeetna Rivers.
GEO-06 FERC 11/14/2012 “Clearly describe the exact number, location, and spatial Section 6.6.3.1 of the Fluvial Geomorphology Modeling below Watana
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 60 December 2012
Geomorphology Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
extent of your proposed focus areas for each proposed
study. Provide justification for the number of proposed sites
selected for detailed 2-D hydraulic modeling and other
intensive study elements. Include criteria to be used for
selecting focus areas and study-specific rationale for co-
locating sites.” –pdf page 5
Dam Study introduces the concept of the Focus Areas including the need
to apply a 2-D bed evolution model at most Focus Areas rather than the 1-
D bed evolution model. Section 6.6.4.1.2.4 provides the details on the
involvement of the Geomorphology Studies in the Focus Area site
selection. This includes the exact location (RM), number of sites (10) and
geomorphic criteria (one site in each geomorphic reach and representative
of the range of geomorphic features found in the reach) and modeling
criteria (extent of site for proper boundary conditions use modeling
approach). Table 6.6-5 identifies the Focus Areas and their extent in RMs.
Additional detail on the overall Focus Area selection process is provided in
the Fish and Aquatics Instream Flow Study (Section 8.5.4.2). This includes
maps of the individual Focus Area showing upstream and downstream
limits and discussion of fish use and habitat information applied in the
Focus Area selection process.
Additional text was added to Section 6.6.4.1.2.4 to further respond to this
comment.
GEO-07 FERC 11/14/2012 “Geomorphology (Section 6.5) and Fluvial Geomorphology
Modeling (Section 6.6); In section 6.5.4.1, Delineate
Geomorphically Similar [Homogeneous] Reaches, you
describe using an initial geomorphic classification system
containing three single channel reach types and four multiple
channel reach types, based in part on their characteristic
sediment storage features. Table 9.9-4 in section 9.9.5.4.2,
Characterization and Mapping of Aquatic Habitats, describes
mainstem macrohabitat types (main-channel, off-channel,
and tributary) that are nested within these geomorphic reach
types and are defined in part by their characteristic
morphology. It would be helpful if sediment storage features
characteristic of geomorphic reaches were defined or related
more directly to the type of geomorphic features
characteristic of the mainstem habitat types.” –pdf page 8
Sediment storage zones, including mid-channel (braid bars, vegetated
islands) and bank-attached (floodplain) are directly incorporated into the
preliminary classification system addressed in Section 6.5.4.1.2.2.1. A
discussion of the temporal and spatial elements of sediment storage is
provided in Section 6.5.4.1.
GEO-08 FERC 11/14/12 “In section 8.5.3, Study Area, you describe your proposed
hierarchical habitat classification system. Please ensure that
the category descriptions, definitions, and terminology are
The macrohabitat types (main channel, side channel, side slough, upland
slough, tributary mouth and tributary) delineation of the Middle Susitna
River Segment is being performed in 2012 for ~ 50% of the Middle Susitna
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 61 December 2012
Geomorphology Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
consistent with those presented in the Geomorphology
Study, Characterization and Mapping of Aquatic Habitats
Study, and any other related studies. For example, in Table
9.9-4, you describe split-main and braided-main channel
types, which are not described in section 8.5.3. Moreover, in
the description of HSC Study Site Selection, you refer to a
percolation channel, a term that is not used elsewhere.” –pdf
page 10
River Segment in the Geomorphology Study per the 1980s definitions. The
further subdivision of the main channel macrohabitat type identified in
Table 9.9-4 (Multiple split main [changed from “braided-main channel” to
avoid confusion with the reach types] and split main) is being performed by
the Fish and Aquatic Resources over the 1980 macrohabitat type
delineation being supplied by the Geomorphology Study. Similarly, the
identification of backwater areas and beaver complexes will be performed
in the FAR (Section 9.9) study after the Geomorphology Study provides
the results of the habitat delineation per the 1980s definitions. Table 9.9-4,
detailing the habitat classification system reflects this coordination.
GEO-09 ADNR-
DGGS 11/14/2012 Page 5-58 of PSP section 5.8.1 “It is unclear whether due
consideration is being given to the Upper River and the
dam's potential impact on geomorphologic conditions there.”
–pdf page 12
The potential project impacts to the geomorphology of the Upper River are
limited to the reservoir shoreline, the tributary confluences with the
reservoir and the main channel delta at the upstream end of the reservoir.
These are all addressed in Section 6.6.5.8 Reservoir Geomorphology.
GEO-10 ADNR-
DGGS 11/14/2012 Page 5-77 of PSP section 5.8.4.6.1 “Will the potential impact
of wildfires on sediment load be factored into this study?” –
pdf page 13
No. Additional sediment loading scenarios other than the possible increase
in sediment supply to the reservoir from glacial surge are not proposed in
the RSP.
GEO-11 ADNR-
DGGS 11/14/2012 Page 5-88 of PSP section 5.8.4.8.3.2 “Proper terminology
would be 'thawing of permafrost', not 'melting of permafrost.'”
–pdf page 13
Agreed. The two uses of the term “melting of permafrost” was changed to
“thawing of permafrost” in Section 6.5.4.8.2.3.
GEO-12 ADNR-
DGGS 11/14/2012 Pages 5-93 to 5-94 of PSP section 5.8.4.10.2 “Suggest
including an evaluation of potential icings (aufeis) at stream
crossing locations.” –pdf page 13
This is a detail design issue that will not likely be initiated until 2015 as part
of the AEA FERC License Application. The potential for aufeis will be
evaluated during the road engineering phase and measures to address
aufeis formation will be developed. Part of the design criteria would be to
address aufeis icing issues.
GEO-13 TNC 11/14/2012 Focus Area Selection
The study plans are inconsistent on the use of the terms
“focus areas” and “study sites”. In these comments, we
assume that these are intended to be the same places so will
use the term “focus area”. The method for selection of focus
areas is also inconsistent between and within study plans.
Table 8.5-13 of the Fish and Aquatics Instream Flow Study
The terminology in the Geomorphology Study has been edited to refer to
“Focus Areas” rather than “intensive” or “detailed” study sites. The
Characterization of Aquatic Habitats Study (Section 9.9) is preparing “line”
based habitat mapping per the 5-level mapping scheme identified in Table
9.9-4 to be available the end of Q1 2013. The Geomorphology Study is
also preparing polygon based mapping of ~50% of the Middle Susitna
River Segment (Section 6.5.4.5) based on the 1980s definitions of the
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 62 December 2012
Geomorphology Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
(8.5) indicates that Focus Area selection is happening
currently (Q3-4 2012) even before studies are approved or
officially begin. If selection is to be based on the criteria
presented in 8.5.4.2, habitat mapping results from 2013
studies would seem to be required to select focus areas. –
pdf page 2
macrohabitat types (main channel, side channel, side slough, upland
slough, tributary mouth and tributary). This will also be available end of
Q4 2012.
GEO-14 TNC 11/14/2012 Focus Area Selection
Focus areas should be selected based on biological
functions and habitat utilization by salmon as well as physical
processes related to instream flow, including habitat-flow
relationships, surface-groundwater interactions, geomorphic
processes, and ice processes. Biological functions for
salmon (i.e. spawning, rearing, migration, overwintering)
could potentially change with project operations, and
appropriate focus area selection can help to characterize and
quantify that anticipated change. –pdf page 2
The overall selection process, schedule and criteria for the Focus Areas is
provided in the Fish and Aquatics Instream Flow Study (Section 8.5.4.2).
Section 6.6.4.1.2.4 of the Fluvial Geomorphology Modeling below Watana
Dam Study provides the details on the involvement of the Geomorphology
Studies in the Focus Area site selection. This includes the exact location
(RM), number of sites (10) and geomorphic (one site in each geomorphic
reach and representative of the range of geomorphic features found in the
reach) and modeling criteria (extent of site for proper boundary conditions
use modeling approach).
GEO-15 TNC 11/14/2012 Focus Area Selection
Focus areas should be selected in the Middle and Lower
Rivers. The river from the three river confluence and below is
especially dynamic. Focus areas in the Lower River are
required to understand changes to salmon habitat due to
project operations. As noted in our comments on Climate
Change impacts above, the cumulative impacts of this
project with other anticipated changes to the basin could
affect salmon and salmon habitat in the Lower River”. –pdf
page 2
Although both Middle and Lower River segments are under consideration
as part of the IFS, the majority of detailed study elements described in the
RSP are concentrated within the Middle River Segment. This is because
project operations related to load-following and variable flow regulation will
likely have the greatest potential effects on this segment of the river.
These effects tend to attenuate in a downstream direction as channel
morphologies change, and flows change due to tributary inflow and flow
accretion. (Please see AEA’s response to comments IFS-016 and IFS-
019 for additional detail). AEA intends to seek TWG input and finalize the
initial set of study areas by February/March of 2013 to enable detailed field
studies to occur. The need to add or redistribute Focus Areas and study
sites into the Lower River Segment will be determined based upon the
results of the open-water flow routing model (see Section 8.5.3). The
downstream study limit for the Fluvial Geomorphology modeling effort has
been identified as RM 75, which includes 23.5 miles of the Lower Susitna
River Segment including all 14.5 miles of Geomorphic Reach LR-1 (RM
98.5 to RM 84) and the upper 9 miles of Geomorphic Reach LR-2. The
downstream limit for the Fluvial Geomorphology Modeling below Watana
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 63 December 2012
Geomorphology Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
Dam Study will be confirmed or adjusted based on review of study results
at several stages. This process is presented in section 6.6.3.2 of the
Fluvial Geomorphology Modeling below Watana Dam Study Plan and
Section 8.5.3 of the Instream Flow Study. The first review will be
conducted in Q1 2013 as initial results of study component 6.5.4.6
Reconnaissance-Level Assessment of Project Effects on the Lower and
Middle Susitna River Segments and Open-Water Flow Routing Model are
available (Section 8.5.4.3). A second check-in will occur after the results
of the initial runs of the 1-D bed evolution model become available.
Several of the efforts in the Geomorphology Study extend to either RM 28
or RM 00 such as the mapping of geomorphic features and comparison of
current and historical channel locations (Section 6.5.4.4).
GEO-16 TNC 11/14/2012 “Lower River Studies
Many of the study plans assume no effects from the project
and its operation below Talkeetna (Mile 97) and do not
include the Lower River in their scope. As noted in our
comments on Climate Change impacts above, the
cumulative impacts of this project with other anticipated
changes to the basin could affect salmon and salmon habitat
in the Lower River. Load-following operation, which will
essentially flip the hydrological pattern between winter and
summer, must be modeled for effects on the Lower River.
The hydrological model has been extended to Mile 84 in the
upper Lower River, and the study plan notes that the model
will be extended further into the Lower River if project effects
are seen at Mile 84. It is not clear what the trigger will be to
extend the model and how or when that will be decided. The
Revised Study Plans, including those for geomorphology,
instream flow, and ice processes, should include the Lower
River. If they do not but leave the possibility open depending
upon early results, the plans should be explicit about why
they assume no effect on the Lower River and what criteria
will be used to revisit the need to extend models when early
results are available.” –pdf page 3
Please see AEA’s response to comments GEO-02 and GEO-15.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 64 December 2012
Geomorphology Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
GEO-17 USFWS 11/14/2012 “Included broad statements regarding collaboration and
integration of specific studies. The Service recommends that
this integration be described in detail. For the
geomorphology and fluvial geomorphology modeling study
plans, this should include: the objectives; methodologies that
address the objectives; and how the results will influence
other studies. This must include data collection and model
results that the geomorphology studies rely on and how
these results will be applied to other studies. For example,
the study plan must describe how the geomorphology study
will use the fish habitat utilization data that the Service
requested to improve the spatial habitat mapping, and how
the results of the geomorphology study will be integrated into
the instream flow study to achieve the Service’s
recommended objectives.” –pdf page 24
AEA has revised the RSP to address this and similar comments. This
includes: text added to Section 6.1 to better explain the relationship
between the Geomorphology Study, Fluvial Geomorphology Modeling
below Watana Dam Study and the various aquatic resource studies
including the Fish and Aquatics Instream Flow Study and Riparian
Instream Flow Study, identification of key indicators that the
Geomorphology studies will provide to the aquatic resource studies, the
wording of the objectives of several study components was modified to be
more in line with the NMFS and USFWS Study requests as well as convey
the actual intended objectives better (these are detailed in subsequent
comment responses made on specific objectives by NMFS, USFWS and
EPA), the study interdependency charts were added to Sections 6.5.6 and
6.6.6 along with tables providing inputs form other studies and products
provided by the Geomorphology studies to other studies. Tables 6.6-5 and
6.6-7 identify specific information that the 1-D and 2-D modeling effort and
the Geomorphology Study will provide other studies. A study component
was added to the Geomorphology Study (Section 6.5.4.11) that describes
the integration of the Geomorphology Study with the Fluvial
Geomorphology Modeling below Watana Dam Study to provide the
support to interpret modeling results and develop the habitat indicators for
the aquatic resource studies. Sections 6.6.4.3 has been modified to more
clearly identify products that the Fluvial Geomorphology Modeling below
Watana Dam Study, in concert with the Geomorphology Study will provide
to the Fish and Aquatics Instream Flow Study (Section 8.5), Riparian
Instream Flow Study (Section 8.6), Ice Processes in the Susitna River
Study (Section 7.6) and Groundwater Study (Section 7.5) Section.
Note: The Geomorphology Study is performing the habitat mapping to the
3rd level, macrohabitat. Subsequent levels of habitat mapping will be
performed in the Fish and Aquatic Resources (Section 9.9). The mapping
performed by the FAR will consider fish habitat utilization data.
GEO-18 USFWS 11/14/2012 “The Service’s study request recommends specific
methodologies. It is unclear in the PSP if the Service’s
proposed methods will be incorporated into the study plan or
why other methods are adequate or better suited to achieve
Service stated study objectives. Methods for channel
Field Data Collection Efforts of the Fluvial Geomorphology Study further
describes the substrate size characterization, and cross-section and
longitudinal profile surveys (Section 6.6.4.1.2.9). AEA proposes that
mapping of the substrate facies within the Focus Area be based on
mapping of the mesoscale habitat unit. This mapping will identify features
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 65 December 2012
Geomorphology Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
substrate size characterization, longitudinal and cross-
sectional bed profiles are not described in this proposed
study plan. In the Geomorphic Characterization of the River
section of the Service’s study request, we recommend bed
material characterization to include spatial sediment facie
mapping (Buffington and Montgomery 1999), pebble counts
(Wolman 1954), and bulk samples.” –pdf page 24
at the scale of the individual habitat units that include riffles, pools, runs,
meso-scale bars (i.e., dimensions on the order of the channel width in side
channels and sloughs), banklines, large LWD clusters and similar features.
Characteristics of the substrate making up these features will be measured
using techniques appropriate to the size range of the material in each unit.
In coarse-grained areas (i.e., gravel and cobbles), surface samples will be
taken using the pebble count method (Wolman, 1954). In areas where the
material is sufficiently fine (i.e., sand and fine- to medium-gravel), bulk
samples will be collected for laboratory grain size analysis.
GEO-19 NMFS 11/14/2012 “In NMFS's study request, we suggest specific
methodologies. We request that each of our requests be
examined and responded to, either by being incorporated
into the study plans or providing explanations why other
methods are adequate or better suited to achieve NMFS's
stated study objectives. Methods for channel substrate size
characterization, longitudinal and cross-sectional bed profiles
are not described in this proposed study plan. In the
Geomorphic Characterization of the River section of NMFS's
study request (1.3.5.2), we requested bed material
characterization to include spatial sediment facie mapping
(Buffington and Montgomery 1999), pebble counts (Wolman
1954), and bulk samples.” –pdf page 41
See AEA’s response to comment GEO-18.
GEO-20 USFWS 11/14/2012 “The revisions for the geomorphology and fluvial
geomorphology modeling study plans should provide a
description of the expected end-product, and whether these
results will be sufficient to address Project effects to
anadromous fish habitat. The study plan should also include
a description of uncertainties associated with the studies,
models, and analysis of project effects and how these
uncertainties are determined.” –pdf page 24
Identification of the information to be supplied from the Geomorphology
Study to support the Fluvial Geomorphology Modeling below Watana Dam
Study is identified in Section 6.5.4.11. The study interdependencies charts
and associated discussions in Section 6.5.6 and 6.6.6 also identify
products and associate schedule for delivery to various studies that will
require the results of the Geomorphology Study to evaluate project effects
on aquatic resources. Section 6.6.4.3 identifies the end-products that will
be delivered through the combination of the Fluvial Geomorphology
Modeling and Geomorphology studies to facilitate evaluation of Project
effects on anadromous fish and other aquatic resources can be evaluated
by the Fish and Aquatics Instream Flow Study (Section 8.5).
To assist in identifying and understanding uncertainties, sensitivity
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 66 December 2012
Geomorphology Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
analysis will be performed for the 1-D and 2-D modeling efforts by varying
key input parameters within the range of physically reasonable values
(Section 6.6.4.2.2.3). Additionally, a range of hydrologic conditions will be
evaluated in the 50 year simulation period to be used for the 1-D model
bed evolution model encompasses a broad range of hydrologic conditions
and will be used to assess the sensitivity of the study areas to hydrologic
variability. The influence of extreme events will be addressed by modeling
the 100-year flood with both 1-D and 2-D models. Variation in response to
the six representative years (wet, average, and dry for wet and cold PDO)
based on both the 1-D and 2-D model results will also provide an
understanding of the uncertainty associated with hydrologic conditions.
GEO-21 NMFS 11/14/2012 “NMFS believes the PSPs to do not sufficiently describe
what they will accomplish and show. The revisions for the
combined geomorphology and fluvial geomorphology
modeling study plans should provide a description of what
can be determined at the end of the studies, and whether the
results will be sufficient to address NMFS requests related to
project effects to anadromous fish habitat. Also, a description
of determining the uncertainties associated with the studies,
models, and analysis of project effects should be provided.”
–pdf page 40
Please see AEA’s response to comment GEO-20.
GEO-22 USFWS 11/14/2012 “Geomorphic characterization of the Project-affected river
channels should include a good understanding of the current
rivers system. This will be achieved by addressing Service
specific objectives and methods, including:
- Characterize and map relic geomorphic forms from
past glaciation, paleofloods and debris flow events
- Characterize and map the geology of the Susitna
River, identifying controlling features to channel
and floodplain geomorphology.
- Characterize and map the fluvial geomorphology of
the Susitna River.
- Describe and identify the primary geomorphic
Subsection 6.5.4.1.2.3 was added to the RSP to clearly indicate that the
effort requested by USFWS and NMFS will be conducted and that a
thorough geomorphic characterization of the existing Susitna River system
will be developed. The understanding of how the system functions
including the formation and maintenance of the geomorphic features that
comprise the important aquatic habitats in the Middle and Lower Susitna
River Segments is necessary to quantify potential Project effects on the
aquatic habitat. Field verification of the mapping effort will be conducted as
part of the field data collection effort described in the Fluvial
Geomorphology Modeling below Watana Dam Study Section 6.6.4.1.2.9.
Revised Study Plan
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FERC Project No. 14241 Page 67 December 2012
Geomorphology Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
processes that create and influence fluvial
geomorphic features.
If the specific objectives we recommend are recognized,
including past glacial form, geology, and characterizing the
fluvial forms and processes, then the study plan should
provide an adequate overall understanding of the river
system function. We recommend the study plan provide
sufficient detail to support that each of the Service study
request objectives are being achieved.” –pdf page 24
GEO-23 NMFS 11/14/2012 “This is a good overarching objective, but that should include
several of NMFS's more specific objectives. NMFS
requested specific study components relative to the river
system functions under existing conditions that were not
addressed in ABA's study plans. The PSP will provide
adequate geomorphic characterization by addressing
NMFS's specific objectives and methods, including the
following tasks:
• Characterize and map relic geomorphic forms from past
glaciation, paleofloods and debris flow events;
• Characterize and map the geology of the Susitna River,
identifying controlling features to channel and floodplain
geomorphology;
• Characterize and map the fluvial geomorphology of the
Susitna River; and
• Describe and identify the primary geomorphic processes
that create and influence fluvial geomorphic features. If the
specific objectives we requested are included, including past
glacial form, geology, and characterization of the fluvial
forms and processes, then the study plan should provide an
adequate overall understanding of the river system function.
But detail should be provided in the revised study plan to
show that each of the NMFS study request objectives is
Please see AEA’s response to comment GEO-22.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 68 December 2012
Geomorphology Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
being achieved.” –pdf page 41
GEO-24 NMFS 11/14/2012 “The additional detail requested will be used to assess the
applicants plan and if it meets the intent of the NMFS study
requests. The additional detail should include a schedule and
methods for attaining habitat utilization, abundance, and
distribution information on anadromous fish species.” –pdf
page 40
The Geomorphology Study is performing the habitat mapping to the 3rd
level, macrohabitat. Subsequent levels of habitat mapping will be
performed in the Fish and Aquatic Resources (Section 9.9.5.4.2 Middle
River and 9.9.5.4.3 Lower River). The mapping performed by the Fish and
Aquatics Resources studies in the Middle and Lower Rivers will “aid in
understanding the behavior, movements, and spatial use of fish in the Fish
Distribution and Abundance in the Upper (Section 9.5) and Middle and
Lower Susitna River (Section 9.6). Habitat characterization will help in
understanding the potential Project effects of the flow regime in the
Instream Flow Study (Section 8).” (Quoted from Section 9.9.8). The
schedule (Section 9.6.6) and methods (Section 9.6.4) for obtaining habitat
distribution and abundance information on anadromous fish in the Middle
and Lower Rivers is presented in Section 9.6.
GEO-25 NMFS 11/14/2012 “A link between geomorphic process and fish habitat is
necessary to understand how the project may influence the
processes that create and maintain fish habitat. NMFS
requested that correlation of geomorphic forms and
processes to riverine habitat types be done for the project
area, and that the project construction and operation be
assessed to evaluate change to the habitat types.” –pdf page
42
The linkage between geomorphic process and fish habitat is first
established in the Subsection 6.5.4.1.2.3 Geomorphic Characterization of
the Susitna River. In-channel (e.g. side channels, bars, islands) and
channel margin (e.g. floodplain, side sloughs) geomorphic subunits are the
foundations for the range of available habitats in the Susitna River, and
thus, an analysis of river and floodplain morphology and morphologic
change over time and space also provides a measure of the distribution
and changes of habitats. Characterization and understanding of the
processes that create influence and maintain the geomorphic subunits
(and therefore, the habitat units) will be updated throughout the study as
further knowledge is acquired through the field data collection and analysis
efforts, and coordination with the other resource teams. The results of
modeling and analysis of the effects of the altered hydrology and sediment
supply under Project conditions on the geomorphic features and
corresponding riverine habitat types will be used to either directly quantify
key habitat indicators or will provide information to the Fish and Aquatics
Instream Flow Study to facilitate quantification of key habitat indicators that
involve both geomorphic and non-geomorphic factors.
GEO-26 USFWS 11/14/2012 “The Service requested that correlation of geomorphic forms
and processes to riverine habitat types be done for the
Please see AEA’s response to comment GEO-25.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 69 December 2012
Geomorphology Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
project area, and that the project construction and operation
be assessed to evaluate change to the habitat types.
Additional information, such as the characterization of
surface area versus flow relationships of riverine habitat
types will help characterize the timing and distribution of
habitat under the natural flow regime.” –pdf page 25
GEO-27 USFWS 11/14/2012 “The PSP includes several locations where additional data
will be collected to supplement historical data (to be
performed by the USGS). These locations are on the Susitna
River mainstem (near Tonsina Creek, at the Susitna River
Gold Creek gage, and the Susitna River at Sunshine, the
Chulitna River near the mouth). The PSP proposes to use
this information with historic information to calculate the
sediment input from major tributaries. The Service maintains
that existing sediment transport data from the Talkeetna
Rivers is insufficient to conduct a sediment budget or to
empirically characterize the Susitna River sediment supply
and transport conditions. Instead, we recommend that
sediment transport data collection be conducted near the
mouths of both the Chulitna and Talkeetna Rivers. The
sediment transport data collected at the Chulitna and
Talkeetna Rivers is necessary to reduce error and increase
understanding of sediment transport associated with the
large and small tributaries and dispersed sediment input
associated with hillslope and mass wasting processes.”
See AEA’s response to comment GEO-03.
GEO-28 USFWS 11/14/2012 “An assessment of the source, transport, and storage of
large woody debris in the Susitna River and the role of large
woody debris in channel form and aquatic habitat is needed
in conjunction with data from the studies of hydrology,
geomorphology, riparian and aquatic habitat, and ice
processes, in order to determine the potential effects of
project operation on large wood resources. The
geomorphology PSP does not specifically state that it will
collect large wood information but it does state that large
wood information will be used in the assessment of Project
An assessment of LWD is included in Section 6.5.4.9 of the study plan and
includes an evaluation of LWD recruitment, loading, function, and potential
project effects. The LWD study will evaluate the interaction of LWD with
hydrology, riparian, aquatic, ice processes, and river geomorphology.
Data will be collected from aerial photographs throughout the entire study
area and field studies in Focus Areas.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 70 December 2012
Geomorphology Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
effects on geomorphology. The Service recommends that the
geomorphology PSP include detail regarding which study will
collect large wood information, the sufficiency of this data
collection to meet the needs of other studies, and how/when
will it be provided to appropriate studies.” –pdf page 25
GEO-29 NMFS 11/14/2012 “NMFS requested an assessment of the source, transport,
and storage of large woody debris (LWD) in the Susitna
River and the role of L WD in channel form and aquatic
habitats to assess the magnitude of these effects. This
information in conjunction with data from the studies of
hydrology, geomorphology, riparian and aquatic habitat, and
ice processes, would be used to determine the potential
effects of project operation on large wood resources. NMFS
requests a description of how LWD data will be collected and
how that information is sufficient to address the role of LWD
debris in geomorphic processes.” –pdf page 42
Please see AEA’s response to comment GEO-28.
GEO-30 USFWS 11/14/2012 “The examination of magnitudes of change of geomorphic
features should also be examined from the perspective of
large wood recruitment. The study plan should explain how
the geomorphology study will incorporate an understanding
of geomorphic change and processes to understand large
wood recruitment.” –pdf page 26
An evaluation of the interaction of LWD with hydrology, riparian, aquatic,
ice processes, and river geomorphology will be completed through
discussions among the appropriate resource specialists during the study
process (Sections 6.5.4.9.2 and 6.6.4.1.2.7). Geomorphic modeling of
potential changes in LWD loading will take place at selected Focus Areas
utilizing the 2-D model. Additional text is included in Section 6.6.4.1.2.7 of
the Fluvial Geomorphology Modeling below Watana Dam Study to
describe the integration of LWD into the overall assessment of potential
changes in geomorphic features. Additional text is included in Section
6.5.4.9.2 to identify support from the Large Woody Debris study
component for the modeling effort.
GEO-31 NMFS 11/14/2012 “We request that, when examining the magnitudes of change
of geomorphic features, the study incorporate LWD
recruitment in the controlling variables (potential to contribute
to channel avulsion) and identify recruitment processes. The
revised study plan should explain how the geomorphology
study will develop an understanding of large wood
Please see AEA’s response to comment GEO-30.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 71 December 2012
Geomorphology Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
recruitment.” –pdf page 42
GEO-32 USFWS 11/14/2012 “We recommend that the conceptual frame work be used
downstream of the proposed dam location longitudinally to
the downstream extent of the modeled area, and that the
study area be extended if the framework calculations find
influence in the lower river.” –pdf page 27
Section 6.5.4.6 describes use of the framework as part of the evaluation to
confirm or alter the downstream study limit in early Q1 2013. The section
has been revised to include application of the framework, the sediment
transport assessment and the streamflow assessment to include both the
Lower and Middle Susitna River Segments and for these tools to be used
throughout the study to help integrate with and interpret results of the
Fluvial Geomorphology Modeling below Watana Dam Study (Section 6.6).
AEA emphasizes that the framework entails more than calculation of the
dimensionless parameters as implied by the comment. As Grant et al.
2003 indicates, other factors influence the sensitivity of the system to
experience channel adjustment as a result of changes in the
dimensionless parameters. The framework will be used in evaluating the
downstream study limit in Q1 2013.
GEO-33 FERC 11/14/2012 In section 6.5.4.5.1, you state that results from Study
Component 5: Riverine Habitat versus Flow Relationship
Middle River will provide the basis for macrohabitat mapping
to support the Instream Flow Study. Please clarify how the
results from study component 5 will be used to quantify total
or usable habitat area under a range of flows as part of the
instream flow study.”
The Geomorphology Study in 2012 is preparing polygon based mapping of
~50% of the Middle Susitna River Segment based on the 1980s definitions
of the macrohabitat types (main channel, side channel, side slough,
upland slough, tributary mouth and tributary). Portions or all of the
remaining Middle River may be mapped in 2013 depending on the specific
data needs of the Fish and Aquatics Instream Flow Study. The mapping is
being performed for three discharges in order to establish surface area vs.
flow relationships for the macrohabitat units defined in the 1980s (main
channel, side channel, side slough, upland slough, tributary mouth and
tributary). This will provide one means by which the Fish and Aquatics
Instream Flow Study determine change in habitat related to alteration of
flows. The habitat mapping can also be used to extrapolate Fish and
Aquatics Instream Flow Study results from Focus Areas to similarly
mapped but not modeled areas. Additional detail on modeling of habitat
versus flow relationships and extrapolation of Focus Area results can be
found in the Fish and Aquatics Instream Flow Study (Sections 8.5.4.6 and
8.5.4.7).
GEO-34 NMFS 11/14/2012 “For the lower river the study plan describes a
reconnaissance level assessment (by assessing
geomorphology and habitat via aerial photography). The
Section 6.5.4.6 describes use of the framework as part of the evaluation to
confirm or alter the downstream study limit in early Q1 2013. The section
includes application of the framework, the sediment transport assessment
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 72 December 2012
Geomorphology Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
applicant proposes that a conceptual frame work be used to
assess project effects to the lower river, below the Chulitna
and Talkeetna confluences. The conceptual frame work
described by the applicant and requested by NMFS and
proposed by the applicant is defined in Grant et al. (2003). It
is unclear where the framework will be applied, we request
that the conceptual frame work be used downstream of the
proposed dam location to the downstream extent of the
modeled area (downstream of Sunshine).” –pdf page 43
and the streamflow assessment to include both the Lower and Middle
Susitna River Segments and for these tools to be used throughout the
study to help integrate with and interpret results of the Fluvial
Geomorphology Modeling below Watana Dam Study (Section 6.6). AEA
emphasizes that the framework entails more than calculation of the
dimensionless parameters as suggested by the comment. As Grant et al.
2003 indicates, other factors influence the sensitivity of the system to
experience channel adjustment as a result of changes in the
dimensionless parameters. The framework will be used in evaluating the
downstream study limit in Q1 2013.
GEO-35 NMFS 11/14/2012 If the framework calculations find that detectable change is
likely in the lower river, then the riverine models should be
extended downstream. This will rely on the development of
the hydraulic flow routing models (see our comments on
instream flow) and will require the extension of this modeling
effort. The decision to extend the mapping and more
qualitative assessments in the lower river must be described,
as well as the determining factor for extension of these study
components. –pdf page 43
See AEA’s response to comment GEO-02.
GEO-36 NMFS 11/14/2012 “Also, because the habitat mapping is being done under the
Geomorphology study plan, the lower extent of that
component must be compared to winter operations and the
potential hydraulic or water quality effects downstream. This
is necessary to assess which habitats and species may be
affected in the lower river.” –pdf page 43
Extension of habitat mapping and flow routing model will be conducted if
the criteria indicate the need to continue the Fish and Aquatics Instream
Flow Study further downstream into the Lower River. Although both Middle
and Lower River segments are under consideration as part of the IFS, the
majority of detailed study elements described in the RSP are concentrated
within the Middle River Segment. This is because project operations
related to load-following and variable flow regulation will likely have the
greatest potential effects on this segment of the river. These effects tend
to attenuate in a downstream direction as channel morphologies change,
and flows change due to tributary inflow and flow accretion (Please see
AEA’s response to comments IFS-016 and -019 for additional detail).
AEA intends to seek TWG input and finalize the initial set of study areas
by February/March of 2013 to enable detailed field studies to occur. The
need for additional Focus Areas and study sites in the Lower River
Segment will be determined based on results of the Open-water flow
Revised Study Plan
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FERC Project No. 14241 Page 73 December 2012
Geomorphology Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
routing model (see Section 8.5.3) Geomorphology Study identified below.
Note: Mapping of geomorphic features for both the 1980s and current
aerial photography is being performed for the entire Lower Susitna River
Segment.
GEO-37 USFWS 11/14/2012 “Characterization of bed material mobilization is described in
the PSP. The methods include use of USGS empirical
sediment rating curves, incipient motion calculations, and
field observations. To achieve the objective of characterizing
bed material mobilization, the bed material must be
characterized as per the Service’s recommendation (see our
comments under the first objective).” –pdf page 26
The computational procedure that will be used to characterize bed material
mobilization is the same as those suggested in the NMFS and USFWS
comment. The relationships from Parker, et al (1982) will be used for bed
material gradations that contain less than about 20 percent sand because
sand in this relatively small fraction does not affect the critical shear stress
for mobilization. For locations in which the bed material contains more
than about 20 percent sand, the relation from Wilcock and Crowe (2003)
will be used because it accounts for the effect of reduced critical shear
stress when substantial sand is present. Both these relationships
recognize the importance of the hiding factor when considering
mobilization thresholds for individual sizes in the overall gradation. It is
common practice to assume a Shields critical value of 0.03 for bed
material mobilization of the median D50 particle size in gravel bed streams,
but there is considerable uncertainty in the precise value, and from a
practical perspective, it is very difficult to define true incipient motion, even
in a laboratory setting. For this reason, both Parker, et al (1982) and
Wilcock and Crowe (2003) define incipient motion based on a small but
non-zero dimensionless transport rate that is a function of the Shields
stress for the D50, and as described in the study plan, this definition will be
adopted for this study. The measured bedload data will be used to validate
(or adjust, if necessary) estimates of bed material mobilization thresholds.
We do not believe that particle tracking through the use of painted rocks or
similar techniques can be used to define general bed mobilization in the
Susitna River because there is no practical way to place the painted rocks
in the key areas in a manner that would be representative of the bed
material structure, and particularly in areas with flowing water. Painted
rocks could be used to help define mobilization thresholds in the shallow
side channels and chutes.
GEO-38 CSDA 11/14/2012 PSP – “Sediment load contributions due to glacial melt and
possible surging glacier event.” CSDA Comment – “The
The analysis of reservoir trap efficiency in Section 6.5.4.8.2.1 includes
analysis of a sediment loading scenario that considers glacial surge if the
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 74 December 2012
Geomorphology Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
impact of silt input into the reservoir and its effect on
operation of the dam is critical. This is the only place it is
mentioned as being considered in planning for the dam, but
there is nothing indicating what kind and the extent of studies
planned if any.” –pdf page 11
Glacier and Runoff Changes Study (Section 7.7.4.4) indicates the potential
for increased sediment delivery to the reservoir. This includes an estimate
of the reduction in reservoir life.
GEO-39 CSDA 11/14/2012 “Silt accumulation in the reservoir is also critical. It is not
clear in any way what is proposed for investigating sediment
load due to glacial melt, if anything.” –pdf page 10
The trapping of sediments in the reservoir will be studied under Section
6.5.4.8.2.1 of the Geomorphology Study. This includes an initial estimate
of sediment trap efficiency based on available equations and relationships
and a more refined estimate based on results of the EFDC modeling of the
reservoir conducted in the Water Quality Modeling Study (Section 5.6).
The analysis of reservoir trap efficiency in 6.5.4.8.2.1 includes analysis of
a sediment loading scenario that considers glacial surge if the Glacier and
Runoff Changes Study (Section 7.7.4.4) indicates the potential for
increased sediment delivery to the reservoir.
GEO-40 CSDA 11/14/2012 “The stability of the reservoir rim, especially in the drawdown
area, is critical. It is difficult to tell what studies, if any, are
proposed to investigate soil liquefaction, solifluction, or
gelifluction effects on the reservoir rim.” –pdf page 10
A description of reservoir erosion studies is included in section 6.5.4.8.2.3
and includes:
• Mass wasting.
• Surface erosion from sheetwash.
• Wave erosion (wind and boat wakes if motorized boat recreation is
permitted).
• Solifluction, freeze-thaw, and thawing of permafrost.
• Beach/bank development at full pool.
• Erosion by ice movement on the reservoir surface.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 75 December 2012
Fluvial Geomorphology Modeling below Watana Dam Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
FGM-01 CWA 11/14/2012 Scope is insufficient in studying the Lower River based on
AEA’s apparent assumption that Project effects will not
significantly affect the Lower River geomorphology, which
should be modeled. –pdf page 7
Please see AEA’s response to comment GEO-02
FGM-02 USFWS 11/14/2012 “Included broad statements regarding collaboration and
integration of specific studies. The Service recommends that
this integration be described in detail. For the
geomorphology and fluvial geomorphology modeling study
plans, this should include: the objectives; methodologies that
address the objectives; and how the results will influence
other studies. This must include data collection and model
results that the geomorphology studies rely on and how
these results will be applied to other studies. For example,
the study plan must describe how the geomorphology study
will use the fish habitat utilization data that the Service
requested to improve the spatial habitat mapping, and how
the results of the geomorphology study will be integrated into
the instream flow study to achieve the Service’s
recommended objectives.” –pdf page 24
Please see AEA’s response to comment GEO-17
FGM-03 ADNR-
DMLW
11/14/2012 “The numerical models currently being developed are for the
primary purpose of gaining a better understanding of
processes. Are there plans to apply a more holistic,
integrated approach during later phases of the analyses?” –
pdf page 9
It has always been the intent of the study to apply a holistic, integrated
multi-disciplinary approach to the Geomorphology studies. A study
component was added to the Geomorphology Study (Section 6.5.4.11)
that describes the integration of the Geomorphology Study with the Fluvial
Geomorphology Modeling below Watana Dam Study to provide the
support to interpret modeling results and develop the habitat indicators for
the aquatic resource studies. Section 6.6.4.3 has been modified to more
clearly identify products that the Fluvial Geomorphology Modeling below
Watana Dam Study, in concert with the Geomorphology Study will provide
to the Fish and Aquatics Instream Flow Study, Riparian Instream Flow
Study, Ice Processes and Groundwater Studies.
FGM-04 FERC 11/14/2012 “Describe in each of the relevant studies how the different
modeling results would be used. Where a parameter is
measured (or estimated using a model) in more than one
study, define which value will take precedence.” –pdf page 5
A model “Precedence Table” (Table 6.6-4) has been added to Section
6.6.4.1.2.2 of the Fluvial Geomorphology Modeling below Watana Dam
Study (FGMS) to identify which models will take precedence in providing
flow and hydraulic information. Additional detail has been added to
Section 6.6.4.3 as to specific parameters the FGMS will be providing
Revised Study Plan
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FERC Project No. 14241 Page 76 December 2012
Fluvial Geomorphology Modeling below Watana Dam Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
other studies (see Table 6.6-6 & 6.6-7).
FGM-05 ADNR-
DMLW 11/14/2012 “There are several different numerical models being
developed to gain a better understanding of processes. Will
there be any cross-checking (as applicable) among the
simulated results from the various models where overlap
occurs? In other words, is there consensus among the
simulated results (as applicable)?” –pdf page 9
Yes, there will be cross-checking between models. Significant differences
will either be explained based on differences in model formulation and
resolution or inconsistencies in input parameters. In cases where the
difference may be due to use of different input parameter values, for
example Manning’s n-values, the values will be adjusted appropriately.
This discussion is in Section 6.6.4.1.2.2. There is also a hierarchy or
precedence as to which models results will take precedence for specific
types of information. This “Precedence Table” (Table 6.6-4) is included in
Section 6.6.4.2.
FGM-06 ADNR-
DMLW 11/14/2012 “Determination of the grid size spacing for the fluvial
geomorphology numerical models should be determined
based on the spatial resolution of available data and not on
the computational run times. A statement regarding the
approach used in the determination of grid size spacing
should be included with the reported results.” –pdf page 9
The mesh size of the 2-D model will be determined based on the physical
conditions and modeling needs within each area of the model domain, the
spatial scale of the geomorphic and habitat features that are being
modeled, and the resolution necessary to correctly represent their
hydraulic effects and behavior in the model. Computer run time, while a
potential issue in meeting schedules, will not be a factor in establishing
the grid size. This issue was discussed in the draft RSPs simply to make
readers aware that it is an issue that must be considered in planning the
work. Models that allow a variable mesh size, with high resolution in
areas of key interest and coarser resolution in other areas, can help
overcome part of the runtime problem without degrading the quality of the
information produced from the 2-D model. As a result, capability for using
variable mesh size is a factor in model selection. The discussion on grid
size in Section 6.6.4.1.2.3 has been edited to clarify the priorities in mesh
size considerations.
FGM-07 TNC 11/14/2012 “Operation Scenarios
The various models that are developed for the study plan
should look at three scenarios: existing (non-project),
proposed load-following operation, and base load operation.
Early introductions of this current project proposed base load
operations. With current power generation dependent upon
natural gas supplies, it is foreseeable that in the future this
project could be operated to supply base loads. In case of
that operational change in future, the base load case should
be included in the models. This would also provide the
AEA has included four operational scenarios in the RSP. The four
scenarios represent the existing condition, a maximum load-following, an
intermediate load-following, and a base-load scenario. The three with-
Project scenarios will provide bookends and an intermediate assessment
of potential Project effects. The text in Section 6.6.4.2.2.2 has been
edited to reflect this commitment.
Revised Study Plan
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FERC Project No. 14241 Page 77 December 2012
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
opportunity to gage the impacts of a wider range of operation
regimes.” –pdf page 3
FGM-08 NMFS 11/14/2012 “The with-project scenarios will be evaluated over a 50-year
continuously operating scenario. The scenarios should
represent a variety of operating scenarios to provide NMFS
with the full operating range from no project to the current
proposal. This information must be coordinated with the
other studies (see below). The geomorphology study should
provide a summary of channel change and links to habitat
with each of the operation scenarios.” –pdf page 45
See AEA’s response to comment FGM-07.
The Geomorphology Studies will provide a summary of channel change
identified for each scenario. Section 6.6.4.3 identifies habitat indicators
that the Geomorphology Studies will evaluate directly and information the
Geomorphology Study will pass to other Studies, such as the Fish and
Aquatics Instream Flow Study to evaluate other habitat indicators.
FGM-09 TNC 11/14/2012 “Focus Area Selection
The study plans are inconsistent on the use of the terms
“focus areas‟ and “study sites.‟ In these comments, we
assume that these are intended to be the same places so will
use the term ”focus area.‟ The method for selection of focus
areas is also inconsistent between and within study plans.
Table 8.5-13 of the Fish and Aquatics Instream Flow Study
(8.5) indicates that Focus Area selection is happening
currently (Q3-4 2012) even before studies are approved or
officially begin. If selection is to be based on the criteria
presented in 8.5.4.2, habitat mapping results from 2013
studies would seem to be required to select focus areas. –
pdf page 2
See AEA’s response to comment GEO-13.
FGM-10 TNC 11/14/2012 “Focus Area Selection
Focus areas should be selected based on biological
functions and habitat utilization by salmon as well as physical
processes related to instream flow, including habitat-flow
relationships, surface-groundwater interactions, geomorphic
processes, and ice processes. Biological functions for
salmon (i.e. spawning, rearing, migration, overwintering)
could potentially change with project operations, and
appropriate focus area selection can help to characterize and
quantify that anticipated change. –pdf page 2
See AEA’s response to comment GEO-14.
FGM-11 TNC 11/14/2012 “Focus Area Selection
Focus areas should be selected in the Middle and Lower
See AEA’s response to comment GEO-15.
Revised Study Plan
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FERC Project No. 14241 Page 78 December 2012
Fluvial Geomorphology Modeling below Watana Dam Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
Rivers. The river from the three river confluence and below is
especially dynamic. Focus areas in the Lower River are
required to understand changes to salmon habitat due to
project operations. As noted in our comments on Climate
Change impacts above, the cumulative impacts of this
project with other anticipated changes to the basin could
affect salmon and salmon habitat in the Lower River.” –pdf
page 2
FGM-12 TNC 11/14/2012 “Lower River Studies
Many of the study plans assume no effects from the project
and its operation below Talkeetna (Mile 97) and do not
include the Lower River in their scope. As noted in our
comments on Climate Change impacts above, the
cumulative impacts of this project with other anticipated
changes to the basin could affect salmon and salmon habitat
in the Lower River. Load-following operation, which will
essentially flip the hydrological pattern between winter and
summer, must be modeled for effects on the Lower River.
The hydrological model has been extended to Mile 84 in the
upper Lower River, and the study plan notes that the model
will be extended further into the Lower River if project effects
are seen at Mile 84. It is not clear what the trigger will be to
extend the model and how or when that will be decided. The
Revised Study Plans, including those for geomorphology,
instream flow, and ice processes, should include the Lower
River. If they do not but leave the possibility open depending
upon early results, the plans should be explicit about why
they assume no effect on the Lower River and what criteria
will be used to revisit the need to extend models when early
results are available.” –pdf page 3
See AEA’s response to comment GEO-02 and GEO-15.
FGM-13 EPA 11/14/2012 “The PSP/RSP should not assume that reaches with
nominally acceptable distributions of macrohabitat types will
also experience acceptable variation in water depths and
flow velocities, which are determined by river discharge.
Rather, the PSP/RSP needs to handle this as a hypothesis
for testing, which requires integrating the results of the flow
The approach does not make the assumption identified in the comment.
The overall framework for the geomorphology studies and the relationship
to the studies for the other resource areas is provided in Section 6.1.
Integration between the Geomorphology Study and the Fluvial
Geomorphology Modeling below Watana Dam Study is provided in
Section 6.5.11. A more detailed discussion of the overall integration of the
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 79 December 2012
Fluvial Geomorphology Modeling below Watana Dam Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
modeling with the results of the geomorphic studies.” –pdf
page 15
studies to develop the Integrated Resource Analysis is provided in
Instream Flow Study Section 8.5.4.1Instream Flow Study. The changes
in habitat indicators based on future geomorphic conditions and flow
conditions will be evaluated.
FGM-14 USFWS 11/14/2012 “AEA will provide an assessment of where the channel
geometry and substrate will likely be affected by project
construction and operations to the instream flow study to
assess where the instream flow analysis assumptions may
not be valid. We recommend that the geomorphology
modeling results for Project operational scenarios also be
presented in the instream flow study to allow for an
integrated analysis of the changes to riverine and floodplain
habitats influenced by Project operations. Other information
that should be provided to the instream flow analysis is a
change in large wood recruitment, change in substrate size
composition, discharges necessary to mobilize substrate, the
frequency of bed mobilization, bedload and total sediment
rating curves, geomorphic response reaches and correlated
habitat effects. Additional longitudinal information, such as
bed elevation adjustment should be described and provided
to the groundwater and instream flow studies to assess
effects of geomorphic response on habitat availability and
quality.” –pdf page 29
AEA agrees that the geomorphology studies will provide the information
identified in the Service’s comment or provide the information necessary
for studies such as the Fish and Aquatics Instream Flow Study and
Riparian Instream Flow Study to determine the influences for their
resource areas. The Geomorphology Studies will provide a summary of
channel change identified for each scenario. This summary will be
included in the Instream Flow Study Section 6.6.4.3 of the Fluvial
Geomorphology Modeling below Watana Dam Study identifies habitat
indicators that the Geomorphology Studies will evaluate directly and
information the Geomorphology Studies will provide other studies, such
as the Fish and Aquatics Instream Flow Study, Riparian Instream Flow
Study and Groundwater Study, to evaluate Project effects in their
resource areas. Tables 6.6-6 and 6.6-7 list the 1-D and 2-D model
parameters and other information that will be provided by the
Geomorphology and Fluvial Geomorphology Modeling studies.
FGM-15 EPA 11/14/2012 “The analysis of the potential hydrologic impacts of
alternative patterns of flow regulation must involve a
comparison of existing to alternative flows at a
geomorphically and geographically representative sample of
the modeled cross-sections. Assuming that the HEC-RAS
(flow routing) model
is well-calibrated and well-validated, such comparisons will
provide crucial information on how each flow-regulation
alternative will alter the natural flow regime at locations
representing the full spectrum of hydro-geomorphic
conditions along the river. The PSP/RSP may explicitly state
that this is how it will assess flow alteration, but we did not
find this information. It needs to be stated.” –pdf page 15
The development of the flow routing model is presented in the Instream
Flow Study (Section 8.5.4.3) including cross-section selection. An IHA
analysis is also being conducted in the Instream Flow Study (Section
8.5.4.4.1.1.3). In the case of Focus Areas where the 2-D bed evolution
model is applied, the routing model will provide the boundary conditions
for the 2-D model to determine the hydraulic conditions for both existing
and with-Project hydrologic conditions.
Details on the overall Focus Area selection process are provided in the
Fish and Aquatics Instream Flow Study (Section 8.5.4.2). Section
6.6.4.1.2.4 provides the details on the involvement of the Geomorphology
studies in the Focus Area site selection.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 80 December 2012
Fluvial Geomorphology Modeling below Watana Dam Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
FGM-16 NMFS 11/14/2012 “Additional information that should be provided with the
estimate of potential channel change including a translation
to habitat change, change in large wood recruitment, change
in floodplain sedimentation, and change in substrate size
composition. All of this information will help NMFS analyze
the proposed operations and to develop 10 (j)
recommendations for instream flow.” –pdf page 45
The Geomorphology Study will provide the requested information.
Section 6.6.4.3 of the Fluvial Geomorphology Modeling below Watana
Dam Study identifies habitat indicators that the Geomorphology Studies
will evaluate directly and information the Geomorphology Studies will
provide other studies, such as the Fish and Aquatics Instream Flow
Study, Riparian Instream Flow Study and Groundwater Study, to evaluate
Project effects in their resource areas. Tables 6.6-6 and 6.6-7 list the 1-D
and 2-D model parameters and other information that will be provided by
the Geomorphology and Fluvial Geomorphology Modeling studies.
FGM-17 NMFS 11/14/2012 “We request that the geomorphology modeling results for
project operation scenarios also be presented in the instream
flow study to allow for an integrated analysis of the changes
to riverine and floodplain habitats under project operations.
Presentation of the results in the instream flow study will help
NMFS compare all of the related operation effects to riverine
processes. Other information that should be provided to the
instream flow analysis is a change in large wood recruitment,
change in substrate size
composition, discharges necessary to mobilize substrate, the
frequency of bed mobilization, bedload and total sediment
rating curves, geomorphic response reaches, and correlated
habitat effects. Additional longitudinal information, such as
bed elevation adjustment, should be described and provided
to the groundwater and instream flow studies to assess
effects of geomorphic response on habitat availability and
quality…” –pdf page 45-46
Section 6.1 explains the relationship between the Geomorphology Study,
Fluvial Geomorphology Modeling below Watana Dam Study and the
various aquatic resource studies including the Instream Flow Study
(Section 8.5) and Riparian Instream Flow Study (Section 8.6) and
identifies the key indicators that the Geomorphology studies will provide to
the aquatic resource studies. Additionally, AEA has modified the wording
of the objectives of several study components to be more in line with the
NMFS and USFWS Study requests as well as to convey the actual
intended objectives better. AEA has also added the study
interdependency charts to Sections 6.5.6 and 6.6.6 along with tables
providing inputs form other studies and products provided by the
Geomorphology studies to other studies. AEA also added a study
component to the Geomorphology Study (Section 6.5.411) that describes
the integration of the Geomorphology Study with the Fluvial
Geomorphology Modeling below Watana Dam Study to provide the
support to interpret modeling results and develop the habitat indicators for
the aquatic resource studies. AEA has also modified Section 6.6.4.3 to
more clearly identify products that the Fluvial Geomorphology Modeling
below Watana Dam Study, in concert with the Geomorphology Study will
provide to the Instream Flow Study (Section 8.5), Riparian Instream Flow
Study (Section 8.6), Ice Processes in the Susitna River Study (Section
7.6), Water Quality (Section 5) and Groundwater Study (Section 7.5).
Tables 6.6-6 and 6.6-7 in the Fluvial Geomorphology Modeling below
Watana Dam Study RSP list 1-D and 2-D model results and other
Geomorphology Study results that will be supplied to these studies to
support the determination of Project effects.
FGM-18 EPA 11/14/2012 Comment 7 Part 1 – The RSP needs to make clear why the The RSP clarifies that the assessment of channel stability / dynamics is
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 81 December 2012
Fluvial Geomorphology Modeling below Watana Dam Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
assessment of channel stability is important to understanding
Project impacts on key resources attributes. The Susitna’s
channel morphology is naturally dynamic. Therefore, the
ecologically more relevant question may not be, is the
channel stable?, but, How much “instability” is natural in the
system? This can be quantified using digital maps of the river
valley, for individual reaches, by determining how much of
the area covered by water in the 1980s is now (2012) land
versus still covered by water (taking into account river stage;
and how much area covered by water today was land versus
covered by water in the 1980s. The resulting transition matrix
can be used to calculate a “turnover rate”, for each reach, for
the period between the 1980s and 2012. For those reaches
with aerial imagery available from the 1950s, similar data can
be compiled for the period between the 1950s and 1980s. –
pdf page 17
important to understanding Projects effects. The need for this
understanding is first brought up in the Introduction (Section 6.1) to the
Geomorphology Studies. It is further discussed in the objectives of the
Geomorphology Study (Section 6.5.1.1). It is again discussed in
subsection 6.5.4.14.1 of the study components: Assess Geomorphic
Change Middle and Lower Susitna River Segments. It is central to
establishing a baseline for comparison of with Project conditions and in
understanding the geomorphic processes governing the creation and
maintenance of the geomorphic features that provide the important
aquatic and riparian habitats. The introduction to the overall
Geomorphology Study effort, Section 6.1 was edited to include this
discussion upfront.
The turnover analysis and expansion of the analysis of channel change to
include aerial imagery from ~1950s, contingent on images of sufficient
quality being available, were added to the Geomorphology Study in
Section 6.5.4.4. The turnover analysis and inclusion of the 1950s aerials
will apply to both the Middle and Lower Susitna River Segments.
FGM-19 EPA 11/14/2012 Comment 7 Part 2 – The quantitative data on turnover rate
can be compared statistically to data on other potential
determinants of channel change, such as gradient, bed rock
confinement, and magnitude of sediment impacts from
tributaries. This will result in a more robust, quantitative
model of factors that affect turnover rate, for incorporation
into the understanding of geomorphic modeling results. –pdf
page 19
The turnover rate analysis (Section 6.5.4.4) will be viewed and interpreted
in respect to potential determinants of channel change such as gradient,
confinement and channel type. It is unlikely that there will be sufficient
information to perform a meaningful statistical analysis.
FGM-20 EPA 11/14/2012 Comment 7 Part 3 – An analysis of the hydrologic and
sediment, or of other disturbance regimes and biotic controls
(fire, temperature, predation, herbivory, species competition,
exotic species etc.), preceding the periods of observation for
the aerial imagery comparison can inform the question of
channel dynamics. Potential indirect influences on these
controls such as changes in land use, development, land
management, hunting, beaver trapping, etc. must also be
assessed. –pdf page 19
The Geomorphology Study will consider hydrology and sediment transport
(including glacial related events) in the analysis of channel change and
turnover rate. This and other details of the turnover analysis are
presented in Section 6.5.4.2.2.
Revised Study Plan
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FERC Project No. 14241 Page 82 December 2012
Fluvial Geomorphology Modeling below Watana Dam Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
FGM-21 EPA 11/14/2012 Comment 8– Given the very brief window of time proposed
for the new field studies of the Susitna – and the brief
window of time studied during the 1980s – it could be crucial
to extend the knowledge acquired on the Susitna itself with
knowledge acquired from other river systems affected by
dams in comparable hydrogeologic settings, including
studies of long-term dynamics (see also Wellmeyer et al.
2005). Such an approach would assess habitat conditions
downstream from dams on similar sized rivers in similar
biogeographic environments, and compare these habitat
conditions to those found either along unaffected reaches
elsewhere on those rivers or to similar reaches along the
Susitna. The data on different rivers could be compared
based on the assumption that regional river reaches will
demonstrate ecological similarities because they share
hydrologic and geomorphic contexts, climatic regimes, and,
prior to damming, at least some natural communities and
species assemblages (e.g., Graf 2005). The project
scientists should look for any such data that might be
available regionally. –pdf page 19
AEA has added Section 6.5.4.6.2.4 to the Geomorphology Study that
involves performing a literature search and review for downstream effects
of dams, focused on projects in similar cold region environments.
FGM-22 EPA 11/14/2012 Comment 9 Part 1
Given the contribution of LWD to channel geomorphic
dynamics, it should be incorporated into the Fluvial
Geomorphology Modeling below Watana Dam study (Section
6.6). This would support a quantitative assessment of the
potential geomorphic consequences of a loss of LWD due to
reservoir entrapment; or an increase in LWD recruitment due
to riparian erosion or mass wasting below the Dam. –pdf
page 20
An assessment of LWD is included in Section 6.5.4.9 of the study plan
and includes an evaluation of LWD recruitment, loading, function, and
potential project effects. The LWD study will evaluate the interaction of
LWD with hydrology, riparian, aquatic, ice processes, and river
geomorphology. Data will be collected from aerial photographs
throughout the entire study area and field studies in Focus Areas.
Geomorphic modeling of potential changes in LWD loading will take place
at selected Focus Areas utilizing the 2-D model. Additional text has been
added to Section 6.6.4.1.2.7 of the Fluvial Geomorphology Modeling
below Watana Dam Study to describe the integration of LWD into the
overall assessment of potential changes in geomorphic features.
Additional text has also been added to section 6.5.4.9.2 to identify support
from the Large Woody Debris study component for the modeling effort.
FGM-23 EPA 11/14/2012 Comment 9 Part 2 –
In addition to identifying LWD functional roles, the proposed
studies could estimate/quantify the volume of sediment (and
Mapping of LWD on aerial photographs upstream of Three Rivers will
include information on associated geomorphic features as possible from
the photographs. Detailed mapping of LWD and associated
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 83 December 2012
Fluvial Geomorphology Modeling below Watana Dam Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
approximate associated particle sizes) retained by LWD
within the active river area; and the surface area of the
geomorphic features (e.g., pools, point bars, etc.) formed by
the wood. The proposed map of LWD should have an
attribute table that includes the volume/area of habitat and
geomorphic features associated with individual LWD
occurrences. This would permit development of more
quantitative products from the LWD Study, such as estimates
of the anticipated reduction in areas of specific habitat types
and in the volume of sediment retained, as a result of
changes in the volume or number or LWD supplied
downstream of the dam. –pdf page 20
channel/substrate/habitat features in the Focus Areas was added to the
Study Plan to permit more quantitative analysis of LWD with hydraulics,
bedload transport, channel geomorphology, aquatic and riparian habitat in
these Focus Areas (Section 6.5.4.9).
FGM-24 EPA 11/14/2012 Comment 10
Neither the Geomorphology nor the Fluvial Geomorphology
Modeling below Watana Dam studies (Sections 6.5 and 6.6,
respectively) explicitly addresses the potential contribution of
ice to the geomorphic dynamics of the system. For example,
ice fragments can be potent scouring elements affecting not
just channel banks but the bed as well, when mobilized
during ice breakup. The fluctuations in dam releases
proposed for the project during the winter (load-following
operations) could result in repeated daily cycles of ice
formation and disruption, resulting in a high rate of
mobilization of ice fragments. It is plausible that this frequent
mobilization of ice fragments could cause unnatural scouring
of the active river area. Given the potential contribution of ice
scour to channel geomorphic dynamics, consideration should
be given to whether ice cover, fragmentation, and
mobilization could be incorporated into the Fluvial
Geomorphology Modeling below Watana Dam study (Section
6.6). Doing so would support a quantitative assessment of
the potential geomorphic consequences of ice formation and
disruption due to reservoir operations. –pdf page 20
The Ice Processes in the Susitna River Study (Section 7.6) in the Susitna
River will provide the Geomorphology study with the information on the
potential Project effects on ice break-up and the formation of fragments.
The River 1-D model will predict whether the ice cover will be broken up
by the load-following fluctuations. The model will address hourly and daily
cycles of flow fluctuation. Quantitative tools to estimate bed scour from ice
fragments are not currently available. If this remains the case, we
propose that if Project scenarios result in increased frequency of break-
up, that the potential for bed scour be identified as a relative ranking
among scenarios based on the frequency of break-up.
FGM-25 EPA 11/14/2012 Comment 11
The modeling effort described is deterministic; however, river
system dynamics are naturally somewhat stochastic. If a
To assist in identifying and understanding uncertainties, sensitivity
analysis will be performed for the 1-D and 2-D modeling efforts by varying
key input parameters within the range of physically reasonable values
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
stochastic approach to the modeling is not performed, the
modeling could incorporate one or more sensitivity analyses,
exploring the consequences of varying particular input
parameters or boundary conditions, for which natural
variation (or uncertainty) would be expected. For example,
bedload and suspended sediment load are highly variable
parameters (DeVries 1970). The 1-D and 2-D computer
modeling efforts therefore need to conduct sensitivity
analyses, to assess how variability in inputs for such
parameters affects the model results. Any discussion of
model uncertainty also needs to be tied back to the question
of how the representation of geomorphic uncertainty affects
predictions for key indicators (Wilcock et al. 2003). For
example, given the uncertainties in our understanding of ice
formation and its role in scour and bed and bank particle
mobilization and in the entrainment of LWD, the study
designers should explain how this uncertainty could affect
model results. We therefore would ask, Are sensitivity
analyses or the incorporation of variability into model inputs
feasible for the proposed Study? (The description of software
options indicates that simulation run times are a matter of
concern.) –pdf page 21
(Section 6.6.4.2.2.3). Additionally, a range of hydrologic conditions will be
evaluated in the 50 year simulation period to be used for the 1-D model
bed evolution model encompasses a broad range of hydrologic conditions
and will be used to assess the sensitivity of the study areas to hydrologic
variability. The influence of extreme events will be addressed by
modeling the 100-year flood with both 1-D and 2-D models. Variation in
response to the six representative years (wet, average and dry for wet
and cold PDO) based on both the 1-D and 2-D model results will also
provide an understanding of the uncertainty associated with hydrologic
conditions.
FGM-26 EPA 11/14/2012 Comment 12
We recommend that the output of the initial 50-year modeling
to RM 75 should be formally, quantitatively evaluated to ask
the specific question: Are potentially ecologically significant
effects of dam operations detectable in the 1-D or 2-D or
hydrologic modeling results at RM 75? Answering this
question requires not just the modeling output, and the
consideration of the length of time over which impacts may
occur, but the conceptual ecological (and physical) models
described above. These conceptual models would
summarize present understanding of what constitutes the
acceptable range of variation in indicator condition, for those
indicators measurable with the modeling output. –pdf page
22
The process, criteria and schedule for determining the need to extend the
downstream limits into or further into the Lower River are presented in the
Instream Flow Study (Section 8.5.3) and the Geomorphology Study
(Section 6.5.3). The assessment and the following six criteria will be used
to evaluate the need to extend studies into the Lower River Segment and
if studies are needed, will identify which geomorphic reaches require
instream flow analysis in 2013. The criteria include: 1) Magnitude of daily
stage change due to load-following operations relative to the range of
variability for a given location and time under existing conditions (i.e.,
unregulated flows); 2) Magnitude of monthly and seasonal stage change
under Project operations relative to the range of variability under
unregulated flow conditions; 3) Changes in surface area (as estimated
from relationships derived from LiDAR and comparative evaluations of
habitat unit area depicted in aerial digital imagery under different flow
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conditions) due to Project operations; 4) Anticipated changes in flow and
stage to Lower River off-channel habitats; 5) Anticipated Project effects
resulting from changes in flow, stage and surface area on habitat use and
function, and fish distribution (based on historical and current information
concerning fish distribution and use) by geomorphic reaches in the Lower
River Segment; and 6) Initial assessment of potential changes in channel
morphology of the Lower River (Section 6.5.4.6) based on Project related
changes to hydrology and sediment supply in the Lower River. Results of
the 2013 studies would then be used to determine the extent to which
Lower River Segment studies should be adjusted in 2014.
FGM-27 EPA 11/14/2012 “The selection of additional cross-sections for the HEC-RAS
modeling needs to produce a geomorphically representative
sample of locations.” –pdf page 15
The development of the flow routing model is presented in the Instream
Flow Study (Section 8.5.4.3) including cross-section selection. In the case
of Focus Areas where the 2-D bed evolution model is applied, the routing
model will provide the boundary conditions for the 2-D model to determine
the hydraulic conditions for both existing and with-Project hydrologic
conditions. Additional cross-sections are to be surveyed in 2013 to
provide the appropriate resolution for the 1-D sediment transport model.
Section 6.6.4.1.2.9 identifies which indicates on the order of 80 to 100
additional cross-sections will be surveyed in 2013. These cross-sections
will also be used in the routing model.
FGM-28 USFWS 11/14/2012 “The revisions for the geomorphology and fluvial
geomorphology modeling study plans should provide a
description of the expected end-product, and whether these
results will be sufficient to address Project effects to
anadromous fish habitat. The study plan should also include
a description of uncertainties associated with the studies,
models, and analysis of project effects and how these
uncertainties are determined.” –pdf page 24
Identification of the information to be supplied from the Geomorphology
Study to support the Fluvial Geomorphology Modeling below Watana
Dam Study is identified in Section 6.5.4.11. The study interdependencies
charts and associated discussions in Section 6.5.6 and 6.6.6 also identify
products and associated schedule for delivery to various studies that will
require the results of the Geomorphology Study to evaluate Project effects
on aquatic resources. Section 6.6.4.3 identifies the end-products that will
be delivered through the combination of the Fluvial Geomorphology
Modeling and Geomorphology studies to facilitate evaluation of Project
effects on anadromous fish and other aquatic resources can be evaluated
by the Fish and Aquatics Instream Flow Study (Section 8.5). Tables 6.6-6
and 6.6-7 list the 1-D and 2-D model parameters and other information
that will be provided by the Geomorphology and Fluvial Geomorphology
Modeling studies.
To assist in identifying and understanding uncertainties, sensitivity
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analysis will be performed for the 1-D and 2-D modeling efforts by varying
key input parameters within the range of physically reasonable values
(Section 6.6.4.2.2.3). Additionally, a range of hydrologic conditions will be
evaluated in the 50 year simulation period to be used for the 1-D model
bed evolution model encompasses a broad range of hydrologic conditions
and will be used to assess the sensitivity of the study areas to hydrologic
variability. The influence of extreme events will be addressed by
modeling the 100-year flood with both 1-D and 2-D models. Variation in
response to the six representative years (wet, average and dry for wet
and cold PDO) based on both the 1-D and 2-D model results will also
provide an understanding of the uncertainty associated with hydrologic
conditions.
FGM-29 USFWS 11/14/2012 “If the system is found to be in dynamic equilibrium, the
Service recommends that the geomorphology and fluvial
geomorphology studies provide the magnitude and trend of
geomorphic change in response to the Project, and that
these changes be translated to spatial and temporal riverine
and floodplain habitat changes. If the system is in
disequilibrium the geomorphology studies should provide an
understanding of the disequilibrium without the Project and
then present the Project effects to the system and
summarize the effects in a spatial and temporal riverine and
floodplain habitat change analysis.” –pdf page 28
AEA agrees with the comment and the point it makes is consistent with
our approach. This is why the without-Project condition, including the
operations scenarios, is assessed for 50 years into the future. This, along
with the analysis of historical information such as comparison of the
1980s cross-sections with current cross-sections and comparison of aerial
photographs from the 1950s and 1980s with current photos, will help
identify current trends. The existing condition, projected 50 years into the
future, provides a basis for comparison with alternative scenarios
representing potential Project conditions over the same period to identify
change (Project effects) both spatially and temporally.
The wording has been revised in the introductory description of the study
to acknowledge the possibility that the system is not in a state of dynamic
equilibrium (Section 6.1).
FGM-30 NMFS 11/14/2012 “NMFS agrees that those four questions should be
answered. NMFS requests that, if the system is found to be
in dynamic equilibrium, the geomorphology and fluvial
geomorphology studies provide the magnitude and trend of
geomorphic change in response to the project and that these
changes are translated to spatial and temporal riverine and
floodplain habitat changes. If the system is in disequilibrium,
the geomorphology studies should provide an understanding
of the disequilibrium without the project and then present the
project's effects to the system and summarize the effects in a
See AEA’s response to comment FGM-30.
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
spatial and temporal riverine and floodplain habitat change
analysis.” –pdf page 44
FGM-31 USFWS 11/14/2012 “The Service recommends that the model selection should
be made soon to ensure adequate collection of data to
populate the models as data collection can be difficult, and
may require several seasons. The bed evolution modeling
approach will consist of a 1-D movable boundary sediment
transport model to address reach-scale issues and 2-D
models to address local scale issues.” –pdf page 28
As indicated in the schedule for Model Selection (Section 6.6.6), a model
will be selected in early Q2 2013 (April). This will provide ample time for
development of the 2013 field data collection. In general, the data needs
for the candidate 1-D models are basically the same. This is also true for
the 2-D models.
FGM-32 NMFS 11/14/2012 “As data collection can be difficult and may require several
seasons, we suggest that the model selection should be
made soon to ensure collection of data populate the
models.–pdf page 44
See AEA’s response to comment FGM-31.
FGM-33 NMFS 11/14/2012 “The bed evolution modeling approach will consist of a 1-D
movable boundary sediment transport model to address
reach-scale issues and 2-D models to address local scale
issues. Both of these should be tied back to effects on
habitat by associated changes to geomorphic form and
process. –pdf page 44
AEA agrees with the comment. The effort described in 6.5.4.1.2.3
Geomorphic Characterization of the Susitna River provides the initial
understanding of the processes that create and maintain the geomorphic
features that represent important aquatic habitat. The effort in section
6.5.4.11 provides for integration with knowledge gained from the
geomorphology study to interpret results of the Fluvial Geomorphology
Modeling. This, combined with the results of the Fluvial Geomorphology
Modeling below Watana Dam Study developed in Section 6.6.4.3, will
provide the linkage to changes in geomorphic form and process.
Additional interpretation of changes in habitat will be developed by the
Instream Flow Study (Section 8) from information developed by the
Geomorphology studies. Tables 6.6-6 and 6.6-7 list the 1-D and 2-D
model parameters and other information that will be provided by the
Geomorphology and Fluvial Geomorphology Modeling studies.
FGM-34 NMFS 11/14/2012 The 1-D model will extend from the proposed dam
downstream extent of the hydraulic flow routing (RM75,
downstream of the USGS Susitna River gage near
Sunshine) unless project effects are found to occur at the
downstream boundary of the model. A clear method for
determine model extension is needed in the study plan to
avoid misunderstanding and responsibilities of this study.” –
pdf page 44
See AEA’s response to comment GEO-02.
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FERC Project No. 14241 Page 88 December 2012
Fluvial Geomorphology Modeling below Watana Dam Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
FGM-35 USFWS 11/14/2012 “One of the models proposed for 1-D model selection is
HEC-6T, which allows for user defined transport equations,
we reiterate that this will require good sediment transport
data and will require data collected on the Chulitna and
Talkeetna Rivers, and may additionally need other tributary
inputs in the middle reach.” –pdf page 29
See AEA’s response to comment GEO-03.
FGM-36 NMFS 11/14/2012 “One of the models proposed for ID model selection is HEC-
6T, which allows for user defined transport equations; we
reiterate that this will require good sediment transport data
and will require data collected on the Chulitna and Talkeetna
Rivers, and may additionally need other tributary inputs in
the middle reach.” –pdf page 45
See AEA’s response to comment GEO-03.
FGM-37 USFWS 11/14/2012 “The 2-D model, used to evaluate the detailed hydraulic and
sediment transport characteristics on smaller, more local
scales, will likely overlap with some of the instream flow
study sites. Site selection for the 2-D models must consider
habitat utilization by anadromous fish, importance of the
habitat, and dynamic flow patterns and geomorphic
processes. Sites should be selected that serve biologic
functions (spawning, rearing, migration, overwintering) and
with potential for change related to Project operations.” –pdf
page 29
All the Focus Areas with 2-D modeling are expected to be Focus Areas
for the Fish and Aquatics Instream Flow Study. The Fish and Aquatics
Instream Flow Study is considering the habitat and biologic functions
identified in the comment in selection of the sites. In turn the Fluvial
Geomorphology Modeling below Watana Dam Study is reviewing the sites
to ensure that the sites include the range of geomorphic features and flow
conditions that help define the habitat that may potentially be changed by
Project operations.
The overall selection process, schedule and criteria for the Focus Areas
are provided in the Fish and Aquatics Instream Flow Study (Section
8.5.4.2). Section 6.6.4.1.2.4 of the Fluvial Geomorphology Modeling
below Watana Dam Study provides the details on the involvement of the
Geomorphology Studies in the Focus Area site selection. This include the
exactly location (RM), number of sites (10) and geomorphic (one site in
each geomorphic reach and representative of the range of geomorphic
features found in the reach) and modeling criteria (extent of site for proper
boundary conditions use modeling approach).
FGM-38 NMFS 11/14/2012 “The 2-D model, used to evaluate the detailed hydraulic and
sediment transport characteristics on smaller, more local
scales, will likely overlap with some of the instream flow
study sites. Site selection for the 2-D models must consider
habitat utilization by anadromous fish, importance of the
See AEA’s response to comment FGM-37.
Revised Study Plan
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FERC Project No. 14241 Page 89 December 2012
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
habitat, and dynamic flow patterns and geomorphic
processes. Sites should be selected that serve biologic
functions (spawning, rearing, migration, overwintering) and
will potentially change with project operations.” –pdf page 45
Revised Study Plan
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FERC Project No. 14241 Page 90 December 2012
Groundwater Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
GW-01 CWA 11/14/2012 Scope is insufficient in studying the Lower River
based on AEA’s apparent assumption that Project
effects will not significantly affect the Lower River
groundwater processes. –page 7-8
AEA is not assuming insignificant Project-related effects on the Lower River groundwater
processes. Although both Middle and Lower River segments are under consideration as
part of the Instream Flow Study (Section 8.5), the majority of detailed study elements
described in the RSP are concentrated within the Middle River Segment. This is because
Project operations related to load-following and variable flow regulation will likely have the
greatest potential effects on this segment of the river. These effects tend to attenuate in a
downstream direction as channel morphologies change, and flows change due to tributary
inflow and flow accretion.
The downstream boundary of the Study Area is currently RM 75 because existing
information indicates that the hydraulic effects of the Project below the Three Rivers
Confluence are attenuated. See Section 8.5.3. However, AEA will reevaluate how far
downstream Project operational significant effects extend based in part upon the results of
the Open-water Flow Routing Model (see Section 8.5.4.3). The results of the Open-water
Flow Routing Model, to be completed in Q1 2013, will be used to determine whether, and
the extent to which, Project operations related to load-following, as well as seasonal flow
changes, occur within the Lower River Segment. Thus, an assessment of the downstream
extent of Project effects will be developed in Q1 2013 with review and input of the TWG.
This assessment will include a review of information developed during the 1980s studies
and study efforts initiated in 2012, such as sediment transport (see Section 6.5), habitat
mapping (see Sections 6.5 and 9.9), operations modeling (see Section 8.5.4.3.2), and the
Mainstem Open-water Flow Routing Model (see Section 8.5.4.3). The assessment will
guide the need to extend studies into the Lower River Segment and if needed, will identify
which geomorphic reaches will be subject to detailed instream flow analysis in 2013.
Results of the 2013 studies would then be used to determine the extent to which Lower
River Segment studies should be adjusted in 2014. In addition, the results of the 1-D
sediment transport modeling (see Section 6.6) from RM 184 to RM 75 will be available in
Q1 2014 and will further inform the need for these adjustments. Pilot HSC/HSI studies
were initiated in 2012, and will be continued in 2013, and include data collection within
Lower River Segment habitats (see Section 8.5.4.5). See also Section 8.5.3 for more
discussion regarding the Lower River Segment.
The Groundwater Study also includes an analysis of shallow residential wells (see Section
7.5.4.9), many of which may be in the more populated upper portion of the Lower River.
Following an inventory of existing shallow wells, those wells that have the highest
likelihood of being affected by changes in the mainstem Susitna River flow regime will be
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
monitored and potential Project effects evaluated to assess groundwater vulnerability.
GW-02 CCC 11/15/2012 a) There does not appear to be a clear link
between the groundwater and surface water
studies and the engineering studies.
b) How will the ground to surface water
interaction at the dam site impact the
stability of the dam?
c) How will changing groundwater conditions
impact the health of the forests
downstream?
d) How will the riparian zone above the dam
be impacted as water pressure increases
with the reservoir?
Regarding comments a and b, as described in Section 7.5.4.3, the Groundwater Study will
be responsible for analyzing potential changes in groundwater flow at the proposed dam
site associated with Project operations. Input to the Groundwater Study will be provided by
Engineering Feasibility studies and the Geology and Soil Characterization Study (Section
4.5). One of the objectives of the engineering design studies will be to seal potential
groundwater flow paths to reduce potential impacts to the dam structure and operations.
Regarding comment c, potential effects of Project operations on riparian forests
downstream of the dam site will be analyzed by the Riparian IFS (Section 8.6). As
described in Section 7.5.4.5, the Groundwater Study will provide data related to
groundwater/surface water interactions and coordinate the analysis of groundwater
processes with the Riparian IFS.
The Riparian IFS (Section 8.6) will also be responsible for analyzing Project effects on the
riparian zone above the dam, with the Groundwater Study providing input on groundwater-
surface water interactions,
GW-03 FERC 11/14/2012 “Clearly describe the exact number, location, and
spatial extent of your proposed Focus Areas for
each proposed study. Provide justification for the
number of proposed sites selected for detailed 2-
D hydraulic modeling and other intensive study
elements. Include criteria to be used for selecting
Focus Areas and study-specific rationale for co-
locating sites.” –pdf page 5
The location, number, and spatial extent of the proposed Focus Areas are discussed in
Sections 7.5.4.5 and 7.5.4.6. For purposes of the RSP, a total of ten FAs in the Middle
River Segment were identified. These ten areas were selected for planning purposes and
will be evaluated for their depiction of non-modeled areas based on mapping results to be
completed in Q1 2013 (see Section 9.9). The results of this evaluation will be discussed
with the TWG and refinements in Focus Area selection made prior to commencement of
the 2013 studies. In addition, the Groundwater Study includes specific objectives at the
proposed dam site (Section 7.5.4.3), which are in addition to the proposed Focus Areas.
GW-04 ADNR-
DMLW
11/14/2012 “While deeper wells are not common in the area
and no deep observation wells are planned for
studying this specific aspect of the groundwater
system, other deep borings to identify fault zones
and other structural features may provide insight
into the deeper groundwater zones.” –page 10
Coordination with Engineering Feasibility studies and the Geology and Soil
Characterization Study (Section 4.5) will include the evaluation of observation wells in
select geotechnical borings (see Sections 7.5.4.3 and 7.5.4.9). A review of available
groundwater well data bases (e.g. USGS) will be used to identify existing deep wells that
can provide information on groundwater conditions in deeper portions of the watershed
aquifers. The drilling of deep wells is not planned as part of the Groundwater studies and
is not necessary to evaluate Project effects on groundwater levels.
GW-05 ADNR-
DMLW 11/14/2012 “The current monitoring phase would last for a
maximum of two years. The groundwater study
should be extended to better understand the
Interactions between groundwater, wetlands (surface-water) and wetland vegetation are
covered in the Riparian Vegetation Dependency on Groundwater/Surface-Water
Interactions (Section 8.5.4.5). Results of the 1980s studies and other available
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interactions between groundwater and wetlands
under differing hydrologic conditions, which may
evolve over time periods much longer than two
years, and certainly will over the life of the
proposed dam.” –page 10
groundwater data will be used to extend the record of observations to supplement
information to be collected in 2013-2014. The groundwater models, using input from the
surface-water flow routing models, will use the data sets to build simulation modeling tools.
Those tools will be used to define groundwater conditions under the range of hydrologic
years analyzed using the operations model (Section 8.5.4.3.2) and meet the goals and
objectives of the study.
GW-06 ADNR-
DMLW 11/14/2012 “The following comments are submitted regarding
Prior Appropriator Water Rights:
1. The Water Resources Management Unit is
concerned with ground water connectivity to the
Susitna River. Most water rights downstream of
the dam site are groundwater wells which may be
affected by changes in the flow regime of the
Susitna River caused by this project.
2. There are several ground water wells along the
Susitna River. Many of these wells are located
within communities that are along the Susitna
River. Many of these wells have water rights
associated with them. The project’s affects on
lower river flows during the summer months
needs to be evaluated in order to determine how
this project may affect the prior appropriators’
water rights.
3. Studies to determine the effect of ground
water/ surface water connectivity should be
preformed.” –page 10
Potential Project effects on groundwater wells will be addressed as described in Section
7.5.4.9. The ADNR and USGS databases will be used to identify wells in the study area,
and a subset of the wells will be monitored to help study and characterize the groundwater
and surface-water interactions and processes taking place in the shallow water table
aquifers along the river corridor.
GW-07 ADNR-
ADF&G 11/14/2012 “Information is needed on preliminary results from
the thermal imaging assessment that was
scheduled to be conducted in the fall 2012. An
assessment on the feasibility of this investigation
is needed and if it is determined feasible, how
additional thermal imaging data will be collected
and calibrated. These comments are repeated in
section 5.7. Groundwater-Related Habitat Study
since the thermal imaging assessment was also
described there and it is unknown who is the
The relationship between the Groundwater Study and the thermal imaging study is
described in Section 7.5.7. The thermal imaging assessment performed in 2012 is
described in Baseline Water Quality Study Section 5.5.4.9. The thermal imagery data was
gathered in fall 2012 and is being calibrated with concurrent continuous temperature data
from the Middle River sites RM 98 through RM 165. Calibration of thermal imagery and
products to be completed in winter 2012 is also discussed Section 5.5.4.9. Additional
thermal imaging of the Upper River and Lower River may be completed once the thermal
imaging assessment of the Middle River is complete.
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project lead.” –page 19
GW-08 ADNR-
ADF&G 11/14/2012 “Dissolved oxygen should also be measured as a
parameter for HSC and HSI development.” –page
20
Dissolved oxygen measurements in groundwater and surface water will be measured in
association with HSC/HSI sampling efforts using hand-held probes and continuous
monitoring loggers (see Section 7.5.4.6 and Section 8.5.4.5.1).
GW-09 ADNR-
ADF&G 11/14/2012 “More information is needed on the monitoring
strategy in Focus Areas. For example, how will
the study assess groundwater influences over
different habitat types in a focus area? An
example figure/diagram showing proposed
groundwater monitoring well locations in a focus
area would help to better understand proposed
sampling design.” –page 20
This comment is addressed in Riparian Vegetation Dependency on Groundwater/Surface-
Water Interactions (Section 7.5.4.5) and a figure has been added to help show how wells
may be located in a typical study area (Figure 7.5-8).
GW-10 TNC 11/14/2012 “Focus Area Selection
The study plans are inconsistent on the use of the
terms “Focus Areas” and “study sites”. In these
comments, we assume that these are intended to
be the same places so will use the term “focus
area”. The method for selection of Focus Areas is
also inconsistent between and within study plans.
Table 8.5-13 of the Fish and Aquatics Instream
Flow Study (8.5) indicates that Focus Area
selection is happening currently (Q3-4 2012) even
before studies are approved or officially begin. If
selection is to be based on the criteria presented
in 8.5.4.2, habitat mapping results from 2013
studies would seem to be required to select
Focus Areas.
Focus areas should be selected based on
biological functions and habitat utilization by
salmon as well as physical processes related to
instream flow, including habitat-flow relationships,
surface-groundwater interactions, geomorphic
processes, and ice processes. Biological
functions for salmon (i.e. spawning, rearing,
The Groundwater Study (Section 7.5) is a key supporting study needed to improve the
understanding of groundwater and surface-water interactions as they relate to riverine
processes and the response of aquatic and riparian habitats to changes in flow and stage.
The Groundwater Study will also evaluate the effects of changes in mainstem flow and
stage on water rights and use of groundwater by the public. The Focus Areas are locations
where the cumulative understanding is increased by the concentration of multidisciplinary
studies in a series of unique locations that represent the variability in hydrologic,
geomorphologic, aquatic and riparian habitat and other factors. The concentration and
coordination of studies in these areas will lead to a better understanding of riverine
processes at the reach-scale and Focus Area-scale and the use of predictive simulation
tools to evaluate potential Project effects.
See AEA’s response to comment IFS-14. As described in Section 8.5.4.2.1.1, ten
proposed Focus Areas were identified in the Middle River Segment , and are illustrated in
Figures 8.5-13 to 8.5-22. These ten areas were selected for planning purposes and will be
evaluated further for their representativeness of non-modeled areas based on results of
habitat mapping that will be completed in Q1 2013 as part of Section 9.9. The results of
this mapping effort will be discussed with the TWG and refinements in Focus Area
selection made prior to commencement of the 2013 studies. Criteria used in selecting the
proposed Focus Areas include:
1) All major habitat types (main channel, side channel, side slough, upland slough,
tributary delta) will be sampled within each geomorphic reach.
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migration, overwintering) could potentially change
with project operations, and appropriate focus
area selection can help to characterize and
quantify that anticipated change.
Focus areas should be selected in the Middle and
Lower Rivers. The river from the three river
confluence and below is especially dynamic.
Focus areas in the Lower River are required to
understand changes to salmon habitat due to
project operations. As noted in our comments on
Climate Change impacts above, the cumulative
impacts of this project with other anticipated
changes to the basin could affect salmon and
salmon habitat in the Lower River.” –pdf page 2-3
2) At least one (and up to three) Focus Area(s) per geomorphic reach (except geomorphic
reaches associated with Devils Canyon – MR-3 and MR-4) will be studied that is/are
representative of other areas.
3) A replicate sampling strategy will be used for measuring habitat types within each Focus
Area, which may include a random selection process of mesohabitat types.
4) Areas that are known (based on existing and contemporary data) to be biologically
important for salmon spawning/rearing in mainstem and lateral habitats will be sampled
(i.e., critical areas).
5) Areas for which little or no fish use has been documented or for which information on
fish use is lacking will also be sampled to help identify factors affecting the distribution,
timing and abundance of fish.
GW-11 TNC 11/14/2012 “Lower River Studies
Many of the study plans assume no effects from
the project and its operation below Talkeetna
(Mile 97) and do not include the Lower River in
their scope. As noted in our comments on Climate
Change impacts above, the cumulative impacts of
this project with other anticipated changes to the
basin could affect salmon and salmon habitat in
the Lower River. Load-following operation, which
will essentially flip the hydrological pattern
between winter and summer, must be modeled
for effects on the Lower River. The hydrological
model has been extended to Mile 84 in the upper
Lower River, and the study plan notes that the
model will be extended further into the Lower
River if project effects are seen at Mile 84. It is
not clear what the trigger will be to extend the
model and how or when that will be decided. The
Revised Study Plans, including those for
geomorphology, instream flow, and ice
processes, should include the Lower River. If they
See AEA’s response to comment GW-01.
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do not but leave the possibility open depending
upon early results, the plans should be explicit
about why they assume no effect on the Lower
River and what criteria will be used to revisit the
need to extend models when early results are
available.” –pdf page 3
GW-12 TNC 11/14/2012 “Operation Scenarios
The various models that are developed for the
study plan should look at three scenarios: existing
(non-project), proposed load-following operation,
and base load operation. Early introductions of
this current project proposed base load
operations. With current power generation
dependent upon natural gas supplies, it is
foreseeable that in the future this project could be
operated to supply base loads. In case of that
operational change in future, the base load case
should be included in the models. This would also
provide the opportunity to gage the impacts of a
wider range of operation regimes.” –pdf page 3
The Groundwater Study will use the various simulations provided by the Operations Model
(Section 8.5.4.3.2), as routed downstream by the hydraulic routing models (Section
8.5.4.3.1 and Section 7.6), to provide hydrologic input conditions for groundwater model
simulations. Modeled scenarios will include existing conditions, maximum load-following,
intermediate load-following and a base-load scenario. The three with-Project scenarios will
provide bookends and an intermediate assessment of potential Project effects.
GW-13 USFWS 11/14/2012 “Although Alaska Energy
Authority’s (AEA) Proposed Study Plan (PSP)
includes objectives for describing floodplain and
riparian groundwater and surface-water (GW/SW)
relationships, the PSP title implies only aquatic
relationships will be investigated. We recommend
revising the title to more accurately describe the
scope of the study, and including “floodplain” as
appropriate wherever the study subject is
mentioned in the PSP.” –pdf page 15
Although AEA has not changed the title of the Groundwater Study, the scope of the study
includes the floodplain (Section 7.5.1).
GW-14 USFWS 11/14/2012 “Since the Groundwater PSP will be providing
data for other studies, the Groundwater PSP
should describe the methods as well as the
results provided to other studies (e.g., 6.5 Fish
and Aquatics Instream Flow, and 6.6 Riparian
Please see Sections 7.5.4.5 Riparian Vegetation Dependency on Groundwater / Surface
Water Interactions and 7.5.4.6 Aquatic Habitat Groundwater / Surface- Water Interactions.
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Instream Flow studies).” –pdf page 15
GW-15 USFWS 11/14/2012 “Given the complex integration of the various
studies, we appreciate this figure and recommend
including figures like these along with a narrative
in the introduction for each study. Additionally, the
main introduction covering all the PSPs should
include a more general interdependency figure
showing how all the various studies interrelate.
We have not had time to evaluate this draft
interdependency figure, but look forward to
reviewing additional drafts as the study plans
mature.” –pdf page 15
The study has been revised to include an interdependency figure with timeline information
(Figure 7.5-3) for each of the Section 7.5.4 study elements. The interdependency figure
and associated timelines are discussed in Sections 7.5.4.1 to 7.5.4.9.
GW-16 USFWS 11/14/2012 “Besides interdependency figures, please provide
timelines showing how the various study
components (both among major studies and
within studies) feed into other studies and study
components. The Service is concerned the
sequencing of some study components may be
out of sync with the required products from other
studies and study components.” –pdf page 15
The study has been revised to include an interdependency figure with timeline information
in each of the Section 7.5.4 study elements. The interdependency figure and associated
timelines are discussed in Sections 7.5.4.1 to 7.5.4.9. The riparian groundwater study
objective (Section 7.5.4.5) and the aquatic habitat study objective (Section 7.5.4.6) are
examples of studies that work collaboratively in terms of data collection, use and reporting.
GW-17 USFWS 11/14/2012 “The last sentence in the first paragraph of
Section 5.7.1.1 suggests the Groundwater PSP is
not much more than a passive summary of other
studies, when in fact the Groundwater PSP is a
critical input for other studies not unlike the USGS
data used by other studies. The Service is
concerned that relying upon a variety of
investigators with their own study objective
priorities risks degrading the quality and
consistency of the groundwater hydrology data.
The groundwater hydrology investigators should
be responsible for all phases of the groundwater
study, including well installation, monitoring, data
reduction, and analyses.” –pdf page 15
AEA has deleted the referenced sentence. Consistent with the comment, AEA has
provided additional detail clarifying the timing and relationship of the Groundwater Study to
other studies. The relationship between studies is described in the study methods sections
(7.5.4.1 through 7.5.4.9), and interdependencies are described in Section 7.5.7-
Relationship with Other Studies and Figure 7.5-3. In the riparian (7.5.4.5) and aquatic
(7.5.4.6) study elements, the installation of wells, groundwater modeling, data reduction
and analysis are the responsibility of the Groundwater Study. Groundwater Study
objectives pertaining to the Watana Dam site will use data collected by the Geology and
Soils Characterization Study (Section 4.5) and Engineering Feasibility studies.
GW-18 USFWS 11/14/2012 “The methods should be described in sufficient Additional details are provided in Sections 7.5.4.1 through 7.5.4.9. Where specific ASTM
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detail so others can duplicate the study. Citing
methods from other studies or accepted industry
standards is encouraged, but not in lieu of
providing sufficient detail so the methods can be
evaluated without having to refer to the citation.” –
pdf page 15-16
or other standards are referenced, additional details have been added to help evaluate the
application of the standard. The proposed groundwater studies could be duplicated by
other parties using the study implementation descriptions provided in the Groundwater
Study and cited references regarding standard methods and practices.
GW-19 USFWS 11/14/2012 “Unlike the fisheries component of the Aquatic
Instream Flow Study where potential future
Susitna-Watana Hydroelectric Project (Project)
impacts may be compared with other locations in
the state because fish populations are routinely
surveyed, evaluating potential Project impacts on
riparian/floodplain resources without an
“untreated” spatial reference (i.e., similar rivers
without a dam) risks a significant change may be
attributed to an unrelated impact. Green (1979)
outlines four prerequisites for an optimal impact
study design: 1) the impact must not have
occurred; 2) the type, time and place of impact
must be known; 3) all relevant biological and
environmental variables must be measured; and
4) an area unaffected by the impact must be
sampled to serve as a control. The first three
prerequisites are included in the PSPs if they are
designed and implemented so potential Project
impacts can be evaluated by post-dam
resampling. We recommend the Groundwater-
related Habitat Study also include the fourth
component (un-impacted rivers), otherwise AEA
risks what Green (1979, p 71) refers to as “…
executing statistical dances of amazing
complexity around their untestable results” to
show the Project did or did not have a potential
impact on riparian/floodplain resources.” –pdf
page 16
The current Riparian Instream Flow Study is not designed as an “impact study” as
specified by Green (1979). The goal of this study is to provide a physical and vegetation
process modeling approach to predicting potential impacts to downstream riparian
floodplain vegetation from Project operational flow modification of natural Susitna River
flow, sediment, and ice processes regimes (see Section 8.6.1.1). The environmental
analysis within AEA’s FERC License Application will inform the need for ongoing
monitoring.
GW-20 USFWS 11/14/2012 “AEA’s overall study goal is similar to the Service The overall goal of the study plan has been revised to be consistent with the language
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study-request goal; however, the following key
phrases (underlined) are not included: “The
overall goal of the study is to understand Project
effects on surface-water / groundwater
interactions at multiple spatial and temporal
scales as they relate to habitat for aquatic and
floodplain species (e.g., fish, riparian vegetation)
along the Middle and Lower Reaches of the
Susitna River.” The omitted phrases help to
define the scope of the study to include both
landscape and local studies throughout the year,
acknowledge the study will include floodplains,
and limits the study to the Middle and Lower
Reaches of the Susitna River.” –pdf page 16
requested by the USFWS. With respect to the Lower River Segment, see AEA’s response
to comment GW-11.
GW-21 USFWS 11/14/2012 “The Service recognizes the downstream limit of
the study area is still under discussion, and we
look forward to participating in this discussion. In
addition to the longitudinal dimensions of the
study area, we recommend including the width of
the study area. For the groundwater study, the
width should be at least as wide as the expected
area of groundwater influenced by Project
operations, and include an additional buffer to
demonstrate the adjacent groundwater behavior
beyond Project influences.” –pdf page 16
The lateral extent of the Focus Areas will be determined by assessing the extent of surface
water / groundwater interaction through multiple lines of evidence. Mapping of the geologic
floodplain will be conducted first using an uncorrected LiDAR shaded relief map. Alluvial
terrain will be mapped relative to adjacent hill slopes. HEC-RAS (1-D) modeling of
discharge and stage will be used to delineate valley bottom floodplain flooding discharge
magnitudes by the fluvial geomorphology modeling (Section 6.6).
The width of the floodplain where groundwater is influenced by surface water, and Project
operations, will be determined by a combination of: (1) land surface mapping, using LiDAR
or surface mapping information, (2) geologic information, (3) observations of springs and
groundwater recharge to sloughs and ponds, (4) well observations, and (5) floodplain plant
community distribution. Further details are provided in Section 8.6.3.6 as well as Section
7.5 (Groundwater Study).
GW-22 USFWS 11/14/2012 “Service Objective1 (meaningful differences
underlined): “Synthesize historical data for
Susitna River groundwater and groundwater-
dependent aquatic and floodplain habitat,
including the 1980s studies”. “Floodplain” should
be included in the objective to broaden the
objective scope.” –pdf page 17
Objective 1 of the study plan has been revised to be consistent with the language
proposed by the USFWS (Section 7.5.1).
GW-23 USFWS 11/14/2012 “Not included in AEA’s methods is a review and As described in Section 7.5.4.1, Existing Data Synthesis, the groundwater literature review
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summary of other hydro projects in cold regions
and their effects on ice processes affecting
surface-water / groundwater. In addition to
including this review and summary, we also
recommend a review and summary of the current
knowledge of cold regions hydropower projects
effects on ice processes and how that has altered
instream flow, fluvial geomorphology, vegetation,
water quality, and fish habitat. These summaries
should be used to identify potential effects of the
proposed Project and guide the development of
methods and analyses to evaluate these effects.”
–pdf page 17
will include studies conducted at other cold region hydropower and water control projects.
The groundwater literature review will be coordinated with the Ice Processes in the Susitna
River Study (Section 7.6.4.11) and the Geomorphology Study (Section 6.5).
GW-24 USFWS 11/14/2012 “We recommend the process domain definitions
(Montgomery 1999) be vetted with the resource
agencies, and that all relevant information and
knowledge gained from the other studies be used
to assess and refine the process-domain mapping
of the Susitna River basin. Since AEA is
proposing to use process-domains as means to
extrapolate and predict Project effects on surface-
water / groundwater beyond the intensive study
Focus Areas, we recommend an assessment of
the precision and accuracy of the predicted
effects.” –pdf page 17
This comment is addressed in Section 7.5.4.2, Geohydrologic Process-Domains.
Riparian study area selection is based upon riparian process domain characterization
described in Section 8.6.3.2. Riparian Instream Flow Study areas will be selected through
a spatially constrained cluster analysis process and expert-opinion in coordination with the
TWG. Constrained cluster analysis is designed to statistically group river segments, and
reaches, such that classification of similar river elements, including floodplain types (full
range of plant communities) is made through an objective quantitative process (see
Section 8.6.3.2 for further details and references). Ten proposed Focus Areas in the
Middle River Segment have been identified (see AEA’s response to comment GW-10). In
Q1 2013 the quantitative GIS-based cluster analysis will be conducted in support of
finalizing Focus Area selection for 2013, in consultation with the TWG. See Section 8.6.3.2
for detailed methods. Riparian process domain delineation will be an iterative process
where Focus Areas will be first selected for 2013 fieldwork and if needed, additional Focus
Areas will be selected for study in 2014.
GW-25 USFWS 11/14/2012 “In addition AEA’s and Service’s requested
methods, we believe all stakeholders would
benefit by defining the downstream extent of the
reservoir’s influence on groundwater potentially
bypassing the dam. Adding this component would
require including a description of the methods
used to determine the downstream effects on
The downstream extent of changes in groundwater associated with construction and
operation of the reservoir is described in Section 7.5.4.3, Watana Dam/Reservoir.
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groundwater.” –pdf page 18
GW-26 USFWS 11/14/2012 “Service Objective 4 (meaningful differences
underlined): “Map groundwater influenced aquatic
and floodplain habitat (e.g., upwelling areas,
springs, groundwater-dependent wetlands).” The
fourth objective is very similar to our study
request objective, except we recommend
including floodplain habitat as well. The goal of
our study component is to map locations of
surface-water /groundwater interactions at a scale
relevant to riverine habitat types (as described in
the Aquatic and Riparian Instream Flow, and
Fluvial Geomorphology Studies). Groundwater
influences floodplain habitat in addition to the
aquatic habitat proposed by AEA. Groundwater-
dependent wetlands and subirrigated floodplain
plant communities are strongly influenced by the
frequency, timing, and duration of groundwater
levels.” –pdf page 18
The requested edits have been incorporated into the Groundwater Study objectives. This
comment is addressed in Sections 7.5.4.4 and 7.5.4.5. The mapping of floodplain habitat
and groundwater- dependant wetlands and other riparian habitat will use a combination of
LiDAR data, vegetative mapping (Section 11.5), and hydrologic and riparian analysis from
the Riparian Instream Flow Study (Section 8.6).
GW-27 USFWS 11/14/2012 “Terrestrial groundwater-influenced habitats are
much easier to identify than groundwater
influenced aquatic habitats because they can be
easily observed (e.g., springs, hydrophytic
vegetation). For this objective, we recommend
including a component identifying groundwater
dependent wetlands and characterizing their
potential groundwater sources. Subirrigated
floodplain plant communities and their potential
groundwater sources should also be identified at
the “reconnaissance level” as part of this
objective; although we recognize the Riparian
Instream Flow Study (Section 6.6) will likely
provide more detailed information regarding
subirrigated communities.” –pdf page 18
See Section 7.5.4.5, Riparian Vegetation Dependency on Groundwater / Surface Water
Interactions.
GW-28 USFWS 11/14/2012 “Aquatic groundwater-influenced habitat on the This comment is addressed in the Fish and Aquatics Instream Flow Study (Section
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other hand is more difficult to identify because
surface water, especially if turbid or frozen, often
obscures direct observation. For this reason, AEA
proposed a variety of methods to identify
groundwater-influenced aquatic habitat. It is
unclear if the various proposed methods in
Section 5.7.4.4 are adequate to capture the
groundwater influence on aquatic habitats
throughout the study area. These methods are a
series of study components from ice processes,
geomorphology, instream flow, water quality, and
fish studies. We have three basic concerns:
1) the mainstem upwelling areas will not be
accurately accounted for and no actual
groundwater investigation focuses on the
mainstem;
2) these methods are not focused on determining
upwelling areas and may not capture the actual
distribution of upwelling areas; and
3) the Groundwater-related Aquatic Habitat study
plan is not responsible for collection of any of this
data.” –pdf page 18
8.5.4.6.1.5). Additional details on mainstem winter discharge measurements are covered in
the Instream Flow Study Section 8.5.4.4. Winter discharge measurements, in coordination
with USGS data collection program, will occur at 11 of the 13 AEA gaging stations. The
lower two stations are operated for understanding potential tidal effects. Winter gaging will
occur in January and March of 2013 and 2014, or at time frames in coordination with
USGS measurements. Coordination with the Ice Processes in the Susitna River Study
(Section 7.6) on the identification of open leads and the influences that lead to the open
leads will also help identify primary areas of upwelling on the main channel. Groundwater
analyses in main channel areas are described in Sections 7.5.4.1, 7.5.4.2, and 7.5.4.4,
and in main channel areas within Focus Areas as described in Sections 7.5.4.5 and
7.5.4.6. The Groundwater Study is responsible for the collection of groundwater data and
will coordinate with other studies on collecting data that are ancillary, but pertinent, to
groundwater investigations. No single method is expected to capture the complete
distribution of upwelling areas; however, in combination, the proposed methods should be
sufficient to evaluate effects of the Project on aquatic groundwater influenced habitats.
GW-29 USFWS 11/14/2012 “There is a high likelihood that these upwelling
characterization study components won’t
accurately capture the upwelling areas, the
overall distribution of upwelling will not be
accounted for, and the importance of upwelling
for over-wintering fish and fish eggs will not be
captured. If the pilot thermal imaging assessment
successfully captures upwelling areas (with
groundtruthing to assess success), then this
method should be applied to the middle river from
the confluence with the Talkeetna and Chulitna
Rivers upstream to Devil’s Canyon. The success
or failure of the thermal imaging assessment must
also be defined. If the trial thermal imaging study
This comment is addressed in Section 7.5.4.4. Also, see AEA’s response to comments
GW-07 and GW-28.
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is successful how will it be expanded and used to
map upwelling? If it is unsuccessful how does
AEA plan on identifying the spatial distribution of
upwelling? Use of open-leads during winter ice
mapping alone will not demonstrate the full extent
of upwelling areas.” –pdf page 19
GW-30 USFWS 11/14/2012 “We recommend describing groundwater
methods in the groundwater study, and describing
riparian methods in the riparian study. Our
comments below focus on the groundwater
methods from both studies that should be
included in the groundwater study.” –pdf page 19
In response to this request, groundwater methods are described in the Groundwater Study
(see Section 7.5.4.5).
.
GW-31 USFWS 11/14/2012 “The suggested four to six intensive study
reaches (now called Focus Areas) instrumented
with groundwater and surface-water recording
instruments may be insufficient to address this
objective if plant response will be described by
process-domains (see Service pseudoreplication
discussion in our comments for Riparian Instream
Flow Objective 2). For the Focus Areas where
multiple study disciplines will focus and
complement their work, we recommend the
Groundwater-related Aquatic Habitat Study first
develop criteria required for selecting their study
sites independent of the other studies. Next,
develop a list of study products from the
Groundwater-related Aquatic Habitat Study that
other studies require, and then work with the
other studies and stakeholders to select Focus
This comment is addressed in Section 7.5.4.5. The Groundwater Study is not a stand-
alone study; it is designed to be a coordinated effort with other studies to help guide data
collection activities related to GW/SW interactions. See AEA’s response to comment GW-
24 regarding selection of Focus Areas.
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Areas. A master matrix of studies, data needs
and data products would greatly facilitate this
process and stakeholder acceptance.” –pdf page
19
GW-32 USFWS 11/14/2012 “One-and-a-half growing seasons (July 2013 to
September 2014) will likely provide insufficient
groundwater hydrology data to fit individual
species response curves (especially for annual
species), and may not be enough data to
reasonably predict groundwater relationships with
river stage and to verify the model predictions
with independent data. The Service recognizes
that aquifer properties can be estimated by taking
advantage of relatively rapid changes in river
stage, but these events can be confounded by
other factors such as local precipitation.
Precipitation can dramatically affect transient, but
critical, shallow groundwater levels (a few days to
a week or more of elevated water levels), which
would be difficult to evaluate with limited data.
Hydrologists often recommend using at least ten
years of data to reasonably extend the period of
record for river stage. The study plan must define
the uncertainties in groundwater hydrology
different than surface-water hydrology, and must
consider a reasonable period of record to verify
groundwater predictions.” –pdf page 19-20
These comments are addressed in Sections 7.5.4.5 and 7.5.4.6, as well as the Riparian
Instream Flow Study (Section 8.6). The proposed study methods address the potential
influence of local precipitation on groundwater processes. This study will utilize hydrologic
data from the 1980s studies, as well as data collected 2012 through 2014, and will include
development of analysis tools to improve the understanding of hydrologic processes
outside that gained by data collection programs alone. The surface-water records extend
the range of hydrologic information beyond a ten year period of record. The record of
surface-water data collection is being further developed by a thorough data collection
program developed in conjunction with Fish and Aquatics Instream Flow Study (Section
8.5.4.4.1.1) and USGS data collection programs. These data collection and analysis
approaches will provide sufficient data to evaluate potential Project effects.
GW-33 USFWS 11/14/2012 “The “project accuracy standards used for water-
level measurements” for horizontal, vertical and
temporal measurements must be defined. If
MODFLOW (USGS 2005) will be used, what is
the expected accuracy of the predicted water
table surface? What are the model and aquifer
property assumptions for using MODFLOW, and
how are discrepancies addressed and the
predictions affected? The difference between the
See Section 7.5.4.5. The accuracy of MODFLOW is not a function of the model code, but
of the information being applied to any one specific modeling project. The combination of
the proposed well networks and development of groundwater modeling simulation tools
provides a thorough approach to understand the relationships between groundwater,
riparian vegetation, and resulting variations created by surface-water interactions. The
model simulations, along with independent analysis of field data, inform the complex
processes and their interactions.
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water table being too deep or too shallow for
some herbaceous species is as little as 20 cm or
less, and for some sedge communities about 50
cm or less. If the depth-to-water will be estimated
by subtracting the predicted water table (e.g.,
MODFLOW) from the ground surface (e.g.,
LIDAR), then the combined error of both the
water table and the ground surface must be
considered. In addition, the predicted
surfacewater stage and its accuracy must also be
provided for emergent communities. For complex
hydrologic and biotic sites such as Whiskers
Slough, the density of recording wells and
surfacewater gages presented in the 1 October
2012 Riparian Instream Flow TWG meeting may
need to be increased in both density along the
transects and the total number of transects to
achieve the accuracy required for the Riparian
ISF study.” –pdf page 20
GW-34 USFWS 11/14/2012 “AEA’s methods for the Groundwater-related
Aquatic Habitat Study plan are vague and it is
unclear which study is responsible for collecting
the site-specific groundwater data. We
recommend the revised study plan detail the
methods for collecting the groundwater
potentiometric surface at each of the aquatic
study sites.” –pdf page 21
The methods section of the Groundwater Study (Section 7.5.4) has been revised and
expanded to identify parties responsible for collecting and analyzing site-specific
groundwater data. The data collection program for proposed Focus Areas sites related to
aquatic resources is described in Section 7.5.4.6. The potentiometric surface (water table
surface) will be developed by incorporating a series of groundwater and surface
measurements at each Focus Area. The continuous data collection stations will provide an
understanding of rising and falling water stages for groundwater and surface-water
systems. This in combination with the understanding gained from groundwater model,
aerial maps and observations will all be used to help develop potentiometric maps.
GW-35 USFWS 11/14/2012 “Study sites used to understand surface-water /
groundwater interaction and how the process
influences habitat use by anadromous fish should
span all the geomorphic classification types used
by anadromous species, including off channel
(side channels, side sloughs, upland sloughs) and
mainstem features in the middle and lower river.
The number, extent, and location of proposed Focus Areas is intended to span all of the
geomorphic classification types used by anadromous fish species (see AEA’s response to
comment GW-10). Additional detail can be found in section 7.5.4.6. The extrapolation of
results of modeled areas to non-modeled areas is described in Section 8.5.4.7 Temporal
and Spatial Habitat Analyses and will be adjusted as needed to address groundwater-
related processes.
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The methods for extrapolating surface-water/
groundwater study results from the Focus Areas
to the river segments are unclear.” –pdf page 21
GW-36 USFWS 11/14/2012 “AEA Study Objective 5 (with requests submitted
above) has a more detailed study description for
the floodplain alluvial aquifer than for AEA’s
aquatic groundwater Study Objective 6, even
when considering the schematic detailing the
surface-water / groundwater sampling network
presented at the 16 August 2012 TWG meeting.
We recommend the monitoring and modeling
approach described for the floodplain be adapted
and applied to the aquatic instream flow study
sites and other sites of particular fish habitat
importance (spawning, rearing, overwintering
habitats).” –pdf page 21
The Groundwater Study addresses these comments. Further details can be found in
sections 7.5.4.5 Riparian Vegetation Dependency on Groundwater/Surface-Water
Interactions, and 7.5.4.6 Aquatic Habitat Groundwater/Surface-Water Interactions.
GW-37 NMFS 11/14/2012
“The last sentence in the first paragraph of
Section 5.7.1.1 suggests the Groundwater PSP is
not much more than a passive summary of other
studies, when in fact the Groundwater PSP is a
critical input for other studies not unlike the U.S.
Geological Service’s (USGS) data that will be
used by other studies. Clarifying the purpose and
roles of the PSPs will help NMFS understand
what studies are actually be proposed and how
and when they will be conducted.
the pdf page 33.
See AEA’s response to comment GW-17.
GW-38 NMFS 11/14/2012 “This study does not propose collecting any
groundwater related data, but rather proposes
using other studies to collect this data and then to
integrate this data into models of
surface/groundwater interactions. The aquatic
instream flow proposed study plan did not provide
The Groundwater Study has been revised and expanded to address these comments.
Section 7.5.4.6 Aquatic Habitat Groundwater/Surface-Water Interactions has additional
details on the collection and analysis of data related to aquatic habitat. The collection of
groundwater data will be the responsibility of the Groundwater Study.
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methods for understanding project effects to
surface/groundwater exchange, or how project
operations effects to habitat associated with
surface/groundwater exchange will be assessed.
NMFS is concerned that inadequate responsibility
is assigned to this topic and that the data
collected will not meet our stated goals for this
study. We request a clear description of the
methods used, the expected outcome, what can
be determined, and how uncertainty will be
calculated for each of the study objectives
requested (NMFS 2012).” –pdf page 33
GW-39 NMFS 11/14/2012 “During the August 15,2012, Technical Work
Group (TWG) meetings NMFS, the U.S. Fish and
Wildlife Service (USFWS) and other attendees
requested a more detailed study frame work, one
that not only lists a range of methods but defines
the specific objectives and addresses the
agencies objectives and information needs, and
logic for how the proposed methods would be
implemented to achieve those objectives.
A schematic was presented to explain what an
intensive data site would look like for the
floodplain groundwater intensive study sites; a
figure and explanation for what an intensive (now
called Focus Areas) instream flow study site
would include with an description of data and
deliverables could explain how the study will
address NMFS requested study objectives and
clarify the study plan.
Additionally, study plans should explain how the
study will develop confidence intervals and
calculated errors for each of the indices, data
summaries, and model outputs. Without a
The Groundwater Study has been revised and expanded to address these comments.
Figures 7.5-8, 7.5-9 and 7.5-10 illustrate groundwater data collection networks for riparian
and fish and aquatic habitats within a Focus Area. The study method sections also include
information on data collection, model simulations, and sensitivity and accuracy analyses.
Data deliverables are described for each of the study elements in Sections 7.5.4.1 through
7.5.4.9.
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description of data, deliverables, and how
uncertainty will be assessed NMFS cannot
determine if the proposed studies are complete or
adequate.” –pdf page 33
GW-40 NMFS 11/14/2012 “The additional detail requested will be used to
assess the applicant's plan and if it meets the
intent of the NMFS study requests. This should
include a schedule and methods for attaining the
groundwater data relevant to aquatic habitats and
development of operation flow sensitive
surface/groundwater exchange models.
Specifically, more detail is needed about the
proposed approach to assess the habitat
utilization and habitat characteristics for
overwintering juvenile anadromous fish and how
groundwater exchange influences the suitability of
winter habitat.” –pdf page 33
As described in Section 7.5.4.6, groundwater data collection, modeling and analyses are
the responsibility of the Groundwater Study, but analyses of the interaction of
groundwater/surface-water with fish and aquatic habitats requires close coordination with
the Fish and Aquatics Instream Flow Study (Section 8.5). The instream study programs
(Sections 8.5 and 8.6) will address habitat utilization and characteristics, while the
Groundwater Study will focus on the physical and hydraulic aspects of
groundwater/surface-water interactions. Based on the results of the 1980s studies, the
influence of groundwater/surface-water interactions on salmonid spawning and incubation
and juvenile salmonid overwintering habitats are key concerns of proposed Project
operations. The Groundwater Study (Section 7.5) has been designed to analyze such
groundwater exchanges associated with existing conditions and alternative operational
scenarios under winter conditions.
GW-41 NMFS 11/14/2012 “In addition to the outlined methods to evaluate
existing data (section 5.7.4.1 Existing Data
Synthesis), we request a review and summary of
other hydroelectric projects in cold regions and
their effects on surface/groundwater interactions.
This review will help NMFS understand the
existing understanding of likely effects to
surface/groundwater exchange related to
hydroelectric projects and may introduce methods
of study not currently being proposed. This review
will also summarize the current knowledge of cold
regions hydropower projects effects on ice
processes and how that has altered instream
flow, surface/groundwater interaction,
geomorphology, vegetation, water quality, and
fish habitat.”
See AEA’s response to comment GW-23.
GW-42 NMFS 11/14/2012 “The PSP contains large-scale geohydrologic This comment is addressed in Section 7.5.4.2 Geohydrologic Process-Domains. See
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process domains, currently undefined, but it is not
clear how they will be used outside of large scale
classification. NMFS requests that definitions of
process domains be provided, how they are
defined, and how they will be used to understand
project effects to surface/groundwater exchange
at multiple scales. We request the process
domain definitions be vetted with the resource
agencies, and that all relevant information and
knowledge gained from the other studies be used
to assess and refine the process-domain mapping
of the Susitna River basin. Since AEA is
proposing to use process-domains as means to
extrapolate and predict project effects on surface-
water/groundwater beyond the intensive study
Focus Areas, we request an assessment of the
precision and accuracy of the predicted effects.”
AEA’s response to RIFS-21, which covers the evaluation of the process domains,
selection, and scaling of Focus Areas for habitat resources. The continued interaction with
the TWG at regularly scheduled meetings will allow the process to be reviewed at the
different stages of development and implementation.
The proposed Focus Areas in the Middle River Segment are intended to reflect the full
range of riparian and floodplain plant communities within the segment. Focus Area
selection was based upon riparian process domain characterization described in Section
8.6.3.2. Potential refinement of proposed Focus Areas will be conducted using 2012 field
data collected under the Riparian Vegetation Study Downstream of the Proposed Watana
Dam (Section 11.6), and a spatially-constrained cluster analysis process in coordination
with the TWG. Constrained cluster analysis is designed to statistically group river
segments, and reaches, such that classification of similar river elements, including
floodplain types (full range of plant communities) is made through an objective quantitative
process (see Section 8.6.3.2 for further details and references). Riparian process domain
delineation will be an iterative process where Focus Areas will be confirmed for 2013
fieldwork. As additional field data are collected, specifically ice process evidence (tree
scars), additional Focus Area sites may be selected for study in 2014.
GW-43 NMFS 11/14/2012 “The methods described in section 5.7.4.3 of the
applicants study plan are consistent with the
intent of our request. In addition to the flow paths
and conceptual surface/groundwater model, we
request a description of how the downstream
extent of the reservoir's influence on groundwater
will be determined. This will help NMFS
determine if additional study is necessary to
assess the reservoir effects to fish and their
habitat downstream of the inundation zone.”
See AEA’s response to comment GW-02.
GW-44 NMFS 11/14/2012 [below is paraphrased section from relevant
NMFS letter]
a) It is unclear from the PSP if the various
proposed methods adequately capture the
influence of groundwater on aquatic
habitats throughout the study area.
Because the goal of our study request is to
a) The Groundwater Study RSP (Section 7.5) addresses this comment. Additional
information is available in AEA’s responses to comments GW-07 and GW-28, as
well as WQ-05.
b) The methods are defined in the Groundwater Study (Section 7.5.4.4), in Fish and
Aquatics Instream Flow Study hydrology (Section 8.5.4.4.1.1), Baseline Water
Quality Study (Section 5.5.4.9), and Ice Processes in the Susitna River Study
(Section 7.6.4.1). The cumulative methods that will be used to define
groundwater discharge (upwelling) areas to mainstem areas (main channel, side
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understand project effects on
surface/groundwater interactions at multiple
spatial and temporal scales as they relate to
habitat a thorough understanding of the
distribution of groundwater influence aquatic
habitat is needed.
b) We have three basic concerns:
- first the mainstem upwelling areas will
not be accurately accounted for and no
actual groundwater information focuses
on the mainstem;
- second these methods are not focused
on determining upwelling/downwelling
areas and flow paths and may not
capture the actual distribution of
upwelling/downwelling areas and
- third the Groundwater-related Aquatic
Habitat study plan is not responsible for
collection of any of this data.
c) To resolve these concerns, NMFS believes
that the study plan should be refined to
include additional methods (Rosenberry and
LaBaugh 2008) and study areas to
understand the spatial distribution of
surface/groundwater exchange at a scale
relevant to fish and their habitat, and a clear
understanding of when and who is
responsible for delivering the study results.
There is a high likelihood that the
characterization study components will not
capture the overall distribution of
upwelling/downwelling and the importance
of surface/groundwater exchange for over
wintering fish and fish eggs.
channel, side sloughs, upland sloughs, ponds and wetland) include the following:
- Winter discharge measurements conducted in January and March of 2013
and 2014 at AEA gaging stations, in coordination with USGS measuring
discharge at USGS stations. These data sets will be used to measure the
variation and potential increases in discharge along the Middle River
Segment to characterize potential zones of ground discharge to the Susitna
River (Section 8.5.4.4.1.1).
- Winter open leads characterization to identify open leads that may be
thermal systems (discharge of warmer groundwater), velocity systems, or
combinations of both (Section 7.6.4.1).
- Open leads identified by ice studies will be surveyed during winter months
to help verify if leads are primarily thermal or velocity driven (Section
7.5.4.4).
c) Focus Areas included in Groundwater Study Section 7.5.4.6 will have additional
temperature measurements made in selected side channel, side slough, and
upland slough habitats to help further characterize groundwater discharge and
upwelling processes.
d) Pilot thermal imaging with Forward Looking Infra-Red (FLIR) technology was
flown in October 2012. If this technology proves useful, it may be expanded for
other segments in the Middle and Lower River areas.
e) Clarification has been added to Sections 7.5.4.1 through 7.5.4.9 to indicate in
which study data will be collected and analyzed.
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d) If the pilot thermal imaging assessment
successfully captures upwelling areas
(quantifying the success of the method
through comparison of in situ
measurements) then this method should be
applied to the project area. The success or
failure of the thermal imaging assessment
must also be defined. If the trial thermal
imaging study is successful how will it be
expanded and used to map upwelling? If it
is unsuccessful how does AEA plan on
identifying the spatial distribution of
upwelling? Use of open-leads during winter
ice mapping alone will not demonstrate the
full extent of upwelling areas. Beyond
characterization, it is unclear how scale,
source, flow paths, and timing of
surface/groundwater exchange processes
will be accounted for.
e) NMFS believes that the Federal Energy
Regulatory Commission (FERC) should
address the issue of study period extension,
if study result are incompleteness or
insufficient at the end of the ILP study
period how will FERC determine how long
studies should be extended or adapted?
Without complete studies that provide
results relevant to fish and their habitat
NMFS will be unable to make
recommendations that allow for alteration of
habitat or of the natural flow regime.
GW-45 NMFS 11/14/2012 [Below is paraphrased section from relevant
NMFS letter, bottom of PDF page 35 through the
top half of PDF page 36.]
a) The Groundwater Study RSP (Section 7.5) addresses this comment. See AEA’s
response to comment GW-32. This response addresses the comments regarding
growing seasons, precipitation and study period duration. Clarifications on
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a) This study component (described by AEA
Study Objective 5) will provide the
necessary groundwater information for the
riparian instream flow study to develop plant
community response curves, which can be
used to predict the effects of project
operation on floodplain plant communities.
Clarification is needed for the groundwater
objective outlined in the groundwater study
(Section 5.7.4.5), and the riparian instream
flow study (Section 6.6).
b) The suggested four to six intensive study
reaches (now called Focus Areas)
instrumented with groundwater and surface-
water recording instruments may be
insufficient to address this objective if plant
response will be described by process-
domains. NMFS believes there should more
study reaches to address the spatial
distribution and variability of the
surface/groundwater exchange processes.
c) One-and-a-half growing seasons (July 2013
to September 2014) will likely provide
insufficient groundwater hydrology data to fit
individual species response curves
(especially for annual species), and may not
be enough data to reasonably predict
groundwater relationships with river stage
and to verify the model predictions with
independent data.
d) Precipitation may also dramatically affect
transient but critical groundwater levels (a
groundwater study methods have been added to Sections 7.5.4.1 through 7.5.4.9.
b) The Groundwater Study has been designed to support the Riparian Instream Flow
Study (Section 8.6) and the Fish and Aquatics Instream Flow Study (Section 8.5).
These studies, in conjunction with agency review and input, will determine the final
number of Focus Areas for each study. The Groundwater Study will implement the
supporting study elements (Sections 7.5.4.5 and 7.5.4.6, respectively) at each of the
Focus Areas.
c) This comment is addressed in Section 7.5.4.5. See AEA’s response to comment
GW-33.
d) The accuracy of manual groundwater and surface-water level measurements is 0.02
feet. The accuracy of continuous water level measurements by pressure transducers
is generally within 0.02 feet. The accuracy to Project sea level datum is related to the
survey control network. Relative accuracy between measurements within a Focus
Area will typically be within 0.02 feet, but between Focus Areas may be within 0.2
feet vertical accuracy.
e) The accuracy of MODFLOW water table elevations will be determined by comparison
of measured water levels from wells and simulated water levels from modeling runs.
f) The measurement of the error in the LiDAR surface is described in the Fish and
Aquatic Instream Flow Study Section 8.5.4.4.1.1. Where the LiDAR data is
determined to not meet study objectives, then the ground-based mapping of Focus
Areas will be conducted to provide ground surface elevation maps meeting study
requirements.
g) The number of wells for each study area will be determined in Q1 2013 in
coordination with other studies and will be presented for input at TWG quarterly
meetings.
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few days to a week or more of elevated
water levels), which would be difficult to
evaluate with limited data. NMFS suggests
that additional years of study will be
necessary to capture the variability in water
years and to sufficiently understand species
response to hydrologic conditions.
e) NMFS needs an answer to this question:
what are the "project accuracy standards
used for waterlevel measurements" for
horizontal, vertical and temporal
measurements? If MODFLOW will be used,
what is the expected accuracy of the
predicted water table surface, and how will
this be determined and reported after model
development? Should the depth to water be
estimated by subtracting the predicted
water table (e.g., MODFLOW) from the
ground surface (e.g., LIDAR)? In that case,
the combined error of both the water table
and the ground surface must be considered.
In addition, the predicted surface-water
stage and its accuracy must also be
provided for emergent communities.
f) For complex hydrologic and biotic sites
such as Whiskers Slough, the density of
recording wells and surface-water gages
presented in the October 1,2012, Riparian
Instream Flow (ISF) TWG meeting may
need to be increased in both density along
the transects and the total number of
transects to achieve the accuracy required
for the Riparian ISF study. With NMFS and
USFWS recommendations this study
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component will provide results that will allow
the agencies to determine project effects to
shallow alluvial aquifers and relationships
between floodplain and riparian plant
communities and to make
recommendations to minimize these effects.
GW-46 NMFS 11/14/2012 “The study methods for the Groundwater-related
Aquatic Habitat Study plan are vague and unclear
and do not identify which study is responsible for
collection of the site specific groundwater data.
NMFS requests a description of methodologies,
number of piezometers, number of study sites,
and deliverables. We request that the revised
study plan detail the methods for collecting the
groundwater potentiometric surface through each
of the aquatic study sites.” –pdf page 36
This comment is addressed in Sections 7.5.4.1 through 7.5.4.9. Groundwater and surface-
water levels will be measured manually and at a subset of data stations continuously with
pressure transducers. These data, in conjunction with the understanding gained through
the groundwater models will help calculate and define the potentiometric water surfaces,
also called water table maps. .
GW-47 NMFS 11/14/2012 “The flow paths of water through the subsurface
as groundwater and hyporheic flow may
moderate stream temperatures and provide
thermal heterogeneity (Johnson and Jones 2000;
Mellina et al. 2002; Moore et al. 2005; Rothwell
2005). NMFS requests that the Focus Areas
include surface/groundwater study that will
provide baseline understanding of
surface/groundwater exchange (temporally and
spatially), how these processes influence water
quality, and how these processes may change
with the project.” –pdf page 37
This comment is addressed in Section 7.5.4.6 Aquatic Habitat Groundwater/Surface-Water
Interactions. The data collection programs and development of groundwater simulation
models, with surface-water and water quality components, will be used to develop the
understanding of how groundwater and surface water (main channel, side channel, side
sloughs, upload sloughs, wetlands) interact and how this interaction may change with
potential Project operations.
GW-48 NMFS 11/14/2012 “Study sites used to understand
surface/groundwater interaction and how the
process influences use of habitat by anadromous
fish should span all of the habitat types used by
anadromous species, including off channel (side
channels, side sloughs, upland sloughs) and
mainstem features in the middle and lower river.
See AEA’s response to comment GW-35.
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The study plan is incomplete without a description
of methods for extrapolating surface/groundwater
study results from Focus Areas to the entire
project area. NMFS requests a clear description
of how the project effects to fish and their habitat
through changes to surface/groundwater
interaction will be quantified.” –pdf page 37
GW-49 NMFS 11/14/2012 “Modeling may include the use of MOD FLOW
(USGS 2005 and Feinstein 2012)
surface/groundwater interaction models of
floodplain shallow alluvial aquifer and surface-
water relationships. We request that the
monitoring and modeling approach be further
described for the aquatic instream flow study sites
and other sites of particular fish habitat
importance (spawning, rearing, overwintering
habitats). This description and refinement are
necessary in the revised study plans for NMFS to
determine if the approach is adequate to describe
surface/groundwater interaction at each of the
Focus Areas.” –pdf page 37
This comment is addressed in Section 7.5.4.6.
GW-50 NMFS 11/14/2012 “Characterization of water quality must have a
temporal component to assess surface water
influences on groundwater water quality
parameters (temperature, dissolved oxygen,
conductivity, nutrients). This appears to missing
from the PSP.” –pdf page 37
This comment is addressed in Section 7.5.4.6. The study incorporates continuous
groundwater and surface-water monitoring of water temperature, dissolved oxygen, and
spot measurements of conductivity. These parameters are the most useful groundwater
tracers to understand groundwater and surface-water interactions and resulting water
quality changes.
AEA is not measuring groundwater age in this study. The data collection related to water
quality will provide useful data informing local scale groundwater flow systems, without the
use of the water age data.
GW-51 NMFS 11/14/2012 “NMFS agrees with the applicant that
surface/groundwater interactions are critical to
aquatic habitat functions, and that the project
operations will have an impact on the winter flow
conditions, including surface/groundwater
A range of alternative operational scenarios will be evaluated as described in the Fish and
Aquatics Instream Flow Study (Section 8.5.4.3.2). The four modeling scenarios include
existing conditions, maximum load-following, intermediate load-following and a base-load
scenario. The three with-Project scenarios will provide bookends and an intermediate
assessment of potential Project effects. The range of operational scenarios will account for
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exchange which will influence the habitat used by
anadromous species. The methods associated
with the study plan objective eight include data
collection at the stream gages and at specific
study areas. It may be implied by this study
objective, but we request that both baseline and
with project operations winter flow
characterization are necessary. This should
include development of surface/groundwater
exchange models that include winter operations
scenario analysis, accounting for changes to ice
thickness and cover and changes in water quality
(temperature, dissolved oxygen, nutrients,
specific conductivity) all associated with the
proposed winter operations (either load following
or baseload). NMFS believes that adoption of our
recommendation will improve the understanding
of existing processes and allow a better
understanding of the project effects necessary for
NMFS to make conservation recommendations.”
–pdf page 38
changes to ice cover and thickness in the Ice Processes in the Susitna River Study model
(Section 7.6) which will be used to provide input boundary conditions for the main channel
in each of the groundwater modeling domains. As described in Section 7.5.4.6,
groundwater data collection, modeling and analyses are the responsibility of the
Groundwater Study, but analyses of the interaction of groundwater/surface-water with fish
and aquatic habitats requires close coordination with the Fish and Aquatics Instream Flow
Study (Section 8.5). The instream study program (Section 8.5 and 8.6) will address habitat
utilization and characteristics, while the Groundwater Study will focus on the physical and
hydraulic aspects of groundwater/surface-water interactions. Based on the results of the
1980s studies, the influence of groundwater/surface-water interactions on salmonid
spawning and incubation and juvenile salmonid overwintering habitats are key concerns of
proposed Project operations. The Groundwater Study (Section 7.5) has been designed to
analyze such groundwater exchanges associated with existing conditions and alternative
operational scenarios under winter conditions.
GW-52 NMFS 11/14/2012 “Although this objective does not directly relate to
NMFS' trust resources, we believe that
information gained from study objective nine will
aid in the overall understanding of the Susitna
River groundwater system. Additional
groundwater information should be incorporated
into the groundwater models developed at Focus
Areas and at larger (potentially regional) scales.”
–pdf page 38
This comment is addressed in Section 7.5.4.9. The groundwater data collected in shallow
groundwater wells will help improve the understanding of groundwater and surface-water
interactions along the river segments where homeowner and businesses have existing
wells. This information will help in some areas to scale the results and processes
understanding from Focus Areas to geomorphic reaches and segments.
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
ICE-01 CWA 11/14/2012 Scope is insufficient in studying the Lower River based on AEA’s
apparent assumption that Project effects will not significantly affect
the Lower River ice processes. –pdf pages 7-8
AEA is not assuming an insignificant Project-related effect on Lower
River ice processes. AEA is investigating potential Project-induced
effects on ice processes on the Lower River (Section 7.6.3.4). The
Ice Processes in the Susitna River Study includes a section
describing the scope of ice processes observations and modeling on
the Lower River (Section 7.6.3.10).
ICE-02 TNC 11/14/2012 “Lower River Studies
Many of the study plans assume no effects from the project and its
operation below Talkeetna (Mile 97) and do not include the Lower
River in their scope. As noted in our comments on Climate Change
impacts above, the cumulative impacts of this project with other
anticipated changes to the basin could affect salmon and salmon
habitat in the Lower River. Load-following operation, which will
essentially flip the hydrological pattern between winter and
summer, must be modeled for effects on the Lower River. The
hydrological model has been extended to Mile 84 in the upper
Lower River, and the study plan notes that the model will be
extended further into the Lower River if project effects are seen at
Mile 84. It is not clear what the trigger will be to extend the model
and how or when that will be decided. The Revised Study Plans,
including those for geomorphology, instream flow, and ice
processes, should include the Lower River. If they do not but leave
the possibility open depending upon early results, the plans should
be explicit about why they assume no effect on the Lower River
and what criteria will be used to revisit the need to extend models
when early results are available.” –pdf page 3
See AEA’s response to comment ICE-01. See also AEA’s response
to comment IFS-33.
ICE-03 Coalition for
Susitna Dam
Alternatives
11/14/2012 “Two years are not enough for the Ice Processes Study.” –pdf page
3
The number of years of winter observation which will be relied upon
for this study is sufficient to meet the goals and objectives of the
study plan. The study plan will rely upon at least seven years and
likely eight winters/years of observations (including 5 years in
1980’s, 2012-2013, 2013-2014, possibly 2014-2015 (7-8 years)). As
described in Section 7.6.2, these observations span a range of
meteorological conditions. This will allow AEA to meet study plan
goals and objectives.
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ICE-04 Long, Becky 11/13/2012 Two years are inadequate, request for 5 to 7 year study –pdf page
2
See AEA’s response to comment ICE-03.
ICE-05 Chase
Community
Council
11/15/2012 “Will the winter ice making and jamming change and if so, how will
that impact the system Downstream. What effect will the winter
water levels have on ice formation?” –pdf page 2
AEA will be using the ice processes model to predict potential
changes in ice cover formation and break-up, including ice
production, water levels, and jamming (Section 7.6.4.8.)
ICE-06 FERC 11/14/2012 “Describe in each of the relevant studies how the different
modeling results would be used. Where a parameter is measured
(or estimated using a model) in more than one study, define which
value will take precedence.” –pdf page 5
The Ice Processes River1D Model will provide flow routing and
temperature results for the Middle River for the ice-affected period.
The ice-affected period begins when a portion of the river cools to
32 degrees and ice begins to form in the fall until ice has flushed out
of the river in the spring and is no longer affecting temperature or
hydraulics (Section 7.6.4.6 and 7.6.4.7).
The Water Quality Temperature Model and the Open-Water
Hydraulic Routing Model will provide flow routing and temperature
results for the Middle River for the ice-free period. The detailed
River2D and River1D models developed for Instream Flow Study
Focus Areas will provide hydraulic data for the ice-affected period
for these Focus Areas. (Section 7.6.6).
ICE-07 FERC 11/14/2012 “Clearly describe the exact number, location, and spatial extent of
your proposed Focus Areas for each proposed study. Provide
justification for the number of proposed sites selected for detailed
2-D hydraulic modeling and other intensive study elements. Include
criteria to be used for selecting Focus Areas and study-specific
rationale for co-locating sites.” –pdf page 5
The Ice Processes in the Susitna River Study will provide physical
hydraulic data and modeling results for winter conditions at Focus
Areas. The determination of whether a1-D or 2-D model will be
needed will be made after the Focus Areas are selected. See
Section 8.5.4.2.1.1 (Table 8.5-6 and Figures 8.5-13 to 8.5-22) for a
discussion of how the Instream Flow Study Focus Areas will be
selected. As indicated in IFS-014 response, a total of ten Focus
Areas were identified. These 10 areas were selected for planning
purposes and will be evaluated further for their representativeness
of other areas based on results of habitat mapping that will be
completed in Q1 2013. The results of this evaluation will be
discussed with the TWG and refinements in Focus Area selection
made prior to commencement of the 2013 studies. Table 8.5-6
provides the rationale for Focus Area selection. The specific criteria
that were used in selecting the proposed Focus Areas include:
1) All major habitat types (main channel, side channel, side slough,
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upland slough, tributary delta) will be sampled within each
geomorphic reach.
2) At least one (and up to three) Focus Area(s) per geomorphic
reach (excepting geomorphic reaches associated with Devils
Canyon – MR-3 and MR-4) will be studied that is/are representative
of other areas.
3) A replicate sampling strategy will be used for measuring habitat
types within each Focus Area, which may include a random
selection process of mesohabitat types.
4) Areas that are known (based on existing and contemporary data)
to be biologically important for salmon spawning/rearing in mainstem
and lateral habitats will be sampled (i.e., critical habitats).
5) Areas for which little or no fish use has been documented or for
which information on fish use is lacking will also be sampled.
ICE-08 TNC 11/14/2012 “Operation Scenarios
The various models that are developed for the study plan should
look at three scenarios: existing (non-project), proposed load-
following operation, and base load operation. Early introductions of
this current project proposed base load operations. With current
power generation dependent upon natural gas supplies, it is
foreseeable that in the future this project could be operated to
supply base loads. In case of that operational change in future, the
base load case should be included in the models. This would also
provide the opportunity to gage the impacts of a wider range of
operation regimes.” –pdf page 3
AEA has revised the study plan to clarify that it intends to include a
base load scenario included in the Ice Processes Proposed
Conditions model (Section 7.6.4.7).
ICE-09 USFWS 11/14/2012 “The Service requests an analysis of the hydraulic flow routing and
ice process model’s abilities to assess project effects under the
proposed project operations. Specifically, will the model have the
ability to assess hydraulic flow routing and ice process effects at a
scale relevant to fish and their habitat? What can be determined
from the proposed study? How will uncertainty be determined from
the study and modeling results? Additional information must be
The Ice Processes River1D Model will handle winter flow routing, as
described in Section 7.6.6. The River1D model selected was
designed to simulate hydropower operations on ice-covered rivers,
among other scenarios. The model will route flows at the same
scale as the open-water flow routing model. Where this scale is
insufficient to determine effects to fish habitat, the River1D model
will provide boundary conditions for more detailed Focus Area
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provided to the currently proposed ice process models and the
winter hydraulic flow routing models in order to enable a sufficient
understanding of the project effects on anadromous fish and their
habitat.” –pdf page 31
models, which will be River1D or River2D models as appropriate for
the local conditions (Section 7.6.4.8).
ICE-10 USFWS 11/14/2012 “Winter discharge measurements are needed at each of the routing
cross-sections because ice thickness and roughness will greatly
influence the stage-discharge relationships. We request a detailed
description of the minimum number and locations of discharge
measurements to be taken during winter to populate and calibrate
the winter hydraulic flow routing and to be used by the winter ice
process model(s).” –pdf page 31
The Instream Flow Study (Section 8.5.4.3.1) describes how winter
discharges will be measured: “Winter mainstem flows will be
measured using a combination of current meter and ADCP
methods. The winter gaging program will be coordinated with USGS
so that the measurements from both programs occur at the same
general time period. The current schedule is to conduct winter
measurements in January and March of 2013 and 2014. The winter
discharge measurement will occur at the AEA gaging stations from
ESS80 downstream to ESS20 (Table 8.5-8). Winter discharge
measurement will not be collected at ESS10 and ESS15. These
discharge measurements will help assess gaining and losing river
reaches during winter conditions. This effort will be coordinated with
Ice Processes in the Susitna River Study (Section 7.6) so that
measurements also have direct applications to the ice processes
analysis and model development efforts”.
ICE-11 USFWS 11/14/2012 Paraphrased regarding the literature review:
• Should present a general overview of river ice processes
relevant to the Susitna River with reference to the study
reach.
• The literature review should be expanded beyond the 5
listed papers to include international project sites and
non-hydropower infrastructure projects
• The review should provide greater insight into processes
in the study reach, impacts of the project, and methods
of analysis used to assess impacts on river ice
processes and winter fish habitat.
• A glossary of river-ice related terms should be provided.
–pdf page 31
AEA has revised the study to expand the scope of the white paper to
include an overview of ice processes and methods of analysis of
river ice problems relevant to the Susitna River (Section 7.6.4.11).
The review will also cover relevant ice-affected large rivers with
hydropower development where applicable beyond the five listed
publications, including international projects. Hydropower
development has very specific impacts on river ice that other
development (bridges, levees, diversions) does not. Thus,
hydropower will be the focus of the white paper.
A glossary of river ice terms will be provided.
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ICE-12 USFWS 11/14/2012 “The study plan must include a schedule to collect necessary data,
prepare the model, and complete the analysis. Additionally, the
plan should include enough flexibility to extend the studies if the
data and modeling products are not sufficient for the Service to
adequately analyze winter operation effects on anadromous fish.” –
pdf page 32
The study schedule is presented in Section 7.6.7. The ILP process
provides sufficient flexibility and includes opportunities for agency
review and comment.
ICE-13 USFWS 11/14/2012 “While all northern rivers share similar traits in terms of general
river ice processes, they are all very unique. The PSP should
outline how the existing regime will be characterized. By
characterizing the existing regime the study team will gain valuable
insights into the specific behaviors of the study reach over the ice-
affected period. A proper characterization would define the key
drivers behind the dominant river ice processes and describe the
nexus of these dominant processes with fish and fish habitat, and
other studies. The characterization should also identify the
controlling factors with respect to each nexus. Characterization
should consider: spatial and temporal variability; river ice evolution;
annual variations; and key physical and meteorological drivers.
Adequate characterization will help guide the development of a
suitable framework for assessing project impacts. An important
characterization task is observation. The PSP should describe the
data requirements needed to support characterization of the
existing ice regime.” –pdf page 33
The RSP describes the methods of characterizing the existing ice
regime by various methods of observation (aerial reconnaissance,
time-lapse cameras, measurement, continuous pressure
transducers, meteorological data) (Sections 7.6.4.2 to 7.6.4.4).
These methods, combined with the detailed characterizations from
the 1980s, will provide fisheries and geomorphology studies with the
necessary information they need to assess how their resources are
affected by ice. This is described in the Relationship with Other
Studies Section 7.6.7.
ICE-14 USFWS 11/14/2012 “The modeling approach must include a discussion of the selected
model limitations and the limitations of the winter hydraulic flow
routing models. Although the winter hydraulic flow routing model is
discussed under the instream flow study plan and the model results
are needed by this, among other studies, no detailed data
collection for the winter hydraulic flow routing is described.” –pdf
page 33
The Ice Processes Model will route winter flows. The data
described in Section 7.6.4 is needed to populate and calibrate the
Ice Processes Model. Winter Flow Routing specifically will be
calibrated using the winter discharge measurements and associated
ice thickness measurements at transects as described in ISF
Section 8.5.4.3.1. Description of limitations and sources of error in
modeling is included in Section 7.6.4.8..
ICE-15 USFWS 11/14/2012 “Previous modeling efforts using ICECAL, SNTEMP, and DYRESM
are mentioned. It would be appropriate to comment more on: the
key findings resulting from the application of these models (will
these findings help guide the current study?); their data needs (are
Added detail on key findings of the modeling to the study plan
(Section 7.6.2.1), and expanded on the limitations of the model.
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they similar or very different than current needs?); and, their
limitations (what limitations are we overcoming with the proposed
model(s)?).” –pdf page 33
ICE-16 USFWS 11/14/2012 “In section 5.10.2.2, the PSP states that additional data needs are
driven by: “1) the new proposed configuration of the Project and
project operational scenarios; 2) advances in predictive models of
winter flow regimes beyond what was available in the 1980s; and
3) the need to supplement previously documented observations of
natural ice processes.” The first and second factors imply that post
project configurations, operation scenarios, and model data
requirements will drive data needs. The PSP would benefit from
outlining how data needs for these factors may be different or
similar to those for the 1980s studies. Also, how portions of the
1980s data may be useful for the current study. The last factor may
require clarification as it seems to read as “additional data needs
are driven by the need for additional data”.” –pdf pages 33-34
The RSP includes additional detail on how the 1980’s project
configuration was different and had some different issues (i.e., the
reregulation dam and non-fluctuating flow releases made it less
important to have winter flow routing and unsteady ice modeling).
Additional detail about 1980s data that is relevant to this study has
been added to Section 7.6.2.1. The last factor was revised to
provide more detail (section 7.6.2.2)
ICE-17 USFWS 11/14/2012 “Towards the end of section 5.10.2.2, a fourth factor driving data
needs is suggested. That is, changes in channel geometry may
make certain observations from the 1980s not applicable to current
conditions (e.g. locations of ice bridging, open water leads, and ice
jams). Also, that the location of the frazil production varied
significantly between study years. We suggest that the study team
provide more discussion on how the data may be used for the
current study, in spite of changes in channel geometry, and
temperature variability between study years. And caution against
dismissing 1980s data due to changes in channel geometry and
annual climate variations.” –pdf page 34
Relevance of the 1980s data is detailed in Section 7.6.2.2. AEA
does not intend to dismiss the 1980s data; the 1980s data will be
appropriately incorporated into the analysis.
ICE-18 USFWS 11/14/2012 “The last paragraph of section 5.10.2.2, “Finally, updated ice
processes information is needed by the fisheries, instream flow,
instream flow riparian, fluvial geomorphology and groundwater
studies” requires further clarification on how it pertains to additional
information needs.” –pdf page 34
The relationship between ice processes and other resource areas is
detailed in Section 7.6.7.
ICE-19 USFWS 11/14/2012 The use of one model to carry out both flow routing and ice The RSP has been updated to specify that River1D will be used to
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processes is recommended due to the interaction between the flow
routing and ice processes. CRISSP1D can be used to carry out
this modeling but should be calibrated for its flow routing functions
under open water conditions before ice effects are introduced.
Consideration should be given to using the winter flow model to
model flows, water levels, and water temperature for the entire
year. –pdf page 34
model ice processes as well as winter temperature and winter flow
routing. River 1D will be calibrated to open-water conditions prior to
applying an ice cover. See section 7.6.4.6
ICE-20 USFWS 11/14/2012 Hourly time-steps are feasible with CRISSP1D and even desirable
from the ice process modeling perspective die to the diurnal
fluctuations in air temperature. –pdf page 34
River 1D can be run using an hourly time step or smaller, if
necessary for model stability (Section 7.6.4.6).
ICE-21 USFWS 11/14/2012 A1-D model will not be able to simulate the effects of open leads if
they occupy only part of a channel width. –pdf page 34
The mainstem River 1-D model will not simulate open leads within
the ice cover. These may be simulated using River2D at Focus
Areas if that detail is determined to be needed at the particular
Focus Area.
ICE-22 USFWS 11/14/2012 In some instances, it may be appropriate to extend the1-Dmodel
results with very judicious application to address 2-D problems. –
pdf page 34
AEA agrees with this comment. The extension of 1D mainstem flow
routing model results, such as ice thickness or water surface
elevations, to 2-D areas such as sloughs may be warranted, but the
application of the model in these areas will be determined on a
case-by-case basis by the modeling experts when the input data is
available and the open-water model has been calibrated (7.6.4.8).
ICE-23 USFWS 11/14/2012 No mention is made of modeling the reservoir and upstream
tributaries. –pdf page 34
The Water Quality Modeling Study (Section 5.6) includes the
reservoir ice model.
ICE-24 USFWS 11/14/2012 It is important to model the thermal regime of the reservoir area. –
pdf page 34
The Water Quality Modeling Study (Section 5.6) includes the
reservoir thermal and ice model.
ICE-25 USFWS 11/14/2012 “The PSP proposes to collect a variety of winter measurements to
assist in the calibration of the winter flow routing model. Comments
on the ability of this data to meet the study objective to develop a
calibrated flow routing model are:
1. Generally the data collection approach is appropriate to meet the
objectives.
Suggested measurements, including total and submerged ice
thickness and frazil slush thickness, have been added to Section
7.6.4.3. In places, the velocity profile may be more easily measured
with current meter methods rather than an ADCP, but the decision
will be made in the field based upon site-specific conditions.
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2. Winter flow measurements should record total and submerged
ice thickness and frazil slush thickness, both to assist in the
roughness calibration and to provide calibration data for the ice
processes.
3. Consideration should be given to collecting vertical velocity
profiles using an ADCP as part of the discharge measurements.
This can improve accuracy of winter flow measurement and
provides additional information to determine under-ice roughness.
This may also facilitate 2-D model calibrations.” –pdf pages 34-35
ICE-26 USFWS 11/14/2012 “An effective data collection program is essential for providing the
data necessary to support development, calibration, and
application of the adopted model. A well-defined data collection
program is warranted since a significant amount of resources are
required to meet data needs and a lack of sufficient data may
impact project schedule. The following discussion points are
offered for consideration when drafting the revised PSP. The PSP
puts emphasis on “what” data needs to be collected. While this is a
critically important and potentially challenging task, it may prove to
be more challenging to: determine how to collect data, where to
collect it, and how often. The planning effort required to execute a
successful field data collection program should not be undervalued.
The field program should recognize that there may be some site-
specific logistical challenges that may only be learned through
experience. An improved understanding of the ice regime is
expected as the team observes and collects data. This improved
understanding may bring new insights into the data collection
needs and the field program may require modification. It may be
challenging to determine appropriate focus sites prior to gaining an
understanding of the ice regime. Additional input from other study
teams may impact the number and location of focus sites. Further,
data needs for a particular focus site may extend some distance
upstream and/or downstream from the local area.” –pdf page 35
The RSP acknowledges that conditions may be challenging and
leaves flexibility to use alternative methods where needed (Section
7.6.4.4). Focus Area selection will be based on an understanding of
the ice regime utilizing five years of detailed 1980s data as well as
that collected in 2012.
ICE-27 USFWS 11/14/2012 “The PSP would benefit from a plan outline of the proposed data
collection program. The above considerations do not represent a
The RSP includes more detail on data collection, and more detail on
the Lower River study (section 7.6.4.10).
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comprehensive list to be addressed by the plan. While they should
be considered, the primary intent is to illustrate the need for such a
plan. The extent of the modeled study area should be confirmed
with the other discipline leads. It should be sufficient to adequately
capture ice processes within the reaches of interest. For example,
the effects of uncertainty on boundary conditions should be
minimized through the reach of interest. The PSP acknowledges
that “there are currently no accepted models for predicting dynamic
ice processes on complex braided channels, such as those found
in the Lower Susitna River”… “and therefore modeling will not be
planned for a significant portion of the study reach”. The PSP
should address how impacts of the project will be assessed
through portions of the study reach that cannot be simulated by the
adopted model(s). This may be included as part of the overall
assessment framework, as suggested previously.” –pdf page 35
The modeled study area for the River1D model is bounded by the
dam site upstream and the Chulitna confluence downstream. To
extend the model further downstream would require greatly
simplifying the channel geometry. The detailed models, however,
will extend upstream and downstream from the Focus Areas as
necessary to reduce the influence of boundary condition
assumptions (Section 7.6.4.8).
ICE-28 USFWS 11/14/2012 “The PSP suggests that the ice process models “will be calibrated
to the range of observed conditions”. It is recommended that the
PSP discuss how the model will be applied outside the range of
observed conditions. Also, will there be some form of model
verification, or assessment? This discussion may relate to the
benefit of applying a physically-based ice process model.
Experience and specialized expertise may be required to justify
application of the model outside the range of observed conditions.”
–pdf page 36
A model can only be calibrated to observed conditions, by definition.
The process of model verification and error analysis is presented in
Section 7.6.4.9. The model must be applied outside of the range of
observed conditions in order to evaluate effects of the Project, since
the Project currently does not exist. The model will be developed
under the guidance of people who have several decades of
specialized experience developing the model and applying it to
regulated ice-covered rivers.
ICE-29 USFWS 11/14/2012 “The PSP should describe how quantitative predictions of the
following (for mild, moderate, and cold climate scenarios), will meet
the information requirements of the other studies:
• “extent and elevation of ice cover downstream of the
dam”
• “ice-cover progression”, and
• “timing of breakup”.
–pdf page 36
The study results regarding the winter hydraulic conditions specified
in the comment will be used by other studies as outlined in Section
7.6.7, Relationship with Other Studies.
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ICE-30 USFWS 11/14/2012 “AEA’s fourth ice processes objective proposes various Project
operational scenarios on ice processes downstream of the Watana
Dam. This should also include the determination of the ice
processes models to provide adequate data to the winter hydraulic
flow routing to determine the effects of project operational
scenarios on instream flows (timing, quantity, and quality)
downstream of Watana Dam. An error analysis on the ice process
models is necessary, because the model will be used to
extrapolate the project operational flow and temperature conditions
well outside of the natural regime. Also, the ice process model
results will be used to populate operation scenarios (including load
following fluctuations and higher than natural winter flows) for the
winter hydraulic flow routing model which will also be calibrated
under the natural flow regime which consists of stable winter
flows.” –pdf page 36
The ice processes model (River1D) will provide winter flow routing
data and winter water temperatures downstream of the dam
(Section 7.6.4.6). The error analysis to be performed is described in
Section 7.6.4.9.
ICE-31 USFWS 11/14/2012 “As requested above, an understanding of the limitations of the
models and results is necessary to determine if they are applicable
to assessing project effects on fish and their habitat. An error
analysis of the models and results is necessary to examine the
extrapolated results from the ice processes model and in the winter
hydraulic flow routing model to inform whether a true
understanding of winter operations effects is achieved.” –pdf page
36
An error analysis to be completed along with the ice processes
modeling has been added to the Section 7.6.4.9.
ICE-32 USFWS 11/14/2012 “The ice processes model will be calibrated by one to two winters
of data collection under the natural flow regime. The model then
will be used to determine the open water reaches, ice thickness,
and timing and distribution of ice development under project
conditions. As currently proposed the flow regime during the ice
period (ice up to break-up) will be highly variable and much higher
than the natural flow regime requiring extrapolation of the
calibrated model. It is unknown whether the calibrated model be
able to assess how load following operations will influence ice
processes (destabilization of developing ice, ice jam formations,
flooding, etc.) in comparison to the typically stable ice cover during
winter (as discussed in She et al. 2011). An understanding of the
See AEA’s response to comment ICE-28.
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selected ice processes model’s ability to predict ice development
and characteristics with the project operations and the uncertainty
associated with these predictions is necessary to determine if the
winter operations can be analyzed with respect to impact on fish
and their habitat.” –pdf page 37
ICE-33 USFWS 11/14/2012 “The primary role of the ice process study is to provide ice
processes information and effects analysis to other studies.
Changes to ice processes, including the changes of timing and ice
extent and thickness may alter many of the other riverine
processes such as geomorphologic processes, groundwater
exchange, water quality, and instream flow. The resulting modeling
results of post-Project ice processes will be limited in providing
analysis to the fisheries, instream flow, geomorphology, water
quality, and groundwater studies; this limitation must be described.”
–pdf page 37
The limitations of the ice model are described in Section 7.6.4.8.
The combined field, modeling, and research study is designed to
provide adequate data to meet the requirements of the listed studies
for winter hydraulic information. Each of these studies will be
undertaking additional fieldwork and analysis in order to determine
project effects to their resources during the winter period.
ICE-34 USFWS 11/14/2012 “The PSP clearly indicates a need for integration. The PSP does
not explicitly define a plan for informing and integrating with the
other studies. While the importance for integration may be implied
within the various individual PSPs, the project would benefit if there
was a clear plan describing the strategies for information exchange
and integration between the various studies. This plan should
discuss how the model results will be documented and how the
information will be provided in a format that is clear and accessible
to the other studies. The plan should acknowledge the potential
challenges that may be encountered and strategies for dealing with
these challenges.” –pdf page 37
The Relationship with Other Studies Section 7.6.7 describes how
information will be transferred to other studies, and what information
will be used by the Ice Processes in the Susitna River Study from
other studies.
ICE-35 USFWS 11/14/2012 In the Geomorphology (AEA 2012, 5.9.4.2.2.4) proposed study
plan the applicant describes the interaction between the
geomorphology studies and the ice processes study. But in the ice
processes study plan there is no description of simulating the
effects of surges from ice jam breakup; or simulating the effect of
channel blockage (which would likely require two-dimensional ice
process modeling); or the ability of the ice processes modeling and
winter hydraulic flow routing to provide adequate data to populate
River1D and River2D can assess channel blockages and simulate
surges from ice jam flood releases (7.6.4.8). The potential for
applying these capabilities in support of other studies has been
added to Section 7.6.7 on Relationships with Other Studies. These
are the key processes that the Geomorphology Study requires from
the winter conditions hydraulic models as these processes may play
an important role in the creation and/or maintenance of the off-
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the 2-D geomorphic models during winter conditions. –pdf page 37 channel habitats.
ICE-36 NMFS 11/14/2012 “In the proposed Geomorphology (AEA 2012, 5.9.4.2.2.4) study
plan, the applicant describes the interaction between the
geomorphology studies and the ice processes. But in the ice
processes study plan there is no description of simulating the
effects of surges from ice jam breakup or simulating the effect of
channel blockage (which would likely require two-dimensional ice
process modeling); nor does the PSP describe the ability of the ice
processes modeling and winter hydraulic flow routing to provide
adequate data to populate the2-D geomorphic models during
winter conditions.” –pdf page 49
See AEA’s response to comment ICE-35.
ICE-37 NMFS 11/14/2012 “The revised study plan should include a detailed study frame
work; such a frame work is not apparent either in the proposed
study plan document or as a result of workgroup meetings with
AEA. –pdf page 47
The methodologies described in the RSP meet the goals and
objectives of the study, and will provide physical process data to
other studies, as described in Section 7.6.7, Relationship with Other
Studies.
ICE-38 NMFS 11/14/2012 During the August 17,2012 TWG meetings, the applicant described
two potential ice processes models, but no description of the data
necessary to populate, calibrate and validate the models was
provided. The models and necessary data for implementation
should be compared with a description of how they will achieve
NMFS's study objectives. –pdf page 47
The RSP includes a description of the chosen model, River1D (see
Section 7.6.4.6), and the necessary input and calibration data
(Sections 7.6.4.1 and 7.6.4.3).
ICE-39 NMFS 11/14/2012 Also not discussed was the ability for the models to extrapolate to
proposed winter operational flow conditions well outside the natural
flow regime to understand the effects of the project, necessary for
accurate assessment of project operation impacts on riverine
processes that are important to fish and their habitat. –pdf page 47
See AEA’s response to comment ICE-28.
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ICE-40 NMFS 11/14/2012 Regardless of the modeling method hydraulic routing and accurate
determination of discharge under ice cover requires direct
measurement. Because ice thickness and roughness will greatly
influence the stage-discharge relationships, winter discharge
measurements are needed at each of the routing cross-sections.
We request a detailed description of the minimum number and
locations of discharge measurements to be taken during winter to
populate and calibrate the winter hydraulic flow routing model and
to be used by the winter ice process model.” –pdf page 47
See AEA’s response to comment ICE-11.
ICE-41 NMFS 11/14/2012 Although the winter hydraulic flow routing model is discussed under
the instream flow study plan and the model results are needed by
this and other studies, no detailed data collection for the winter
hydraulic flow routing is described. The data necessary to
adequately calibrate and test the models must be described. –pdf
page 48
See AEA’s responses to comments ICE-09 and ICE-14.
ICE-42 NMFS 11/14/2012 “NMFS requests an analysis of the hydraulic flow routing and ice
process model's abilities to assess project effects under the
proposed project operations; the PSP does not provide for this
analysis. Specifically, we want to know if the model will have the
ability to assess hydraulic flow routing and ice process effects at a
scale relevant to fish and their habitat. What can be determined
from the proposed study? –pdf page 48
See AEA’s responses to comments ICE-09 and ICE-14.
ICE-43 NMFS 11/14/2012 How will uncertainty be determined from the study and modeling
results? If the currently proposed ice process models and the
winter hydraulic flow routing models are not sufficient to
understand the project effects on anadromous fish and their
habitat, additional information must be provided. Two-dimensional
ice process models at key habitats may be necessary to
understand project operation effects on overwintering fish. There is
a strong potential that the winter physical processes models (winter
hydraulic flow routing, ice processes, groundwater, and water
quality models) will have large uncertainty; also it is likely that a
true understanding of fish habitat utilization will not be available
with only two winters of fish surveys and studies. The combined
See Section 7.6.4.9 on determination of model uncertainty for the
Ice Processes Model. The selection of modeling methods and
determination of detailed data input needs at Focus Areas will be
done with the goal of minimizing error so that the modeling effort will
provide the most relevant information possible to determining effects
to fish habitat. The error analysis will be incorporated into the
Instream Flow Study (Section 8.5) along with initial model results.
Where the scale of the mainstem River1D model is insufficient to
determine effects to fish habitat, the River1D model will provide
boundary conditions for more detailed Focus Area models, which
will be River1D or River2D models as appropriate for the local
conditions. These models will be based on more detailed geometry
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 129 December 2012
Ice Processes in the Susitna River Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
limitations of the physical processes and fish studies may present a
difficult situation for the agencies to make recommendations to
make protection, minimization, and enhancement
recommendations. Without adequate knowledge of project affects,
NMFS will require the project to operate along the natural flow
regime; this would result in recommendations that require
operations at stable winter flows.” –pdf page 48
and more intensive measurements, thus model error will be
reduced. The Instream Flow Study (Section 8.5) discusses how
model results will be used in conjunction with observations to assess
impacts to fish habitat.
ICE-44 NMFS 11/14/2012 “NMFS believes the proposed study plan for ice processes is
incomplete; additional detail is necessary to understand if the study
plans adequately address our study requests. This additional detail
should include a schedule and methods for attaining ice processes
data necessary for model calibration and instream flow data
necessary for calibration of the winter hydraulic flow routing model.
If this information is provided by another study, it must be explicitly
described in the other study plan and referenced. Also, this study
should explain how the models and data collected in this study will
be used to assess project effects on anadromous fish species. The
study plan must include a schedule to collect necessary data, to
prepare the model, and provide analysis; additionally, the plan
should have the flexibility to extend the studies if the data and
modeling products are not sufficient for NMFS to analyze winter
operation effects on anadromous fish.” –pdf page 48
The RSP has been updated with methods for collecting calibration
data (Section 7.6.4.1 - 7.6.4.4) and a schedule (Section 7.6.7). The
data necessary for calibrating the winter flow routing model includes
the winter discharge measurements and ice thickness data.
This study will provide observations and hydraulic data to the
Instream Flow Study and fisheries studies. Details on how these
data will be used to determine effects on anadromous fish can be
found in the Instream Flow Study, Section 8.5.
ICE-45 NMFS 11/14/2012 “The modeling approach must include a discussion of the selected
model limitations and the limitations of the winter hydraulic flow
routing models, necessary to put the model results into context. –
pdf page 48
See AEA’s response to comment ICE-31.
ICE-46 NMFS 11/14/2012 The calibrated ice processes model review should include an
assessment of the model's ability to predict changes in ice
processes under the project operations at a scale relevant to fish
and their habitat. Also, if the winter hydraulic routing model and the
ice process models are not adequate to assess impacts to fish and
their habitat, a more detailed two-dimensional approach may be
necessary to conduct the winter analysis in the instream flow
As discussed in Section 7.6.4.8, more detailed modeling will be
performed at Focus Areas using either a detailed River 1D model or
a River 2D model, depending on the local hydraulics. This is to
ensure that hydraulic results are at a scale applicable to fish habitat
studies. The spatial detail will be the same as that used in the open-
water models for these areas.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 130 December 2012
Ice Processes in the Susitna River Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
study.” –pdf page 48
ICE-47 NMFS 11/14/2012 "The number of discharge measurements and location of discharge
measurement to develop and calibrate the winter hydraulic flow
routing model is not well described."-pdf page 66
See AEA’s response to comment ICE-10.
ICE-48 NMFS 11/14/2012 "Winter hydraulic flow routing will rely on the ice processes study to
incorporate changes to ice cover with project; a detailed description
of how that data will be provided and incorporated into the
hydraulic flow routing analysis is needed." -pdf page 66
The ice processes model will handle winter hydraulic flow routing.
The model input and calibration data are described in Section
7.6.4.6 and 7.6.4.7 and in the Instream Flow Study Section
8.5.4.3.1.
ICE-49 NMFS 11/14/2012 "Model sensitivities, assumptions and limitations should be
thoroughly described so that a clear understanding of how likely
the results reflect reality can be applied in developing conservation
recommendations." -pdf page 66
See AEA’s response to comment ICE-28.
ICE-50 NMFS 11/14/2012 "The winter hydraulic flow routing will also incorporate a water
quality component that will project downstream changes to flow
(timing, quantity, and water quality)." -pdf page 66
See AEA’s response to comment ICE-30.
ICE-51 Various
Individuals
11/09/2012 (paraphrased): Fluctuating flows would make river ice unstable,
making travel dangerous, or even impossible, for both humans
(snowmachine, dogsled or ski) and animals (moose and caribou).
One of the primary objectives of the Ice Processes in the Susitna
River Study is to predict whether proposed project operations would
destabilize the winter ice cover, and where the winter ice cover
would be affected. The results of this study will be used by the
transportation and recreation studies to determine the effects of the
project on winter travel on the Susitna River.
ICE-52 Okenok,
Brian
11/13/2012 How will flow rates effect the winter ice conditions on the river? Will
traditional winter travel on the ice of the river still be possible? –pdf
page 1
See AEA’s response to comment ICE-51.
ICE-53 Wood, Ruth 11/15/2012 Winter impacts need to be measured from the source to the mouth,
and that includes the tributaries that flow into the Susitna. The
Yentna River is a massive winter-recreation river that joins with the
Susitna. Will the river freeze or run free in the winter? Will the ice
be solid or unsafe shelf ice? What are the impacts on various load-
following scenarios? –pdf page 1
The Ice Processes in the Susitna River Study area includes the
Lower and Middle Rivers and the Upper River to the Oshetna
confluence. The impacts of the project to ice cover on the major
tributaries (Yentna, Chulitna, and Talkeetna Rivers) will be
considered in the analysis. The objectives of the Ice Processes in
the Susitna River Study is to determine changes in river ice extent
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 131 December 2012
Ice Processes in the Susitna River Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
and stability under project scenarios, including load-following.
ICE-54 Wolf, Ellen 11/15/2012 Will the proposed studies be able to confidently predict the effect of
fluctuation river levels on winter ice? –pdf page 1
One of the primary objectives of the Ice Processes in the Susitna
River Study is to predict whether proposed project operations would
destabilize the winter ice cover. This will be accomplished by
developing a River1D model of the Middle River. This method of
modeling ice-covered rivers was developed in part to determine the
effects of load-following on ice cover, and the model of the Susitna
River will be developed under the guidance of leading experts in the
field. The error in the model will be determined using the error
analysis methods outlined in Section 7.6.4.8.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 132 December 2012
Glacier and Runoff Changes Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
GLAC-01 TU 11/14/2012 “The Proposed Study Plan needs to evaluate the changes to water
availability, both in quantity and timing, that is likely to occur from
climate change, and evaluate how operation of the dam under those
new future conditions are likely to impact fish, wildlife and water
resources.” –page 4
See AEA’s response to comments GLAC-4, GLAC-16,
and GLAC-17.
GLAC-02 CWA 11/14/2012 Failure to address the potential additive effects of climate change on
the inherent impacts of the Project on streamflows, aquatic habitat and
riparian and subsistence resources. -pdf page 7
See AEA’s response to comment GLAC-4, GLAC-16,
and, GLAC-17.
GLAC-03 CSDA 11/14/2012 The Glacial and Runoff study does not fulfill the need for climate
change studies to determine a responsible comprehensive decision
regarding project impacts. –page 7-8
See AEA’s response to comment GLAC-4, GLAC-16,
and, GLAC-17.
GLAC-04 Various Individuals 11/13/2012 The Glacial and Runoff Changes Study will consider the future
water quantity and sediment quantity in the proposed reservoir from
future glacier melt and wasting. But this is not enough. Another aspect
of climate change that must be considered is how the project itself will
change the climate of the project area. How will the creation of a large
artificial lake and the changed downstream flows affect local climate?
AEA is not proposing this scope of study. While the
proposed reservoir may have minor influences on air
temperatures and humidity in its immediate vicinity
until ice over, any Project-related adverse effects are
expected to be insignificant. Moreover, the requesters
have made no effort to comply with the study request
content requirements of 18 CFR 5.9(b) and provide no
support for their speculation that the extremely
localized microclimatic influences have any potential to
be significant or adverse.
GLAC-05 TCCI 11/07/2012 TCCI requests that AEA and FERC reconsider the study requests for
climate change studies. -pdf page 6
See AEA’s response to comment GLAC-4, GLAC-16,
and, GLAC-17.
GLAC-06 CCA 11/14/2012 “Climate change in the dam area from the creation of a massive man-
made lake: Certainly a relatively still, large body of water will change
local climate. Will this change adversely affect wildlife, fish, and flora?
Also, would the regulated water flow downriver influence local
climate?” -pdf page 1 third paragraph
See AEA’s response to comment GLAC-4, GLAC-16,
and, GLAC-17.
GLAC-07 ADNR-DGGS 11/14/2012 Page 5-147 P3 in PSP section 5.11.1.1 “While this is generally true
there are situations where positive glacier net balance can be
concurrent with higher water flows. For example, consider a winter of
heavy snow that is followed by a summer with a lot of melting, but not
enough melting to get rid of all the snow. Mass balance would be
positive at the same time as there are high water flows.” –pdf page 13
AEA agrees with this comment. Section 7.7.1 was not
intended to imply that high flows could only occur
during years that there is negative mass balance for
the glacier; it only states that glaciers tend to buffer
annual variations in precipitation.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 133 December 2012
Glacier and Runoff Changes Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
GLAC-08 ADNR-DGGS 11/14/2012 Page 5-148 P2 in PSP section 5.11.2.1 “Definition of 'recent period' in
this context would be helpful. Accepted formal terminology prefers
'Holocene' to 'Recent' if the geologic timescale is being referenced
here. If 'recent' refers simply to 'having happened, begun, or been
done not long ago or not long before,' the use of 'period' after 'recent'
confuses the intent because it implies the more-formal terminology.
Suggest either using 'Holocene' or else more specifically defining the
amount of time encompassed by 'recent' in this context (e.g., 'during
the past xxx years'). “ –pdf page 13
Section 7.7.2.1 has been changed to refer to “recent
decades.”
GLAC-09 ADNR-DGGS 11/14/2012 Page 5-148 P2 in PSP section 5.11.2.1 “Reference needed for
statement ‘Alaska glaciers with the most rapid loss are those
terminating in sea water or lakes.’ “ –pdf page 13
Section 7.7.2.1 cites to Markon et al, 2012 as support
for this statement.
GLAC-10 ADNR-DGGS 11/14/2012 Page 5-149 P1 in PSP section 5.11.2.3 “Is it relevant to include
mention of a predicted longer growing season in this section? If so,
consider explaining how this is relevant to the research question. “ –
pdf page 13
This sentence is not included in the Glacier and Runoff
Changes Study Plan.
GLAC-11 ADNR-DGGS 11/14/2012 Page 5-159 13 Fig. 5.11-1 in PSP section 5.11.9 “A directional arrow
or statement of direction of view shown in photo would be helpful,
especially since the caption includes reference to 'western end' of the
lake.” –pdf page 13
A direction (northeast) is included in the caption of
RSP Figure 7.7-1.
GLAC-12 ADNR-DGGS 11/14/2012 Page 5-160 14 Fig. 5.11-3 in PSP section 5.11.9 “Suggest labeling
Susitna Glacier “ –pdf page 13
RSP Figure 7.7-3 includes labels for Susitna Glacier,
West Fork Glacier, and East Fork Glacier.
GLAC-13 ADNR-DGGS 11/14/2012 Page 5-161 15 Fig. 5.11-5 in PSP section 5.11.9 “Caption should read
‘Mean annual temperature and total annual precipitation at
Talkeetna…’" –pdf page 13
The caption for RSP Figure 7.7-5 reads “Mean annual
temperature and total annual precipitation at
Talkeetna…”
GLAC-14 TNC 11/14/2012 “Climate change effects will change the Susitna Basin in the next 50
years and could have dramatic effects over the full life of the proposed
project. The draft RSP on Glacier and Runoff Changes (7.7) is limited
to the upper Susitna Basin. AEA must study the entire basin to
understand anticipated changes to water flow (including quantity and
timing from precipitation and glaciers) throughout the basin. AEA
claims that the upper river only contributes 17% of total flow at the
mouth, but without understanding how flows will change across the
basin, we cannot understand how the proposed project will affect the
Middle and Lower river over the life of the project. This study should
See AEA’s response to Comment GLAC-1, GLAC-16,
and GLAC-17.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 134 December 2012
Glacier and Runoff Changes Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
provide information to the instream flow and geomorphology studies
on expected changes overall to hydrological flows and sediment input
to all reaches of the Susitna River. The effects of climate change on
glacial melt, snow pack, precipitation, and sediment load should be
studied. These effects throughout the basin, not just the upper Susitna
watershed, must be included to understand how the cumulative
impacts of the dam and climate change will affect flows and sediment
transport throughout the Susitna River.” –pdf page 2
GLAC-15 CIRI 11/14/2012 “CIRI supports AEA's proposed Glacial and Runoff Changes Study as
an appropriate response to the climate change phenomenon and as a
means of securing information the Commission may be able to use in
its NEPA analysis.” –pdf page 7
AEA appreciates CIRI’s comment related to this
proposed study.
GLAC-16 USFWS
NMFS
11/14/2012
11/14/2012 “FERC has also recognized that when, as is true in for this project,
reasonable projections of a range of likely temperature changes are
available, projections of future climate and analyses related to future
reservoir levels and river flows should include a reasonable spectrum
of climate change impacts. As FERC concluded in the study
determination for the Toledo Bend Hydroelectric Project (FERC P-
2305-020) such analyses are needed in order to reach informed
judgments about likely project impacts on aquatic resources
downstream of the project and on recreational resources in and
around the reservoir.”
“FERC likewise determined in the Lake Powell Hydropower and
Pipeline Project, that climate change effects on existing and future
water supplies should be addressed as the availability of water for the
pipeline would affect the ability of the Project to supply water and
generate hydroelectric power. As with the Lake Powell project, the
availability of water supply is directly related to this Project’s purpose.”
–pdf pages 40-41 (USFWS)
AEA does not believe that FERC’s study plan
determinations for the relicensing of the Toledo Bend
Project or the initial licensing of the Lake Powell
Pipeline Project support USFWS’s and NMFS’s
request for a comprehensive study of Susitna River
Project effects under changing climate. To the
contrary, FERC’s study plan determinations for these
projects support AEA’s view that the comprehensive
climate study proposed by USFWS and NMFS does
not meet study criterion 5.9(b)(5) of FERC’s ILP
regulations, 18 C.F.R 5.9(b)(5), which requires a nexus
between project operation and effects on the resource
to be studied, and an explanation on how study results
will inform license requirements.
In the relicensing of the Toledo Bend Project, FERC
rejected a proposed study on the effects of climate
change on basin hydrology. FERC stated: “We are
not aware of any climate change models that are
known to have the accuracy that would be needed to
predict the degree of specific resource impacts and
serve as the basis for informing license conditions.
The potential consequences of climate change can be
effectively monitored using conventional hydrologic
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 135 December 2012
Glacier and Runoff Changes Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
studies and monitoring techniques. For these reasons
and those expressed by the [license applicant], we do
not adopt this requested study.” Study Plan
Determination for the Toledo Bend Project, P-2305-
020 (issued Aug. 6, 2009).
Similarly, in its study plan determination for the Lake
Powell Pipeline Project, FERC stated that it “was
unaware of any climate change models that are fine-
tuned enough to make reservoir operation decisions.”
Study Plan Determination for the Lake Powell Pipeline
Project, P-12966-001 (issued Jan. 21, 2009).
In the Lake Powell Pipeline Project licensing, FERC
did approve the applicant’s proposed study plan to
assess potential effects of water supply on the
proposed project, including estimates of how climate
change and climate variability would affect project
operations and water deliveries. This is essentially the
same approach AEA proposes in this proceeding, i.e.,
assessing the impact of climate change on glacier
runoff into the reservoir.
For these reasons, AEA is not proposing to adopt the
request of USFWS and NMFS to conduct a more
comprehensive study of climate change that would
assess potential Project effects combined with impacts
of climate change on the Susitna watershed
ecosystem. The results of any such study would be
highly speculative and would not inform license
requirements, and AEA’s proposed study would
adequately assess effects of climate change on glacier
runoff into the reservoir.
GLAC-17 USFWS
NMFS
11/14/2012
11/14/2012 “Recent advances and applications of the science are described in
detail in our study request; see, e.g., §1.3.2 of the climate change
study request. FERC should incorporate these developments into the
The nexus between climate change and the proposed
Project is that climate change may affect the amount
and timing of runoff from glaciers into the reservoir.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 136 December 2012
Glacier and Runoff Changes Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
studies it approves, rather than dismiss them. NMFS has provided
adequate supporting science, continued climate change scientifically
accepted and continued warming is unequivocal. NMFS and the
Service request that as part of the study plan determination, FERC
order completion of our Comprehensive Study of Susitna River Project
Effects under Changing Climate Study Request, filed with FERC on
May 31, 2012 pursuant to 18 CFR Section 5.9(b).” – pdf pages 40-41
(USFWS)
The Project will reregulate the river flow so that any
impacts of climate change will be eliminated or
attenuated within the zone of Project effects. The
combined effects of climate change and Project
operations will be incorporated into the reservoir
sedimentation, downstream instream flow,
geomorphology, and other studies that address stream
flow related impacts below the dam. As explained in
AEA’s response to comment GLAC-16, this approach
is consistent with the approach being taken in other
FERC proceedings.
Moreover, AEA notes that a recent study of
consideration of climate change in over 200 federal
EIS’ shows that the approach to climate change
analysis AEA is proposing for the Susitna-Watana
Project is consistent with the practices of other federal
agencies, and AEA is aware of no other federal agency
conducting the kind of detailed, ecosystem level study
that NMFS and USFWS are suggesting should be
required here. See Woolsey, Consideration of Climate
Change in Federal EISs, 2009-2011, Ctr. For Climate
Change, Columbia Law School (July 2012).
Finally, a review of recent NMFS Biological Opinions
and other documents shows that AEA’s study proposal
is consistent with the approach NMFS is taking to
address potential impacts of climate change on
resources potentially affected by a proposed action.
AEA has not found any instance in which NMFS has
conducted a comprehensive assessment of climate
change impacts on the entire ecosystem of an affected
river basin. Rather, in some instances it has included
general climate change background information from
existing studies and, to extent it is available,
information on climate change impacts on the river or
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 137 December 2012
Glacier and Runoff Changes Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
other water bodies that host the listed species; e.g.,
timing of flows, precipitation, water temperatures. See,
e.g., (1) Draft Environmental Assessment:
Authorization for Incidental Take and Implementation
of the PacifiCorp Klamath Hydroelectric Project Interim
Operations Habitat Conservation Plan for Coho
Salmon. NOAA/NMFS, April 2011, at pp. 3-29, 5-6, 5-
9, 5-10); (2) Biological Opinion on Incidental Take
Permit to implement Klamath Hydro Project Interim
Operations HCP for Coho Salmon: NMFS, SW Region
(Feb. 22, 2012) at pp. 83-85; 129. 189-190; (3)
Biological Opinion and Essential Fish Habitat
Recommendations for U.S. Bureau of Reclamation
San Joaquin River Restoration Program: NMFS,
Southwest Region (Sept. 18, 2012) at pp. 53, 108-109;
(4) Biological Opinion and EFH Response for the
Reedsport Ocean Power Technologies 10-PoweBuoy
Wave Park; NMFS Pacific Northwest Region (June 7,
2012) at pp. 38, 54-55; (5) Impacts to Essential Fish
Habitat from Non-Fishing Activities in Alaska: NMFS
Alaska Region (Nov. 2011) passim.; (6) Biological
Opinion and Essential Fish Habitat Recommendations
for Enloe Dam Project: NMFS, Pacific Northwest
Region (Sept. 27, 2012) at p. 26.
GLAC-18 USFWS
NMFS
11/14/2012
11/14/2012 “Where NMFS differs from AEA is that NMFS seeks to expand the
climate study beyond simply the analysis of glacial retreat and flow into
the proposed reservoir, and water quality. We request expanding the
analyses to incorporate reasonably foreseeable changes in climate to
assess vulnerabilities of natural resources in the project watershed.
FERC must understand these vulnerabilities in order to determine how
anadromous fish and their habitats may be affected by the Project, and
ultimately determine if and how the Project may proceed. We suggest
use of several documented methodologies, such as Bryant, 2009, and
of using one of the many available and commonly used climate
change vulnerability assessment processes.” –pdf page 42
See AEA’s responses to comments GLAC-4, GLAC-16
and GLAC-17.
GLAC-19 USFWS 11/14/2012 “5.11.4 Study methods. NMFS and the Service appreciate that AEA The models are calibrated with in situ data and are
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 138 December 2012
Glacier and Runoff Changes Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
NMFS 11/14/2012 will consider exploring future runoff projections available from climate
models in a qualitative manner. However, the analysis of future runoff
should also be assessed quantitatively.
pdf page 44 (USFWS)
validated against glacier mass balance and river
discharge records. Section 7.7.4.4 clarifies that future
runoff is calculated in the model and will be assessed
quantitatively in this study. The use of the word
“qualitative” was meant to recognize the uncertainty
inherent to long-range climate model projections.
GLAC-20 USFWS
NMFS
11/14/2012
11/14/2012 The study also proposes to qualitatively assess the potential effects of
“climate change models.” This reference is unclear – global climate
models (GCMs) are used to simulate the past and project the future
climate and, with greenhouse gas forcing, “change,” but climate
change models don’t exist. While the glacial study plan does include
an analysis of stream flow based on climate projections, it is not clear
how this is being conceptualized. The revised study plan should define
what is meant by “future runoff projections” as compared to “climate
change models.” On page 5-153, the PSP mentions, “This will include
no change from current conditions, continuation of current warming
trends, and adherence to various climatological scenarios such as
SNAP (2011).” “Climatological scenarios such as SNAP” appears to
refer to several downscaled climate projections based on the global
climate models, but this needs clarification.
It is unclear what is meant in the PSP by a “qualitative analysis.” pdf
page 44
See AEA’s response to Comment GLAC-19.
GLAC-21 USFWS
NMFS
11/14/2012
11/14/2012 “Calling out the ECHAM5 model separately from SNAP is unclear –
ECHAM5 is a global climate model with a large spatial scale not well
suited for application at the sub-watershed level as in this Project. A 3-
hour time step is mentioned, but this would also be at the large spatial
scale of global climate models, ~1.9°x1.9° (about 210 km) in the case
of ECHAM5. Daily projections from SNAP would be at a 2 km
resolution downscaled from global climate models, including
ECHAM5. This would be a useful level of resolution for use in this
project. It is possible that the climate scientists plan to use simulations
of these models of the past (e.g., since 1960 is mentioned) but the
explanation of the methods is confusing and needs to be better
articulated. Further on, the PSP states that “Future simulations will be
forced by a suite of downscaled IPCC AR4 projection scenarios and, if
As explained in Section 7.7.4.2, AEA is planning to use
the five-model SNAP composite projection scenarios to
force future hydrologic simulations. AEA plans to
update these simulations with improved downscaled
climate model projections if available (e.g., from IPCC
AR5).
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 139 December 2012
Glacier and Runoff Changes Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
available, the newer AR5 simulations.” This does not appear to be
different from the 5-model SNAP composite. An accurate explanation
of the methods is needed in order for NMFS and the Service to
understand, and FERC to determine, whether these methods are
appropriate for gathering the information necessary to develop a
license application.” –pdf page 45
GLAC-22 USFWS
NMFS
11/14/2012
11/14/2012 “NMFS and the Service support the methods selected for analysis of
change in stream flow on annual and seasonal basis. But we
recommend clarification on how analysis at “single event timescales”
could be completed. Perhaps this is an analysis of extremes in the
downscaled data. More detail on methods is needed as NMFS climate
scientists are unaware of how such an analysis could be made and the
PSP does not explain the methodology.” –pdf page 45
Analysis at “single event timescales” was in reference
to model runs over the period from 1960 to present.
This is clarified in the text in Section 7.7.4.2.
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IFS-001 NMFS 11/14/2012 "The study plan should describe the ability to assess
the full distribution of fish and the uncertainty of their
habitat utilization, the criteria that influence their
selection of habitat, and then understand the
relationship between flow and the specific criteria to
discuss how models will be combined to predict
change in habitat availability, both temporal and spatial
with respects to quantity and quality." Each component
of the 10-component framework (outlined in the NMFS
Study Request) needs to be incorporated into the study
plan and integrated into analyses of project operations:
flow routing, water quality, geomorphology, riparian
function, surface-groundwater interactions, ice
processes, habitat modeling, habitat connectivity,
climate and biological cues.-pdf pages 71-72
Studies of the distribution of habitat types are described in the Aquatic
Habitat Characterization Study (Section 9.9), while studies to determine the
spatial and temporal distribution of fish are described in the Fish
Distribution and Abundance in the Middle and Lower River Study (Section
9.6). The IFS Analytical Framework (see Section 8.5.4.1) is designed to
integrate study and model results of riverine processes such as water
quality, geomorphology, riparian functions, groundwater, and ice processes
to assess the temporal and spatial relationships between riverine and
biological functions. Components of the IFS framework include flow routing
(Section 8.5.4.3), operations modeling (Section 8.5.4.3.2), habitat modeling
(Section 8.5.4.6), habitat connectivity (Section 8.5.4.6.1.2.3) and climate
and biological cues (Section 8.5.4.5.1.3).
IFS-002 NMFS 11/14/2012 "We request a flow operations analysis that will
consists of a range of conditions from baseline (no
project/natural hydrograph) to various proposed
scenarios (as described in the PAD), and alternatives
suggested by the applicant and agencies in a working
group setting. The outlined alternative operating
scenarios will require consensus between the applicant
and agencies." -pdf pages 72-73.
The flow operations modeling (see Section 8.5.4.3.2) is designed to
evaluate a range of conditions including baseline (no project/natural
hydrograph), a maximum load-following, an intermediate load-following,
and a base-load scenario. The three with-Project scenarios will provide
bookends and an intermediate assessment of potential Project effects.
IFS-003 NMFS 11/14/2012 “As instream flow and habitat structure (timing,
quantity, and quality) are the controlling variables for
fish and their habitat in the project area, we request
that integration of the analysis of project effects on
riverine processes be conducted in the Instream Flow
Study. 1bis is described in our second objective,
"Identify, characterize, and quantify the seasonal and
spatial distribution of all fish species and life-stages of
each species within the defined habitat delineations of
the Susitna River floodplain."” –pdf page 75
As described in Section 8.5.4.1, the IFS Analytical Framework integrates
the analysis of Project effects on riverine processes. Project effects on
geomorphology, ice processes, water quality and groundwater/surface
water interactions will be used to quantify changes in fish and aquatic
habitat and riparian indicators (see Figure 8.5-10). The results developed
from studies conducted in modeled Focus Areas will be extrapolated to
non-modeled areas through temporal and spatial habitat analyses
described in Section 8.5.4.7 and integrated with the results of studies
conducted in other resource areas to gain a greater understanding of
overall Project effects to the Susitna River system (see Section 8.5.4.8).
IFS-004 NMFS 11/14/2012 “During the August 16,2012, TWG meetings, NMFS,
USFWS and other attendees requested a more
Additional detail is in the RSP. The study framework is described in Section
8.5.4.1, the process schedule is provided in Table 8.5-14, and a description
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detailed study frame work for all of the riverine
processes studies including the instream flow study
plan. Specifically requested was a framework that not
only lists a range of methods but addresses the
agencies objectives and information needs, and logic
for how the proposed methods would be implemented
to achieve resource agencies objectives. The
additional study plan detail requested will be used to
assess the applicant's plan and to determine if it meets
the intent of the NMFS study requests. The additional
detail should include a process schedule (timeline) and
methods for determination of habitat utilization,
abundance, and distribution information on
anadromous fish species (in this study plan and in the
fish study plan); including temporal and spatial
distribution of spawning and rearing. Each study
component should have a statement of what can be
determined, how other studies are integrated, and an
assessment of uncertainty in each study component.
Each study component should explain how confidence
intervals and calculated errors for each of the indices,
data summaries, and model outputs will be calculated.
If the study component is dependent on or supplies
information for another study, then the uncertainty
analysis must take that into context.” –pdf pages 62-63
of the temporal and spatial analyses of Project effects on aquatic habitats
is provided in 8.5.4.7. Details pertaining to fish distribution are provided in
Section 8.5.2.1.2. Integration with other studies is explained throughout the
Fish and Aquatics Instream Flow RSP and illustrated in Figures 8.5-1 and
8.5-10,
IFS-005 NMFS 11/14/2012 “In contrast to our request the applicant's goal is to
"provide quantitative indices of existing aquatic
habitats and the effects of alternate project operation
scenarios." What is actually proposed by this goal is
not clear. Although the applicant's plan may contribute
to meeting our request, and the intent may be to meet
our requests, it limits the study scope to indices of
existing aquatic habitat and effects of alternate project
operation scenarios. This falls short of resources
agencies goals and objectives because it does not
allow for the quantification of the loss of aquatic
resources and their habitats as a result of the
As explained in Section 8.5.4.1, the IFS Analytical Framework is designed
to integrate study and model results of riverine processes and to assess
the temporal and spatial relationships between riverine and biological
functions. By quantifying indicators of aquatic habitats under unregulated
and alternative operational scenarios, information will be developed as part
of the environmental analysis that will support AEA’s FERC License
Application.
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proposed project operations.” –pdf page 62
IFS-006 FERC 11/14/2012 “In section 8.5.4.1, IFS Analytical Framework, you
state that figure 8.5-11 depicts the analytical
framework of the instream flow study commencing with
the reservoir operations model that will be used to
generate alternative operational scenarios under
different hydrologic conditions. However, figure 8.5-11
does not provide a reference to the study plan that
describes the reservoir operations model. To improve
clarity of the RSP, please include in Figure 8.5-11 a
cross-reference to the section of the study plan where
you describe the reservoir operations model that will
be used to generate alternative operational scenarios.
Also, it would be helpful if you included in figure 8.5-11
a cross-reference to the section of the RSP where
hydrologic elements (e.g., representative water years,
seasonal storage & release, hourly dam releases, flood
flows) are described.” -pdf page 10
Pertinent RSP section numbers are included in the IFS analytical
framework figure (see Figure 8.5-10); the reservoir operations model is
described in Section 8.5.4.3.2, and hydrologic elements are described in
Section 8.5.4.4.
IFS-007 USFWS 11/14/2012 “We recommend that the instream flow modeling
demonstrate complete integration of the riverine
process analysis (groundwater, instream flow,
geomorphology, ice processes, biological response to
flow changes), not simply coordinate with the other
study areas. The results of an integrated riverine
processes analysis should provide an understanding of
instream flow changes induced by Project operations
and fish behavior as it relates to the associated
changes in quality and quantity of fish habitat. The
intent of our request is for the flow analysis to be used
to assess Project-effects on anadromous and resident
fish and their habitat. This analysis will be used to
make specific conservation recommendations by the
Service under our applicable authority of Section 10(j)
of the Federal Power Act. To facilitate our
understanding of the specifics of the study integration,
the Service requires a degree of certainty that each of
As described in Section 8.5.4.1, the IFS Analytical Framework integrates
the analysis of Project effects on riverine processes. Project effects on
geomorphology, ice processes, water quality and groundwater/surface
water interactions will be used to quantify changes in fish and aquatic
habitat and riparian indicators (see Figure 8.5-10).
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the riverine process components are adequately
addressed along with levels of precision and accuracy
of overall model integration results. This will become
evident with more detailed study plans that refine
overall approach, schedule, methods, and
contingencies if necessary site-specific information is
not collected.” –pdf pages 62-63
IFS-008 NMFS 11/14/2012 “We recommend that the instream flow study should
integrate all of the riverine process analysis
(groundwater, instream flow, geomorphology, ice
processes, biological response to flow changes), not
simply coordinate with the other study areas. The
results of an integrated riverine processes analysis
should be an understanding of instream flow changes
induced by project operations and changes to fish
habitat and fish behavior. The intent of our request was
for the flow analysis to be used to assess project
effects on anadromous fish and their habitat. This
would require an integration of the flow dependent
results of the geomorphology studies, groundwater
study, water quality study, fish studies, and ice process
study to analyze all vectors of influence as a result of
changes in instream flow related to fish and their
habitat.” –pdf pages 73-74
See AEA’s response to comment IFS-007.
IFS-009 USFWS 11/14/2012 To understand Project effects, it will be necessary to
integrate the 10 riverine study components outlined in
the May 2012 study request (flow routing, water
quality, geomorphology, riparian function, surface-
groundwater interactions, ice processes, habitat
modeling, habitat connectivity, climate and biological
cues). –pdf page 61
The riverine study components are integrated in the proposed Instream
Flow Study as described in the IFS analytical framework (see Section
8.5.4.1).
IFS-010 NMFS 11/14/2012 “Additional sites should be selected that are not
necessarily representative of overall riverine processes
but are significant because they support
disproportionate or important biologic functions.
Please see AEA’s response to comment IFS-011. Also please note that
winter investigations are part of the IFS (see Section 8.5.4.5.1.2.1).
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Additional site selection should be made using
information on species and life stage distribution and
aquatic and riparian habitat quantification. Site
selection should rely on an understanding of the
characteristics that define fish habitat from several
years of utilization information that is being started in
2012, this will likely require additional sites to be
selected at the conclusion of the 2013 studies to be
implemented in 2014. Site selection to capture
important anadromous fish habitat, in addition to the
sites selected for extrapolation of study results should
emphasize areas that are utilized by anadromous fish
and not ignoring locations or time periods that are
difficult to study, i.e. mainstem utilization and over
wintering habitat.” –pdf page 66
IFS-011 USFWS 11/14/2012 “Additional sites should be selected that are not
necessarily representative of overall riverine
processes, but are significant because they support
disproportionate or important biologic functions.” –pdf
page 56
As described in Section 8.5.4.2.1.2, the study area/study site selection
approach is adaptive, and will allow for the shifts in study focus to other
areas, should results of 2013 studies reveal their biological importance and
sensitivity to flow modifications. Thus, additional sites or Focus Areas may
be added based on results of, for example the fish distribution studies (see
Section 9.5) or habitat characterization studies (see Section 9.9). AEA
notes that this comment essentially refers to what are termed critical study
areas, which are defined in Section 8.5.4.2.1.2 and which factored directly
into the selection of the Focus Areas.
IFS-012 USFWS 11/14/2012 “AEA has proposed using a hierarchical method,
dividing the study area into reaches by hydrology, then
geomorphology, and then macro-habitat types. Each
geomorphic reach is proposed to include an intensive
study site (focus area) with a minimum of one instream
flow reach containing all of the representative meso-
habitats available in that reach. The Service
recommends that AEA proceed further in its
classification to include a detailed discussion of micro-
habitats with reference to classifications of ecological
significance. This will entail delineation of each of the
geomorphic reaches, as well as delineation and spatial
AEA has further refined the hierarchical classification system. These
refinements are provided in Section 8.5.4.2.1.1 and described in more
detail in Section 9.9. Habitat mapping of mesohabitats is in the Middle
River Segment is underway and due to be completed in Q1 2013. More
detail regarding the geomorphic reach delineation process is provided in
Section 6.5.
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mapping of the macro-habitats types, as described at
the TWG meetings. Geomorphic reaches are identified
as those used in the 1980s studies, but no information
regarding how they were delineated during that time
have been provided. This remains a concern for the
overall Project design and statistical representation of
the Susitna River.” –pdf page 55
IFS-013 NMFS 11/14/2012 “AEA Study Objective 1. Map the current aquatic
habitat in mainstem and lateral habitats of the Susitna
River affected by Project operations. The first objective
of the applicant's proposed study plan is to map the
aquatic habitat in the mainstem and lateral habitats in
the project area. The initial subdivision of habitat
mapping will occur at a macro level with six divisions,
consistent with the 1980s studies. Further refinement
and definition of these habitat divisions are described
in this study plan and in the Fish and Aquatic
Resources study plan (7.9) and in the Geomorphology
study plan (5.8). NMFS requests refinement of the
study plan to capture flood plain habitats, specifically
examining the role of beaver ponds as a macro-habitat
relevant to rearing fish. The methods include remote
sensing, ground based habitat surveys, field data
collection of geomorphological variables (bankfull
width; bankfull depth, gradient, channel pattern,
channel type, substrate composition, sinuosity, and
habitat classification).” –pdf page 64
Beaver ponds have been included in the classification system under off-
channel habitats.
This classification system is presented in Table 8.5-5 and described further
in Section 9.9. More details concerning the characterization of riparian
habitats as they pertain to floodplains are found in Section 8.6.
IFS-014 FERC 11/14/2012 “Clearly describe the exact number, location, and
spatial extent of your proposed focus areas for each
proposed study. Provide justification for the number of
proposed sites selected for detailed 2-D hydraulic
modeling and other intensive study elements. Include
criteria to be used for selecting focus areas and study-
specific rationale for co-locating sites.” –pdf page 5
The number of proposed Focus Area sites for the IFS is described in
Section 8.5.4.2.1.1, listed and described in Table 8.5-6 and illustrated in
Figures 8.5-13 to 8.5-22 of the RSP. For purposes of the RSP, a total of
ten potential Focus Areas were identified. These 10 areas were selected
for planning purposes and will be evaluated further for their
representativeness of other areas based on results of habitat mapping that
will be completed in Q1 2013. The results of this evaluation will be shared
with the TWG and refinements in Focus Area selection made prior to
commencement of the 2013 studies. Table 8.5-6 provides the rationale for
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Focus Area selection. The specific criteria that were used in selecting the
proposed Focus Areas include:
1) All major habitat types (main channel, side channel, side slough, upland
slough, tributary delta) will be sampled within each geomorphic reach.
2) At least one (and up to three) Focus Area(s) per geomorphic reach
(excepting geomorphic reaches associated with Devils Canyon – MR-3 and
MR-4) will be studied that is/are representative of other areas.
3) A replicate sampling strategy will be used for measuring habitat types
within each Focus Area, which may include a random selection process of
mesohabitat types.
4) Areas that are known (based on existing and contemporary data) to be
biologically important for salmon spawning/rearing in mainstem and lateral
habitats will be sampled (i.e., critical habitats).
5) Areas for which little or no fish use has been documented or for which
information on fish use is lacking will also be sampled.
IFS-015 USFWS 11/14/2012 “Current scientific understanding of criteria influential to
fish habitat site selection warrants a more
comprehensive consideration of variables. We
maintain that the use of hierarchically nested habitats
and metrics influential to fish habitat site-selection
(micro –habitat) is at a scale more relevant to fish.” –
pdf page 55
Please see Section 8.5.4.5.1.1 for a listing and description of microhabitat
variables that will be collected as part of Habitat Suitability information. In
addition to microhabitat variables that are commonly collected, (e.g. depth,
velocity, substrate), data concerning cover/habitat structure, upwelling
presence/absence, and turbidity will be collected. Upwelling
presence/absence was likewise noted during the 1980s studies and a
binary relationship developed that factored into habitat area computation as
part of the Direct Habitat (DIHAB) model development.
IFS-016 FERC 11/14/2012 “Fish and Aquatics Instream Flow (Section 8.5) In
section 8.5.4.2.1.1, you indicate that the instream flow
study area consists of two river segments, the Middle
River (MR) and Lower River (LR) segments. You
currently propose to model from the dam location
downstream to RM 75. Based on the geomorphic
mapping presented in the geomorphology study
(section 6.5, Figure 6.5-4), RM 75 is located near the
middle of Reach LR2; therefore, modeling would
include all of Reach LR1, and a portion (9 of the 23
Although both Middle and Lower River segments are under consideration
as part of this IFS, the majority of detailed study elements described in the
RSP are concentrated within the Middle River Segment. This is because
project operations related to load-following and variable flow regulation will
likely have the greatest potential effects on this segment of the river. These
effects tend to attenuate in a downstream direction as channel
morphologies change, and flows change due to tributary inflow and flow
accretion.
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miles) of Reach LR2. Please describe how you intend
to assess project effects within the Lower River
segment using the proposed framework, particularly in
regard to reach LR2, when your proposed modeling
will encompass less than half of the LR2 geomorphic
reach.” -pdf page 9
The downstream boundary of the Study Area is currently RM 75 because
existing information indicates that the hydraulic effects of the Project below
the Three Rivers Confluence are attenuated. See Section 8.5.3. However,
AEA will reevaluate how far downstream Project operational significant
effects extend based in part upon the results of the Open-water Flow
Routing Model (see Section 8.5.4.3),which is scheduled to be completed in
Q1 2013. Thus, an initial assessment of the downstream extent of Project
effects will be developed in Q1 2013 with review and input of the TWG.
This assessment will include a review of information developed during the
1980s studies and study efforts initiated in 2012, such as sediment
transport (see Section 6.5), habitat mapping (see Sections 6.5 and 9.9),
operations modeling (see Section 8.5.4.3.2), and the Mainstem Open-water
Flow Routing Model (see Section 8.5.4.3). The assessment will guide the
need to extend studies into the Lower River Segment and if needed, will
identify which geomorphic reaches will be subject to detailed instream flow
analysis in 2013. Results of the 2013 studies would then be used to
determine the extent to which Lower River Segment studies should be
adjusted in 2014. In addition, the results of the 1-D sediment transport
modeling (see Section 6.6) from RM 184 to RM 75 will be available in Q1
2014 and will further inform the need for these adjustments. Given the
importance of multiple-year studies to evaluate the behavioral response of
fish to flow conditions, pilot HSC/HSI studies were initiated in 2012, and will
be continued in 2013, and include data collection within Lower River
Segment habitats (see Section 8.5.4.5). See also Section 8.5.3 for more
discussion regarding the Lower River Segment.
IFS-017 FERC 11/14/2012 “Fish and Aquatics Instream Flow (Section 8.5): In
section 8.5.4.2.1.2, you indicate that no focus areas
were selected in reach MR3 upstream of Devils
Canyon (in addition to reach MR4 Devils Canyon) due
to safety concerns. Please describe the safety
considerations associated with reach MR3 that would
prohibit you from implementing a focus area in this
reach. You should also describe how you intend to
assess project effects in reach MR3 without a focus
area to “provide for an overall understanding of
interrelationships of river flow dynamics on the
physical, chemical and biological factors that influence
MR-3 is a relatively short reach (3.5 mile) located just upstream from the
Devils Canyon reach, MR-4. MR-3 is steep (slope is second highest (17
feet/mile) next to Devils Canyon (30 feet/mile) and is confined within a
relatively narrow canyon. Although flow routing transects were initially
considered for this reach, any attempt to sample this reach was abandoned
once field teams were on the ground and realized it could not be safely
measured. Of particular concern were the swift currents within the reach
and the lack of any margin of safety for recovering someone before they
would be swept into Devils Canyon. MR-3 consists primarily of single-
thread main channel habitat with two areas with split-main channel islands.
No major tributaries enter the reach and it is likely that any anadromous
salmonids (Chinook salmon) that make it through Devils Canyon simply
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fish habitat” in the reach.” -pdf page 9 pass through MR-3. Since there are no Focus Areas or cross-sectional
transects proposed within MR-3 or MR-4, the assessment of project
operational impacts within these reaches will rely largely on the results of
habitat mapping completed in these reaches and the development and
weighting of habitat-flow response relationships (by mesohabitat type) from
the two upper geomorphic reaches, MR-2 and MR-1 (there are 15 existing
cross-sectional transects within these two reaches and three Focus Areas.)
and the next lower reach MR-5, which contains 4 transects. These
relationships, will then be applied to respective mesohabitat types in MR-3
and MR-4 and reach specific habitat-flow response relationships. These
relationships will be adjusted based on flow accretion.
IFS-018 FERC 11/14/2012 “Fish and Aquatics Instream Flow (Section 8.5): In
section 8.5.4.2.1.2, you indicate that transects
established for the flow-routing model were primarily
located across single-thread (i.e., non-braided)
sections of the river. While this is appropriate for
developing the mainstem flow-routing model, the same
model/transects would not adequately represent the
frequency, distribution, abundance, and diversity of
habitats and habitat conditions within the Middle River
and Lower River segments for other study purposes. In
section 8.5.4.6 (Habitat Specific Model Development),
you indicate that additional transects will be selected to
describe distinct habitat features in addition to those
used for defining the mainstem flow-routing model.
Presumably, the additional transects will be used to
expand the model for the purpose of assessing habitat
conditions in relation to flow for such features, and use
the results to extrapolate conditions on a broader scale
(e.g., geomorphic reach). To achieve this purpose,
additional transects will likely be needed to
characterize habitat conditions in the reaches being
evaluated. In your RSP, please distinguish between
the mainstem flowrouting model and any
modified/expanded versions that may be used to
describe distinct habitat features (e.g.,
stranding/trapping), or for purposes such as sediment
As noted in Section 8.5.4.2.1.2, a total of 80 cross-sectional transects in
the Middle River Segment and 8 transects in the Lower River Segment
have been established and flow data collected to support development of
the flow routing model (see Section 8.5.4.3 and Table 8.5-7). As the
comment indicates, these transects were primarily located across single
thread sections of the river and most are outside of the Focus Areas.
However, some of the transects do extend across more complex sections.
In most cases, two to three sets of flow measurements have been made at
each transect. The resulting data sets can be used, at a minimum, for
evaluating velocity-depth distributions across the channel that can be
related to biologically relevant criteria associated with various life stage
requirements (e.g., spawning, adult holding, juvenile rearing). In many
cases (pending review of the cross-sectional data) it should be possible to
develop actual habitat-flow relationships following a 1-D PHABSIM type
analysis (see Section 8.5.4.6). The cross-sectional transects represent an
important data set that can be used to characterize habitat-flow response
characteristics of the main channel of the Susitna River. These types of
data were never collected during the 1980s studies and no main channel
habitat - flow relationships were developed. Importantly, once the main
channel habitat mapping is completed (see Section 9.9), the transect
locations will be assigned to specific mesohabitat types (e.g., riffle, run,
glide, pool) that could be randomly selected for analysis. These additional
transects may also be useful for extrapolating results/relationships from
measured to unmeasured sites. Supplemental main channel transects will
be established as needed to more fully characterize main channel habitats,
either as part of the Focus Area analysis or at separate locations
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transport. In addition, please describe how these 1-D
models relate to focus areas and whether they overlap
or will be integrated with the proposed 2-D modeling
that will be implemented within some or all of the focus
areas.” -pdf pages 9-10
associated with specific mesohabitat types. The need for and exact number
of the supplemental transects will be determined based on results of the
habitat mapping.
IFS-019 TNC 11/14/2012 “Focus Area Selection
The study plans are inconsistent on the use of the
terms “focus areas‟ and “study sites.‟ In these
comments, we assume that these are intended to be
the same places so will use the term ”focus area.‟ The
method for selection of focus areas is also inconsistent
between and within study plans. Table 8.5-13 of the
Fish and Aquatics Instream Flow Study (8.5) indicates
that Focus Area selection is happening currently (Q3-4
2012) even before studies are approved or officially
begin. If selection is to be based on the criteria
presented in 8.5.4.2, habitat mapping results from
2013 studies would seem to be required to select focus
areas.
Focus areas should be selected based on biological
functions and habitat utilization by salmon as well as
physical processes related to instream flow, including
habitat-flow relationships, surface-groundwater
interactions, geomorphic processes, and ice
processes. Biological functions for salmon (i.e.
spawning, rearing, migration, overwintering) could
potentially change with project operations, and
appropriate focus area selection can help to
characterize and quantify that anticipated change.
Focus areas should be selected in the Middle and
Lower Rivers. The river from the three river confluence
and below is especially dynamic. Focus areas in the
Lower River are required to understand changes to
salmon habitat due to project operations. As noted in
our comments on Climate Change impacts above, the
In response to this comment and others, AEA has revised the RSPs to
reflect the common use of terms. However, one point to note is that while
many of the resource studies will be evaluating the Focus Areas in
coordination with other disciplines, there will be "study sites" located
outside of the Focus Areas and these will be specified separately. The
comment concerning Focus Area selection process is addressed in Section
8.5.4.2.1.2. This section provides greater details on the sampling strategies
considered and the rationale for the proposed approach. It also provides
details on the criteria applied for selecting the Focus Areas. It is important
to note that the 10 potential Focus Areas that were identified were selected
for planning purposes and will be evaluated further for their
representativeness based on the results of the habitat mapping that will be
complete in Q1 2013. The results of this evaluation will be discussed with
the TWG and refinements in Focus Area selection made prior to
commencement of the 2013 studies. AEA intends to seek TWG input and
finalize the initial set of study areas by February/March of 2013 to enable
detailed field studies to occur. The need for redistribution or additional
Focus Areas and study sites in the Lower River Segment will be
determined based on results of the Open-water flow routing model (see
Section 8.5.4.3).
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cumulative impacts of this project with other
anticipated changes to the basin could affect salmon
and salmon habitat in the Lower River.” –pdf pages 2-3
IFS-020 NMFS 11/14/2012 “Focus area site selection should be representative of
the physical processes that are related to instream
flow, including habitat-flow relationships,
surface/groundwater exchange, geomorphic
processes, and ice processes that are important to
formation, availability, and quality of fish habitat. The
applicant has proposed using a hierarchical method,
dividing the study area into reaches by hydrology, then
geomorphology, and then macro-habitat types. Each
geomorphic reach would have a site that contained at
least one instream flow reach (focus area) that
contained all of the representative macro-habitats
available in that reach. This will require that the sites
be statistically representative to allow for extrapolation
of results based on metrics not yet determined or
described. We recommend that sites be selected
randomly and be reproducible and that enough sites
be selected to capture the variability of each macro-
habitat for each geomorphic reach and to allow for
replication. This will require, at a minimum, mapping of
the macro-habitat types and delineation of each of the
geomorphic reaches, both described as in progress at
TWG meetings but not described in the PSPs. Results
from the first year studies may require additional sites
if representative or sufficient replication is not captured
from the initial sites.” –pdf page 65
This comment is similar to IFS-021 but appears to be more directed toward
the actual selection of study sites, rather than HSC sampling sites which
presumably was at the center of the IFS-021 comment. AEA has given
careful consideration to the study site/area selection process as outlined in
Section 8.5.4.2. This included consideration of the different sampling
strategies including representative, critical, and random selection, as well
as the pros and cons of each of these approaches and their applicability to
the Project. In the end, it was determined that all three sampling strategies
had applicability to the Project but at different levels of the analysis.
Specific to the recommendation regarding random sampling, please see
the specific discussion on that strategy in Section 8.5.4.2.1.2. That
discussion notes that although random sampling is the least subject to
bias, it becomes increasingly difficult to apply in site selection when the
sites become more complex, such as is the case on the Susitna River.
Strict random sampling is therefore not likely applicable for evaluating off-
channel habitats and sloughs where the morphology of multiple channels
varies substantially and in complex ways within and across sites. However,
random sampling is still applicable and will be applied on the Project for
sampling mesohabitat types and selection of HSC study sites, which was
discussed in the response to IFS-021.
IFS-021 USFWS 11/14/2012 “Focus area site selection should be representative of
the physical processes that are related to instream
flow, including habitat-flow relationships,
surface/groundwater exchange, geomorphic
processes, and ice processes. AEA has proposed
using a hierarchal method, dividing the study area into
reaches by hydrology, then geomorphology, and then
Section 8.5.4.5.1.1.3 contains a detailed description of the site selection
process that will be used for conducting HSC data collection. The process
includes a stratified random sampling scheme that will include river
segment, geomorphic reach and habitat types as listed in Table 8.5-5. For
the Middle Segment, three sites of each habitat type will be randomly
selected from within each of the seven geomorphic reaches (excludes
Geomorphic Reach MR-4 due to safety issues) for a maximum of 168
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macro-habitat types. Each geomorphic reach would
have a site that contained at least one instream flow
reach that contained all of the representative meso-
habitats available in that reach. During the October site
visit, we learned that some of the micro-habitat sites
for HSC development are proposed to be within the
proposed focus areas of the 1980’s slough sites. An
additional unknown number of sites for HSC
development will be identified outside of the focus
areas. This unstructured approach is inadequate to
address our study request and the fundamental
biological questions contained within. Lacking
adequate fish distribution and utilization data, we
recommend that 1) study sites be selected randomly
within representative delineations; 2) that the
delineations be reproducible, 3) that enough sites are
selected to capture the variability of each macro-
habitat for each geomorphic reach and to allow for
sufficient replication. This will require, at a minimum,
mapping of the macro-habitat types and delineation of
each of the geomorphic reaches.” –pdf page 56
potential sampling locations. This total will include the Focus Areas. For
each of the Middle River Segment sampling sites, a special effort will be
made to ensure that HSC sampling occurs within each of the main channel
mesohabitat types present. Sampling is also proposed in the upper
portions of the Lower River Segment extending from RM 77 to RM 97
where three replicates of each mainstem habitat type will be randomly
selected for a maximum of 24 sample sites. The proposed number and
distribution of 2013 HSC sampling sites will be presented to the TWG
during the Q2 2013 meeting.
IFS-022 FERC 11/14/2012 “In section 8.5.3, Study Area, you describe your
proposed hierarchical habitat classification system.
Please ensure that the category descriptions,
definitions, and terminology are consistent with those
presented in the Geomorphology Study,
Characterization and Mapping of Aquatic Habitats
Study, and any other related studies. For example, in
Table 9.9-4, you describe split-main and braided-main
channel types, which are not described in section
8.5.3. Moreover, in the description of HSC Study Site
Selection, you refer to a percolation channel, a term
that is not used elsewhere.” -pdf page 10
A more complete description of the hierarchical system is provided in
Section 8.5.4.2.2.1. This now includes split and multiple split main channels
as described in Table 8.5-5. The system was developed input from the
TWG. AEA has revised the RSP to provide for consistent use of
terminology across studies. The description provided in the HSC Study
Area Selection (see Section 8.5.4.1.1.3) is now consistent with that
described in 8.5.4.2.1.1.
IFS-023 USFWS 11/14/2012 “In the proposed PSP and through subsequent
meetings, presentations, and field trips, AEA’s focus
appears to be limited to study sites used in the 1980’s,
AEA is not limiting its IFS evaluation to only sites sampled in the 1980s.
Indeed, three of the ten Focus Areas identified in the RSP are located
above Devils Canyon and were never studied during the 1980s (see Table
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when this Project was first evaluated. This falls short of
AEA’s commitment to use a hierarchical method,
dividing the study area into reaches by hydrology, then
geomorphology, and then by macro-habitat types. The
study sites focused on, thus far are representative of
side sloughs of the Middle Susitna River. Although
these may be good study sites for side sloughs, they
only represent one macro-habitat type and were
selected without regard to hydrology or
geomorphology.” –pdf page 54
8.5-6). Moreover, the Focus Areas are all relatively long (ranging from 0.5
to 1.9 miles) and therefore include habitat types and features that were
never studied in the 1980s. The 80 main channel transects that were
established for the flow routing model and any supplemental main channel
transects that will be considered as part of the IFS were likewise not
utilized in the 1980s studies. The fact that a number of sites surveyed in
the 1980s are included within the Focus Areas is not surprising given the
spatial extent of surveys completed then. AEA has used the information
provided in the 1980s studies to help guide but not dictate the selection of
study areas. AEA also notes that the Focus Areas and cross-sectional
transects contain a variety of habitat types (e.g. side channel, side slough,
upland slough, main channel, tributary mouth) and are not focused
exclusively on side sloughs, as the comment suggests.
IFS-024 TNC 11/14/2012 “Lower River Studies
Many of the study plans assume no effects from the
project and its operation below Talkeetna (Mile 97) and
do not include the Lower River in their scope. As noted
in our comments on Climate Change impacts above,
the cumulative impacts of this project with other
anticipated changes to the basin could affect salmon
and salmon habitat in the Lower River. Load-following
operation, which will essentially flip the hydrological
pattern between winter and summer, must be modeled
for effects on the Lower River. The hydrological model
has been extended to Mile 84 in the upper Lower
River, and the study plan notes that the model will be
extended further into the Lower River if project effects
are seen at Mile 84. It is not clear what the trigger will
be to extend the model and how or when that will be
decided. The Revised Study Plans, including those for
geomorphology, instream flow, and ice processes,
should include the Lower River. If they do not but leave
the possibility open depending upon early results, the
plans should be explicit about why they assume no
effect on the Lower River and what criteria will be used
to revisit the need to extend models when early results
See AEA’s response to comment IFS-033.
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are available.” –pdf page 3
IFS-025 ADNR-
ADF&G
11/14/2012 “More details are needed on sampling approaches. For
example, what criteria will be used to determine how
many focus areas, mesohabitats and critical area sites
will be selected?” –pdf page 21
Additional details describing the study site selection process including the
criteria for selecting the Focus Areas is provided in Section 8.5.4.2.1.2.
Those criteria included the following:
● All major habitat types (main channel, side channel, side slough, upland
slough, tributary delta) will be sampled within each geomorphic reach.
● At least one (and up to three) Focus Area(s) per geomorphic reach
(excepting geomorphic reaches associated with Devils Canyon – MR-3 and
MR-4) will be studied that is/are representative of other areas.
● A replicate sampling strategy will be used for measuring habitat types
within each Focus Area, which may include a random selection process of
mesohabitat types.
● Areas that are known (based on existing and contemporary data) to be
biologically important for salmon spawning/rearing in mainstem and lateral
habitats will be sampled (i.e., critical habitats).
● Areas for which little or no fish use has been documented or for which
information on fish use is lacking will also be sampled.
IFS-026 NMFS 11/14/2012 “The 1980s flow-habitat studies focused on side slough
macro-habitats where spawning salmon were
observed, representing habitats with high fish use
density. Current methodologies require enough sites to
capture a range of fish use for each of the macro-
habitats. Selected sites should include both occupied
and unoccupied macro-habitats to best understand the
criteria influential to fish distribution and habitat site
selection.” –pdf page 66
Please see AEA’s response to comment IFS-030.
IFS-027 USFWS 11/14/2012 “The objective should be stated more specifically to
address the characterization and quantification (i.e.
mapping) of the habitat types of the Susitna River at
multiple scales.” –pdf page 55
Consistent with this comment, AEA has revised objective 2 as follows: 2)
Select study sites and sampling procedures to collect data and information
that can be used to characterize, quantify, and model mainstem and lateral
Susitna River habitat types at different scales.
IFS-028 NMFS 11/14/2012 “The studies at the focus areas should provide a
greater understanding of project effects on riverine
Please see AEA’s response to comment IFS-033 regarding lower extent of
studies.
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processes and to be representative, providing an
understanding of the potential effects to the larger
project area. Currently the discussion in the TWGs has
focused on the middle river. The same methods we
propose for focus area site selection should be applied
for select focus areas for the lower river.” –pdf page 65
IFS-029 NMFS 11/14/2012 “This classification method must include enough study
sites (focus areas) to capture the variability in the
macro-habitat types, in each geomorphic reach, to
describe characteristics that may influence fish
distribution. For example, water quality and water
sources seem to be the major driver of fish distribution
in glacial rivers, but the current classification does not
differential macro-habitats of different water quality.
Another example is source water, for spawning within
the flood prone area, the USGS on the Matanuska
River (Curran et al. 2011) identified clear water side-
channels as important for spawning, with source water
from the surface (tributaries) or from groundwater
(local or regional was not differentiated).” –pdf page 65
Please see AEA’s response to comment IFS-030.
IFS-030 USFWS 11/14/2012 “We are concerned that the 1980s studies focused
(sampling bias) on side slough macro-habitats where
spawning salmon were observed. This is narrowly
limited to habitats with poorly documented high fish
density. In our study request, we recommended
selection of sites both occupied and unoccupied by
fish for assessment to best inform the criteria influential
to fish distribution and habitat site selection.
Fish and aquatic instream flow study sites should be
selected to be representative of the physical processes
that are related to instream flow important to the
formation of fish habitat, including habitat-flow
relationships, surface/groundwater exchange,
geomorphic processes, and ice processes. In other
words, selection based on the nested hierarchy of
The 1980s studies focused on a variety of habitat types, not just side
sloughs where salmon were observed spawning. Detailed flow related
studies were conducted in side channels, side sloughs, tributary mouths,
upland sloughs and on a limited basis the main channel. These focused on
both spawning and juvenile rearing habitats. See Table 8.5-3 for a listing of
instream flow related sites sampled in the 1980s, along with the types of
habitats they contained.
The Focus Areas selected in the RSP were those deemed representative
of the major features in the geomorphic reach and included mainstem
habitat types of known biological significance (i.e., where fish have been
observed based on previous and/or contemporary studies), as well as
some locations (e.g., Slough 17) where previous sampling revealed few/no
fish (see Section 8.5.4.2.1.2). The Focus Area approach described in
Section 8.5.4.2.1.2 was designed to not only capture the variability of
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habitats, studied at multiple scales, including macro-,
meso- and micro-habitat scale.” –pdf page 55
different habitat types, including those with and without clear water, but
also to allow for an integrated assessment of habitats and how they
function, across multiple disciplines including water quality (Section 5.5),
groundwater (Section 7.5), riparian instream flow (Section 8.6), ice
processes (Section 7.6), and geomorphology (Section 6.5). However, the
Focus Areas were selected for planning purposes and will be reevaluated
for their representativeness of other areas based on results of habitat
mapping that will be completed in Q1 2013.
IFS-031 ADNR-
ADF&G
11/14/2012 “We support the hierarchical classification system for
characterizing habitat categories. This system was
derived from the 1980’s information and provides a
sound framework for designing sampling protocols and
evaluating study results. Still needed is the habitat
inventory data scheduled to be collected this year and
summarized according to the above classification
system for future decision-making.” –pdf pages 20-21
Additional information and descriptions of the hierarchical classification are
provided in Section 8.5.4.2.1 and contained in Table 8.5-5. The habitat
mapping analysis of the Middle River Segment will be completed in Q1
2013.
IFS-032 ADNR-
ADF&G
11/14/2012 “What criteria will be used to identify "a representative
number" of habitat types within the description of study
sites for fish passage/off-channel connectivity
(§6.5.4.5.5.)?” –pdf page 20
The fish passage/off-channel connectivity element of the IFS will be
coordinated closely with the Study of Fish Passage Barriers in the Middle
and Upper Susitna River and Susitna Tributaries (see Section 9.12). As
noted in Section 8.5.4.6.1.2.3, there are 12 major tributaries with names,
approximately 50 unnamed tributaries, and approximately 50 sloughs
located within the Middle River Segment. Passage evaluation studies in the
Middle River Segment will therefore begin in 2013 within each of the Focus
Areas with the selection criteria being that they support spawning habitats
that would be influenced by Project operations. Thus, the studies will center
on the associated tributary mouths, side channels, and side sloughs within
the Focus Areas. Focus Areas within the Middle River Segment that
contain those habitat types include Focus Area-170, Focus Area-168,
Focus Area-148, Focus Area-141, Focus Area-138, Focus Area-135,
Focus Area-124, and Focus Area-101 (See Table 8.5-6). In 2014, barrier
surveys may be expanded to include both additional locations within the
Middle River Segment that, based on results from fish distribution (see
Section 9.5) and escapement studies (see Section 9.7) indicate are used
for spawning and that based on geomorphic analysis (see Section 6.5)
would be susceptible to flow changes resulting from Project operations, as
well as locations in the Lower River Segment. The decision to conduct
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studies in the Lower River Segment will be made based in part on results
of the open-water flow routing model as discussed in Section 8.5.4.3.
IFS-033 CWA 11/14/2012 Scope is insufficient in studying the Lower River based
on AEA’s apparent assumption that Project effects will
not significantly affect the Lower River instream flow. –
pdf pages 7-8
AEA is not assuming an insignificant Project-related effect on instream flow
in the Lower River Segment. As noted in Section 8.5.3, both Middle and
Lower River segments are under consideration as part of this IFS.
However, the majority of detailed study elements described in the RSP are
concentrated within the Middle River Segment. This is because Project
operations related to load-following and variable flow regulation will likely
have the greatest potential effects on this segment of the river. These
effects tend to attenuate in a downstream direction as channel
morphologies change, and flows change due to tributary inflow and flow
accretion. The diversity of habitat types and the information from previous
and current studies that indicate substantial fish use of a number of slough
and side channel complexes within this segment, also support the need to
develop a strong understanding of habitat–flow response relationships in
this segment.
The downstream boundary of the study area is currently RM 75 because
existing information indicates that the hydraulic effects of the project below
the Three Rivers Confluence are attenuated. See Section 8.5.3. However,
AEA will reevaluate how far downstream Project operational significant
effects extend based in part upon the results of the Open-water Flow
Routing Model (see Section 8.5.4.3), which is scheduled to be completed in
Q1 2013 as well as results of the operations model. The results of the
Open-water flow routing model completed in Q1 2013 will be used to
determine whether and the extent to which Project operations related to
load-following as well as seasonal flow changes occur within a section of
the Lower River Segment that includes all of Geomorphic Reach LR-1 and
a portion of LR-2 (down to RM 75). Thus, an assessment of the
downstream extent of Project effects will be developed in Q1 2013 with
review and input of the TWG. This assessment will include a review of
information developed during the 1980s studies and study efforts initiated
in 2012, such as sediment transport (see Section 6.5), habitat mapping
(see Sections 6.5 and 9.9), operations modeling (see Section 8.5.4.2.2),
and the Mainstem Open-water Flow Routing Model (see Section 8.5.4.3).
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The assessment and the following five criteria will be used to evaluate the
need to extend studies into the Lower River Segment and if studies are
needed, will identify which geomorphic reaches require instream flow
analysis in 2013. The criteria include:
• Magnitude of daily stage change due to load-following operations relative
to the range of variability for a given location and time under existing
conditions (i.e., unregulated flows);
•Magnitude of monthly and seasonal stage change under Project
operations relative to the range of variability under unregulated flow
conditions;
• Changes in surface area (as estimated from relationships derived from
LiDAR and comparative evaluations of habitat unit area depicted in aerial
digital imagery under different flow conditions) due to Project operations;
• Anticipated changes in flow and stage to Lower River off-channel
habitats; and
• Anticipated Project effects resulting from changes in flow, stage and
surface area on habitat use and function, and fish distribution (based on
historical and current information concerning fish distribution and use) by
geomorphic reaches in the Lower River Segment.
Results of the 2013 studies would then be used to determine the extent to
which Lower River Segment studies should be adjusted in 2014.
IFS-034 FERC 11/14/2012 “Fish and Aquatics Instream Flow (Section 8.5): In
section 8.5.4.3.1, you state that the hydraulic-routing
model will extend downstream until flow fluctuations
are within the range of without-project conditions.
Please define this range and associated thresholds in
your RSP and explain them in terms of the operational
scenarios (e.g., worst-case scenario) and criteria that
will be used in the decision-making process.” -pdf page
9
Hydraulic flow routing (see Section 8.5.4.3.1) is used to provide flow and
stage data at various locations downstream of the proposed dam site under
existing conditions and alternative operational scenarios. The results of the
flow routing will be used by all riverine process and aquatic resources to
support Q1 2013 decisions regarding the need to extend resource studies
into the Lower River. See AEA’s response to comment IFS-033. Decision
criteria to guide extension of studies into the Lower River are specific to
each riverine process and aquatic resource. For instance, the process to
determine the downstream limit for the Fluvial Geomorphology Modeling
below Watana Dam Study will follow the process described in Section
6.6.3.2. The process to determine the downstream limit for fish and aquatic
habitats will follow the river stratification and study area selection process
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described in Section 8.5.4.2. The flow routing description in Section
8.5.4.3.1 has also been modified.
IFS-035 FERC 11/14/2012 “Include in your RSP a description of the flow-routing
model and a schedule and the specific criteria that you
will use to establish the downstream extent of the flow-
routing model. The RSP should clearly document: (1)
the other study plans that may be modified based on
the outcome of the flow-routing model; (2) how each
plan would be modified; and (3) triggers for
modifications to each plan.” –pdf page 4
Results of the draft open-water flow routing model (see Section 8.5.4.3.1)
will be available in Q1 2013. The initial model will be used to assess the
magnitude, timing and frequency of hourly flow and stage changes
associated with proposed load-following operations during ice-free periods.
The results will be used by all riverine process and aquatic resource groups
to evaluate downstream extent of Project effects. Project operations will
likely include storing water during the snowmelt season (May through
August) and releasing it during the winter (October through April) (AEA
2011). This would reduce flows downstream of the dam site from May
through August and increase flows October through April. During Q1 2013,
results of the draft open-water flow routing model will be used to evaluate
downstream flow and stage changes associated with reduced Project flow
releases during the open-water portions of the reservoir refill period. Since
the results of the Ice Processes in the Susitna River Study model (see
Section 7.6) will not be available prior to the start of the 2013 summer field
season; the downstream extent of Project effects on flow and stage during
the winter will be assessed by routing winter flow releases identified by the
operations model (see Section 8.5.4.3.2) downstream using the open-water
flow routing model. Although winter stage and flow projections will not be
robust, they will provide sufficient information on downstream flow and
stage effects to support early 2013 decisions regarding the need to extend
resource studies into the Lower River. As discussed in AEA’s response to
comment IFS-034, decision criteria to guide extension of studies into the
Lower River are specific to each riverine process and aquatic resource.
The flow routing description in Section 8.5.4.3.1 has been modified. Should
extension of an open-water flow routing model downstream of RM 75 be
needed to address data needs of riverine process and habitat modeling
studies, the additional channel and hydraulic data can be collected in Q3
2013. The additional data will be incorporated into a revised open-water
flow routing model which will be shared with the TWG in Q4 2013 and the
results provided in the ISR. A final open-water flow routing model will be
developed in Q4 2014 and reported in the USR.
IFS-036 EPA 11/14/2012 "Percent difference values are particularly unhelpful for
assessing change in the average timing of specific
As described in Section 8.5.4.4.1.3, the suite of hydrologic statistics to be
used to evaluate existing conditions and alternative operational scenarios,
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event types between two flow records. The average
timing of a flow event cannot be changed by more than
± 365 days (or ± 183 days, depending on the choice of
method). Thus, for example, a seemingly small ± 10%
shift in the average timing of a flow event type actually
corresponds to a potentially ecologically significant
shift of ± 36.5 days. Changes in the timing of specific
flow conditions must be assessed based on absolute
differences, not percentages." –pdf pages 15-16
including modifications to select parameters to increase ecological
relevance to the Susitna River resources, will be developed with input from
the TWG.
IFS-037 NMFS 11/14/2012 "The results of the operations analysis will be used in a
comparative frame work to inform the effects on the
natural riverine system and will allow agencies to
assess operating conditions and to make
recommendations and mandatory conditions on the
final license application. Results should also include a
sensitivity analysis (Steel et al. 2009; Turner et al.
2001)" -pdf page 72
As described in Section 8.5.4.3.2, operations modeling will provide
downstream flow releases that will be input to habitat modeling of existing
and alternative operational scenarios over a range of hydrologic conditions.
Sensitivity analysis will be conducted of individual habitat modeling
components (see 8.5.4.5.1.1.8) and sensitivity analyses of overall results
will be conducted as described in Section 8.5.4.7: Temporal and Spatial
Habitat Analyses.
IFS-038 EPA 11/14/2012 "The IHA output measures the difference between
pairs of records based on the percent difference in
value for each parameter. However, percent difference
values per se provide no information on the ecological
significance of difference between flow records. A 10%
change might be ecologically significant for one
parameter, but not for another, depending on the
ecosystem. Percent difference values thus are
unhelpful, unless accompanied by an evaluation of
how much alteration would be ecologically significant
for each parameter, for each season of the year. The
PSP/RSP does not include any process for estimating
what magnitude of change (from existing to regulated
flows) would be ecologically harmful for any IHA
parameter.” –pdf pages 15-16
The results of statistical analyses of IHA/EFC-type parameters will be
reviewed with the TWG to identify ecologically meaningful differences
between existing conditions and alternative operational scenarios. The
results of the hydrologic analyses, combined with the results of the habitat
modeling efforts, will inform the development of AEA’s environmental
analysis in its License Application and provide guidance when developing
operational rules.
IFS-039 EPA 11/14/2012 "The Instream Flow study (Section 8.5) plan is silent
on what Environmental Flow Components (EFCs) it will
select for assessment (see discussion of the IHA
As described in Section 8.5.4.4.1.3, the suite of hydrologic statistics to be
used to evaluate existing conditions and alternative operational scenarios,
including modifications to select parameters to increase ecological
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program, above). In turn, the Geomorphology
PSP/RSP (Section 6.5) discusses at length the
importance of assessing at least one EFC: “Effective
Discharge.” The rationale for assessing Effective
Discharge needs to be integrated into a discussion of
the entire suite of EFCs relevant to the Project, a
necessary step seemingly missing from the PSP/RSP,
as noted under Point 5, above. In turn, this overarching
discussion of the EFCs for the Project should include
recommendations for the seasons of the annual cycle
that need to be assessed separately during the flow
analysis. For example, it is clear that Winter EFCs
should be different from all others, and that other
ecologically meaningful divisions of the annual
hydrologic cycle are necessary." –pdf page 16
relevance to the Susitna River resources, will be developed in consultation
with the TWG in Q1 2014 (see Table 8.5-14).
IFS-040 EPA 11/14/2012 "The present version of the IHA program has known
bugs. The PSP/RSP team should consult with the
support team for the software." –pdf pages 15-16
AEA will consult with the IHA program support team to identify known bugs.
Modifications to the standard IHA/EFC statistical packages are envisioned
to correct bugs and to increase ecological relevance of select parameters
to Susitna River resources.
IFS-041 EPA 11/14/2012 "While we agree that annual Effective Discharge
should be one of the EFCs, we think the argument for
a dominant role for Effective Discharge in shaping
habitat along the Susitna is overstated. . . . Thus,
Effective Discharge may well be only one potentially
important EFC with respect to average annual
cumulative sediment transport in the Susitna-Watana
system that provides information on year-to-year
changes in channel form that may affect, for example,
the narrowing of the main active channel following
extreme flow events, with consequent encroachment
by vegetation. As Doyle et al. describe (2005), the
application of an effective discharge analysis in
ecology is more complex than in geomorphology;
effectiveness curves will vary across ecological
variable and ecosystems. But understanding fluvial
geomorphologic dynamics – and the potential impacts
See AEA’s response to comment IFS-039.
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of the Project on these dynamics – requires assessing
larger flows as well. The PSP/RSP should identify
specific high- and extreme high-flow event types
(EFCs) for inclusion in the study (by season, if
appropriate); and should include some approach for
assessing flow pulses associated with ice jams, as
well." –pdf page 17
IFS-042 USFWS 11/14/2012 “In addition to AEA’s proposed use of the Indicators of
Hydrologic Alterations (IHA) and Range of Variability
models (TNC 1997; Richter et al. 1996; Richter et al.
1997), we recommend using the concept of natural
flow regime (and variation) to maintain biodiversity and
ecosystems and to identify ecologically relevant
hydrologic indices that characterize the natural flow
regime (Henriksen et al. 2006; Olden and Poff 2003;
Poff et al. 1997).” –pdf page 53
See AEA’s response to comment IFS-042.
IFS-043 NMFS 11/14/2012 “In addition to the proposed use of the Indicators of
Hydrologic Alterations (IHA) and Range of Variability
models (TNC 1997; Richter et al. 1996; Richter et al.
1997), we recommend using the concept of the
relationship between the natural flow regime and
variation to maintain biodiversity and ecosystems, to
identify ecologically relevant hydrologic indices that
characterize the natural flow regime (Henriksen et al.
2006; Olden and Poff 2003; Poff et al. 1997). Also
lacking in AEA’s PSP is information regarding the
integration and understanding of hydrologic conditions
that may influence biologic cues, such as juvenile out
migration timing and success, adult access to
spawning areas; and indirectly flow changes that may
influence water quality and influence biologic cues. For
riverine processes with insufficient information at the
end of the study period, the natural flow regime should
be the default recommendations for instream flow.” –
pdf page 63
The suite of hydrologic statistics (see Section 8.5.4.4.1.3), including
modifications to select parameters to increase ecological relevance to the
Susitna River resources, will be developed with input from the TWG by Q1
2014 (see Table 8.5-14). This may include the timing, magnitude and
frequency of spring and early summer freshets that provide biological cues
that influence juvenile salmon out-migration, and summer and fall freshets
that provide biological cues that may influence adult access to spawning
areas. The results of the hydrologic analyses, combined with the results of
the habitat modeling efforts, will inform the development of AEA’s
environmental analysis in its License Application and provide guidance
when developing operational rules. As described in Section 8.5.4.5.1,
HSC/HSI will be developed that describe fish utilization as parameters of
depth, velocity, substrate, cover, turbidity, and upwelling. Fish utilization of
parameters, such as cover, depth, and substrate, may be in response to
the risk of predation, but may be a function of other interrelated factors
such as water temperature and food availability. Development of HSC/HSI
will document target species and life stages utilization of microhabitat
habitat types. In coordination with fish distribution studies (see RSP
Section 9.6), habitat use strategies will be considered when developing
HSC/HSI to evaluate the effects of Project operations on the temporal and
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spatial distribution of fish.
IFS-044 USFWS 11/14/2012 “Local instrumentation (pressure transducers/depth
sensors) is also needed to assess hydrographic
relationships between primary and off-channel habitats
(sloughs and floodplain ponds/beaver ponds). Since
the hydrography of off-channel habitats is primarily a
function of discharge in the Susitna’s mainstem,
instrumentation of these relationships is needed to
quantify patterns of lateral connectivity and, through
interaction with USGS gages on the Susitna, identify
critical thresholds of lateral hydrologic connectivity
through surface and groundwater interaction. Local
instrumentation of wells and perennial sloughs and
ponds is needed throughout the study area in habitats
that represent a statistically valid sample of the global
distribution of habitats utilized by fish.” –pdf page 54
The distribution of instrumentation to assess hydrographic relationships
between main channel and off-channel habitats is described in Section
8.5.4.4.1.1: Hydrologic Data Collection and Section 7.5: Groundwater
Study.
IFS-045 USFWS 11/14/2012 “The following comments are related to the use of
Richter’s concepts (1996; 1997) and USGS software
(Henriksen et al. 2006) to characterize the natural flow
regime, and the use of Matthews and Richter (2007) to
characterize and isolate ecological flow components of
the Susitna River’s flow regime. The life histories of
floodplain fishes are adapted to the Susitna’s flow
regime and their seasonal patterns of habitat use
require natural flow variability (Mimms and Olden
2012). Mapping of the diversity of aquatic habitats and
surveys of seasonal fish distribution within these
habitats is needed to identify ecological flow
components necessary to maintain fish production.” –
pdf page 53
As described in Section 8.5.4.4.1.3, the suite of hydrologic statistics to be
used to evaluate existing conditions and alternative operational scenarios,
including modifications to select parameters to increase ecological
relevance to Susitna River resources, will be developed with input from the
TWG in Q1 2014. Mapping of aquatic habitats and information on the
seasonal distribution of fish within the habitats will be conducted and are
described in Section 9.9 and Section 9.6, respectively.
IFS-046 TU 11/14/2012 “The Proposed Study Plan needs to evaluate the
changes to water availability, both in quantity and
timing, that is likely to occur from climate change, and
evaluate how operation of the dam under those new
future conditions are likely to impact fish, wildlife and
The effects of glacier wastage and retreat on runoff in the Susitna basin
and changes in climate over the license term will be analyzed to estimate
annual runoff, seasonality and peak flows to simulate the inflow of water to
the proposed Susitna-Watana reservoir (see Section 7.7). Operation of the
Project under existing conditions and alternative operational scenarios will
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water resources.” –pdf page 4 be analyzed as described in Section 8.5.4.3.2.
IFS-047 USFWS 11/14/2012 “We also recommend a flow operations analysis that
will consist of a range of conditions from baseline (no
Project/natural hydrograph) to various proposed
scenarios (as described in the PAD), and alternatives
suggested by AEA and agencies in a working group
setting.” –pdf page 61
As described in Section 8.5.4.3.2, the operations model will be used to
evaluate a range of alternative operational scenarios.
IFS-048 EPA 11/14/2012 The present version of the IHA program does not
include some parameters that could be useful for
assessing change in flow regimes along the Susitna,
such as the annual center-point of discharge and some
of the indexes suggested by Graf (2006). Alternative
programs (e.g., the USGS HIT program; Henriksen et
al. 2006; Kennen et al. 2009) may include some of
these potential additional parameters (see also Olden
and Poff 2003; Poff et al. 2010). However, other
programs may not incorporate features found in the
IHA, such as the ability to analyze flows by season. As
a result, it may be better to program all or at least
supplemental Environmental Flow analyses in a stand-
alone environment, such as a statistical package or
spreadsheet program, to create a suite of analyses
tailored to the specific needs of a project. And the
PSP/RSP needs to include a rigorous assessment of
the right parameters to apply to the Susitna-Watana
system, rather take a “kitchen sink” approach (see
above). –pdf pages 15-16
As described in Section 8.5.4.4.1.3, the suite of hydrologic statistics to be
used to evaluate existing conditions and alternative operational scenarios,
including modifications to select parameters to increase ecological
relevance to the Susitna River resources, will be developed with input from
the TWG. For instance, a stand-alone statistical package will be developed
to analyze effects of hourly flow changes associated with proposed Project
load-following operations.
IFS-049 EPA 11/14/2012 Use of IHA to compare differences between
unregulated and regulated flow conditions should be
reviewed because the 33 IHA parameters represent a
'kitchen sink' of variables, some of which may not be
ecologically relevant to the Susitna-Watana Project.
Inclusion of variables that are not ecologically relevant
to the Project will give an inaccurate picture of the
Project impacts. The analysis must focus only on
The hydrologic statistics described in Tables 8.5-12 and 8.5-13 will be
reviewed with input from the TWG in Q1 2014 to identify those parameters
that are ecologically relevant to Susitna River resources (see 8.5.4.4.1.3).
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Environmental Flow Components (EFCs) that are
ecologically relevant to the project, and relevant to
each season of the annual cycle. Selection of the right
EFCs is in fact one of the most important steps in any
environmental flow assessment –pdf pages 15-16
IFS-050 NMFS 11/14/2012 "Any (HSC) criteria used from 1980s literature on the
Susitna River must include all likely factors that
influence the utilization of the habitat characteristics
the curves are used to assess. This should include at a
minimum water quality (dissolved oxygen, turbidity,
and temperature), habitat spatial structure (distance to
cover, large wood, bank and bedform
characterization), and groundwater upwelling or
downwelling in addition to the typical hydraulic
variables (flow, depth, substrate)." -pdf page 68
We agree. Data collected at sampling locations include primary factors
considered to influence fish habitat use and will consist of the following:
biological information (fish species, life stage, length, location of juvenile
fish within the water column, redd dimensions, fish position relative to cover
features and relevant comments regarding fish behavior), hydraulic data
(water depth, velocity, presence of upwelling), habitat type and structure
(macro- and mesohabitat type, substrate size and percent composition,
and cover feature type), and water quality metrics (temperature, dissolved
oxygen, turbidity, upwelling presence and temperature) (see Section
8.5.4.5.1.1).
IFS-051 NMFS 11/14/2012 "NMFS requests that only site specific HSIIHSC be
used in assessing instream flow effects to fish on
project operations; criteria from other sites (in Alaska
or other places) presents a large risk of
misrepresenting project effects to fish and their habitat.
Criteria developed outside of the Susitna and other
large southcentral rivers are not acceptable due to the
species adaptation to specific systems and because of
the lack of criteria development for glacial systems like
the Susitna River.” -pdf page 68
Habitat suitability criteria (HSC) will be developed for target species based
on data specific to the Susitna River. If site-specific data cannot be
obtained for a target species/life stage, HSC curves will be developed from
the following secondary sources, in order of preference: existing site-
specific data collected from the Susitna River during the 1980s studies;
site-specific data collected from other similar Alaska river systems; or
professional opinion (roundtable or Delphi) of local resource specialists that
are familiar with habitat use by the species and life stages of interest for
this study (see Section 8.5.4.5).
IFS-052 NMFS 11/14/2012 "To demonstrate that NMFS 2012 study requests are
being met, the PSP needs to detail how the applicant
proposes to develop site specific habitat suitability
indices/criteria for each anadromous species and life
stage (or why this necessary information cannot be
provided)." - pdf page 68
The site specific habitat criteria/indices will be produced for all target
species and life stages and is detailed in Section 8.5.4.5 ('Habitat
Suitability Criteria Development'). Proposed target species identified in this
section are: Chinook, coho, chum, and sockeye salmon; rainbow trout;
arctic grayling; Dolly Varden trout; burbot; longnose sucker; humpback
whitefish; and round whitefish. Determination of target species and life
stages will be with input from the TWG group during Q1 2013 (see Section
8.5.4.5.1).
IFS-053 NMFS 11/14/2012 “Additional areas that need more explanation of study
methods and their ability to achieve the objectives we
Potential effects of Project operation on salmon egg incubation and fry
emergence will be evaluated as part of 'Effective Spawning-Incubation
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request include a study to evaluate project effects to
salmon egg incubation, fry emergence, juvenile
migration, rearing and overwintering. Studies of river
productivity are described in our comment on the
proposed study plan for fish. Analysis of project
operations on river productivity must be included in the
instream flow analysis, specifically under the aquatic
habitat models. This analysis of river productivity
should include operations that cause rapid changes in
flow (associated with the proposed load following),
these recurring flow changes may the impact the
aquatic systems by reducing biotic productivity directly
due to flow variation or indirectly due to changes in
water depth, water quality, temperature, or sediment
transport (Chusman 1985).” –pdf page 72
Habitat Analyses' (see Section 8.5.4.6.1.5). Project effects on salmon
rearing, including winter rearing, will be addressed as part of habitat-
specific modeling (see Section 8.5.4.6) and 'Winter Habitat Use Sampling'
(see Section 8.5.4.5.1.2.1). Evaluation of effects on juvenile migration will
be completed in association with habitat-specific modeling (see Section
8.5.4.6) and Fish and Aquatic Resources (see Section 9). Effects of Project
operation on river productivity are described in Section 9.8 ('River
Productivity Study) and Section 8.5.4.5.1.2.3.
IFS-054 NMFS 11/14/2012 “Additionally, an understanding of the
surface/groundwater exchange flows will also be
needed to assess water quality in these habitats.
Biological cues are not addressed in AEA's proposed
Instream Flow Study. NMFS specifically requested a
study component to address an investigation of flow
dependent biological cues, which will rely on the
detailed study of habitat utilization by anadromous
species throughout their life history (NMFS, Instream
Flow Study Request Section 1.3.5.3). NMFS requested
an examination of instream flows that may correlate
with historical escapement indices, run timing and
seasonal water temperatures and associated biological
responses. A summary of life stage events for each of
the anadromous species should be presented in table
form, including the corresponding habitat and
hydrologic conditions. We acknowledge that a
preliminary periodicity chart was provided to attendees
of the October 4th site visit to the Susitna River, and
we appreciate the initial effort of ABA's consultants to
provide the requested information.” –pdf pages 74-75
As described in the IFS analytical framework (see Section 8.5.4.1), riverine
process studies will be integrated rather than independent in order to
evaluate Project effects on aquatic habitats. In response to the NMFS
study request, an evaluation of flow dependent biological cues has been
included in the RSP (see Section 8.5.4.5.1.3). Long-term adult salmon
escapement data will be examined to identify relationships between
temporal patterns in environmental conditions and salmon distribution,
abundance and migration. Analyses of possible relationships between
climatic, hydrologic, and fish habitat indices and salmon abundance and
migration timing will be based on available long-term data sets for Deshka
River Chinook salmon and Yentna River sockeye salmon, though other
long-term data sets pertaining to salmon migration timing and abundance
will be included if available. Implementation details will be discussed with
the TWG in Q2 2013 and study results presented in the ISR in Q1 2014.
For each target species, including all salmon species, a table will be
prepared that summarizes the periodicity of fish use, by life stage and
macrohabitat type within each Susitna River Segment (see Section
8.5.4.5.1). A draft version of the periodicity table for salmon species
(without macrohabitat types) is presented in Table 8.5-2. Periodicity tables
that depict timing of use among macrohabitat types in each Susitna River
Segment will be produced for all target species and life stages as part of
the Periodicity TM in Q1 2013. Hydrologic conditions are not included in
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species periodicity tables, however, further development of fish periodicity
and habitat utilization data and identification of data needs will occur with
input from the TWG during 2013 and 2014 (see Table 8.5-14).
IFS-055 USFWS 11/14/2012 “AEA should provide detailed methods on how it
proposes to develop site-specific habitat suitability
indices/criteria for each species and life stage. Micro-
habitat utilization directly informs the ISF decision-
making process. To gain understanding of the micro-
habitat utilization we request the use of criteria
developed specifically for the Susitna River or regional
rivers with similar habitats (for example the Talkeetna,
Chuitna, Matanuska Rivers). Micro-habitat utilization
criteria developed outside of the Susitna River and/or
other large south central rivers is not acceptable due to
differences in species adaptation to specific riverine
habitats and flow regimes. Furthermore, there is a
general lack of micro-habitat utilization criteria
development for glacial systems like the Susitna River.
Any criteria used from other sites or from 1980s
literature must include all likely variables that influence
the utilization of the habitat. These variables should
include at a minimum water quality (dissolved oxygen,
turbidity, and temperature), habitat spatial structure
(distance to cover, large wood, bank and bedform
characterization), and groundwater upwelling or
downwelling in addition to the typical hydraulic
variables (flow, depth, substrate).” –pdf pages 58-59
As described in Section 8.5.4.5.1, HSC/HSI will be developed for each
target species and life stage based on site specific data in the Susitna
River. If site-specific data cannot be obtained for a target species/life stage,
HSC curves will be developed from the following secondary sources, in
order of preference: existing site-specific data collected from the Susitna
River during the 1980s studies; site-specific data collected from other
similar Alaska river systems; or professional opinion (roundtable or Delphi)
of local resource specialists that are familiar with habitat use by the species
and life stages of interest for this study (see Section 8.5.4.5). HSC curves
were developed during the 1980s for depth, velocity, substrate, cover,
turbidity and upwelling, though the extent of parameters measured and
analyzed varied by species (see Table 8.5-1). The development of
HSC/HSI data and determinations of the need for and applicability of 1980s
data to supplement site specific data collected during 2012-2014 will occur
with input from the TWG (see Section 8.5.4.5.1).
IFS-056 ADNR-
ADF&G
11/14/2012 “An analysis is needed on Middle River areas
susceptible to fish stranding and trapping. Hunter
(1992) cites 2 studies that indicate stranding can occur
on low gradient areas, less than 4 percent (Bauersfeld
1978) and 5 percent (Beck Associates 1989). A
topographical survey of potential stranding areas is
needed with modeling at hourly time increments to
assess stranding and trapping potential. Simulation
should include existing and alternative operation
Section 8.5.4.5.1.2.2, Section 8.5.4.6.1.1.4, and Section 8.5.4.6.1.6.1
provide a detailed description of the theory, sampling methods, and
analysis of the potential impacts of alternative Project operational scenarios
on stranding and trapping of juvenile fish. Stranding and trapping analysis
will be completed in conjunction with and rely on and incorporate data
developed as part of the flow routing model, varial zone modeling,
bathymetric and digital terrain modeling, and juvenile fish surveys.
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scenarios under normal, dry and wet hydrologic
conditions. Factors that may contribute to stranding
and/or trapping should be considered including:
aquatic species/life stage, cover, duration of a
stranding/trapping event, and time of year.” – pdf
pages 21-22
IFS-057 USFWS 11/14/2012 “Biological cues are not addressed in AEA’s proposed
instream flow study. The Service’s study request
included a component to investigate flow dependent
biological cues, which will rely on the detailed study of
seasonal habitat utilization by anadromous species
and resident fish throughout their life history. Our
request included an examination of instream flows that
may correlate with historical escapement indices, run
timing and seasonal water temperatures and
associated biological responses. A periodicity chart for
each of the anadromous species should was identified
as an information gap related to fish species of the
Susitna River. This information should be presented in
table form and include the corresponding macro-
habitat and hydrologic conditions. We acknowledge
that a preliminary periodicity chart was provided to
attendees of the October 4th site visit to the Susitna
River, and appreciate AEA’s effort of to provide the
requested information. We look forward to working with
AEA to expand the scope and detail of the periodicity
chart.” –pdf page 63
In response to the USFWS study request, an evaluation of flow dependent
biological cues has been included in the RSP (see Section 8.5.4.5.1.3).
Long-term adult salmon escapement data will be examined to identify
relationships between temporal patterns in environmental conditions and
salmon distribution, abundance and migration. Analyses of possible
relationships between climatic, hydrologic, and fish habitat indices and
salmon abundance and migration timing will be based on available long-
term data sets for Deshka River Chinook salmon and Yentna River
sockeye salmon, though other long-term data sets pertaining to salmon
migration timing and abundance will be included if available.
Implementation details will be discussed with the TWG in Q2 2013 and
study results presented in the ISR in Q1 2014. For each target species,
including all salmon species, a table will be prepared that summarizes the
periodicity of fish use, by life stage and macrohabitat type within each
Susitna River Segment. A draft version of the periodicity table for salmon
species (without macrohabitat types) is presented in RSP Table 8.5-2.
Periodicity tables that depict timing of use among macrohabitat types in
each Sustina River Segment will be produced for all target species and life
stages as part of the Periodicity TM in Q1 2013. Hydrologic conditions are
not included in species periodicity tables, however, further development of
fish periodicity and habitat utilization data and identification of data needs
will occur with input from the TWG (see Section 8.5.4.5.1).
IFS-058 ADNR-
ADF&G
11/14/2012 “Dissolved oxygen should also be measured as a
parameter for HSC and HSI development.” –pdf page
20
Dissolved oxygen will be measured in association with HSC/HSI sampling
efforts using hand-held probes and continuous monitoring loggers (see
Section 8.5.4.5.1).
IFS-059 NMFS 11/14/2012 “Habitat suitability indices (HSI) and criteria (HSC)
should be developed from an analysis of which
environmental criteria influence fish habitat use in the
Susitna River system. The criteria should explain the
Habitat suitability indices (HSI) and criteria (HSC) will be based upon data
specific to the Susitna River and will be developed for target species, life
stages and macrohabitats (e.g., main channel/side channel/side slough,
clear/turbid water, upwelling presence/absence) such that multiple curves
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distribution, condition, and growth rates of anadromous
fish in the river system, for each species and life stage.
Site specific habitat criteria should be evaluated in the
context of the hierarchical habitat framework, such that
habitat criteria are determined and evaluated in all
habitats of importance to each agreed-upon target
species and life stage. NMFS recommends the
determination of which criteria are important prior to
model selection. Fish behavior is not addressed in the
PSPs; study of the energetic consequences of these
behaviors must be conducted to ensure that
bioenergetic criteria used to define fish habitat quality
do not depend on arbitrary assumptions about fish
activity costs (Boisclair 2001).” –pdf page 67
will be generated for certain species and life stages (see Section 8.5.4.5.1).
Data collected at HSC sampling locations will include primary factors
considered to influence fish habitat use and sites will be randomly selected
among available aquatic habitats. A stratified random site selection
approach will be used to ensure that data collection sites cover the range
of conditions within all habitat types in the Susitna River (see Section
8.5.4.5.1.1.3). Habitat suitability data for agreed upon target species and
life stages will be developed with input from the TWG (see Section
8.5.4.5.1). While we agree that HSC/HSI should explain fish distribution, it
is not clear that these metrics determine fish condition and growth; there
are environmental (e.g., air temperature, precipitation), biological (e.g.,
genetic composition) and behavioral factors (e.g., intra- and inter-specific
competition) irrespective of the proposed criteria that have been shown to
affect fish condition and growth. Observations of fish behavior will be
recorded during winter to identify potential diurnal patterns in habitat use,
which will inform HSC/HSI development. HSC/HSI are approximations of
the biological response of fish to physical habitat conditions (i.e., depth,
velocity, substrate, water quality, upwelling). Relationships between fish
behavior, growth and aquatic habitat will be evaluated in association with
bioenergetic modeling described in Section 9.8.4.5.
IFS-060 NMFS 11/14/2012 “In our study requests (NMFS 2012), NMFS asked for
specific criteria for each life stage for anadromous
species; if guilds are going to be used, the habitat
utilization data must be shown to support this method.
A list of criteria to collect at fish sampling locations and
at the focus areas should include the following:
• hydraulic information (depth and velocity);
• water quality parameters (temperature, dissolved
oxygen, turbidity, possibly others);
• groundwater characterization (upwelling/downwelling,
temperature and chemistry of upwelling water);
• substrate (size distribution and facie mapping);
• spatial structure of the habitat;
We agree; the use of guilds will only be used if supported by site-specific
utilization data. Data collected at sampling locations include primary factors
considered to influence fish habitat use and will consist of the following:
biological information (fish species, life stage, length, location of juvenile
fish within the water column, redd dimensions, fish position relative to cover
features and relevant comments regarding fish behavior), hydraulic data
(water depth, velocity, presence of upwelling), habitat type and structure
(macro- and mesohabitat type, substrate size and percent composition,
and cover feature type), and water quality metrics (temperature, dissolved
oxygen, turbidity, upwelling presence and temperature) (see Section
8.5.4.5.1.1). HSC curves will be developed by species and life stage based
on stream-specific data (e.g., macrohabitat type, clear vs turbid water,
upwelling sites) such that multiple curves will be generated for certain
species and life stages (see Section 8.5.4.5.1.1.7). A stratified random site
selection approach will be used to ensure that data collection sites cover
the range of conditions within all habitat types in the Susitna River (see
Section 8.5.4.5.1.1.3). Variance and confidence intervals associated with
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• cover availability; and
• indicators of productivity, etc.
The micro-habitat data must be collected at all macro-
habitat habitat types, with mesohabitats represented in
each macro-habitat with replication. This will result in
seasonal curves for each species or subset of species
and life stages for each macro-habitat. Criteria to be
used must be developed over a range of
representative habitats for which they will be used.
Also, criteria used in flow habitat analysis of project
effects must be demonstrated to have a statistically
significant relationship to habitat utilization for the time
of year, life-stage, and habitat for which it will be used.”
-pdf page 69
each HSC data set will be determined during bootstrap analyses (see
Section 8.5.4.5.1.1.8).
IFS-061 ADNR-
ADF&G
11/14/2012 “information is needed on criteria that will be used to
identify cover types and substrate sizes.” –pdf page 20
Cover types to be used in association with HSC/HSI data collection are:
boulder (> 10 inch diameter), large wood debris (> 4 inch diameter, > 10
feet long), aquatic vegetation, undercut bank, overhanging vegetation (<
3.3 feet of water surface), and water depth (> 3.3 feet depth) (see Section
8.5.4.5.1). Substrates will be classified using a Wentworth grain scale
modified to reflect English units of measurement (see RSP Table 8.5-17).
IFS-062 ADNR-
ADF&G
11/14/2012 “Information is needed on equipment that will be used
and calibration protocols.” –pdf page 21
Equipment to be used in association with habitat specific HSC/HSI data
collection will include: Price AA current meters for water velocity
measurement, portable hand-held temperature probes for instantaneous
measurement of surface streamflow and groundwater upwelling
temperatures, portable hand-held dissolved oxygen probes, portable
turbidity meters (see Section 8.5.4.5.1). In addition to the above listed
materials, equipment to be used during studies of winter fish behavior,
habitat utilization, and water quality sampling will include: continuously
monitoring temperature loggers to measure surface and intergravel water
temperature, continuously monitoring dissolved oxygen loggers to record
intergravel dissolved oxygen levels and continuously monitoring surface
water and groundwater stage recorders (see Section 8.5.4.5.1.2.1).
Procedures for accuracy testing and/or calibration of this equipment are
described in the identified Sections associated with each effort.
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IFS-063 USFWS 11/14/2012 “The Service’s study request specified the need for
habitat specific criteria for each species and life stage.
If guilds are proposed the habitat utilization data must
be shown to support this method. A list of criteria to
collect at fish sampling locations and at the focus
areas should include hydraulic information, water
quality parameters, groundwater information,
substrate, spatial structure and arrangement of the
habitat, cover availability, and indicators of productivity,
etc. The data must be collected at all macro-habitat
habitat types, with meso-habitats represented in each
macro-habitat with replication. This will result in
seasonal curves for each species or subset of species
and life stages for each macro-habitat. Criteria to be
used must be developed over a range of
representative habitats for which they will be used.
Also, criteria used in flow habitat analysis of Project
effects must be demonstrated to have a statistically
significant relationship to habitat utilization for the time
of year, life-stage, and habitat for which it will be used.”
–pdf page 59
See AEA’s response to comment IFS-60.
IFS-064 USFWS 11/14/2012 “We recommend AEA assess patterns of habitat
utilization within each macro-habitat to identify the
appropriate tools for assessing flow-habitat
relationships. This is necessary to identify the micro-
habitat variables that control the distribution of fish.
Habitat availability and patterns of habitat utilization
have not yet been systematically assessed in a
statistically valid manner in the Susitna River
floodplain. It is inappropriate to develop habitat
suitability criteria (HSC) without first assessing which
habitat criteria influence the distribution of fish. AEA
should provide a detailed process for assessing fish
species habitat utilization and influential habitat
variables that will then inform Project-effects on fish
and their habitat.” –pdf page 57
We agree that a statistically valid sampling approach is necessary. In
regards to HSC/HSI data collection, a stratified random site selection
approach will be used across geomorphic reaches, macro- and
mesohabitats in each Susitna River Segment to ensure that sampling sites
cover the range of conditions within all habitat types (see Section 8.5.4.5).
Data collected at sampling locations will include primary factors that are
considered to influence fish habitat use and will consist of the following:
biological information (fish species, life stage, length, location of juvenile
fish within the water column, redd dimensions, fish position relative to cover
features and relevant comments regarding fish behavior), hydraulic data
(water depth, velocity, presence of upwelling), habitat type and structure
(macro- and mesohabitat type, substrate size and percent composition,
and cover feature type), and water quality metrics (temperature, dissolved
oxygen, turbidity, upwelling presence and temperature) (see Section
8.5.4.5.1.1). Determination of necessary fish habitat utilization criteria and
development of HSC/HSI data will occur with input from the TWG (see
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Section 8.5.4.5.1).
IFS-065 ADNR-
ADF&G
11/14/2012 “We support the addition of lateral edge habitat
evaluation for assessing aquatic resource effects in
this habitat. More information is needed on the
sampling approach, sampling area, equipment, etc.” –
pdf page 20
The extent and distribution of lateral habitats (off-channel areas) will be
determined as part of the Characterization and Mapping of Aquatic
Habitats (see Section 9.9.5) using IFSAR 20-foot contour topographic data,
low altitude aerial video, LiDAR imagery, cross-sectional profiles, and the
2012 geomorphic mapping of channel types as applicable (see Section
6.5.4.5). Analysis of off-channel habitat surface area versus mainstem flow
relationships will be completed over a range of flows (e.g., 5,100 to 23,000
cubic feet per second [cfs] measured at Gold Creek gage (~RM 134) in the
Middle River (see Section 6.5.4.5). Predicting and defining the connectivity
of off-channel habitats with mainstem river flow will be completed as part of
the breaching flow analysis (see Section 9.12).
IFS-066 ADNR-
ADF&G
11/14/2012 “We support the HSC/HSI data collection objective.
Information is needed for identified target species over
multiple years to incorporate habitat variability
associated with utilization. Further discussion is
needed on the selection of these species and data
needs. Site-specific HSC/HSI data is critical to obtain
meaningful results and may entail consideration of
alternative strategies to meet these data needs.” –pdf
page 20
As described in Section 8.5.4.5, HSI data will be collected in defined
habitat types over 2 years. HSC/HSI data collection efforts were initiated as
a pilot program in 2012 and will continue in 2013 and 2014. HSC/HSI data
collected during 2012-2014 will be specific to the Susitna River and will be
supplemented, if necessary, by site-specific HSC/HSI data collected in the
early 1980s. Selection of target fish species and life stages and
development of HSC/HSI data will occur with input from the TWG (see
Section 8.5.4.5.1).
IFS-067 FERC 11/14/2012 “In section 9.6.4.1, Study Site Selection, and section
9.6.4.3.1, Objective 1, Fish Distribution, Relative
Abundance, and Habitat Associations, you state that
winter sampling sites and sampling methods will be
selected based on information gathered from a pilot
study in winter 2012-2013 at Whiskers Slough and
Slough 8A. Please include in your RSP a detailed
description of the pilot study and provide a schedule
for when the results will be finalized and incorporated
into your study methods for winter fish distribution
sampling in 2013 and 2014.” –pdf page 14
The pilot 2012-2013 winter study is described in Section 8.5.4.5.1.2.1.
Results from 2012-2013 pilot studies will be finalized and distributed to the
TWG by Q3 2013 and will be included in the ISR in Q1 2014 (see Table
8.5-15). Study methods for the 2013-2014 winter fish distribution study,
which will incorporate 2012-2013 pilot study results, will be completed by
Q3 2013.
IFS-068 ADNR-
ADF&G
11/14/2012 “Intergravel, over-winter temperature monitoring of
redds should be expanded to include measurements of
We agree. As described in Section 8.5.4.5.1.2.1, intergravel dissolved
oxygen levels in spawning sites will be monitored during 2012-2013 winter
studies using a continuously recording DO logger that will be deployed
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dissolved oxygen.” –pdf page 21 approximately 20 centimeters (7.9 inches) below the substrate surface.
Instantaneous measurements of surface water DO will also be measured
using hand-held probes during 2012-2013 Winter Studies.
IFS-069 NMFS 11/14/2012 "After model selection, population, calibration and
scenario runs a variety of post processing comparative
analyses derived from the output metrics estimated
under the habitat specific aquatic habitat models will
be provided to resource agencies. These include (but
are not necessarily limited to) the following:
comparisons of habitat quantity and quality, ramping
rates, juvenile fish stranding/trapping, habitat
sustainability and distribution and abundance of
benthic macro invertebrates under alternative
operational scenarios." -pdf page 73
See AEA’s response to comment IFS-084.
IFS-070 AHP, AS,
CSDA, NHI,
HRC
11/14/12 "The potential of fluctuating flow to displace fish
laterally as well as downstream should also be
ascertained, because displacement may increase the
overall mortality rate of the juvenile salmon
populations." Stage fluctuations will cause increased
fish movement, which may indirectly cause increased
juvenile fish mortality rates due to increased predation,
movement to unsuitable habitats, and reduced body
condition. -pdf pages 9-10
The IFS study will measure the potential for direct effects of fluctuation flow
on fish habitat and in particular baseline conditions regarding stranding and
trapping of juvenile fishes (see Sections 8.5.4.5.1.2.2 and 8.5.4.5.1.2.3). In
addition, there are specific objectives in the Fish Distribution and
Abundance Middle and Lower Susitna River Study plan that will document
baseline conditions for movement patterns of juvenile salmon from
spawning to rearing habitats (see Section 9.6.4.3.3) and will describe diel
behaviors of fish (see Section 9.6.4.3.3). These baseline data will provide
information relevant for addressing potential effects of fluctuating flows. To
the best of AEA’s knowledge there is no model or accepted scientific
approach that would allow for predictions as to how potential flow
fluctuations would directly affect fish movements and subsequent indirect
consequences of those movements as the result of fish moving into future
habitats with uncertain ecological conditions.
IFS-071 ADNR-
ADF&G
11/14/2012 “An analysis of natural Susitna River stage changes
over the available period-of-record is needed similar to
the analyses presented in Hunter (1992). At a
minimum, the data should be tabulated similar to
results provided in Hunter (1992), Tables 1 and 2.” –
pdf page 21
Varial zone modeling (see Section 8.5.4.6.1.6) and time series analysis
(see Section 8.5.4.7.1) will be used to assess the rate and magnitude of
stage change under both natural and with Project operational flow
scenarios. The result of these analyses will be presented as a tabular list of
rate of stage change (inches per hour) and habitat quantities (time series)
under different flow levels for each of the target species and life stages.
IFS-072 ADNR- 11/14/2012 “For PHABSIM and similar transect-based methods, Habitat modeling is expected to represent a combination of dependent and
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ADF&G will transects be hydraulically independent, dependent
or a combination and accordingly, what water surface
elevation models and composite suitability index will be
used?” –pdf page 20
independent techniques. The selection of PHABSIM modeling techniques
will be determined in 2nd Quarter 2013, with input from the TWG (see
Section 8.5.4.6). Model selection will be based on the hydraulic
characteristics of each site and the information needed to address Project
effects. For instance, the use of 2-D modeling techniques will involve
dependent water surface modeling techniques. The mainstem flow routing
model, used to calculate site boundary conditions, will represent a
combination of dependent and independent transect calculations.
IFS-073 FERC 11/14/2012 “In section 8.5.4.5.1.2.2, Stranding and Trapping, you
describe some of the factors influencing stranding and
trapping, and indicate that the calibrated flow-routing
model will be used. In section 8.5.4.6.1.6, you indicate
that a varial zone model will be used to assess
stranding and trapping. It is not clear how you will use
these models to assess stranding and trapping. Please
include a complete description of how stranding and
trapping will be evaluated. Specifically, please provide
more detail on the models proposed, the extent of
modeling, and whether multiple modeling approaches
will be used (e.g., 1-D modeling at the reach-scale and
2-D modeling within focus areas).” -pdf page 10
Assessment of potential stranding and trapping of juvenile fish related to
Project operations will utilize results of flow routing modeling, bathymetric
mapping, 1-D and 2-D hydraulic modeling, and HSC/HSI curve
development. Sections 8.5.4.5.1.2.2 and 8.5.4.6.1.6 provide a detailed
description of how information and data from each of these data sources
will be used to evaluated stranding and trapping as part of the varial zone
modeling (see Section 8.5.4.6.1.6) that is proposed for at each of the
Focus Areas.
IFS-074 FERC 11/14/2012 “In section 8.5.4.6, Habitat-Specific Model
Development, you outline a number of models and
analyses. As part of these analyses, it will be important
to understand how project operations will change the
natural hydrograph, how project operations will change
habitat availability in relation to life history timing of fish
and aquatic species, and how these changes influence
the spatial location of available habitat. In your
proposed assessment of spawning and incubation, it
will be important to understand the extent that suitable
habitat shifts are expected as a result of proposed
project operations. For example, if flows during the
Chinook salmon spawning period are managed lower
than they would be under existing conditions, certain
locations currently used by Chinook for spawning may
Potential habitat shifts in response to Project operations will be addressed
through an evaluation of flow effects on the range of habitats available
under existing, unregulated flows and habitats that become available under
alternative operational scenarios. As described in Section 8.5.4.2.1.2-
Selection of Study Areas/Study Sites, habitat modeling will be conducted in
areas selected to be representative of the range of physical conditions in
each geomorphic reach. Operations modeling (Section 8.5.4.3.2) will
quantify flow releases under existing and alternative operational scenarios
and Section 6.6-Fluvial Geomorphology Modeling will quantify changes in
the distribution of mesohabitat units. Habitat modeling results will be
compiled by mesohabitat unit (Section 8.5.4.7) and will quantify potential
habitat shifts. Load-following operations increase the magnitude,
frequency, duration, and timing of stage changes. Fish inhabiting areas of
repeated inundation and dewatering, termed the varial zone, are exposed
to potential stranding, trapping, reduced food supply and energy
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no longer be available; however, new areas not
currently used but that meet the spawning habitat
criteria for Chinook may become available at the lower
managed flow. Such habitat shifts may result in, for
example, spawning in locations that are more
susceptible to scour, or spawning locations that are no
longer close to suitable rearing habitats. We have
similar concerns with regard to the assessment of
rearing habitat under load following operations. Data
developed from these studies will need to provide an
understanding the spatial extent of movement required
by salmon, as well as the continuity of available habitat
over the range of flow fluctuations. Therefore, please
specify how your data analysis and reporting will
consider the spatial shifts in suitable habitat.” –pdf
page 11
expenditure. Varial zone modeling (Section 8.5.4.6.1.6) is designed to
quantify the extent of the varial zone and stability of available habitats for
three time scales under existing conditions and alternative operational
scenarios.
IFS-075 FERC 11/14/2012 “In section 8.5.4.6.1.5, [AEA describes] the effective
spawning/incubation habitat analysis to evaluate the
risk of dewatering and scour. The level of detail
provided to address this issue is insufficient to
determine the adequacy of the approach. In [AEA’s]
RSP, please provide a detailed description of the
model including the model framework, input
parameters, where the input data is derived (i.e., other
models or studies), the area over which the model will
be applied, critical model assumptions, the output from
the model, and how it will be used to inform the
evaluation of project effects.” –pdf page 12
Significant detail has been added to Section 8.5.4.6.1.5, Effective
Spawning/Incubation Habitat Analyses. The model framework is shown in
Figure 8.5-32. Analyses of potential salmonid spawning areas within Focus
Areas will include input from Section 7.5-Groundwater Study, Section 6.6
Fluvial Geomorphology Modeling below Watana Dam Study, and Section
5.6-Water Quality Modeling Study. As described in Section 8.5.4.6.1.5,
model assumptions include duration of spawning, egg incubation and
alevin life stages, minimum water depth for spawning, and mortality rates of
eggs exposed to dewatering, scour, low oxygen and reductions in
groundwater upwelling. The results of the analyses will provide quantitative
habitat indicators under existing and alternative operational scenarios.
IFS-076 ADNR-
ADF&G
11/14/2012 “Information is needed on flow ranges that will be
collected to evaluate flow-habitat relationships for each
modeling approach.” –pdf page 20
Three stage-discharge data sets, collected at flow levels of approximately
8,000 cfs, 16,000 cfs and 28,000 cfs at the USGS gage at Gold Creek (No.
15292000), will be used to establish Focus Area boundary conditions. As
described in Section 8.5.4.6-Habitat Specific Model Development, various
models may need additional stage and flow data to develop habitat-specific
analyses; data requirements for each model are described in the specific
section. For example, stage recorder data at select off-channel habitats
and adjacent main channel areas will be needed to establish the
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relationship between mainstem and off-channel flow and stage for habitat
connectivity and breaching flows (see Section 8.5.4.6.1.2.3).
IFS-077 FERC 11/14/2012 “It is not clear what is being proposed and under which
studies it is being proposed to assess effects of load-
following operations on upwelling and groundwater
dynamics related to egg incubation and emergence
survival. In section 7.5.4.6, Aquatic Habitat
Groundwater/Surface-Water Interactions, you indicate
that work will be accomplished by the instream flow
study. However, in the Fish and Aquatics Instream
Flow Study (8.5), you no longer include a study to
evaluate the effects of load-following operations on
upwelling and groundwater dynamics related to egg
incubation and emergence survival. In your RSP,
please describe what models are proposed; over what
area they would be applied; what parameters would be
modeled; how and where the parameters are derived;
which parameters are based on field measurements;
what assumptions will be made to determine how
those conditions will change with project operations;
and how the modeling will be used or integrated with
other models (e.g., effective spawning and incubation)
to evaluate the effects of project operation on egg
incubation and emergence survival.” –pdf page 12
Several studies are being proposed to assess the effects of load-following
operations on upwelling and groundwater dynamics related to egg
incubation and emergence survival including effective spawning/incubation
analysis (see Section 8.5.4.6.1.5), varial zone modeling (see Section
8.5.4.6.1.6), winter habitat use (see Section 8.5.4.5.1.2.1), and
Groundwater Study (see Section 7.5). Specific details on study area, data
needs, model parameters, and assumptions are presented for each of the
proposed studies. Analysis of the temporal and spatial effects of load-
following on the habitat-flow relationships in the Susitna River will be
completed using several different tools including habitat-time series
analysis, habitat duration curves, and extrapolation methods presented in
Section 8.5.4.7.
IFS-078 USFWS 11/14/2012 “The Service agrees that properly chosen, integrated
aquatic habitat models can be informative, and with
relevant site-specific data this component of
operational instream flow analysis can be biologically
meaningful. However, AEA’s selection of a traditional
hydraulic habitat model to assess the instream flow
objectives for this Project may be premature.
Environmental criteria that influence patterns of habitat
utilization within the greater distributions of target
species and life stages need to be identified first. This
procedural pre-requisite may demonstrate that
hydraulic habitat modeling is not the appropriate tool
Identifying and quantifying the predicted changes in aquatic habitat in the
Middle and Lower Segments of the Susitna River under the proposed
Project operational scenarios will require the use of several different
hydraulic and biological models. The mainstem aquatic habitat model
integrates hydraulic modeling, channel bathymetry, and biological
information on the distribution, timing, abundance, and suitability of habitat
to estimate metrics (such as varial zone area and frequency of inundation
and dewatering) that will be used to compare the effects of the proposed
operational scenarios. Section 8.5.4.6.1.1 provides an overview of the
habitat and hydraulic models proposed for as part of the evaluation of
Project related effects including boundary conditions transects, 2-
Dimensional (2-D) modeling, single transect PHABSIM, stranding and
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for use in forecasting the environmental impact of the
proposed Project.” -pdf pages 59-60
trapping, and fish passage/connectivity. The selection of specific habitat
models will be made following a careful review of the approaches used
during the 1980s studies, and a review of contemporary methods available
for addressing the objectives of the instream flow study. AEA will seek
TWG input on habitat model selection during Q2 2013 (see Section 8.5.4).
IFS-079 USFWS 11/14/2012 “Thresholds of lateral connectivity need to be identified
and monitored through the use of remotely sensed
media and local instrumentation. Aerial and satellite
photography can be utilized from a range of seasonal
flow conditions (Benke et al. 2000) to assess patterns
of hydrologic connectivity across the Susitna River
floodplain. LiDAR data can be used interactively with
hydraulic modeling to model patterns of hydrologic
connectivity with even greater resolution.” –pdf page
54
Lateral connectivity will be identified through a combination of remote
sensing and on-site data collection. The extent and distribution of lateral
habitats (off-channel areas) will be determined as part of the Fisheries and
Aquatic Resources Study (see Section 9.9.5) using IFSAR 20-foot contour
topographic data, low altitude aerial video, LiDAR imagery, cross-sectional
profiles, and the 2012 geomorphic mapping of channel types (see Section
6.5.4.5). Defining the connectivity of off-channel habitats with main channel
flow will be completed as part of the breaching flow analysis (see Section
8.5.4.6.1.2.3, and Section 9.12.
IFS-080 FERC 11/14/2012 “Understanding the effects of load following on fish egg
incubation, egg and alevin survival, stranding, and
entrapment will be critical to our analysis of the project.
To address the potential for adverse effects from load
following on fisheries resources, you propose to
develop aquatic habitat models (e.g., effective habitat
and varial zone modeling) to produce metrics such as
frequency and duration of exposure/inundation of the
varial zone at selected locations. More detail on these
models is required to determine whether your
approach will be sufficient to evaluate project effects.
Please provide a detailed description of the proposed
models, spatial extent of modeling, required input
parameters, source of input parameters (e.g.,
literature, another model), model output, and how
results will be analyzed. For all models, especially
those based on values in the literature, a sensitivity
analysis should be included to identify those
parameters with the greatest effect on model results so
that uncertainty in these critical parameters can be
Section 8.5.4.6 provides a detailed description of the specific models,
proposed sampling area, data collection needs and methods, analyses,
calibration, and metrics for evaluation of potential Project impacts to
spawning/incubation habitat and stranding and trapping of juvenile fish.
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evaluated.” –pdf pages 10-11
IFS-081 ADNR-
ADF&G
11/14/2012 “We support and agree with the approach proposed for
using 2-D modeling in the main channel and other
areas as appropriate for sampling focus areas.” –pdf
page 21
To assist with the assessment of potential Project effects, 2-D hydraulic
modeling will be used to evaluate the detailed hydraulic characteristics of
the Susitna River on smaller, more local scales where it is necessary to
consider the more complex flow patterns to understand and quantify project
affects under various Project operation scenarios. The 2-D model will be
applied to specific Focus Areas that are representative of important habitat
conditions and the various channel classification types. These sites will be
chosen with input from the TWG and the Fish and Aquatics Instream Flow
Study, Riparian Instream Flow Study, Ice Processes in the Susitna River
Study, and Fish and Aquatics studies to facilitate integration of available
information between the studies (see Section 8.5.4.2). A detailed
discussion of the 2-D modeling is presented in Section 6.6.
IFS-082 ADNR-
ADF&G
11/14/2012 “We support the use of varial zone modeling to assess
effective spawning/incubation habitat. Modeling
simulations may need smaller time steps during the
analysis phase (possibly down to 15-minute
increments) depending on the rate of flow change over
time with proposed operation scenarios.” –pdf page 21
Time-step increments, used to calculate stage changes, will be identified
during calibration of the Mainstem (Open-water) Flow Routing Model in 4th
Quarter 2012 (see Section 8.5.4.3). Depending on the initial calibration
results, time steps as short as 3-minutes may be needed to match
predicted to measured stage changes. In 2014, the calibrated flow routing
model will be used to evaluate the effects of Project operations using 1-
hour time-steps unless the Technical Workgroup (TWG) determines that
shorter time steps are needed to evaluate specific fisheries resources.
IFS-083 ADNR-
ADF&G
11/14/2012 “What criteria will be used to select and weight
transects used to provide information for habitat-flow
models?” –pdf page 20
With input from the TWG and riverine process study leads, transect
selection within each Focus Area will be based on known fish use (see
Section 9), habitat composition (see Section 9.9), groundwater– aquatic
habitats (see Section 7.5), river access, and sampling safety will all be
considered. Additional habitat transects/segments will be selected to
describe distinct habitat features such as groundwater areas, spawning
and rearing habitats, overwintering habitats, distinct tributary
mouths/deltas, and potential areas vulnerable to fish trapping/stranding.
The transects used for defining the flow routing model will also be
integrated into this analysis. Results of sites that are modeled using either
1-D (i.e., transect) or 2-D techniques will be extrapolated to non-modeled
sites based on the proportion of habitat area they represent within the
geomorphic reach. If biological studies indicate that specific habitat types
are highly important to a species, the weighting of modeling results from
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those habitat types will be given priority as determined with input from the
TWG Q3 2014.
IFS-084 NMFS 11/14/2012 NMFS expects that the applicant will develop
integrated aquatic habitat models that produce a time
series of data for a variety of biological metrics under
existing conditions and alternate operational scenarios.
These metrics include (but are not limited to) the
following: water surface elevation at selected river
locations, water velocity within study site subdivisions
(cells or transects) over a range of flows during
seasonal conditions, varial zone area, frequency and
duration of exposure/inundation of the varial zone at
selected river locations; and habitat suitability indices."
-pdf page 73
The IFS will result in the collection of data and development of different
types of habitat-flow relationships including but not limited to those founded
on PHABSIM that depict WUA or habitat versus flow by species and life
stage; effective habitat versus discharge relationships that define how
spawning and incubation areas respond to flow changes; and varial zone
analysis that quantifies areas of stranding and trapping relative to flow
change. Additional components that will factor into the habitat – flow
relationships will include those associated with water temperature, turbidity,
and groundwater. These relationships will be part of the analytical
framework that will be used in evaluating the operational effects of the
Project (see Section 8.5.4.8). This will require both a temporal analysis that
focuses on how the various habitat response variables change with flow
over biologically important time periods (i.e., periodicity), and a spatial
analysis that can be used for expanding or extrapolating results from
measured to unmeasured habitats within the river. Section 8.5.4.7 provides
a detailed description of how each of the aquatic habitat models will be will
be used in evaluating operational effect of the Project on different habitats.
IFS-085 USFWS 11/14/2012 “Instead we recommend the use of lateral hydrologic
connectivity modeling (e.g. Benke et al 2000) in
combination with hydrologic-based methods, such as
USGS’s HIP model, to quantitatively inform natural
patterns of hydrologic connectivity with habitats known
to be important for target species and life stages.” –pdf
page 60
See AEA’s response to comment IFS-080.
IFS-086 ADNR-
ADF&G
11/14/2012 “An analysis and discussion of results on how
proposed operations will affect fish and other aquatic
organisms including but not limited to: juvenile
emigration (salmonid drift), spawning interference
(conditions that may affect the ability of fish to
successful complete spawning without
interference/interruption from flow related effects), and
effects on aquatic invertebrates.” –pdf page 22
This comment relates to stranding and trapping which is described in detail
in Sections 8.5.4.6.1.1.4 and Section 8.5.4.6.1.6.1. The results from the
varial zone modeling and the stranding and trapping studies will be
included in the Integrated analysis described in Section 8.5.4.8.
IFS-087 ADNR- 11/14/2012 “How will the data be aggregated from the different Results from the different habitat models, as well as models from other
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ADF&G models to evaluate single flow recommendations?” –
pdf page 21
resource disciplines will be used to select a suite of indicator variables that
will be applied in evaluating overall project effects. This process is
described further in Section 8.5.4.8. Methods for completing temporal and
spatial analysis of the models are described in Section 8.5.4.7.
IFS-088 USFWS 11/14/2012 “Study efforts at the focus areas should provide a
greater understanding of potential Project effects on
riverine processes. The site extrapolation methods
should allow for extending the understanding from the
selected reaches to the overall Project area. These
methods should be defined prior to selecting focus
areas to ensure that focus areas are selected that will
work for extrapolation.” –pdf page 56
The methods for spatial analysis and the extrapolation of results from
modeled to un-modeled areas are generally described in Section
8.5.4.7.1.2. As noted in that section, this analyses will be challenging for
the Susitna River given its length, widely variable size (width), diverse
geomorphologies, and complex habitat types. The approach considers the
distinctiveness of the different habitat types within a given area and at the
same time the similarity of these habitat types to other areas. Development
of habitat – flow relationships for specific habitat types (e.g. side channel,
side slough) and mesohabitat types (riffle, run, pool, etc.) from one area
should then, with appropriate adjustment for dimensional differences and
other distinguishing factors, be expandable to unmeasured areas
containing similar characteristics. The Focus Areas identified in the RSP
were selected in part due to their representativeness of other habitat types
in the river (see Section 8.5.4.2.1.2) and therefore should be appropriate
for scaling up to other areas. However, as noted in that discussion, these
areas are subject to review and may be modified based on results of
habitat mapping completed in Q1 2013.
IFS-089 USFWS 11/14/2012 “The Service requested both biologically relevant
instream habitat models and spatial scaling of study
sites; both the model and study sites should be
selected with a thorough understanding of anadromous
and resident fish distribution in the Susitna River
system, including life history strategies, habitat
utilization, and interannual variability. Related to this
objective AEA describes an Instream Flow Study
analytical framework (AEA, 6.5.4.1).” –pdf page 60
The selection of habitat models is described in Section 8.5.4.6. How model
results would be spatially evaluated is described in Section 8.5.4.7. See
also AEA’s response to comment IFS-088.
IFS-090 NMFS 11/14/2012 “This will require that the sites be statistically
representative and have replication to allow for
extrapolation of results based on metrics not yet
determined or described. Methods on how to select
representative reaches was not provided in the PSP or
Please see AEA’s Response to comment IFS-020.
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TWG meetings, what was suggested was using
professional judgment. We believe that sites should be
selected randomly and be reproducible, that enough
sites are selected to capture the variability for each
geomorphic reach, and to allow for replication. This will
require, at a minimum, mapping of the macrohabitat
types and delineation of each of the geomorphic
reaches, both described as in progress at TWG but not
described in the PSPs.” –pdf page 63
IFS-091 CSDA 11/14/2012 “A minimum of 2 years is needed to establish the site-
specific Habitat Suitability Index (HIS) curves needed
for all target fish species.” –page 3
See AEA’s response to comment IFS-095.
IFS-092 NMFS 11/14/2012 “Finally, we are concerned that the duration of the
proposed studies will not represent the range of
conditions that occur naturally. Habitat-flow
relationships should be developed over a temporal
scale long enough to capture natural variability. The
current time frame may not allow for capturing
variability in fish-habitat relationships, or for obtaining
fish distribution data under various flow and biologic
conditions (low and high escapement, range in
temperature and precipitation years, range in Pacific
Decadal Oscillation, range in flow years). To address
variability in natural hydrologic conditions and to
capture variability in biologic conditions we suggest
using the average span of a typical Chinook salmon,
five years for Deshka River Chinook. The Deshka
River Chinook salmon stock age-composition currently
represents the only one of its kind within the Susitna
River basin. Salmon stock age-composition is a well
noted data gap within the ADFG Chinook stock
assessment analysis for Cook Inlet. (ADFG 2012).” –
pdf pages 63-64
See AEA’s response to comment IFS-095. In addition, the commenter has
not provided a rationale for the number of years of study other than
suggesting the life cycle of a salmon. AEA believes that it is not the years
of data collection that are important, but rather, an understanding of the
affected environment and how the Project would impact it. AEA believes
the hydrologic and climactic variability of the historic record is sufficient to
understand how the Project would affect the resources. With the IFS
modeling efforts combined with the physical and biological information
collected informally in 2012 and through formal study efforts in 2013 and
2014, AEA will have sufficient information to understand the physical
processes, and the effects the proposed Project will have on instream flow
resources. This will permit AEA to propose appropriate protection,
mitigation and enhancement measures in its License Application to FERC.
IFS-093 USFWS 11/14/2012 “Habitat-flow relationships should also be developed
over a minimum temporal scale to address the
See AEA’s response to comment IFS-095.
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dominant age-class of Deshka River (Susitna River
tributary; approximately RM 40) Chinook salmon. On
average, a five-year period of study would represent
one generation of Deshka River Chinook salmon
based upon available age-composition information. In
some years, 4- or 6- year olds predominate (ADFG
2012; Alaska Chinook salmon GAP ANALYSIS). The
Deshka River Chinook salmon stock age-composition
currently represents the only one of its kind within the
Susitna River basin. Salmon stock age-composition is
a well-noted data gap within the ADFG Chinook stock
assessment analysis for Cook Inlet. The Service
supports the State of Alaska Sustainable Salmon
Fisheries Policy (ADFG 2001) calling for a
Precautionary Approach to managing salmon stocks
and habitats in the face of uncertainty. The
Precautionary Approach specifically requires action on
a time scale of five years, “…which is approximately
the generation time of most salmon species.” A
minimum of five years of study also allows the
developer to account for a substantial range of natural
environmental variability that is critical to identify
patterns of habitat availability and utilization by fish. If
studies are not conducted over a sufficient period of
time, the impacts of this Project cannot be adequately
assessed.” –pdf page 52
IFS-094 CSDA 11/14/2012 “Instream Flow Studies should be developed over a
temporal scale of five years. This is in order to
encompass a representative time frame.” –pdf page 3
third bullet
See response to IFS-095 comment.
IFS-095 CWA 11/14/2012 “The PSP’s maximum 2 year study period for analyzing
impacts on instream flows is insufficient.”–pdf page 6
with more detail on page 7
In addition to the 57-year hydrologic record for the Susitna River at Gold
Creek, AEA is expanding the number of flow gaging sites in the Susitna
River watershed as described in Section 8.5.4.4. This hydrologic record will
capture the annual and seasonal variability of flows and exceed the state
ADNR instream flow data collection requirements. However, the hydrologic
record should be considered an input to the IFS modeling effort. The IFS
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Analytical Framework is designed to integrate study and model results of
riverine processes and to assess relationships between riverine and
biological functions. Indicators of aquatic habitats under unregulated and
alternative operational scenarios will be calculated under average, wet, and
dry hydrologic conditions, and warm and cold Pacific decadal oscillation
phases. One objective of the IFS modeling efforts is to extrapolate
measured conditions to non-modeled conditions both spatially and
temporally. This allows data collected over the study period to be used to
evaluate Project effects over the range of environmental conditions that
occur naturally.
Several years of HSC/HSI and other habitat utilization data are available
from the 1980s studies and contribute to site-specific knowledge of the
potential local adaptations of the species. Additional biological information
was developed in 2012 and formal studies will be conducted in 2103 and
2014 as part of the current licensing efforts. These multiple years of site
specific studies from the 1980s, and 2012 through 2014, will capture
variability in flow-habitat and fish-habitat relationships and support the IFS
as a licensing decision tool.
IFS-096 USFWS 11/14/2012 “The Service maintains that the duration of the
proposed studies will not represent the range of
environmental (e.g. stream flow, temperature, snow
pack, icing) conditions that occur naturally. Habitat
mapping, study site selection, and habitat utilization
(fish) surveys need to be conducted over all seasons
and over a sufficient period of time (years) to account
for intra and inter-annual variability in environmental
conditions. All evidence and ecological theory supports
the fact that species are locally adapted to this
variability and in many ways depend upon it (Mims and
Olden 2012).” –pdf pages 51-52
See response to IFS-095 comment.
IFS-097 USFWS 11/14/2012 “With an understanding of fish habitat utilization and
the site-specific environmental variables (micro-
habitat) that influence fish-use of habitat, variable
inputs and model selection will be at a scale relevant to
fish habitat. The Service maintains that this
See response to IFS-095 comment.
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understanding can occur with multiple years of
assessment and habitat utilization (fish distribution)
that allow for detection of patterns in habitat usage with
respect to hydraulics, substrate, and cover- all of which
are flow dependent (Holm et al 2001). As such, the
ecological relevance of criteria must be assessed over
a period of multiple years to account for variability in
habitat selection as a function of natural variability in
environmental flow conditions; as well as reduce the
error surrounding these measurements. Multiple years
of data will also allow for assessment validation of
associated fish abundance (occupied versus
unoccupied), seasonal movement and distribution
surrounding flow-habitat relationships within selected
study sites.” –pdf page 58
IFS-098 TCCI 11/07/2012 The study should be conducted for a longer duration to
encompass natural variation in fish abundance and
distribution and environmental conditions. The council
agrees with recommendations by NMFS and USFWS
to conduct studies for a minimum of one salmon life
cycle (5 - 7 years) -pdf pages 2-4
See AEA’s response to comment IFS-092.
IFS-099 Long, Becky 11/13/2012 Two years are inadequate, request for 5 to 7 year
study –pdf page 2
See AEA’s response to comment IFS-092.
IFS-100 ADNR-
ADF&G
11/14/2012 “A description is needed on the manner in which
information will be compiled to present results (e.g.
Decision Support System) including data sources that
will be incorporated, geo-spatial capabilities, and
product outputs.” –pdf page 21
A description of the decision support system-type process is described in
Section 8.5.4.8.
IFS-101 FERC 11/14/2012 “Describe in each of the relevant studies how the
different modeling results would be used. Where a
parameter is measured (or estimated using a model) in
more than one study, define which value will take
precedence.” –pdf page 5
A decision support system-type process will be used to integrate the range
of habitat modeling results and inform the evaluation of alternative
operational scenarios (see Section 8.5.4.8).
IFS-102 TNC 11/14/2012 “Operation Scenarios A range of alternative operational scenarios will be evaluated as described
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The various models that are developed for the study
plan should look at three scenarios: existing (non-
project), proposed load-following operation, and base
load operation. Early introductions of this current
project proposed base load operations. With current
power generation dependent upon natural gas
supplies, it is foreseeable that in the future this project
could be operated to supply base loads. In case of that
operational change in future, the base load case
should be included in the models. This would also
provide the opportunity to gage the impacts of a wider
range of operation regimes.” –pdf page 3
in Section 8.5.4.3.2. See AEA’s response to comment IFS-002.
IFS-103 NMFS 11/14/2012 “Ibis objective is similar to our requests for a modeling
framework that will provide a comparative temporal
and spatial analysis of riverine process studies and
model results for a range of alternative operations. It is
unclear which studies would develop the habitat
utilization data proposed for comparative analysis,
specifically for the juvenile and adult rearing and egg
incubation. All of the project operation analysis for
instream flow effects should include groundwater and
water quality analysis, especially for juvenile
overwintering and egg incubation. NMFS's study
requests included an objective to identify, characterize,
and integrate the timing, quantity and function of
instream flow to riverine processes. Included in this
request were specific processes, including
geomorphology, floodplain and riparian form and
vegetation, biological cues, water quality,
surface/groundwater exchange, and riverine habitat
availability and quality. AEA's study plan includes
some of these processes in the proposed plan but it is
unclear how they will integrate surface/groundwater
exchange, water quality, river productivity, and
biological cues and at what scale. It is also unclear
how results from these studies will be extrapolated to
gain a greater understanding of the overall project
As described in Section 8.5.4.1, the IFS Analytical Framework provides a
comparative temporal and spatial analysis that integrates Project effects on
geomorphology, ice processes, water quality and groundwater to quantify
changes in fish and aquatic habitat and riparian indicators under existing
conditions and alternative operational scenarios (see Figure 8.5-10). The
framework of the effective spawning/incubation analyses is described in
Section 8.5.4.6.1.5 and Figure 8.5-32. The results developed from studies
conducted in modeled Focus Areas will be extrapolated to non-modeled
areas through temporal and spatial habitat analyses described in Section
8.5.4.7 and integrated with the results of studies conducted in other
resource areas to gain a greater understanding of overall Project effects to
the Susitna River system (see Section 8.5.4.8).
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effects to the Susitna River system. The groundwater
studies proposed by AEA (see our detailed comments
on the groundwater study plan) should result in
dynamic flow sensitive models for main channel and
off channel habitats, allowing an analysis of how the
exchange flows will be altered with project operations,
although it is not clear how distribution of upwelling
areas will be identified if the methods described in the
groundwater study plan are not successful (which is
highly likely).” –pdf page 74
IFS-104 EPA 11/14/2012 "Winter high and low flows define the range of water
depths and velocities available for fish egg
development and juvenile maturation, mostly under the
ice (see Points about ice dynamics, below). Winter
high flows also may be closely tied to ice dynamics,
such as the formation and breakup of ice dams, which
may affect channel geomorphology (see above, and
Point 10, below). The Instream Flow Study needs to
assess how much impact dam operations will have on
river stage during the Winter and, crucially, how far
downstream these impacts will be evident. (And, again,
as noted above, the impacts need to be addressed in
terms of absolute alteration relative to the natural
range of variation, not in terms of “percent difference”).
The effects of Winter dam releases (e.g., hourly
variation; increased daily discharge) on river stage
may persist further downstream than the effects on
river geomorphology. Thus, as noted above, the
PSP/RSP should actively assess rather than assume
that reaches with nominally acceptable distributions of
macrohabitat types will also experience acceptable
patterns of variation in river discharge, stage, and flow
velocities – and do so separately by season." –pdf
pages 16-17
Winter flow and stage conditions downstream of the proposed dam site will
be predicted under existing conditions and alternative operational
scenarios as part of the Ice Processes in the Susitna River Study modeling
efforts (see Section 7.6). The results of the Ice Processes model, in terms
of stage and velocity data relative to bed elevations, will be used as input to
the hydraulic and habitat modeling of Focus Areas as described in Section
8.4.5.6.
IFS-105 ADNR-
ADF&G
11/14/2012 “For the eulachon (Section 7.16) and boating
(Section10.7) studies, similar information is needed on
Information concerning eulachon spawning habitat will be collected as part
of the Eulachon Run, Timing, Distribution, and Spawning in the Susitna
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how the flow-habitat/resource information will be
collected. For example, what is the study area, what
sampling strategy will be used, how many and what
range of calibration-discharge sets will be collected if
appropriate, and how will HSC/HSI data be
developed?” –pdf page 21
River study (see Section 9.16.4.3). This information will be useful for
evaluating how these habitats may be altered under different flow
conditions.
IFS-106 USFWS 11/14/2012 “Specifically requested was a framework that not only
defines and lists the individual study plan objectives,
but also includes the full range of proposed study
methodologies. This information was then to be further
integrated with the May 31, 2012 study requests in
order to assess whether or not AEA individual
proposed study plans meet the intent of the Service’s
overall study requests.
The study plan integration should also provide details
for: 1) a process schedule (timeline) and
methodologies for habitat mapping; 2) selection of the
proposed focus areas and study sites; 3) surveys of
fish distribution and collection of microhabitat utilization
[hierarchically stratified by macro- and meso-habitats];
4) statistical testing of microhabitat variables that are
ecologically relevant to habitat selection; and 5)
quantification of flow-habitat relationships. Specific
methodologies for surveying anadromous and resident
fish distributions should also include temporal and
spatial distribution of spawning, summer rearing, and
overwintering sites.” –pdf page 52
The analytical framework for the IFS has been revised and is described in
Section 8.5.4.1. Integration of studies is discussed in Section 8.5.4.8 and
study interdependencies depicted in Figure 8.5-1. A detailed process
schedule is presented in Table 8.5-14.
IFS-107 CWA 11/14/2012 The PSP’s work products are incomplete and exclude
prevention and/or mitigation efforts. -Pages 11-12 –
(Section IV)
The studies described in the RSPs are focused on the collection of data
and information that will be used in part for defining baseline conditions (i.e.
pre-project conditions) and for developing a set of analytical tools that can
be used to evaluate Project effects on different resources. These studies
will inform the environmental analysis that will be used to support AEA’s
FERC License Application.
IFS-108 FERC 11/14/2012 “In attachment 8-1, List of Terms and Definitions, you
identify the size classes for nine sediment types to be
The method for determining sediment sizes will be visually estimating the
percentages of the dominant and subdominant substrate surface layers at
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used in the habitat suitability curve/habitat suitability
index (HSC/HIS) study, but you do not identify the
methods to determine the sediment sizes. Sampling
methods used to collect the bed material to be used in
the sediment transport models is described in section
6.6.4.1.2.8, Field Data Collection Efforts. It is likely that
the bed material sizes used sediment transport models
would correspond to the American Geophysical Union
sediment classification system, which is not equivalent
to the sediment classification presented in attachment
8-1. Consequently, it is possible that the sediment
types used in the HSC/HIS study would not be
equivalent to sediment types used in the transport
model. Because these studies are interrelated, please
identify the methodology used to determine the
sediment sizes presented in attachment 8-1 and
describe any differences to the system used to
determine the sediment sizes to be used in the
transport models.” -pdf page 13
each HSC/HSI measurement location using a modified Wentworth (1922)
substrate size classification system as presented in Table 8.5-17.
Characterization of bed material during the Fluvial Geomorphology
Modeling (see Sections 6.6 and 6.6.4.1.2.8) will be conducted utilizing
surface pebble counts (Wolman count) or photo grid. Completion of the
pebble counts yields the diameter of the intermediate axis of a randomly
selected sample (generally n=100) of surface substrate. The pebble count
data can then be combined according to the modified Wentworth size
classes (see Table 8.5-17) and converted into percentages by size class.
The data can then be graphed to illustrate percentage of total for each size
class, dominant size class, and cumulative distribution.
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Comment
er
Date Filed Comment or Study Request AEA’s Response
RIFS-01 CWA 11/14/2012 Scope is insufficient in studying the Lower River based on
AEA’s apparent assumption that Project effects will not
significantly affect the Lower River riparian habitat. – pdf
pages 7-8
AEA is not assuming insignificant Project-related effects on the
Lower River groundwater processes. Although both Middle and
Lower River segments are under consideration as part of the
Instream Flow Study (Section 8.5), the majority of detailed study
elements described in the RSP are concentrated within the Middle
River Segment. This is because Project operations related to load-
following and variable flow regulation will likely have the greatest
potential effects on this segment of the river. These effects tend to
attenuate in a downstream direction as channel morphologies
change, and flows change due to tributary inflow and flow
accretion.
The downstream boundary of the study area is currently RM 75
because existing information indicates that the hydraulic effects of
the Project below the Three Rivers Confluence are attenuated.
See Section 8.5.3. However, AEA will reevaluate how far
downstream Project operational significant effects extend based in
part upon the results of the Open-water Flow Routing Model (see
Section 8.5.4.3),which is scheduled to be completed in Q1 2013.
Thus, an initial assessment of the downstream extent of Project
effects will be developed in Q1 2013 with review and input of the
TWG. This assessment will include a review of information
developed during the 1980s studies and study efforts initiated in
2012, such as sediment transport (see Section 6.5), habitat
mapping (see RSP Sections 6.5 and 9.9), operations modeling
(see Section 8.5.4.3.2), and the Mainstem Open-water Flow
Routing Model (see Section 8.5.4.3). The assessment will guide
the need to extend studies into the Lower River Segment and if
needed, will identify which geomorphic reaches will be subject to
detailed instream flow analysis in 2013. Results of the 2013
studies would then be used to determine the extent to which Lower
River Segment studies should be adjusted in 2014. In addition, the
results of the 1-D sediment transport modeling (see Section 6.6)
from RM 184 to RM 75 will be available in Q1 2014 and will further
inform the need for these adjustments. Pilot HSC/HSI studies were
initiated in 2012, and will be continued in 2013, and include data
collection within Lower River Segment habitats (see Section
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8.5.4.5). See also Section 8.5.3 for more discussion regarding the
Lower River Segment.
RIFS-02 CCC 11/14/2012 “How will the natural floodplain system be impacted if there is
no longer a spring flush of ice and water?” –pdf page 2
The goal of the Riparian Instream Flow Study is to provide a
physical and vegetation process modeling approach to predicting
impacts to downstream riparian vegetation from Project operational
flow modification of natural Susitna River Flow, sediment and ice
processes regimes (Section 8.6.1.1). See the method description in
Section 8.6.3.
RIFS-03 FERC 11/14/2012 “Describe in each of the relevant studies how the different
modeling results would be used. Where a parameter is
measured (or estimated using a model) in more than one
study, define which value will take precedence.” –pdf page 5
Modeling results, flow charts depicting parameters, and multiple
model interdependencies are included in each of the Riparian
Instream Flow Study components (see Sections 8.6.3.2 through
8.6.3.7). AEA has provided a description in each of these studies
regarding how the modeling results will be used.
Measurement and modeling values will be used in various
modeling studies to answer different questions. For example,
groundwater levels will be measured at Focus Areas at individual
well point locations. These values will be used to construct
floodplain vegetation (individual species and plant community
types) groundwater response curves (Section 8.6.3.6.2).
MODFLOW will be used to model groundwater response to various
Project operational scenarios (see Groundwater Study Section 7.5
for methods) based upon measured groundwater depths and
surface water levels (Groundwater Study Section 7.5). Surface
water and sediment transport will be both measured and modeled
at each Focus Area by the Fluvial Geomorphology Modeling below
Watana Dam Study (Section 6.6). The measured values, river
stage and sediment transport, will be used in the 2-D modeling that
will assess potential changes to sediment deposition throughout
each Focus Area for various Project operational scenarios. Ice
Processes effects, areas of ice dams and vertical zones of ice
floodplain interactions, will be modeled (Section 7.6). Ice process
floodplain vegetation interaction zones will be measured by
mapping tree ice-scars throughout the Study Area (Section
8.6.3.4).
RIFS-04 FERC 11/14/2012 “Clearly describe the exact number, location, and spatial
extent of your proposed focus areas for each proposed
study. Provide justification for the number of proposed sites
selected for detailed 2-D hydraulic modeling and other
intensive study elements. Include criteria to be used for
Additional detail regarding the Focus Area selection process,
criteria and rationale is included in the Fish and Aquatic Instream
Flow Study (Section 8.5.4.2.1.2) and Riparian Instream Flow Study
(Section 8.6.3.2). The RSP includes 10 proposed Focus Areas
which are located in the Middle River and a process for which
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selecting focus areas and study-specific rationale for co-
locating sites.” -pdf page 5
Focus Areas may be redistributed or added in the Lower River (see
Section 8.5.4.2.1.2 and Figure 8.5-11). Section 8.6.3.2 describes a
quatitative analytical approach for selecting the number and
locations of Focus Areas, with riparian components, as an iterative
process using additional data as it becomes available. Section
8.5.6.1.1.2 describes the rationale for use of 2-D hydraulic
modeling. The number of sites for which the 2-D model, and other
intensive study elements, will be applied will be determined when
details are finalized (see Focus Area Selection−Riparian Process
Domain, Section 8.6.3.2 for details of Focus Area selection).
RIFS-05 FERC 11/14/2012 “In general, the complexity of the Riparian Instream Flow
Study (section 8.6) makes it challenging to follow the
linkages between the study objectives, methods, and results.
A table or graphic listing study objectives, the methods
proposed for achieving the objectives, and expected types of
results to be generated from the various study tasks would
help us evaluate whether the methods contained in the RSP
will be sufficient to capture the potential effects of the project
on riparian resources.” -pdf page 12
Study objectives, methods and expected results are detailed in
Tables 8.6.-2 through 8.6-9. Flow charts depicting parameters and
multiple model interdependencies are included in each of the
Riparian Instream Flow Study components in Figure 8.6-1, Figure
8.6-3, Figure 8.6-4, Figure 8.6-7, Figure 8.6-9, Figure 8.6-13,
Figure 8.6-14, Figure 8.6-19, and Figure 8.6-20.
RIFS-06 FERC 11/14/2012 “The study area section describes the classification scheme
proposed for delineating project reaches and habitat types.
Although not explicitly stated, the classification scheme
appears to inform the delineation of riparian-process
domains. If the classification scheme and riparian-process-
domain delineation methods are linked, please describe their
relationship in section 8.6.3.2, Focus Area Selection-Riparian
Process Domain Delineation. At end of section 8.6.3.2, you
state that focus areas have been selected. If that is the case,
please describe the focus areas and the process and
rationale that were used in site selection. Please describe the
number and approximate location of focus areas, and the
number of sampling transects, points, or plots that will be
located in each sampling area. The study schedule indicates
that focus areas will be selected by early 2013, but that field
data collection will begin in 2012. Please reconcile this
apparent inconsistency in the schedule and description of
focus area site selection.” -pdf page 12
Focus Areas with riparian components will be selected through a
spatially constrained cluster analysis process and expert-opinion.
Additional detail regarding the Focus Area selection process,
criteria and rationale is detailed in the Fish and Aquatic Instream
Flow Study (Section 8.5.4.2.1.2) and Riparian Instream Flow Study
(Section 8.6.3.2). The RSP includes 10 proposed Focus Areas
which are located in the Middle River and a process for which sites
will be redistributed or added to the Lower River (Section
8.5.4.2.1.2 and Figure 8.5-11). The process for revising number
and locations of Focus Areas as data becomes available is
described in Section 8.6.3.2. In Q1 2013 a quantitative GIS-based
cluster analysis will be conducted for the study area in support of
making Focus Area selections for 2013, with input from the TWG.
Field data from 2012 Riparian Vegetation Study Downstream of the
Proposed Watana Dam (Section 11.6) and additional river
reconnaissance efforts conducted in October 2012, will be used in
support of the Focus Area selection process. The 2012 field data
includes: mapping and characterization of floodplain plant
community types; soils type characterization; and fluvial terrain
mapping and characterization; and preliminary mapping of tree ice-
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scars. The 2012 riparian vegetation mapping effort was conducted
to both support 2013/2014 riparian vegetation mapping and
characterization and to support development of the Riparian
Instream Flow Study final study design, including Focus Area
selection process. The Focus Area sampling protocol and methods
concerning the number of transects, plot types and configurations
can be found in Riparian Vegetation Study Downstream of the
Propoased Watana Dam plan (Section 11.6).
RIFS-07 FERC 11/14/2012 “The same description of focus area modeling is presented in
several sections of the draft RSP. However, the majority of
the description appears to be better suited for section 8.6.3.2,
Focus Area Selection-Process Domain Delineation because
it describes the basis for scaling the results of focus area
field surveys and modeling up to process domains. Other
portions of the description appear to be better suited for the
work products sections under various study objectives.” -pdf
pages 12-13
Section 8.6.3.2 Focus Area Selection−Riparian Process Domain
Delineation describes the rationale for the study area stratified
sampling approach. Focus Area and Riparian Process Domain
modeling linkages are described in detail in Section 8.6.3.2.
RIFS-08 FERC 11/14/2012 “In attachment 8-1, List of Terms and Definitions, you identify
the size classes for nine sediment types to be used in the
habitat suitability curve/habitat suitability index (HSC/HIS)
study, but you do not identify the methods to determine the
sediment sizes. Sampling methods used to collect the bed
material to be used in the sediment transport models is
described in section 6.6.4.1.2.8, Field Data Collection Efforts.
It is likely that the bed material sizes used sediment transport
models would correspond to the American Geophysical
Union sediment classification system, which is not equivalent
to the sediment classification presented in attachment 8-1.
Consequently, it is possible that the sediment types used in
the HSC/HIS study would not be equivalent to sediment
types used in the transport model. Because these studies are
interrelated, please identify the methodology used to
determine the sediment sizes presented in attachment 8-1
and describe any differences to the system used to
determine the sediment sizes to be used in the transport
models.” -pdf page 13
Development of HSC/HSI is an element of the Fish and Aquatic
Instream Flow Study not the Riparian Instream Flow Study. See
AEA’s response to comment IFS-108.
RIFS-09 ADNR-
DMLW
11/14/2012 “There are no large lakes in the Study Area but there are
many wetlands and there may also be a number of smaller
ponds, within the wetland areas. There does not appear to be
Although the Riparian Instream Flow Study addresses physical,
chemical and biologic functions of floodplain wetlands from the
perspective of floodplain vegetation, wetland functional analysis is
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plans for a study of wetland functioning within the study area.
This would be a multi-disciplinary as aspects of both surface
water and groundwater hydrology are involved.” –pdf page 9
not a goal or objective of this study. Wetland functional
assessments in the Susitna River riparian area below the dam site
will be performed as part of the Riparian Vegetation Study
Downstream of the Proposed Watana Dam (Section 11.6) and for
areas within the vicinity of the corridors and above the dam are site
will be performed as part of the Wetland Mapping Study (Section
11.7). The methods are fully described in Section 11.6.4 and
11.7.4.3, respectively.
RIFS-10 ADNR-
DMLW 11/14/2012 “There is no mention of the source of recharge to the
wetlands that was referred to. Much of the wetland area is
inundated during ice dam events, but the timing of these
events are irregular in nature and the ground surface may be
frozen during the events, preventing regular infiltration. While
upwelling groundwater and percolating precipitation, primarily
snowmelt, may account for a significant portion of the
wetlands, both recharge and discharge due to river stage, i.e.
potential horizontal flow to and from the wetlands, may be
significant.” –pdf page 9
See AEA’s response to comment RIFS-09.The Riparian Instream
Flow Study will measure and model groundwater and surface water
interactions, including “groundwater recharge, ” however the focus
is not wetlands, but floodplain vegetation. Groundwater and
surface water interactions will be modeled in floodplains affected by
ice (see Section 8.6.3.4) and groundwater (see Section 8.6.3.6).
RIFS-11 TNC 11/14/2012 “Focus Area Selection
The study plans are inconsistent on the use of the terms
”focus areas and ”study sites. In these comments, we
assume that these are intended to be the same places so will
use the term ”focus area. The method for selection of focus
areas is also inconsistent between and within study plans.
Table 8.5-13 of the Fish and Aquatics Instream Flow Study
(8.5) indicates that Focus Area selection is happening
currently (Q3-4 2012) even before studies are approved or
officially begin. If selection is to be based on the criteria
presented in 8.5.4.2, habitat mapping results from 2013
studies would seem to be required to select focus areas.
Focus areas should be selected based on biological
functions and habitat utilization by salmon as well as physical
processes related to instream flow, including habitat-flow
relationships, surface-groundwater interactions, geomorphic
processes, and ice processes. Biological functions for
salmon (i.e. spawning, rearing, migration, overwintering)
could potentially change with project operations, and
appropriate focus area selection can help to characterize and
quantify that anticipated change.
See AEA’s response to comment IFS-019.
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Focus areas should be selected in the Middle and Lower
Rivers. The river from the three river confluence and below is
especially dynamic. Focus areas in the Lower River are
required to understand changes to salmon habitat due to
project operations. As noted in our comments on Climate
Change impacts above, the cumulative impacts of this project
with other anticipated changes to the basin could affect
salmon and salmon habitat in the Lower River.” –pdf pages
2-3
RIFS-12 TNC 11/14/2012 “Lower River Studies
Many of the study plans assume no effects from the project
and its operation below Talkeetna (Mile 97) and do not
include the Lower River in their scope. As noted in our
comments on Climate Change impacts above, the cumulative
impacts of this project with other anticipated changes to the
basin could affect salmon and salmon habitat in the Lower
River. Load-following operation, which will essentially flip the
hydrological pattern between winter and summer, must be
modeled for effects on the Lower River. The hydrological
model has been extended to Mile 84 in the upper Lower
River, and the study plan notes that the model will be
extended further into the Lower River if project effects are
seen at Mile 84. It is not clear what the trigger will be to
extend the model and how or when that will be decided. The
Revised Study Plans, including those for geomorphology,
instream flow, and ice processes, should include the Lower
River. If they do not but leave the possibility open depending
upon early results, the plans should be explicit about why
they assume no effect on the Lower River and what criteria
will be used to revisit the need to extend models when early
results are available.” –pdf page 3
See AEA’s response for comment IFS-024.
RIFS-13 TNC 11/14/2012 “Operation Scenarios
The various models that are developed for the study plan
should look at three scenarios: existing (non-project),
proposed load-following operation, and base load operation.
Early introductions of this current project proposed base load
operations. With current power generation dependent upon
natural gas supplies, it is foreseeable that in the future this
project could be operated to supply base loads. In case of
See AEA’s response for comment IFS-102.
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that operational change in future, the base load case should
be included in the models. This would also provide the
opportunity to gage the impacts of a wider range of operation
regimes.” –pdf page 3
RIFS-14 USFWS 11/14/2012 “The U.S. Fish and Wildlife Service’s (Service) 31 May 2012
study request entitled Instream
Flows for Floodplain and Riparian Vegetation Study
resembles Alaska Energy Authority’s (AEA) Proposed Study
Plan (PSP) title, except “floodplain” is included in our study-
plan title. Riparian areas and floodplains are often the same;
however, many people visualize riparian areas as a narrow
band immediately adjacent to streams and rivers. We
envision this study including the entire floodplain, and not
simply a narrow zone along the Susitna River. To help
minimize this potential misconception, we recommend
revising the study plan title to include the word “floodplain.”” –
pdf page 67
Although AEA is not revising the study title, the scope of the study
includes an evaluation of the floodplain as described in the study.
RIFS-15 USFWS 11/14/2012 Interdependency figure – “Given the complex integration of
the various studies, we appreciate this figure and
recommend including figures like these along with a narrative
in the introduction for each study. Additionally, the main
introduction covering all the studies should include a more
general interdependency figure showing how all the various
studies interrelate. We have not had time to evaluate this
draft interdependency figure, but we look forward to
reviewing additional drafts as the study plans mature.” –pdf
page 67
See AEA’s response to comment RIFS-05.
RIFS-16 USFWS 11/14/2012 “Besides interdependency figures, please provide timelines
showing how the various study components (both among
major studies and within studies) feed into other studies and
study components. The Service is concerned the sequencing
of some study components may be out of sync with the
required products from other studies and study components.”
–pdf page 67
See Schedule (Section 8.6.5) and Relationship with Other Studies
(Section 8.6.6).
RIFS-17 USFWS 11/14/2012 “Unlike the fisheries component of the Aquatic Instream Flow
Study where potential future Susitna-Watana Hydroelectric
Project (Project) impacts may be compared with other
locations in the state because fish populations are routinely
surveyed, evaluating potential Project impacts on
The current Riparian Instream Flow Study is not designed as an
“impact study” as specified in Green (1979). The goal of this study
is to provide a physical and vegetation process modeling approach
to predicting potential impacts to downstream riparian floodplain
vegetation from Project operational flow modification of natural
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riparian/floodplain resources without an “untreated” spatial
reference (i.e., similar rivers without a dam) risks a significant
change may be attributed to an unrelated impact. Green
(1979) outlines four prerequisites for an optimal impact study
design: 1) the impact must not have occurred; 2) the type,
time and place of impact must be known; 3) all relevant
biological and environmental variables must be measured;
and 4) an area unaffected by the impact must be sampled to
serve as a control. The first three prerequisites are included
in the PSPs if they are designed and implemented so
potential Project impacts can be evaluated by post-dam
resampling. We recommend the Riparian Instream Flow
Study also include the fourth component (un-impacted
rivers), otherwise AEA risks what Green (1979, p 71) refers
to as “… executing statistical dances of amazing complexity
around their untestable results” to show the Project did or did
not have a potential impact on riparian/floodplain resources.”
–pdf page 68
Susitna River flow, sediment, and ice processes regimes (see
Section 8.6.1.1). The environmental analysis within AEA’s FERC
License Application will inform the need for ongoing monitoring.
RIFS-18 USFWS 11/14/2012 “AEA Study Goals and Objectives: The Service requested a
specific goal that includes quantifying the frequency, timing
and duration of surface-water and groundwater levels
required to establish, maintain, and promote floodplain and
riparian plant communities. Two ancillary goals were also
requested: 1) to quantify the frequency and rate of sediment
deposition required to promote soil development; and 2) to
quantify the effect of river ice on the establishment and
persistence of riparian plant communities. Although the text
of AEA’s draft revised goal was not presented at the 24
October 2012 TWG meeting, we expect the RSP will include
a goal similar to ours. While goals can be very general in
nature, the specifics in our goal sets the stage for a rigorous
study plan designed to evaluate potential Project effects on
floodplain plant communities.” –pdf page 68
AEA’s Riparian Instream Flow Study goals and objectives are
consistent with the USFWS Study Plan Request’s goals and
objectives. Susitna River flow, groundwater, sediment and ice
process regimes (magnitude, duration, frequency and timing) will
be measured and modeled in the Riparian Instream Flow Study
(Section 8.6.1.1). Section 8.6.3.6 explains that the floodplain
vegetation groundwater and surface water interaction study will
measure and model (1) groundwater depth seasonally, and (2)
surface water hydroregime, including water surface elevation,
frequency, duration, timing throughout the Focus Areas. Sediment
transport and deposition will be 2-D modeled at each Focus Area
by Fluvial Geomorphology Modeling below Watana Dam Study
(Section 6.6). The rate of historic sediment deposition will be
sampled by direct isotopic and dendrochronologic measurement
(Section 8.6.3.5). Soil development will be described in detailed soil
sampling conducted in the Riparian Vegetation Study Downstream
of the Proposed Watana Dam (Section 11.6). An individual study of
ice effects on floodplain vegetation will be conducted comparing ice
effected floodplain vegetation establishment and development with
unaffected floodplains (Section 8.6.3.4).
RIFS-19 USFWS 11/14/2012 “In addition to the longitudinal dimensions of the study area The lateral extent of the Focus Areas will be determined by
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and the width of surface-water flooding, we recommend
including the area of groundwater potentially influenced by
Project operations. For the riparian study, the width should
be at least as wide as the expected area of groundwater
within the maximum depth of all plant roots and influenced by
Project operations.” –pdf page 69
assessing the extent of surface water / groundwater interaction
through multiple lines of evidence. Mapping of the geologic
floodplain will be conducted first using an uncorrected LiDAR
shaded relief map. Alluvial terrain will be mapped relative to
adjacent hillslopes. HEC-RAS (1-D) modeling of discharge and
stage will be used to delineate valley bottom floodplain flooding
discharge magnitudes by the fluvial geomorphology modeling
(Section 6.6).
The width of the floodplain where groundwater is influenced by
surface water, and Project operations, will be determined by a
combination of: (1) land surface mapping, using LiDAR or surface
mapping information, (2) geologic information, (3) observations of
springs and groundwater recharge to slough and ponds, (4) well
observations, and (5) floodplain plant community distribution.
Further details are provided in Section 8.6.3.6 as well as Section
7.5 (Groundwater Study).
RIFS-20 USFWS 11/14/2012 “For the focus areas where multiple study disciplines will
focus and complement their work, we recommend the
Riparian Instream Flow Study first develop criteria required
for selecting their study sites independent of the other
studies. Next, develop a list of study products from the
Riparian Instream Flow Study that other studies require, and
then work with the other studies and stakeholders to select
focus areas. A master matrix of studies, data needs and data
products would greatly facilitate this process and stakeholder
acceptance.” –pdf page 69
Riparian Instream Flow Study sites will be selected independently
through the process described in Section 8.6.3.2 Focus Area
Selection−Riparian Process Domain Delineation. Criteria for
selection include: geomorphic type classification, riparian
vegetation types, and ice process domain delineation (Section
8.6.3.2). Riparian study sites, including the riparian components of
the Focus Areas, will be selected through a process of cluster and
power analyses and expert-opinion as described in Section 8.6.3.2.
There will be significant overlap between Riparian Instream Flow
Study sites and Aquatic Instream Flow Study sites because
geomorphic processes, valley planform configuration, and resulting
channel types result in a limited number of “geomorphic channel
types.” Therefore both studies will have overlapping study site
needs and can use the same sites, Focus Areas. See Fluvial
Geomorphology Modeling below Watana Dam Study Section 6.6
for details concerning geomorphic classification.
Riparian sites within Focus Areas are selected based upon riparian
process domain characterization described in Section 8.6.3.2.
Focus Areas will be selected through a spatially constrained cluster
analysis process and expert-opinion. Proposed Focus Areas have
been previously identified through the expert-opinion process for
both Fish and Aquatic Instream Flow Study and Riparian Instream
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Flow Study. In Q1 2013 a quantitative GIS-based cluster analysis
will be conducted of the Study Area in support of making Focus
Area selections for 2013, in consultation with the TWG. See
Section 8.6.3.2 for detailed methods. Field data from the 2012
Riparian Vegetation Study Downstream of the Proposed Watana
Dam (Section 11.6), and additional river reconnaissance efforts,
will be used in support of the Riparian study site selection within
Focus Area process.
Individual study Focus Areas will be presented to TWG in Q1 2013
with the results of the Riparian GIS cluster analysis. Focus Area
selection process is described in detail in Fish and Aquatic
Instream Flow Study Section 8.5.4.2 and Riparian Instream Flow
Study Section 8.6.3.2.
A ‘master matrix’ of studies, data needs and data products will be
presented at the Q1 2013 TWG Focus Area selection meetings.
RIFS-21 USFWS 11/14/2012 “Riparian Instream Flow study sites should reflect the full
range of riparian and floodplain plant communities along the
Susitna River. The Riparian Botanical Resources (Mapping)
Study (PSP Section 9.6) will likely need to be substantially
completed before the Riparian Instream Flow study sites can
be selected with confidence that the full range of plant
communities are studied. Similarly, the process-domains
(Montgomery 1999) should be defined before focus areas are
selected. The range of plant communities and process-
domains should be part of the master matrix mentioned
above for selecting focus areas.” –pdf page 69
Riparian Instream Flow Study sites reflect the full range of riparian
and floodplain plant communities along the Susitna River. See
AEA’s response to comment RIFS-20.
RIFS-22 USFWS 11/14/2012 “Study sites should include areas where Project operation is
expected to cause early channel bed degradation or
aggradation (11 September 2012 Service email request).
AEA has since proposed to select focus areas between the
dam and Devils Canyon; the river segment most likely to
experience channel bed degradation. Focus areas should
also be located in areas likely to experience channel bed
aggradation.” –pdf page 69
Focus Areas likely to experience channel bed aggradation will be
determined in 2013 (Q4 2013, Q1 2014) through initial sediment
transport modeling and geomorphic reach analyses conducted by
theFluvial Geomorphology Modeling below Watana Dam Study
(Section 6.6). Additional Focus Areas will be selected in Q1 2014, if
necessary, to capture these geomorphic processes and floodplain
vegetation response analysis.
RIFS-23 USFWS 11/14/2012 “The number of study sites should provide sufficient
replication to address the needs of the objectives (11
September 2012 Service email request). AEA’s TWG
Focus Area for the riparian study will be selected based upon
riparian process domain characterization described in Section
8.6.3.2. Focus Areas will be selected through a spatially
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meeting response (24 October 2012) that “Focus Areas will
be representative (emphasis added) of specific riparian
process domains and their channel / floodplain
characteristics (ice process domains, channel plan form,
channel slope, channel confinement)” does not address our
concern about pseudoreplication (Hurlbert 1984). Study sites
are typically the experimental unit where replication is used
for true statistical analysis. All other sampling (e.g., within the
study site) is really subsampling used to obtain a better
average value for that one replicate. As envisioned by many
of the PSPs, the “representative” focus areas are really only
one replicate for each process-domain. If transects within the
focus areas will be used as the experimental unit, then the
focus areas should be large enough to assure at least
minimal dispersion of transects representing the river
segment, and all stakeholders will need to be comfortable
with the focus areas “representing” the river segment. AEA’s
Response 3 (TWG meeting 24 October 2012) that the
Riparian Botanical Resources (Mapping) Study (Section 9.6)
will provide additional dispersion of sample sites outside the
focus area is an important addition to the focus areas, but
only for the study products that rely on these additional field
data. One of the most important contributions of the riparian
mapping study includes using these data to help upscale
predicted Project-related plant community responses.” –pdf
pages 69-70
constrained cluster analysis process, and expert-opinion, with input
from the TWG. Constrained cluster analysis is designed to
statistically group river segments, and reaches, such that
classification of similar river elements, including floodplain types
(full range of plant communities) is made through an objective
quantitative process (see Section 8.6.3.2 for further details and
references). The cluster analysis will form the basis for stratifying
the river into similar process domains.
The number of Focus Areas necessary to capture riparian process
domain floodplain vegetation variability will be determined through
a power analysis. Focus Areas, by design, will be representatively
composed of the range of plant community types found throughout
each riparian process domain. The number of replicate plant
community samples, within all domain specific Focus Areas,
necessary to capture the variability found in floodplain vegetation,
and floodplain geomorphic land form types, will be assessed
through a power analysis in Q1-2 2013. Further sample survey
details are included in both Riparian Instream Flow Study Section
8.6.3.2 and Riparian Vegetation Study Downstream of the
Propoased Watana Dam Section 11.6.
RIFS-24 USFWS 11/14/2012 “In an email (11 September 2012), the Service asked the
following questions relating to seedling germination and
establishment. How will the Susitna River bimodal peak flows
be addressed? How will the fate of “second peak” seedlings
be addressed? How will the role of precipitation in
maintaining favorable soil moisture conditions be evaluated?
Will soil texture be considered? If so, how will the soil profile
be described? AEA responded (TWG meeting 24 October
2012) with the following replies. Bimodal peak flows will be
addressed by measuring and modeling such flows at each
Focus Area. “Second peak” seedling fate will be assessed in
the seedling recruitment plot study by aging woody seedlings
and quantifying these “recruitment flow regime”
It is AEA’s view that a two year Seedling Establishment and
Recruitment Study (Section 8.6.3.3.2) using woody seedling
dendrochronology to date the year of seedling year of
establishment is adequate to characterize seedling establishment
hydrologic conditions. Seedling year of establishment will be used,
with the historic discharge record, to model the flood regime at the
sample site 1-D or 2-D hydraulic models (see Section 8.6.3.3.2 for
further details).
While not included within the AEA study plan, to address USFWS
request, AEA will conduct a longitudinal three year second-peak
seedling cohort establishment and survival analysis to inform the
adaptive management components of future Project instream flow
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characteristics. The role of precipitation in maintaining
favorable soil moisture conditions will be evaluated by
measuring precipitation at each Focus Area meteorological
station and soil surface moisture at each Focus Area. Further
methodological details will be provided in the Groundwater
Study RSP Sec 7.5. Soil texture will be considered by
sampling, measuring and describing soil stratigraphy using
standard NRCS soils survey protocols (Field Book for
Describing and Sampling Soils by Schoeneberger, Wysocki,
Benham, and Broderson, 2002). These are appropriate
responses; however, the Service believes following the fate
of a cohort of second-peak germinated plants will likely be
more sensitive than aging woody seedlings and attempting to
relate their survival to past bimodal peaks. Aging woody
seedlings is likely more appropriate for mature plants where
past flow regimes are the only option for estimating
recruitment and not establishment. We also are concerned
that a two-year study will likely be insufficient to determine
the survival after germination, since three years is often
considered necessary to evaluate successful survival and
recruitment into the reproductive population.” –pdf page 70
regimes. This analysis is described in Section 8.6, Attachment 8-2.
Specifically, the objective of the analysis is to identify, and
measure, seedling and flow regime characteristics in a longitudinal
cohort analysis as compared to the two-year Seedling
Establishment and Recruitment Study (Section 8.6.3.3.2) The
seedling establishment analysis will be initiated in summer 2013
and carried through for three years 2014 to 2016; final results will
be presented in a technical memorandum to be prepared Q4 2016.
The technical memorandum is not necessary for the environmental
analysis supporting AEA’s License Application because the
anticipated results are not necessary to assess overall Project
effects. Instead, AEA anticipates relying upon the technical
memorandum for adaptive management of future Project
operations.
RIFS-25 USFWS 11/14/2012 "For seedling germination and establishment, the Service is
concerned the groundwater model MODFLOW is not
sensitive enough to quantify hydroperiod relationships for
seedlings (11 September 2012 email). We also asked what
other metrics will be used to quantify/separate surface water,
groundwater, soil moisture, precipitation, and other potential
hydrological process supporting seedling establishment and
recruitment? AEA responded (TWG meeting 24 October
2012) with the following replies. Seedling plot groundwater
regime will be both modeled with MODFLOW and a subset of
wells will be located within seedling areas allowing for
groundwater seedling response curves to be developed to
check precision of MODFLOW results with local well data.
Detailed groundwater / surface water modeling metrics
necessary to assess seedling establishment and recruitment
conditions will be provided in the Groundwater RSP. Metrics
will include: met stations at each Focus Area to measure
local precipitation, and measurements of the height of the
MODFLOW will be used to model groundwater regime throughout
the Focus Areas to quantitatively describe groundwater and plant
community type relationships. Groundwater well points will be
installed, with recording pressure transducers, in all plant
community types, including seedling establishment areas, within
each Focus Area. Plant community data will be collected at each
well point (see Riparian Botanical Study 11.6). Meteorological
stations will collect precipitation and temperature data. The
seedling plot data, and plant community type sample data, will be
used to develop both select individual plant species and plant
community type response curves. Therefore the sensitivity
necessary to capture seedling establishment groundwater
relationship will be measured at individual well points with pressure
transducers collecting data in 15 minute increments (see
Groundwater Study 7.5 for detailed methods). MODFLOW
modeling is designed is to quantify the range of floodplain terrain
surfaces and plant community types groundwater relationship that
would not be possible with well points alone. Therefore, the
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capillary fringe relative to the groundwater surface at well
points to measure effective soil pore water availability to
seedlings. The Service is satisfied that wells will be located
within the seedling areas. We believe MODFLOW is much
less accurate than onsite wells equipped with recording
pressure transducers for detailed studies such as seedling
germination. MODFLOW for this study component would
only be required if the germination sites are located some
distance from the river and the groundwater connection to
the river may be questioned." - pdf page 71.
combined well point and MODFLOW design will capture both
seedling plot and floodplain plant community groundwater spatial
variability.
RIFS-26 USFWS 11/14/2012 “The Service has the following outstanding questions from
PSP Section 6.6.4.3.1.4 relating to this objective, and we
expect they will be addressed in the RSP:
Is “abundance” density appropriate or will some other metric
be applied?
What is the “elevation” reference: ASL, an arbitrary datum,
or some elevation that can be linked to the local river or
groundwater stage (keep in mind the river drops
downstream, so that must be accounted for also)?
Is there a citation for others using 2-meter square plots?
What is the shape of these plots? A square plot may not be
appropriate for a narrow band of seedlings along a specific
elevation in the gradient above the river.” –pdf page 71
Plant abundance is defined by a number of measures including
Point intercept transects, ocular estimates of cover, tree basal area
as defined in Riparian Vegetation Study Downstream of the
Proposed Watana Dam Section 11.6. Elevation reference
throughout the Riparian Instream Flow Study is NAVD88. Vertical
datum. Plant sampling methods, including plot size and shape, are
detailed in the Riparian Vegetation Study Downstream of the
Proposed Watana Dam Section 11.6.4.2.
Two meter square plots are no longer in the sampling design; one-
meter square plots will be used for seedling sampling (Mueller-
Dombois, D. and H. Ellenberg. 1974. Aims and Methods of
Vegetation Ecology. Wiley, New York.; Elzinga, C.L., D.W. Salzer,
and J.W. Willoughby. 1998. Measuring and Monitoring Plant
Populations. UDI, Bureau of Land Management). See Section
8.6.3.3.2 for sample plot dimensions.
RIFS-27 USFWS 11/14/2012 “Rood et al. 2007) of dominant riparian species (e.g., balsam
poplar, willows). The discussion in the PSP on ice processes
(Section 6.6.4.4.1) was unfocused, and essentially provided
no discernible methods: “Final details of the geomorphology
and ice processes modeling … will be developed as the 2012
studies are obtained.” AEA provided a substantial update for
the proposed draft RSP methods at the 24 October 2012
TWG meeting. The steps proposed by AEA are:
1. One goal of this study will be to characterize the role of
river ice in establishment, survival and recruitment of
dominant riparian species. There has been limited research
into this question on boreal rivers: Engstrom et al., Effects of
River Ice on riparian vegetation. (Freshwater Biology 2011,
The method in modeling the ice processes-floodplain vegetation
interaction presented by AEA at the October 24, 2012 TWG
meeting is explained in detail in the Riparian Instream Flow Study
Section 8.6.3.4.2
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56: 1095-1105).
2. A similar study approach and methods will be developed
and is presented in the RSP.
3. The magnitude, frequency and longitudinal distribution of
ice events affecting riparian species/communities will be
assessed by a combination of on-the-ground surveys of tree i
distribution (mapping and aging with dendrochronology) and
the results of the ice processes modeling.
4. A geospatial analysis of the modeled, and empirically
mapped, locations of ice floodplain interactions will be
conducted.
5. Tree ice scars will be used to map ice floodplain
interaction zones along the river.
6. Ice process modeling will also be used to identify the
vertical and lateral extent of ice floodplain vegetation
interaction zones.
The Service believes this is a reasonable approach for
characterizing the role of river ice in plant communities. We
look forward to the RSP also describing how the role of river
ice will be used to predict the potential plant community
change resulting from project operations.” –pdf page 72
RIFS-28 USFWS 11/14/2012 “The proposed soil sampling techniques are included in PSP
Section 6.6.4.3.1.5, but based on these techniques it is
unclear how our requested objective to characterize the role
of sediment deposition in the formation of floodplain and
riparian soils will be met, and how sediment deposition
affects the rate and trajectory of plant community succession
(email 11 September 2012). This objective should investigate
the rate of deposition, depth of sediment, and soil profile
development required for natural floodplain plant community
succession, and then use the predicted sediment deposition
characteristic from the Fluvial Geomorphology Study to
predict the effects of Project operation on floodplain plant
communities. AEA provided the following response to our
concern (TWG meeting 24 October 2012), which we find
satisfactory for now and look forward to the details in the
RSP.” –pdf page 72
Analysis of floodplain soil and plant community development is
presented in Section 8.6.3.5. The stated goal of the study is to
characterize the role of erosion and sediment deposition in:
evolution of floodplain plan form, soil development and trajectory of
plant community succession. This study will investigate the
geomorphic evolution of Susitna River study area floodplain
stratigraphy, and soils, and associated plant community
succession. Complete study approach and methods are presented
in Section 8.6.3.5.
RIFS-29 USFWS 11/14/2012 "The Service also asked how the results from this objective
will be used to predict potential Project-related changes in
Natural seed dispersal hydro and sediment regime relationships
will be measured in the field (individual studies). Project operational
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seedling establishment and recruitment into the population
(11 September 2012 email). AEA responded (TWG meeting
24 October 2012) with the following satisfactory response,
and we look forward to the details in the RSP. Natural seed
dispersal hydro and sediment regime relationships will be
measured in the field (individual studies). Project operational
changes to the natural hydro and sediment regimes will be
assessed and changes to the natural seedling recruitment
and establishment “physical template” will be assessed.
Potential Project-related changes to seedling recruitment and
establishment sites will be compared first at the Focus Area
sites and then throughout the Study Area to model potential
Project-related changes in the recruitment “safe site”
conditions (Harper, J. 1977. Population Biology of Plants), as
described in draft RSP Sec 8.6.3.5 and Sec 8.6.3.7." -pdf
page 71.
changes to the natural hydrograph and sediment regimes will be
assessed and changes to the natural seedling recruitment and
establishment “physical template” will be assessed. Potential
Project-related changes to seedling recruitment and establishment
sites will be compared first at the Focus Area sites and then
throughout the study area to model potential Project-related
changes in the recruitment “safe site” conditions (Harper, J. 1977.
Population Biology of Plants), as described in Section 8.6.3.5 and
Section 8.6.3.7. Seedling establishment and recruitment study
detailed approach and methods are presented in Section 8.6.3.3.2.
RIFS-30 NMFS 11/14/2012 “Some general terminology in the PSP needs to be clarified.
To avoid confusion, it is important that readers and study
plan users be on the same page, interpreting terms the same
way. Define and standardize usage of the words site, study
site, intensive study site, study area, project study area,
project study site, focus area, each study area, plot, and
plotted. Consider changing the phrase riparian habitat to
floodplain habitat or explain how the two terms are being
used differently (or interchangeably). Although they refer to
the same habitat the word riparian is sometimes construed to
mean a narrow fringe of vegetation immediately adjacent to
open water. In the Susitna River valley the floodplain (Le.
habitat influenced by ground and surface water interactions)
can extend thousands of feet from the river. The ancient
beaver dams at Whiskers Slough which appear to be
connected to the river by ground water beneath floating
Sphagnum bogs are one example.” –pdf page 79
In the Riparian Instream Flow Study the term Focus Area
supplants: study site and intensive study site. Study area is defined
as the extent of the Susitna River anticipated to be affected by
Project operations. The term riparian habitat has been revised to
read “floodplain habitat” in the Riparian Instream Flow Study.
RIFS-31 NMFS 11/14/2012 “The proposed study plan should clarify what is meant by the
term "baseline", which is an essential, critical term. PSP
Section 6.6.2 states that " ... of primary importance ...is the
previous vegetation mapping and successional dynamics
studies by McKendrick et al. (1982), Collins and Helm (1997),
and Helm and Collins (1997) ... previous works will be used
Baseline conditions are the current conditions of the Susitna River
and floodplains under the natural flow, sediment and ice processes
regimes. Baseline condition documentation and analysis is a goal
of the Riparian Instream Flow Study. The 1980s study data is an
invaluable description of riparian conditions in 1980s and is
therefore one of the multiple sources of data used in the Riparian
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as a - baseline to develop a stratified sampling protocol for
this and the botanical riparian study" (p. 6.44) and that the
"riparian study-modeling efforts will build upon the Collins
and Helm (1997) ... conceptual model" (p. 6-43). The need
for new data is acknowledged " ... to provide a contemporary
understanding of the baseline riparian conditions existing
(emphasis ours) in the Susitna River (p. 6-44)." Which
dataset(s) does the applicant consider representative of
baseline conditions? Thirty year old data, data collected
during studies for this ILP (and prior to impacts from the
presumed hydropower dam operations), or some
combination?” –pdf page 79
Instream Flow Study. The study builds upon and updates these
studies. See Section 8.6.1.1.
RIFS-32 NMFS 11/14/2012 “The July 2012 ABA PSP goal is vague and does not
specifically address the need to characterize and quantify
current conditions. The model as proposed would rely heavily
upon historic data rather than data to be collected during the
study. Historic data (1980s) are important for model
development but they are not representative of current
conditions. A two year study is too short to provide
meaningful data; it takes at least three years for seedlings to
be recruited into a reproductive cohort (Rood et al. 2007).
Models should integrate new data collected over the span of
five years, at a minimum, which is the average life span of a
chinook salmon. A characterization and tabulation of current
conditions can be used as an index to quantify predicted and
measured changes to riparian/floodplain vegetation in the
Susitna River Valley.” –pdf page 80
See AEA’s response to comment RIFS-31 for discussion of
approach to characterizing current conditions.
For the remainder of AEA’s response to this comment, see RIFS
24
RIFS-33 NMFS 11/14/2012 “Clearly:.:. state the intention to expand the scope of
literature surveys and syntheses to include literature that
describes processes and functions of similar rivers with and
without hydropower projects. Include literature that integrates
surface and groundwater interactions with plant community
distribution and response to different riverine functions.
Studies on the Nyack River (Montana) and lower Talkeetna
River (Alaska) floodplains have demonstrated that plant
species richness and productivity patterns within alluvial flood
plains are strongly influenced by similar factors and
processes regardless of physiographic setting (Mouw et al.
2009). The more comprehensive literature review will better
The review will include studies of surface and groundwater
interactions. See Section 8.6.3.1 for full details.
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reflect the current understanding of riparian function relative
to instream flow and will provide better insight into the
potential project effects.” –pdf page 80
RIFS-34 NMFS 11/14/2012 “The detailed timeline for completion of the different studies
that ABA is developing for inclusion in the RISF study should
help clarify some of the confusion about which product will
inform subsequent steps in the study. Please provide clear
linkages between different products and studies. For
example, state that plant communities will be mapped before
botanical riparian site selection and study can commence.
Section 6.6.4.3 implies that a mapping and measurement
approach will build upon those measures developed for the
Botanical Riparian Study (which is built upon vegetation
mapping results). This is probably not what AEA intended to
imply, and detailed study interaction charts and timelines
should help clarify this.” –pdf pages 80-81
See AEA’s response to comment RIFS-05.
RIFS-35 NMFS 11/14/2012 “The need for and methods to integrate current conditions
and historic data into sub-models described in other AEA
PSPs in order to predict possible effects from the proposed
project should be the endpoint of this study. Although AEA
states that they will develop a " ... series of biological and
riverine process studies .... to supplement historic 1980' s
and 1990s' data ... " they do not say when the studies will be
conducted. A description of how AEA proposes reaching that
endpoint, including a timeline for the completion of different
sub-models and a schematic of how the different sub-models
inform subsequent models, would be helpful as a summary of
the products the applicant intends to develop to address
proposed objectives. Figure 6.5-3 in the PSP is a rough
schematic of relationships between different studies, models,
and processes, however it needs to be updated and clarified.
Many linkages are missing, and studies intended to inform
subsequent studies appear to be scheduled simultaneously
rather than sequentially. Revised interaction charts and
timelines provided in late October appear to address some of
these concerns.” –pdf page 81
See AEA’s response to comment RIFS-05.
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
FISH-01 TU 11/14/2012 “Meaningful collection and evaluation of baseline date for fish
populations—including estimates of juvenile density, adult
escapement, spawning rates and condition—will require
significantly more time than allowed in a two-year period.” –
pdf page 5
The Fish and Aquatic Resources studies will begin with a review of
biological data available from the 5 years of study in the 1980s and
additional studies conducted in various locations throughout the River
between 2000 and 2011. AEA also initiate fish studies in 2012 that will
be expanded upon in 2013, and 2014. All of these data, a total eight
years of study on Fish and aquatic populations in the Susitna River will
support AEA’s License Application. The 13 proposed studies describe
in Section 9 of the study plan have been designed to provide
meaningful data to describe the fish populations and the aquatic
habitats that they rely upon and include estimates of fish density,
distribution and apportionment of spawning salmon, among a myriad of
other relevant study objectives. AEA licensing study program has
been designed to provide a comprehensive and rigorous data set over
three sampling season that can be combined with existing data to
describe baseline conditions and provide the basis for assessments of
potential project impacts and development of appropriate Protection,
Enhancement, and Mitigation plans. Additional years of data collection
are not needed to improve the quality of the data necessary to support
a FERC License Application.
FISH-02 CSDA 11/14/2012 “The studies of the various life stages, distribution,
abundance, escapement and habitat utilization of fish should
be through a life cycle of a Chinook salmon which is 5 to 7
years. This is necessary considering the lack of knowledge
about the affected fish and marine mammal species and their
habitat needs. Two years is inadequate to document
baseline biological conditions. Susitna River Chinook
populations are currently depressed. If baseline studies are
done under a period of low abundance, a bias will be
introduced that will hamper accuracy of future modeling
outputs. This can be applied to all the 13 studies of Fish and
AquaticResources.” –pdf page 3 second bullet
See AEA’s response to comment – FISH-01.
Anadromous salmon populations are variable and are subject to long
term cycles in abundance that are driven by circulation patterns acting
on a global scale and subsequently affect ocean conditions. AEA
concurs that Chinook salmon populations statewide presently appear
to be in a low abundance phase of the cycle. AEA is also aware that
this low abundance phase is expected to continue for the next several
years, so adding more years of Chinook salmon data after 2014 is not
likely to address a different phase of the cycle and would not likely
improve the quality of the data collected regarding Chinook salmon
populations.
Understanding the interannual variability in fish abundance has been
an important influential factor in AEA’s approach to characterizing the
Fish and Aquatic Resources and assessing potential project impacts.
For example, AEA has proposed a habitat-based characterization of
the Fish and Aquatic Resource and will be collecting information on
relative fish abundance, distribution and apportionment of fish by
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
representative habitats not on counts or estimates of fish populations.
The fish data collected by habitat type will help us understand the fish-
habitat relationships that are currently occuring. The models that AEA
will use to predict potential Project impacts are also habitat based and
will make predictions of changes to aquatic habitat not absolute fish
numbers to demonstrate an effect. These models have the advantage
of incorporating both site specific data on fish habitat as well as data
from numerous studies in other systems where fish habitat has been
characterized. Thus, if the current data set for Chinook salmon habitat
appears more restrictive, perhaps as a function of fewer fish occupying
only the best habitats, the model can be adjusted to broaden the range
of habitat suitability criteria applied to the model. The AEA program
has been designed to collect detailed and appropriate data that will be
effective in addressing potential impacts associated with the proposed
Wantana Dam, will help to develop protection, mitigation and
enhancement measures, as appropriate.
FISH-03 Long, Becky 11/13/2012 Two years are inadequate, request for 5 to 7 year study –
top of pdf page 2
See AEA’s response to comment FISH–01.
FISH-04 TCCI 11/07/2012 TCCI is concerned that aquatic resource studies are limited
by the ILP two year time frame. Mandatory conditioning
agencies USFWS and NMFS both have requested study
periods in accordance with the life cycle of study species.
TCCI directly represents the interest of commercial and sport
fisherman in the region. The annual Susitna Chinook run
ushers in the Susitna Valley’s tourist season and provides a
sport/subsistence resource for residents. The regional
economy depends on the health of the stock and it’s habitat -
from fishing tours to lodging, restaurants, and shops. In a
Sept. 5, 2013 letter to AKF&G Commissioner Campbell,
TCCI expressed it’s concern:..
See AEA’s response to comment FISH–01.
FISH-05 CCC 11/15/2012 “How will fish studies be conducted in the winter without
impacting the behavior of the fish?” -pdf page 2 – Bullet five
Active fish sampling methods are used to capture fish and, as such,
are intended to alter fish behavior. In addition, several passive
methods for monitoring fish movements and diel behavior are
proposed in Fish Distribution and Abundance in the Middle and Lower
Susitna River Study plan and described in Section 9.6.4.5. These
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
include use of a multibeam sonar technology (DIDSON), underwater
video, and by tagging fish with PIT and radio tags and remotely
tracking them over time.
FISH-06 FERC 11/14/2012 “In their May 31, 2012, study requests, FWS and NMFS
requested a study to characterize the use of biological flow
cues for various life-history behaviors. Neither the PSP nor
the draft RSP include an approach to address this objective
or provide a justification for why the requested study is not
included. Please include in your RSP an approach to
address the study objective, or provide an explanation for
why it is not adopted in your study plan.” –pdf page 14-15
In response to the FWS and NMFS study requests, an evaluation of
biological flow cues has been included in the Fish and Aquatics
Instream Flow Study (see Section 8.5.4.5.1.3). Long-term adult
salmon escapement data will be examined to identify relationships
between temporal patterns in environmental conditions and salmon
distribution, abundance and migration. Analyses of possible
relationships between climatic, hydrologic, and fish habitat indices and
salmon abundance and migration timing will be based on available
long-term data sets for Deshka River Chinook salmon and Yentna
River sockeye salmon, though other long-term data sets pertaining to
salmon migration timing and abundance will be included if available.
FISH-07 NMFS 11/14/2012 “The FERC ILP two-year time frame makes it difficult and
probably impossible to collect adequate site specific data in
order to build models that will reflect this variation in
characteristics driving fish habitat relationships. NMFS
requests that FERC extend this timeline to allow design,
completion and analysis of studies that adequately address
the potential impacts to those relationships. If this short study
period persists, then having well developed study plans prior
to beginning field data collection becomes paramount. Given
the current deficiencies in the proposed study plans for ‘Fish
and Aquatic Resources,’ it is unlikely that study plan
deficiencies can be remedied so that study plans that
withstand scientific scrutiny and meet NMFS' and FERC's
criteria will be completed in time for field data collection to
begin in 2013.” -pdf page 85
For the reasons described in AEA’s response to comment FISH–01,
the FERC ILP two-year study process is adequate to meet the goals
and objectives of the study program.
FISH-08 NMFS 11/14/2012 “Study plans must have clear objectives including the
purpose or information need. A clear objective is necessary
in order to refine study methods. Clearly defined objectives
help to avoid collecting unnecessary or irrelevant data.
Objectives should be developed to provide specific
information or to test a hypothesis so that the appropriate
AEA concurs, as was evidenced by the planning process that has
occurred in 2012. Initial study objectives were developed with input
from the TWG in March of 2012. Since that time AEA has conducted
numerous TWG meetings and subgroup meetings to identify new
objectives, and modify and refine existing study objectives.
Preliminary study objectives were prepared by AEA in draft study
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
statistical design can be selected. The purpose or
information need shows the relationship of the study to
previous work and how the study results will be applied.” -pdf
page 87
requests, the objectives were then modified and refined based on
agency comments received first for the PSP and then subsequently for
the Interim-RSP prepared and distributed by AEA in October 2012.
AEA believes that this iterative 9-month process has resulted in
specific and clear objectives that will adequately describe baseline
conditions and support environmental analysis that will accompany the
AEA FERC License Application.
FISH-09 NMFS 11/14/2012 “The study plan need to show a good understanding of the
topic based upon a review of other related studies. Thorough
reviews of previous studies are necessary to avoid repeating
previous work and to build upon the current information
base. Literature reviews help to avoid previously identified
sampling problems and to address conflicting results.
Previous site-specific information can help to guide sample
site selection, sample timing and frequency, and collection
methods.” –pdf page 87
AEA agrees. AEA’s science team has been reviewing and
summarizing the existing literature on the Susitna River throughout
2012. Our understanding of the extensive historic data has grown
through 2012 and is reflected in the changes and additional detail
added to the RSP. Continued synthesis of the existing information is
an important component of several Fish and Aquatic study plans,
including Sections 9.5, 9.6, 9.8, and 9.11.
FISH-10 NMFS 11/14/2012 “Study methods must be developed to address the stated
objective. Methods should include:
• descriptions of sample locations;
• sampling collection timing and frequency; and
• how samples will be collected, handled, and processed.” –
pdf page 87
Study method details are described throughout the RSP. It is the very
nature of sampling in a dynamic natural environment that some details,
size of nets to be used and specific sampling locations, need to be
determined at the time of field data collection as they are dependent
upon flow and access and other physical conditions of that location at
the time of sampling. In order to ensure consistency and reliability
among samples we will be developing Fish Distribution and
Abundance and River Productivity Implementation Plans.
The implementation plans, described within specific study plans, will
include the level of detail sufficient to instruct field crews in data
collection efforts. In addition, each plan will include protocols and a
guide to the decision making process in the form of a chart or decision
tree that will be used in the field, specific of sampling locations, details
about the choice and use of sampling techniques and apparatuses,
and a list of field equipment needed.
FISH-11 NMFS 11/14/2012 “Depending upon the study design, sample locations should
be selected randomly or randomly among strata to reduce
variability among groups, or alternately, to represent the
range of independent variables. Sample timing and
AEA has proposed a habitat-based approach to the characterization of
the Fish and Aquatic Resources that incorporates both systematic
sampling across reaches and habitat types with random selection
within habitats. Sampling timing varies from bi-weekly for emergent
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frequency should be developed based upon the rate of
change of the parameter under investigation and to
represent the temporal scale of potential impacts
(treatments).” –pdf page 87
fish to seasonally for algae and macroinvertebrates and was based on
anticipated changes in habitat use that are related to life history
dependent and seasonal behavior exhibited by aquatic organisms.
FISH-12 NMFS 11/14/2012 “The study design should include measures of sample
representativeness, accuracy, and precision.
Representativeness is a measure of the scale of spatial and
temporal inference. Representativeness is dependent upon
sample replication and associated error. Measures of
accuracy are a comparison of sample values to known
values, while precision is a measure of the difference
between two or more sample values. Population estimates
can be used to test for the accuracy of catch per unit effort
values as an indication of fish density. Approximately 10% of
the samples should be duplicated to determine the precision
of catch per unit effort values.” –pdf page 87-88
There are more than 13 distinct study designs included in the Fish and
Aquatic Resources studies and although there is much variability of
experimental design from study to study, there are consistencies in
sampling approaches that address representativeness, accuracy and
precision. Overall, AEA has taken a habitat-based study design that
stratifies sampling by geomorphic reach and physical aquatic habitats
that occur within those reaches. The basis for the delineation of the
reaches and habitat types within the sampling strata are consistent
across all resources and include remote reach delineation in the
Geomorphology Study (Section 6.5), and habitat delineation in
Characterization and Mapping of Aquatic Habitats, Section 9.9.
Replicate sampling within these predefined reaches and habitats will
allow for synthesis of data at the same representative spatial scale
across studies and resource areas.
Temporal representativeness is more study specific as it pertains
specifically to the time step required to address specific objectives and
this will vary from diel sampling to evaluate day and night movement
patterns to seasonal sampling to evaluate changes in patterns of river
productivity. In all studies replicates are being collected within the
study-specific time step.
During the September 13th Fish Distribution and Abundance Subgroup
meeting and at the October 25th TWG meeting, the USFWS noted that
collection of population estimate data was not necessary to
characterize baseline conditions, nor to evaluate potential Project
impacts and recommended eliminating this scale of data collection
from the studies. On both occasions some discussion ensued but no
one present dissented with this opinion. As a result, the studies were
revised to eliminate data collection designed to estimate fish
populations. It was stated that relative abundance and
presence/absence data was adequate to describe fish populations and
habitat use and infer potential impacts to fish. Thus, AEA does not
propose to evaluate accuracy of fish counts but will use relative
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
abundance estimates to compare across strata as appropriate based
on sampling method used. AEA has agreed to evaluate precision of
fish collection methods and will address how sampling events will be
randomized to determine sampling precision by habitat type and
method in the Fish Distribution Implementation Plan.
FISH-13 NMFS 11/14/2012 “Sampling plans also must describe how sampling efficiency
will be determined. Differences in sampling method efficiency
among locations will need to be accounted for to validate
data analyses. For example, the efficiency of electrofishing
may be determined as the number of fish captured per
number of fish observed (Beechie et al. 2005). The efficiency
of electro fishing likely will vary between clear-water sloughs,
tributary mouths, deep stained streams, and the turbid
mainstem and side channels or between sites with low and
high water velocity. Therefore, differences in catch per unit
effort (CPUE) among habitats could be due to differences in
sampling efficiency. Comparisons among locations must
either correct for differences in sampling efficiency or be
limited to those locations where efficiency of methods is
similar.” –pdf page 88
Although AEA agrees that understanding the efficiency of sampling
methods is important when generating populations estimates based on
fish counts, AEA disagrees that determine a level of sampling
efficiency is necessary for determination of relative abundance. As
stated in comment response FISH – 13, population level estimates are
not included in the RSP at the request of USFWS. AEA proposed fish
sampling focuses on fish distribution (presence/absence) and relative
abundance. As described in RSPs 9.5 and 9.6.4.3.1 all methods will
be conducted consistent with generating estimates of CPUE that are
meaningful and facilitate comparison of counts or densities of fish over
space and time. This includes calibration and quality control of
methods and documentation of conditions that affect sampling
efficiency—such as visibility, water temperature, and conductivity—to
ensure that a consistent level of effort is applied over the sampling unit.
In addition, in the event that these data will be used for statistical
comparison during future effects analysis. Section 9.6.4 indicates that
AEA will determine how to incorporate additional samples to evaluate
precision of count data within habitats and by method and will include
this design detail in the Fish Distribution and Abundance
Implementation Plan that will be filed with FERC on March 15, 2013.
FISH-14 NMFS 11/14/2012 “The study plan should identify any data that will be used
from other sources and identify that external data quality.
Many ABA study plans are using data from other sources.
For example, Middle and lower river Fish study plans are
proposing to use information from ground-water related fish
habitat studies, habitat characterization, and fish passage
studies, but also will need data from the water quality and
river productivity studies. They should identify exactly what
information is to be obtained from these other studies and
how the external data will be evaluated for data quality and
application to the stated objective. For example, if water
Data interdependencies between and among studies are identified in
each study plan. For example, Sections 9.5.7 and 9.6.7 describe the
exchange and flow of data.
Regarding data quality, in 2012 AEA established data standards and
QAQC procedures that have been and will continue to be implemented
across all water-related resources and include standards for location
data. The intent of establishing these data standards was to ensure
that all data are collected in appropriate fashion for exchange across
various study plans an resources.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 211 December 2012
Fish and Aquatic Resources
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
temperature or turbidity data are to be used from the water
quality study, the studies need to discuss explicitly how
sample values represent habitat characteristics applicable to
the evaluation of the distribution, relative abundance, or
growth rates of fish species.” –pdf page 88
FISH-15 NMFS 11/14/2012 “The study plan should describe the statistical design for
data analyses. A description of the statistical design and how
the study results will be used is necessary for the evaluation
of study methods. If the study is being developed to
determine fish density per geomorphic classification type,
which will be extrapolated to estimate density at unsampled
locations, then sampling locations and timing must be
selected for data analyses to meet this objective. Sampling
locations, timing and frequency will differ between a study
designed to test for significant differences in fish metrics
among groups of different geomorphic classification, and one
that will use regression to test for significant relationships
between fish community metrics and habitat characteristics.”
–pdf page 88
As described in the Fish and Aquatic Resources study plans, data will
be collected to characterize existing conditions as well as to inform
future effects analysis. AEA agrees that it is important to design
studies to facilitate analysis and to a large extent has done that by
incorporating specific objectives such as, the early life history of
juvenile salmon and winter spawning species, and through
development of predictive models such as fish bioenergetics model,
the water surface elevation model for Cook Inlet beluga whales, and
the instream flow model. In other cases it is premature to understand
exactly what comparisons or analysis will best to facilitate an
understanding of potential Project impacts. In these cases, more
specific information about the type, magnitude, timing, and location of
potential impacts is needed prior to determining what are the correct
analyses or even appropriate data comparisons. To facilitate these
future data analyses, AEA has proposed broad and intensive sampling
of fish and aquatic habitats that will occur on a monthly time step from
June 2013 through October 2014. These data are being collected in a
manner to facilitate statistically valid comparisons (e.g. standard
protocols, derivation of CPUE) to address potential Project impacts
during final analysis of the Project.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 212 December 2012
Study of Fish Distribution and Abundance in the Upper Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
FDAUP-01 FERC 11/14/2012 “In sections 9.5.4.1 (Upper River) and 9.6.4.1 (Middle and Lower
River), [AEA describes] methods for selecting study sites for [the] fish
distribution and abundance studies. In both sections, you propose a
five-level, nested stratified sampling approach based on the following
stratification scheme: (1) major hydraulic segment, (2) geomorphic
reach, (3) mainstem habitat type, (4) main channel mesohabitat, and
(5) edge habitat. In Figures 9.6-2 through 9.6-5, you present
schematics of strata proposed for sampling in the Lower River and
Middle River segments; however, you omit level 2 (geomorphic
reaches) from the figures. It is unclear how you intend to describe fish
distribution and relative abundance without using level 2 of your
stratification scheme. Please consider revising your site selection
methods to be consistent with the nested (hierarchical) approach;
explain how mesohabitat units from main channel habitats will be
selected to represent unique geomorphic reaches; and describe how
data collected in mesohabitat units will be extrapolated to broader
scales (e.g., geomorphic reach).” –pdf page 13
Level two stratification (geomorphic reaches) is discussed in
Section 9.5.4.1 but is not included in Figure 9.5-2. because not
all habitat types will be found within each geomorphic reach
and inclusion would make the figure confusing. Site section for
fish sampling in the Upper River will necessarily vary with
habitat and will not be stratified equally among geomorphic
reaches. Stratification of site will occur as much across
geomorphic reaches but is limited due to habitat availability,
access and safety. Site selection methods describe a nested
hierarchical approach; mesohabitat units will be selected using
a random approach. See Section 9.5.4.1.
FDAUP-02 FERC 11/14/2012 “Similarly, the Instream Flow Study (Section 8.5) proposes ten focus
areas for intensive sampling in the middle reach. The number and
location of focus areas for the Lower River and Upper River segments
have not been proposed. In the Fish Distribution and Abundance
Study, Figure 9.6-5, you propose to sample a total of 40 different
habitat types (i.e., 8 each of 5 different habitat types: side slough,
upland slough, side channel, beaver complex, and tributary mouth
habitat types) within the 10 proposed Middle River focus areas.
However, you do not describe how you will select these sites within
the focus areas. In [AEA’s] RSP, please describe how these habitat
units will be selected within the ten focus areas.” –pdf page 14
AEA has not proposed any IFS Focus Areas in the Upper River
Segment since the effects of flow regulation from Project
operations will not occur above the dam. Please see AEA’s
responses to comments FDAML-04 and IFS-004 regarding
extending studies into the Lower River Segment.
FDAUP-03 FERC 11/14/2012 “In the Study of Fish Distribution and Abundance in the Middle and
Lower Susitna River (Section 9.6), you describe in detail in section
9.6.4.2 and Table 9.6-2 your proposed sampling frequency. However,
the same level of detail on sampling frequency is not provided in your
Study of Fish Distribution and Abundance in the Upper Susitna River
(Section 9.5), and the information provided is insufficient to determine
the frequency of each sampling event. Please revise section 9.5.4.2
of your RSP to include a detailed sampling schedule for the Study of
Selection of main channel habitats is described in the same
level of detail as in the Middle and Lower River (Sections
9.5.4.2 and 9.6.4.2). However, the manner in which tributary
habitats will be sampled varies greatly between the two study
plans. Because of access issues (steep canyon walls and
swift, non-wadeable streams), less habitat mapping detail is
available from the Upper River tributaries. These tributaries will
be selected based on accessibility, among other criteria. For
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 213 December 2012
Study of Fish Distribution and Abundance in the Upper Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
Fish Distribution and Abundance in the Upper Susitna River (9.5) that
includes the sampling frequency for each method.” –pdf page 14
this reason, AEA proposes to sample 25% of the mapped
habitats which will encompass replicates of all habitat types.
See Section 9.5.4.2 and Section 9.9.
FDAUP-04 FERC 11/14/2012 “Details on the PIT-tag portion of the study were requested during the
September 13, 2012, study plan meeting, including the number and
species of fish to be PIT-tagged. However, this level of detail is not
included in your draft RSP. The requested PIT tagging information is
needed to evaluate whether the proposed methods will be sufficient
to describe life history timing, migration behavior, etc. Therefore,
please include in your RSP specific information on the number and
species of fish to be PIT tagged.” –pdf page 14
Additional information on PIT-tagging can be found in Section
9.5.4.4.12. The PIT tag work is predominantly focused on
juvenile Chinook salmon. All juvenile Chinook salmon of
taggable size will be tagged. Up to 1000 fish per species per
array will be tagged based on proximity to PIT arrays. Target
species include Arctic grayling, burbot, humpback white fish,
round white fish, Dolly Varden, and northern pike if present.
Protocols for pit tagging will be described in further detail in the
Fish Distribution and Abundance Implementation Plan. As
specified in Section Section 9.5.4, AEA will file the study
implementation plan with FERC by March 15, 2013.
FDAUP-05 ADNR -
ADF&G “Recommend a section be included to specifically address winter
sampling methods. Minnow trapping under ice should be conducted
during the winter period to document fish presence and absence; we
also recommend evaluating the feasibility of under ice videography.”
–pdf page 22
Because of winter access issues and accompanying safety
concerns, no winter sampling is planned for the Upper River.
Details on the winter approach in the Middle and Lower River
have been included in Section 9.6.4.5.
FDAUP-06 ADNR -
ADF&G 11/14/2012 “Fish distribution efforts should be directed at streams not already
identified as supporting anadromous fishes in ADF&Gs Anadromous
Waters Catalog (AWC). AWC information can be accessed through
ADF&Gs online Fish Resource Monitor at:
http://gis.sf.adfg.state.ak.us/FlexMaps/fishresourcemonitor.html?mod
e=awc” –pdf page 22
Because of this general inaccessibility, very rugged terrain, and
mostly non-wadeable stream channels, near census mapping
(100 percent coverage) is challenging and in some cases
unsafe or impossible. For these reasons, only tributaries
mapped by the Characterization and Mapping of Aquatic
Habitats (See Section 9.9; Table 9.9-2) will be eligible for fish
distribution and abundance sampling. Up to 18 tributary
streams will be targeted for sampling during 2013 and 2014.
Of the 18 tributaries selected for sampling, all tributaries in
which Chinook salmon juveniles or adults were observed within
or at the mouth of a tributary during 2012, or during previous
surveys by Buckwalter (2011) will be sampled. AEA agrees to
the request made by ADF&G and of the remaining tributaries
that are suitable for sampling listed in Section 9.9, Table 9.9-2,
efforts will be focused on streams that are not already identified
as supporting anadromous fishes in the ADF&G AWC (see
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 214 December 2012
Study of Fish Distribution and Abundance in the Upper Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
updated Section (9.5.4.1).
FDAUP-07 ADNR -
ADF&G 11/14/2012 “Baseline metals and mercury assessment are not the same. What is
being sampled and to what standards? What metals are being
studied?” –pdf page 22
Object 5 has been amended to differentiate between metals
and mercury (Section 9.5.4.3.5).
As described in Baseline Water Quality Study (Sections
5.5.4.5, 5.5.4.6, and 5.5.4.7), sediment, fish tissue and water
will be sampled for metals. EPA methods will be used for
analysis. Table 5.5.-3 contains a list of all the metals that are
being sampled. As described in Mercury Assessment and
Potential for Bioaccumulation Study Section 5.7.4.2,
vegetation, soil, water, sediment, sediment pore water,
piscivorous birds and mammals, and fish tissue (see Section
5.7.4.2.6) samples will be evaluated for mercury. Modeling will
be used to estimate methylmercury concentrations in fish
(5.7.4.3). Target fish species for baseline metals testing
include: Dolly Varden, Arctic grayling, whitefish species, long
nose sucker, lake trout, burbot, and resident rainbow trout.
Target fish species for mercury sampling include: Dolly Varden,
arctic grayling, stickleback, long nose sucker, whitefish species,
lake trout, burbot, and resident rainbow trout.
FDAUP-08 ADNR -
ADF&G 11/14/2012 “Recommend to add: 8. Identify spawning locations for both
anadromous and resident fish species. The need is noted below in
text but not specifically included in goals and objectives.” –pdf page
23
Radio tags will be implanted in up to 30 fish of selected species
(Arctic grayling, burbot, humpback white fish, round white fish,
Dolly Varden, and northern pike if present). These tags will be
tracked via aircraft and/or boat on a monthly basis to describe
seasonal movements with emphasis on identifying spawning
and overwintering habitats within the hydrologic zone of
influence upstream of the project. See Section 9.5.4.4.12.
Chinook salmon spawning locations will be documented in a
similar manner in the Salmon Escapement Study. See Section
9.7.4.2.
FDAUP-09 ADNR -
ADF&G 11/14/2012 “Arctic grayling were listed as “believed to be” the most abundant
species in the inundation zone (Delaney et al. 1981, Sautner and
Stratton 1983), yet are not included in the species of interest listed
above. Recommendation - Identify and list target species for this and
every study.”–pdf page 23
AEA has added Arctic grayling to objective 2, which identifies
all of the target species (Section 9.5.1).
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 215 December 2012
Study of Fish Distribution and Abundance in the Upper Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
FDAUP-10 ADNR -
ADF&G
11/14/2012 Documentation of all fish collected during sampling shall include
species and length.” –pdf page 23
Consistent with this comment, Section 9.5.4.4.11 indicates that
all fish captured will be identified to species and up to 30 fish
per species per day will be measured for length as per ADF&G
protocol.
FDAUP-11 ADNR -
ADF&G 11/14/2012 “Species listing in this section does not match species list on Table
7.5.9. Update table with current information.” –pdf page 23
The species list in Sections 9.5.1, 9.5.2, and 9.5.4 match the
list in Table 9.5-1. These lists have been updated by cross-
referencing information from 2012 studies.
FDAUP-12 ADNR -
ADF&G 11/14/2012 “Chinook salmon are the only anadromous species known to occur in
the upper Susitna River and tributaries although the information on
the extent of their distribution is limited.”
Dolly Varden in Alaska systems are not evenly distributed and may
be found in tributaries.
Longnose suckers are found in high densities in Upper Susitna
tributaries.” –pdf page 23
Agreed. However, there is currently no documentation that
Dolly Varden, humpback whitefish and long nose suckers
above Devils Canyon are anadromous.
FDAUP-13 ADNR -
ADF&G 11/14/2012 “7.5.4.1 Passive and Active Sampling (Page 7-13)
“nighttime sampling”
Long daylight hours during the summer may reduce the difference
between day and "night" sampling effectiveness. The periods of
twilight are important sampling periods.” –pdf page 23
Agreed. AEA has revised Section 9.5.4.3 to include language
that reflects sampling during twilight hours.
FDAUP-14 ADNR -
ADF&G 11/14/2012 “7.5.4.1 Passive and Active Sampling (Page 7-13)
“and state and federal regulatory agencies will grant permission to
conduct the sampling efforts”
This statement appears to imply state and federal agencies will
automatically grant permission or permits. Recommend rewording,
i.e. Fish sampling will only be conducted after all required state and
federal permits are obtained.” –pdf page 23
Agreed. AEA has revised the language as follows “The
decisions about what methods to apply will be made… in
accordance with state and federal fish sampling permit
requirements.” And “All fish sampling and handling techniques
described within this study will be conducted under state and
federal biological collection permits. Limitations on the use of
some methods during particular time periods or locations may
affect the ability to make statistical comparisons among spatial
and temporal strata.” See Section 9.5.4.3 and 9.5.4.4.
FDAUP-15 ADNR -
ADF&G 11/14/2012 “Gill Net Sampling (Page 7-13)
Identify the net information...if we know what was used in the 1980’s
then it should be identified. What is the depth of each net? Did they
mean 7.5 ft. deep panels instead of 7.5 ft. long panels? List mesh
sizes, number of panels, panel lengths and overall net length. Will
small mesh ends be located nearshore or will sampling be random or
reversed as to mesh size close to shore? Will surface and bottom set
Net specifications will be described in further detail in the Fish
Distribution and Abundance Implementation Plan. As specified
in Section 9.5.4, AEA will file the study implementation plan
with FERC by March 15, 2013.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 216 December 2012
Study of Fish Distribution and Abundance in the Upper Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
nets be deployed? What is the targeted time duration for each set.” –
pdf page 23
FDAUP-16 ADNR -
ADF&G 11/14/2012 Electrofishing (Page 7-13) – “More detailed descriptions are needed
on how catch-per-unit-effort (CPUE) will be calculated during multi-
pass electro-fishing. CPUE results should provide a meaningful
estimate that is not significantly biased.” –pdf page 24
Protocols for electrofishing will be described in further detail in
the Fish Distribution and Abundance Implementation Plan. As
specified in Section 9.5.4, AEA will file the study
implementation plan with FERC by March 15, 2013.
FDAUP-17 ADNR -
ADF&G 11/14/2012 Electrofishing (Page 7-13) - “Due to the size of the area to be studied,
it is not clear if monthly sampling will be adequate. Further description
of the rationale for this sampling frequency is needed.” –pdf page 24
AEA will endeavor to sample on a biweekly basis during critical
transition periods (i.e., migration from natal to rearing habitats)
in May and June. Owing to the size of the area, it will be
challenging to survey each site in July-October more than on a
monthly basis. See Section 9.5.4.2.
FDAUP-18 ADNR -
ADF&G 11/14/2012 Electrofishing (Page 7-13)- ” Electrofishing should be discontinued in
a sampling reach if large salmonids are encountered. Criteria should
be developed to determine when or if electrofishing should be
discontinued when other large fish are encountered. Rainbow trout
are particularly sensitive to electrofishing. Sampling plans should
include a description of electrofishing protocols.” –pdf page 24
Agreed. AEA will cease electrofishing activities if large fish are
encountered (Section 9.5.4.4.2). Protocols for electrofishing will
be described in detail in the Fish Distribution and Abundance
Implementation Plan. As specified in Section 9.5.4, these
protocols will be consistent with NMFS (2000). AEA will file the
study implementation plan with FERC by March 15, 2013.
FDAUP-19 ADNR -
ADF&G 11/14/2012 Electrofishing (Page 7-13) “Electrofishing may be effective in the side
channels or sloughs but may have limited success in swift or turbid
waters. Suspended materials in turbid water can affect conductivity
which may result in harmful effects on fish, especially larger fish due
to a larger body surface in contact with the electrical field. Sudden
changes in turbidity can create zones of higher amperage which can
be fatal to young-of-year fish as well as larger fish. Electrofishing in
swift current is problematic with fish being swept away before they
can be netted. Similarly, turbidity increases losses from samples.” –
pdf page 24
Agreed. AEA has revised Section 9.5.4.4.2 to address this
comment.
FDAUP-20 ADNR -
ADF&G 11/14/2012 Electrofishing (Page 7-13) “ADF&G has not established SOP’s
related to electrofishing settings etc. Smith-Root is the manufacturer
of most electrofishing equipment and boats and offers certified
training in safety and use of their equipment.” –page 24
Agreed. AEA has revised Section 9.5.4.4.2 to address this
comment.
FDAUP-21 ADNR -
ADF&G 11/14/2012 Electrofishing (Page 7-13) “Field protocols and site
selection/justification is needed. Length of transects, type of
Protocols for electrofishing will be described in detail in the Fish
Distribution and Abundance Implementation Plan. As specified
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 217 December 2012
Study of Fish Distribution and Abundance in the Upper Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
substrate, geomorphic characteristics etc. need to be identified. Block
nets should be used to ensure meaningful sampling results during
backpack shocking for relative abundance surveys.” –pdf page 24
in Section 9.5.4, these protocols will be consistent with NMFS
2000. AEA will file the study implementation plan with FERC by
March 15, 2013.
FDAUP-22 ADNR -
ADF&G 11/14/2012 Trot Lines (Page 7-14) “Trot line sampling is terminal, recommend
use of alternative, non-lethal methods of burbot sampling whenever
possible.” –pdf page 24
Agreed. Hoop traps will be the preferred non-lethal method for
capturing burbot; trot lines will be used secondarily to provide
additional data. See Section 9.5.4.4.8.
FDAUP-23 ADNR -
ADF&G 11/14/2012 Trot Lines (Page 7-14) “More information needed on site selection
and rationale.” –pdf page 24
AEA has revised Section 9.5.4.1 to add additional information
on the site selection criteria. After review of the preliminary
results from the habitat characterization and mapping efforts
(9.9) selected sites will be described in detail in the Fish
Distribution and Abundance Implementation Plan. As specified
in RSP Section 9.5.4, AEA will file the study implementation
plan with FERC by March 15, 2013.
FDAUP-24 ADNR -
ADF&G 11/14/2012 Trot Lines (Page 7-14) “Burbot are mass spawners and migrate and
collect in large "balls" during the winter (January and February). This
spawning probably occurs in slow moving side channels. Under ice
video may be of some use once locations are identified.” –pdf page
24
No winter sampling is planned for the Upper River owing to
access and safety considerations. However, evaluation of the
effectiveness of both trot lines and under ice video is proposed
in the Middle and Lower River 2012-13 winter sampling
approach. See section 9.6.4.3.4.
FDAUP-25 ADNR -
ADF&G 11/14/2012 Trot Lines (Page 7-14) “Recommended reference material:
Paragamian, Vaughn L and David H. Bennett, 2008. Burbot: Ecology,
Management and Culture. American Fisheries Society, Symposium
59, Bethesda, Maryland. AFS Stock Number 54059P, 270 pages.” –
pdf page 25
AEA appreciates the suggested reference material. AEA will
review this material prior to 2012-13 winter sampling in the
Middle/Lower River and while developing the implementation
plan (Section 9.5.4).
FDAUP-26 ADNR -
ADF&G 11/14/2012 Minnow Traps (Page 7-14) “Salmon eggs are required to be sterilized
or disinfected in iodine solution under conditions of ADF&G sampling
permits.” –pdf page 25
The following language has been added: “As per ADF&G Fish
resource Permit stipulations, all salmon eggs used as bait will
be commercially sterilized or disinfected with a ten minute soak
in a 1/100 Betadyne solution prior to use.” See Sections
9.5.4.4.4 and 9.5.4.4.5
FDAUP-27 ADNR -
ADF&G 11/14/2012 Minnow Traps (Page 7-14) “When and where will minnow traps be
deployed and how will areas for deployment be selected?” –pdf page
25
Minnow traps will be selected as an alternative gear type for
sampling reaches where other methods would be ineffective
(Section 9.5.4.4.6). This determination will be made on-site
based on site characteristics. Detailed protocols for gear type
section and deployment including minnow traps will be
developed in the Fish Distribution and Abundance
Implementation Plan. As specified in Section 9.5.4, AEA will file
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 218 December 2012
Study of Fish Distribution and Abundance in the Upper Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
the study implementation plan with FERC by March 15, 2013.
FDAUP-28 ADNR -
ADF&G 11/14/2012 Minnow Traps (Page 7-14) “Winter deployment of minnow traps
should be considered.” –pdf page 25
Because of winter access issues and accompanying safety
concerns, no winter sampling is planned for the Upper River.
Details on the winter approach in the Middle and Lower River
including the use of minnow traps can be found in Section
9.6.4.5.
FDAUP-29 ADNR -
ADF&G 11/14/2012 Snorkeling (Page 7-14) “Will two or one biologist snorkel during each
snorkeling survey event?” –pdf page 25 AEA has added additional detail to Section 9.5.4.4.6 in
response to this comment. In stream channels with a width of
less than 4 meters (1.2 feet), the survey will be conducted by a
single snorkeler viewing and counting fish on both side of the
channel, alternating from left to right counts. In stream
channels with a width greater than 4 meters (1.2 feet), the
surveys will be conducted by two snorkelers.
FDAUP-30 ADNR -
ADF&G 11/14/2012 Snorkeling (Page 7-14) “What is the sampling schedule? When?
Seasons? Site selection criteria/rational needed.” –pdf page 25
AEA has added additional detail to Section 9.5.4.4.6 in
response to this comment. In the Upper River, sampling will
occur on a monthly basis from ice-out to freeze-up. Sampling
will be more frequent (biweekly) early in the season (May-June)
to encompass critical transitions from spawning to rearing
areas. The decisions about what methods to apply will be
made by field crews after initial site selection in coordination
with Fish Distribution and Abundance Study Lead and the Fish
Program Lead. Snorkeling will be the preferred method when
adult fish are present, and where water is not swift, deep or
turbid.
FDAUP-31 ADNR -
ADF&G 11/14/2012 Snorkeling (Page 7-14) “Will block nets be used?” –pdf page 25 Block nets will be used for estimates of relative abundance;
they will not be used for fish presence/absence surveys. See
Section 9.5.4.4.6.
FDAUP-32 ADNR -
ADF&G 11/14/2012 Fyke/Hoop Nets (Page 7-15) “What is the mesh size, hoop size,
number of hoops, length of nets, etc.?” –pdf page 25
AEA has included specifications for fyke nets and hoop traps
in Sections 9.5.4.4.7 and 9.5.4.4.8. Fyke nets and hoop traps
have 1/8-inch mesh size diameter, hoop size is 1 foot in
diameter, and up to 4 hoops. Length is anticipated to be up
to12 feet; net specifications will be described in further detail in
the Fish Distribution and Abundance Implementation Plan. As
specified in Section 9.5.4, AEA will file the study
implementation plan with FERC by March 15, 2013.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 219 December 2012
Study of Fish Distribution and Abundance in the Upper Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
Hoop traps of two lengths may be used, 3.05 and 3.66 m (10
and 12 ft). The small hoop trap has seven, 6.35-mm (0.25 in)
steel hoops with diameters tapered from 0.61 m (2 ft) at the
entrance to 0.46 m (1.5 ft) at the cod end. The large trap has
inside diameters tapering from 91 to 69 cm (36 to 27 in) with
throat diameters of 36 cm (14 in). Each trap has a double
throat that narrows to an opening 10 cm (4 in) in diameter. All
netting is knotted nylon woven into 25-mm (1-in) bar mesh.
FDAUP-33 ADNR -
ADF&G 11/14/2012 Fyke/Hoop Nets (Page 7-15) “Is this continued sampling or a single
event? What time of year? How many sampling events? List
protocols.” –pdf page 25
Fyke nets will be used to capture small fish in sloughs and side
channels with moderate velocity throughout the ice free
season. Fyke nets will be deployed for a maximum of 2 days.
Hoop traps will be deployed in main channel habitats of low to
moderate velocity late August through early October to catch
burbot for tagging studies. Hoop traps will be deployed
overnight, but less than 24 hours. See Section 9.5.4.4.7 and
9.5.4.4.8. Sampling methods will be described in further detail
in the Fish Distribution and Abundance Implementation Plan.
As specified in Section 9.5.4, AEA will file the study
implementation plan with FERC by March 15, 2013.
FDAUP-34 ADNR -
ADF&G 11/14/2012 Beach Seine (Page 7-15) “Identification of beach seines should not
limit the equipment choices as to length and depth. What is the mesh
size?” –pdf page 25
Agreed. Seines will be 15 and 25 feet wide by 5 feet depth with
¼ inch mesh. See Section 9.5.4.4.9.
FDAUP-35 ADNR -
ADF&G 11/14/2012 Beach Seine (Page 7-15) “Small water can be sampled using a
shorter and shallower beach seine. As long as the area sampled is
noted and the net is deep enough to fill the water column then
comparisons can be made.” –pdf page 25
Agreed. AEA has revised the RSP to reflect this comment.
See Section 9.5.4.4.9
FDAUP-36 ADNR -
ADF&G 11/14/2012 Beach Seine (Page 7-15) “Will different substrate types be sampled?
Identify geomorphic areas to be sampled.” –pdf page 25
Yes. Beach seines will be used in shallow water areas that are
free of debris and snags predominantly in side channels and
sloughs. See Section 9.5.4.4.9.
FDAUP-37 ADNR -
ADF&G 11/14/2012 Beach Seine (Page 7-15) “Will sampling include all time periods
including daylight, twilight and periods of darkness?” –pdf page 25
Yes. See Section 9.5.4.3.1.
FDAUP-38 ADNR -
ADF&G 11/14/2012 Beach Seine (Page 7-15) “Identify protocols.” –pdf page 25 AEA has revised Section 9.5.4.3.1 to add protocols; net sizes
and soak times will be standardized.
FDAUP-39 ADNR - 11/14/2012 Outmigrant Trap (Page 7-15) “Identify if traps will be manned during Traps will be checked twice daily while operational. See
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ADF&G deployment.” – pdf page 25 Section 9.5.4.4.10.
FDAUP-40 ADNR -
ADF&G 11/14/2012 DIDSON and Video Cameras (Page 7-15) “Recommend that these
cameras be used to identify burbot spawning in these areas.” –pdf
page 26
As described in AEA’s response to comment FDAUP-24, no
winter sampling is planned for the Upper River owing to safety
and access concerns. Burbot are winter spawners. Use of
under ice video to identify burbot spawning has been added to
Section 9.6.4.3.4 of the Fish Distribution and Abundance in the
Middle and Lower Susitna River.
FDAUP-41 ADNR -
ADF&G 11/14/2012 DIDSON and Video Cameras (Page 7-15) “Identify camera locations.”
–pdf page 26
DIDSON and video cameras will be deployed in selected
sloughs and side channels (Section 9.5.4.4.13.). A detailed
description of site selection and sampling methods will be in the
Fish Distribution and Abundance Implementation Plan. As
specified in Section 9.5.4, AEA will file the study
implementation plan with FERC by March 15, 2013.
FDAUP-42 ADNR -
ADF&G 11/14/2012 DIDSON and Video Cameras (Page 7-15) “Location of all video and
DIDSON surveys should be located by GPS and identified on aerial
photos and project maps.” –pdf page 26
Agreed. AEA has revised Section 9.5.4.4.13 to address this
comment.
FDAUP-43 ADNR -
ADF&G 11/14/2012 Fish Handling (Page 7-16) “See comments under section 7.5.4.2.
regarding use of PIT tags. Describe the method to implant PIT tags
and where on fish they are to be tagged. Describe anesthetic
procedures that will be used. Will FLOYTM tags be used for recapture
studies?” –pdf page 26
Sampling protocols for PIT-tagging will be described in further
detail in the Fish Distribution and Abundance Implementation
Plan. As specified in Section 9.5.4, AEA will file the study
implementation plan with FERC by March 15, 2013.
FDAUP-44 ADNR -
ADF&G 11/14/2012 Fish Handling (Page 7-16) “Goals for assessment of baseline metal
studies and mercury studies may be vastly different and require
different age classes.” –pdf page 26
As described in Section 5.5.1, the fish-specific objective of the
metals study is to: Measure baseline metals concentrations in
sediment and fish tissue for comparison to state criteria. As
described in Sections 5.7.1 the fish specific objectives of the
mercury study are to: (1) Characterize the baseline mercury
concentrations of the Susitna River and tributaries. This will
include collection and analyses of vegetation, soil, water,
sediment pore water, sediment, piscivorous birds and
mammals, and fish tissue samples for mercury. (2) Use
modeling to estimate methylmercury concentrations in fish.
Assess potential pathways for methylmercury to migrate to the
surrounding environment. There is a well-known positive
correlation between fish size (length and weight) and metal
concentrations in muscle tissue. Larger, older fish tend to have
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higher concentrations and will be the targeted for sampling (see
Sections 5.5.4.7 and 5.7.4.2.6).
FDAUP-45 ADNR -
ADF&G 11/14/2012 Fish Handling (Page 7-16) “Due to subsistence uses of whole fish,
whole fish samples should be processed.” –pdf page 26
Unlike some contaminants, methylmercury concentrates in the
muscle tissue of fish (RSP Section 5.5.4.7). Because of this
whole fish samples can underestimate the amount of
methylmercury present, and can be less protective to human
health ( Section 5.7.2). For this reason AEA proposes to collect
and analyze samples of muscle tissue for most fish, and
muscle and liver tissue for burbots. This is consistent with
ADEC methylmercury sampling program (ADEC 2012), as well
as USGS and EPA protocols (Frenzel; 2000; USEPA 2000;
USEPA 1997a), and should be protective of all consumers.
FDAUP-46 ADNR -
ADF&G 11/14/2012 Fish Handling (Page 7-16) “Sampling should focus on older fish
initially to identify if bioaccumulation is occurring. Younger fish have
lower levels of bioaccumulated metals or pollutants which may cause
results to indicate lower concentrations than targeted, older harvested
fish. If results are positive, additional sampling will be needed.” –pdf
page 26
Agreed. Tissue or whole adult fish samples will also be
collected in the mainstem Susitna River for assessment of
metals (see Section 5.5.4.7, Baseline Metal Levels in Fish
Tissue) and mercury (see Section 5.7.4.2.6, Mercury
Assessment and Potential for Bioaccumulation Study)
concentrations. Target adult fish species for baseline metals
testing include: Dolly Varden, Arctic grayling, whitefish species,
long nose sucker, lake trout, burbot, and resident rainbow trout.
Target adult fish species for mercury sampling include: Dolly
Varden, arctic grayling, stickleback, long nose sucker, whitefish
species, lake trout, burbot, and resident rainbow trout.
FDAUP-47 ADNR -
ADF&G 11/14/2012 7.5.4.2. Remote Fish Telemetry (Pages 7-16 to 7-18) “Further
discussion regarding use of PIT tags has raised concern on the ability
of this technology to be utilized effectively in the project area. The
primary concern is that, as noted in this section, PIT tagged fish must
pass in close proximity of an antenna array thereby limiting its use to
sufficiently small water bodies. It is unknown how many water bodies
fit this criteria and where they are located to provide a complete
assessment. Further discussion is needed.” –pdf page 26
Agreed. The use of PIT tag arrays is limited to smaller
waterbodies and habitat features. Arrays in the Upper River will
be primarily focused on areas identified as important juvenile
Chinook salmon habitats. See Section 9.5.4.4.12. Limitations
of various sampling techniques is the rationale behind the suite
of techniques that are proposed to understand fish distribution
and abundance (9.5.4.4). Sampling protocols for PIT-tagging
and other remote telemetry methods will be described in further
detail in the Fish Distribution and Abundance Implementation
Plan. As specified in Section 9.5.4, AEA will file the study
implementation plan with FERC by March 15, 2013.
FDAUP-48 ADNR - 11/14/2012 7.5.4.2. Remote Fish Telemetry (Pages 7-16 to 7-18) “The likelihood Agreed. The likelihood of intentional human consumption will
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ADF&G of unintentional human consumption of PIT tags needs to be
addressed.” –pdf page 26
be described in further detail in the Fish Distribution and
Abundance Implementation Plan. As specified in Section 9.5.4,
AEA will file the study implementation plan with FERC by
March 15, 2013.
FDAUP-49 USFWS 11/14/2012 “Studies should determine if the remaining stream reaches will
continue to support resident fish populations.” –pdf page 76
There is no nexus with Project affects and stream reaches
above the reservoir inundation zone. There will be no Project-
induced changes to the habitat, flow regime, or water quality
upstream of the reservoir inundation zone that would impact
the ability of these streams reaches to support resident fish
communities. Existing information and data collected in 2012
indicate that all fish species within the reservoir zone are
native.
Anticipated Project impacts upstream of the dam site are
limited to the inundation zone where AEA is collecting baseline
data and addressing the potential for changes related to fish
and aquatic habitats (Section 9.9.2), fish distribution and
abundance (Section 9.5.1), adult salmon use (Sections 9.7.4.2
and 9.7.4.3), fish community (Section 9.10.1.1), reservoir water
quality (Section 5.6.4.8), and fish barriers (Section 9.12.1).
FDAUP-50 USFWS 11/14/2012 “Specific information needs include:
• Proportion of juvenile and adult salmon populations produced
upstream of the proposed dam site;
• Timing of juvenile salmon and resident fish migration from Upper
River tributaries and main channel habitats to downstream of the
proposed dam site;
• Proportion of fish populations (e.g., Dolly Varden and Arctic
grayling) in the Upper reach contributing to populations in
downstream reaches;
• Location, life cycle, and species of resident fish and non-
anadromous salmon within the Upper reach;
• Distribution and availability (quantity and quality) of habitats for
juvenile and adult resident and non-salmon anadromous fish
upstream and within the proposed reservoir.” –pdf page 76
The proportion of adult Chinook salmon spawning above the
proposed dam site falls under the Salmon Escapement Study
(Section 9.7). Juvenile salmon in the Upper River will be
surveyed in this study (Sections 9.5.4.3.1, 9.5.4.3.2, and
9.5.4.3.3).
The timing of juvenile salmon and resident fish migration is
addressed in Section 9.5.4.3.2. There is an objective that
specifically addresses the timing of migration.
Fish distribution and relative abundance information will be
collected for Dolly Varden and Arctic grayling over all three
segments of the river (Section 9.5.4.3.1). Data collection will
allow for comparison over river segments, geomorphic reaches,
and habitat types.
Location, life cycle, and species information will be collected
(See objective 1; Sections 9.5.1 and 9.5.4.3.1).
Information on the distribution and availability of habitats will be
collected under the Characterization and Mapping of Aquatic
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Habitats (see Sections 9.9.5.3, 9.9.5.4.1, and 9.9.5.5).
FDAUP-51 USFWS 11/14/2012 “The study plan does not identify which species will be targeted for
sampling. Resident species within the Upper River include Dolly
Varden, rainbow trout, Arctic grayling, Chinook salmon, humpback
whitefish, burbot, longnose sucker, and lake trout. Except for lake
trout, most of these species are thought to use the mainstem Susitna
and lower tributary reaches within the inundation zone for some
portion of their life cycle and could be affected by Project construction
and operation. Life histories and habitat requirements vary among
these species. Species specific sampling methods will need to be
developed. Fish collection methods vary for each species and life
stage, and appropriate sampling is needed to provide useful
information.” –pdf page 77
The RSP contains a list of species to be sampled. See Section
9.5.1 and Table 9.5-1.
Agreed. Sampling methods will be species specific and site
specific (see Sections 9.5.4.3 and 9.5.4.4). Sampling
methodology and site selection will be described in further
detail in the Fish Distribution and Abundance Implementation
Plan. As specified in Section 9.5.4, AEA will file the study
implementation plan with FERC by March 15, 2013.
FDAUP-52 USFWS 11/14/2012 “The PSP describes a plan for eight tributary streams to be sampled
during 2013 and 2014. These will be chosen with a focus on Chinook
salmon distribution, selecting all tributaries in which Chinook salmon
juveniles or adults were observed previous. Studies found Chinook
salmon in four tributaries: Fog Creek (RM 173.9), Kosina Creek (RM
202.4), Tsusena Creek (RM 178.9), and the Oshetna River (RM
226.9) (Buckwalter 2011). The remaining four tributaries for the
current study are to be selected, as described in the PSP, at random.
Within each selected tributary, up to three meso-habitat types (pool,
riffle, backwater) will be selected at random for sampling, and
physical habitat measurements of length, width, and habitat type will
be collected.” –pdf page 77
Section 9.5.4.1 describes the sampling strata. Because of the
general inaccessibility, very rugged terrain, and mostly non-
wadeable stream channels, near census mapping (100 percent
coverage) is challenging and in some cases unsafe or
impossible. For these reasons, only tributaries mapped by the
Characterization and Mapping of Aquatic Habitats (See Section
9.9; Table 9.9-2) will be selected for fish distribution and
abundance sampling. Up to 18 tributary streams will be
targeted for sampling during 2013 and 2014. Of the 18
tributaries selected for sampling, all tributaries in which Chinook
salmon juveniles or adults were documented within or at the
mouth of a tributary during previous surveys will be sampled.
Per ADF&G request, of the remaining tributaries that are
suitable for sampling, tributaries where no data exists in the
AWC catalog will be prioritized. See Section 9.5.4.1.
FDAUP-53 USFWS 11/14/2012 “Sample timing and frequency should be developed to support the
Upper River study objective. In 1981 and 1982, peak juvenile Chinook
salmon abundance in Middle River tributaries was from June through
August. For example, in Portage Creek few juvenile fish were
captured in June, with peak Chinook salmon catches occurring in
August (ADF&G 1981). Tributary catches decreased in August and
September and mainstem juvenile Chinook salmon abundance
Sampling will occur on a monthly basis for each site except
during critical periods (i.e., migration from natal to rearing
habitats) where it will occur biweekly. See Section 9.5.4.2. This
sampling frequency in conjunction with continuous PIT tag
monitoring (9.5.4.4.12) and out-migrant trap (9.5.4.4.10)
sampling at more frequent intervals will capture juvenile salmon
movements. Sampling frequency will be described in further
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increased. Therefore, Middle River juvenile Chinook salmon likely
overwinter in the mainstem and thus sample timing and frequency
should be developed to determine if this same movement pattern is
observed in the Upper River.” –pdf pages 77-78
detail in the Fish Distribution and Abundance Implementation
Plan. As specified in Section 9.5.4, AEA will file the study
implementation plan with FERC by March 15, 2013.
FDAUP-54 USFWS 11/14/2012 “Sampling locations should be selected to address specific questions
for fish species and life stages and to evaluate potential Project
effects. For example, sample site selection to document the
distribution of burbot will likely be different than site selection to
document the distribution of Dolly Varden. Additionally, by choosing
sites based on suitability for Chinook salmon, the plan may bias the
capture of different species, relative to the degree of sympatry among
species. The PSP does not appear to be designed to document the
distribution or abundance of the resident fish species. Lake trout, for
example, will probably not be found near the mouths of these
tributaries, but they have been found in Sally Lake and Deadman
Lake (ADF&G 1981a). If sites similar to these lakes are not sampled,
this study could miss a species that potentially could move or be
transported into a reservoir (functionally a large lake) and could have
a large effect on the potential reservoir fish community.” –pdf page 78
Sampling methods will be species specific and site specific and
will depend on site conditions encountered in the field.
Additional detail will be provided in the Fish Distribution and
Abundance Implementation Plan. See Sections 9.5.4.3 and
9.5.4.4.
The study is directed at documenting baseline conditions of fish
distribution and relative abundance within the reservoir
inundation zone. There is no nexus with Project affects and
stream reaches or lakes above the reservoir inundation zone.
There will be no Project induced changes to the habitat, flow
regime, or water quality upstream of the reservoir inundation
zone that would impact the ability of these streams reaches or
lakes to support resident fish communities. Existing information
and data collected in 2012 indicate that all fish species within
the reservoir zone are native.
Anticipated Project impacts upstream of the dam site are
limited to the inundation zone where AEA is collecting baseline
data and addressing the potential for changes related to fish
and aquatic habitats (Section 9.9.2), fish distribution and
abundance (Section 9.5.1), adult salmon use (Sections 9.7.4.2
and 9.7.4.3), fish community (Section 9.10.1.1), reservoir water
quality (Section 5.6.4.8), and fish barriers (Section 9.12.1).
FDAUP-55 USFWS 11/14/2012 “The PSP for the Lower and Middle river (Section 7.6) describes
sampling efforts in the mainstem, tributary mouths, side sloughs,
upland sloughs, and side channels. Sloughs and side channels may
not be as common in the Upper River as they are in the Middle River.
Offchannel habitat, which provides rearing habitat in the Upper River,
should be sampled to evaluate the relative importance of these
locations to Upper River fish communities. Additionally, because
tributaries in the impoundment zone have the potential to be affected
miles upstream of their current mouths, we recommend including
tributary-sampling efforts up to and above the predicted elevations of
Sample strata have been revised. Off-channel habitats will be
sampled. See Section 9.5.4.1.
All known Chinook salmon-bearing tributaries will be sampled
up to the 3,000-foot elevation, which is based on the known
extent of Chinook salmon distribution. Other tributaries will be
sampled up to the 2,200-foot contour which defines the zone of
hydrologic influence. See Section 9.5.4.1.
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inundation to determine the availability, quality, and type of habitats
that would be altered, and those habitats that will be unaltered, by
permanent reservoir-filling.” –pdf page 78
FDAUP-56 USFWS 11/14/2012 “The PSP states that sampling will be based on Chinook salmon
distribution, with surveys above the 2,200-foot elevation focusing on
locating Chinook salmon, and studies above the 3,000-foot elevation
only conducted at sites where Chinook salmon were found. It is
unclear if there will be any habitat measures associated with sampling
the streams to be inundated. This is necessary in order to measure
fish habitat lost to reservoir-creation and to measure habitat
alternatives. Schmidt and Stratton ADF&G (1984) found that
inundation would remove some passage barriers, such as Deadman
Creek falls. Additionally, fish and habitat sampling efforts should be
conducted in the many small lakes and ponds in the Upper River
drainage to look for anadromous salmon and resident fish
overwintering habitat.” –pdf page 78
Habitats will be characterized and measured under the
Characterization and Mapping of Aquatic Habitats study
(Section 9.9).
Fish passage barriers will be surveyed and measured under
the Study of Fish Passage Barriers in the Middle and Upper
Susitna River and Susitna Tributaries (Section 9.12).
FDAUP-57 USFWS 11/14/2012 “Proposed fish collection methods are similar to the Middle and Lower
river resident fish study (Section 7.6), with monthly sampling from
May to September (and two events in August), no sampling October-
November, and two sampling events between December and April.
As with Section 7.6, methods will involve active and passive capture
methods and biotelemetry, to identify seasonal timing, distribution,
and abundance of fish. This section will also determine the effect of
fluctuating reservoir levels on fish movement into and out of
tributaries.” –pdf page 78
Sampling frequency and timing has been revised. Sampling
will occur on a monthly basis for each site except during critical
periods (i.e., migration from natal to rearing habitats) where it
will occur biweekly. See Section 9.5.4.2. The schedule for
fixed radio telemetry receivers has been revised to begin
shortly after ice out on June 1. Monthly aerial surveys will
occur throughout the year with biweekly surveys occurring from
July through September. See Section 9.5.4.4.12.
FDAUP-58 USFWS 11/14/2012 “This study plan also does not describe how it intends to determine
effects of fluctuating reservoir levels on fish passage between
tributaries and the mainstem Susitna River. It is unclear if this will be
based on data collected during this study, or as part of another study,
such as the Study of Fish Passage Barriers (Section 7.12). As there
are no methods described as to how this objective will be
accomplished, we are assuming that it will be part of Study Section
7.12. We recommend the Upper River resident fish study coordinate
with the fish passage barriers study to determine which species will
likely be affected by passage barriers, and what the physical limits
Agreed. The evaluation of fish passage barriers falls under the
Study of Fish Passage Barriers in the Middle and Upper
Susitna River and Susitna Tributaries (Section 9.12). Fish
Distribution and Abundance studies will coordinate closely with
Study of Fish Passage Barriers in the Middle and Upper
Susitna River and Susitna Tributaries (see Section and 9.5.7
and Figure 9.5-4).
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are to passage for each migrating life stage and species.” –pdf page
79
FDAUP-59 USFWS 11/14/2012 “Sampling methods, site selection, and sampling timing and
frequency should be developed based on the life history of fish
species and potential Project effects. The PSP provides little
information on the methods that will be used to determine winter
habitat selection by resident and anadromous fish in the Upper River.
The primary Project effect will be the inundation of the mainstem and
lower reaches of tributary streams. Project effects are likely to be
greatest to those fish that spawn or overwinter within these reaches.
Tributaries at this elevation may freeze to the stream bed requiring
fish migration to overwintering locations. Many resident fish present in
the Upper River (e.g., Dolly Varden, Arctic grayling, whitefish),
migrate to the mainstem of larger rivers to overwinter. Therefore,
methods should be developed to determine if resident and
anadromous fish migrate to the mainstem in late fall and the
overwintering habitat provided in tributary streams. The only winter
sampling methods proposed in the Upper River are the use of
DIDSON and video cameras. Surveys will be conducted in 10
“selected” sloughs and side channels. These proposed sampling
methods and proposed locations are not likely to provide the
necessary information to document overwintering habitats or potential
Project effects to overwintering fish.” –pdf page 79
Selected sampling methods will be species-specific and site-
specific. See Sections 9.5.4.3 and 9.5.4.4. Because of safety
and access concerns, no winter sampling is proposed for the
Upper River; however remote fish telemetry techniques are
proposed to document the seasonal movements of resident
fishes (Table 9.5-2). For radio telemetry, the Salmon
Escapement Study (9.7) will provide approximately weekly
aerial survey coverage of the study area (approximately July
through October). At other times of the year, the frequency of
aerial surveys may be monthly and during critical species-
specific time periods (e.g., burbot spawning), may be biweekly.
More detail on sampling frequency will be provided in the Fish
Distribution and Abundance Implementation Plan. As specified
in Section 9.5.4, AEA will file the study implementation plan
with FERC by March 15, 2013.
FDAUP-60 USFWS 11/14/2012 “The methods do not describe which marine derived elements will be
tested for, or methodology for sample collection and analyses. It is
our understanding that this a stable isotope study, but this needs to
be clarified and more detail provided. Analyses of stable isotopes in
tissue samples and otoliths are known to be effective methods for
determining anadromy in salmonids and other fishes (Kline et al.
1998; Limburg 1998; Doucett et al 1999; Zimmerman 2005). The
methods do not describe which marine derived elements will be
tested for, or methodology for sample collection and analyses. It is
our understanding that this a stable isotope study, but this needs to
be clarified and more detail provided. Analyses of stable isotopes in
tissue samples and otoliths are known to be effective methods for
determining anadromy in salmonids and other fishes (Kline et al.
Marine-derived nutrient analyses falls under the purview of the
River Productivity Study (Section 9.8). One objective of that
study is to “Conduct a trophic analysis, using trophic modeling
and stable isotope analysis, to describe the food web
relationships in the current riverine community within the Middle
and Upper Susitna River” (see Section 9.8.4.5.2). Typically,
Carbon (δ13C) and nitrogen (δ15N) isotope ratios are used for
these analyses. More detail will on stable isotope analysis will
be included in the River Productivity Implementation Plan. As
specified in Section 9.8.4, AEA will file the study
implementation plan with FERC by March 15, 2013.
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1998; Limburg 1998; Doucett et al 1999; Zimmerman 2005).” –pdf
page 79-80
FDAUP-61 USFWS 11/14/2012 “In contrast to testing otoliths for marine derived elements, samples
could also collect non-lethal tissue samples or fin clip effects. Kline et
al. (1998) and Doucett et al. (1999) looked at stable carbon isotopes
in tissue samples and compared them to samples collected from
other fish known to be resident in fresh water or resident in the
marine environment. Fish known to be resident and marine should be
sampled to provide values for comparison. By using a non-lethal
sampling approach, more samples could be collected, which would
provide a more thorough test for anadromy in fish populations in the
Upper River. Tissues are analyzed for carbon isotope ratios (Kline et
al. 1998; Doucett et al. 1999). Non-lethal sampling methods should
be considered, if they can provide valuable data for assessing
anadromy in these populations. If redd sites are located for Dolly
Varden and humpback whitefish, newly-emergment fry can also be
tested for marine-derived elements. The tissue of juveniles will be
composed mainly of elements in their yolk sac (Doucett et al. 1999).
This method requires sampling before fresh water feeding dilutes the
marine-derived elements.” –pdf page 80
Marine-derived nutrient analyses falls under the purview of the
River Productivity Study. One objective of that study is to
“Conduct a trophic analysis, using trophic modeling and stable
isotope analysis, to describe the food web relationships in the
current riverine community within the Middle and Upper Susitna
River” (See Section 9.8.4.5.2). The non-lethal collection of fish
tissue samples are proposed to accomplish this objective
(9.8.4.5.2). More detail will on stable isotope analysis will be
included in the River Productivity Implementation Plan. As
specified in Section 9.8.4, AEA will file the study
implementation plan with FERC by March 15, 2013.
As per objective 4, otoliths will be collected from Dolly Varden
and humpback whitefish in the Upper River to determine
whether these fish are anadromous. Otoliths are also
necessary to support an on-going study being conducted by the
USFWS.
FDAUP-62 USFWS 11/14/2012 “Understanding resident fish use of the impoundment zone, and
affected tributaries for critical life stages including spawning and
overwintering is an essential information need. The distribution of
these habitats, relative to permanent and seasonal inundation zones,
is necessary to evaluate effects to the Upper River fish community.” –
pdf page 81
Agreed. Data on fish distribution, relative abundance, and
habitat associations will be collected under objective 1. See
Sections 9.5.1 and 9.5.4.3.1.
Because of safety and access considerations, no winter
sampling is planned for the Upper River; however remote fish
telemetry techniques are proposed to document the seasonal
movements of resident fishes (Table 9.5-2). For radio
telemetry, the Salmon Escapement Study (Section 9.7) will
provide approximately weekly aerial survey coverage of the
study area (approximately July through October). At other
times of the year, the frequency of aerial surveys may be
monthly and during critical species-specific time periods (e.g.,
burbot spawning), may be biweekly. More detail will on
sampling frequency will be provided in the Fish Distribution and
Abundance Implementation Plan. As specified in Section 9.5.4,
Revised Study Plan
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
AEA will file the study implementation plan with FERC by
March 15, 2013.
FDAUP-63 USFWS 11/14/2012 “The Upper River study proposes to radio tag up to 30 individuals of
each species, whereas the Middle and Lower river study (Section 7.6)
proposes to tag up to 10 of each species. It is unclear what species
will be tagged, what age class, where or when fish will be captured for
tagging and how selection of age class, tagging location, and timing
of tagging would be selected to identify movement or migration
patterns. The PSP does not identify why more fish will be tagged in
the Upper, compared to the Middle and Lower River sites.” –pdf page
81
AEA has added additional information to the RSP on target fish
species, sample, size, location, and fish size. See Section
9.5.4.4.12.
FDAUP-64 USFWS 11/14/2012 “With a sampling schedule based on the timing of anadromous
salmon spawning, July through October; the study likely will miss
movements of resident fish species. Spring migration from
overwintering locations or to spawning sites have been predicted or
observed for many of the Susitna River resident species, including
rainbow trout, Arctic grayling, round whitefish, and longnose suckers
(ADF&G 1981b, 1983). If receivers are not operational until July,
resident spring migrations will be missed in the first study year.
Monthly measures may not be frequent enough to document
seasonal migration patterns and will not assess movements during
winter months. Tracking fall movement is necessary to identify Dolly
Varden spawning locations, and winter movement is to identify burbot
spawning locations, or early spring migrations that often occur under
the ice.” –pdf page 81
The schedule for fixed radio telemetry receivers has been
revised to begin shortly after ice out on June 1. Monthly aerial
surveys will occur throughout the year with biweekly surveys
occurring from July through September. See Section
9.5.4.4.12.
FDAUP-65 USFWS 11/14/2012 “This objective addresses the migration of fish past the dam site, but
limits quantification of downstream movement to one method. This is
a modification of the Service requested objective that stated,
“Document the timing of downstream movement and catch for all
juvenile fish species, and outmigration timing for anadromous
species”. The PSP does not provide a purpose or information need
for this objective. Methods are limited to one trap and one trap type
which may or may not be sufficient, depending upon the purpose of
the study. The PSP contains no description of the effectiveness of the
methods at capturing fish that may be migrating downstream at this
AEA has modified the Study Plan to include a multitude of
techniques. In addition to sampling efforts in the Middle and
Lower River (Section 9.6), up to six PIT tag arrays (Section
9.5.4.4.12) and two out-migrant traps (Section 9.5.4.4.10.) will
be deployed in the Upper River to gather data on downstream
movement timing. Other methods (i.e., seining, electrofishing,
minnow trapping) will be conducted on a monthly basis can be
used to infer migratory movements and timing (monthly). See
Section 9.5.4.4.
Revised Study Plan
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Study of Fish Distribution and Abundance in the Upper Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
location. There is no description of data analyses or a discussion of
how the results will be applied to Project operation.” –pdf page 81
Catch-Per-Unit-Effort will be provided along with the time,
location, species, and size of fish observed. See Section
9.5.4.4.
FDAUP-66 USFWS 11/14/2012 “The construction and operation of the proposed Project would
potentially create a migration barrier, modify downstream migration
rates, or result in increased fish mortality. Determining species
outmigration and timing is an important Upper River objective.
Sample methods, location, timing and frequency of sampling for
upstream and downstream movements may be different for each fish
species under investigation. We recommend the use of mark-
recapture methods to determine the total number of migrating fish or
determine the accuracy of “catch” at estimating total migrating
population by species. The study plan should clearly identify how the
data will be analyzed and used. Migrant traps can miss some species
depending on when they are deployed, their location relative to
spawning sites, and proximity to the shore (Thedinga et al. 1994).
Therefore, the absence of fish cannot be used to indicate that a given
fish species or life stage is not migrating unless a study is designed to
determine the probability of fish capture by life stage.” –pdf page 81-
82
In addition to sampling efforts in the Middle and Lower River
(Section 9.6), up to six PIT tag arrays (Section 9.5.4.4.12) and
two out-migrant traps (Section 9.5.4.4.10.) will be deployed in
the Upper River to gather data on downstream movement
timing. Other methods (i.e., seining, electrofishing, minnow
trapping) will be conducted on a monthly basis can be used to
infer migratory movements and timing (monthly). See Section
9.5.4.4.
All juvenile salmon captured will be PIT-tagged in an effort to
document downstream migration and movement patterns.
Migration patterns of adult fish in the Upper River will be
monitored with remote telemetry techniques. However,
because of the size of the river and the potentially large
number of fish, determining the total number of migrating fish is
not a study objective. It would be challenging, if not impossible,
to produce reliable estimates of the total number of fish
migrating past the proposed dam site.
AEA agrees that the absence of fish cannot be used to indicate
that a given fish species or life stage is not migrating.
FDAUP-67 USFWS 11/14/2012 AEA Study Objective 7. Document the presence/absence of northern
pike in all samples: “This objective is unclear, and the reason for its
inclusion is not identified. The PSP already states that all captured
fish will be identified to species, measured, and weighed. Therefore,
the inclusion of this study objective implies that independent methods
will be developed to determine the presence or absence of northern
pike within the Upper River.” –pdf page 82
Northern pike is an invasive non-native species present in the
Susitna basin; its presence and distribution is a management
concern to ADF&G. AEA included this objective in the study
based upon a specific request by ADF&G. While angling will
be the primary method of targeting northern pike, the presence
of pike will be documented in all surveys. See Section
9.5.4.3.6.
FDAUP-68 USFWS 11/14/2012 “To our knowledge, intensive sampling for northern pike within this
segment of the Susitna River has not been conducted. We
recommend working with the Alaska Department of Fish and Game
(ADF&G) to develop a sampling plan that identifies Upper River
See AEA’s response to comment FDAUP-67.
Revised Study Plan
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Study of Fish Distribution and Abundance in the Upper Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
sampling locations, sample timing and frequency, and collection
methods to determine if northern pike are present. Analytical methods
should calculate the probability of pike presence even if not captured
given the level of sampling effort.” –pdf page 82
FDAUP-69 NMFS 11/14/2012 “Studies should be developed to determine how the inundation will
affect the suitability of these locations for spawning and rearing.
Studies should determine if the remaining stream reaches will
continue to support resident fish populations and rearing juvenile
Chinook salmon. We request that the upper river study objectives be
refined to reflect specific information needs for evaluating potential
project-effects to the fish community.” –pdf page 90
See AEA’s response to comment FDAUP-49.
FDAUP-70 NMFS 11/14/2012 “The AEA PSP provides only a brief review of previous studies
conducted on fish species likely to be observed within this river
segment and its tributaries. Study methods (including sample
collection, sampling locations, sample timing and frequency) do not
support the stated objective. The PSP does not identify collection
methods for specific fish species or life stages. Data analytical
methods and the statistical design are not provided. It is unclear how
the results of these studies will be used to evaluate or mitigate
potential impacts to the upper river fish community. This information
would be useful to NMFS as it pertains to potential losses of fish
production from the dam, which could in turn affect overall
productivity and result in increases in the number or range of
predatory species that could prey upon vulnerable spawning,
incubating or rearing salmon in the reservoir zone or downstream of
the project.” –pdf page 91
AEA has added additional detail to Section 9.5.4 describing the
sample site selection, sampling frequency and methods. As
described in Section 9.4.5.3.1, Objective 1 will characterize the
baseline condition of fish distribution and relative abundance.
The proposed sampling approach is a stratified random design
(Section 9.5.4.1) that proposes collecting data monthly during
the open water period at 45 sites using a variety of methods
(Section 9.5.4.4) to facilitate capture of all species and life
stages present.] Given that this task is descriptive in nature it
does not require statistical tests or analysis. The data are
being collected in a fashion that standardizes them across
place and time, for example the derivation of density and CPUE
(Section 9.5.4.3.1). These data will allow for comparative
analysis and application of statistical tests that would be
developed, as necessary, during final analysis in support of the
License Application.
FDAUP-71 NMFS 11/14/2012 “The study plan does not identify which species will be targeted for
sampling. Resident and anadromous species within the upper river
include: Dolly Varden, rainbow trout, Arctic grayling, Chinook salmon,
humpback whitefish, burbot, longnose sucker, an~ lake trout. Most of
these species are believed to use the mainstem Susitna and lower
tributary reaches within the inundation zone for some portion of their
life cycle and could be affected by project construction and operation.
Life histories and habitat requirements vary among these species.
See AEA’s response to comment FDAUP-51
Revised Study Plan
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Study of Fish Distribution and Abundance in the Upper Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
Species specific sampling methods will need to be developed. Fish
collection methods vary for each species and life stage, and
haphazard sampling is unlikely to provide useful information.” –pdf
page 91
FDAUP-72 NMFS 11/14/2012 “The PSP describes a plan for eight tributary streams to be sampled
during 2013 and 2014. These will be chosen with a focus on Chinook
salmon distribution, selecting all tributaries in which Chinook salmon
juveniles or adults were observed previously. Studies found Chinook
salmon in four tributaries: Fog Creek (RM 173.9), Kosina Creek (RM
202.4), Tsusena Creek (RM 178.9), and the Oshetna River (RM
226.9) (Buckwalter 2011). The remaining four tributaries for the
current study are to be selected, as described in the PSP, at random.
Within each selected tributary, up to three meso-habitat types (pool,
riffle, backwater) will be selected at random for sampling, and
physical habitat measurements of length, width, and habitat type will
be collected.” –pdf page 91
See AEA’s response to comment FDAUP-52.
FDAUP-73 NMFS 11/14/2012 “Sample timing and frequency should be developed to support the
project objective. Peak juvenile Chinook abundance in middle river
tributaries has been observed to be from June through August (1981
and 1982). For example, in Portage Creek few fish were captured in
June, with peak Chinook catches in August (ADF&G 1981). Tributary
catches decreased in August and September and mainstem Chinook
salmon abundance increased. Therefore, middle river juvenile
Chinook salmon likely overwinter in the mainstem and sample timing
and frequency should be developed to determine if this same
migration pattern is observed in the upper river.” –pdf page 91
See AEA’s response to comment FDAUP-53.
FDAUP-74 NMFS 11/14/2012 “Sampling locations should be selected to address specific questions
for fish species and life stages and to evaluate potential project
effects. For example, sample site selection to document the
distribution of bur bot likely will be different than site selection to
document the distribution of Dolly Varden. Additionally, by choosing
sites based on past presence of, and presumably then, suitability for
Chinook salmon, the plan may bias captures for or against different
species, relative to the degree of sympatry among species. The PSP
does not appear to be designed to document the distribution or
See AEA’s response to comment FDAUP-52.
Revised Study Plan
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FERC Project No. 14241 Page 232 December 2012
Study of Fish Distribution and Abundance in the Upper Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
abundance of resident fish species. Lake trout, for example, will
probably not be found near the mouths of these tributaries, but they
have been found in Sally Lake and Deadman Lake (ADF&G 1981a).·
If sites similar to these lakes are not sampled, this study could miss a
species that would likely move into a reservoir (functionally a large
lake) and could have a large effect on the potential reservoir fish
community including substantial predatory effects on any juvenile
salmon that would migrate from tributary stream habitat to either
downstream rearing habitat or the ocean.” –pdf page 92
FDAUP-75 NMFS 11/14/2012 “The AEA PSP for the lower and middle river (Section 7.6) describes
sampling efforts in the mainstem, tributary mouths, side sloughs,
upland sloughs, and side channels. Sloughs and side channels may
not be as common in the upper river as they are in the middle river;
however, offchannel habitat provide rearing habitat fish sampling
should be conducted to evaluate the relative importance of these
locations to upper river fish communities. Additionally, as tributaries in
the impoundment zone have the potential to be affected miles
upstream of their current mouths, tributary sampling efforts need to
be conducted up to and above the predicted elevations of inundation
to determine what kind of habitat would be altered, and what kind of
habitats will be unaltered by reservoir-filling.” –pdf page 92
See AEA’s response to comment FDAUP-55.
FDAUP-76 NMFS 11/14/2012 “The PSP states that sampling will be based on Chinook salmon
distribution, with surveys above 2,200 ft focusing OIi locating Chinook
salmon, and studies above 3,000 ft only conducted at sites where
Chinook salmon were found. It is unclear if there will be any habitat
measures associated with sampling the streams to be inundated. This
is necessary in order to measure fish habitat loss from reservoir-
creation and to measure habitat alternatives. Schmidt and Stratton
ADF&G (1984) found that inundation would remove some passage
barriers, such as Deadman Creek falls. Additionally, fish and habitat
sampling efforts should be conducted in the many small lakes and
ponds in the upper river to look for anadromous salmon and resident
fish overwintering habitat.” –pdf page 92
See AEA’s response to comment FDAUP-56.
FDAUP-77 NMFS 11/14/2012 “Proposed fish collection methods are similar to the middle and lower
river resident fish study (Section 7.6), with monthly sampling from
See AEA’s response to comment FDAUP-57.
Revised Study Plan
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
May to September (with two events in August), no sampling October-
November, and two sampling events between December and April.
As with Section 7.6, methods will involve active and passive capture
methods and biotelemetry, to identify seasonal timing, distribution,
and abundance of fish. This study also proposes to determine the
effect of fluctuating reservoir levels on fish movement into and out of
tributaries.” –pdf page 92
FDAUP-78 NMFS 11/14/2012 Sampling methods do not identify measures of habitat variables to
determine fish distribution among sites and among sampling events.
–pdf page 67-68
See AEA’s response to comments FDAUP 53-57.
FDAUP-79 NMFS 11/14/2012 “This study plan also does not describe how it intends to determine
effects of fluctuating reservoir levels on fish passage between
tributaries and the mainstem Susitna River. It is unclear if this will be
based on data collected during this study, or as part of another study,
such as the Study of Fish Passage Barriers (Section 7.12). As there
are no methods described for how this objective will be accomplished,
we are assuming that it will be part of Study Section 7.12. However,
the upper river resident fish crew will need to coordinate with the fish
passage barriers crew to determine which species will likely be
affected by passage barriers, and what are the physical limits to
passage for each migrating life stage and species.” –pdf page 93
See AEA’s response to comment FDAUP-58.
FDAUP-80 NMFS 11/14/2012 “Sampling methods, site selection, and sampling timing and
frequency should be developed based on the life history of fish
species and potential project effects. The PSP provides little
information on the methods that will be used to determine winter
habitat selection by resident and anadromous fish in the upper river.
The primary project effect will be the inundation of the mainstem and
lower reaches of tributary streams. Project effects are likely to be
greatest to those fish that spawn or overwinter within these reaches.
Tributaries at this elevation may freeze to the stream bed requiring
fish migration to overwintering locations. Many resident fish present in
the upper river (i.e. Dolly Varden, grayling, whitefish), migrate to the
mainstem of larger rivers to overwinter. Therefore, methods should be
developed to determine if resident and anadromous fish migrate to
the mainstem in late fall and the overwintering habitat provided in
See AEA’s response to comment FDAUP-59.
Revised Study Plan
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FERC Project No. 14241 Page 234 December 2012
Study of Fish Distribution and Abundance in the Upper Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
tributary streams. The only winter sampling methods proposed in the
upper river are the use of DID SON and video cameras. Surveys will
be conducted in 10 "selected" sloughs and side channels. These
proposed sampling methods and site selection are not likely to
provide the information necessary to document overwintering habitats
or potential project effects to overwintering fish, as these methods do
not identify the portion of the total population overwintering and will
not sample all available habitats.” –pdf page 93
FDAUP-81 NMFS 11/14/2012 “The methods do not describe which marine derived elements will be
tested for, or methodology for sample collection and analyses. The
brief description of methods likely refers to a stable isotope study, but
this needs to be clarified. Analyses of stable isotopes in tissue
samples and otoliths have proven to be effective methods for
determining anadromy in salmonids and other fishes (Kline et al.
1998; Limburg 1998; Doucett et al 1999; Zimmerman 2005).” –pdf
page 93-94
See AEA’s response to comment FDAUP-60.
FDAUP-82 NMFS 11/14/2012 “Zimmerman (2005) found that strontium (Sr) or strontium-to-calcium
(Sr:Ca) ratios in otoliths are linearly correlated to salinity and
environmental Sr concentrations. This method is sensitive enough to
discriminate between fresh water, brackish water, and seawater life
stages, but Sr uptake is species-specific and possibly population-
specific. Testing of otoliths can provide information on the timing of
transitions between freshwater and salt water, and distinguish
between sympatric populations of anadromous and nonadromous
fishes (Thibault et al. 2010). If testing for Sr or ratios of Sr:Ca, ratios
should be compared to known resident upper river fish and known
marine species. Larger individuals of each species are the most likely
to exhibit anadromous life-stages and should be selected for
sampling as proposed.” –pdf page 94
See AEA’s response to comment FDAUP-61.
FDAUP-83 NMFS 11/14/2012 “In contrast to testing otoliths for marine derived elements, samples
could also be collected from tissues, or fin clippings to have non-
lethal effects (Kline et al. 1998; Doucett et al. 1999). These studies
looked at stable carbon isotopes in tissue samples and compared
them to samples collected from other fish known to be resident in
freshwater or resident in the marine environment. Fish known to be
See AEA’s response to comment FDAUP-61.
Revised Study Plan
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Study of Fish Distribution and Abundance in the Upper Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
resident and marine should be sampled to provide values for
comparison. By using a non-lethal sampling approach, more samples
could be collected, which would a more thorough test for anadromy in
fish populations in the upper river. Tissues are analyzed for carbon
isotope ratios (Kline et al. 1998; Doucett et al. 1999). Non-lethal
sampling methods should be considered, if they can provide valuable
data for assessing anadromy in these populations. If redd sites are
located for Dolly Varden and humpback whitefish, newly-emerged
juveniles can also be tested for marine-derived elements. The tissue
of juveniles will be composed mainly of elements in their yolk sac
(Doucett et al. 1999). This method requires sampling before fresh
water feeding dilutes the marine-derived elements.” –pdf page 94
FDAUP-84 NMFS 11/14/2012 “There is no discussion of the study statistical design or how
migration data will be analyzed or applied to evaluating or mitigating
potential project effects. Understanding resident fish use of the
impoundment zone, and affected tributaries for critical life stages
including spawning and overwinter is a critical information need. The
distribution of these habitats, relative to the inundations zone, is
necessary to evaluate effects to the remnant fish community.” –pdf
page 95
Several methods will be used to assess resident fish use of the
impoundment zones and its tributaries. Two out migrant traps
will be deployed to gather data on downstream movement
timing (Section 9.5.4.4.10). Other methods (i.e., seining,
electrofishing, minnow trapping) will be conducted on a monthly
basis during the open water period and can be used to infer
migratory movements and timing (monthly) (See Section
9.5.4.4). Because of safety and access concerns, no winter
sampling is proposed for the Upper River; it will, however, be
included in the Lower and Middle River (See Section 9.6.1).
Also see AEA’s response to comment FDAUP-63.
FDAUP-85 NMFS 11/14/2012 “The upper river study proposes to radio tag up to 30 individuals of
each species, whereas the middle and lower river study (Section 7.6)
proposes to tag up to 10 of each species. It is unclear what species
will be tagged, what age class, where or when fish will be captured for
tagging and how selection of age class, tagging location, and timing
of tagging has been selected to identify migration patterns. The PSP
does not identify why more fish will be tagged in the upper, compared
to the middle and lower river sites.” –pdf page 95
See AEA’s response to comment FDAUP-63.
FDAUP-86 NMFS 11/14/2012 “With sample timing based on anadromous salmon spawn timing,
July through October; the study likely will miss movements of resident
fish species. Spring migration from overwintering locations or to
See AEA’s response to comment FDAUP-64.
Revised Study Plan
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Study of Fish Distribution and Abundance in the Upper Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
spawning sites have been predicted or observed for many of the
Susitna River resident species, including: rainbow trout, Arctic
grayling, round white fish, and longnose suckers (ADF&G 1981 b,
1983). If receivers are not operational until July, resident spring
migrations will be missed. Monthly measures may not be frequent
enough to document migration patterns and will not assess
movements during winter months. Tracking winter movement is
necessary to identify burbot spawning locations and early spring
migrations that often occur under the ice.” –pdf page 95
FDAUP-87 NMFS 11/14/2012 “This objective addresses the migration of fish past the dam site, but
limits quantification of downstream movement to one method. This is
a modification of the agency objective that stated, "Document the
timing of downstream movement and catch for all juvenile fish
species, and outmigration timing for anadromous species." The PSP
does not provide a purpose or information need for this objective.
Methods are limited to one trap which may or may not be sufficient,
depending upon the purpose of the study. The PSP contains no
description of the effectiveness of the methods at capturing fish that
may be migrating downstream at this location. There is no description
of data analyses or a discussion of how the results will be applied to
project operation or mitigation.” –pdf page 95-96
See AEA’s response to comment FDAUP-65.
FDAUP-88 NMFS 11/14/2012 “The construction and operation of the proposed project have the
potential to create a migration barrier, modify downstream migration
rates, and/or result in fish mortality. Determining species outmigration
and timing is an important upper river objective. Sample methods,
location, timing and frequency of sampling may be different for each
fish species under investigation. Mark recapture methods should be
used to determine the total number of migrating fish or determine the
accuracy of "catch" at estimating total migrating population by
species. The study plan should clearly identify how the data will be
analyzed and used. Migrant traps can miss some species depending
on when they are deployed, their location relative to spawning sites,
and proximity to the shore (Thedinga et al. 1994). Therefore, the
absence of fish cannot be used to indicate that a given fish species or
life stage is not migrating unless a study is designed to determine the
probability of fish capture by life stage.” –pdf page 96
See AEA’s response to comment FDAUP-66.
Revised Study Plan
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FERC Project No. 14241 Page 237 December 2012
Study of Fish Distribution and Abundance in the Upper Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
FDAUP-89 NMFS 11/14/2012 “AEA Study Objective 7. Document the presence/absence of northern
pike in all samples. This objective is unclear, and the reason for its
inclusion is not identified. The ABA PSP already states that all
captured fish will be identified to species, measured, and weighed.
Therefore, the inclusion of this study objective implies that
independent methods will be developed to determine the presence or
absence of northern pike in the upper river.” –pdf page 96
See AEA’s response to comment FDAUP-67.
FDAUP-90 NMFS 11/14/2012 “To our knowledge, intensive sampling for northern pike within this
segment of the Susitna River has not been conducted. We
recommend working with the ADF&G to develop a sampling plan that
identifies upper river sampling locations, sample timing and
frequency, and collection methods to determine whether northern
pike are present. Analytical methods should calculate the probability
of pike presence even if not captured given the level of sampling
effort.” –pdf page 96
See AEA’s response to comment FDAUP-67. See Section
9.5.4.3.6.
Revised Study Plan
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FERC Project No. 14241 Page 238 December 2012
Study of Fish Distribution and Abundance in the Middle and Lower Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
FDAML-01 CWA 11/14/2012 Scope is insufficient in studying the Lower River based on
AEA’s apparent assumption that Project effects will not
significantly affect the Lower fish community. –pdf page 7-8
AEA is not assuming insignificant Project-related effects on the Lower
River processes.
As noted in Section 9.6.3, both Middle and Lower River segments are
under consideration as part of the Fish Distribution and Abundance Study.
The proposed study area for Fish Distribution and Abundance
encompasses the Susitna River from RM 61 upstream to the proposed
Watana Dam site (RM 184). Section 9.6.4.1 indicates that there will be 27
sampling sites for fish distribution within the Lower River. However, the
majority of detailed study elements described in the RSP are concentrated
within the Middle River Segment. This is because project operations
related to load-following and variable flow regulation will likely have the
greatest potential effects on this segment of the river.
FDAML-02 CSDA 11/14/2012 “A minimum of 2 years is needed to evaluate the potential
project impacts on incubation and fry emergence in off
channel habitats in the middle Susitna River.” –pdf page 4 first
bullet
Section 9.6.4.3.3 describes a baseline study objective focused on the early
life history of juvenile salmon that includes tasks focused on emergence
time and fry movement. This specific study will be conducted over 2013
and 2014. Potential for the Project to impact salmon incubation habitat will
be address within the Instream Flow Study Program as described in
Section 8.5.4.6.1.5.
In addition, a pilot study is planned to investigate off-channel intergravel
temperature and DO at two locations during the 2012/2013 winter season
(see Section 9.6.4.5). That study will serve to inform methods for the
2013/2014 winter study.
FDAML-03 FERC 11/14/2012 “In sections 9.5.4.1 (Upper River) and 9.6.4.1 (Middle and
Lower River), you describe methods for selecting study sites
for your fish distribution and abundance studies. In both
sections, you propose a five-level, nested stratified sampling
approach based on the following stratification scheme: (1)
major hydraulic segment, (2) geomorphic reach, (3) mainstem
habitat type, (4) main channel mesohabitat, and (5) edge
habitat. In Figures 9.6-2 through 9.6-5, you present
schematics of strata proposed for sampling in the Lower River
and Middle River segments; however, you omit level 2
(geomorphic reaches) from the figures. It is unclear how you
intend to describe fish distribution and relative abundance
without using level 2 of your stratification scheme. Please
Level two stratification (geomorphic reaches) is discussed in Section
9.6.4.1 but is not included in Figure 9.6-2 because not all habitat types will
be found within each geomorphic reach and inclusion would make the
figure confusing. Site section for fish sampling in the Upper River will
necessarily vary with habitat and will not be stratified equally among
geomorphic reaches. Stratification of site will occur as much across
geomorphic reaches but is limited due to habitat availability, access and
safety. Site selection methods describe a nested hierarchical approach;
mesohabitat units will be selected using a random approach. See Section
9.6.4.1.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 239 December 2012
Study of Fish Distribution and Abundance in the Middle and Lower Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
consider revising your site selection methods to be consistent
with the nested (hierarchical) approach; explain how
mesohabitat units from main channel habitats will be selected
to represent unique geomorphic reaches; and describe how
data collected in mesohabitat units will be extrapolated to
broader scales (e.g., geomorphic reach).” –pdf page 13
FDAML-04 FERC 11/14/2012 “Similarly, the Instream Flow Study (Section 8.5) proposes ten
focus areas for intensive sampling in the middle reach. The
number and location of focus areas for the Lower River and
Upper River segments have not been proposed. In the Fish
Distribution and Abundance Study, Figure 9.6-5, you propose
to sample a total of 40 different habitat types (i.e., 8 each of 5
different habitat types: side slough, upland slough, side
channel, beaver complex, and tributary mouth habitat types)
within the 10 proposed Middle River focus areas. However,
you do not describe how you will select these sites within the
focus areas. In your RSP, please describe how these habitat
units will be selected within the ten focus areas.” –pdf page 14
The Fish Distribution and Abundance Middle and Lower Susitna River
Study will include sampling for relative abundance of fishes and fish
habitat association in Focus Areas. Final site selection for Focus Area-
sampling is dependent upon results of the geomorphic reach delineation
and habitat mapping tasks. These results are anticipated in spring of 2013
and the process for finalizing the locations is explained in Section
8.5.4.2.1.2 of the Instream Flow Study.
Within each Focus Area, one sampling site representative of each
mesohabitat type (side slough, upland slough, side channel, beaver pond,
and tributary mouth) present will then be selected for sampling using
techniques to determine relative abundance (9.6.4.1). The site selection
process and specific locations of proposed Focus Areas for fish sampling
is described in the Fish and Aquatics Instream Flow Study Section
8.5.4.2.1.
No Instream Flow Study Focus Areas are proposed for the Upper River
Segment since the effects of flow regulation from Project operations will
not occur above the dam. Please see response to comment IFS-004
regarding extending studies into the Lower River Segment.
FDAML-05 FERC 11/14/2012 “In section 9.6.4.1, Study Site Selection, and section 9.6.4.3.1,
Objective 1, Fish Distribution, Relative Abundance, and
Habitat Associations, you state that winter sampling sites and
sampling methods will be selected based on information
gathered from a pilot study in winter 2012-2013 at Whiskers
Slough and Slough 8A. Please include in your RSP a detailed
description of the pilot study and provide a schedule for when
the results will be finalized and incorporated into your study
methods for winter fish distribution sampling in 2013 and
2014.” –pdf page 14
Details on the Winter Pilot Study Approach are described in Section
9.6.4.5. As described in the Interdependencies Section of the RSP
(Section 9.6.7). An iterative process will take place during the first and
second quarters for 2013 where the winter study helps to inform other
studies including the Fish Distribution and Abundance in the Middle and
Lower Susitna River Implementation Plan. The results of the 2012-2013
winter pilot study will be filed with the FERC in the Initial Study Report.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 240 December 2012
Study of Fish Distribution and Abundance in the Middle and Lower Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
FDAML-06 FERC 11/14/2012 “Details on the PIT-tag portion of the study were requested
during the September 13, 2012, study plan meeting, including
the number and species of fish to be PIT-tagged. However,
this level of detail is not included in your draft RSP. The
requested PIT tagging information is needed to evaluate
whether the proposed methods will be sufficient to describe
life history timing, migration behavior, etc. Therefore, please
include in your RSP specific information on the number and
species of fish to be PIT tagged.” –pdf page 14
See AEA’s Response to FDAUP-04.
FDAML-07 ADF&G 11/14/2012 “Recommend a section specifically addressing winter
sampling approaches. Minnow trapping under ice should be
incorporated during the winter sampling and recommend
evaluating the feasibility of under ice videography and Didson
technologies.” –pdf page 26
Agreed. Section 9.6.4.5, incorporates minnow trapping, videography and
use of DIDSON for winter sampling.
FDAML-08 ADF&G 11/14/2012 Section 7.6.1.1. Study Goals and Objectives (Page 7-23) “Fish
distribution efforts should be directed at streams not already
identified as supporting anadromous fishes in ADF&Gs
Anadromous Waters Catalog (AWC). AWC information can be
accessed through ADF&Gs online Fish Resource Monitor at:
http://gis.sf.adfg.state.ak.us/FlexMaps/fishresourcemonitor.ht
ml?mode=awc” –pdf page 27
Due to the number and varied nature of tributaries, sampling in 18 of the
62 middle river tributaries is proposed. Tributaries will be selected in a
stratified random design across the eight geomorphic reaches that
represent multiple stream orders. AEA is amenable to prioritizing
tributaries that have not previously been sampled as long as they are
representative. Sampling within the lower reaches of tributaries in the
lower river is not proposed. See Section 9.6.4.1.
FDAML-09 ADF&G 11/14/2012 Section 7.6.1.1. Study Goals and Objectives (Page 7-23)
“Identify target species”” –pdf page 27
Target species are juvenile salmonids and selected fish species such as
rainbow trout, Dolly Varden, humpback whitefish, round whitefish, northern
pike, arctic lamprey, Arctic grayling, and burbot. See Section 9.6.1.
FDAML-10 ADF&G 11/14/2012 Section 7.6.1.1. Study Goals and Objectives (Page 7-23) “Is
goal #1 for juveniles only?” –pdf page 27
Objective 1 refers to juvenile salmonids and all juvenile non salmonid
anadromous fish and resident fish. See Section 9.6.1.
FDAML-11 ADF&G 11/14/2012 Section 7.6.4.1.2. Outmigrant Traps (Page 7-27) “Identify
locations of out-migrant traps and if traps will be manned
during deployment.” –pdf page 27
A maximum of 6 out-migrant traps will be deployed. Between two and
three will be deployed in the main channel to indicate broad timing of out-
migrants from all upstream sources. Between three and four will be
deployed in tributary mouths and sloughs, such as Fog Creek, Kosina
Creek, Portage Creek, Indian Creek and possibly Gold Creek and
Whiskers Slough.
Specific locations will be described in detail in Fish Distribution and
Abundance in the Implementation Plan. AEA will file the implementation
plan with FERC no later than March 15, 2013. Traps will be checked twice
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 241 December 2012
Study of Fish Distribution and Abundance in the Middle and Lower Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
daily while operational. See Section 9.6.4.4.10.
FDAML-12 ADF&G 11/14/2012 Section 7.6.4.1.2. Outmigrant Traps (Page 7-27) “Page 7-27
states “Flow conditions permitting, traps will be fished on a
cycle of 48 hours on, 72 hours off throughout the ice-free
period. Is this from ice-out to ice up? This is several months of
two days on and three days off. Equivalent to 40% of all hours
between spring thaw and fall freeze up. Is this really what is
proposed?”” –pdf page 27
Depending on flow and site access, traps will be fished on a cycle of 48
hours on and 72 hours off throughout the ice-free period. See Section
9.6.4.4.10.
FDAML-13 ADF&G 11/14/2012 Section 7.6.4.2. Remote Fish Telemetry (Page 7-27)
“However, the “re-sighting” of PIT-tagged fish is limited to the
sites where antenna arrays are placed.”
See comments regarding use of PIT tags in section 7.5.4.2.
All fish captured by any sampling method after the first PIT
tagging event will need to be checked for a PIT tag. If fish are
sacrificed, the PIT tag registry must be updated as soon as
possible. Checking all fish for PIT tags will prevent double
tagging of a fish which could introduce error in later passive
tag reading.” –pdf page 27
Agreed, all juvenile salmon, rainbow trout, Arctic grayling, Dolly Varden,
burbot, longnose sucker, and whitefish greater than 60 mm in length that
are handled will be scanned for PIT tags using a portable tag reader. See
Section 9.6.4.4.14.
FDAML-14 ADF&G 11/14/2012 Section 7.6.4.2.1. Radiotelemetry (Page 7-27) “Identify
species to be tagged.” –pdf page 27
Up to 30 radio transmitters will be implanted in selected species including
Arctic grayling, Dolly Varden, rainbow trout, burbot, round whitefish,
humpback whitefish, Arctic lamprey, and northern pike. See Sections
9.6.4.3.2 and 9.6.4.4.12.
FDAML-15 ADF&G 11/14/2012 Section 7.6.4.2.1. Radiotelemetry (Page 7-27) “Define surgical
methods and placements of radio tags in fish. Will an exterior
mark be also used to quickly identify radio tagged fish during
later sampling events?” –pdf page 27
See radio telemetry details in Section 9.6.4.4.12 and 9.6.4.4.14. Further
information on protocols to be described in detail in Fish Distribution and
Abundance in the Implementation Plan. AEA will file the implementation
plan with FERC no later than March 15, 2013.
Run timing from five seasons of intensive effort in the 1980s and from
2012 was used to judge the duration of field operations for the Curry
fishwheels. These data suggest the vast majority of chum and coho
salmon have moved past Curry by late August. Catches in early
September (and electrofishing in the 1980s) suggest the runs of new fish
are complete by early September. In the event that fishwheel catches are
still significant and/or the runs are late (and water and ice conditions
permit), AEA will continue to run the fishwheels into as late into the fall as
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 242 December 2012
Study of Fish Distribution and Abundance in the Middle and Lower Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
catches of migrating fish are sustained.
FDAML-17 TNC 11/14/2012 “The study plans are inconsistent on the use of the terms
„focus areas‟ and “study sites.‟ In these comments, we
assume that these are intended to be the same places so will
use the term “focus area.‟ The method for selection of focus
areas is also inconsistent between and within study plans.
Table 8.5-13 of the Fish and Aquatics Instream Flow Study
(8.5) indicates that Focus Area selection is happening
currently (Q3-4 2012) even before studies are approved or
officially begin. If selection is to be based on the criteria
presented in 8.5.4.2, habitat mapping results from 2013
studies would seem to be required to select focus areas.
Focus areas should be selected based on biological functions
and habitat utilization by salmon as well as physical processes
related to instream flow, including habitat-flow relationships,
surface-groundwater interactions, geomorphic processes, and
ice processes. Biological functions for salmon (i.e. spawning,
rearing, migration, overwintering) could potentially change
with project operations, and appropriate focus area selection
can help to characterize and quantify that anticipated change.
Focus areas should be selected in the Middle and Lower
Rivers. The river from the three river confluence and below is
especially dynamic. Focus areas in the Lower River are
required to understand changes to salmon habitat due to
project operations. As noted in our comments on Climate
Change impacts above, the cumulative impacts of this project
with other anticipated changes to the basin could affect
salmon and salmon habitat in the Lower River.” –pdf pages 2-
3
Study sites are specific locations where data is being collected. Focus
Areas are stretches of river in which a full complement of cross-disciplinary
intensive studies will occur to enhance the richness of the data. These
multidisciplinary studies include geomorphology, water quality, instream
flow, aquatic habitat, and fish sampling. Focus Area sites are being
selected based on a combination of recent and historic data along with the
professional judgment of the various technical teams (see Section
8.5.4.2.1.2). The first selection criterion is to select one or more sites that
are considered representative of the stratum or larger river and that
contain all habitat types of importance. A suite of criteria includes, but is
not limited to geomorphological, riparian/floodplain, fish presence, and
habitat characteristics; groundwater, ice, and water quality. Constraints
such as safety considerations, raptor nests, land ownership and access
will also be considered. Geospatial data for these individual attributes will
be overlain in the Geographic Information System (GIS) to assist in site
selection.
FDAML-18 TNC 11/14/2012 “Lower River Studies
Many of the study plans assume no effects from the project
and its operation below Talkeetna (Mile 97) and do not include
the Lower River in their scope. As noted in our comments on
Climate Change impacts above, the cumulative impacts of this
project with other anticipated changes to the basin could affect
See AEA’s response to comment FDAML-01.
In addition, flow effects tend to attenuate in a downstream direction as
channel morphologies change, and flows change due to tributary inflow
and flow accretion.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 243 December 2012
Study of Fish Distribution and Abundance in the Middle and Lower Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
salmon and salmon habitat in the Lower River. Load-following
operation, which will essentially flip the hydrological pattern
between winter and summer, must be modeled for effects on
the Lower River. The hydrological model has been extended
to Mile 84 in the upper Lower River, and the study plan notes
that the model will be extended further into the Lower River if
project effects are seen at Mile 84. It is not clear what the
trigger will be to extend the model and how or when that will
be decided. The Revised Study Plans, including those for
geomorphology, instream flow, and ice processes, should
include the Lower River. If they do not but leave the possibility
open depending upon early results, the plans should be
explicit about why they assume no effect on the Lower River
and what criteria will be used to revisit the need to extend
models when early results are available.” –pdf page 3
AEA will reevaluate how far downstream Project operational significant
effects extend based in part upon the results of the Mainstem Flow
Routing Models (see Section 8.5.4.3), which is scheduled to be completed
in Q1 2013. Thus, an initial assessment of the downstream extent of
Project effects will be developed in Q2 2013 with review and input of the
TWG. This assessment will include a review of information developed
during the 1980s studies and study efforts initiated in 2012, such as
sediment transport (Section 6.5), habitat mapping (Sections 6.5 and 9.9),
operations modeling (Section 8.5.4.3), and the Mainstem Flow Routing
Models (Section 8.5.4.3). The assessment will guide the need to extend
studies into the Lower River Segment and if needed, will identify which
geomorphic reaches will be subject to detailed instream flow analysis in
2013. Results of the 2013 studies would then be used to determine the
extent to which Lower River Segment studies should be adjusted in 2014.
FDAML-19 USFWS 11/14/2012 Re: AEA Study Objective 1
The Service recommends the methods include three study
components for each fish species. The first is to describe the
seasonal distribution of juvenile anadromous salmonids,
nonsalmonid anadromous fishes, and resident fish. The
second study component is to describe the relative
abundance of fish species, and the third is to describe the
fish-habitat associations. Specific detailed quantitative
information is necessary for all three study components. This
objective should characterize all factors that influence the
seasonal distribution and abundance of juvenile anadromous
and resident fish and not simply support physical and instream
flow modeling.
Proposed sampling frequency and potential locations are
provided but may not be appropriate for the study objective.
The study does not include an evaluation of sampling
efficiency, accuracy, precision, or representativeness. There is
also no description of how the study results will be analyzed or
the metrics used to evaluate potential Project effects. –pdf
page 86
AEA disagrees that this study should characterize all factors or variables
that may influence the distribution and abundance of juvenile anadromous
and resident fish. First, AEA does not think that to “characterize all factors
and variables” is a clear and achievable objective. We know from past
study some of the variables that may influence fish distirbutions such as
cover, presences/absence of predators, presence/absence of prey,
presence/absence of competitors, temperature, flow, three dimensional
structure, upwelling. However, scientists do not know all of the possible
factors that may influence distribution and they do not know the intracacies
of how these factors interact to influence distribution and/or how a fish may
prioritize factors in choosing habitats. Furthermore, we do not think this
level of detail is necessary to characterize fish distributions and/or fish
habitat associations.
Objective 1, as written in Section 9.6.1, is to “describe the seasonal
distribution, relative abundance and fish habitat associations of juvenile
anadromous salmonids, non-salmonid anadromous fishes and resident
fishes.” AEAs approach to sampling for fish under this objective has been
to use a stratified random design. Sampling will be random for habitat
units within the coarse strata of mainstem and mesohabitats as Methods
presented in Section 9.6.4.3.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 244 December 2012
Study of Fish Distribution and Abundance in the Middle and Lower Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
Proposed sampling techniques include the collection of qualitative
(presence-absence) as well as quantitative (including CPUE, fish density,
and counts) data. The sampling approach is based on stratified-random
sampling of all habitats not sampling where environmental factors suggest
fish may or may not be present.
As described in Section 9.6.4.2, sampling frequency will vary among
seasons and sites based on specific objectives. Generally, sampling will
occur monthly at all sites for fish distribution and relative abundance
surveys during the ice-free season. At Focus Areas, sampling will occur
monthly year-round. As per USFWS, sampling will occur bi-weekly to
characterize the movements of juvenile salmonids during critical transition
periods from natal to rearing habitats.
Established protocols will be followed to ensure consistent application of
methods; however, since sampling efficiency, accuracy and precision are
influenced by site conditions we are not going to be able to predict these
estimators. This RSP describes baseline characterization of data that will
be used to evaluate potential Project effects. Dam design and project
operations would need to be advanced prior to determine the appropriate
effects analysis.
FDAML-20 USFWS 11/14/2012 Embryo development, fry emergence and the spatiotemporal
distribution of juvenile fish during the summer, fall, and winter
rearing periods may vary from year to year due to
environmental conditions (temperature, flow, ect) which can
be influenced by Project Operations. The seasonal distribution
of eggs will be determined through the Adult Escapement
Study; however, the temporal distribution of fry will be
influenced by egg development rates. The Service’s request
for the evaluation of egg development is not addressed in the
PSP. –pdf page 87
See AEA’s response to comment FDAML-02.
FDAML-21 USFWS 11/14/2012 Understanding of the timing and influence of environmental
variables on juvenile salmon migration from spawning to
rearing habitats is critical for Project evaluation and will likely
AEA agrees that understanding the seasonal distribution and migration
timing of juvenile salmon is important for Project evaluation. As described
in Sections 9.6.4.3.1 and 9.6.4.3.3, Bi-weekly sampling of fish distribution
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 245 December 2012
Study of Fish Distribution and Abundance in the Middle and Lower Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
require multiple sampling methods, locations and frequencies.
Migrant traps should be used with a sufficient level of effort to
determine the timing and environmental conditions for chum
and sockeye. The service recommends that placement of
migrant traps occur near spawning locations as to document
timing of fry migration relative to environmental conditions, the
size class distribution of migrating fry, and abundance
estimates to evaluate potential spawning success. Trap
locations should be identified during the adult spawning study.
–pdf pages 87-88
(Objective 1, Task A) from ice-out through July 1 will occur in Focus Areas
to identify changes in fish distribution by habitat type. Sampling methods
will include snorkeling, seining, electrofishing, minnow traps, fyke nets,
and out-migrant traps. In addition, we propose to sample with up to six
out-migrant traps on a schedule of 48 hours on, 72 hours off throughout
the ice-free period (Section 9.6.4.4.10). The selection of sampling sites
will be based on data from the adult spawning study and will be described
in detail in the Fish Distribution and Abundance Implementation Plan.
FDAML-22 USFWS 11/14/2012 Understanding of the seasonal distribution of juvenile salmon
among habitats can be influenced by sampling methods. The
Service recommends sampling locations be stratified among
geomorphic classification types but also consider the
relationship to spawning areas and microhabitat
characteristics as well. A description of the methods, the link
from methods to objectives and the analytical approach, and
the metrics used for analysis are still unknown and should be
described in the RSP. –pdf page 88
Agreed. A combination of methods will be used to reduce the influence of
gear bias from any single method on fish distribution and abundance data.
As with any sampling effort, results should be interpreted judiciously in
light of potential biases. Potential biases are outlined in gear descriptions
in Sections 9.6.4.3 and 9.6.4.4. AEA agrees to stratify by habitat type
across geomorphic reaches where possible; however, it is anticipated that
not all habitat types will be present within each reach. Further detail on
sampling protocols and site selection will be provided in the Fish
Distribution and Abundance Implementation Plan, which will be filed with
FERC no later than March 15, 2013.
FDAML-23 USFWS 11/14/2012 “Specific sampling locations among macrohabitat types,
should also consider microhabitat variability within a habitat
type (e.g., woody debris, substrate size, bank cover, riparian
cover, temperature). For example, juvenile fish CPUE likely
may vary considerably among mainstem sampling locations
adjacent to point bars, along outside bends, or within the mid-
channel (Beechie et. al. 2005). Similarly, CPUE from samples
collected at or near the confluence of sloughs and the
mainstem could be different from those collected greater
distances up sloughs due to variable water quality or physical
conditions. Microhabitat sampling locations should be
identified to interpret sample results designed to evaluate the
temporal distribution of juvenile salmon among macrohabitat
types.” –pdf page 88-89
Fish sampling in microhabitats will be conducted under the HSC/HSI task
(Section 8.5.4.5.1.1.4) of the Fish and Aquatics Instream Flow Study, As
described therein, the specific location of sampling will be recorded with a
GPS, photographed, and microhabitat features will characterized for many
fish sampling sites during HSC data collection. In addition, a general
description of microhabitat characteristics will be described for all HSC
sampling sites on data collection forms to help explain variability; however,
sampling at the microhabitat level of stratification would result in very small
sample sizes of these features that would preclude useful analytical
comparisons.
For fish sampling in mainstem and mesohabitats, the proposed nested
stratification scheme (Section 9.6.4.1) was designed so as to capture
variability in relative abundance between and seasonal use of habitat
types on a spatial scale that is useful for evaluating project effects. A
mesohabitat level assessment based on river morphology and ecologically
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 246 December 2012
Study of Fish Distribution and Abundance in the Middle and Lower Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
significant habitat attributes provides documentation that is consistent and
reproducible.
FDAML-24 USFWS 11/14/2012 “A similar process should be applied to identifying sampling
locations for tributary spawning species. As mentioned
previously, Chinook spawning in the 1980s occurred primarily
in two right bank tributary streams in the Middle Susitna River:
Indian River and Portage Creek (upstream of River Mile 138).
Whereas, coho salmon spawning occurred primarily in
tributaries near below river mile 110. Thus, early season
sampling in locations closer to tributaries used by spawning
adults would likely have higher CPUE values. Therefore, the
Service recommends that sampling locations for juvenile
salmon be stratified spatially and temporally by proximity to
spawning areas including river mile and bank (i.e., left or
right), geomorphic classification types, and then meso-habitat
characteristics (see comments on habitat classification) to
understand the seasonal distribution of juvenile salmon within
the Middle and Lower Susitna River.” –pdf page 89
AEA agrees to stratify by habitat type across geomorphic reaches where
possible; however, it is anticipated that not all habitat types will be present
within each reach. The tributary streams mentioned may be good locations
for the placement of out-migrant traps. The locations of out-migrant traps
will be determined with input from the Fish and Aquatic TWG (Section
9.6.4.3.2). Further detail on sampling protocols and site selection will be
given in the Fish Distribution and Abundance Implementation Plan, which
will be filed with FERC no later than March 15, 2013 (see Section 9.6.4) .
FDAML-25 USFWS 11/14/2012 “It may also be necessary to develop a sampling frequency
that is linked to changes in chemical or biological
characteristics, or otherwise relevant to proposed Project
operations. If juvenile salmon distribution is related to changes
in turbidity because of seasonal increases in flow from
glaciers, then sampling frequency should provide
measurements over a range of mainstem conditions. Similarly,
if mainstem turbid waters provide cover (Gregory and Levings
1998, Ginetz and Larkin 1976) and influence fish distribution
in sloughs as water levels rise, then sampling locations and
frequency should provide measures that encompass these
changes in habitat characteristics. The direct effects of the
Project on fish will likely vary under different operational
scenarios. At a minimum, sampling frequency should provide
a measure of fish distribution when Project effects are
expected to be greatest. For example, if changes in flow are
expected to influence fish movements, then sampling
frequency should document fish movement prior to, during,
As described in Section 9.6.4, AEA proposes to conduct fish distribution
and relative abundance sampling at a total of 262 sites that represent all
habitat types present in the Upper, Middle and reach 1 of the Lower River
(LR-1) at a monthly sampling frequency during the ice free period. A
reduced number of sites also will be sampled during the ice in period.
In addition, movements of multiple fish species will be monitored through
the use of pit tags, radio tags, and fish traps (Section 9.6.4.3.2). These
methods will be implemented throughout the year. AEA is confident that
this frequency will cover a full range of environmental conditions including
chemical, biological and hydrologic conditions that change over the course
of the year.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 247 December 2012
Study of Fish Distribution and Abundance in the Middle and Lower Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
and following similar natural variations in flow.” –pdf page 89
FDAML-26 USFWS 11/14/2012 As an objective to determine if juvenile salmon maintain site
fidelity from if summer through winter or emigrate to new
locations, PIT tag arrays could be used at Susitna confluence
and at upland and side sloughs. To infer the relative
importance of overwintering habitat locations a variety of
methods is likely needed including PIT tagging and video.
Monthly winter fish sampling using these methods could be
done at sites randomly stratified by geomorphic class types. –
pdf page 90
Locations for PIT tag arrays and fish traps will be determined in Q1 2013
with input from the TWG. The specific locations and rationale used to
select them will be documented in the Fish Distribution and Abundance
Implementation Plan, which will be filed with FERC no later than March 15,
2013 (Section 9.6.4).
FDAML-27 USFWS 11/14/2012 “Relative Abundance
The use of relative abundance data are not explained in the
PSP, but differences in CPUE could be used to identify
important fish habitat characteristics and may also be used to
develop habitat suitability criteria for instream flow analyses.
However, relative abundance for juvenile salmon in particular,
can vary with proximity to spawning areas, catchability among
habitat types, and with differences in flow, and should be
considered when evaluating habitat quality. Underwater video
could potentially have less sampling bias based on flow, cover
or depth, but could be affected by poor visibility from turbidity
and may be limited to providing only qualitative information
such as fish presence/absence, fry emergence times, or diel
fish activity. However, the sampling methods for underwater
video are only mentioned for winter use in the PSP (detailed in
Mueller et. al. 2006). Use of video during the open water
season in clear water sloughs or tributaries could also provide
an additional method for observing juvenile sockeye salmon
that may not otherwise be captured using other gear types.” –
pdf page 91
AEA agrees the winter pilot study in 2012 will provide an assessment of
the value of DIDSON and underwater video in this system. As described
in Section 9.6.4.3.3, if these tools prove effective they will be used
seasonally to evaluate diurnal behaviors of fish in Focus Areas.
FDAML-28 USFWS 11/14/2012 The PSP does not outline how fish-habitat relationships for
juvenile salmon will be used, how habitat characteristics will
be measured, or how statistical methods will be used to
determine these relationships. The Service recommends that
AEA review literature on the characteristics that define habitat
The Fish Distribution and Abundance Middle and Lower Susitna River
RSP describes collection of data for baseline characterization on fish
distribution, relative abundance, and fish-habitat associations, as well as
six other specific study objectives that help to describe fish use of habitats.
These data are, by nature, descriptive and do not require specific
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quality from egg through summer and winter rearing to better
understand parameters that should be incorporated into the
RSP. –pdf page 91
statistical approaches or analysis to determine relationship between fish
abundance and habitat type. During future analysis of Project effects,
statistical analysis may be appropriate to compare across samples or over
time.
Habitat characterization is described in Section 9.9. On-the-ground habitat
surveys will be conducted using a standardized, and widely accepted
habitat protocol developed by USFWS. This protocol, including habitat
parameters that will be documented is described in Section 9.9.5.3.
FDAML-29 USFWS 11/14/2012 The methods outlined in PSP to describe the seasonal
movements and migratory patterns of juvenile anadromous
and resident juvenile fish have not been developed to meet
the Service’s study request. The PSP lacks methods to
characterize flow related, or synchronization of resident fish
migration and life histories to other physical, chemical, or
biological environmental variables. Methods should clearly
identify target species and when, where, and how each
species is to be captured and identify important physical,
chemical, or biological variables that may explain movement
patterns. Pit tag receiver operations and installation could limit
results; locations should further consider the life history
patterns of target species. Pit tagging is also limited by fish
size and will not provide information on the early life stages
most vulnerable to Project operations. –pdf page 92
An early life history of salmon objective is described in Section 9.6.4.3.3.
This objective specifically addresses movements of juvenile salmonids
from incubation to rearing habitats. In addition, radio telemetry is being
used with multiple species to document seasonal and/or life history based
movements into and out of habitats. These data will allow for future
evaluations of movement patterns such as effects of storm events and
rapidly changing flows on fish movement. Target species for radio
telemetry are listed in Section 9.6.4.4.12.
As explained in Section 9.6.4.4.12, selection of locations for telemetry and
PIT tag arrays will include current knowledge of the distribution, habitat
use, and life histories of all target species. Locations will be selected in
Q1 of 2013 with input from the TWG.
Multiple environmental factors affect fish movements including flow, storm
events, presence of predators and conspecifics, food availability,
temperature, light, celestial cues, individual motivational state, among
likely many other variables yet to be shown to result in fish movement.
AEA anticipates that the Project will likely affect the seasonal flow regime
in the river and, as described above, is undertaking studies to provide
baseline data relevant to seasonal movements and flows. AEA believes
that understanding the intricate synchronization of fish migration and life
histories to a variety of other physical, chemical, and biological
environmental variables is outside of the nexus of the Project.
FDAML-30 USFWS 11/14/2012 “The methods described to address this objective include
using biotelemetry to identify seasonal movements of juvenile
anadromous and resident fish; however, it is not clear how this
Telemetry studies are intended to describe the baseline condition of
seasonal and life history based movements of target fish species
throughout the year. The study may or may not relate directly to habitat
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will relate to the habitat characterization studies or the
instream flow models. Methods mention ways biotelemetry
can be used to measure growth rates and calculate population
estimates, but there is no objective that describes why these
data will be collected or how it will be used. It is assumed that
growth rates and abundances will be used to characterize
preferred seasonal habitats for each species, which might
then be combined with instream flow analyses to determine
how these habitats might change thereby quantifying effects
to fish populations. However, there is no description of
whether physical (depth, velocity, temperature), chemical (pH,
conductivity, dissolved oxygen), or biotic variables (primary
and secondary productivity) will be measured in conjunction
with fish capture and tracking efforts, particularly if spawning
or overwintering habitats are located outside the reaches
included in habitat characterization or river productivity
studies. Without accompanying measures of fish-habitat
characteristics or parameters influencing fish movement, it is
unclear how distribution trends can be estimated or
extrapolated out to similar, non-sampled areas.
Presence/absence information is not sufficient to provide
necessary information to make decisions on how a
hydroelectric project could influence fish survival and
distribution or movement among foraging, spawning or
overwintering habitats.” –pdf page 93
characterization or instream flow modeling efforts. It is only after the
results are available that an understanding can be achieved of where
tagged fish move and the data collected can be used in other studies to
help interpret those movements. For instance, it is feasible that a group of
rainbow trout tagged while in a tributary mouth habitat move well upstream
in the tributary and remain there for the duration of the study period. In this
case there would be no relationship to habitat or instream flow studies.
However, much more likely is the scenario that tagged fish move
throughout habitats that have been mapped and characterized by the
Characterization and Mapping of Aquatic Habitat study (Section 9.9).
Then, the results of the habitat mapping and characterization and/or
instream flow studies (Section 8.5) can be synthesized with telemetry
results to describe seasonal fish-habitat relationships and to predict
potential project related effects.
Because, PIT tags are individually coded the recapture of tagged fish can
provide data regarding fish growth. This is not an objective of the study
but opportunity to collect ancillary data to help characterize existing fish
populations.
The approach to Fish and Aquatic Resources that AEA proposes is a
habitat-based approach. The Project has the potential to alter aquatic
habitat and thereby potentially affect fish and other aquatic resources
using those habitats. All of the baseline data collected that describes the
aquatic environment including habitat mapping and characterization, flow-
habitat relationships, water quality, geomorphology, algal and
macroinvertebrate communities, fish presence, fish relative abundance,
fish-habitat associations, and fish movement patterns will be available for
integration and synthesis as a part of the environmental analysis that will
support AEA’s FERC License Application.
FDAML-31 USFWS 11/14/2012 “Sampling habitats based on equally measuring the “major
habitat [geomorphic classification] types” assumes that the
distribution of geomorphic habitats is equal throughout the
drainage. Many factors, such as water chemistry and
productivity will also influence the distribution of fish among
these sites, beyond this geomorphic characterization.
Classifying fish as preferring side channels versus side
sloughs may miss the habitat variables influencing fish
Stratification will occur across geomorphic reaches as much as possible
but will be dictated by the distribution of habitat types present within each
reach. AEA is confident that the stratified random sampling design at the
mesohabitat scale (see Section 9.6.4.1) will document baseline conditions
of fish distribution and abundance at a level that is consistent and
reproducible. A macrohabitat level stratification approach is beyond the
scope of this study. Because site characteristics change temporally (i.e.,
with flow), habitat measurements will be collected at each site using the
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distribution. Therefore, it is important to measure habitat
variables at each sample site and event to determine if use of
macrohabitats is in proportion to availability when evaluating
fish distribution and abundance.” –pdf page 93
characterization methods identified in Section 9.9. Some additional
variables specific to each gear type will be collected, for example,
conductivities will be taken at all sites where electrofishing will occur
(Section 9.6.4.4.2). To help elucidate what physical and chemical
variables may be influencing fish-habitat use and fish movements at
specific sites or for specific species, additional information will be collected
at sites identified as Focus Areas (Section 8.5.4.2.1.2), HSC sampling
sites (Section 8.5.4.5.1.1.4), or Winter Sampling (Section 9.6.4.5) by
multiple resources such as instream flow, water quality, riparian,
groundwater, ice, and geomorphology.
FDAML-32 USFWS 11/14/2012 The number of fish to be tagged may not be sufficient to meet
study objective. If fish selected for tagged are stratified by
habitat type, this only allows for two fish per strata which may
not provide an understanding of movements habitat utilization
by species. Monthly winter and spring aerial surveys have the
potential to miss movements and migration timing, more
frequent surveys are needed. More information is need
regarding which species will be tagged, the minimum size for
radio transmitters, and how the movement of fish <60mm will
be monitored. –pdf page 93
AEA agrees that the proposed radio tag sample size of 10 fish for each
target species, as indicated in the PSP, is insufficient and has modified the
RSP to reflect that up to 30 fish per species will be tagged. As described
in Sections 9.6.4.3.2 and 9.6.4.4.12,up to 30 radio transmitters will be
implanted in each target species including Dolly Varden, humpback
whitefish, round whitefish, northern pike, Arctic grayling, burbot, and
rainbow trout. In addition to PIT tagging (Section 9.6.4.4.12), the
proposed approach to radio tag up to 30 individuals of each resident or
non-anadromous target species will help achieve the stated objectives
(Sections 9.6.4.3.2 and 9.6.4.3.4) and allow for a level of understanding of
seasonal movement patterns necessary to establish a baseline.
As described in Sections 9.6.4.4.12 and 9.6.4.4.14, the radio telemetry
study will rely upon both mobile tracking and fixed antenna arrays. The
location of the fixed antenna arrays can be used to help focus in on
important migratory components that may be missed with monthly mobile
surveys. The location of fixed arrays installed in 2013 will be determined
with input from the TWG in Q1 2013.
Section 9.6.4.4.12 reads “Tags will be surgically implanted in up to 30 fish
of sufficient body size of each species distributed temporally and
longitudinally throughout the middle and lower river”. Because some fish
species will be difficult to capture in sufficient numbers, and some habitat
associations are dubious (i.e., fishwheel capture does not mean fish are
associated with that habitat), tagging efforts will be stratified temporally
and longitudinally to provide a greater opportunity to achieve sample size
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targets. Detailed information on the size of tags and the size of fish to be
tagged are provided in Section 9.6.4.4.12, Table 9.6-3, and Figure 9.6-6.
FDAML-33 USFWS 11/14/2012 “The PSP maintains that up to 10 sites will be selected for
deploying PIT tag antenna arrays to detect movements into or
out of selected sites and will be deployed shortly after ice-off
in 2013. Additionally, swim-over antennas are planned to be
deployed at five sites prior to ice-over, on an experimental
basis. The target species in this study and the criteria used for
site selection of antenna arrays has not been clearly defined.
Information on large and fine scale movements of fish will be
dependent on site selection for antenna arrays and tagging
sites. There is a large sample area to cover with only 10 or
fewer observation sites, especially considering that it will only
register movements into and out of relatively small tributaries
and sloughs.” –pdf page 94
AEA disagrees that more than 10 PIT tag antenna arrays are necessary to
achieve the level of detail necessary to achieve study Objective 2,
seasonal movements (Section 9.6.4.3.2). In addition to PIT tagging, other
techniques including radio telemetry and out-migrant traps will be used to
address seasonal fish movements (Section 9.6.4.3.2). Additional
information has been provided in Section 9.6.4.4.12 with respect to PIT
tagging. Up to 1000 tags per species per PIT tag array will be tagged
based on proximity to PIT arrays. Target species include juvenile
salmonids and selected fish species such as rainbow trout, Dolly Varden,
humpback whitefish, round whitefish, northern pike, Arctic lamprey, Arctic
grayling, and burbot. Site selection of PIT tag antenna arrays will be
determined with input from the Fish and Aquatic Resources TWG and may
include selected side channel, side slough, tributary mouth, and upland
slough sites to detect movement of tagged fish into or out of the site.
Further detail on PIT tag protocols and site selection will be given in the
Fish Distribution and Abundance Implementation Plan, which will be filed
with FERC no later than March 15, 2013 (Section 9.6.4).
FDAML-34 USFWS 11/14/2012 The stated study objective to “Document the timing of
downstream movement and catch for all fish species using
outmigrant traps” is too broad; the objective should be
expanded and state a purpose to ensure that appropriate
methods and sites are selected. The study should also
discuss how the data collected will be used. –pdf page 94
The stated objective serves it purpose and the methodology is designed to
provide necessary information to meet this study objective. Out-migrant
traps are passive sampling tools and, as such, they collect all fish that
swim into them. As implied by the objective, catch data will be used to
help describe the timing of downstream movements of all species
collected. However, as described in Section 9.6.4.3.2, the out-migrant
objective will be focused on movements of fish species out of select
tributaries and out of select Middle River habitats such as Focus Areas
with documented high fish use. The location of traps will be determined
with input from the TWG.
FDAML-35 USFWS 11/14/2012 Under the PSP objective “Characterize the age structure,
growth, and condition of juvenile anadromous and resident
fish by season” no information is provided on why metrics are
being collected and how they will be used in Project
evaluation. AEA should identify the specific study objectives
and information needs that require juvenile anadromous and
The study objective in the Section 9.6.4.3.5 is Document the Seasonal
Age Class Structure, Growth, and Condition of Juvenile Anadromous and
Resident Fish by Habitat Type. These baseline data will be used to
support the stranding and trapping portion of the Fish and Aquatics
Instream Flow Study (Section 8.5.4.5.1.2.2). Detailed information on
sampling locations and methods will be provided in the Fish Distribution
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resident fish growth rates. Then appropriate sampling location
and methods and analytical methods should be developed. –
pdf page 95
and Abundance Implementation Plan, which will be filed with FERC no
later than March 15, 2013 (Section 9.6.4). The intent of this study objective
is to document baseline conditions for age, growth and condition by habitat
type that is consistent and reproducible. AEA is confident that the level of
effort proposed (27 sites in Lower River for relative abundance, 96 sites in
Middle River for fish distribution, 54 sites in the Middle River for relative
abundance, 18 tributaries in the Middle River, and up to 40 sampling
locations within Focus Areas) is rigorous and sufficient for effects analysis.
FDAML-36 USFWS 11/14/2012 It is not clear whether invasive fish species other than
northern pike will be considered or evaluated under study
objective 5. The PSP did not provide the purpose of this study
objective or identify how northern pike distribution, relative
abundance or habitat associations may be affected by the
proposed Project. –pdf page 95
The purpose of this study is to document baseline conditions on the
seasonal distribution, relative abundance, and habitat associations of all
invasive fish species encountered. Northern pike is identified because it is
presently the only known invasive fish species in the Middle/Lower River,
is a known predator of juvenile salmon, and will be the focus of Objective 6
(see Section 9.6.4.3.6). The presence/absence and habitat associations of
northern pike and other invasive fish species will be documented in all
sampling events involving fish capture or observation associated with
Objectives 1 and 2. Directed efforts with angling will also be used to
capture northern pike. Radio-tagging 30 northern pike will provide
additional information on distribution and movements.
FDAML-37 USFWS 11/14/2012 “The PSP provides no description of the sampling locations,
timing, frequency, or methods (passive or active) that will be
used to document northern pike (or other invasive species)
distribution, relative abundance, or habitat associations. A
review of methods employed previously by Alaska Department
of Fish and Game (ADF&G) should be provided and a
description of how and where these methods would be used
to accomplish the stated objective.” Pdf page 96
As described in Section 9.6.4.3, the initial task of this study will consist of a
focused literature review to guide selection of appropriate methods by
species and habitat type, sampling event timing, and sampling event
frequency. This includes a synthesis of existing information on life history,
spatial and temporal distribution, and relative abundance by species and
life stage and a review of sampling strategies, methods, and procedures
used in the 1980s fish studies.
In addition to the suite of fish sampling methods designed to capture a
multitude of species, there will be directed efforts to capture northern pike
with angling. Radio-tagging of up to 30 northern pike will provide
additional information on distribution and movements. See Section
9.6.4.3.6.
Further detail will be given in the Fish Distribution and Abundance
Implementation Plan, which will be filed with FERC no later than March 15,
2013 (see Section 9.6.4).
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FDAML-38 USFWS 11/14/2012 “The PSP does not provide information on data analyses or
how information on northern pike would be incorporated into
the evaluation of potential Project-related effects. It appears
that evaluation of northern pike distribution, relative
abundance, and habitat associations will consist of reporting
when and where there are incidental catches of northern pike
through other sampling efforts.” –pdf page 96
Northern pike is an invasive non-native species present in the Susitna
basin; its presence and distribution is a management concern to ADF&G.
AEA included this objective in the study based upon a specific request by
ADF&G. While angling will be the primary method of targeting northern
pike, the presence of pike will be documented in all surveys.
FDAML-39 USFWS 11/14/2012 “A clear understanding of the distribution of northern pike is
important for the interpretation of biotic effects to the
distribution and abundance of juvenile salmon and other
resident salmonid and non-salmonid anadromous species.
This may be of particular importance for lower gradient
streams that have similar physical characteristics to those
where northern pike are currently present. These could
include tributaries that will likely be influenced by Project
operations including Whiskers Creek, Birch Creek and slough,
Trapper Creek, Cache Creek, and Rabideux Creek, that
provide spawning and rearing habitat for Chinook and coho
salmon and rearing habitat for Chinook, coho and sockeye
salmon. In addition, as pike distribution increases, the
importance of moderate-sloped clear water tributaries to
glacial rivers may become more important for salmon as
locations where pike are absent. The Middle Susitna River
provides important rearing and overwintering habitat for
Chinook salmon and displacement of these fish due to Project
operations could make them more susceptible to predation by
northern pike. Similarly, flow fluctuations during winter could
displace overwintering fish from mainstem habitats to
backwater locations and increase risk of pike predation. The
loss of flushing flows due to Project operations could increase
physical habitat characteristics that give northern pike a
competitive advantage.” –pdf page 96
See AEA’s response to comment FDAML-338.
FDAML-40 USFWS 11/14/2012 “This Study Request Objective was not addressed in the PSP,
but has been discussed at TWG meetings. The Services
anticipate that most portions of this objective will be included
in the Revised Study Plan as part of the Instream Flow Study,
An objective has been added in the Instream Flow Study that specifically
addresses Intergravel monitoring. See AEA’s response to comment
FDAML–02.
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however we cannot comment on the details of what this may
entail at this time. Characteristics of suitable spawning habitat
vary by species but include water depth, velocity, temperature,
flow, space, upwelling and downwelling, substrate size, and
percent fine sediment (see review in Bjornn and Reiser 1991).
Habitat characteristics that affect incubation (rates and
success) and emergence (dates and times) include dissolved
oxygen, water temperature, biochemical oxygen demand,
substrate size, percent fines, channel gradient, water depth,
flow, velocity, stream bed porosity, and velocity of water
through the redd (Bjornn and Reiser 1991). An evaluation and
monitoring of spawning and incubation habitat as described
below in the Services’ Study Request Objective 9 will be
included in the intragravel study. The evaluation of existing
emergence times is still being developed and may include the
use of migrant traps in areas with open leads and possibly
with the use of video. Although some discussion of the
methods has occurred, detailed methods should be provided
in the methods of the Instream Flow Study.” –pdf page 97
For the 2012-2013 study component focused on intergravel temperature,
dissolved oxygen and water surface levels, monitoring sites will be
selected using a stratified random sampling approach. The Whiskers
Slough and Slough 8A study areas will be stratified by habitat type (main
channel, side channel, tributary mouth, side slough, and tributary), with
special emphasis given to areas at which salmon spawning was observed
in 2012. A total of 10-12 monitoring sites will be randomly selected among
strata. Depending on individual site characteristics, temperature
monitoring devices will be installed at locations of 1) groundwater
upwelling, 2) bank seepage and lateral flow from mainstem, 3) mixing
between upwelling and bank seepage, 4) no apparent intergravel
discharge, 5) fish spawning, and 6) main channel Susitna River flow.
See Section 9.6.4.3.3 for a description of the early life history of salmon
study the address emergence and fry movements.
FDAML-41 USFWS 11/14/2012 “Although stranding (and trapping) of juvenile fish is
mentioned in the Instream Flow Study, this objective was not
addressed in the PSP. This objective has been presented and
discussed at subsequent TWG meetings and there has been
a commitment by AEA to include this in the Habitat Specific
Varial Zone modeling. There has also been some discussion
at TWG meetings and during the October 2012 site visit of
empirically evaluating juvenile fish stranding and trapping
under natural flows. Because fish stranding was observed
during our October 2012 site visit, the Service maintains there
is a need for more detailed discussion of empirically
evaluating stranding and trapping in relation to assessing pre-
and post-Project effects.” –pdf page 97
A specific objective has been added to the study at the request of USFWS
to focus on early life history. Specific tasks under this objective include:
describe emergence timing, determine movement patterns and timing of
juvenile salmonids from spawning to rearing habitats. See Section
9.6.4.3.3.
FDAML-42 USFWS 11/14/2012 “Agency Study Request Objective 9. Measure intragravel
water temperature in spawning habitats and winter juvenile
fish habitats at different surface elevations and different
depths to determine the potential for freezing of redds,
See AEA’s response to comments FDAML-02 and FDAML-40.
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freezing of juvenile fish, and their habitats.
This Study Request Objective (Agency Study Objective 9) was
not addressed in the PSP, but has been presented at recent
TWG meetings and will be added in the Revised Study Plan
as part of the Instream Flow Study. Although some
discussion of the methods has occurred, more detailed
methods should be provided in the revised Instream Flow
Study.” –pdf page 97
FDAML-43 NMFS 11/14/2012 “There is only minimal review of related species specific or
site-specific studies and in many cases species life history
information is not included in the proposed study. General fish
sampling methods are listed but specific methods that will be
used to sample different species or life stages are not
presented. Sampling locations refer to different geomorphic
classification types. Sampling locations need to be selected
proportional to the distribution of habitat classification types.
Sample locations should be randomly selected from all
available sites with similar classification after that habitat
classification assessment is completed. NMFS should agree
with the habitat classification scheme and the habitat sampling
methodology in advance of studies being conducted. The
study plan needs to account for the variability in sampling
efficiency among habitat types and establish in advance how
this variability will be accounted when evaluating differences
in distribution or habitat associations.” –pdf page 99
As described in Section 9.6.4.3, the initial task of the study will consist of a
focused literature review to guide selection of appropriate methods by
species and habitat type, sampling event timing, and sampling event
frequency.
Sampling efficiency among gear types is discussed in Section 9.6.4.4.
AEA does not propose to sample study sites based on a geomorphic
reach classification scale but on a mesohabitat scale (Section 9.6.4.1) that
is consistent with licensing studies completed in the 1980s. AEA has
proposed a habitat-based characterization of the Fish and Aquatic
Resources and will be collecting information on fish relative abundance,
distribution and apportionment of fish by representative habitats (Section
9.6.4.1). This will help us understand the current fish-habitat relationships.
The models that AEA will use to predict potential Project impacts are also
habitat based and will use predictions of changes to aquatic habitat to
demonstrate an affect instead of absolute fish numbers. These models
have the advantage of incorporating both site specific data on fish habitat
as well as data from numerous studies in other systems where fish habitat
has been characterized. AEA is confident that it has developed rigorous
fish and instream flow programs that will be effective in understanding the
potential impacts of the proposed Project on fisheries resources.
Detailed information on gear types, sampling protocols, and site selections
will be provided in the Fish Distribution and Abundance Implementation
Plan, which will be filed with FERC no later than March 15, 2013 (see
Section 9.6.4).
FDAML-44 NMFS 11/14/2012 “Monthly sampling is proposed; however, this adequacy of this Sampling frequency and timing has been revised. Sampling will occur on
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sampling frequency to address study objectives needs to be
explained. There is no indication that any habitat
characteristics will be measured in order to determine causal
factors influencing habitat selection and habitat quality. The
analytical methods need to be determined in advance;
statistical tests and acceptable power analysis to determine
significant differences in fish community metrics between
geomorphic classification types needs to be included in the
study design. The PSP must be revised to address these
concerns and describe how the data from these studies will be
used to evaluate potential project effects.” –pdf page 99
a monthly basis for each site except during critical periods (i.e., migration
from natal to rearing habitats) where it will occur biweekly. See Section
9.6.4.2. Since site characteristics change temporally (i.e., with flow),
habitat measurements will be collected at each site using the
characterization methods identified in Section 9.9. Additional information
may be collected specific to each gear type; for example, conductivities
will be taken in all sites where electrofishing will occur. See Section
9.6.4.4.2.
Multiple environmental factors affect fish movements including flow, storm
events, presence of predators and conspecifics, food availability,
temperature, light, celestial cues, individual motivational state, among
likely many other variables yet to be shown to result in fish movement.
AEA anticipates that the Project will likely affect the seasonal flow regime
in the river and, as described above, is undertaking studies to provide
baseline data relevant to seasonal movements and flows. AEA believes
that understanding the intricate synchronization of fish migration and life
histories to a variety of other physical, chemical, and biological
environmental variables is outside of the nexus of the Project.
This study is focused on baseline characterization of the current fish
assemblage and their distribution, relative abundance, and species habitat
associations. Comparison of fish community metrics between habitat
types is not a study objective. AEA is confident that the approach
proposed in the RSP will allow for the level of detail necessary to address
potential Project effects.
FDAML-45 NMFS 11/14/2012 “Instream flow analysis of habitat suitability is proposed as the
analytical method to be applied to determine the distribution
and abundance of fish in the middle and lower river. Both the
proposed method and the methodology described in the PSP
are problematic for the following reasons. The method
requires development of species and life-stage specific habitat
suitability curves (HSC). The development and application of
HSCs have been a subject of debate among scientists since
publication of the instream flow increment methodology
(Mathur et al. 1985, Kondolf et al. 2000). However, the
Fish sampling in microhabitats will be conducted under the HSC/HSI task
(Section 8.5.4.5.1.1.4) of the Fish and Aquatics Instream Flow Study. As
described therein, the specific location of sampling will be recorded with a
GPS, photographed, and microhabitat features will characterized for many
fish sampling sites during HSC data collection. In addition, a general
description of micro habitat characteristics will be described for all HSC
sampling sites on data collection forms to help explain variability; however,
sampling at the microhabitat level of stratification would result in very small
sample sizes of these features that would that preclude useful analytical
comparisons.
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methods that will be used to develop habitat suitability curves
and how they will address the limitations of this methodology
need to be provided. HSC development is partially addressed
in Study 6.5, Instream Flow and Aquatic Habitat. but that
study request objective needs to be addressed for the upper,
middle, and lower reaches for all juvenile anadromous fish
species and life stages affected, and needs to be included in
the PSPs for resident fish and non-salmonid anadromous fish.
The PSPs need to clarify how HSC information will be
collected, particularly in winter for post-emergent fish up to 60
mm when fish will be most vulnerable to load-following
operations (stranding and trapping). There are no empirical
studies described to evaluate potential project effects or for
inclusion in habitat modeling efforts; this study planning
deficient needs to be resolved. There is generic reference to
developing HSC model in Study 6.5 for these species and life
stages; the source of that information needs to be identified
for NMFS to adequately assess that proposed study
component.” -pdf pages 99-100
FDAML-46 NMFS 11/14/2012 “NMFS believes that lower river studies are necessary to
evaluate potential biotic effects due to species displacement
from middle river habitats, to document the relative
contribution to fish production and use between these two
river segments, provide replicate measures of fish-habitat
relationships, and to provide for post-project comparisons.
The study area for the middle and lower river fish studies in
AEA's PSP is from river mile 28 to the Watana Dam site.
However, during presentations at the TWG meetings, it was
suggested that the study area be limited to the downstream
extent of estimated flow effects as determined through the
flow-routing studies. Limiting the studies based on estimated
extent of flow modification ignores potential indirect project
effects and NMFS does not agree with the proposed
truncation of the study site given the lack of information on the
extent of likely project effects.” –pdf page 100
See AEA’s response to comments FDAML-01 and FDAML-18.
AEA agrees that sampling in the Lower River is necessary and the RSP
includes sampling locations in the upper reaches of the Lower River
Segment (RM 61-98).
AEA disagrees with the comment that potential project effects on organic
matter and macronutrients will extend downstream of the Three Rivers
Confluence into the Lower River. A review of USGS average monthly flow
data indicates that the Chulitna and Talkeetna rivers combine and
contribute annually more than 50% of the flow in the Lower River, where
as the Middle Susitna River contributes more on the order of 40%. This
pattern is reflected in winter monthly flow contributions as well. Based
on the documented flow differences between the Sustina River and the
Chulitna and Talkeetna rivers and well as varying temperature
regimes and turbidity regimes, AEA anticipates that substantial differences
in organic matter and nutrients occur within these river systems. We also
anticipate that the larger combined flow related influences of the Chulitna
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and Talkeetna rivers in combination will attenuate potential Project
operation effects on the mainstem Susitna River downstream from the
Three Rivers Confluence. As described in Section 9.8.3, AEA will
reevaluate how far downstream potential project operational effects may
extend based in part upon the results of the Open-water Flow Routing
Model (see Section 8.5.4.3), which is scheduled to be completed in Q1
2013.
AEA does not agree that the potential Project changes in concentrations of
organic matter and nutrients could extend upstream into the Chulitna and
Talkeetna River. The concentrations of these parameters and
subsequently the habitat quality in these tributary rivers will be determined
primarily by the flow, sediment and temperature conditions that occur
within these basins. These environmental conditions will not be affected by
the construction or operation of the proposed Watana Dam.
FDAML-47 NMFS 11/14/2012 “Lower river fish and aquatic studies are necessary to
documents the relative importance of these two stream
segments. Differences in water chemical and physical
characteristics could result in differences in habitat quality. For
example, greater numbers of juvenile Chinook salmon were
found overwintering within the middle river compared to lower
river sites even though total available habitats were much
lower (ADFG 1981). The biological reasons for this apparent
variability in habitat quality and/or habitat use need to be
assessed for NMFS application in developing protection,
mitigation, and enhancements.” –pdf page 100
Agreed. The focus of Lower River sampling will be to select sites in lateral
habitats where the Project may affect changes and to supplement habitat
types with limited or no replication in the Middle River. See AEA’s
response to comment FDAML-46.
FDAML-48 NMFS 11/14/2012 “Lower river sampling is necessary to provide adequate
replication of macro-habitats to determine fish habitat
relationships. Tributary mouths have been identified as one of
the geomorphic classification types that may provide important
juvenile salmon overwintering habitat. However, there are
considerable biological, water quality, and physical differences
among tributaries. For example, Whiskers Creek is a
moderate sloped stream characterized by low pH, high
dissolved carbon, and relatively dense coho spawning, and
coho and Chinook overwintering populations. However, it is
the only middle river tributary with these characteristics.
The Lower River sampling described in the RSP includes selection of
sites in lateral habitats which may be susceptible to potential project
effects. See Section 9.6.4.3.
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Therefore, replication of this tributary type will require
selection of similar lower river sites (e.g. Trapper Creek,
Cache Creek, Rabideux Creek, Moose Creek, Greys Creek,
and Kroto CreeklDeshka River) to determine if the
characteristics of these tributary mouths are important
components of fish habitat. A similar discussion could be
applied to Indian River and Portage Creek, which combined
provide most of the Chinook spawning but provide only two
sample replicates of this stream type. Addition replicate sites
could be found in the lower river including Montana Creek,
Willow Creek, Sheep Creek, and possibly the Kashwitna
River.” –pdf pages 100-101
FDAML-49 NMFS 11/14/2012 “Proposed study plans for post-project monitoring are not
provided and need to be developed for a wide range of study
areas, including this and other lower river sites. Lower river
sites may be suitable as long-term monitoring locations. Lower
river sites may have many of the same biological, chemical,
and physical conditions as middle river locations. Lower river
sites could be used to differentiate between changes in
relative abundance due to changing climate, escapement or
marine survival and project-related effects. Without pre-project
lower river studies, any post-project changes in Susitna River
fish and aquatic resources may be assumed to be due to
project construction and operation. Without pre-project lower
river studies, decisions regarding project mitigation including
hydropower operations may need to be made without any
information on pre-project fish and aquatic resources in the
lower river. NMFS requests that post-project monitoring
include lower river sites with sufficient baseline information on
these sites to determine if any changes in their physical,
chemical and biological characteristics are due to project
operations or to non-project related causes. This information
is needed for Adaptive Management, as recommended in
NMFS Climate Change Study Request (for additional
recommendations on Adaptive Management see NMFS
Section 5.11 PSP comments in this document).” –pdf page
The objectives of this study plan do not include development of post-
Project monitoring plan. Based upon the results of its environmental
analysis supporting AEA’s FERC License Application, AEA will determine
the nature, scope, and location of post-Project monitoring.
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101
FDAML-50 NMFS 11/14/2012 “Study of Fish Passage Barriers in the Middle and Upper
Susitna River and Susitna Tributaries: NMFS finds this to be
an overly-broad study objective and being so, it will result in
the following problems. It includes the spatial and temporal
distribution of multiple fish species with different life histories,
their relative abundance, and factors influencing habitat
associations. The purpose of this study objective is only briefly
defined by AEA. There is only a cursory review of existing
information. Methods have not been developed for specific
study objectives. Proposed sampling frequency and locations
are provided but are not appropriate for the study objective.
The study does not include any evaluation of sampling
efficiency, accuracy, precision, or representativeness. There is
no description of how the study results will be analyzed or
used to evaluate potential project effects.” –pdf page 101
The potential exists for the Project to alter flow and flow-related physical
habitat features in such a way as to create impediments to fish passage
into and out of Middle River habitat. Thus, four objectives are proposed
for study in Section 9.12.1.1. These study objectives are specific and
relate directly to the potential Project nexus. Detailed methods to
accomplish these objectives are presented in Section 9.12.4. Section
9.12.4.13 provides a summary description of data necessary to support
analyses and a summary of how it will be analyzed.
FDAML-51 NMFS 11/14/2012 “The seasonal distribution of adult anadromous salmon and
salmon eggs will be determined through AEAs Adult
Escapement Studies (Section 7.7). However, the temporal
distribution of Pacific salmon fry will be influenced by egg
development rates. The presence of chum or sockeye salmon
fry within the Susitna River or off-channel habitats will depend
upon egg development and emergence timing. The evaluation
of spawning and egg development is not included in ABA
proposed study plans but is the subject of multiple agency
study plan objectives outlined below. Because this important
consideration is missing from the AEA PSP, NMFS wants it
placed into the study plan. Given the likelihood of winter
operations to affect incubating and overwintering salmon,
infonnation of the effects of the proj ect on habitat important
for those critical life stages is necessary for NMFS to develop
measures such as ecological flows to protect or mitigate
against these negative impacts.” –pdf pages 102-103
See AEA’s response to comment FDAML-02.
FDAML-52 NMFS 11/14/2012 “The timing and influence of environmental variables on
juvenile salmon migration from spawning to summer rearing
The proposed monthly sampling frequency with additional biweekly
sampling in incubation and early life history rearing habitats, as described
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habitats are critical to project evaluation. Emergent salmon fry
are weak swimmers, and the presence and access to slow
water nearshore habitats and off-channel locations can be
affected by changing flows. The distribution of resident fish
species and other predators may be due to the presence of
migrating salmon fry. The description of the seasonal
distribution of juvenile Pacific salmon will require unique
sampling methods, sampling locations, and sampling
frequency for different species.” –pdf page 103
in Section 9.6.4, is adequate to capture variability in relative abundance of
fishes between habitats and across time. A mesohabitat level assessment
based on river morphology and ecologically significant habitat attributes
provides documentation that is consistent and reproducible and at a
spatial scale that is useful for future evaluations of Project effects.
FDAML-53 NMFS 11/14/2012 “The PSP needs to specify where fyke nets will be used in to
capture migrating sockeye and chum juveniles. Migrant traps
such as fyke nets and inclined plane traps must be used at
appropriate sites with a level of frequency that can determine
if the timing of chum and sockeye migration is strongly
affected by conditions that could be modified by project
operations (i.e. water temperature and flow).” –pdf page 103
As described in Section 9.6.4.3.3, methods to capture emergent juvenile
salmon, including fyke net traps, will be deployed bi-weekly starting in mid-
April or when ice clears. The decision to collect bi-weekly data on
emergent fish was made with input from USFWS and NMFS
representatives at the September 13, 2012 subgroup meeting. Additional
details on this strategy will be provided in the Fish Distribution and
Abundance Implementation Plan that will be filed with FERC no later than
March 15, 2013.
FDAML-54 NMFS 11/14/2012 “Migrant traps (fyke nets, screw or incline plane traps) located
near adult sockeye and chum salmon spawning locations
should be used to document fry migration timing relative to
environmental conditions, to estimate the size distribution of
migrating fry, and to develop population estimates to evaluate
spawning success (fry per spawning female x fecundity). The
use of migrant traps for sockeye salmon is preferable to other
sampling methods as electro fishing, beach seines, and
minnow trapping used to capture sockeye fry had limited and
variable success. The results of adult salmon escapement and
incubation and emergent studies should be used to identify
proposed sampling locations and the timing of migrant trap
operation.” –pdf page 103
See AEA’s response to comment FDAML-53 regarding identification of the
location of out-migrant traps.
See also Section 9.6.4.3.3 for a description of the early life history of
salmon study component that addresses emergence and fry movements.
In additional to other gear types, out-migrant traps will be deployed to
determine out-migration timing and relative abundance of juvenile salmon
including sockeye; see Section 9.6.4.10.
Regarding population estimates of fry, AEA disagrees. Fish population
estimate are highly variable over time and space, have large amount of
uncertainity associated with them even under the best conditions, and
require sufficient effort so as to compromise AEA’s ability to obtain
comprehensive coverage for fish. As discussed both in the September 13,
2012 subgroup meeting and October 25, 2012 TWG meeting, USFWS
requested that AEA not collect data in order to derive population
estimates, but rather increase sampling associated with relative fish
abundance and presence/absence. For additional reference ADF&G
outlined the biases associated with estimates of productivity (smolts per
spawner) in their review of 1980s studies and future recommendations
report., Susitna Aquatics Study Report #3501.
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In addition, AEA eliminated sampling to generate population estimates at
the request of USFWS. This request was made during the October 25,
2012 TWG meeting; and no opposition was noted to this request.
FDAML-55 NMFS 11/14/2012 “Migrant traps near the confluence of tributaries and the
Susitna River are preferable to document juvenile Chinook
and coho salmon movement from spawning to rearing areas
compared to seasonal variability in CPUE. In addition to more
detailed run timing, migrant traps allow for population
estimates using mark recapture methods. This provides a
method to calculate spawning success in tributary streams.” –
pdf page 104
Agreed. A maximum of six out-migrant traps will be deployed. Up to three
traps will be stationed in the mainstem Susitna River to characterize
downstream migratory timing. Because Chinook salmon are
predominantly tributary spawners, out-migrant traps will also be deployed
in mouths of tributaries such as Portage Creek, Indian River, and Whiskers
Creek. Specific locations will be provided in the Fish Distribution and
Abundance Implementation Plan, which will be filed with FERC no later
than March 15, 2013. See Sections 9.6.4.3.2 and 9.6.4.4.10.
FDAML-56 NMFS 11/14/2012 “Results from other sampling methods can be biased due to
differences in catchability. Electrofishing catchability varies
with differences in water depths, cover, velocities, and visibility
(Schmidt et al. I984). Similarly, minnow traps can be size
selective and seasonal catch rates can be influenced by water
temperature, flow, and the presence of predators (Stott 1970,
Jackson and Harvey 1997).” –pdf page 104
Agreed. A combination of methods will be used to reduce the influence of
gear bias from any single method on fish distribution and abundance data.
As with any sampling effort, results should be interpreted judiciously in
light of potential biases. Potential biases are outlined in gear description
Sections 9.6.4.3 and 9.6.4.4.
FDAML-57 NMFS 11/14/2012 “The seasonal distribution of juvenile Pacific salmon within the
Middle and Lower Susitna River during summer rearing likely
will be based on the relative abundance or CPUE among
sampling locations. Our understanding of the distribution of
juvenile salmon among habitats can be influenced by the
locations sampled, when samples are collected, the frequency
of sampling, and differences in catchability due to sampling
methods. Sampling timing and frequency, locations, and
sampling methods should be related to species life histories
and to address specific project related questions.” –pdf page
104
Agreed. See Section 9.6.4.3.
FDAML-58 NMFS 11/14/2012 “Sampling locations should be stratified among physical
geomorphic classification types including turbid mainstem and
side channels, and off-channel sloughs and tributaries.
However, sampling locations also must consider the
relationship to spawning areas and micro-habitat
See AEA’s response to comment FDAML-31.
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characteristics. For example, previous Susitna River studies
have documented sockeye salmon spawning in discrete
locations and the migration of fry from these areas following
emergence peaking in early to mid-July. Due to specific
sockeye salmon spawning locations and migration timing,
June sampling of mainstem habitats immediately upstream
and downstream of spawning areas likely will result in large
differences in sockeye fry CPUE. Similarly, if sockeye salmon
spawning locations are all predominantly on the left bank (i.e.
Slough 8A and Slough 11), then sockeye fry CPUE may differ
considerably between samples collected on the left or right
bank. If these two locations are treated as replicate mainstem
habitats, then CPUE will be highly variable and we will be less
likely to determine if there are significant differences among
habitat types. Whereas, if these are discrete sampling areas
based upon stratified sampling, we will have a much better
understanding of June sockeye fry distribution among main
stem habitat locations.” –pdf page 104-105
FDAML-59 NMFS 11/14/2012 “Specific sampling locations among macro-habitat types, must
also consider micro-habitat variability within that habitat type
(woody debris, substrate size, bank cover, riparian cover,
temperature). For example, juvenile CPUE likely will vary
considerably among mainstem sampling locations adjacent to
point bars, along outside bends, or within the mid-channel
(Beechie et. al. 2005). Similarly, CPUE from samples
collected at or near the confluence of sloughs and the
mainstem could be different from those collected greater
distances up sloughs due to variable water quality or physical
conditions. Micro-habitat sampling locations must be identified
in order to interpret sample results designed to determine
temporal distribution of juvenile salmon among macro-habitat
types.” –pdf page 105
Agreed, where sub-sampling of habitat types is required the specific length
of habitat sampled will need to be randomly and or systematically
determined. The protocols that will be used to determine specific lengths
of aquatic habitat sampled will be determined once mainstem and
mesohabitats are selected for sampling and will be provided in the Fish
Distribution and Abundance Implementation Plan which will be filed with
FERC no later than March 15, 2013 (see Section 9.6.4).
FDAML-60 NMFS 11/14/2012 “A similar thought process should be applied to identifying
sampling locations for juvenile coho and Chinook salmon. As
mentioned previously, Chinook spawning occurs primarily in
two right bank tributary streams in the Middle Susitna River:
See AEA’s response to comment FDAML- 59.
AEA does not agree that it would be useful to stratify sampling locations by
proximity to spawning areas, river mile, or mirco-habitat features for the
purposes of this study.
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Indian River and Portage Creek (upstream of Mile 138).
Whereas, coho salmon spawning occurs primarily in
tributaries near below river mile 110. June sampling locations
closer to tributaries used by spawning adults are likely to have
higher CPUE values. Therefore, sampling locations for
juvenile salmon must be stratified by proximity to spawning
areas including river mile and right or left bank, geomorphic
classification types, and then meso-habitat characteristics
(see comments on habitat classification) in order to obtain an
understanding of the seasonal distribution of juvenile Pacific
salmon within the Middle and Lower Susitna River.” –pdf page
105
For fish sampling in mainstem and mesohabitats, the proposed nested
stratification scheme (Section 9.6.4.1) was designed so as to capture
variability in relative abundance between and seasonal use of habitat
types on a spatial scale that is useful for evaluating project effects. A
mesohabitat level assessment based on river morphology and ecologically
significant habitat attributes provides documentation that is consistent and
reproducible.
Fish sampling in microhabitats will be conducted under the HSC/HSI task
(Section 8.5.4.5.1.1.4) of the Fish and Aquatics Instream Flow Study, As
described therein, the specific location of sampling will be recorded with a
GPS, photographed, and microhabitat features will characterized for many
fish sampling sites during HSC data collection. In addition, a general
description of microhabitat characteristics will be described for all HSC
sampling sites on data collection forms to help explain variability; however,
sampling at the microhabitat level of stratification would result in very small
sample sizes of these features that would preclude useful analytical
comparisons.
FDAML-61 NMFS 11/14/2012 “It may also be necessary to develop a sampling frequency
that is tied to changes in chemical or biological characteristics,
or relevant to proposed project operations. For example, if
juvenile salmon distribution is believed to be related to
changes in turbidity due to seasonal increases in flow from
glaciers, then sampling frequency should provide
measurements over a range of mainstem conditions. Similarly,
if cover provided by mainstem turbid waters (Gregory and
Levings 1998, Ginetz and Larkin 1976) influences fish
distribution in sloughs as water levels rise, then sampling
locations and frequency should provide measures that
encompass these changes in habitat characteristics. The
direct effects of the project on fish likely will vary under
different operational scenarios. Sampling frequency should
provide measures of fish distribution when project effects are
likely to be greatest. For example, if changes in flow are
expected to influence migration, then sampling frequency
should document fish movement prior to, during, and following
similar natural variations in flow.” –pdf page 105-106
See AEA’s response to comment FDAML-25.
Sampling frequency and timing has been revised since the submission of
the Proposed Study Plan. Sampling will occur on a monthly basis for each
site except during critical periods (i.e., migration from natal to rearing
habitats) where it will occur biweekly. See Section 9.6.4.2. To help
elucidate what physical and chemical variables may be influencing juvenile
fish-habitat use and fish movements at specific sites or for specific
species, additional information will be collected at sites identified as Focus
Areas (Section 8.5.4.2.1.2), HSC sampling sites (Section 8.5.4.5.1.1.4), or
Winter Sampling sites(Section 9.6.4.5) by multiple resources such as
instream flow, water quality, riparian, groundwater, ice, and
geomorphology.
In addition, since site characteristics change temporally (i.e., with flow),
habitat measurements will be collected at each site using the
characterization methods identified in the Characterization and Mapping of
Aquatic Habitat, Section 9.9. Additional information may be collected
specific to each gear type. For example, conductivities will be taken in all
sites where electrofishing will occur. See Section 9.6.4.4.2.
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FDAML-62 NMFS 11/14/2012 “AEAs proposed study plans to document the distribution of
juvenile Pacific salmon during winter should identify whether
fish maintain site fidelity from summer through winter or if they
emigrate from summer rearing locations. The locations
selected for overwintering should be identified as well as
identifying similar but unused habitat in winter. PIT tagging of
salmon juveniles in tributaries with stationary antennae arrays
near the Susitna confluence could be used to determine the
portion of fish migrating out of these streams as water
temperatures and light levels decline or in response to fall
storms or changes in flow. PIT tags also could be used to
determine site fidelity within upland and side sloughs with tag
detection at stationary arrays near the slough mouth. The PSP
is deficient because it will not provide information necessary to
determine where fish overwinter and why these particular
habitats are selected. If the plan follows our recommendation
below, this critical information will help NMFS recommend
stream flows that allow fish to maintain access to
overwintering habitat.” –pdf page 108
See AEA’s response to comment FDAML-26.
In addition to PIT tagging, other techniques including out-migrant traps and
regular sampling at more than 250 sites over 158 river miles will be used
to address seasonal fish movements (Section 9.6.4.3.2). Further data
collected on juvenile fish-habitat use and fish movements at specific sites
or for specific species, will be collected at sites identified as Focus Areas
(Section 8.5.4.2.1.2), HSC sampling sites (Section 8.5.4.5.1.1.4), or Winter
Sampling (Section 9.6.4.5) by multiple resources such as instream flow,
water quality, riparian, groundwater, ice, and geomorphology. AEA
expects that this amount of effort will provide the level of detail necessary
on seasonal movements of juvenile salmonids to address potential project
effects.
FDAML-63 NMFS 11/14/2012 “Based upon previous Susitna River sampling, juvenile
salmon have been found overwintering in tributary mouth,
mainstem, and off-channel habitats. Monthly winter fish
sampling at random sites stratified by geomorphic
classification types should be used to identify distribution
during winter. However, sampling methods are likely to be
limited during winter months and the probability of fish
capture, or observation, will vary between sites, so differences
in CPUE cannot be used to infer differences in relative
importance of overwintering habitat locations. Seines were the
only method that consistently captured sockeye salmon
juveniles in both mainstem and off-channel habitats; however,
seines cannot be used when there is partial ice cover.
Similarly, minnow traps were the primary sampling method
used to capture juvenile coho and Chinook salmon. However,
the use of minnow traps under the ice will be difficult, and
catchability varies with temperature (Stott 1970). NMFS
Agreed. As described in Section 9.6.4.5, winter fish sampling will employ
multiple methods to determine which are most effective for each fish
species, life stage, and habitat type. Based on results of Winter 2012-
2013 Pilot Studies, under-ice fish observations will be made using
DIDSON sonar and underwater video cameras. Because sampling efforts
will occur in both open water and ice covered sites, methods will vary
depending on conditions. In ice-covered sites the primary sampling
methods will be trotlines and minnow traps. In open water sites, the fish
capture methods will be baited minnow traps, electrofishing, and beach
seines. Radio telemetry and half duplex PIT technologies will be used at
ice covered sites to test tag detection range and efficiency during winter
conditions.
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recommends the use of underwater video as it appears to be
the only method available to document the presence or
absence of juvenile salmon at multiple sampling locations. It is
unknown whether video observations of fish are proportional
to fish densities; this should be tested through comparison
with other sampling techniques.” –pdf page 108
FDAML-64 NMFS 11/14/2012 “For juvenile salmon, NMFS recommends using growth rates
as a primary indicator of habitat quality rather than using
relative abundance based on catch per unit effort (CPUE).
Differences in CPUE should not be used alone to identify
important fish habitats and may not be appropriate for use in
developing habitat suitability criteria for instream flow analyses
due to inconsistency in sampling results using various
sampling methods (seine, minnow traps, electrofishing, etc.).
Particularly for juvenile salmon, relative abundance can vary
with proximity to spawning areas, catchability among habitats
and with differences in flow, and should not be used
indiscriminately to indicate relative habitat quality.” –pdf page
108
AEA concurs that indiscriminate use of fish abundance data would be
inappropriate and that fish abundance is not likely to be the only predictor
of habitat quality. When evaluating habitat quality AEA will consider a
number of factors including but not limited total fish abundance, species
richness, fish growth, number of life stages present, water quality
parameters, algal and macroinvertebrate communities. AEA disagees that
growth rates should be the primary indicator of habitat quality simply
because fish move and may move between habitats at a daily, weekly,
monthly or seasonal time step depending on life stage, size, and a variety
of other environmental factors. As fish move among habitats daily growth
rates will vary overtime with the dynamic environmental conditions they
encounter. Given the size and dynamic nature of the Sustina river and the
number of species and life stages that AEA proposed to describe fish-
habitat associations for we cannot expect to understand movements at a
level of detail necessary to assign growth rate to a specific habita. Thus,
AEA does not consider defining the growth-habitat relationships, that
would be necessary to use growth as an indicator of habitat quality, as a
realistic or achievable objective.
FDAML-65 NMFS 11/14/2012 “The relative abundance of juvenile salmon fry closely
following emergence, and in close proximity to spawning
locations likely reflects spawning incubation success rather
than quality of rearing habitat and should not be interpreted as
an index of abundance or quality of rearing habitat.” –pdf page
108
AEA agrees, in the early life history component of the RSP (Section
9.6.4.3.3.) it states that the sampling objective for fry stage is to describe
emergence timing not relative abundance as a measure of rearing habitat.
Since relative abundance data will be collected year-round, it will be
important that this data is reviewed before it is analyzed. As an example,
during QAQC procedures, salmonids of a certain size class may be
selected or excluded if data are to be used for abundance or habitat
quality. As with any sampling effort, results should be interpreted
judiciously in light of potential temporal, spatial or gear biases (see Section
9.6.4.3.1).
FDAML-66 NMFS 11/14/2012 “Catchability for all standard gear types can vary greatly See AEA’s response to comment FDAML-56
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among different habitat types. Beach seining was found to be
more effective in turbid waters in a 1983 gear efficiency study
in several sloughs on the Susitna River (Schmidt et al 1984,
Part 2, Appendix B). In clear waters fish can see and avoid the
seine or hide under cover. Although it is more effective in
turbid waters, seining is less effective in habitats that contain
deep pools and abundant cover. Electrofishing performs better
in clear water but is also affected by cover and results vary
depending on the user. For both methods, CPUE could
underestimate density for all species. In addition, results
based on CPUE would not directly reflect habitat quality
because of the biases of gear among habitat types. This is
especially pronounced for juvenile sockeye salmon, which
school in deep pools, prefer clear water, but can only be
caught efficiently with seining.” –pdf page 109
FDAML-67 NMFS 11/14/2012 “Baited minnow trap CPUE can vary with flow, potentially
recruiting a greater number of large fish in areas of increased
velocity (Culp and Glozier 1989). Smaller fish can also more
easily escape from traps, therefore age 0+ Chinook and coho
abundance could be underestimated in the spring and early
summer (Culp and Glozier 1989, Jackson and Harvey 1997).
The placement and orientation of minnow traps can also affect
CPUE and are hard to replicate effectively and uniformly in
order to accurately represent density. This method is also
proven ineffective at capturing sockeye because they are not
attracted to bait.” –pdf page 109
Agreed. The efficacy of minnow traps varies with species, life stage, and
habitat characteristics. A combination of methods will be used to reduce
the influence of gear bias on fish distribution and abundance. During the
1980s, minnow traps were effective and the primary method used for
capturing sculpin, lamprey, and threespine stickleback. See Section
9.6.4.4.5.
FDAML-68 NMFS 11/14/2012 “Underwater video could potentially contain less sampling
biases based on flow, cover or depth but could be effected by
turbidity due to poor visibility. The sampling methods for video
use are only described for winter use in the PSP (detailed in
Mueller et. al. 2006). Application of video during the open
water season in clear water sloughs or tributaries could also
provide crucial data for evaluating fish abundance. This would
provide an addition method for observing juvenile sockeye
salmon that are not captured in minnow traps and avoid beach
seines in clear water as mentioned above.” –pdf page 109
Agreed. Details on underwater video sampling are described in Section
9.6.4.4.13.
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FDAML-69 NMFS 11/14/2012 “In summary, documenting juvenile salmon fish habitat
relationships could be considered the most important
information needed to evaluate the proposed project. The
development and implementation of many other very difficult
and expensive studies (ground water, water quality, flow
routing, productivity etc.) are being conducted largely to
determine their influence on fish habitat relationships.
Instream flow analyses will be based upon understanding
project effects on characteristics that drive fish habitat
relationships. Ultimately, the operation of the proposed project
may be determined by these studies. In addition, fish habitat
relationships are extremely complex and can be influenced by
many variable and interacting physical, chemical, and
biological parameters. However, the AEA PSP gives only a
cursory summary offish collection methods with a general and
minimal description of sampling locations and frequency that
are not based upon the life histories of the fish species know
to reside within the Middle Susitna River.” –pdf page 111
Baseline fish-habitat association data associated with this study will be
collected as part of Objective 1, described in Section 9.6.4.3.1. Additional
information on fish-habitat use and fish movements at specific sites or for
specific species, will be collected at sites identified as Focus Areas
(Section 8.5.4.2.1.2), HSC/HSI sampling sites (Section 8.5.4.5.1.1.4), and
during Winter Sampling (Section 9.6.4.5) by multiple resources such as
instream flow, water quality, riparian, groundwater, ice, and
geomorphology.
Additional detail on sampling protocols sufficient for implementation by
field crews, sampling site selection protocols, and specific locations of
sampling sites will be presented in the Fish Distribution and Abundance
Implementation Plan, which will be filed with FERC prior to March 15,
2013 (Section 9.6.4).
FDAML-70 NMFS 11/14/2012 NMFS study objectives for resident fish have not been
addressed in the PSP. The characterization of seasonal
distribution, relative abundance ad habitat associations of
resident fish and migration will not result in data useful for
evaluating project effects. Study plans need to be developed
to characterize flow-related, or synchronized resident fish
migration and life histories as the related to other physical,
chemical, or biological environmental variables. –pdf page
112
.AEA disagrees that the study plan will not result in useful data to evaluate
potential project effects on resident fishes. Resident fish seasonal
distribution, abundance, habitat use and movements are address under
three separate objectives in the Section 9.6.
Objective 1 of the characterizes the distribution, relative of abundance of
resident and anadromous species using the same approach. This includes
sampling at 217 different sites once a month during the open water period,
with multiple methods to target all life stages and species present (Section
9.6.4.3.1).
In addition, as described under Obejctive 2, seasonal movements of
resident fish species will be addressed by operating fish traps and
following target resident fish species using biotelemetry, specifically PIT
and radio tags (Section 9.6.4.4.12). As explained in Section 9.6.4.4.12,
selection of locations for telemetry and PIT tag arrays will include current
knowledge of the distribution, habitat use, and life histories of all target
species. Locations will be selected in Q1 of 2013 with input from the
TWG.
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
Furthermore, Objective 4 (Section 9.6.4.3.4) focuses in of resident species
that spawn in winter and therefore require additional sampling to
understand spawning habitat associations.
Multiple environmental factors affect fish movements including flow, storm
events, presence of predators and conspecifics, food availability,
temperature, light, celestial cues, individual motivational state, among
likely many other variables yet to be shown to result in fish movement.
AEA anticipates that the Project will likely affect the seasonal flow regime
in the river and, as described above, is undertaking studies to provide
baseline data relevant to seasonal movements and flows. AEA thinks that
understanding the intricate synchronization of fish migration and life
histories to a variety of other physical, chemical, and biological
environmental variables is outside of the nexus of the Project.
FDAML-71 NMFS 11/14/2012 “The study methods do not clearly identify those species that
will be evaluated. However, a list of species is provided,
which, in part is covered under other study objectives (i.e.
seasonal movement of northern pike). The AEA PSP provides
only cursory information on the general life-history patterns of
the target fish species and does not include any site specific
information (See Appendix to this Study Section). Methods do
not identify when, where, or how specific fish species will be
captured. For many species, the location and operation of
receivers has not considered life history patterns of the target
species. Sampling methods do not appear to be developed to
address the study objective. PIT tagging is identified in the
study objective, but the limitations on installation and
operation of arrays will bias results. The study does not
identify any of the other biological, chemical, or physical
characteristics that may explain migration patterns. There is
no description of how the analyses of the data obtained from
this study will be conducted to meet the study objective.” –pdf
page 112
Section 9.6.4 and 9.6.6.6.12 describe target species and specifics
regarding the use of radio-telemetry and PIT tagging to document fish
movements in the Middle and Lower River. In addition the initial study
task, Section 9.6.4.3, is to compile relevant life history information to
support sampling of all species thought to be present in the study area
See AEA’s response to comment FDAML–29 regarding the determination
of biological, chemical and or other physical characteristics that may
explain fish movement patterns.
FDAML-72 NMFS 11/14/2012 “The methods planned to address this objective include using
biotelemetry to identify seasonal movements of resident fish;
however, it is not clear how this will relate to the habitat
See AEA’s response to comment FDAML – 30.
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characterization studies or the instream flow models. Methods
(described below) mention ways in which biotelemetry can be
used to measure growth rates and calculate population
estimates, but there is no objective for why these data will be
collected or used. It is assumed that growth rates and
abundances will be used to characterize preferred seasonal
habitats for each species. which might then be combined with
instream flow analyses to determine how these habitats might
change thereby quantifying effects to fish populations.
However, there is no description of whether physical (depth,
velocity, temperature), chemical (PH, conductivity, dissolved
oxygen), or biotic variables (primary and secondary
productivity) will be measured in conjunction with fish capture
and tracking efforts, particularly if spawning or overwintering
habitats are located outside the reaches included in habitat
characterization or productivity studies. Without
accompanying measures of fish habitat characteristics or
parameters influencing migration, no distribution trends can be
estimated or extrapolated out to similar, non-sampled areas. A
basic presence/absence study is not enough to provide
valuable information to make decisions on how a hydroelectric
project could influence fish survival and distribution or
migration among foraging, spawning or overwintering
habitats.” –pdf pages 112-113
FDAML-74 NMFS 11/14/2012 “Sampling habitats based on equally measuring the "five
major habitat [geomorphic classification] types" assumes that
the distribution of geomorphic habitats is equal throughout the
drainage. Many factors, such as water chemistry and
productivity will control the distribution of fish among these
sites, likely to a greater extent than this general, physical
characterization. Classifying fish as preferring side channels
vs. side sloughs may entirely miss what drives fish distribution
in these areas. For this reason, it is important to measure
habitat variables at each sampling site and event, and try to
determine if any of those variables outweigh macro-habitat
types (use in excess of availability) in determining fish
See AEA’s response to comment FDAML-31.
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distribution and abundance. Additionally, adding
supplemental, non-intensive sampling events at sites where
radio-tagged fish are observed, but that are not part of the
regularly planned sampling schedule is suggested. Single
sampling events of various habitats could be helpful for
capturing species that may not be abundant at the sites
selected or to look for presence of invasive species in more
locations.” –pdf page 113-114
FDAML-75 NMFS 11/14/2012 “The number of fish proposed to be tracked in the AEA study
plan is insufficient to document the migration patterns to
spawning, summer foraging, and overwintering habitats to
meet the study objective. The operation of radio receivers has
not been developed to track the resident species identified.
Radio transmitters are proposed to be "surgically implanted in
up to 10 fish of sufficient body size of each species from five
geomorphic types in the Middle and lower river." This
description of methods does not provide enough detail for
valuable comments. General information that needs to be
provided includes: which species will be tagged; the
"sufficient" sizes for radio transmitters; how movements of
smaller, juvenile fish will be monitored. If fish selection is
equally stratified among five different habitat types, this only
provides information on movements for two fish from each
habitat type below Devil Canyon. It is unclear if this level of
effort will be sufficient to understand general movements and
seasonal habitat utilization by each species of resident fish.
The plan is to only maintain fixed receiver stations during July
through October, to coincide with adult salmon migrations;
however, this will miss many resident fish migrations that
occur in the spring (see specific species below). If a main
objective for the biotelemetry studies is to track seasonal
movements of resident fish, the observation period should not
only be based on adult salmon migrations. Monthly winter and
spring aerial surveys have the potential to miss movements
and migration timing from overwintering to spawning or
summer rearing habitats.” –pdf page 114
AEA agrees, the number of fish to be radio tagged has been revised.
Instead of 10, a goal of 30 fish of selected species will be tagged. Target
species include Dolly Varden, humpback whitefish, round whitefish,
northern pike, Arctic grayling, burbot, and rainbow trout. See Section
9.6.4.3.2. In addition to radio tagging, PIT tagging and monthly/bimonthly
sampling techniques at more than 250 sites over 158 river miles will be
used to address seasonal fish movements (Section 9.6.4.3.2). AEA
expects that the level effort and combination of techniques will be sufficient
for baseline data collections to meet the stated objectives (Sections
9.6.4.3.2 and 9.6.4.3.4).
The Salmon Escapement Study (See Section 9.7) will provide
approximately weekly aerial survey coverage of the study area
(approximately July through October). At other times of the year, the
frequency and location of aerial surveys will be at least monthly and bi-
weekly during critical species-specific time periods (e.g., burbot spawning).
Telemetry surveys will also be conducted by boat, snow machine, and on
foot to obtain the most accurate and highest resolution positions of
spawning fish. Fixed Station receivers operated July through October by
the Salmon Escapement Study (Section 9.7) will be extended to include
the month of June. Using the guidance of fixed-station and aerial survey
data on the known positions of tagged fish, specific locations of any
concentrations of tagged fish that are suspected to be spawning will be
visited to obtain individual fish positions. See Section 9.6.4.4.12.
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
FDAML-76 NMFS 11/14/2012 “Additionally, radio-tagging studies can have high failure rates,
from tagging-induced mortality, expulsion of tags, or tag
malfunction (Chisholm and Hubert 1985; Ridder 1998).
Tagging 10 or fewer fish does not seem to account for this
problem when determining sample sizes.” –pdf page 114
AEA agrees, the number of fish to be radio tagged has been revised.
Instead of 10, a goal of 30 fish of selected species will be tagged. Target
species include Dolly Varden, humpback whitefish, round whitefish,
northern pike, Arctic grayling, burbot, and rainbow trout. See Section
9.6.4.3.2.
FDAML-77 NMFS 11/14/2012 “The PSP also states that up to ten sites will be selected for
deploying PIT tag antenna arrays to detect movement into or
out of the site and will be deployed shortly after ice-off in
2013. Additionally, swim-over antennas are planned to be
deployed at five sites prior to ice-over, on an experimental
basis. As with the radio tagging plan, the target species that
will be tagged for this study need to be defined. The criteria to
be used for site selection of antenna arrays are also unclear.
Will the experimental winter antennas be deployed at the
same sites that arrays were set up during the summer?
Information on large and fme scale movements of fish will be
dependent on site selection for antenna arrays and tagging
sites. This is a very large area to cover with ten or fewer
observation sites, especially considering that it will only
register movements into and out of sufficiently small tributaries
and sloughs.” –pdf page 114
See AEA’s response to comment FDAML- 6.
FDAML-78 NMFS 11/14/2012 “The fish collection methods do not appear to be related to the
project objective, but are merely a list of sampling techniques.
The objective states that biotelemetry and tracking of PIT
tagged fish will be used to document migration patterns of
resident fish. The specific methods should clearly identify how
target species are to be captured for tagging or for the
recapture of tagged fish (although this is not discussed). For
example, trot lines result if fish mortality; therefore, this does
not seem to be an appropriate method to be used to collect
fish for tagging and tracking. Similarly; how will sonar or
snorkeling be used to track radio or PIT tagged fish?” –pdf
page 114-115
Because of the wide diversity of habitat types, species, and life stages
under investigation, a variety of methods must be deployed (Section
9.6.4). Detailed information on sampling locations and methods will be
provided in the Fish Distribution and Abundance Implementation Plan,
which will be filed with FERC no later than March 15, 2013 (Section 9.6.4).
Methods by objective are given in Section 9.6.4.3. Methods will be site-
specific and species specific. For radio tagging efforts, capture of target
fish species will occur opportunistically with regular distribution and
abundance sampling and as directed efforts if necessary and as using a
variety of gear types along a temporal and longitudinal gradient
(9.6.4.4.12). Preference will be given fish caught with more benign
techniques that cause minimal harm/stress to fish. AEA agrees that trot
lines are generally lethal and therefore not an effective capture method for
tagging studies and this is clearly stated in Section 9.6.4.4.4. Alternate
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methods will be pursued, for example using hoop traps for burbot following
protocols outlined by ADF&G (e.g., Evenson 1993). See Section 9.6.4.4.8.
FDAML-79 NMFS 11/14/2012 “The following information, and appended information, on life
history and site-specific studies is provided to clarify the need
for developing study sampling plans that account for
differences among resident fish within the proposed study
area.” –pdf page 115
Thank you for the comment and additional information. AEA will consider
this information when implementing the study plan.
The initial task of this study will consist of a focused literature review to
guide selection of appropriate methods by species and habitat type,
sampling event timing, and sampling event frequency. Anticipated
products from the literature review include the following:
• A synthesis of existing information on life history, spatial and
temporal distribution, and relative abundance by species and life
stage.
• A review of sampling strategies, methods, and procedures used
in the 1980s fish studies.
• Preparation of periodicity charts for each species within the
study area (timing of adult migration, holding, and spawning;
timing of incubation, rearing, and out-migration).
• A summary of mainstem Susitna River habitat utilization for each
species, by riverine habitat type (main channel, side channel,
side slough, upland slough, tributary mouth, tributary).
• A summary of existing age,size, and genetics information.
• A summary of distribution of invasive species, such as northern
pike.
See Section 9.6.4.3.
FDAML-80 NMFS 11/14/2012 The stated study objective to “Document the timing of
downstream movement and catch for all fish species using
out-migrant traps” is too broad; the objective should be
expanded and state a purpose to ensure that appropriate
methods and sites are selected. The study should also
discuss how the data collected will be used. –pdf page 121
See AEA’s response to comment FDAML-34.
FDAML-81 NMFS 11/14/2012 Under the PSP objective “Characterize the age structure,
growth, and condition of juvenile anadromous and resident
fish by season” no information is provided on why metrics are
being collected and how they will be used in Project
evaluation. AEA should indent specific study objectives and
information needs in collaboration with the Services. Then
The study objective in the RSP has been modified to Document the
Seasonal Age Class Structure, Growth, and Condition of Juvenile
Anadromous and Resident Fish by Habitat Type (Section 9.6.4.3.5). These
baseline data will be used to support the Fish Stranding and Trapping
Study. Detailed information on sampling locations and methods will be
provided in the Fish Distribution and Abundance in the Middle and Lower
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appropriate sampling location and methods and analytical
methods should be developed. –pdf page 121
Susitna River Implementation Plan, which will be submitted to FERC on
March 15, 2013 (Section 9.6.4).
FDAML-82 NMFS 11/14/2012 “This AEA objective is directed toward any invasive species
but refers to northern pike; therefore, it is unclear whether
other invasive species are anticipated or should be considered
in the evaluation of this objective. If the intent is to document
the seasonal distribution, relative abundance, and habitat
associations of other invasive species, if present in samples,
then detailed procedures should be provided on how this
would be accomplished. The AEA PSP does not provide a
purpose for this objective or how the proposed project may
influence the distribution or relative abundance of northern
pike (or other invasive species). The PSP states only that
northern pike have been observed in the lower river, but does
not provide a synopsis of known distribution, relative
abundance where present, or known habitat associations. The
study plan should review the current information on northern
pike and habitat associations and identify how the proposed
project may affect current distribution, relative abundance, and
available habitats. The proposed study plan should outline the
limitations of our current understanding of northern pike
distribution within the Susitna River drainage and how the
proposed study will build upon this information.” –pdf page
122
See AEA responses to FDAML-36 to FDAML 39.
The purpose is to document the seasonal distribution, relative abundance,
and habitat associations of all invasive fish species encountered. Northern
pike is identified because it is presently the only known invasive fish
species in the Middle/Lower River, is a known predator of juvenile salmon,
and will be the focus of this objective. The presence/absence and habitat
associations of northern pike and other invasive fish species will be
documented in all fish capture and observation sampling events
associated with Objectives 1 and 2. Additional directed efforts with angling
will be used to capture northern pike. Radio-tagging of up to 30 northern
pike will provide additional information on distribution and movements.
See Section 9.6.4.3.6
In addition the initial task for this RSP is the compilation of all relevant life
history information for all target species. This will include information
available on northern pike in the Lower Sustina River.
FDAML-83 NMFS 11/14/2012 “The AEA PSP provides no description of the sampling
locations, timing, frequency, or methods (passive or active)
that will be used to document northern pike (or other invasive
species) distribution, relative abundance, or habitat
associations. A review of methods employed previously by the
ADFG should be provided and a description of how and where
these methods would be used by AEA to accomplish the
stated objective.” –pdf page 122
See AEA responses to FDAML-36 to FDAML 39.
The initial task of this study will consist of a focused literature review to
guide selection of appropriate methods by species and habitat type,
sampling event timing, and sampling event frequency. This includes a
synthesis of existing information on life history, spatial and temporal
distribution, and relative abundance by species and life stage and a review
of sampling strategies, methods, and procedures used in the 1980s fish
studies See Section 9.6.4.3
In addition to the suite of fish sampling methods designed to capture a
multitude of species at more than 250 sites over 158 river miles in the
Lower, Middle and Upper Susitna River, there will be directed efforts to
capture pike with angling. Radio-tagging of up to 30 northern pike will
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provide additional information on distribution and movements. See
Section 9.6.4.3.6.
Further detail will be provided in the Fish Distribution and Abundance
Implementation Plan, which will be filed with FERC no later than March 15,
2013 (Section 9.6.4).
FDAML-84 NMFS 11/14/2012 “The AEA PSP does not provide any information on data
analyses or how information on northern pike would be
incorporated into the evaluation of project related effects.
Based upon the current PSP it appears that evaluation of
northern pike distribution, relative abundance, and habitat
associations will consist of reporting when and where there
are incidental catches of northern pike through other sampling
efforts. Because northern pike are significant, NMFS wishes to
discuss below why studies should be more robust.” –pdf page
122
See AEA responses to FDAML-36 to FDAML 39.
AEA expects that the level of effort proposed is rigorous and will provide
the baseline data that is necessary for effects analysis. Evaluation of
project related effects will occur as a part of the environmental analysis
supporting AEA’s FERC License Application.
In addition to radio and PIT tagging, a suite of fish sampling methods are
proposed to capture a multitude of species at more than 250 sites over
158 river miles in the Lower, Middle and Upper Susitna River, including
directed efforts to capture pike with angling. See Section 9.6.4.3.6.
FDAML-85 NMFS 11/14/2012 Understanding northern pike distribution is important for the
interpretation of biotic effects to the distribution and
abundance of juvenile salmon and other resident species.
This may be particularly important in lower sloped tributaries
where pike may be present, and moderate sloped tributaries
that may become more important as pike become more
abundant. Displacement of juvenile salmon from overwintering
habitat could make them more susceptible to predation. –pdf
page 123
See AEA’s response to comment FDAML -38.
FDAML-86 NMFS 11/14/2012 “The AEA study plan correctly identifies the distribution,
relative abundance, and habitat associations of northern pike
(and other invasive species) as an important study objective.
However, methods that describe how this objective is to be
accomplished are missing from the PSP. The AEA PSP
should clearly define how the seasonal abundance,
distribution, and habitat associations of northern pike (and
other invasive species) will be determined and how these data
See AEA’s response to comment FDAML- 85
The presence/absence and habitat associations of northern pike and other
invasive fish species will be documented in all fish capture and
observation sampling events associated with Objectives 1 and 2.
Additional directed efforts with angling will be used to capture northern
pike. Radio-tagging of up to 30 northern pike will provide additional
information on distribution and movements. (see Section 9.6.4.3.6)
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will be used to evaluate the effects of northern pike on the
abundance of other resident and anadromous fish. In addition,
the proposed study plan should outline potential effects of
project operation on the distribution of northern pike. AEA
should work closely or contract with the ADFG biologists who
have been studying pike within the Susitna drainage to
develop a study plan that clearly defines specific sampling
methods, including sampling locations, collection and tagging
of pike, tracking of tagged fish, and analytical methods
appropriate to the stated objective. The analytical methods
should calculate the probability of pike presence or absence
given the sampling effort.” –pdf page 123
FDAML-87 NMFS 11/14/2012 “The current PSPs should be expanded to add a sampling
plan to evaluate water quality and physical habitat
characteristics within spawning redds or factors that could
influence egg development and fry emergence. The PSPs
need to be refined to include methods to measure intragravel
water temperatures in redds, measure cumulative thermal
units, and determine the relationship between surface water
temperature, flow and intragravel temperatures. NMFS
developed two study objectives to characterize spawning
habitat conditions, and we request that FERC order
completion of these important studies.” –pdf page 123
The NMFS Study objectives (1) to evaluate embryo
development, hatching success and emergence times at
areas with and without groundwater upwelling and (2)
measure intergravel temperature at different surface
elevations and depths in spawning and overwinter habitats to
determine potential for freezing.
Potential effects of Project operation on salmon egg incubation and fry
emergence will be evaluated as part of 'Effective Spawning-Incubation
Habitat Analyses' (see Section 8.5.4.6.1.5). Project effects on salmon
rearing, including winter rearing, will be addressed as part of habitat-
specific modeling (see Section 8.5.4.6) and 'Winter Habitat Use Sampling'
(see Section 8.5.4.5.1.2.1).
AEA disagrees with the need to collect information on hatching success.
Recent data indicate most of the variability in hatching success is
confounded by parentage, and therefore it would not be realistic to expect
to tease out lesser affects on variability that might be associated with
Project-induced flow or temperature changes. Consistent with their overall
approach AEA is taking a habitat-based approach to the evaluation of
incubation habitat quality.
Emergence timing is to be addressed by this study. Section 9.6.4.3.3
describes a baseline study objective focused on the early life history of
juvenile salmon that includes tasks focused on emergence time and fry
movement. This specific study will be conducted over 2013 and 2014.
Several studies are being proposed to assess potential project effects of
on upwelling and groundwater dynamics related to egg incubation and
emergence survival including effective spawning/incubation analysis (see
Section 8.5.4.6.1.5), varial zone modeling (see Section 8.5.4.6.1.6), winter
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habitat use (see Section 8.5.4.5.1.2.1), and Groundwater Study (see
Section 7.5). Specific details on study area, data needs, model
parameters, and assumptions are presented for each of the proposed
studies.
FDAML-88 NMFS 11/14/2012 “Information on the variability in hatching success among
spawning locations and differences in water quality conditions
between locations used for spawning and those that have
similar characteristics but are not used for spawning will help
determine those site-specific characteristics of spawning and
incubation. This information will be used by NMFS for
determining the project effects on these parameters and
developing protection, mitigation, and enhancements for any
project license proposal. Collection of this necessary
information should be accomplished by comparing water
physical and chemical characteristics within the four major
spawning habitat types and at locations with and without
upwelling in each of these locations. Hatching success and
emergence times could be determined from the number of
adult females, fecundity, and fry population estimates.” –pdf
page 124
Water quality information on spawning grounds is being collected as part
of the Intergravel Monitoring component of the Instream Flow Study. See
Section 8.5.4.5.1.2.1.
AEA disagrees with the need to collect information on hatching
success. Recent data indicate most of the variability in hatching success
is confounded by parentage, and therefore it would not be realistic to
expect to tease out lesser affects on variability that might be associated
with Project-induced flow or temperature changes. Consistent with their
overall approach AEA is taking a habitat-based approach to the evaluation
of incubation habitat quality.
For the 2012-2013 pilot study component focused on intergravel
temperature, dissolved oxygen and water surface levels, monitoring sites
will be selected using a stratified random sampling approach (See Section
8.5.4.5.1.2.1). The Whiskers Slough and Slough 8A study areas will be
stratified by habitat type (main channel, side channel, tributary mouth, side
slough, and tributary), with special emphasis given to areas at which
salmon spawning was observed in 2012. A total of 10-12 monitoring sites
will be randomly selected among strata. Depending on individual site
characteristics, temperature monitoring devices will be installed at
locations of 1) groundwater upwelling, 2) bank seepage and lateral flow
from mainstem, 3) mixing between upwelling and bank seepage, 4) no
apparent intergravel discharge, 5) fish spawning, and 6) main channel
Susitna River flow.
In addition, data on emergence timing will be collected as described in
Section 9.6.4.3.3.
FDAML-89 NMFS 11/14/2012 “Water temperature should be measured at a minimum of 10
spawning locations and 10 winter rearing locations that, due to
channel form, vary in water depth throughout the winter, in
To help elucidate what physical and chemical variables may be influencing
fish-habitat use and fish movements at specific sites or for specific
species, additional information will be collected at sites identified as Focus
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order to determine the influence of water depth on bed and
intragravel temperatures. Temperatures should be measured
10 cm above the substrate, at the stream bed, and at
approximately 10 cm, 20 cm and 30 cm below the stream bed.
Data analyses should be conducted to determine a
relationship between air temperature and water depth, and
temperatures within the substrate used for egg incubation and
overwintering fish. These results would be used to determine
the water depths necessary to maintain optimal temperatures
within the stream bed. This information is needed for NMFS to
determine the characteristics of critical overwintering
incubation and rearing habitat that needs to be protected from
adverse effects of project operations through development of
protective measures such as ecological flows, ramping rates,
allowable flow fluctuations and other mitigation measures.” –
pdf page 124
Areas (Section 8.5.4.2.1.2), HSC/HSI sampling sites (Section
8.5.4.5.1.1.4), and during Winter Sampling (Section 9.6.4.5) by multiple
resources such as instream flow, water quality, riparian, groundwater, ice,
and geomorphology.
A 2012-2013 winter pilot study will monitor intergravel temperature at 10-
12 monitoring sites at two Focus Area locations. The Whiskers Slough and
Slough 8A study areas will be stratified by habitat type (main channel, side
channel, tributary mouth, side slough, and tributary), with special emphasis
given to areas at which salmon spawning was observed in 2012. Based on
this pilot study, recommendations will be developed for 2013-14 winter
sampling. For intergravel temperature measurement, Hobo Tidbit
temperature probes will be deployed at three separate gravel depths (5
cm, 20 cm, and 35 cm) corresponding to observed burial depth ranges of
chum and sockeye eggs (Bigler and Levesque 1985, DeVries 1997). For
more details specific to intergravel temperature monitoring at spawning
locations see the proposed methods for the winter pilot study in Section
8.5.4.5.1.2.1 and 9.6.4.5.
FDAML-90 NMFS 11/14/2012 “HSC is mentioned in Study 6.5, Instream Flow and Aquatic
Habitats but the study request objective needs to be
addressed also in the PSP relative to Upper, Middle, or Lower
reaches for juvenile anadromous, resident fish, and non-
salmonid anadromous fish studies. It needs to be clearly
describe how HSC information will be collected, particularly in
winter for post-emergent fish up to 60 mm when fish will be
most vulnerable to load-following operations. There needs to
be empirical baseline information collected to evaluate
potential project effects and for inclusion in habitat modeling
efforts. There is generic reference to developing HSC models
in Study 6.5 Instream Flow and Aquatic Habitat, for these
species and life stages, but the source of that information
needs to be identified.” –pdf page 125
While this study may be used to validate HSC associations, HSC
development is under the purview of the Instream Flow Study, a detailed
description of data collection is provided in Section 8.5.4.5.1.1. For 2013–
2014 studies, site-specific habitat suitability information will be collected for
target species using HSC-focused field surveys to locate and measure
microhabitat use by spawning and rearing (adult and juvenile) life stages.
Proposed sampling methods include biotelemetry, pedestrian, snorkel, and
seining. Two other possible methods, DIDSON sonar and electrofishing,
are being explored for use in detecting habitat use in turbid water
conditions. Selected methods will vary based on habitat characteristics,
season, and species/life history of interest. Selected methods are subject
to ADF&G Fishery Resource Collection Permit requirements. Additionally,
winter surveys will utilize underwater video during clear water periods to
identify under-ice and open-water habitat use by rearing life stages.
Depending on safety concerns, it has been proposed to conduct both
daytime and nighttime surveys during winter sampling to determine any
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differences in habitat use. See Section 8.5.4.5.1.1.6 for a description of
data collection methods for each HSC sampling technique for juvenile
fishes.
The 2012-13 Winter Pilot Study methodology for HSC is detailed in
Section 8.5.4.5.1.2.1 and 9.6.4.5 and includes the use of underwater video
cameras and DIDSON sonar obtain measurements of site-specific habitat
utilization data for juvenile and adult fish species in support of habitat
suitability criteria development.
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ESCAPE-01 CSDA 11/14/2012 “Fish Passage Study: This is a necessary study in order for NMFS
to determine the need and feasibility of fishway prescriptions which
they have to do under federal law. This study should span at least
5 years and preferably 7 years. It is directly tied into the
investigation into the salmon species that are migrating above
Devil’s Canyon.”
See AEA’s response to comment FISH-02.
ESCAPE-02 Various
Individuals
11/07/2012-
11/14/2012
Two year study is inadequate for Chinook salmon, recommends 5-
7 years.
See AEA’s response to comment FISH-02.
Chinook salmon will be studied in the Lower, Middle, and Upper
Susitna River for three years (2012-14). The substantial study
effort across three years along with extensive work by ADF&G
since 2007, including about 5,400 radio-tagged Chinook salmon
in the Lower and Middle River, and multiple other approaches
(visual aerial and ground surveys, acoustics, etc.) will be
sufficient to characterize the spawning distribution of Chinook
salmon to adequately characterize potential Project impacts.
Given the range of ages at maturity, these three years will
represent fish from parts of all Chinook salmon brood years on
the Susitna River.
ESCAPE-03 TNC 11/14/2012 “Study Period and Horizon: The licensing process must allow
sufficient time for field studies to document how salmon use the
entire Susitna River, from Cook Inlet to above the proposed
reservoir. This timeline should be driven by natural cycles, such as
salmon lifecycles, and not hurried for human convenience. AEA‟s
proposal to study salmon for only three years is inadequate.
Susitna River salmon, including sockeye, coho, and Chinook, are
experiencing declines in returns and this project has the potential
to add to the negative conditions for salmon. A minimum of five
years of data is required to understand fish distribution and
utilization by life stage.”
See AEA’s response to comment ESCAPE-02. Note that with
multiple ages at maturity, these study years will sample at least
parts of all brood years that return to the Susitna River.
The extent of adult Salmon Escapement Study components in
the study plan is not limited to three years across all areas and
species. The studies will be based on multiple research projects
at multiple study sites across the last five years (Yanusz et al
2007; Merizon et al. 2010; Yanusz et al. 2011; Cleary et al.
(multiple documents in prep.; AEA in prep):
• Chinook salmon tagging in Lower River, 2012-2014;
• Chinook salmon tagging in Middle River, 2012-2014;
• Coho salmon tagging in Lower River, 2009-2014;
• Coho salmon tagging in Middle River: 2012-2014;
• Chum salmon tagging in Lower River, 2009-2012;
• Chum salmon tagging in the Middle River, 2012-2014;
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• Sockeye salmon tagging in the Lower River, 2006-08;
• Sockeye salmon tagging in the Middle River, 2012-
2014;
• Pink salmon tagging in the Lower River, 2012-2014;
• Pink salmon tagging in the Middle River, 2012-2014.
ESCAPE-04 NMFS 11/14/2012 “Objective 8…This study objective should be expanded to all five
species. NMFS does not agree that escapement, or other studies,
should be limited to Chinook and coho when the project is likely to
adversely affect all five species of Pacific salmon.”
See AEA’s response to comment ESCAPE-03.
As described in Section 9.7.4.8, coho and Chinook salmon will
be more intensively studied in 2013-14 in order to develop
system- or Susitna-River-wide escapement estimates. Susitna
River chum (2009-2012) and sockeye salmon (2006-2008) have
been the focus of escapement estimation studies by ADF&G in
recent years. Distribution and habitat use by pink salmon
(apportionment by habitat type, but not absolute escapement
estimates) will be studied in the Lower and Middle River in 2012-
2014. Pink salmon abundance in the Susitna River alternates
annually between even-year peak and odd-year off peak returns;
as well it is highly variable across years of each brood line.
Absolute system-wide escapement estimates from pink salmon
over 3 or 5 years will not materially alter an assessment of the
Project impacts. Collectively, all species will have received
multiple years of research effort in the Lower, Middle, and Upper
River during the period 2007-2014; results across all species will
be based on over 12,000 radio-tagged salmon.
ESCAPE-05 NMFS 11/14/2012 “It is unclear why coho and Chinook salmon will be tagged more
intensively than other species...’
See AEA’s response to comment ESCAPE-03 and ESCAPE-04.
ESCAPE-06 USFWS 11/14/2012 “It is unclear why coho and Chinook salmon will be tagged more
intensively than other species.
See AEA’s response to comment ESCAPE-03 and ESCAPE-04.
ESCAPE-07 NMFS 11/14/2012 “Additionally, it is unclear why only Chinook and coho are to be
tagged in the lower Susitna River, whereas all five species are
tagged at Curry Station (RM 103). There needs to be a justification
for unequal sampling and tagging effort among species.”
See AEA’s response to comment ESCAPE-03 and ESCAPE-04.
ESCAPE-08 USFWS 11/14/2012 “Additionally, it is unclear why only Chinook and coho salmon will
be tagged in the lower Susitna River, whereas all five salmon
See AEA’s response to comment ESCAPE-03 and ESCAPE-04.
In addition, AEA has added pink salmon tagging in the Lower
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species will be tagged at Curry Station (RM 103). There should to
be justification for what appears to be unequal sampling and
tagging efforts among species.’
River (see Section 9.7.12, Objective 1).
ESCAPE-09 NMFS 11/14/2012 ‘It is mentioned that additional marking of sockeye and chum with
spaghetti tags could be useful for this study. If these fish will be
tagged to determine if fishwheel captures are random, then this
needs to be described in a revised study plan. The number of
tagged fish necessary to address these concerns needs to be
identified to provide a clear objective.’
AEA proposes to capture and tag the greatest number of
sockeye and chum salmon at Curry as permitted. Recoveries of
these additional tagged fish will be analyzed together with radio-
tagged fish recoveries, and if sufficient numbers are tagged, will
be analyzed separately, to test the study’s assumptions. A priori
spaghetti-tagging goals are not meaningful as all fish that can be
captured and tagged in excess of the radio-tagging goals
(without severely limiting radio tagging effort) will maximize the
power of such tests. The additional statistical power from
spaghetti tagging will be strongly a function of the numbers of
recoveries. Additional text has been added to Section 9.7.4.1.3
to further elaborate on the approach and provide more definitive
commitment to the spaghetti-tagging effort.
ESCAPE-10 USFWS 11/14/2012 It is mentioned that additional marking of sockeye and chum with
spaghetti tags could be useful for this study. If these fish will be
tagged to determine if fish wheel captures are random, then this
needs to be described in a revised study plan. The number of
tagged fish necessary to address these concerns needs to be
identified to provide a clear objective.”
See AEA’s response to comment ESCAPE-09.
ESCAPE-11 USFWS 11/14/2012 “The methods proposed here will miss fish migrating to spawning
sites within the Middle River that are downstream of the Curry
Station (RM 103) sampling site. Whiskers Creek (RM 101.4) is a
major spawning location for coho salmon, with some spawning by
Chinook and chum salmon as well (Barrett et al. 1985), but this
tributary will be missed or minimized due to the location of the
tagging site 20 miles upstream. Thompson et al. (1986) found that
only a portion of fish that spawned downstream of Curry reached
this station during milling, and this proportion was directly related to
the distance from Curry Station. The further downstream of Curry
that spawning areas were located, the fewer fish from these lower
river spawning areas were captured by the fish wheels at Curry.
Chinook salmon spawn in three tributaries in the Middle River
As found in the 1980s and in 2012, Curry provides an excellent
location to capture and tag large numbers of salmon for
intensively studying adult salmon in the mid and upper Middle
River. While some of these Curry fish redistribute themselves to
the lower Middle River (1980s and 2012), this will aid in the
identification of spawning sites in that area.
In addition, AEA will address adult salmon use of the lower
Middle River areas with a multi-faceted approach. First, several
years of chum, sockeye, and coho salmon radio tagging in the
lower Susitna have been conducted recently by ADF&G (see
AEA’s response to comment ESCAPE-03). Second, Chinook,
coho, and pink salmon will be radio-tagged in the Lower River at
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downstream of Curry Station (RM 103); coho salmon spawn in
seven downstream tributaries; pink salmon spawn in seven
downstream sloughs and 12 downstream tributaries; chum salmon
spawn in five tributaries and 8 sloughs downstream; and sockeye
salmon spawn in 7 sloughs downstream of Curry Station (Barrett et
al. 1985). For Chinook, chum, and sockeye salmon, these sloughs
and tributaries did not make up a substantial portion of their total
escapement to the Middle River, but roughly 78% of the Middle
River coho and 28.3% of pink salmon escapements to tributaries
were downstream of Curry Station.”
~RM 30 in 2013 and 2014. Radio-tagging in the Lower River will
provide information about the use of the lower Middle River area
by adult salmon. Third and more importantly, fish distribution and
abundance surveys will address Focus Areas (Section 9.6.4.1)
in the lower Middle River and establish presence of adult salmon
during the spawning periods and characterize habitat features
and suitability criteria. Between radio-tagged fish from the Lower
River and fish distribution surveys in this area, AEA will not miss
fish spawning below Curry.
ESCAPE-12 NMFS 11/14/2012 “The proposed methods will miss fish migrating to spawning sites
within the middle river that are downstream of Curry. Whiskers
Creek (RM 101.4) is a major spawning location for coho salmon,
with some spawning by Chinook salmon as well (Barrett et al.
1985), but this tributary will be missed or minimized due to the
location of the tagging site 20 miles upstream. Thompson et al.
(1986) found that only a portion of fish that spawned downstream
of Curry reached this station during milling, and this proportion was
directly related to the distance from Curry Station. …. Chinook
salmon spawn in three tributaries in the middle river downstream of
Curry Station (RM 120); coho salmon spawn in seven downstream
tributaries; pink salmon spawn in seven downstream sloughs and
12 downstream tributaries; chum salmon spawn in five tributaries
and 8 sloughs downstream; and sockeye salmon spawn in 7
sloughs downstream of Curry Station (Barrett et al. 1985). For
Chinook, chum, and sockeye salmon, these sloughs and tributaries
did not make up a substantial portion of their total escapement to
the middle river, but roughly 78% of the middle river coho and
28.3% of pink salmon escapements to tributaries were downstream
of Curry Station.”
See AEA’s response to comment ESCAPE-11.
ESCAPE-13 USFWS 11/14/2012 “The purpose of the Salmon Escapement Study, as proposed by
AEA, is to assess the current run timing and distribution of each of
the five species of salmon among different habitat types in the
lower and middle Susitna River, with emphasis on the middle
reach. As previous studies have been unsuccessful in consistently
measuring spawning in the mainstem channel, this objective
AEA agrees and these study objectives are addressed by
several studies in the RSP. The Instream Flow Study (Section
8.5) will develop habitat suitability criteria (Section 8.5.4.5),
entailing measurements of physical habitat and water quality at
spawning sites in mainstem habitat (Section 8.5.4.5.1.1.5). The
study will also develop models to evaluate connectivity with off-
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should be considered a priority for this study plan. Additionally,
habitat characteristics such as water chemistry and physical habitat
measurements will be important for determining factors influencing
current salmon spawning distribution patterns. This information will
be necessary for evaluating the potential for post-Project effects on
distribution patterns, availability of spawning habitat, and access to
spawning sites.”
channel habitats (Section 8.5.4.6.1.7). The potential for Project
effects on fish passage barriers will be further assessed by
Study of Fish Passage Barriers in the Middle and Upper Susitna
River and Susitna Tributaries (see Section 9.12.1).
ESCAPE-14 NMFS 11/14/2012 “The purpose of the Salmon Escapement Study is to assess the
current rum timing and distribution of each of the five species of
salmon among different habitat types in the lower and middle
Susitna River, with emphasis on the middle reach. As previous
studies have been unsuccessful in consistently measuring
spawning in the mainstem, this objective should be considered a
priority for these studies. Additionally, it is important habitat
characteristics, including water chemistry and physical measures,
will be important for determining factors influencing current
distribution patterns. This information will be necessary for
evaluating the potential for post-project effects on distribution
patterns, availability of spawning habitat, and access to spawning
sites.”
See AEA’s response to comment ESCAPE-13.
ESCAPE-14 USFWS 11/14/2012 “Determine the availability and accessibility of spawning habitats by
adult salmon to mainstem and tributary locations based upon flow
regime. It is unclear if this specific objective is being addressed
anywhere in the PSP. It will be important to identify potential
barriers to spawning habitats at current flow regimes and how
access might change with a modified flow regime. Successful
migration into tributaries can be strongly related to water levels at
the mouths of the tributaries, with high rates of stranding mortalities
in years of low water (Carlson and Quinn 2007). As the proposed
flow regime is for increased base flows and increased fluctuating
flows during winter months and reduced flows during summer
months, when adult salmon are migrating and spawning, stranding
mortality could become an important factor in spawning success.
This concern needs to be addressed in the study plan. Flows
necessary for salmon access into tributaries, sloughs, and side
channels needs to be determined for each of the five species.”
Barriers at current conditions and post-Project are addressed in
the Study of Fish Passage Barriers in the Middle and Upper
Susitna River and Susitna Tributaries (see Section 9.12.1).
Access into off-channel habitats at various flows will be
addressed in the Instream Flow Study (see Section 8.5.4.6.7).
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ESCAPE-15 NMFS 11/14/2012 “It is unclear if this specific eighth objective of NMFS Adult Salmon
Distribution, Abundance, Habitat Utilization and Escapement in the
Susitna River study request is being addressed anywhere in the
PSP. It will be important to identify potential barriers to spawning
habitats at current flow regimes and how access might change with
a modified flow regime. Successful migration into tributaries can be
strongly related to water levels at the mouths of the tributaries, with
high rates of stranding mortalities in years of low water (Carlson
and Quinn 2007). As the proposed flow regime is for increased
flows during winter months and reduced flows during summer
months, when adult salmon are migrating and spawning, stranding
mortality could become a significant factor in spawning success.
This concern needs to be addressed in the proposed studies.
Flows necessary for salmon access into tributaries, sloughs, and
side channels need to be determined for each of the five species.”
See AEA’s response to comment ESCAPE-14.
ESCAPE-16 USFWS 11/14/2012 “To determine run apportionment, all macrohabitat types used for
spawning (mainstem, tributaries, and sloughs) will also need to be
included, not just select tributary counts.”
AEA agrees. The objectives of this study include identification of
the spawning locations of radio-tagged salmon (see Section
9.7.4.2, Objective 2) and the methods include identification of
these locations at sufficient spatial resolution to assign a
macrohabitat type to the fate of tagged fish (mainstem, tributary,
slough, and side channel)
ESCAPE-17 NMFS 11/14/2012 “To determine run apportionment, all macrohabitat types used for
spawning (mainstem, tributaries, and sloughs) will also need to be
included, not just select tributary counts.”
See AEA’s response to comment ESCAPE-16.
ESCAPE-18 USFWS 11/14/2012 Related USFWS/NMFS study objective not addressed: I Measure
critical habitat characteristics (e.g., channel type, flow, substrate,
and groundwater) at reaches used for spawning and compare
these characteristics with those in adjacent reaches that do not
contain spawning adults. This study request objective is not
addressed in the PSP nor is any objective that looks at
characterizing use, availability, or quality of potential spawning
habitats. There appears to be no empirical baseline information
being collected; only semi-quantitative surveys to determine
distribution and potential abundance of redds. Also, there is a
reference to studies evaluating potential dewatering or scouring of
The USFWS/NMFS study objective is being addressed in
several studies. The Instream Flow Study (Section 8.5) will
assess the potential for redd effects from load-following
operations (Section 8.5.4.6.1.5); the availability and quality of
spawning habitat (Section 8.5.4.5); and the characteristics of
spawning sites (Section 8.5.4.1.1.5). Habitat will be
characterized at various levels, including at spawning sites as
described in Section 8.5.4.5 and at random sites as described in
Section 9.9.5.4.. Based upon data collected in these studies,
AEA anticipates that it will conduct this type of comparison as
part of its environmental analysis supporting its FERC License
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redds in Section 6, but no empirical baseline information to assess
the potential for daily load-following operations to cause redd
dewatering or freezing. At recent TWG meetings, a habitat quality
component was added in Section 6, but it is still unclear if or how
areas without spawning will be characterized.”
Application.
ESCAPE-19 NMFS 11/14/2012 “This study request objective is not addressed nor is there any
objective that looks at characterizing use, availability, or quality of
potential spawning habitats. There appears to be no empirical
baseline information being collected; ….. This information is
needed by NMFS to determine the immediate effect of proposed
project load-following operations on incubating salmon in the
Susitna River that we will use to develop recommendations of
license requirements that would protect salmon.”
See AEA’s response to comment ESCAPE-18.
ESCAPE-20 USFWS 11/14/2012 “Objective 8… The methods described do not address this
objective. There is no clear description of how many weirs will be
operated for this study, or how locations for these weirs will be
chosen. Looking at mark-recaptures in a few tributaries does not
address distribution throughout the Susitna River and its tributaries.
Observations, through weirs, foot surveys, or fish sampling
methods should be conducted at more tributaries than this study
describes. Additionally, no weirs are located within the Middle
River. As this section of the river has the greater potential for
impact by a hydroelectric project than the Lower River, it is
important to know the distribution and escapement of salmon into
these Middle River tributaries. The Service recommends that AEA
expand this objective to include all five species of salmon.”
AEA has revised the study plan to clarify how the methods will
address Objective 8. Radio tags establish the distribution and
weirs and spawning ground surveys establish the mark rate on
the fish, which is used to convert distribution into relative and/or
absolute abundance, depending on the precision and variability
of mark rate estimates from the different recapture sites (see
Sections 9.7.4.1.3, 9.7.4.6, and 9.7.4.8). ADF&G has
considerable weir experience in the Susitna (and elsewhere) and
combined that experience with historical aerial survey data to
develop the four proposed weir sites. These four weir sites will
likely provide ample numbers of fish to examine for developing
system-wide mark-recapture estimates and allow for testing of
key assumptions. The distribution and relative escapement of
salmon in the Susitna River and Middle River Segment
tributaries will be established using the 1,400 radio tags on
Chinook and 600 tags on coho salmon that will be deployed in
the Lower River Segment in each of 2013 and 2014.
ESCAPE-21 NMFS 11/14/2012 Objective 8: “The methods described do not address this objective.
There is no clear description of how many weirs will be operated
for this study, or how locations for these weirs will be chosen.
Looking at mark-recaptures in a few tributaries does not address
distribution throughout the Susitna River and its tributaries.
See AEA’s response to comment ESCAPE-20.
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Observations, through weirs, foot surveys, or fish sampling
methods should be conducted at more tributaries than this study
describes. Additionally, no weirs are located within the middle river.
As this section of the river has the greater potential for impact by a
hydroelectric project than the lower river, it is important to know the
distribution and escapement of salmon into these middle river
tributaries.”
ESCAPE-22 USFWS 11/14/2012 “It is unclear how the aerial counts conducted for this study will be
used to obtain escapement numbers. The Service recommends
that ground surveys or fish sampling methods be conducted to
ground-truth these counts or to determine if sites were spawning or
holding sites. Accuracy and precision of aerial counts varies with
conditions, reducing counts in areas with high turbidity or depths or
overhanging riparian vegetation. Additionally, smaller individuals,
such as “jacks” are more difficult to see with aerial surveys, due to
their size and lighter coloration (Neilson and Geen 1981). AEA
does not provide sufficient justification regarding why this
methodology has been developed to count Chinook salmon and
not the other four species of Pacific salmon spawning throughout
the Susitna River drainage.”
Aerial counts will be used to establish minimum tributary-specific
mark rates in Portage Creek and Indian River, and combined
with ground surveys/sampling, will provide the likely ranges of
possible mark rates. The justification for this methodology is that
mark rates can be combined with the numbers of radio tags
present in these tributaries and in other locations to get the
approximate numbers of all fish by habitat or tributary.
Experience from 2012 confirmed that aerial surveys will not
provide a useful means of estimating mark rates on other
species (too few fish observable from the air). AEA has revised
Section 9.7.4.2.2 to more clearly establish the purpose (and
limits) of the aerial survey effort.
ESCAPE-23 NMFS 11/14/2012 “It is unclear how the aerial counts conducted for this study will be
used to obtain escapement numbers. Ground surveys or fish
sampling methods should be conducted to ground-truth these
counts or to determine if sites were spawning or holding sites, but
methods only describe aerial counts. Accuracy and precision of
aerial counts varies with conditions, reducing counts in areas with
high turbidity or depths or overhanging riparian vegetation.
Additionally, smaller individuals, such as ''jacks'' are more difficult
to see with aerial surveys, due to their size and lighter coloration
(Neilson and Geen 1981). There is no justification why this study
has been developed to count Chinook salmon and not the other
four species of Pacific salmon spawning throughout the Susitna
River drainage.”
See AEA’s response to comment ESCAPE-22.
ESCAPE-24 USFWS 11/14/2012 “The Service recommends that AEA provide additional detail in
describing methods for selecting fish for tagging and how the
Based on the 2012 study and anticipated catch rates at Curry,
nearly all captured Chinook, coho, and sockeye salmon will be
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tagging effort will be stratified throughout the migration/spawning
season. Since fish wheel captures may not be representative of
migrating populations (e.g., larger individuals may be less likely to
be captured), we recommend that tagging efforts be nonrandom in
order to selectively tag fish that are not equally represented.’
tagged. For chum and pink salmon, a fraction of fish will be
randomly selected from the daily catch for tagging.
Tag goals by date (daily and cumulative year-to-date) will be
established, as was done in 2012, using historical run timing
curves from 1981-85, and 2012. Once underway each season,
the tagging rate will be updated and will be a function of the
current catches compared to the historical run timing curves.
This approach could possibly result in tagging something like 1
out of 2, or 2 out of 3 Chinook salmon if much higher catches are
encountered in 2013 and 2014 compared to 2012. A similar
situation could occur for the other salmon species, as well.
A description of the methods for assessing size or stock-specific
selectivity has been added to Section 9.7.4.1.7. The standard
(and preferred) approach is to tag all the catch or randomly
select fish from the catch for tagging and then assess the degree
of selective capture and tagging post-season. This can provide
a complete picture of the ultimate selectivity, which also captures
any post-release differences in behavior as a function of fish size
or the stock of origin. There is no empirical estimate of the
degree of size selectivity to apply using the method proposed in
the comment, and if after years it were possible, the standard
approach is much preferred as it allows a direct calculation of
any such effect.
ESCAPE-25 NMFS 11/14/2012 “Methods should describe how fish will be selected for tagging and
how tagging effort will be stratified throughout the
migration/spawning season. Since fishwheel captures may not be
representative of migrating populations (e.g. larger individuals may
be less likely to be captured), tagging efforts should be non-
random in order to selectively tag fish that are not equally
represented.”
See AEA’s response to comment ESCAPE-24.
ESCAPE-26 NMFS 11/14/2012 “Capture methods for tagging, through fishwheels, may be non-
random and disproportionally capture fish of certain sizes or from
certain populations (Thompson et al. 1986). Disproportionate
sampling would, in turn, lead to incorrect assumptions about
See AEA’s response to comment ESCAPE-24. Also, if
disproportionate sampling can be quantified, stratification can
address the issue and not result in incorrect
assumptions/conclusions. The study plan sets out methods to
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project effects, and a poorly informed licensing order.” test assumptions about capture probabilities by stock and body
size.
ESCAPE-27 USFWS 11/14/2012 “Capture methods for tagging, through fish wheels, may be non-
random and disproportionally capture fish of certain sizes or from
certain populations (Thompson et al. 1986).”
See AEA’s responses to comments ESCAPE-24 and ESCAPE-
26.
ESCAPE-28 USFWS 11/14/2012 “The study plan must define how DIDSON results will be verified
for accuracy, and how this method be assessed for use in 2013
and 2014. If this method is determined ineffective, an alternative
method should be proposed for sampling the turbid mainstem for
spawning aggregations.”
A more complete description of how this will be assessed,
including alternative sampling methods, has been added to
Section 9.7.4.4.
ESCAPE-29 NMFS 11/14/2012 “It needs to be defined how DIDSON results will be verified for
accuracy, and how this method be assessed for use in 2013 and
2014. If this method is determined ineffective, an alternative
method should be proposed for sampling the turbid mainstem for
spawning aggregations.”
See AEA’s response to comment ESCAPE-28.
ESCAPE-30 FERC 11/14/2012 ”The study plan identifies, in general terms, how the study would
be implemented; however, it is lacking sufficient detail for
Commission approval. Therefore, please include in your RSP the
following additional information: a description of what is meant by a
commonly applied two-event, capture recapture experiment”
Additional detail has been added to Section 9.7.4.8 to provide
generic and Susitna-specific application of the two-event,
capture-recapture experiment.
A commonly applied two-event, capture-recapture experiment
will be used to estimate the annual abundance of Chinook
salmon in the entire Susitna River drainage and the coho salmon
abundance in the Susitna River above the Yentna River
confluence. Such methods to estimate salmon escapement are
ubiquitous in Alaska and along the West Coast of North
America. In the Susitna River, the capture event will be provided
by fishwheels operating throughout the seasonal salmon
migration. Radio tags will be applied to fish as close to
proportional of the migrating salmon as possible. Later in the
salmon migration, a series of recapture sites at tributaries and
mainstem locations will establish the proportion of each species’
that has a tag (also known as the species-specific and stock-
specific mark rate). Using relatively simple algebra and making
some testable assumptions, an estimate of the total species-
specific abundance that passed the tagging site can be
estimated, in this case, the abundance and in-river escapement
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at the fishwheels sites on the Susitna (Chinook and coho
salmon) and the Yentna (Chinook salmon) rivers. Length, sex,
and genetics information from the tagged and untagged fish will
be used to assess the validity of most assumptions. Behavior of
radio-tagged fish following tagging also provides information for
evaluating two critical assumptions – the number of tagged fish
that have “entered” the experiment, and whether their behavior
compromises the experiment.
ESCAPE-31 FERC 11/14/2012 ”The study plan identifies, in general terms, how the study would
be implemented; however, it is lacking sufficient detail for
Commission approval. Therefore, please include in your RSP the
following additional information: the number of each species of fish
that you will tag during each year of study implementation,
including the number that would be radio-tagged or tagged with
some other tag device, and a description of any other tag devices
that would be used (e.g, spaghetti tag).”
Section 9.7.4.1 (Objective 1) provides the goals for the numbers
of fish to be tagged by species, year, and location. Section
9.7.4.1.3 has been clarified to emphasize that fish captured in
addition to radio-tagging goals will be spaghetti tagged; the
exact numbers for which will depend on fishwheel catches
obtained (e.g., some species will be too small a catch to exceed
radio-tagging goal).
ESCAPE-32 FERC 11/14/2012 ”The study plan identifies, in general terms, how the study would
be implemented; however, it is lacking sufficient detail for
Commission approval. Therefore, please include in your RSP the
following additional information: a description of when you intend to
finalize the results of the 2012 genetics study and a schedule for
incorporating the 2012 study results into your study methods for
the system-wide adult salmon escapement study.”
AEA has removed the reference to a possible genetics-based
method to estimate escapement. Prior to the 2012 field season,
ADF&G requested and proposed that two options remain open
for estimating the system-wide escapement of Chinook salmon.
These options included two types of mark-recapture studies: one
study using radio tags as a mark (the preferred method) and one
study using genetic information as a mark. ADF&G proposed
two options because it was not known if sufficient numbers of
fish for a traditional radio-tagging study could be captured in the
Lower River. Based on the capture success experienced during
the 2012 radio telemetry study, AEA and ADF&G decided that
the system-wide escapement estimate be developed using the
radio tag approach.
ESCAPE-33 FERC 11/14/2012 “Your draft RSP provides some additional information on the
proposed study. Specifically, you propose to conduct a commonly
applied two-event, capture-recapture experiment for both Chinook
and coho salmon. You propose to include two capture sites, one
each on the [Yentna] River and the Susitna River, with two fish
wheels deployed at each capture site. You also propose to
See AEA’s response to comment ESCAPE-32. Tagging is the
preferred method and appears feasible based on the 2012 radio
telemetry studies. Some tissue samples were collected in 2012,
as well as in earlier years, from stocks in the Susitna drainage;
more intensive samples will be collected in 2013-14 as
described in the Genetic Baseline Study for Selected Fish
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recapture tagged fish in several tributaries and at various sites
along the mainstem Susitna River. Finally, you state that fish would
be tagged, but it may also be possible to use genetics to identify
the spawning destination of fish captured at the fish wheels, and
that studies being conducted in the summer of 2012 will determine
the feasibility of using genetics to serve as an identifiable mark,
thus eliminating the need to address tag loss and tagging effects
associated with traditional capture-recapture models.”
Species (Section 9.14).
ESCAPE-34 USFWS 11/14/2012 “There is no description of methods to test for effects of radio
tagging on fish survival and behavior. Radio tags can potentially
have lethal effects or non-lethal behavioral effects on tagged fish,
which could lead to changes in speed or direction of movements
(e.g., Yanusz et al. 2011, Keefer et al. 2010). A portion of fish
above the radio-tagging goals will also be spaghetti tagged,
including all Chinook and coho captured. This less-intrusive
tagging method is proposed to provide additional movement data
beyond the radio-tagged fish movements, but it is not clear if it can
be used to test the effects and accuracy of radio tagging efforts.
Fish movements observed with both methods should be compared
to make an assessment of radio tag effects. However, even
spaghetti tags can be stressful to the fish, causing altered
migration patterns due to stress (Thompson et al. 1986).”
Section 9.7.4.1.6 has been revised to address handling-induced
effects on fish behavior. Fish will be spaghetti tagged to provide
additional data to test assumptions (i.e., assess the
representativeness of the fish that are captured in the
fishwheels) and to augment the development of a mark rate in
the population (Section 9.7.4.1.3). Although spaghetti tagging
can provide some additional insight into post-tagging behavior
(e.g., differing mark rates between tag type), the sample sizes
for both spaghetti tags released and subsequently observed at
spawning sites are not likely to be sufficient to assess this issue
with adequate statistical power (see Section 9.7.4.1.3).
ESCAPE-35 NMFS 11/14/2012 There is no description of methods to test for effects of radio
tagging on survival and behavior. Radio tags can have lethal
effects or non-lethal behavior effects on tagged fish, which could
lead to changes in speed or direction of movements (e.g. Yanusz
et al. 2011, Keefer et al. 2010). A portion of fish above the radio-
tagging goals will also be spaghetti-tagged, including all Chinook
and coho captured. This less-intrusive tagging method is planned
to provide additional movement data beyond the radio-tagged fish
movements, but it is not clear if it can be used to test the effects
and accuracy of radio tagging efforts. Fish movements observed
with both methods should be compared to make an assessment of
radio tag effects. However, even spaghetti tags can be stressful to
the fish, causing altered migration patterns due to stress
(Thompson et al. 1986).”
See AEA’s response to comment ESCAPE-34.
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ESCAPE-36 CWA 11/14/2012 “As part of the TWG meetings, however, the federal and state
agency stakeholders have asserted that because of the economic
and recreational importance of salmon in the Susitna River, it is
critical to adequately characterize their life history needs in the
watershed. The PSP, however, does not indicate the need to study
the distribution and abundance of salmon and other species that
are potentially impacted by the Project through their entire lifecycle.
This is regardless of the fact that both NMFS and USFW filed study
requests for anadromous fish for a minimum of the life cycle of
each species.”
See AEA’s responses to comments FISH-02 and ESCAPE-03.
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RIVPRO-01 FERC 11/14/2012 “In section 9.8.4.1 of the River Productivity Study, you propose to review,
summarize, and synthesize the literature on the impacts of hydropower
development and operations, including temperature and turbidity, on
benthic macroinvertebrate and algal communities in cold climates. In its
May 31, 2012, study requests, the FWS requested that you develop a
white paper to present the results of the literature review. In a September
7, 2012, email communication, the FWS requested clarification on
whether your proposed literature review differed from its requested white
paper. In your October 24, 2012, table summarizing the consultation
history on the fish and aquatic resources study plans, you indicate that
the literature synthesis and white paper could be considered
synonymous. However, the draft RSP does not describe the form of the
literature review and summary. Please describe in your RSP how the
literature review will be presented (e.g., written report, annotated
bibliography, etc.).” –pdf page 14
The literature review will be presented as a written report
(see Section 9.8.4.1).
RIVPRO-02 FERC 11/14/2012 “In section 9.8.4.4, you propose to conduct a feasibility study in 2013 to
evaluate the appropriateness of using reference sites on the Talkeetna
River for monitoring longterm project-related change in benthic
productivity. The draft RSP states that sampling results from Talkeetna
River sites will be compared to results from similar sites in the Middle
Susitna River Reach to evaluate whether the Talkeetna River would
serve as a suitable reference site. Please clarify in your RSP the criteria
that will be used to determine the suitability of the Talkeetna River as a
reference site.” –pdf page 15
As described in Section 9.8.4.4, statistical analyses will
test for similarities and significant differences between
Talkeetna sites and Middle Susitna site by comparing
community compositions and a collection of calculated
metrics. Specific details on statstical methods will be
provided in the River Productivity Implementation Plan
(Section 9.8.4.), but may include ANOVA, MANOVA,
Cluster Analyses using NonMetric MultiDimensional
Scaling (NMDS) ordination with the Bray-Curtis
Dissimilarity Coefficient, and/or other multivariate
ordination techniques (Principal Components Analysis,
Canonical Correspondence Analysis). Results indicating
close similarities, or no significant differences between the
two rivers would indicate suitability as a reference.
RIVPRO-03 FERC 11/14/2012 “In section 9.8.4.5, you propose to conduct a trophic study, using trophic
modeling and stable isotope analysis, to describe food-web relationships
in the current riverine community within the middle and upper Susitna
River. As part of this study, you propose to develop growth-rate potential
models for coho salmon, northern pike, and rainbow trout.
However, during the October 25, 2012, fish and aquatics study meeting,
Because northern pike are limited to the tributaries in
lower reaches of the Sustina River, AEA does not believe
they are appropriate for evaluation of Project effects in the
Middle River Segment. The upstream-most population
has been documented in the Casewell Creek, a tributary
to the Susitna that enter at approximately RM 63. At this
time AEA thinks it is more prudent to use species
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someone mentioned that it was not likely possible to collect northern pike
from the Middle River and Upper River segments because the species is
believed to be present only in the lower river. You therefore proposed to
use another fish species, such as sculpin, instead of northern pike.
Please provide an explanation in your RSP for why you have selected
sculpin or another fish species instead of northern pike for development
of a growth-rate potential model (i.e., clarify the species selected and
identify if it is intended to be a replacement or a surrogate for northern
pike). –pdf page 15
distributed in the Middle River where the greater potential
for Project impact occurs. In lieu of northern pike, AEA
has selected Chinook salmon for the trophic model, due to
its high ecological and economic value in the Susitna
Basin, and its wide distribution throughout the Susitna
River, and that sufficient data exists on Chinook for the
bioenergetics model. Thus, Section 9.9.8.4.5.1 describes
the selection of coho salmon, Chinook salmon, and
rainbow trout for bioenergetics modeling.
RIVPRO-04 FERC 11/14/2012 Regarding Section 9.8.4.5 please address whether sufficient information
is available on the alternative species’ foraging and bioenergetics
parameters or if model parameters would need to be developed. –pdf
page 15
As described in Section 9.8.4.5.1, sufficient information on
foraging and bioenergetics parameters are available for
coho salmon and rainbow trout. Mechanistic drift foraging
models for Chinook salmon are not yet available to allow
the estimation of growth rate potential under changing
conditions. However, field data and bioenergetics analysis
will allow useful comparisons of growth rates, consumption
rates, and growth efficiency (the growth achieved per
gram of food consumed) among different habitats under
current conditions. To make these comparisons, a
Wisconsin bioenergetics model parameterized for Chinook
salmon (Stewart and Ibarra 1991; Madenjian et al. 2004)
will take field inputs of body size, growth rate, water
temperature, diet composition, and the energy density of
prey. The model will estimate the consumption rate and
growth efficiency. These metrics will be compared among
habitats to determine whether growth is currently limited
primarily by water temperature, food consumption, or food
quality in the study area, and whether these limiting
factors differ among habitats (McCarthy et al. 2009).
RIVPRO-05 FERC 11/14/2012 In Section 9.8.4.5, please describe the methods you propose for
capturing each fish species, the number of individuals required, sampling
site locations, and a sampling schedule.” –pdf page 15
Methods for collecting fish specimens are included in
Sections 9.5.4.3 and 9.6.4.3, as fish collected in those
study efforts will be sampled for fish diet analysis, scales,
and stable isotope analyses.
Detail of the number of specimens per species/life stage
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(8 for diet and scales, 5 for stable isotopes) has been
described in the methods (Section 9.8.4.5).
Site locations will be finalized in the first quarter of 2013,
with review and input from the TWG, a review of 2012
results, and a site reconnaissance visit to assess final
candidate sites. Reaches where stations are to be located
are indicated in RSP 9.8.4.2.1 and figures 9.8-1 and 9.8-2.
Sampling sites will be located within Focus Areas
established by the Instream Flow Study plan (Section
8.5.4.2.1.1). Specific details on site locations will be
provided in the River Productivity Implementation Plan
(Section 9.8.4.).
Because river conditions can be unpredictable, timing of
seasonal sampling events can only be tentatively set for
April – early June for spring, late June – August for
summer, and September/October for fall, subject to
weather and river conditions (flow, stage).
RIVPRO-06 FERC 11/14/2012 “In section 9.8.4.5.2, you propose to conduct a stable isotope analysis of
the riverine food web. The draft RSP describes the use of stable isotopes
to investigate the contribution of marine-derived nutrients from spawning
salmon to freshwater ecosystems, but does not mention the potential
contribution of non-salmonid anadromous species. The FWS requested
that you analyze the contribution of marine derived nutrients from non-
salmonid anadromous species. Please describe the fish species that will
be evaluated in the marine derived nutrient, stable isotope study and
provide supporting rationale for inclusion of each species. If you do not
propose to include non-salmonid anadromous species in the analysis,
then please provide an explanation for why FWS’ requested study
component is not adopted in your RSP.” –pdf page 16
Marine derived nutrients (MDN) cannot be traced back to
their source species. Stable isotope analysis can only
detect the 15N isotope levels that are indicative of having
come from a marine source. Target fish species to be
sampled for stable isotope analysis are those that are
abundant in the middle river and will be coho and Chinook
salmon juveniles, and rainbow trout adults and juveniles,
as well as salmon carcasses, drifting invertebrates,
benthic macroinvertebrates, organic matter, and algae.
No other anadromous fishes spawn in sufficient
abundance above RM 98 to allow for their inclusion as a
component of marine derived nutrients.
RIVPRO-07 FERC 11/14/2012 “In a comment dated September 27, 2012, ARRI requested additional
detail regarding locations and frequency of sampling for the fish diet
analysis in section 7.8.4.7. Although the consultation table handed out at
the October 24, 2012, meeting states that the requested information has
been added to section 9.8.4.7, that does not appear to be the case.
Site locations will be finalized in the first quarter of 2013,
after review and input from the TWG, a review of 2012
results, and a site reconnaissance visit to assess final
candidate sites. Locations and the protocol used to select
them will be described in the River Productivity
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Please include in your RSP the frequency and timing of fish and
macroinvertebrate sampling for this analysis.” –pdf page 16
Implementation Plan that will be filed with FERC no later
than March 15, 2013 (Section 9.8.4.)
River conditions are unpredictable; therefore timing of
seasonal sampling events can only be tentatively set. The
study establishes sampling periods for April – early June
for spring, late June – August for summer, and
September/October for fall. Specific sampling dates within
those periods will be determined by reviewing the
hydrograph and weather patterns.for targeted seasonal
flows. Development of thee targeted seasonal flows will
be addressed in the River Productivity Implementation
Plan.
RIVPRO-08 FERC 11/14/2012 “In section 9.8.4.9, you propose to estimate benthic macroinvertebrate
colonization rates in the Middle Susitna River Reach to monitor baseline
conditions and evaluate future changes to productivity in the Susitna
River. In its May 31, 2012, study request the FWS requested that you use
a stratified random sampling approach to collect data on
macroinvertebrate colonization rates in a variety of habitats (e.g., turbid
vs. non-turbid, areas with groundwater upwelling vs. areas without
upwelling). The draft RSP states that data will be collected in a mainstem
habitat representative of the Middle Susitna River Reach to reflect typical
colonization conditions, but does not specify whether the requested
“variety of habitat types” will be sampled. Please include this information
in your RSP, or, if you do not propose to sample a variety of habitat
types, provide an explanation for not including FWS’s request sampling.”
–pdf page 16
As described in Section 9.8.4.9, collection of baseline
colonization rate data will occur in multiple habitat types to
address two likely Project effects: changes in turbidity and
temperature. The influences of turbidity and temperature
on the benthic community colonization rates will be
investigated for four habitat types, which would reflect
varying conditions of these two factors. Due to the
difficulty of isolating each of conditions under natural
conditions, colonization will be examined under
turbid/warm, clear/warm, turbid/cold, clear/cold conditions.
AEA’s proposed design does not include colonization
rates in upwelling vs. non-upwelling areas because
upwelling areas have multiple interrelated environmental
factors that would effect colonization (e.g., nutrients,
conductivity, flow, temperature, dissolved oxygen) which
would prevent isolating individual Project effects. Sampling
would be conducted for both study years. Sampling
locations and scheduling will be deterimined after a review
of 2012 results, from both AEA studies as well as data
collected outside of AEA, and site reconnaissance visits to
assess final candidate sites.
Specific details on site locations will be provided in the
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River Productivity Implementation Plan.
Another potential Project effect is fluctuating water levels,
resulting in a varial zone downstream of the dam.
Colonization data collected from this study will be used as
part of the varial zone model (Section 8.5.4.6), in order to
address potential impacts of fluctuating flow releases on
the benthic macroinvertebrate community.
RIVPRO-09 FERC 11/14/2012 “At the October 25, 2012, fish and aquatics study plan meeting, questions
arose regarding whether and how macroinvertebrate sampling would be
conducted during high flows. You responded that the objective is to
sample in areas that have been wetted for a long enough period of time
for macroinvertebrates to colonize, and that at least a month is typically
required for this to occur. Please add this information, as well as specifics
on timing and location of sampling, to the study description in section
9.8.4.9.” –pdf page 16
Section 9.8.4.2.1 indicates that shoreline bathymetry will
be evaluated such that changes in water level must
remain constant enough that accessible substrates remain
continually inundated for a period of at least one month, to
facilitate colonization of those substrates.
RIVPRO-10 ADF&G 11/14/2012 Section 7.8.4.2.1.Benthic Macroinvertebrate sampling.” Should consider
drill holes for winter macroinvertebrate sampling; probably safer than
sampling winter open water sites.” –pdf page 28
The additional resources required to conduct winter
sampling is not warranted for this study. Aquatic insects in
the Susitna River are largely univoltine (one generation);
therefore, the generation sampled in the late fall before ice
up would be representative of the overwintering
population. The sample collections in the early spring
before or during the initial ice out event would be the
resulting population that had successfully overwintered
(Section 9.8.4.2.1).
RIVPRO-11 ADF&G 11/14/2012 Section 7.8.4.2.1.Benthic Macroinvertebrate sampling. “Explain site
selection and how site will be sampled at all flows. If sample sites will not
be permanently wetted, how is the length of time required for colonization
determined in order to sample sites that are not permanently wetted.” –
pdf page 28
See AEA’s response to comment RIVPRO-09
RIVPRO-12 ADF&G 11/14/2012 Section 7.8.4.2.1.Benthic Macroinvertebrate sampling. “More information
is needed on woody debris sampling design. Multiple sections taken from
each snag would likely result in pseudoreplication issues. Recommend
sampling multiple snags.” –pdf page 28
Sampling method is based on those detailed in Moulton et
al. 2002, which states that each sample will be taken from
separate snag pieces, but that snags may be at the same
location, depending on abundance of woody debris at a
site. Sampling details will be provided in the River
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Productivity Implementation Plan filed with FERC no later
than March 15, 2013 (Section 9.8.4.).
RIVPRO-13 ADF&G 11/14/2012 “Section 7.8.4.2.2 Benthic Algae Sampling
Describe the methods that will be used for sampling and analysis.” –pdf
page 28
Algal sampling methods will follow the EPA’s field
operations procedures for periphyton single or targeted
habitat sampling (Peck et al 2006; Barbour et al. 1999).
Further details will be provided in the River Productivity
Implementation Plan (Section 9.8.4.).
RIVPRO-14 ADF&G 11/14/2012 “Section 7.8.4.4. Surrogates for future impacts
Should assess the feasibility of establishing reference sites in adjacent
systems (e.g. evaluate the Chulitna, Talkeetna, etc.).” –pdf page 28
Section 9.8.4.4 describes the proposed reference site
feasibility study. One station will be established on the
Talkeetna River, with a mainstem site and two off-channel
habitat sites associated with the mainstem site. Benthic
macroinvertebrate, algae, and drift sampling will occur
during approximately the same periods as sampling in the
Middle Susitna River Segment ( Sections 9.8.4.2 and
9.8.4.3), with seasonal sampling during 2013 only. In the
first quarter of 2014, sampling results from Talkeetna sites
will be compared to results from similar sites in the Middle
Susitna River Segment to determine whether the
Talkeetna River would serve as a suitable reference site.
See also RIVPRO-02 for response on analysis.
RIVPRO-15 ADF&G 11/14/2012 Section 7.8.4.7 Fish Diet “What are the targeted species and lifestage for
diet analysis? What methods will be used and what is the feasibility of
non-lethal methods for juvenile salmonids?” –pdf page 28
As described in Section 9.8.4.7, species/life stages for diet
analysis will be coho and Chinook salmon juveniles, and
rainbow trout adults and juveniles.
Stomach lavage with syringes will be used. This method
has been shown to be effective at flushing stomach
contents from juvenile salmonids with low mortalities.
(personal comm. M. Wipfli, UAF). Further details
regarding sample collection will be provided in the River
Productivity Implementation Plan (Section 9.8.4.).
RIVPRO-16 ADF&G 11/14/2012 Section 7.8.4.7 Fish Diet “What sample preservation will be used? Need
to consider prey condition after flushing. To what level of taxonomic
resolution will samples be identified?” –pdf page 28
Section 9.8.4.7 indicates that stomach contents will be
preserved with ethyl alcohol (not denatured) immediately.
Further details regarding sample processing and levels of
taxonomic resolution will be provided in the River
Productivity Implementation Plan (Section 9.8.4.).
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RIVPRO-17 ADF&G 11/14/2012 “Section 7.8.4.9 Macroinvertebrate Colonization
What is the artificial substrate material and likelihood it will influence
colonization results?” –pdf page 28
Before any final decision on what artificial substrate design
can be made, additional information is needed on flows,
stream bed movement, public accessibility and the risk of
vandalism, as well as natural substrates in the selected
study sites, and considerations of logistics (transportation
limitations). All artificial substrates display a bias towards
colonization, but such bias can be corrected for with
proper design (Rosenberg and Resh 1982). This
information will be collected and synthesized Q1 2013,
and the decision process used and the artificial substrate
design selected will be described in the River Productivity
Implementation Plan (Section 9.8.4.).
RIVPRO-18 USFWS 11/14/2012 “AEA Study Objective 1: Synthesize existing literature on the impacts of
hydropower development and operations (including temperature and
turbidity) on benthic macroinvertebrate and algal communities. This
objective should include a literature review and annotated bibliographies
of hydropower development and operation on benthic and transported
organic matter, and ecosystem productivity, not just algal biomass. The
study plan should outline the steps that will be used to accomplish this
task (i.e., data base searches, key words, resulting product). The
literature review should result in annotated bibliographies. All data bases
searched and key words should be listed. The bibliography should
contain the author’s abstract as well as AEAs interpretation of the study
relative to the proposed project.
Electronic copies of all publications should be provided along with the
annotated bibliography.
The AEA synthesis should identify all potential project effects and show
how AEAs study plans have been developed to adequately evaluate and
monitor these potential Project effects on the Susitna River.” –pdf page
108
AEA considers an annotated bibliography as beyond the
scope and need of the study. A literature review that
summarizes existing relevant literature will be sufficient to
describe what is known about the effects of
hydrodevelopment.
The topic of effects on organic matter will be addressed in
the literature review, in the context of how it is related to
benthic communities as a food source.
To the extent consistent with copyright laws, AEA will
provide electronic copies of all publications cited in the
review through the ARLIS library.
The objective of the literature review is to review the
current state of knowledge of the effects of hydropower
operations on benthic macroinvertebrate and algal
communities. The review, by its very nature, will identify
effects upon the benthic communities as recorded in the
literature. The literature review is a starting point in the
assessment of potential effects, not the assessment itself.
Identifying all potential Project effects would require
having actual Project operation scenarios, which will not
be available until late 2013.
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RIVPRO-19 USFWS 11/14/2012 “Sampling locations should be selected to obtain replicate measures
documenting the range of project effects among main channel and off-
channel locations and in order to evaluate the influence of
macroinvertebrate and algal abundance on fish distribution and
production. The PSP has located 3 of the proposed 9 mainstem sampling
locations within and just above the inundation zone. Project effects are
likely to be greatest within the tributaries above the inundation zone,
where current resident fish populations will be concentrated into a smaller
area potentially exceeding production capacity. In addition, these streams
will be providing a large portion of the food resources to the fish
community likely to develop within the reservoir. Determining the area
and quality of remaining stream habitat following project construction is
an important project objective.
Quantifying macroinvertebrate and algal production and invertebrate drift
relative to the abundance of resident fish in tributaries above the
inundation zone should be an additional objective and the site of Upper
River sampling locations.” –pdf page 109
As described in Section 9.8.4.2.1, AEA’s sampling design
includes replicate measures to document the range of
Project effects in the mainstem channel and off-channel
locations within the Upper River Segment. Figure 9.8-2
includes two sampling stations (6 sites) in the Upper River
Segment upstream of the inundation zone. The study no
longer includes stations within the inundation zone.
AEA does not agree that Project effects are likely to be
greatest within the tributaries above the inundation zone,
for the following reasons: 1) Changes to temperature,
turbidity, and flow in the mainstem below the dam will be
the greatest Project effects; 2) There is no information that
fish populations will be concentrated within smaller areas
within the tributaries. In fact, some fish populations may
expand into the reservoir, and may benefit from the larger
food base available there. The potential for fish population
expansion into the reservoir will be addressed in Section
9.10. Production from the tributaries above the inundation
zone will not be altered due to Project effects, and do not
have a Project nexus. Therefore, quantification of benthic
macroinvertebrates, algae, and drift is unnecessary
RIVPRO-20 USFWS 11/14/2012 “Three of the remaining mainstem sites are located below the dam site,
but above Devils Canyon. The purpose for selecting these locations is
unclear, although likely to characterize distinct geomorphic reaches.
Project effects likely will be greatest within these reaches, but they do not
overlap with known fish distribution. We agree that documenting changes
in the biotic community immediately below the dam is an important
objective; however, the PSP should expand upon the reasons sites were
selected within this reach, and how these sites be used to determine
mainstem and off-channel effects. The PSP should identify the number of
sites and replicates that are needed for the statistical design and how the
analyses will be conducted.” –pdf page 109
As described in Section 9.8.4.2.1, AEA’s sampling design
includes replicate measures to document the range of
Project effects in the mainstem channel and off-channel
locations in the Middle River Segment immediately below
the proposed dam site. This study includes two sampling
stations (6 sites) in the MR-1 and MR-2 reaches which will
be located within Focus Areas established by the Instream
Flow Study plan (Section 8.5.4.2.1.1). (See Figure 9.8-1).
Selection of these locations for sampling was based on
their proximity to the dam, where the largest Project
effects are anticipated.
Sampling within the Middle River Segment will occur
within these multi-disciplinary Focus Areas, in an attempt
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to correlate benthic community data with additional
environmental data collected by other studies (water
quality [Section 5.5], geomorphology [Section 6.5], and
instream flow [Section 8.5]) also sampling in Focus areas.
These sites are intended to provide a representation of
benthic macroinvertebrates, algae, and their relationships
in the food web of the Susitna River at the reach scale.
Sites are designed as monitoring sites, to collect pre-
Project baseline data at these locations for later
comparisons to post-Project sampling, as well as to
provide that data to various models that can be used to
predict potential Project effects (IFIM and Varial Zone
Modeling, Section 8.5.4.6.; Trophic Modeling, Section
9.8.4.5..) Specific details on site locations and sample
sizes will be provided in the River Productivity
Implementation Plan.
RIVPRO-21 USFWS 11/14/2012 “Most resident and anadromous fish spawning and rearing locations and
the areas for greatest potential project impacts are between Portage
Creek and the three-rivers confluence near Talkeetna. However, AES
has identified only one mainstem and two associated off-channel
sampling locations to “characterize” the macroinvertebrate and algal
communities within this ~60 miles of river. The Service recommends
sampling locations be selected in proportion to the distribution of main
channel and off-channel habitats and micro-habitats within these areas.
Sampling locations should be selected so that they can be used to
evaluate Project effects and fish distribution and abundance, and growth
rates. Sampling locations should be located above and below major
tributaries to evaluate tributary influence on local invertebrate
communities and their contribution to total invertebrate drift. We
recommend a minimum of 10 mainstem sampling sites between the
Indian River and Talkeetna. Additional mainstem sampling sites should
be selected to replicate the meso- and microhabitat within the main
channel. These meso- and microhabitats should represent differences in
substrate (woody debris, boulder/cobble, cobble/gravel, sand/silt),
proximity to vegetated banks, point bars, and velocities. Extrapolation of
Section 9.8.4.2.1 includes the establishment of two
sampling locations within this Middle River Segment,
which will be located within Focus Areas established by
the Instream Flow Study plan (Section 8.5.4.2.1.1).
Specific details on site locations will be provided in the
River Productivity Implementation Plan.
The proposed two stations (6 sites) are intended to
provide a representation of benthic macroinvertebrates,
algae, and their relationships in the food web of the
Susitna River at the reach scale. Sites are designed as
monitoring sites, to collect pre-Project baseline data at
these locations for later comparisons to post-Project
sampling, as well as to provide that data to various models
that can be used to predict potential Project effects (IFIM
and Varial Zone Modeling, Section 8.5.4.6; Trophic
Modeling, Section 9.8.4.5.)
AEA does not agree that 10 sites are necessary or that
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habitat values to upper classification levels will require sampling relative
to, or quantification of, the abundance of these habitat characteristics
within each macro-habitat.” –pdf page 109
sampling needs to be replicated at the meso- and
microhabitat levels. That level of detail is unnessary to
address potential Project effects. Furthermore, river
productivity at a meso- or finer habitat scale would be
highly variable over time fluctuating with localized changes
perhaps related to seasonal runoff, nutrient input, and
turbidity fluctuations. AEA’s proposed design assesses
river productivity at a reach scale where localized effects
will be diminished and the ability to detect potential effects
from the Project will be enhanced.
AEA’s proposed approach achieves study objectives in a
more cost-effective manner, with less risk of complications
due to uncontrollable natural variation.
AEA does not agree the extrapolation to the reach level
requires sampling at the macro- and microhabitat levels.
AEA is proposing a parsimonious design that will
efficiently evaluate Project effects on algae and
macroinvertebrate communities. AEA is confident that the
River Productivity Study as designed with six sampling
stations and seasonal sampling frequency will provide
sufficient data to describe existing conditions, support
rigorous modeling efforts that can be used to evaluate
potential Project effects and will facilitate future monitoring
needs.
RIVPRO-22 USFWS 11/14/2012 “A similar thought process should be applied to the selection of sites to
adequately characterize off-channel habitats. The PSP is currently
classifying 4 different off-channel habitats: tributaries, tributary mouths,
side sloughs, and upland sloughs. However, there is considerable
differences in the productivity among sites of the same classification (i.e.
the relative contribution of invertebrate drift to the main channel from the
Indian River compared to Whiskers Creek likely is large). Obtaining 3
replicates of these off-channel sites would result in 12 off-channel
sampling locations and a minimum of 5 replicates is recommended.
Replicate sampling within these locations to document differences in
AEA does not agree that 5 replicates per off-channel
habitat location are necessary or that sampling needs to
be replicated at the meso- and microhabitat levels. That
level of detail is unnessary to address potential Project
effects. Furthermore, river productivity at a meso- or finer
habitat scale would be highly variable over time fluctuating
with localized changes perhaps related to seasonal runoff,
nutrient input, and turbidity fluctuations. AEA’s proposed
design assesses river productivity at a reach scale where
localized effects will be diminished and the ability to detect
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invertebrate abundance among different meso-habitats including
variations in flow, substrate, depth, and velocity, and macrophytes beds,
all of which can be modified by Project operation (e.g., flushing flows),
would require additional sampling effort.” –pdf page 109
potential effects from the Project will be enhanced.
This requested level of effort unnecessarily refocuses the
study to the mesohabitat and microhabitat scale, which is
in excess of that required to address the potential Project
effects. Focused efforts at the reach scale at established
representative locations using standardized sampling
methods are sufficient in order to collect meaningful data
to establish a pre-Project baseline, as well as to provide
that data to various models that can be used to predict
potential Project effects (IFIM and Varial Zone Modeling,
Section 8.5.4.6.; Trophic Modeling, Section 9.8.4.5.).
AEA’s proposed approach achieves study objectives in a
more cost-effective manner, with less risk of complications
due to uncontrollable natural variation.
See AEA’s response to comment RIVPRO-21.
RIVPRO-23 USFWS 11/14/2012 “Algal sampling locations within the Middle River, including meso- and
microhabitats should be elected independent of macroinvertebrates, as
algae respond to different environmental variables and project effects will
vary.” –pdf page 110
As proposed in Section 9.8.4.2.2, algal sampling is
conducted in conjunction with benthic macroinvertebrate
sampling in order to correlate the two communities. Algae
serves as a food resource to benthic macroinvertebrates,
and can influence the distribution, abundance, and
composition of the macroinvertebrate community.
These sites are intended to provide a representation of
benthic macroinvertebrates, algae, and their relationships
in the food web of the Susitna River at the reach scale.
Sites are designed as monitoring sites, to collect pre-
Project baseline data at these locations for later
comparisons to post-Project sampling, as well as to
provide that data to various models that can be used to
predict potential Project effects (IFIM and Varial Zone
Modeling, Section 8.5.4.6.; Trophic Modeling, Section
9.8.4.5.).
RIVPRO-24 USFWS 11/14/2012 “Results should be able to provide information that can be used to AEA concurs with the potential for high variability in these
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evaluate macroinvertebrate and fish distribution as a function of algal
abundance, and sampling locations may overlap. Algal growth will vary
with differences in light availability (turbidity), water velocity, and nutrient
concentrations. Algal biomass likely will vary considerable between
tributaries, the main channel, and clear off-channel habitats. Nutrient
concentrations could be very different below sloughs and tributaries
compared to upstream locations, and nutrients and light can vary within a
slough as turbid mainstem water levels increase and decrease with stage
height.” –pdf page 110
results across habitats. Furthermore, AEA understands
the need to determine the primary driver(s) of productivity
in the Susitna River, be it algae, drift, organic matter. It is
for these reasons AEA is proposing to evaluate river
productivity at the reach level by determining not only the
abundance of these nutrient and food resources but also
how they are utilized by fish. As described in Sections
9.8.4.5, the River Productivity Study includes a robust
trophic analysis, using bioenergetics modeling and stable
isoptope analysis to assist in defining trophic relationships
and explaining energy source pathways in the Susitna
River food web (Section 9.8.5). Stable isotope analysis
has the potential to trace the sources of productivity,
stream-based vs. terrestrial vs. marine-derived, within the
food web.
RIVPRO-25 USFWS 11/14/2012 “In order to calculate the production potential within sampling locations,
samples also must be stratified by meso- and microhabitats.” –pdf page
110
See AEA’s response to comment RIVPRO-21 and
RIVPRO-22.
RIVPRO-26 USFWS 11/14/2012 “Many of the concerns addressed previously apply to site selection in the
Lower River below the three-rivers confluence. Sampling to explain fish
habitat distribution should consider previous comments. However, an
important Lower River objective is to determine the current and post-
Project contribution of Benthic Organic Matter (BOM) and invertebrate
drift to Lower River sites. Current and post-Project productivity could be
much different in the Susitna River than in the Chulitna River due to
differences in channel form, substrate, nutrient concentrations,
temperature, and turbidity. Therefore, current and post-Project changes
in organic matter and invertebrate drift to the Lower River could extend
Project effects downstream. The Service recommends a sampling plan
be developed around this objective, which will require sampling locations
in the Chulitna and Talkeetna Rivers as well as Susitna River sites below
the confluence.” –pdf page 110
The Lower Susitna River Segment, defined as the
approximate 98-mile section of river between the Chulitna
and Talkeetna rivers confluence and Cook Inlet, will not be
sampled in this study, as it is anticipated that the larger
influences of the Chulitna and Talkeetna rivers will
attenuate Project operation effects, if any, that would
affect benthic communities on the mainstem Susitna River
below the confluence of the three rivers
AEA will reevaluate how far downstream Project
operational significant effects extend based in part upon
the results of the Open-water Flow Routing Model (see
Section 8.5.4.3), which is scheduled to be completed in
Q1 2013. Thus, an initial assessment of the downstream
extent of Project effects will be developed in Q2 2013 with
input from the TWG. This assessment will include a
review of information developed during the 1980s studies
and study efforts initiated in 2012, such as sediment
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transport (Section 6.5), habitat mapping (Sections 6.5 and
9.9), operations modeling (Section 8.5.4.2.2), and the
Mainstem Open-water Flow Routing Model (Section
8.5.4.3). The assessment will guide the need to extend
studies into the Lower River Segment and if needed, will
identify which geomorphic reaches will be subject to
detailed instream flow analysis in 2013. Results of this
2013 assessment will then be used to determine the
extent to which the study should be modified to include
sampling in the Lower River Segment in 2014.
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RIVPRO-27 USFWS 11/14/2012 “Algal sample timing and frequency should be developed to evaluate
changes relative to parameters that influence growth. The availability of
solar energy and nutrients is greater in early spring. Turbidity is lower
during the early spring, increasing with the contribution of glacial flow.
Solar input is greater prior to leaf-out and nutrient concentrations often
are higher due to reduced uptake by terrestrial vegetation.
The Service recommends that algal sample timing begin in early spring
with frequent sample collection in order to measure the change in
biomass relative to changing solar radiation, turbidity, and nutrient
concentrations. This information will be important for the evaluation of
post-Project effects as project construction likely will alter all three of
these variables.
Water depth and storm flows are the other two variables that can
influence algal sloughing and production, and should be accounted for
when selecting sample timing and frequency. Sample locations at
multiple depths across the channel could be used to estimate changes in
algal biomass due to seasonal or project-related changes in water depth.
Algal biomass will vary considerably before and after flushing flows, so
samples must be collected prior to and following storm events.
Reduced turbidity in the late fall may also provide a brief period of algal
production.The Service recommends that algal sampling be collected in
the fall to document this period of potential increased production. As an
alternative, AEA should consider seasonal measures of ecosystem
metabolism that integrate the effects of multiple different parameters
influencing algal productivity.” –pdf page 111
AEA concurs with the need to capture seasonal variability
including potential peaks in algal growth when turbidity is
lower. However, because river conditions can be
unpredictable, timing of seasonal sampling events can
only be tentatively set for April – early June for spring, late
June – August for summer, and September/October for
fall, subject to weather and river conditions (flow, stage).
These collection periods would conincide with the
Service’s request.
In order to address the effects of changing flow patterns
on algae, baseline data will be collected to assess benthic
community responses to storm events within side slough
habitats. Sampling will be conducted both before and
after storm events that meet or exceed a 1.5-yr flood event
at two side sloughs sites located in two separate Focus
Areas in the Middle River Segment between Portage
Creek and Talkeetna (Section 8.5.4.2.1.1.). Samples will
be collected at both the upstream and downstream ends
of each slough, and will include benthic macro-
invertebrates, algae, and organic matter. Sampling will be
conducted for two storm events per year. Specific details
on site locations and targeted flows will be will be based
on information from the instream flow (Section 8.5). and
geomorphology (Section 6.5) studies available in early
2013, and will be provided in the River Productivity
Implementation Plan (Section 9.8.4.).
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RIVPRO-28 USFWS 11/14/2012 “The Service does not agree that sample collection of riffle habitats only
is adequate.
As stated previously, this represents only one meso-habitat and will bias
characterization of invertebrate communities. In addition, most of the
locations referenced do not Therefore, adopting a stratified random
sampling and standardizing the mesohabitat conditions reduces contain
riffles to sample. –pdf page 111
Sampling habitats which have coarser substrates and
faster velocities, i.e., riffle/run habitats, focuses sampling
efforts on those areas that are higher in macroinvertebrate
diversity and abundances (Barbour et al 1999; Carter and
Resh 2001; Moulton et al. 2002; Resh and Jackson 1993).
Flow and substrate are considered among the most
important controlling factors of benthic communities (Ward
and Stanford 1979; Armitage 1984; Minshall 1984). As
riffles and runs feature swift and turbulent flows, those
habitats feature high dissolved oxygen, currents for both
the transport of drifting insects and detritus, and an
influence on substrate composition available (Hart and
Finelli 1999). Coarser substrates generally provide more
interstitial spaces for macroinvertebrates to use as refugia,
as well as for the trapping of detritus for food (Hershey
and Lamberti 2001; Rabeni and Minshall 1970). As a
result, diversity and abundance generally increases with
substrate stability and detritus (Minshall 1984). Riflle/run
areas also offer a level of standardization in terms of
habitat stratification, which reduces sample variability and
facilitates comparisons among sites (Carter and Resh
2001; Resh and Jackson 1993; Klemm et al. 1990;
Hilsenhoff 1988).
The proposed sampling sites are intended to provide a
representation of benthic macroinvertebrates, algae, and
their relationships in the food web of the Susitna River at
the reach scale (Section 9.8.4.2.1.) See also Table 9.8-1,
and Figures 9.8-1 and 9.8-2. Sites are designed as
monitoring sites, to collect pre-Project baseline data at
these locations for later comparisons to post-Project
sampling, as well as to provide that data to various models
that can be used to predict potential Project effects (IFIM
and Varial Zone Modeling, Section 8.5.4.6.; Trophic
Modeling, Section 9.8.4.5.).
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RIVPRO-29 USFWS 11/14/2012 Sampling methods should be used that are quantitative and appropriate
for fine and coarse substrates. Alaska Stream Condition Index (ASCI)
methods (Major and Barbour 2001) are based upon a composite of 20
samples collected in proportion to habitat availability (including woody
debris, roots, and macrophytes beds) using a “D” frame kick net. Mesh
size is important as the community is made up of many small organisms
(~300 μm mesh is standard).
This methodology; however, does not allow for determining invertebrate
density which is an important metric. One possibility would be
supplementing benthic samples using a Hess sampler with qualitative
samples of unique habitats. Multiple samples at one sampling site should
not be considered replicates of that habitat type, but metric means
calculated (or samples composited) to obtain one value for that site,
unless they are replicating mesohabitats within a site. Field sorting of
macroinvertebrates is not recommended. Any proposed subsampling
method should be included in the study plan.” –pdf page 111
AEA does not agree that sampling needs to occur in both
fine and coarse substrates because sampling across
substrate types introduces site variablility, specifically
regarding species compositions and abundances that
would complicate evaluation of Project effects. AEA
proposes a more robust sampling design which focuses
sampling coarser substrates and faster velocities, i.e.,
riffle/run habitats, because: 1) those areas that are higher
in macroinvertebrate diversity and abundances (Barbour
et al 1999; Carter and Resh 2001; Moulton et al. 2002;
Resh and Jackson 1993); 2) offer a level of
standardization in terms of habitat stratification, which
reduces sample variability and facilitates comparisons
among sites (Carter and Resh 2001;Resh and Jackson
1993; Klemm et al. 1990; Hilsenhoff 1988). See also
RIVPRO-28.
AEA disagrees that rapid bioassessment protocol such as
ASCI is appropriate to meet multiple study objectives.
ASCI method is a rapid bioassessment method, intended
to collect general information about an entire site or
location, and all the various habitats within it. It combines
all materials from all 20 samples collected from a variety of
habitats into one sample, from which metrics are
calculated that represent the site as a whole. While this is
preferable to agencies that need to assess the health and
conditions of mutliple streams region-wide, it is not an
appropriate sampling method when setting up a study
design that will require statistical comparisons among
reaches, seasons, and years. This lack of replication, by
reducing the sample size to one, will prevent any statistical
analysis with other sites, time periods, and any pre-
versus. post-Project comparisons. AEA agrees that a
further disadvantage of the ASCI method is that it does not
allow for determining macroinvertebrate density estimates.
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AEA does not agree with averaging and compositing
samples at a site. AEA believes replicate samples can be
obtained within one habitat type. By employing a
controlled sampling order, downstream to upstream, we
can obtain truly independent replicate samples to faciliate
statistical analyses.
AEA concurs that field sorting of macroinvertebrates is not
recommended. Full samples will be preserved in the field,
and sorting and subsampling procedures will be
conducting in a laboratory. Details on sorting and
subsampling methods will be provided in the River
Productivity Implementation Plan (Section 9.8.4.).
RIVPRO-30 USFWS 11/14/2012 “The PSP does not provide any details on algal sample collection
methods or sample handling and processing. Stating that methods will
follow unspecified state protocols and a list of citations is not sufficient for
evaluating the proposed PSP methodology. The methods shouldm
describe how samples will be collected from the multiple different
available substrates,including:
• Sample substrate must be based upon predetermined criteria;
• Determine whether entire substrate be cleared of algae or a portion
of the substrate delineated for sampling;
Algal sampling methods will be based upon the EPA’s
field operations procedures for periphyton single or
targeted habitat sampling (Peck et al 2006; Barbour et al.
1999). As specified in these procedures, the
recommended substrate/habitat combination is cobble
obtained from riffles and runs with current velocities of 10-
50 centimeters per second. Further details specific to
algae sample collections, sample handling, and
processing will be summarized from the EPA field
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• Define measurements for the area to be sampled;
• Address duplicate sampling from the same substrate to allow for
species identification, AFDM, and chlorophyll-a analyses;
• Describe field sample be preservation methodologies, i.e., avoid
degrading chlorophyll a;
• Describe replicate sampling representative of each site and each
meso-habitat within each site;
• Provide procedures that will address patchy distribution of algae
within a macro-habitat;
• Describe procedures for laboratory sub-sampling occurring prior to
algal species identification.”
–pdf page 111
operations procedures in the River Productivity
Implementation Plan (Section 9.8.4.).
RIVPRO-31 USFWS 11/14/2012 “The AEA study objective, to “estimate” drift of benthic
macroinvertebrates, does not reflect the importance of this topic in
understanding project effects to the biotic community. Sampling
locations, timing and frequency should be selected to quantify differences
in drift among habitats and be used to evaluate seasonal and spatial fish
distributions and differences in potential project effects. We believe that
documenting invertebrate drift in tributaries above the inundation zone
may be important to evaluate food available to the resident and
anadromous fish remaining in these reaches and as a contribution to the
reservoir.” –pdf page 112
AEA disagrees that the study objective does not reflect the
importance of this topic of drift. Our objective of sampling
invertebrate drift addresses what species, quantities, and
sources of invertebrates are entering the water column as
drift, and their availability to fish as food resources. This
information is a critical component in the bioenergetics
model, and is significant in evaluating Profect effects on
the trophic transfer of energy in the Sustina aquatic
community.
As proposed in Section 9.8.4.3, drift sampling will be
conducted at all six sampling stations, which include
mainstem and off-channel habitat types.Site locations will
be finalized in the first quarter of 2013, with input from the
TWG, a review of 2012 results, and a site reconnaissance
visit to assess final candidate sites. Specific details on
sampling timing and frequency will be provided in the
River Productivity Implementation Plan (Section 9.8.4.).
Regarding sites in the inundation zone, drift above the
inundation zone would not be expected to change due
Project operation effects. See AEA’s response to
comment RIVPRO-19
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RIVPRO-32 USFWS 11/14/2012 “Sampling Locations
A single sampling location for invertebrate drift between Devils Canyon
and Talkeetna will be inadequate for accomplishing study plan objectives.
Invertebrate drift sampling locations should be adjusted to coincide with
juvenile and resident fish sampling. Mainstem sampling locations should
be located above, within, and below major tributaries. These sampling
locations will be used to document the contribution of tributaries to
mainstem drift and to determine if food availability is related to rearing-
fish abundance at these locations. Macroinvertebrate drift (or plankton
tows) should be replicated at all macro habitat locations concurrent with
fish sampling.
Replicate samples should be collected within each macro-habitat;
however, drift abundance does not likely vary with the same meso-habitat
characteristics that influence benthic macroinvertebrate distribution.
Terrestrial invertebrates in the drift likely vary with proximity to riparian
vegetation and must be considered when sampling locations are selected
(Johansen et al. 2005). Macroinvertebrate drift should be measured in
the Chulitna and Talkeetna Rivers near the confluence to determine the
relative contribution of the Susitna River to downstream food resources.”
–pdf page 112
AEA disagrees that its drift sampling design will be
inadequate for accomplishing study objectives. AEA’s
sampling design, which includes the establishment of two
sampling locations (6 sites in total) within this Middle River
Segment, is adequate to describe Project effects at the
reach level.
Project construction and operations are not expected to
affect drift or fish populations within major tributaries
(including the Chulitna and Talkeetna rivers) except within
the zone of hydrologic influence (tributary mouths).
Therefore, it is not necessary to document the contribution
of tributaries to mainstem drift. Specific details on site
locations will be provided in the River Productivity
Implementation Plan (Section 9.8.4.).
AEA does not agree that sampling at the macro- and
microhabitat is necessary to evaluate Project effects.
These sites are intended to provide a representation of
benthic macroinvertebrates, algae, and their relationships
in the food web of the Susitna River at the reach scale.
Sites are designed as monitoring sites, to collect pre-
Project baseline data at these locations for later
comparisons to post-Project sampling, as well as to
provide that data to various models that can be used to
predict potential Project effects (IFIM and Varial Zone
Modeling, Section 8.5.4.6.; Trophic Modeling, Section
9.8.4.5.).
RIVPRO-33 USFWS 11/14/2012 “Drift sample timing and frequency should be based upon life history and
habitat use of drift feeding fish and to evaluate potential Project effects.
For example, AEA should evaluate drift density during sockeye fry
migration from spawning locations to summer rearing habitats.
Tributary drift should be measured to account for relative productivity
among sites during summer and to determine if changes coincide with
late summer Chinook and coho salmon migrations. Invertebrate drift
should be used to document summer rearing and overwintering habitat
Timing of life history events for coho and Chinook salmon,
and rainbow trout (target species for trophic analysis) will
be consulted when scheduling sampling efforts (Section
9.8.4.2.1.).
As proposed, invertebrate drift sampling is conducted in
support of the trophic analysis, specifically the
bioenergetics model (Section 9.8.4.5.1.). AEA disagrees
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quality for juvenile salmonids.
Sample collection should occur in the early morning and evening to
document densities during peak fish feeding activity.” –pdf page 113
with the value to evaluate drift in relation to sockeye fry
migration, Chinook and coho salmon migrations, as this
sampling would not support sampling objectives, and
would not feed into the bioenergetics model and trophic
analysis. In the selection process for determining study
sites, we will incorporate available information on
distributions and habitat use of target species/life stages.
Specific details on sampling locations, timing and
frequency will be provided in the River Productivity
Implementation Plan (Section 9.8.4.).
RIVPRO-34 USFWS 11/14/2012 “Drift sampling should be conducted in a manner to inform potential
Project effects. Variations in flows and flows that breach the upper end of
side sloughs alter macroinvertebrate drift densities.Flood flows may
capture many terrestrial insects and result in increases in invertebrate
drift.
The PSP should reflect a review of relevant literature to determine other
potential Project effects on invertebrate drift and incorporate this
information into the study design.” –pdf page 113
As proposed, invertebrate drift sampling is conducted in
support of the trophic analysis, specifically the
bioenergetics model (Section 9.8.4.5.1).
AEA has added additional sampling specific to
macroinvertebrate sampling in relation to storm events
(Section 9.8.4.2.1). However, drift sampling is not
included, as sampling would need to occur immediately
during and after the flood event, to capture drift responses
effectively. AEA believes the level of sampling described
in the study plan (benthic macroinvertebrates, algae, and
OM) is sufficient to address potential Project impacts.
See AEA’s response to comment RIVPRO-44.
Literature review of hydropower effects on invertebrate
drift is included as part of Objective 1 (Section 9.8.4.1.).
RIVPRO-35 USFWS 11/14/2012 “Sampling Methods
Methodologies for macroinvertebrate drift sample collection, preservation,
and processing should be fully described in the study plan. Mesh size,
area of sampler, and sample depth (surface and depth) can influence the
composition of drift. Mesh size should be fine enough to capture
Chironomids and early instars of other taxa. Mesh size of approximately
300 μm is recommended. Due to the high concentration of fines within
the mainstem, drift nets could clog within minutes resulting in the loss of
samples. Therefore, samplers should be monitored during sample
collection. Multiple samples may need to be collected in order to get an
Information on drift sampling methods, including sample
collection, preservation and processing will be fully
described in the River Productivity Implementation Plan
(Section 9.8.4.), to be filed with FERC no later than March
15, 2013.
In Section 9.8.4.3., AEA included the use of an in-net flow
meter.
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accurate measure of drift abundance (portion of day sample represents).
Measures of water velocity when installing and removing the nets (along
with the area of the net opening) will not provide an accurate measure of
the volume of water flowing through the net as changes in velocity during
this time may not be linear; the use of flow meters (e.g., General
Oceanics) within the net opening that document total flow would provide
greater accuracy.” –pdf page 113
RIVPRO-36 USFWS 11/14/2012 “Stream water turbidity and inorganic suspended sediment should be
measured concurrent with fish and drift sampling. Changes in visibility
caused by sediment can reduce fish capture efficiency and should be
accounted for in analyses relating fish distribution with invertebrate drift
abundance among macro-habitat types.” –pdf page 113
Since drift sampling is to be conducted in conjunction with
benthic macroinvertebrates and algae samples, turbidity
and photosynthethically active radiation (as an estimator
of visibility/light penetration) will be collected during
sampling (Section 9.8.2.2).
RIVPRO-37 USFWS 11/14/2012 “The methods for sample storage, preservation, sorting, and identification
should be fully described. Drift samples should not be subsampled for
identification. Weight and length/weight relationships should be obtained
for all taxa and instars so that the biomass of drift can be calculated.
Invertebrate biomass data will be necessary for analyses of fish feeding
studies and trophic analyses if mass-balance methods are used.” –pdf
page 113
Section 9.8.4.3 provides additional information on
measuring weights from the drift samples. Information on
biomass and energy density of drifting prey items for use
in the bioenergetics model (Section 9.8.4.5.1). Drifting
terrestrial invertebrates from two stations will be utilized for
stable isotope analysis. Additional information requested
on sample processing will be described in the River
Productivity Implementation Plan (Section 9.8.4.), to be
filed with FERC no later than March 15, 2013.
RIVPRO-38 USFWS 11/14/2012 “Data Analyses
The PSP does not provide sufficient information on drift data analysis,
statistical design, or use of the data to assess differences in fish
distribution and production or in evaluation of potential Project effects.” –
pdf page 113
Section 9.8.4.3 provides additional information on the use
of results from drift sampling. Drift results will be
compared to fish diet analyses, and the benthic
macroinvertebrate data, to discern source of drift items
and preference of drift items in fish diets. Drift results will
also be utilized by the trophic analysis (Section 9.8.4.5).
Enviromental data collected in conjunction with samples
during the collection period (e.g., turbidity, flow,
temperature, and possibly others) would serve as
covariates in any statistical comparisions to other sites,
seasons, years.
Specific information requested on statistical design and
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analysis will be described in the River Productivity
Implementation Plan (Section 9.8.4.), to be filed with
FERC no later than March 15, 2013.
RIVPRO-39 USFWS 11/14/2012 “The Service recommends that sampling locations, including replicate
macro and micro-habitat types, be identified on the Talkeetna River and
be used to provide reference data for post-Project evaluation. AEA
should develop a study plan for post-Project monitoring that includes an
assessment of Susitna River productivity.” –pdf page 113
See AEA’s response to comment RIVPRO-14.
RIVPRO-40 USFWS 11/14/2012 “We believe that a thorough review prior to developing monitoring plans
would be beneficial. All of the information requested under Study
Objective 1, should be provided as a product of this review.” –pdf page
114
AEA is confident that the proposed approach for River
Productivity will adequately document existing conditions
and provide a rigorious data set that will support both
modeling efforts that can be used in effect analysis as well
as future monitoring needs. A literature review addressing
documented impacts at existing hydroelectric facilities is
included as an objective of this study (Section 9.8.4.1) and
will be conducted early in 2013.
RIVPRO-41 USFWS 11/14/2012 AEA Study Objective 6
Comments on Objective 6 of the PSP: Level of effort (sampling
locations, replication among macro- and mesohabitats, and sampling
frequency) is insufficient to provide an adequate HSC.
Diet preferences of target fish in the Susitna should be used to determine
macroinvertebrate species HSC.
HSC objective should be modified to define the purpose for HSC
development in relation to macroinvertebrates and algae, and provide
methods on field site selection, timing, and frequency.
Methods to measure velocity at scales applicable to benthic organisms
should be established. Alternatively, Froude number or sheer stress
could be used. –pdf page 114
Section 9.8.4.6 details the process of developing HSC for
benthic macroinvertebrates and algae communities and
defines the purpose for HSC development in relation to
macroinvertebrates and algae. Data for use in HSC
development will be collected from Objectives 2, (Section
9.8.4.2), and Objective 9, (Section 9.8.4.9), and
information in the literature. This approach is the most
efficient to achieve study objectives and consistent with a
reach level analysis of Project effects. HSC data
collection will be replicated within habitat types.
HSC species selection will consider diet preferences of
target fish (See Section 9.8.4.6.) Additionally, HSC may
be developed for guilds, by grouping taxa into guilds
based on life histories, behavior, and functional feeding
groups.
Velocities will be measured at the stream bed level
(Section 9.8.4.2.1.). This will be added to the RSP.
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Additional information requested on field site selection,
timing and frequency will be described in the River
Productivity Implementation Plan (Section 9.8.4.), to be
filed with FERC no later than March 15, 2013.
RIVPRO-42 USFWS 11/14/2012 “This study objective differs from the Service’s study objective to:
“Characterize trophic
interactions using seasonal diets (stomach content analysis) of all age
classes of non-salmon anadromous, resident and invasive fish species.”
The importance of this objective is to determine the food resources used
by fish within the Susitna River. The Service recommends that the study
plan methodology select sampling locations based upon the objective
rather than in association with sampling conducted to meet other
objectives. Target fish species and life stages should first be identified.
These should include all age-classes of non-salmon anadromous,
resident, and invasive fish species as proposed by the Service. Fish
sampling locations should represent the macrohabitats used by the target
fish species and life stage.
An appropriate sample size should be determined a priori.
Sampling methods for each species and life stage should be identified,
along with sample handling, preservation, and analyses. Invertebrate
weight data should be used to determine biomass in addition to numbers
of each species consumed. The analytical methods should be described
as well as how the results will be applied to evaluating potential Project
effects.” –pdf page 115
AEA’s study objective, Section 9.8.4.7, does differ from
the Service’s study request objective. AEA agrees that
while the importance of this objective is to determine the
food resources used by fish within the Susitna River, the
study does not need to address all age classes of non-
salmon anadromous, resident and invasive fish species.
The data collected by this objective is a critical component
of the trophic analysis, and is therefore focused to provide
fish dietary data to the bioenergetics model and stable
isotope analysis for the targeted fish species and life
stages chosen for that analysis (Section 9.8.4.5.1). These
targeted fish species are coho and Chinook salmon
juveniles, and rainbow adults and juveniles; fish stomach
content samples will be collected from those species only.
AEA has selected sampling locations in the Middle River
Segment that are located among Focus Areas established
by the Instream Flow Study, as described in Section
8.5.4.2.1.1. The Focus Areas to be sampled will be
selected, in part, because of their importance in spawning
and rearing habitat for the target species. Therefore, AEA
has selected the sampling locations based upon the study
objective.
Methods for collecting fish specimens are included in
Sections 9.5.4.3 and 9.6.4.3, as fish collected in those
study efforts will be sampled for fish diet analysis, scales,
and stable isotope analyses.
Specific information on sampling design and methodology,
and analysis will be described in the River Productivity
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Implementation Plan (Section 9.8.4.), to be filed with
FERC no later than March 15, 2013.
See also AEA’s response to comment RIVPRO-05
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RIVPRO-43 USFWS 11/14/2012 “A partial review of the literature raises a number of questions that should
be addressed through studies being developed and implemented in
support the FERC license application.
1. What is the current change in concentrations of BOM in the mainstem
from the dam site to the confluence?
2. Are there significant differences in BOM among and within macro-
habitat sites and is this related to the adjacent plant community?
3. How does the magnitude of overtopping flows affect BOM storage
within side channels and side sloughs or the flushing of organic matter?
4. How important are beaver and woody debris dams on the retention of
organic matter in side channels, side sloughs, and upland sloughs?
5. How will variable ramping rates influence the transport (flushing) of
organic matter from upland and side-sloughs?
6. Is there a relationship between BOM, macroinvertebrates density, and
rearing juvenile fish abundance or distribution?
7. How does the variation in water temperatures and water chemistry
among macrohabitats influence BOM decomposition rates? Will these
rates change with different plant species?
8. Could high concentrations of BOM result in anaerobic conditions in
sloughs during winter?
9. How important are flood flows for the accrual of BOM relative to other
lateral inputs and the total carbon budget?
10. What role do tributaries play in the delivery of organic matter to the
Susitna River?” –pdf page 115
AEA is not proposing investigations to such questions
regarding organic matter system dynamics because such
investigations would be focused on river processes, and
less on the trophic community analysis that is the focus of
this study. Results of such investigations would not be
easily related/ correlated to the organisms of interest, i.e.
macroinvertebrates and fish, and, therefore, would be
difficult to use those results to predict project effects on
those communities. In addition, each of these would
require a specialized and extensive study involving
development with or by other study plans.
AEA believes that Section 9.8.4.8 sufficiently addresses
the role of organic matter resources as it relates to the
trophic analysis. Organic matter collection is included in
the study plan in order to relate it as a food source
available to the benthic community. Collecting and
measuring BOM in conjunction with benthic
macroinvertebrates reveals the amount of OM immediately
available to those organisms, and as such, can indicate
the influence such OM content can have on the
distribution, abundance, and community structure of
benthic macroinvertebrates (Rabeni and Minshall 1977;
Minshall 1984). The sampling collections proposed, with
additional information supplied by the stable isotope
analysis proposed in Section 9.8.4.5.2, will provide
information relating to Questions 1, 2, 6, and 10.
In addition, the RSP proposes sampling pre-and post-
storm (increased flow) events (Section 9.8.4.2.1). In order
to address the effects of changing flow patterns on benthic
macroinvertebrates, algae, and associated organic matter
resources, baseline data will be collected to assess
benthic community responses to storm events within side
slough habitats. Sampling will be conducted both before
and after storm events that meet or exceed a 1.5-yr flood
event at two side sloughs sites located in two separate
Focus Areas in the Middle River Segment between
Portage Creek and Talkeetna (Section 8.5.4.2.1.1.).
Samples will be collected at both the upstream and
downstream ends of each slough, and will include benthic
macroinvertebrates, algae, and BOM. Sampling will be
conducted for two storm events per year, and will provide
i f ti l t d t Q ti 3 5 d 9 S ifi
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RIVPRO-44 USFWS 11/14/2012 Comments on Objective 8 of the PSP: requests sample site in the
mainstem above, below, and within major tributaries, as well as within
each macrohabitat (multiple sites) and Seasons, and before and after
storm events.
recommends leaf packs to measure organic matter processing, or
measures of ecosystem respiration.
requests more detail on collection methods. –pdf page 116
AEA does not agree in the establishment of sampling sites
focused on major tributaries nor at macrohabitat scales
(See AEA’s response to comment RIVPRO-19). Project
construction and operations are not expected to affect
organic matter within major tributaries except within the
zone of hydrologic influence (tributary mouths). Therefore,
it is not necessary to document the contribution of
tributaries to mainstem organic matter.
AEA agrees that sampling should occur in mainstem and
lateral habitats, and across seasons. Section 9.8.4.8
provides information on the collection of organic matter in
the study.
In order to address the effects of changing flow patterns
on BOM, baseline data will be collected to assess benthic
community responses to storm events within side slough
habitats (Section 9.8.4.2.1.). Sampling will be conducted
both before and after storm events that meet or exceed a
1.5-yr flood event at two side sloughs sites located in two
separate Focus Areas (Section 8.5.4.2.1.1.) in the Middle
River Segment between Portage Creek and Talkeetna.
Samples will be collected at both the upstream and
downstream ends of each slough, and will include benthic
macroinvertebrates, algae, and BOM. Sampling will be
conducted for two storm events per year.
AEA has not included leaf packs to measure organic
matter processing, or measures of ecosystem respiration.
The use of leaf packs to measure OM processing, while
useful in detailed studies of organic matter dynamics, do
not add relevant data to the trophic analysis that is the
focus of the study plan. Stable isotope analysis is the tool
that will be used to assess energy pathways of organic
matter to benthic macroinvertebrates to fish (Section
9.8.4.5.2). See also AEA;s response to comment
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RIVPRO-43.
Specific details on collection methods, site locations, and
targeted flows will be provided in the River Productivity
Implementation Plan (Section 9.8.4.), to be filed with
FERC no later than March 15, 2013.
RIVPRO-45 USFWS 11/14/2012 “The study plan currently does not provide enough information to
determine how proposed methods would allow for “monitoring baseline
conditions” or “changes in productivity.”
While the overall approach appears sound, site selection and the
disturbance regime should more closely resemble potential Project
effects. The effects of dewatering and recolonization will be much greater
during the winter when load following is proposed. Short-term exposure
to temperatures well below freezing may result in macroinvertebrate
mortality. Effects will vary by species and frequency and duration of
exposure. Exposure duration may not mimic currently operational flows
that may dewater a site twice a day throughout the winter. Project effects
and varial zone area will change with distance from the dam and channel
geomorphology. Therefore, sampling locations should be selected to
evaluate different levels of potential Project effects.” –pdf page 117
Section 9.8.4.9 includes the objective to "Estimate benthic
macroinvertebrate colonization rates in the Middle Susitna
River Segment under pre-Project baseline conditions to
assist in evaluating future post-Project changes to
productivity in the Middle Susitna."
As described in Section 9.8.4.9, the collection of baseline
colonization rate data will occur in multiple habitat types to
address two likely Project effects: changes in turbidity and
temperature. The influences of turbidity and temperature
on the benthic community colonization rates will be
investigated for four habitat types, which would reflect
varying conditions of these two factors. Due to the
difficulty of isolating each of conditions under natural
conditions, colonization will be examined under
turbid/warm, clear/warm, turbid/cold, clear/cold conditions.
Sampling locations and scheduling will be deterimined
after a review of 2012 results, from both AEA studies as
well as data collected outside of AEA, and site
reconnaissance visits to assess final candidate sites.
Another potential Project effect is fluctuating water levels,
resulting in a varial zone downstream of the dam.
Colonization data collected from this study will be used as
part of the varial zone model (Section 8.5.4.6), in order to
address potential impacts of fluctuating flow releases on
the benthic macroinvertebrate community.
Specific details on site locations will be provided in the
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River Productivity Implementation Plan (Section 9.8.4.), to
be filed with FERC no later than March 15, 2013.
RIVPRO-46 USFWS 11/14/2012 Unaddressed Service objective: recommends that AEA develop a study
plan to survey Macoma balthica in the Susitna River Flats; to determine
the factors influencing their abundance, distribution, and availability to
overwintering shorebirds; and determine how Project operations may
affect their abundance and distribution. –pdf page 117
The population of bivalve species Macoma balthica is the
food supply of overwintering Bering race of Rock
Sandpipers in the Susitna River flats. This intertidal
habitat is located in the lower few miles of the Susitna
River. The Lower Susitna River Segment will not be
sampled in this study, as the larger influences of the
Chulitna and Talkeetna rivers will attenuate Project
operation effects, if any, that would affect benthic
macroinvertebrate communities on the mainstem Susitna
River below the Three Rivers Confluence.
AEA will reevaluate how far downstream Project
operational significant effects extend based in part upon
the results of the Open-water Flow Routing Model (see
Section 8.5.4.3), which is scheduled to be completed in
Q1 2013. Thus, an initial assessment of the downstream
extent of Project effects will be developed in Q2 2013 with
review and input of the TWG. This assessment will
include a review of information developed during the
1980s studies and study efforts initiated in 2012, such as
sediment transport (Section 6.5), habitat mapping
(Sections 6.5 and 9.9), operations modeling (Section
8.5.4.2.2), and the Mainstem Open-water Flow Routing
Model (Section 8.5.4.3). The assessment will guide the
need to extend studies into the Lower River Segment and
if needed, will identify which geomorphic reaches will be
subject to detailed instream flow analysis in 2013. Results
of the 2013 studies would then be used to determine the
extent to which Lower River Segment studies should be
adjusted in 2014.
RIVPRO-47 NMFS 11/14/2012 “This objective should include a literature review and annotated
bibliographies of hydropower development and operation effects on
benthic and transported organic matter, and ecosystem productivity, not
just algal biomass. The PSP should outline the steps that will be used to
See AEA’s response to comment RIVPRO-18.
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accomplish this task (Le. data base searches, key words, resulting
product). The literature review should result in annotated bibliographies.
All data bases searched and key words should be listed. The
bibliography should contain the author's abstract as well as AEAs
interpretation of the study relative to the proposed project. Electronic
copies of all publications should be provided along with the annotated
bibliography. The AEA synthesis should identify all potential project
effects and show how AEAs PSP or revised study plans have been
developed to adequately evaluate and monitor these potential project
effects on the Susitna River.” –pdf page 137
RIVPRO-48 NMFS 11/14/2012 “Sampling plans for macro-invertebrates, algal community composition,
biomass, and productivity, should be developed around understanding
their influence on fish distribution and production, and evaluating
potential project effects.” –pdf page 137
AEA does not agree that sampling macroinvertebrates
should be developed around fish distribution and
production. AEA’s sampling design is reach based in
order to evaluate potential Project effects by study reach.
This study plan is designed to collect pre-Project baseline
data at a number of locations that are representative of
habitats important to fish populations in the Susitna River.
Sampling at these locations is intended to provide a
representation of benthic macroinvertebrates, algae, and
their relationships in the food web of the Susitna River at
the reach scale. Pre-Project baseline data is collected for
later comparisons to post-Project sampling, as well as to
provide that data to various models that can be used to
predict potential Project effects (IFIM and Varial Zone
Modeling, Section 8.5.4.6.; Trophic Modeling, Section
9.8.4.5.) In addition, AEA will consider existing
information fish distribution and habitat use when
determining specific sites for sampling to support the
trophic analysis.
RIVPRO-49 NMFS 11/14/2012 “Measures of macro-invertebrate emergence timing and biomass among
macro-habitat locations have been suggested by AEA as an additional
project objective. As invertebrate development and emergence are
influenced by water temperature and emergence and survival of juvenile
fry are linked to this food source, this appears to be a useful addition to
this study sections. More information will need to be provided on insect
emergence sampling methods, design, and data analyses.” –pdf page
The study plan includes information on insect emergence
sampling methods, design, and data analyses. Section
9.8.4.2.1 describes the use and deployment of floating
emergence traps at each site to determine both the timing
and the amount of adult insect emergence from the
Susitna River. Adult aquatic insect emergence mass is a
product of aquatic insect production from the stream and
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138 is therefore a good surrogate for actual production (minus
predation). Trapped adults will be identified, enumerated,
and weighed. Staple isotope analysis wil be conducted on
specimens from 2 sampling stations (6 sites). Exact trap
design, processing methods, and analyses will be detailed
in the River Productivity Implementation Plan (Section
9.8.4.), to be filed with FERC no later than March 15,
2013.
RIVPRO-50 NMFS 11/14/2012 “Sampling locations should be selected to obtain replicate measures
documenting the range of project effects among main channel and off-
channel locations and in order to evaluate the influence of macro-
invertebrate and algal abundance on fish distribution and production. The
PSP has located three of the proposed nine mainstem sampling locations
within and just above the inundation zone. The purpose for sampling
within the inundation zone requires clarification, as conversion of
mainstem and tributary river habitat into a reservoir will undoubtedly alter
the invertebrate and algal community, and pre-project data are not
necessary to quantify this effect.
However, project effects are likely to be greatest within the tributaries
above the inundation zone, where current resident fish populations will be
concentrated into a smaller area potentially exceeding production
capacity and increasing competition and predation on rearing juvenile
Chinook salmon. In addition, these streams will be providing a large
portion of the food resources to the fish community likely to develop
within the reservoir. Determining the area and quality of remaining stream
habitat following project construction is an important project objective.
Quantifying macro-invertebrate and algal production and invertebrate drift
relative to the abundance of resident fish in tributaries above the
inundation zone should be an additional objective. Macro-invertebrate
and algal sampling locations should be located within tributaries above
the inundation zones. Sampling locations should be sufficient to replicate
the different stream types based upon geomorphic habitat classification.
Sampling locations should be above the inundation zone in streams that
currently support juvenile Chinook salmon. With this information NMFS
will be able to estimate potential food resources within these remnant
streams and their potential to support fish communities.” –pdf page 138
See AEA’s response to comment RIVPRO-19.
Revised Study Plan
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
RIVPRO-51 NMFS 11/14/2012 “Three of the remaining mainstem sites are located below the dam site,
but above Devil Canyon. The purpose for selecting these locations is
unclear, although likely to characterize distinct geomorphic reaches.
Project effects likely will be greatest within these reaches, but they do not
overlap with known fish distribution. We agree that documenting changes
in the biotic community immediately below the dam is an important
objective; however, the PSP should expand upon the reasons sites were
selected within this reach, and how these sites be used to determine
mainstem and off-channel effects. The PSP should identify the number of
sites and replicates that are needed for the statistical design and how the
analyses will be conducted. A PSP developed to monitor post-project
effects has not been provided; therefore it is difficult to evaluate site
selection for this objective. However, in order to evaluate post-project
effects we recommend that a minimum of five mainstem sampling
locations be selected within this geomorphic reach. Sampling locations
should be located near the stream margin and replicate similar meso-
and micro-habitat characteristics. Off-channel habitat locations should be
selected to adequately characterize these habitats based upon their
distribution. If available, 5 replicates of each macro-habitat type should
be selected. Similar sites should be identified within the Talkeetna River
that replicates these geomorphic and macro-habitat types to allow for
postproject statistical evaluation of changes to the macro-invertebrate
and algal communities.” –pdf page 139
As described in Section 9.8.4.2.1, AEA’s sampling design
includes replicate measures to document the range of
Project effects in the mainstem channel and off-channel
locations in the Middle River Segment immediately below
the proposed dam site. Two sampling stations (6 sites) in
the MR-1 and MR-2 reaches which will be located within
Focus Areas established by the Instream Flow Study plan
(Section 8.5.4.2.1.1); see Figure 9.8-1. Selection of these
locations for sampling was based on their proximity to the
dam, where the largest Project effects are anticipated.
AEA does not agree that 5 sites are necessary or that
sampling needs to be replicated at the meso- and
microhabitat levels. That level of detail is unnessary to
address potential Project effects. Furthermore, river
productivity at a meso- or finer habitat scale would be
highly variable over time fluctuating with localized changes
perhaps related to seasonal runoff, nutrient input, and
turbidity fluctuations. AEA’s proposed design assesses
river productivity at a reach scale where localized effects
will be diminished and the ability to detect potential effects
from the Project will be enhanced. AEA’s proposed
approach achieves study objectives in a more cost-
effective manner, with less risk of complications due to
uncontrollable natural variation.
AEA has proposed a reference site feasibility study on the
Talkeetna River, as described in Section 9.8.4.4. One
station will be established on the Talkeetna River, with a
mainstem site and two off-channel habitat sites associated
with the mainstem site. Benthic macroinvertebrate, algae,
and drift sampling will occur during approximately the
same periods as sampling in the Middle Susitna River
Segment ( Sections 9.8.4.2 and 9.8.4.3), with seasonal
sampling during 2013 only. See AEA’s response to
comment RIVPRO-14.
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
RIVPRO-52 NMFS 11/14/2012 “The majority of resident and anadromous fish spawning and rearing
locations and the area for greatest potential project impacts are between
Portage Creek and the three-rivers confluence near Talkeetna. However,
the PSP has identified one mainstem and two associated off-channel
sampling locations to "characterize" the macro-invertebrate and algal
communities within these -60 miles of river. As a comparison, consider
the level of effort directed to measuring these major drivers of stream
ecology and fish productivity with the level of effort directed toward
monitoring ground water/surface water interactions that influence, to
some degree, salmon spawning locations. Sample results from one
mainstem and two associated off-channel sampling locations will not
provide data that can be used to evaluate the influence of macro-
invertebrates or algae abundance on fish distribution among or within
macro-habitats or to evaluate potential project effects.” –pdf page 139
See AEA’s response to comment RIVPRO-21.
RIVPRO-53 NMFS 11/14/2012 “NMFS requests that sampling locations be selected in proportion to the
distribution of main channel and off-channel habitats and micro-habitats
within these areas. Sampling locations should be selected so that they
can be used to evaluate project effects and fish distribution and
abundance, and growth rates. Sampling locations should be located
above and below major tributaries to evaluate their influence on local
invertebrate communities and their contribution to total invertebrate drift.
We recommend a minimum of ten mainstem sampling sites between the
Indian River and Talkeetna. Additional mainstem sampling sites should
be selected to replicate the meso- and micro-habitat within the main
channel. These meso- and micro-habitats should represent differences in
substrate (woody debris, boulder/cobble, cobble/gravel, sand/silt),
proximity to vegetated banks, point bars, and velocities. Extrapolation of
habitat values to upper classification levels will require sampling relative
to, or quantification of, the abundance of these habitat characteristics
within each macro-habitat.” –pdf page 139
See AEA’s response to comment RIVPRO-21.
RIVPRO-54 NMFS 11/14/2012 “A similar thought process should be applied to the selection of sites to
adequately characterize off-channel habitats. The PSP is currently
classifying four different off-channel habitats:
tributaries, tributary mouths, side sloughs, and upland sloughs. However,
there is considerable difference in the productivity among sites of the
same classification (i.e. the relative contribution of invertebrate drift to the
See AEA’s response to comment RIVPRO-22.
Revised Study Plan
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
main channel from the Indian River compared to Whiskers Creek likely is
large). Obtaining three replicates of these off-channel sites would result
in twelve offchannel sampling locations and a minimum of five replicates
is recommended. Replicate sampling within these locations to document
differences in invertebrate abundance among different meso-habitats
including variations in flow, substrate, depth, and velocity, and
macrophytes beds, all of which can be modified by project operation (e.g.
flushing flows), would require additional sampling effort.” –pdf page 140
RIVPRO-55 NMFS 11/14/2012 “Algal sampling locations in the middle river, including meso- and micro-
habitats should be selected independent of macro-invertebrates, as algae
respond to different environmental variables and project effects will vary.”
–pdf page 140
See AEA’s response to comment RIVPRO-23.
RIVPRO-56 NMFS 11/14/2012 “Results should be able to provide information that can be used to
evaluate macro-invertebrate and fish distribution as a function of algal
abundance, and sampling locations may overlap. Algal growth will vary
with differences in light availability (turbidity), water velocity, and nutrient
concentrations. Algal biomass likely will vary considerable between
tributaries, the main channel, and clear off-channel habitats. Nutrient
concentrations could be very different below sloughs and tributaries
compared to upstream locations, and nutrients and light can vary within a
slough as turbid mainstem water levels increase and decrease with stage
height. Haphazard sample location selection without considering and
accounting for natural and potential-project related variability in factors
influencing algal growth will result in data with little value.” –pdf page 140
See AEA’s response to comment RIVPRO-24. AEA’s
approach to sampling will not be haphazard. AEA’s
approach stratifies sampling by reach upstream and
downstream of the Watana Dam site, factoring in Project
effects of flow, temperature, and turbidity on benthic
macroinvertebrates, algae, and organic matter. AEA
expects Project effects to be greatest in the Middle River
Segment and has focused the bulk of sampling therein,
with additional sampling upstream of the inundation zone
above potential Project effects.
In anticipation that Project effects will vary between
mainstem and lateral habitats, we have included three
sampling sites per station to address potential Project
effects across the channel.
RIVPRO-57 NMFS 11/14/2012 “In order to calculate the production potential within sampling locations,
samples also must be stratified by meso- and micro-habitats.” –pdf page
140
See AEA’s response to comment RIVPRO-25.
RIVPRO-58 NMFS 11/14/2012 “Many of the concerns addressed previously apply to site selection in the
lower river below the three-rivers confluence. Sampling to explain fish
habitat distribution should consider previous comments. However, an
important lower river objective is to determine the current and post-
project contribution ofBOM and invertebrate drift to lower river sites.
See AEA’s response to comment RIVPRO-26. As
described in Section 9.8.4.2.1, AEA proposed baseline
data collection to assess the benthic community
responses to storm events within side slough
habitats. Sampling will be conducted both before and
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
Current and post-project productivity could be much different in the
Susitna River than in the Chulitna River due to differences in channel
form, substrate, nutrient concentrations, temperature, and turbidity.
Therefore, current and post-project changes in organic matter and
invertebrate drift to the lower river could extend project effects
downstream. A sampling plan should be developed around this objective,
which will require sampling locations in the Chulitna and Talkeetna Rivers
as well as Susitna River sites below the confluence.” –pdf page 141
after storm events that meet or exceed a 1.5-year flood
event at two side slough sites, located in two separate
Focus Areas in the Middle River Segment between
Portage Creek and Talkeetna (Section 8.5.4.2.1.2).
Additional sampling detail is provided in Section
9.8.4.2.1. Study site selection will be provided in the River
Productivity Implementation Plan that will be filed with
FERC on March 15, 2013.
RIVPRO-59 NMFS 11/14/2012 “Algal sample timing and frequency should be developed to evaluate
changes relative to parameters that influence growth. The availability of
solar energy and nutrients is greater in early spring. Turbidity is lower
during the early spring, increasing with the contribution of glacial flow.
Solar input is greater prior to leaf-out and nutrient concentrations often
are higher due to reduced uptake by terrestrial vegetation.
The Service recommends that algal sample timing begin in early spring
with frequent sample collection in order to measure the change in
biomass relative to changing solar radiation, turbidity, and nutrient
concentrations. This information will be important for the evaluation of
post-Project effects as project construction likely will alter all three of
these variables.
Water depth and storm flows are the other two variables that can
influence algal sloughing and production, and should be accounted for
when selecting sample timing and frequency. Sample locations at
multiple depths across the channel could be used to estimate changes in
algal biomass due to seasonal or project-related changes in water depth.
Algal biomass will vary considerably before and after flushing flows, so
samples must be collected prior to and following storm events.
Reduced turbidity in the late fall may also provide a brief period of algal
production.The Service recommends that algal sampling be collected in
the fall to document this period of potential increased production. As an
alternative, AEA should consider seasonal measures of ecosystem
metabolism that integrate the effects of multiple different parameters
See AEA’s response to comment RIVPRO-27.
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
influencing algal productivity.” –pdf page 141
RIVPRO-60 NMFS 11/14/2012 “The Service does not agree that sample collection of riffle habitats only
is adequate.
As stated previously, this represents only one meso-habitat and will bias
characterization of invertebrate communities. In addition, most of the
locations referenced do not Therefore, adopting a stratified random
sampling and standardizing the mesohabitat conditions reduces contain
riffles to sample. –pdf page 111
See AEA’s response to comment RIVPRO-28.
RIVPRO-61 NMFS 11/14/2012 Sampling methods should be used that are quantitative and appropriate
for fine and coarse substrates. Alaska Stream Condition Index (ASCI)
methods (Major and Barbour 2001) are based upon a composite of 20
samples collected in proportion to habitat availability (including woody
debris, roots, and macrophytes beds) using a “D” frame kick net. Mesh
size is important as the community is made up of many small organisms
(~300 μm mesh is standard).
This methodology; however, does not allow for determining invertebrate
density which is an important metric. One possibility would be
supplementing benthic samples using a Hess sampler with qualitative
samples of unique habitats. Multiple samples at one sampling site should
not be considered replicates of that habitat type, but metric means
calculated (or samples composited) to obtain one value for that site,
unless they are replicating mesohabitats within a site. Field sorting of
macroinvertebrates is not recommended. Any proposed subsampling
method should be included in the study plan.” –pdf page 111
See AEA’s response to comment RIVPRO-29.
RIVPRO-62 NMFS 11/14/2012 “The PSP does not provide any details on algal sample collection
methods or sample handling and processing. Stating that methods will
follow unspecified state protocols and a list of citations is not sufficient for
evaluating the proposed PSP methodology. The methods shouldm
describe how samples will be collected from the multiple different
available substrates,including:
• Sample substrate must be based upon predetermined criteria;
• Determine whether entire substrate be cleared of algae or a portion
of the substrate delineated for sampling;
• Define measurements for the area to be sampled;
See AEA’s response to comment RIVPRO-30.
Revised Study Plan
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
• Address duplicate sampling from the same substrate to allow for
species identification,AFDM, and chlorophyll-a analyses;
• Describe field sample be preservation methodologies, i.e., avoid
degrading chlorophyll a;
• Describe replicate sampling representative of each site and each
meso-habitat within each site;
• Provide procedures that will address patchy distribution of algae
within a macro-habitat;
• Describe procedures for laboratory sub-sampling occurring prior to
algal species identification.” –pdf page 111
RIVPRO-63 NMFS 11/14/2012 “The AEA study objective, to "estimate" drift of benthic macro-
invertebrates, does not reflect the importance of this topic in
understanding project effects to the biotic community. Sampling
locations, timing and frequency should be selected to quantify differences
in drift among habitats and be used to evaluate seasonal and spatial fish
distributions and differences in potential project effects.” –pdf page 111
See AEA’s response to comment RIVPRO-31.
RIVPRO-64 NMFS 11/14/2012 “Sampling Locations
One sampling location for invertebrate drift between Devil Canyon and
Talkeetna will be inadequate for accomplishing project objectives.
Invertebrate drift sampling locations should be adjusted to coincide with
juvenile and resident fish sampling. Mainstem sampling locations should
be located above, within, and below major tributaries. These sampling
locations will be used to document the contribution of tributaries to
mainstem drift and to determine if food availability is related to rearing
fish abundance at these locations. Macro-invertebrate drift (or plankton
tows) should be replicated at all macro-habitat locations concurrent with
fish sampling. Replicate samples should be collected within each macro-
habitat; however, drift abundance does not likely vary with the same
meso-habitat characteristics that influence benthic macroinvertebrate
distribution. Terrestrial invertebrates in the drift likely vary with proximity
to riparian vegetation and must be considered when sampling locations
are selected (Johansen et al. 2005). Macro-invertebrate drift should be
measured in the Chulitna and Talkeetna Rivers near the confluence to
determine the relative contribution of the Susitna River to downstream
food resources.” –pdf page 144
See AEA’s response to comment RIVPRO-32.
Revised Study Plan
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FERC Project No. 14241 Page 329 December 2012
River Productivity Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
RIVPRO-65 NMFS 11/14/2012 “Drift sample timing and frequency should be based upon life history and
habitat use of drift feeding fish and to evaluate potential project effects
and not concurrent with benthic invertebrate sampling as proposed in the
AEA PSP, otherwise the PSP is deficient. For example, what is drift
density during sockeye fry migration from spawning locations to summer
rearing habitat? Tributary drift should be measured to account for relative
productivity among sites during summer and to determine if changes
coincide with late summer Chinook and coho migrations. Invertebrate
drift should be used to document summer rearing and overwintering
habitat quality for juvenile salmonids. Sample collection should occur in
the early morning and evening to document densities during peak fish
feeding activity.” –pdf page 144
See AEA’s response to comment RIVPRO-33.
RIVPRO-66 NMFS 11/14/2012 “Drift sampling should be conducted to documents potential project
effects. Variations in flows and flows that breach the upper end of side
sloughs alter macro-invertebrate drift densities. Flood flows may capture
many terrestrial insects and result in increases in invertebrate drift. The
PSP should reflect a review of relevant literature to determine other
potential project effects on invertebrate drift and incorporate this
information into the study design.” –pdf page 144
See AEA’s response to comment RIVPRO-34.
RIVPRO-67 NMFS 11/14/2012 “Macro-invertebrate drift sample collection, preservation, and processing
should be clearly explained. The PSP fails to provide for that. Mesh
sizes, area of sampler, and sample depth (surface and depth) can
influence the composition of drift. Mesh size should be fine enough to
capture Chironomids and early instars of other taxa. Mesh size of
approximately 300 Ilm is suggested. Due to the high concentration of
fines within the mainstem, drift nets could clog within minutes resulting in
the loss of samples. Therefore, samplers should be monitored during
sample collection. Multiple samples may need to be collected in order to
get an accurate measure of drift abundance (portion of day sample
represents). Measures of water velocity when installing and removing the
nets (along with the area of the net opening) will not provide an accurate
measure of the volume of water flowing through the net as changes in
velocity during this time will not be linear. The use of flow meters (e.g.
General Oceanics) within the net opening that document total flow would
be more accurate.” –pdf page 144
See AEA’s response to comment RIVPRO-35.
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
RIVPRO-68 NMFS 11/14/2012 “Stream water turbidity and inorganic suspended sediment should be
measured concurrent with fish and drift sampling. Changes in visibility
caused by sediment can reduce fish capture efficiency and should be
accounted for in analyses relating fish distribution with invertebrate drift
abundance among macro-habitat types.” –pdf page 145
See AEA’s response to comment RIVPRO-36.
RIVPRO-69 NMFS 11/14/2012 “The methods for sample storage, preservation, sorting, and identification
should be provided. Drift samples should not be subsampled for
identification. Weight and length/weight relationships should be obtained
for all taxa and instars so that the biomass of drift can be calculated.
Invertebrate biomass data will be necessary for analyses of fish feeding
studies and trophic analyses if mass-balance methods are used.” –pdf
page 145
See AEA’s response to comment RIVPRO-37.
RIVPRO-70 NMFS 11/14/2012 “No information is provided on how drift data will be analyzed, what
statistical methods will be used or how the data will analyzed and used to
explain differences in fish distribution and production or to evaluate
potential project effects. The selection of appropriate sampling locations,
sampling timing and frequency, and number of replicates depends upon
clear project objectives and the statistical design. All of these
components are lacking. As written, completion of this study will not
produce any useful data. The PSP needs to be revised to include an a
priori description of the data analysis methods and a power analysis
needs to be conducted to determine needed sample size. A priori power
analysis needs to be conducted prior to the research study to estimate
sufficient sample sizes to achieve adequate power. Posthoc power
analysis, conducted after the study has been completed using the
obtained sample size and effect size to determine what the power was in
the study, is unacceptable to NMFS.” –pdf page 145
AEA is collecting data suited for a before-after-control-
impact sampling design, in order to evaluate future post-
Project effects.
AEA is not convinced that an a priori power analysis is
possible due to a lack of data on the variation between
pre- and post-Project communities; in lieu of conducting a
power analysis, AEA has utilized recommendations from
the literature that specify at sample size of 3-5 replicates is
standard among macroinvertebrate sampling studies
(Resh and McElravy 1993; Klemm et al 1990). AEA also
considered sampling methods used in the 1980s Susitna
studies (Hansen and Richards 1985; Trihey and
Associates 1986)
Specific information on statistical design and analysis will
be described in the River Productivity Implementation Plan
(Section 9.8.4.), to be filed with FERC no later than March
15, 2013.
RIVPRO-71 NMFS 11/14/2012 “The agencies request that sampling locations including replicate macro
and micro-habitat types be identified on the Talkeetna River and be used
to provide reference data for post-project evaluation. A PSP for post-
project monitoring has not been provided; therefore, we will reserve
See AEA’s response to comment RIVPRO-14.
Revised Study Plan
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
comment until that time.” –pdf page 145
RIVPRO-72 NMFS 11/14/2012 “We believe that a thorough review prior to developing PSPs that create
monitoring plans would be beneficial. All of the information requested
under Study Objective 1, should be provided as a product of this review.”
–pdf page 146
See AEA’s response to comment RIVPRO-40.
RIVPRO-73 NMFS 11/14/2012 Comments on Objective 6 of the PSP: Level of effort (sampling
locations, replication among macro- and mesohabitats, and sampling
frequency) is insufficient to provide an adequate HSC.
Diet preferences of target fish in the Susitna should be used to determine
macroinvertebrate species HSC.
HSC objective should be modified to define the purpose for HSC
development in relation to macroinvertebrates and algae, and provide
methods on field site selection, timing, and frequency.
Methods to measure velocity at scales applicable to benthic organisms
should be established. Alternatively, Froude number or sheer stress
could be used. –pdf page 146
See AEA’s response to comment RIVPRO-41.
RIVPRO-74 NMFS 11/14/2012 “This study objective differs from the Service’s study objective to:
“Characterize trophic
interactions using seasonal diets (stomach content analysis) of all age
classes of non-salmon anadromous, resident and invasive fish species.”
The importance of this objective is to determine the food resources used
by fish within the Susitna River. The Service recommends that the study
plan methodology select sampling locations based upon the objective
rather than in association with sampling conducted to meet other
objectives. Target fish species and life stages should first be identified.
These should include all age-classes of non-salmon anadromous,
resident, and invasive fish species as proposed by the Service. Fish
sampling locations should represent the macrohabitats used by the target
fish species and life stage.
An appropriate sample size should be determined a priori.
See AEA’s response to comment RIVPRO-42.
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Sampling methods for each species and life stage should be identified,
along with sample handling, preservation, and analyses. Invertebrate
weight data should be used to determine biomass in addition to numbers
of each species consumed. The analytical methods should be described
as well as how the results will be applied to evaluating potential Project
effects.” –pdf page 146
RIVPRO-75 NMFS 11/14/2012 “This partial review of the literature raises a number of questions that
should be addressed through studies being developed and implemented
in support the FERC license application:
1. What is the current change in concentrations of BOM in the mainstem
from the dam site to the confluence?
2. Are there significant differences in BOM among and within macro-
habitat sites and is this related to the adjacent plant community?
3. How does the magnitude of overtopping flows affect BOM storage
within side channels and side sloughs or the flushing of organic matter?
4. How important are beaver and woody debris dams on the retention of
organic matter in side channels, side sloughs, and upland sloughs?
5. How will variable ramping rates influence the transport (flushing) of
organic matter from upland and side-sloughs?
6. Is there a relationship between BOM, macro-invertebrates density, and
rearing juvenile fish abundance or distribution?
7. How does the variation in water temperatures and water chemistry
among macro-habitats influence BOM decomposition rates? Will these
rates change with different plant species?
8. Could high concentrations ofBOM result in anaerobic conditions in
sloughs during winter?
9. How important are flood flows for the accrual ofBOM relative to other
lateral inputs and the total carbon budget?
10. What role do tributaries play in the delivery of organic matter to the
Susitna River?” –pdf page 149
See AEA’s response to comment RIVPRO-43.
RIVPRO-76 NMFS 11/14/2012 “Many of these questions regarding project effects could be addressed
through careful site selection, sample timing and frequency. Sample sites
located in the mainstem above and below major tributaries and within
those tributaries could evaluate mainstem longitudinal changes and,
along with measures of TOM and tributary discharge, the role of
tributaries in the organic matter budget. Replicate seasonal samples
See AEA’s response to comment RIVPRO-44.
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within each macro-habitat and at replicate macro-habitat locations could
be used to test for significant differences among sites and between
seasons. BOM and TOM sample collection at select sites prior to and
following storm events along with data from flow routing studies (over
topping flows) and geomorphology studies (bed sheer stress) could be
used to test for flow-effects on organic matter retention in sloughs. Sites
with and without beaver dams and quantification of debris dams could
help identify the influence of these structures on organic matter retention.
TOM sampling at the mouth of upland sloughs following storms could be
used to estimate the effects of ramping rates on BOM flushing. The use
of leaf packs to measure organic matter processing at sloughs is a
standard method (Young et al. 2008) that could be used to evaluate
influences of temperature and nutrient concentrations on food
processing. Alternately, measures of ecosystem respiration relative to
BOM standing stocks and TOM could be used to assess organic matter
processing and carbon spiraling lengths (Thomas et al. 2005).
BOM and TOM collection methods need to be described. The methods
should identify the number of replicate samples at each site. Mesh sizes
(upOM, FPOM, CPOM) and whether nets will be nested should be
clarified. The methods should state whether benthic samples will be open
to transported material during sample collection. Methods should
describe the depth the substrate will be disturbed and how sample loss
will be avoided in cobble and boulder substrate. Methods for collecting
samples in fine substrate without measureable velocity should be
provided. Organic matter deposition can be patchy, so the process for
selecting a site to place the sampler or to deal with unequal distribution of
organic matter within a habitat should be explained. How samples will be
preserved, stored, processed, and analyzed should be described.” –pdf
page 150
RIVPRO-77 NMFS 11/14/2012 “The study plan currently does not provide enough information for critical
review. In is unclear how proposed methods would allow for "monitoring
baseline conditions" or "changes in productivity." While the overall
approach appears sound, site selection and the disturbance regime
should more closely resemble potential project effects. The effects of
dewatering and recolonization will be much greater during the winter
when load following is proposed. Only short term exposure to
See AEA’s response to comment RIVPRO-45.
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temperatures well below freezing may result in macro-invertebrate
mortality. Effects will vary by species and frequency and duration of
exposure. Exposure duration may not mimic currently operational flows
that may dewater a site twice a day throughout the winter. Project effects
and varial zone area will change with distance from the dam and channel
geomorphology. Therefore, sampling locations should be selected to
evaluate different levels of proposed project effects.”
NMFS recommends that the PSP be revised to identify sampling
locations that reflect the distribution of macro-habitats important for
anadromous fish within the Susitna River. Methods to document the
colonization rates among these habitats should reflect the expected
disturbance regime imposed by the project operation. This includes both
the season and daily variability in flows.” –pdf page 151
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AQHAB-01 CWA 11/14/2012 Scope is insufficient in studying the Lower River based on
AEA’s apparent assumption that Project effects will not
significantly affect the Lower River aquatic habitats. –pdf page
7
AEA is not assuming an insignificant Project-related effect on
instream flow in the Lower River Segment. However, due to the
direct relationship between flow and physical habitat changes that
may result in barriers, the study elements described in the study
are concentrated within the Upper and Middle River
Segments. Project operations related to reservoir creation, load-
following, and variable flow regulation will have the greatest
potential effects on these segments of the river. In addition, flow
effects will attenuate in a downstream direction as channel
morphologies change, tributary inflows are added and flow
accretion occurs.
The downstream boundary of the Study Area is currently RM 98
because existing information indicates that the hydraulic effects of
the project below the three river confluence is significantly
attenuated. See Section 9.9.3. However, AEA will reevaluate how
far downstream Project operational significant effects extend
based in part upon the results of the Open-water Flow Routing
Model (see Section 08.5.4.3), which is scheduled to be completed
in Q1 2013. Thus, an initial assessment of the downstream extent
of Project effects will be developed in Q2 2013 with review and
input of the TWG. This initial assessment includes a review of
information developed during the 1980s studies and study efforts
initiated in 2012, such as sediment transport (Section 6.5), habitat
mapping (Sections 6.5 and 09.9), operations modeling (Section
8.5.4.2.2), and the Mainstem Open-water Flow Routing Model
(Section 8.5.4.3). The assessment will guide the need to extend
studies into the Lower River Segment.
AQHAB-02 FERC 11/14/12 “In section 8.5.3, Study Area, you describe your proposed
hierarchical habitat classification system. Please ensure that
the category descriptions, definitions, and terminology are
consistent with those presented in the Geomorphology Study,
Characterization and Mapping of Aquatic Habitats Study, and
any other related studies. For example, in Table 9.9-4, you
describe split-main and braided-main channel types, which are
not described in section 8.5.3. Moreover, in the description of
AEA has revised the terminologies for channel and habitat
category descriptions and definitions i to be consistent with
terminologies used in the Geomorphology Study, Characterization,
Mapping of Aquatic Habitats Study, and any other related studies.
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HSC Study Site Selection, you refer to a percolation channel, a
term that is not used elsewhere.” –pdf page 10
AQHAB-03 FERC 11/14/2012 “Section 9.9.5.4. Mainstem Habitat Mapping, indicates that
habitat mapping in mainstem habitats will be limited to linear
(mid-line) length estimates except for off-channel slough habitat
where areas will be mapped. Please clarify whether this area
polygon mapping is limited to side slough and upland slough
habitats, or whether other off-channel habitats will be included.
Please clarify whether measurements collected during on-the-
ground truthing will be used to estimate habitat areas or
conditions such as large woody debris loading and cover in
reaches not ground-truthed.” –pdf page 10
Section 9.09 is revised to clarify locations for line-mapping versus
polygon mapping and to clarify how on-the-ground mapping will be
used.
Referring to Table 9.9-4, of Study 9.9, main channel habitat will be
typed to Level 4 (Mesohabitat) throughout the entire Middle River
hydrologic segment using the line segment method. Mesohabitat
for Level 4 includes pool, glide, run, riffle, and rapid. Cascade
type is eliminated in the study, as there are no cascades in the
main channel of the Middle or Upper rivers.
Off-channel habitats will be typed to Level 3. Level 3 off-channel
habitat types include side slough, upland slough, backwater, and
beaver complex (these off-channel types are also referred to as
macrohabitat in the study. Level 3 Slough and Upland Slough
habitat types will be delineated by polygons as opposed to the
mainstem, which will be delineated by line segments. Section
9.9.5.4 is revised to clarify.
As stated in the Section 9.9.5.4, a sub-set of off-channel and main
channel habitat units will be ground mapped and will include
metrics described for tributaries, e.g. depth, width, wood, cover,
etc., as appropriate for off-channel and main channel habitats. In
addition, all off-channel and main channel types in the Instream
Flow Study Focus Areas will be surveyed. Measurements
collected during on-the-ground truthing will be used to estimate
habitat areas or conditions such as large woody debris loading
and cover in reaches not ground-truthed. Whether Focus Areas
are representative of the range of off-channel types in the Middle
river can then be determined.
AQHAB-04 USFWS 11/14/2012 “In general, the U.S. Fish and Wildlife Serve (Service) is
concerned with AEA’s approach of using geomorphic and
hydrologic classifications as a means of defining “fish habitat”.
Although the Service is not opposed to the geomorphic and
AEA disagrees with the USFWS statement that “the relationship
between these classification types [sloughs, side channels,
percolation channels, etc] and the distribution or abundance of any
fish species has not been established.” It is AEA’s opinion that the
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hydrologic classification of the Susitna River and its tributaries,
it should be clear that the relationship between these
classification types and the distribution or abundance of any
fish species has not been established. For example,
classification of a site as a side slough does not imply that
these sites provide unique fish
habitat characteristics. It should be clear that the classification
of these sites is based upon the
degree of connection to the main channel. This will have some
effect on fish habitat characteristics within this classification
type, but by no means defines fish habitat and should not be
referred to as a “habitat classification”.’ –pdf page 122
selectivity of these channel types by different species and life
stages in the Susitna and other rivers is well established.
Differential utilization by fish is due to differences in unique
microhabitats offered by the different types of channels. The
selection of the various channel types is based less on the degree
of connection to the main channel, as suggested by the USFWS,
than by the preference by different species and life stages of the
microhabitats contained in these different channel types.
Section 9.9.5.4 includes classification to mesohabitat type for the
main channel of the entire Middle and Upper rivers and to
tributaries within the zone of hydrologic influence in the Middle
River and the length of the study area for Upper River tributaries.
Regarding the use of the term “habitat”, unless AEA uses the
terms macro, meso, or micro, the term “habitat” is used in the
general context or meaning of the word.
AQHAB-05 USFWS 11/14/2012 “The next level of classification is defined as “meso-habitat”
and the PSP argues that mesohabitat classification is important
because, “it is at this level that fish selectively use different
habitats to support different life stages and functions,” and it is
at this level that Project effects Will be evaluated. The PSP
further splits the classification is into fast versus slow water.
Fast Water includes riffles and runs, and slow water includes
pools, which are further subdivided. There is no indication that
this classification based on water velocity is related to fish
habitat selection. This classification of flow types may be
applicable to Upper River tributaries, but is not applicable to
most of the other classifications. That is, it is not applicable to
classify main channels, side channels, tributary mouths, or
upland sloughs into riffles runs or pools. Classification to this
level is likely unrelated to “mesohabitats” selected by fish within
the Susitna River.” –pdf page 123
The study includes a separate classification system for the
mainstem versus tributaries. The nested and hierarchical
classification system for both tributaries and mainstem address
most of the USFWS comment.
AEA does not agree with the USFWS statement that “There is no
indication that this classification [fast versus slow water] based on
water velocity is related to fish habitat selection.” On the contrary,
inherent in any fish habitat classification system is the microhabitat
variable of water velocity. Velocity is a fundamental habitat-use-
criteria for differential utilization of habitat at both the species and
life stage levels. The use of fast and slow water at the higher
hierarchical level is standard and completely appropriate.
AEA agrees with the USFWS that the “fast and slow water”
hierarchical level is less applicable in the mainstem and more
applicable in the tributaries. This difference is reflected in the study
plan.
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AQHAB-06 USFWS 11/14/2012 “The Service recommends AEA develop a series of definitions
for river habitat classifications
(geomorphic, hydrologic, and fish-related) that will be used
consistently within and across all individual studies throughout
the PSP. The classification approach outlined in this PSP is
considered totally different from meso- and microhabitat
classification to be used in the instream flow analyses. The
distribution of meso- and microhabitats used in instream flow
analyses and developed from fish-habitat relationships is
described in our comments on the Instream Flow
Study Plan. Since the distribution of meso- and microhabitats is
unrelated to AEA’s proposed
geomorphic classification type (i.e., main channel, side-slough,
upland slough, etc.), measures
of microhabitat or Weighted Useable Area (WUA) within a
geomorphic type cannot be
extrapolated to represent all similar geomorphic classification
types and summed to obtain a value for the Middle River. Thus,
the proposed classification is unrelated to environmental
variables relevant to fish distribution and habitat site-selection.”
–pdf page 123
Habitat definitions and classifications in the study were revised
from the PSP to be more clear and consistent within and across all
studies, particularly the instream flow study and the
geomorphology studies.
Regarding USFWS’s microhabitat comment, microhabitat is
typically not mapped in habitat mapping. Habitat mapping stops at
the mesohabitat level. Microhabitat is generally “mapped and
measured” using an instream flow model as is proposed in Study
8.5. A fundamental assumption of PHABSIM or similar instream
flow method is that if mesohabitats are adequately represented in
the instream flow model then associated microhabitats will be
adequately represented in the instream flow model.
The nested and hierarchical channel and habitat classification
system as described in Section 9.09 is not designed or intended to
be representative of fish distribution or habitat site selection. Its
purpose is to determine the variability, distribution, frequency, and
structure of the range of habitat types in the study area available
for fish use.
AQHAB-07 USFWS 11/14/2012 “Although aerial video may be useful for habitat mapping, the
scale of delineation must be described in order to determine its
usefulness in conjunction with ground surveys. The frequency
and number of sites surveyed on the ground will also be
determined by the objective’s definition of scale.” –pdf page
123
The scale of delineation, application, and use of aerial video for
channel and habitat mapping and how it will be complemented
with ground surveys are described in detail in Sections 9.9.5.2 and
9.9.5.3..
AQHAB-08 USFWS 11/14/2012 “The remote imagery will only be used to cover the mainstem
channel and larger tributaries. It is unclear whether an attempt
will be made to cover sloughs and side-channels off the
mainstem with remote imagery even if there is sufficient open
canopy. In addition ground surveys in the upper reach will only
be conducted on the mainstem and tributaries. It is again
unclear what is meant by mainstem, does this include sloughs
and side-channels in the Upper River? The accuracy and
statistical significance of the data collected for habitat mapping
Off-channel habitats in both the Middle and Upper rivers will be
delineated and channel typed using a combination of still aerial
imagery, LiDAR, and, where visible using aerial video. A sub-set of
representative off-channel types will be ground mapped to the
mesohabitat level. This approach is clearly described in the
Section 9.9.5.4.
Mainstem is defined as all channel types within the zone of
hydrologic influence of the Susitna River. This includes tributaries
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would be compromised if some habitats are missed due to the
inability of aerial imaging to capture them.” –pdf page 123
up to the upper limit of hydrologic influence. The mainstem does
not include tributaries or ponds above the limit of hydrologic
influence.
As stated in the Sections 9.9.5.4.1 and 9.9.5.4.1, a sub-set of off-
channel and main channel habitat units will be ground mapped
and will include metrics described for tributaries, e.g. depth, width,
wood, cover, etc., as appropriate for off-channel and main channel
habitats. In addition, all off-channel and main channel types in the
Instream Flow Study Focus Areas will be surveyed.
Measurements collected during on-the-ground truthing will be
used to estimate habitat areas or conditions such as large woody
debris loading and cover in reaches not ground-truthed. Section
9.9.5.4.2.
AQHAB-09 USFWS 11/14/2012 “Ground surveys will be an important supplement to aerial
video mapping. Not only will ground surveys provide data for
habitats unidentifiable by aerial video mapping (due to
vegetative cover) but they will also be useful in evaluating video
mapping accuracy. Although it is mentioned in the methodology
that a subset of sites will be used to refine video mapping and
verify its accuracy, a standard of accuracy is not specified. A
standard of accuracy must be set before initiation of sampling
that determines the amount of ground-truthing data that must
be collected. Ground-truthing must also be conducted during a
similar flow as when the video was obtained or else it may
show more inaccuracies than actually exist.” –pdf page 123
Aerial video will only be used where the stream is clearly visible
and mesohabitat types are clearly discernible. Aerial video will
only be used for determining reach type, channel type, and
mesohabitat type.
Ground truthing will be used to both sub-sample the video
mapping and help “calibrate” the video mapper’s eye. Sections
9.9.5.3.2 and 9.9.5.4.2describes the details for the ground
mapping component.
Regarding reliability or “accuracy” of aerial video for habitat
typing,Section 9.9.5.3.1 describes testing of its reliability. The test
demonstrated the reliability of the method. The method has been
successfully applied on several FERC relicensings.
Mesohabitat typing is best done at a low to moderate flow. This is
the flow that visually best represents the habitat type that is
created by the underlying bed structure. Bed structure does not
change from flow to flow. Pools, riffles, runs, glides, etc are
created by the underlying channel, bed structure, and substrate.
AQHAB-10 USFWS 11/14/2012 “It is most concerning that the video mapping data will only be
collected in mid to late September when flows are expected to
Video mapping at a high flow would not be effective for delineating
habitat types. As described above in AEA’s response to comment
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be low and waters relatively clear. Although these conditions
may be the best for image quality (lack of vegetative cover),
sampling only during these conditions will alter the
classification results. Inundated habitats that are only present
during high flow would not be properly classified. A
classification scheme should be designed to be flow
independent and have sampling that occurs at both high and
low flows. This is especially important if these data are to be
combined with data from other studies to assess project effects
on aquatic habitat.” –pdf page 123
AQHAB-09, habitat mapping is best done at a low to moderate
flow. Video taping at a high flow would only show the spatial
extent of channel and floodplain inundation. Visibility into the
water column would be almost zero and habitat types, such as
pools, riffles, and runs would be indistinguishable. GIS maps
showing water depth and the water’s edge overlays using flow
routing results would be a much better tool for understanding the
spatial extent and inundation at high flow.
Also, the objectives of other study plans include consideration of
high flows. the Instream Flow Study, Section 8.5, includes
modeling microhabitat at multiple flows, including high flows. The
Geomorphology Study, Section 6.5, includes obtaining aerial still
imagery of the river at multiple flows.
AQHAB-11 USFWS 11/14/2012 “Once fish-habitat associations are understood, it will be
important to map the distribution of those habitats to determine
the percent of total available habitat lost due to the
impoundment.”
“The proportional distribution of fish habitat for different life
stages within or out of the inundation zone would be more
important, as this is the scale of impact, as opposed to impacts
that may modify reach-level habitat characteristic (i.e.,
pools/riffles, undercut banks, w:d ratios, LWD, etc.)”
“It is unclear whether off-channel habitats will be further
characterized by aerial methods as side sloughs, upland
sloughs, backwaters, ponds, or relic channels (as listed in table
7.9-1 of AEA’s PSP) or if they will be further classified into
meso-habitats.” –pdf page 124
Section 9.9 is revised to more clearly describe the methods to
determine the distribution and frequency of main channel and
tributary mesohabitats that may be lost due to impoundment in the
Upper River. Section 9.9.5.
AEA agrees with the USFWS statement that “the proportional
distribution of fish habitat for different life stages within or out of
the inundation zone would be more important, as this is the scale
of impact, as opposed to impacts that may modify reach-level
habitat characteristic (i.e., pools/riffles, undercut banks, w:d ratios,
LWD, etc.)”
Section 9.9.5 provides that the emphasis of habitat mapping in the
Upper River is the distribution and frequency of mesohabitat types.
These data will then be used in combination with fish habitat
associations (Fish Distribution and Abundance Study in the Upper
Susitna River, Section -9.05) to determine fish distribution and
relative abundance.
All Upper River off-channel habitat types in the main channel will
be typed and mapped to Level 3 as described in the Section
9.9.5.4.1. A representative sub-set will be mapped to Level 4
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(mesohabitat) as described in the RSP.
AQHAB-12 USFWS 11/14/2012 “Classification of main channel, tributary, and off-channel
locations should be used as a macro-habitat level classification,
as described in Service-recommended hierarchal nested
habitat table”.
“Tributaries could be further classified using traditional
geomorphic methods but could include water quality measures
to separate out lower-sloped stream with high dissolved carbon
and more moderate sloped clear-water streams.”
“A well-defined, lateral main-channel habitat classification may
be most important for characterizing the distribution of fish.
Juvenile salmonid abundance is likely greater along the stream
margins than in mid-channel, and greater along vegetated
banks with a complex distribution of velocities and depths than
adjacent to un-vegetated point bars. Fish use of off-channel
habitats appears to vary with water source. Groundwater
dominated side sloughs support sockeye and chum salmon
spawning, side sloughs and upland sloughs with a surface
water connection appear to provide important rearing habitat,
while upland sloughs habitat quality may vary with
concentration of dissolved oxygen.” –pdf page 124
AEA has not adopted USFWS’ recommended approach because .
. . . As described in Section [insert], the study applies the
hierarchical and nested channel and habitat classification system.
The study’s classification system embodies all of the habitat
constituents and levels (down to the mesohabitat level) that are
included in the recommended USFWS classification table
presented on page 126 of the USFWS Comment letter.
AEA does not agree that its classification system ignores the
fundamental influences of ground and surface water exchanges in
its classification system. Classification by slough, side channel,
upland slough, etc. inherently classifies channels and habitats of
different hydrology or connectivity to the main channel.
The habitat mapping method proposed in the study does not
extend to the microhabitat level, which is the typical limit of habitat
mapping. Microhabitat constituents of hydraulics, water quality,
substrate, and cover are “micro” mapped and analyzed by
application of an instream flow model such as PHABSIM.
The “lateral main channel” mapping method proposed in Section
09.9 maps and quantifies edge habitat separately from
mesohabitat typing (Section 9.9.5.5).
Also, as stated above, classification by slough, side channel,
upland slough, etc. inherently classifies channels and habitats of
different hydrology or connectivity to the main channel, thereby
differentiating between channel types and habitat types
preferentially selected by different species and life-stages.
AQHAB-13 USFWS 11/14/2012 “AEA’s purpose for pursuing this objective is unclear and
should be provided for adequate evaluation of the proposed
methodologies, data collection, and analysis.
The level of classification includes main channel and side
channel, tributaries, off-channel locations and lakes.
AEA has clarified the study objectives described in Section 9.9.2
regarding the Upper River..
Section 9.9.5.5 addresses lakes to be mapped that are potentially
inundated by the reservoir.
The study includes a nested hierarchical classification system that
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Classification of lakes is not provided but should include lake
surface area, perimeter, bathymetry and whether or not there is
a surface water connection to Susitna River tributaries. As with
the Middle River, we recommend initial classification of
tributaries using the Rosgen Classification method (Rosgen
1994), similar to the USFS Tier II habitat classification
described. This level of classification will be more useful than
classification of flows types. More specific habitat classification
should be based upon characteristics of fish-habitat
relationships important for fish within these tributaries. The
purpose and applicability for Tier III classification for Susitna
River tributaries should be clarified.” –pdf page 125
incorporates the FWS recommendations. Sections 9.9.5.3.2.1 and
9.9.5.3.2.2 described the habitat classification system for
tributaries.
Study methods described in Section 9.9 will provide necessary
data to quantify the spatial extent and types of habitat lost due to
inundation of the lower sections of Upper River tributaries.
Sections 9.9.5. and 9.9.5.3.
AQHAB-14 USFWS 11/14/2012 Though AEA agrees that the mesohabitat level is indeed
important to fish, exchanges of ground and surface water
operating at the macrohabitat scale, and manifesting
themselves locally at the microhabitat scale, should not be
ignored and habitat mapping should occur pursuant to the
necessary hierarchical model we have proposed.
The habitat hierarchy referred to in the PSP is inconsistent with
the text of the PSP and was seemingly developed for high-
gradient forested streams of the temperate coastal region. –pdf
page 126
Regarding USFWS’s microhabitat comment, microhabitat is
typically not mapped in habitat mapping. Habitat mapping stops at
the mesohabitat level. Microhabitat is generally “mapped and
measured” using an instream flow model as is proposed in Study
8.5. A fundamental assumption of PHABSIM or similar instream
flow method is that if mesohabitats are adequately represented in
the instream flow model then associated microhabitats will be
adequately represented in the instream flow model.
AEA does not agree that the classification system described in
Sections 9.9.5.3 and 9.9.5.5 ignores the fundamental influences of
ground and surface water exchanges in its classification system.
Classification by slough, side channel, upland slough, etc.
inherently classifies channels and habitats of different hydrology or
connectivity to the main channel.
Regarding a nested hierarchical classification system See AEA’s
response to comment AQHAB--13.
AQHAB-15 NMFS 11/14/2012 “NMFS requests the following changes to the habitat
classification system that is to be used for developing study
plans needed to determine the effects of this project. Level 1
classification should be based upon geomorphology and
applied to mainstem and tributary river segments. For example,
if the methodology proposed by Rosgen were applied, the main
NMFS suggests that the habitat classification system be in line
with geomophological characteristics that drive habitat
classification at the reach level. NMFS also suggests using the
Rosgen typing methodology.
Section 9.9 presents a nested hierarchical classification system
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stem Susitna River including side channels could be
considered as "D" channel type and tributaries primarily "A" and
"B" channel types. The exact methodology is less important
that the geomorphological characteristics that drive
classification at this level.” –pdf page 157
that AEA believes incorporates NMFS’ comments and
recommendations. Moreover, the classification system used in
Section 9.9 (and other dependent studies) must integrate with the
channel classification system used in the Geomorphology Study
Section 6.5. AEA’s habitat classification system described in the
Section incorporates concepts of the Rosgen classification
system.
A habitat classification system for tributaries is clearly described in
the Sections 9.9.5.3.2.1 and 9.9.5.3.2.2.
AQHAB-16 NMFS 11/14/2012 “The next level of classification should describe the variation in
habitat characteristics restrained by the upper level. AEAs PSP
is confusing because they attempt to force categories
developed for type "A" or "B" streams (using the Rosgen
classification methods again as an example). Classification
based upon variability in flow types, riffles, runs, pools,
cascades, etc., are applicable subdivision of type "A" or "B"
streams but not the mainstem Susitna. The USFWS classifies
habitats within the mainstem floodplain as primary channels,
flood channels, tributary mouths, spring channels or floodplain
ponds. This classification is similar to the classification
developed by the Alaska Department of Fish and Game in the
1980s and adopted by AEA which includes main channels, side
channels, side sloughs, upland sloughs, and tributary mouths.
We believe that differences between these two habitat
classification methods can be reconciled by defining these
classifications.” –pdf page 157
Regarding a nested hierarchical classification system, see AEA’s
response to comment AQHAB-15.
AQHAB-17 NMFS 11/14/2012 “The next level of classification within these "macro-habitats"
should be developed based upon characteristics that influence
fish distribution. These meso-habitats should be selected that
describe the variability in fish among macro-habitat types.
Current AEA proposed classification methods do not capture
classification at this level. NMFS recommends continued
discussions to develop appropriate classification at this level.” –
pdf page 157
The study presents a nested hierarchical classification system
that incorporates NMFS’ comments and recommendations.
Moreover, the classification system used in study (and other
dependent studies) must integrate with the channel classification
system used in the Section 6.5. AEA’s habitat classification
system described in the RSP incorporates concepts of the Rosgen
classification system.
The study presents a nested hierarchical classification system that
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incorporates the NMFS recommendation to apply a different
classification system for Upper River high gradient tributaries than
for the large low-gradient floodplain rivers of the mainstem Susitna
River. The two classification systems are clearly described in
Sections 9.9.5.3 and 9.9.5.5.
AQHAB-18 NMFS 11/14/2012 “The limitations of aerial video and remote imagery should be
established through ground surveys. This was not shown in the
PSP. Although aerial video may be useful for habitat mapping
the scale of delineation must be described in order to
determine its usefulness in conjunction with ground surveys.
The frequency and number of sites ground surveyed will also
be determined by the objective's definition of scale. The remote
imagery will only be used to cover the mainstem channel and
larger tributaries. It is unclear whether an attempt will be made
to cover sloughs and side-channels off the mainstem even if
there is sufficient open canopy. In addition ground surveys in
the upper reach will only be conducted on the mainstem and
tributaries. The accuracy and statistical significance of the data
collected for habitat mapping would be compromised if some
habitats are missed due to the inability of aerial imaging to
capture them. Ground surveys should be used to classify
habitats that cannot be visualized with remote imagery or
videos. –pdf page 157”
See AEA’s response to comment AQHAB-9.
AQHAB-19 NMFS 11/14/2012 “Ground surveys will be an important supplement to aerial
video mapping, but their application toward determining the
accuracy of aerial videos is needs to be adequately described.
Not only will ground surveys provide data for habitats
unidentifiable by aerial video mapping (due to vegetative cover)
but will be useful in evaluating video mapping accuracy.
Although it is mentioned in the methodology that a subset of
sites will be used to refine video mapping and verify its
accuracy a standard of accuracy is not specified. A standard of
accuracy must be set before initiation of sampling that
determines the amount of ground-truthing data that must be
collected. Ground-truthing must also be conducted during a
similar flow as when the video was obtained or else it may
.See AEA’s response to comment AQHAB-9.
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show more inaccuracies than actually exist. Therefore,
methods must be developed to evaluate the accuracy of habitat
mapping based upon aerial videos.” –pdf page 157
AQHAB-20 NMFS 11/14/2012 “Video was conducted in early September, 2012, when flows
were low (10,000 cfs) and the water was relatively clear.
Habitat mapping using video imaging from fall after leaf-off can
result in inaccurate classification of habitats due to low flow
conditions. This may result in erroneous meso-habitat
classification due to differences in backwater at different stage
heights. Although these conditions may be the best for image
quality (lack of vegetative cover), sampling only during low-flow
conditions is inadequate. Habitats that are only present during
high flow would not be properly classified. A classification
scheme should be designed that is independent of and
sampling needs to be done during both high and low flows.
This is especially important if these data are to be combined
with data from other studies to assess project effects on
aquatic habitat.” –pdf page 158
See AEA’s response to comment AQHAB-9.
AQHAB-21 NMFS 11/14/2012 “The purpose for the application of this classification method to
upper river tributaries and mainstem locations within the
inundation zone is unclear. The PSP does not describe this
objective's purpose. We ask that AEA write a clear, direct
objective purpose with the following considerations. We are
unsure, given AEA's limited resources, why this is being
conducted. The upper river mainstem within the impoundment
zone should be classified to the macrohabitat level (i.e. off-
channel habitats) to determine the overall distribution offish
habitat. It is unclear within the PSP whether off-channel
habitats are to be further characterized by aerial methods as
side sloughs, upland sloughs, backwaters, ponds, or relic
channels (as listed in table 7.9-1 of AEA's PSP) or if they will
be further classified into meso-habitats. If off-channel habitats
are not being further delineated and mapped then the reasons
for this limitation within the objective must be detailed. Although
there may be a limited number of off-channel habitats
compared to the Middle reach they may contain unique and
AEA has clarified the Study Objective 3 regarding study objectives
in the Upper River. Section 9.9.2.
Study methods described in the study will provide necessary data
to quantify the spatial extent and types of habitat lost due to
inundation of sections of the Upper River tributaries. Section 9.9.5.
and 9.9.5.3..
Sections 9.9.5.4.1 and 9.9.5.4.1 describes the methods for
mapping off-channel habitat types.
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abundant suitable habitat for a variety of species and should be
addressed.” –pdf page 158
AQHAB-22 NMFS 11/14/2012 “NMFS supports the classification of the Susitna River into
macro-habitats based upon channel morphology and water
quality as proposed once differences with USFWS
classification methods have been worked out, but believes that
the PSP fails to adequately classify habitat. As stated in our
general comments, additional discussions among agencies and
AEA will need to establish applicable meso- and micro-habitat
classification methods. The current AEA PSP classification of
meso- and micro-habitats is unclear and needs to be refined.
The Fish and Aquatics TWG are developing a Susitna River
classification system based off of the USFS Aquatic Habitat
Surveys Protocol (USFS 2001). It is stated in the PSP that the
TWG will make adjustments and modification to the protocol
where necessary; however, in TWG meetings it has been
detailed that these procedures will be modified in the field
(TWG meeting Oct 25,2012). While it is expected that methods
may have to vary depending on what challenges arise in the
field, more detail needs to be provided within the study plan
describing initial methods for review. The USFWS previously
recommended the use of micro-habitat classifications for large
rivers, such as Beechie (2005). Although this habitat
classification scheme will be useful for a possible framework,
the uniqueness of the Susitna River system must be kept in
mind. The USFS habitat classification is based on data
collected from southeastern Alaskan streams (USFS 2001) and
will likely require many modifications to be suitable for the
Susitna River and associated tributaries and off-channel
habitats.” –pdf page 159
The study includes a nested hierarchical classification system,
which incorporates the NMFS recommendations. Sections
9.9.5.3.2.1 and 9.9.5.3.2.2 includes a habitat classification system
for tributaries.
AQHAB-23 NMFS 11/14/2012 “The variability in habitat characteristics within each macro-
habitat will be important for our understanding of factors
influencing fish distribution and production and are likely to be
characteristics influenced by project operations. Therefore,
clear definitions of classification at this level will need to be
established. Lateral main channel habitat classification may be
Section 9.9.5.3.2.1 includes a clear definition of the Tier Levels
and macrohabitat and mesohabitat types in both tributaries and
the mainstem. Categorization by slough, side channel, and upland
slough inherently classifies channels and habitats into different
degrees of hydrology or connectivity to the main channel.
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most important for the distribution of fish. Juvenile salmonid
abundance is likely to be greater along the stream margins
than in mid-channel, and greater along vegetated banks with a
complex distribution of velocities and depths than adjacent to
unvegetated point bars (micro-habitat classification outlined
below). Fish use of off-channel habitats appears to vary with
water source. Ground-water dominated side sloughs support
sockeye and chum salmon spawning, side sloughs and upland
sloughs with a surface water connection appear to provide
important rearing habitat, while upland slough habitat quality
may vary with concentration of dissolved oxygen.” –pdf page
159
AEA will map and analyze microhabitat constituents of hydraulics,
water quality, substrate, and cover through applying an instream
flow model such as PHABSIM.
AQHAB-24 NMFS 11/14/2012 “NMFS believes that the study area must extend below RM 28
because the project effects may reach further than areas the
PSP projects. Lastly, state and federal agencies have resource
responsibilities and authorities that extend below RM 28. These
include, but are not limited to the aquatic resources within the
Susitna Flats State Game Refuge, beluga whales and their
habitats, and anadromous and resident fish and their habitats.
We remained concerned with the stunting of the proposed
project-effects boundary at RM 28, and the fact that project
impacts are not proposed to be assessed within the full extent
of natural resource agencies management authority. The
applicant refers to RM 28 as the "potential zone of project
hydrologic influence" without any documentation or validation of
this claim. Resource agencies have repeatedly expressed
concern with this designation.” –pdf page 159
See AEA’s response to comment AQHAB-01.
AQHAB-25 NMFS 11/14/2012 “The purpose for classifying tributaries and lakes upsteam from
the inundation zone, is unclear and should be clarified. Clear
objectives and the purpose for the study are necessary for
evaluation of the proposed methods. If classification is being
conducted to quantify remaining post-project habitat, then the
relationships between fish species and macro- meso- and
microhabitat characteristics must also be established. Current
upper river fish study plan methods have not been developed
to establish these relationships.” –pdf page 160
Regarding “Study Objective 3” See AEA’s response to comment
AQHAB-13.
AEA agrees that the emphasis of habitat mapping in the Upper
River (Section 9.9.5) is the distribution and frequency of
mesohabitat types. These data will then be used in combination
with fish habitat associations (Fish Distribution and Abundance
Study in the Upper Susitna River – Section 9.5) to determine
relative use of habitat types relative abundance.
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AQHAB-26 NMFS 11/14/2012 “We recommend initial classification of tributaries using the
Rosgen geomorphic classification method (Rosgen 1994),
similar to the USFS Tier II habitat classification described. This
level of classification could be followed by the classification of
flow types. More specific habitat classification should be based
upon characteristics of fish-habitat relationships important for
fish within these tributaries (similar to micro-habitats listed
below for the mainstem Susitna). Further classification of lakes
is not provided but should include lake surface area, perimeter,
bathymetry and whether or not there is a surface water
connection to Susitna River tributaries. The purpose and
applicability for Tier III classification for Susitna River tributaries
should be clarified as they were likely developed to evaluate
potential effects from timber harvesting that can result in
changes in peak flows, fine sediments, and L WD input. The
influence of woody debris on channel morphology and the
creation of slow-water habitats, for example, is likely much
different in the Tongass Forest than in the high elevations of
upper river tributaries.” –pdf page 160
Regarding a nested hierarchical classification system See AEA’s
response to comment AQHAB-15.
Section9.9.5.5 includes mapping of lakes that are potentially
inundated by the reservoir.
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RESFSH-01 NMFS 11/14/2012 “NMFS requests that future fish population development scenarios
include alternatives that consider development of resources that would
benefit commercial and subsistence fisheries in addition to the PSPs
goals of creating sportfishing and recreational opportunities.” – pdf
page 162
AEA concurs with the request to include evaluation of the
potential development of a future reservoir that may
support commercial and subsistence fisheries as a
management alternative for the future reservoir fish
community. The Study includes this evaluation as an
objective (see Section 9.10.1.1) and task (see task 4 in
Section 9.10.4.2).
RESFSH-02 NMFS 11/14/2012 “NMFS recommends that the upper river enhancement potential for
salmon be reconsidered today as an alternative for the future reservoir
fish community. In addition to providing recreational benefits, the
proposed Watana reservoir has the potential to provide for enhanced
commercial and subsistence fisheries and ecological values in the
entire watershed and beyond: to the species marine habitats of the
Gulf of Alaska. Instead of or in addition to sport fisheries and
recreational opportunities, NMFS recommends studying the potential
for enhancement of commercial and subsistence fisheries within the
future reservoir. In addition to Chinook, which are known to inhabit the
upper river, NMFS recommends studying the potential for the reservoir
and upper river to support sockeye, chum and possibly Coho salmon.”
– pdf page 163
Although currently available information suggests that
under the current flow regime only Chinook are able to
navigate the rapids at Devils Canyon, AEA concurs with
the request to include an assessment of the enhancement
potential for Chinook, sockeye, chum, and Coho salmon
within the future reservoir fish community and entrainment
analysis (see Section 9.10.2). The evaluation of the
potential establishment of new fisheries is beyond the
scope of this study as it would require Alaska State
regulatory change and state commission actions.
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PASS-01 CSDA 11/14/2012 “Fish Passage Study: This is a necessary study in order for NMFS
to determine the need and feasibility of fishway prescriptions
which they have to do under federal law. This study should span
at least 5 years and preferably 7 years. It is directly tied into the
investigation into the salmon species that are migrating above
Devil’s Canyon.” – pdf page 3
As explained in Section 9.11.2, both adult and juvenile Chinook
salmon have been documented upstream of the proposed
Watana Dam site. In addition there are other migratory species for
which distribution has been documented both upstream and
downstream of the proposed dam. Thus, this study address the
engineering feasibility of designing fish passage facilities to
provide an effective means of passing these fish species around
the proposed dam. As described in Section 9.11.4 Task 2, the
study will begin with a review of biological data available from the
5 years of study in the 1980s as well as additional studies recently
conducted in the upper river. The study will incorporate new
information collected by AEA in 2012, 2013, and 2014. These
data will provide the basis of the feasibility assessment.
Furthermore, critical information needs will be evaluated by the
Fish Passage Technical Workgroup (TWG) at the beginning of the
study with the intent of incorporating those data needs into 2013
and 2014 data collection efforts (see Section 9.11.4 Task 1).
Additional years of data collection are not needed to improve the
quality of the data necessary to determine passage feasibility.
See also AEA’s response to comment FISH-01 and FISH-02.
PASS-02 Ransy, Denis 11/14/2012 “Serious studies must be done on fish passage above the dam
because we are going to preserve the salmon that do migrate
above the dam site. We need to know exactly how many and
what species they are.” – pdf page 1
AEA has planned for multiple studies to address distributions and
movements of fish above and below Devils Canyon. Objectives of
these studies are described in Section 9.5.1 and 9.6.1 and
methods to accomplish these include: 1) radio-tagging adult
Pacific salmon and resident migratory fishes, 2) fish tagging and
trapping, and 3) year round fish sampling at more than 200
different sites within the Middle and Upper River. The Study of
Fish Passage Feasibility at Watna Dam will be initiated using
existing data and will incorporate data from the new studies as it
becomes available. See Section 9.11.7 and Figure 9.11-1 for
details regarding interdependencies between these studies and
the Fish Passage Study.
PASS-03 NMFS 11/14/2012 NMFS would like to stress that this guidance does not indicate
that in any way that cost benefit analysis can be used to
determine whether fish passage is necessary on the basis of
benefits exceeding costs. The proposed study plan should be
As described in the AEA’s response to comment PASS-08, the
study has included economic factors in the feasibility study solely
for evaluating the cost effectiveness of various fish passage
alternatives. This study is limited to analyzing the feasibility of fish
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revised to clarify that consideration of economic factors is limited
to evaluating the cost effectiveness of various fish passage
alternatives and will not be a factor in NMFS’s determination of
whether fish passage will be prescribed. – pdf page 172
passage and does not analyze the benefits of fish passage at the
proposed Project. Whether AEA includes fish passage as part of
its proposed Project, however, will depend on a more
comprehensive analysis that examines the benefits of fish
passage to the species compared with the costs of fish passage
and with the benefits and costs of alternative mitigation measures.
Further, AEA does not agree that economic factors are irrelevant
to NMFS' determination of whether fish passage will be
prescribed. See Section 33 of the Federal Power Act (as added
by section 241 of EPAct 2005).
PASS-04 USFWS 11/14/2012 “The Services provided generic guidance on methodology and
information needs for determining fish passage feasibility...” and
requesting planning begin with early coordination with Resource
Agency Engineers starting with site reconnaissance and review of
preliminary engineering design. – pdf page 129
AEA’s study plan follows the generic guidance provided by the
Services. Because these guidelines were developed primarily to
address fish passage at existing hydro-electric developments
(pers comm Ed Meyer NMFS Fish Engineer, October 18, 2012),
AEA has tailored them to specifically address the feasibility of fish
passage at a new hydro-electric development. As such, the
Service’s Design Development Phases 1 -3 were directly
incorporated in Tasks 2-5 (Section 9.11.4). Design Development
Phases 4 and 5 were not included as Preliminary and Final
Design are steps that follow after a feasibility study is completed
and alternatives are selected. Section 9.11.4 lists biological,
physical, and Project operations data that will be compiled for this
feasibility study.
As described in AEA’s response to comment PASS-02, AEA
engaged NMFS Fisheries Engineer, Ed Meyer on two occasions
in Fall 2012 to discuss feasibility study planning. AEA participated
in a two-day meeting on September 24th and 25th and AEA
Consultants had a teleconference with Ed on October 18, 2012.
AEA’s proposed schedule (Section 9.11.6 and Table 9.11-1)
acknowledges that a site reconnaissance is scheduled for Q2
2013, which will allow viewing of proposed dam and facility sites
without snow/ice. In addition, a workshop for the Fish Passage
Technical Workgroup will be convened at the end of the first
quarter 2013. This will allow time for assembly and synthesis of
existing relevant biological and engineering data to present to the
Fish Passage Technical Workgroup.
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PASS-05 USFWS 11/14/2012 “The three-year limit of the study period is inadequate to
understand adult salmon migrations especially at a time when
stocks, particularly Chinook salmon, are low and their abundance
above the project may be drastically reduced. We recommend
that fisheries surveys be conducted for at least one average life
span of each salmon species, which is an average of five years
for Chinook salmon (range to seven years). This is needed to
obtain the minimum amount of biological information about the
population that is necessary to develop and design mitigation, and
determine the need for fish passage.” – pdf page 134
Section 9.11 does not address the need for passage. As
described in Section 9.11.1, the study presumes a need for
passage exists and addresses whether and what engineering
options are feasible to provide passage.
As described in Section 9.11.4 Task 2, the study will begin with a
review of biological data available from several years of study in
the 1980s as well as additional studies recently conducted in the
Upper River. The study will incorporate new information collected
by AEA in 2012, 2013, and 2014. These data will provide the
basis of the feasibility assessment. Furthermore, as described in
Section 9.11.4 Task 1, critical information needs will be evaluated
by the Fish Passage Technical Workgroup at the beginning of the
study with the intent of incorporating those data needs into 2013
and 2014 data collection efforts. AEA expect that the existing and
proposed (2012-2014) data collection efforts will be sufficient to
determine passage feasibility.
PASS-06 USFWS 11/14/2012 7.11.2. Existing Information and Need for Additional Information
The PSP states that there is currently no specific engineering
information and little biological information to provide a basis for
determining the need for and feasibility of passage at the
proposed dam. The biological need for passage is an issue
independent of the engineering feasibility; these issues should be
analyzed separately. While the Service agrees that there is little
biological information for the upper river, it has been known since
1982 that Chinook salmon pass upstream of the Devils Canyon
and spawn successfully in the upper Susitna River. It is the
professional judgment of the ADF&G Susitna Hydro Aquatic
Studies Team made in 1982 that juvenile Chinook salmon are
produced in the upper Susitna River (ADF&G 1983). The
outstanding biological questions relate to the population size,
productivity, and habitat availability and use, rather than whether
there is a biological need for Chinook salmon, possibly other
salmon species, and other anadromous and resident species to
migrate through the proposed dam site to habitat used for
spawning, incubation, rearing, and migration.” – pdf page 134
AEA concurs that biological need should not be an objective of
the Study of Fish Passage Feasibility at Watana Dam. As
described in Section 9.11.1, AEA will assess whether to propose
fish passage based on the results of other studies and other
available information along with input from federal and state
agencies and other licensing participants.
PASS-07 USFWS 11/14/2012 The Service has not concurred with AEA’s use of target species The Study of Fish Passage Feasibility at Watana Dam proposes
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due to the paucity of information regarding fish passage at
Watana. – pdf page 134
identification of all potential target species to help make informed
decisions about passage facilities (i.e., consideration of location
downstream collection options, and/or effectiveness of a surface
or at depth collector). It is not the intent to limit passage
alternatives to a reduced number of species. In fact it is the
opposite. Target species are noted during the passage feasibility
study to make sure that the conceptual design of passage
brackets the full range of fish that may benefit from passage
including for example, weak swimmers, anguilliform versus
fusiform swimmers, bottom versus surface swimmers. Specifics
about the biology of target species are used to address selection
between options. All available information will be included to
ensure that the passage feasibility study considers all migratory
species/life stages, anadromous and resident, with the potential to
pass upstream or downstream of the proposed dam site. The
target species will be identified as part of Task 2 in Section
9.11.4.
PASS-08 USFWS 11/14/2012 The Service does not support limiting a range of options by
including costs in the comparison matrix. – pdf page 135
AEA concurs that all passage option should be considered during
feasibility and none should be eliminated on the basis of cost at
this feasibility phase. AEA proposes to keep cost as one of the
criteria for the Pugh Matrix. As described in the Section 9.11.4
Task 5, the matrix is not used to choose an alternative but is used
to compare components across conceptual alternatives. It will
influence but not dictate decisions. With use of the matrix, the
effectiveness of passage facilities will be evaluated and the
results used to refine and optimize each alternative. Cost is one of
many criteria that may be helpful to compare across two
components, such as trap and haul by truck versus trap and haul
by helicopter, that have been previously determined to be equally
effective at accomplishing the stated objective. It is important as
part of the feasibility study to rank or compare between
alternatives and that is where the multiple criteria will be relevant
and will be used.
PASS-09 USFWS 11/14/2012 “Section 7.11.6. Schedule
There appears to be a disconnect regarding when some of the
biological information from the studies will be available and the
AEA agrees that the Study of Fish Passage Feasibility at Watana
Dam will need to incorporate new information as it is obtained and
selecting and refining alternatives will likely be an iterative
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initiation of the conceptual design process. For example, a lot of
the biological information on juvenile, adult or smolt passage will
not be available until the 2013/2014 time frame and the
conceptual alternative are supposed to be completed by 2013.
This means that it may be necessary to revisit the conceptual
alternative design assumptions based upon any new data and
update the designs as necessary.” – pdf page 135
process. To allow for this iteration, the study include regularly
scheduled meetings and workshops that will be conducted
(Section 9.11.6) with the Fish Passage Technical Workgroup
throughout the duration of the study.
PASS-10 USFWS 11/14/2012 “The study plan should be organized to address the Service’s
information needs and study requests in sufficient detail to
determine what parts of our study request are adopted, what parts
are not; and if not, why not. AEA has not identified the differences
between our study request and their study, nor explained where
and why they did not address our requests.” – pdf page 136
The study plan has been organized to address the generic
guidance provided by the Service and to accommodate steps and
information needs identified in the Design Development Phases.
See AEA’s response to comment Pass-04. Steps 1-3 from the
Service’s study request are directly incorporated into Tasks 2-5
(see Section 9.11.4). Task 1 of Section 9.11.4 incorporates the
collection of the necessary information to inform a feasibility
study.(see comment-response PASS-04), AEA will compile and
synthesize all of the information as detailed in The Service’s
Study Request. More specifically biological, site specific and
operational information that is available and deemed relevant to
fish passage will be compiled and synthesized starting in January
2013. It is important to note that the NMFS guidelines list data
that are needed to inform Preliminary Design Development and
that this step is one beyond feasibility. However, AEA
understands the need for much of this data to address feasibility
and will provide information on all topics listed in the study
requests at a sufficient level of detail to understand intended
project details and operation. A synthesis of this information will
be presented to the Fish Passage Technical Workgroup at the Q1
2013 meeting to evaluate additional data needs.
AEA does not propose collecting operational information detailed
by the Service’s items 3-7 as these items are generally accepted
as needs for preliminary design in order to determine
compatibility between facility design specifications and
operations, which will occur after the feasibility analysis. These
items fall outside the level of detail necessary for feasibility
assessment.
PASS-11 USFWS 11/14/2012 “The Service continues to recommend that fisheries surveys be See AEA’s response to comment FDAUP-01.
Revised Study Plan
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
conducted for at least one generation of each salmon species,
which is an average of five years for Chinook salmon (range to
seven years). This is needed to obtain the minimum amount of
biological information about the population that is necessary to
develop and design mitigation, and determine the need for fish
passage for this project.” – pdf page 136
PASS-12 USFWS 11/14/2012 “The proposed study indicates that the biological need for fish
passage will be determined, and that this is linked to the
economic costs of providing passage. The biological need for
passage exists: anadromous fish are known to spawn and rear
upstream of the proposed dam. The biological information
requested is necessary to determine the engineering feasibility of
designing effective up and downstream passage of fish and to
determine the ecological and socioeconomic losses that would
result from not providing passage. This determination must be
informed by fish surveys consisting of at least one average life-
span of each salmon species.” – pdf page 137
See AEA’s response to comment PASS-06.
PASS-13 USFWS 11/14/2012 The RSP should include three dam design alternatives: 1) a dam
design that integrates fish passage, 2) the current dam designed
without passage and with retrofitted passage facilities, and 3) the
current dam with no passage facilities. The schedule as proposed
include conceptual alternative development in August 2013 and
this is too late to all for a full range of options for fish passage to
be considered without adding unnecessary expense and delays
into the project. – pdf page 137
Section 9.11.1 describes that the alternatives developed under
this feasibility study will address the three dam design alternatives
proposed by the Service. The proposed schedule, Table 9.11-1,
in the RSP has conceptual alternative development occurring
from July 1 through December 30, 2013 and then the Feasibility
of Alternative and Alternative Refinement occurring in 2014. This
schedule was designed to integrate passage concepts into the
overall dam design schedule, fits well within two year ILP
timeframe and is design to allow for iteration and a full
consideration of all passage options considering the influx of
biological data from 2012 -2014 studies.
PASS-14 USFWS 11/14/2012 “In addition to the general physical information at the project site,
specific hydrologic and hydraulic (including project operations)
information should be provided for the fish passage season (both
upstream and downstream passage) along with other physical
information such as expected debris loading, ice conditions,
expected sediment transport (as it affect passage facilities),
expected forebay and tailwater rating curves, project operation
Task 1 of theStudy of Fish Passage Feasibility at Watana Dam
(Section 9.11.4) incorporates the collection of the necessary
information to inform a feasibility study. AEA will compile and
synthesize all of the information as detailed in the Service’s Study
Request. More specifically biological (Service’s items 1-15), site
specific (Service’s items 1-11) and operational (Service’s items 1,
2, 8-14) information that is available and deemed relevant to fish
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
information (rule curve, restrictions, etc.), river morphology trends,
predatory species expected, downstream sites for a barrier
dam/trap and haul operation, size of upstream and downstream
migrants (fry versus smolt), etc.” – pdf page 137
passage will be compiled and synthesized starting in January
2013. This information will be presented to the Fish Passage
Technical Workgroup at the first workshop in March to assess
additional data needs.
PASS-15 USFWS 11/14/2012 “The Service requests that AEA provide a comparison of our
study request with their draft RSP, and identify any unaddressed
study request components. The Service also requests that AEA
identify the relationships among the 2012 pre-ILP studies, the
suggested ILP studies, define the timing of related studies, and
explain how these studies will be completed within the ILP study
planning, study dispute, and study completion schedules.
Completing these tasks would greatly benefit the licensing
process.” – pdf page 137
See AEA’s response to comment PASS-10 for comparison
between the USFWS study request and this study plan. Section
9.11.7 and Figure 9.11-1 address interdependencies across the
pre-ILP and ILP studies and defines the timing of the information
flow. The schedule that outlines completion of studies and study
deliverables is presented in Section 9.11.6 and Table 9.11-1.
PASS-16 NMFS 11/14/2012 The comment includes the follow component:
a- The PSP is very brief and does not address NMFS
information needs [listed in the comments as Design
Development Phases (NMFS comment at page 142),
b- Preliminary Design Development – Required Site
Information (NMFS comment at page 143),
c- Preliminary Design Development – Required Biological
Information (NMFS comment at page 144), and
Assessment of Operation Impacts on Fish Passage for
the Proposed Project information (NMFS comment at
page 145-146))and study requests in sufficient detail to
determine what parts of our study request are adopted,
what parts are not and if not why not.
AEA has not identified the differences between our study request
and their study or explained where and why they did not address
our requests. NMFS requests again through this filing that the
study plan determination include the elements NMFS seeks in
order to inform any fish passage prescription under Section 18 of
the FPA. – pdf page 171
As part of the AEA collaborative process to resolve outstanding
issues related to the development of study plans (as described in
Section 1), on September 24 and 25, 2012, AEA, NMFS, and
other state and federal agencies and licensing participants had
meetings on the Study of Fish Passage Feasibility at Watana
Dam. Based upon feedback from NMFS and others during the
meetings, AEA made substantial revisions to the Study of Fish
Passage Feasibility at Watana Dam. RSP 9.11 includes these
revisions. AEA believes that this study plan is now responsive to
the NMFS information needs regarding fish passage feasibility.
As explained in Section 9.11.4, the feasibility evaluation includes
six tasks needed to determine fish passage technical feasibility for
the Project. This study generally follows the guidance provided in
the NMFS Anadromous Salmonid Passage Facility Design
document (NMFS 2011). These tasks are summarized below:
1. Establish a Fish Passage Technical Workgroup to provide
input on the feasibility assessment.
2. Prepare for feasibility study.
3. Conduct site reconnaissance.
4. Develop concepts.
5. Evaluate feasibility of conceptual alternatives.
6. Develop refined passage strategy(ies).
This study follows the generic guidance provided by the Services.
Revised Study Plan
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Study of Fish Passage Feasibility at Watana Dam
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
Because these guidelines were developed primarily to address
fish passage at existing hydro-electric developments (pers comm
Ed Meyer NMFS Fish Engineer, October 18, 2012), AEA has
tailored them to specifically address the feasibility of fish passage
at a new hydro-electric development.
Regarding component a, the identified information needs related
to Design Development Phases (NMFS comment at page 142),
the study includes all of the numbered items except for 4 and 5.
The RSP has not included these items because they comprise
Preliminary and Final Design phases that by necessity follow the
completion of a feasibility study. As indicated within the
description of these phases within the guidelines document and
comment text (NMFS 2011 at [Insert]), preliminary design occurs
after a preferred alternative has been selected.
Regarding components b, c, and d, Preliminary Design
Development – Required Site Information (NMFS comment at
page 143), Preliminary Design Development – Required
Biological Information (NMFS comment at page 144), and
Assessment of Operation Impacts on Fish Passage for the
Proposed Project information (NMFS comment at pages 145-
146), the RSP includes compilation and synthesis of information
under all of the numbered items. As the heading in the NMFS
guideline document and comments suggest, much of the
information listed in the numbered items is required for the
Preliminary Design Development Phase. However, AEA
understands the need for some of this data to address feasibility
and will provide information on all numbered items at a sufficient
level of detail to understand intended project details and
operation. A synthesis of this information will be presented to the
Fish Passage Technical Workgroup at the first quarter of 2013
and will assist with evaluating additional data needs.
PASS-17 NMFS 11/14/2012 “Existing Information and Need for Additional Information
The PSP states that there is currently no specific engineering
information and little biological information to provide a basis for
determining the need for and feasibility of passage at the
proposed dam. The biological need for passage is an issue
See AEA’s response to comment PASS-06
Revised Study Plan
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FERC Project No. 14241 Page 358 December 2012
Study of Fish Passage Feasibility at Watana Dam
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
independent of the engineering feasibility; these issues should be
analyzed separately. While NMFS agrees that there is little
biological information for the upper river, it has been known since
1982 that Chinook salmon pass upstream of the Devil Canyon
and spawn successfully in the upper Susitna River. It is the
professional judgment of the ADFG Susitna Hydro Aquatic
Studies Team made in 1982 that juvenile Chinook salmon are
produced in the upper Susitna River (ADFG 1983).” – pdf page
173
PASS-18 NMFS 11/14/2012 “7.11.4.1. Compile, Review and Summarize Information
NMFS has not concurred with ABA's suggested use of target
species for fish passage, in large part due to the paucity of
information regarding the species, life stages and timing of fish
passage at Watana. It may be both desirable and possible to
select a smaller range of target species and life stages, once the
information from the following studies is available: – pdf page 173
See AEA’s response to comment PASS-07.
PASS-19 NMFS 11/14/2012 “7.11.4.3. Define and Document a Development Process
NMFS agrees that a process should be discussed to establish
appropriate evaluation criteria for different fish passage
alternatives. However, it is inappropriate to unduly limit the range
of fish passage options under consideration from a biological and
engineering standpoint by the including estimated costs
associated with facilities into a weighted comparison matrix. In
determining which alternatives are considered for further analysis
of fish passage, the biological goals, objectives and concerns and
the technical issues such as constructability, climate and logistical
considerations, operations, etc. should be assessed.” – pdf page
173
See AEA’s response to comment PASS-08.
PASS-20 NMFS 11/14/2012 “At this stage, biological information and criteria should be
gathered, and a full range of engineering options should be
pursued, including novel ones. No alternative should be rejected
based on currently operative assumptions about cost at the
feasibility stage. If AEA's suggested process were to be followed,
then the development of suitable fish passage could be seriously
limited or even excluded from the onset, and FERC's ability to
AEA concurs that all available information should be gathered, all
relevant criteria consider and a full range of engineering options
considered. This is the intent of Task 4 (see Section 9.11.4). See
also AEA’s response to comment PASS-14.
To specifically address including cost as a criteria for the Pugh
Matrix, please See AEA’s response to comment PASS-08.
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produce a license order in compliance with federal environmental
laws could be unnecessarily hampered.” – pdf page 174
PASS-21 NMFS 11/14/2012 “7.11.6. Schedule
There appears to be a disconnect regarding when some of the
biological information from the studies will be available and the
conceptual design process. For example, a lot of the biological
information on juvenile, adult or smolt passage will not be
available until the 2013/2014 time frame, but the conceptual
alternatives are supposed to be completed by 2013. This means
that it may be necessary to revisit the conceptual alternative
design assumptions based upon any new data and update the
designs as necessary, which may be wasteful of applicant and
agency resources and result in avoidable delays.” – pdf page 174
Section 9.11.7 and Figure 9.11-1 describe the interdependencies
among the Study of Fish Passage Feasibility at Watana Damand
other ILP studies and specifically address the timing and the flow
of information into the Feasibility Study. Furthermore the schedule
(Section 9.11.6 and Table 9.11-1) is designed to allow for the
iterative exchange of information and refinements to conceptual
designs and passage alternatives.
For details on correspondence throughout the study, See AEA’s
response to comment PASS-09.
PASS-22 NMFS 11/14/2012 “The RSP should be organized to address NMFS' s information
needs and study requests in sufficient detail to determine what
parts of our study request are adopted, what parts are not, and if
not, why not AEA has not identified the differences between our
study request and their study nor explained where and why they
did not address our requests.” – pdf page 175
See AEA’s response to comment PASS-10.
PASS-23 NMFS 11/14/2012 “NMFS continues to recommend that fisheries surveys be
conducted for at least one average life span of each salmon
species, which is an average of five years for Chinook salmon
(range from three to seven years). This is needed to obtain the
minimum amount of biological information about the population
that is necessary to develop and design mitigation, and determine
the need for fish passage for this project.” – pdf page 175
See AEA’s response to comment FDAUP-01.
PASS-24 NMFS 11/14/2012 “The proposed study indicates that the biological need for fish
passage will be determined, and that this is linked to the
economic costs of providing passage. The RSP should reflect that
the biological need for passage exists: anadromous fish are
known to spawn and rear upstream of the proposed dam. The
biological information requested is necessary to determine the
engineering feasibility of designing effective up and downstream
passage of fish and to determine the ecological and
socioeconomic losses that would result from not providing
See AEA’s response to comment PASS-06.
Revised Study Plan
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Study of Fish Passage Feasibility at Watana Dam
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
passage, including conducting fisheries surveys for at least one
average life-span of each salmon species.” – pdf page 175
PASS-25 NMFS 11/14/2012 “The RSP should be revised as a plan to investigate the ability to
design, construct and operate up- and down-stream fish passage
into a new project from the ground up rather than as if fish
passage facilities were being considered to retrofit an existing
dam that already blocks fish.” – pdf page 175
The Study of FIsh Passage Feasibility at Watana Dam will assess
feasibility of both a dam design with integrated fish passage
facilities as well as the current design with retrofit passage
facilities per NMFS and USFWS comments and communications
with NMFS Fish Passage Engineer, Ed Meyer (Sept 24th and 25th
meeting, teleconference on October 18,2012).
PASS-26 NMFS 11/14/2012 The proposed schedule delays development of conceptual
alternatives until August of 2013. This is too late in the
engineering design process for this dam and operations to allow
for a full range of options for fish passage to be considered
without adding unnecessary expense and delays into the project.
– pdf page 176
See AEA’s response to comment PASS-13.
PASS-27 NMFS 11/14/2012 “In addition to the general physical information at the project,
specific hydrologic and hydraulic (including project operations)
information should be provided for the fish passage season (both
upstream and downstream passage). Other physical information
is needed including expected debris loading, ice conditions,
expected sediment transport (as it affect passage facilities),
expected forebay and tailwater rating curves, project operation
information (rule curve, restrictions, etc.), river morphology trends,
predatory species expected above and below the dam,
downstream sites for a barrier dam/trap and haul operation, and
size of upstream and downstream migrants (fry versus smolts).
Determining the specific information needs for fish passage
should be the first task of the Fish Passage TWO.’ – pdf page 176
See AEA’s response to comment PASS-14.
PASS-28 NMFS 11/14/2012 “NMFS also requests that AEA identify the relationships among
the 2012 pre-ILP studies, the suggested ILP studies, define the
timing of related studies, and explain how these studies will be
completed within the ILP study planning, study dispute, and study
The Section 9.11.7 and Figure 9.11-1 address interdependencies
across the pre-ILP and ILP studies and defines the timing of the
information flow. The schedule that outlines completion of the
studies and study deliverables in presented in Section 9.11.6 and
Revised Study Plan
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Study of Fish Passage Feasibility at Watana Dam
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completion schedules.’ – pdf page 176 Table 9.11-1.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 362 December 2012
Study of Fish Passage Barriers in the Middle and Upper Susitna River and Susitna Tributaries
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
BARR-01 CWA 11/14/2012 Scope is insufficient in studying the Lower River based on AEA’s
apparent assumption that Project effects will not significantly affect the
Lower River fish passage. – pdf page 7
AEA is not assuming no Project effects on Fish and
Aquatic Resources in the Lower River Segment. However,
due to the direct relationship between flow and physical
habitat changes that may result in barriers, the study
elements described in the Section 9.12 are concentrated
within the Upper and Middle River Segments. Project
operations related to reservoir creation, load-following,
and variable flow regulation will have the greatest potential
effects on these segments of the river. In addition, flow
effects will attenuate in a downstream direction as channel
morphologies change, tributary inflows are added and flow
accretion occurs.
The downstream boundary of the Study Area is currently
RM 98 because existing information indicates that the
hydraulic effects of the project below the three river
confluence is significantly attenuated. See Section
09.12.3. However, AEA will reevaluate how far
downstream Project operational significant effects extend
based in part upon the results of the Open-water Flow
Routing Model (see Section 8.5.4.3), which is scheduled
to be completed in Q1 2013. Thus, an initial assessment
of the downstream extent of Project effects will be
developed in Q2 2013 with review and input of the TWG.
This initial assessment includes a review of information
developed during the 1980s studies and study efforts
initiated in 2012, such as sediment transport (Section 6.5),
habitat mapping (Sections 6.5 and 9.9), operations
modeling (Section 8.5.4.2.2), and the Mainstem Open-
water Flow Routing Model (Section 8.5.4.3). The
assessment will guide the need to extend studies into the
Lower River Segment and, if needed, will identify which
geomorphic reaches will be subject to barrier analysis.
Results of the 2013 studies would then be used to
determine the extent to which Lower River Segment
studies should be adjusted in 2014.
BARR-02 NMFS 11/14/2012 “The ABA PSP needs to consider existing and likely future physical Regarding potential juvenile depth barriers across tributary
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
barriers at railroad crossings, delayed migration, increased predation,
and velocity and depth barriers for juvenile salmon and resident fish that
could result from project operations, particularly over time due to channel
aggradation and the formation of sediment wedges. The Alaska Railroad
parallels the east side of the Susitna River from Talkeetna to Gold Creek.
The railroad crosses multiple streams on bridges and over culverts.
Access to culvert outlets and water depth and velocity at bridges and
within crossings could be influenced by future Susitna River water
elevations due to channelization, formation of sediment wedges and
channel incision. Surveys must include all railroad stream crossings.
These potential barriers to fish access should also be studied
downstream where the railroad alignment is adjacent to the Susitna
River, specifically at Wiggle Creek.” – pdf page 178
deltas, refer to Section 9.12.4.2.3.
All barriers within the ZHI will be investigated whether
natural or manmade. Sections 9.12.1, Objective 3, and
9.12.4 clarify that “barriers” includes both natural and
manmade features.
Regarding velocity barriers to juvenile salmonids, AEA
agrees that tributary entrances across steep deltas need
to be assessed. See Section 9.12.4.6.
Regarding delayed migration that may result in increased
predation, see AEA’s response to comment BARR-3.
BARR-03 NMFS 11/14/2012 “The risk of predation due to reduced water depths at fish passage
locations, even when not a physical barrier to passage, must be
evaluated.” – pdf page 178
AEA agrees there is a potential for increased predation on
fish below a barrier that may be created by Project
operation. The primary reason for the increase would be
the impedance of movement or a “pooling” of fish below
the barrier. This impedance to movement or pooling effect
could make the fish more vulnerable to predation.
However, if the depth or velocity at the passage section
are within the fish’s capabilities to pass, impedance to
movement and increased predation cannot be assumed,
and therefore, the potential for increased predation will not
be evaluated at that location.
Studies to evaluate the potential for increased predation at
specific passage barriers due to impeded movement
assumes the feature has been identified as a physical,
depth, or velocity barrier connected with the proposed
Project. If such a barrier is created by the Project, the
potential for impeded movement or pooling of fish below
the barrier will be evaluated. These types of studies are
not specified in the RSP as such studies are very specific
to the type of barrier, its location, the species/life stage of
concern, and the type of predation, i.e. mammalian, avian,
piscivorous, or all three. These and other specifics will be
determined with input from the license participants on a
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
barrier-by-barrier basis. Section 9.12.4.2 of the RSP has
been revised to include the the option of an evaluation of
delayed movement at barriers as determined necessary
with input from license participants.
BARR-04 NMFS 11/14/2012 “The AEA PSP should be revised to include objectives, field methods,
including possible empirical studies, and data analyses that will evaluate
the effects of the proposed project to fish passage. These studies must
include surveys of ARRC stream crossings, the influence of water
surface elevation at passage locations on migration rates and predation,
and the physical and behavioral effects of flow modification on juvenile
salmon and juvenile resident fish migration into off-channel and tributary
rearing and overwintering habitats.” – pdf page 179
Regarding passage at ARRC stream crossing, see AEA’s
response to comment BARR-2.
Regarding predation, see AEA’s response to comment
BARR-3.
BARR-05 NMFS 11/14/2012 “This study objective is incomplete and needs to be clarified. As stated, it
is the location of passage barriers in tributaries and refers to only
physical barriers but not depth barriers. It also is restrictive to tributaries.
It is not clear if this includes or excludes tributary mouths, side channels,
side, sloughs, and upland sloughs-all critically important habitats for
salmon production in the Susitna River and likely to be negatively
affected by project operations. The location of physical or depth barriers
in these off-channel locations is not included in any of the objectives.
Objective 2 is the identification of the type of barrier, which may include
depth barriers as those characterized as "seasonal", or "partial," but does
not include determining the location of these barriers. As this is the only
study objective that includes locating barriers, it should include locating
all physical, temporary, seasonal, and partial, physical, depth, velocity,
and behavior barriers located within the project's hydrologic zone of
influence, and within selected tributaries outside of the hydrologic zone of
influence.” – pdf page 180
The four study goals and objectives stated in Section
9.12.1 of the RSP must be considered as a whole. When
considered together the goals and objectives include all
tributaries and mainstem habitats “within the zone of
hydrologic influence.”
Text has been added in the RSP to clearly identify
mainstem sloughs and side channel type habitat as areas
of study (Section 9.12.4).
The term “barrier”, as used in the four objectives includes
all the types of potential barriers including structural
(physical), depth, and velocity barriers in tributaries and
the mainstem and both upstream and downstream
migration barriers (Section 9.12.1).
The term “Identification”, as used in the 4 objectives,
includes GPS location of any and all potential barriers
investigated. Section 9.12.1 is revised to clarify that GPS
location will be obtained for all barriers.
The identification and location of potential barriers “outside
of the hydrologic zone of influence” will only occur in the
Upper River tributaries. AEA does not propose to
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
investigate barriers above the zone of hydrologic influence
in the Middle River.
BARR-06 NMFS 11/14/2012 “The PSP should clearly identify the criteria that will be used to determine
potential fish barriers, and identify the methods or study that will be used
to determine or define the passage barrier criteria and locations of those
barriers. If methods specific to this objective are not provided in any
interrelated. study, they should be described in this PSP.” – pdf page 180
RSP Section 9.9 references existing criteria that are
available with a detailed description of how they will be
used. Where they are not available the RSP states that
they will be determined in consultation with Licensing
Participants (Section 9.12.4).
BARR-07 NMFS 11/14/2012 “Potential barrier characterization will require more than measurements of
leap heights, pool depths, water depth, and passage length. Site-specific
adult salmon and resident fish data should be obtained to determine
under what flow conditions (tributary, side channel, and mainstem)
passage across a barrier occurs. Studies should evaluate holding times
under variable flow conditions and relate these data to egg viability.
Additional information necessary to evaluate juvenile fish migration must
be provided in the Revised Study Plans.” – pdf page 180
AEA proposes to use existing passage criteria or existing
criteria modified with input from the TWG.
Studies to evaluate holding times would assume that an
upstream or downstream migration passage barrier due to
the Project has been identified. If such a depth, velocity, or
physical barrier is created as a result of the Project,
potential delay or holding times will be evaluated. These
types of studies are not specified in the RSP but will be
determined once a barrier is identified in consultation with
Licensing Participants on a barrier-by-barrier basis. Such
questions as species and life stage, seasonal timing of the
barrier, type of barrier would be considered.
BARR-08 NMFS 11/14/2012 “The PSP methods need to identify how these two objectives will be
addressed; currently they do not. Objective 3 refers to changes to
existing fish barriers. This objective should be clarified. Changes include
evaluating whether flowing ice is the predominant mechanism for
removing beaver dams. This objective should also evaluate how fish
passage across barriers will be influenced by changes in water depth,
velocity, stage height, ratios of pool depth to leap height due to different
project operational scenarios in low to high water years and as flows are
projected to change over time as informed by the study of the effects of
changing climate conditions on flows.” – pdf page 181
The Sections 9.12.4.2.3, 9.12.4.2.4, and 9.12.4.5 are
specific on how changes to depth and velocity will be
evaluated in side channels and sloughs under different
Project flows and seasons.
Physical barriers (other than beaver dams) that require
leaping behavior to pass are not expected to be present
within the ZHI in the Middle River.
Regarding ice and beaver dams, beaver dams are
transient and dynamic in the Susitna River, as they are in
most large rivers. They are removed by high river flows, by
ice, or are abandoned and deteriorate over time. The
beaver dam may be partially removed by flow or ice and
rebuilt within a matter of days or the dam may be
completely removed and rebuilt some time in the future or
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
never rebuilt. Beaver are opportunistic dam builders.
Section 9.9 will identify the location of beaver dams in the
Susitna River within the ZHI that may be barriers and RSP
Section 7.6 will provide information regarding potential
changes in ice processes in the Susitna River, including
side channel and sloughs in general where beaver dams
are most prevalent. Whether this information will
determine the relative importance of ice versus other
causal factors of beaver dam removal is unknown at this
time. AEA questions whether a study, as suggested by
NMFS, could conclusively determine the contribution of
the Project to the net rate of beaver dam removal and
whether the change in removal is caused by ice, river
flows, or a shift in the beaver dam population or dam
building activity from year to year.
NMFS has not sufficiently explained the type of study
envisioned for AEA to include such a study component in
Section 9.9.
BARR-09 NMFS 11/14/2012 “NMFS request that the PSP be expanded so that it may determine what
data are necessary for analyses, how will they be obtained, what are the
data quality expectations, when will sampling be conducted, the
analytical and modeling that will be applied, and the interpretation and
application of results.” – pdf page 181
Section 9.12.4.provides a summary description of the data
necessary to conduct any analyses and provides a
summary of how the data will be analyzed. Section 9.12.4
describes how the data will be obtained. Section 9.12.6
provides a study schedule.
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Aquatic Resources Study within the Access Alignment, Transmission Alignment, and Construction Area
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
AQTRANS-01 CSDA 11/14/2012 “Regarding the proposed access routes’ stream crossings, USFWS
recommends a minimum of 3 years of onsite stream gage data.” –
pdf page 4
Two years of data will be sufficient to meet the study
objectives of 1) characterizing the aquatic habitats and fish
assemblages at potential stream crossings within a 200-
meter (650-foot) buffer zone along proposed access road
and transmission line alignments; and 2) describing
aquatic habitats and species present within the
construction area for the dam and related hydropower
facilities. See also AEA’s response to comment FISH-01
and FISH-02.
AQTRANS-02 FERC 11/14/2012 “In its August 31, 2012, comment letter, ADF&G requested that
transmission line crossing locations be surveyed by electrofishing for
a distance equal to 40-wetted stream widths, with a minimum survey
length of 50 meters. In your October 24, 2012, RSP consultation
table, you note that section 7.13 of the PSP provides for
electrofishing a stream length of 40 wetted channel widths, up to a
maximum of 400 meters; however, the PSP does not specify a
minimum length for the surveys. You state in your October 24, 2012,
consultation table that section 9.13 of the draft RSP was revised to
propose a minimum survey length of 50 meters. Please ensure that
your RSP specifies a minimum electrofishing survey length of 50
meters, or provide an explanation for why the request is not
adopted.” –pdf page 18
The Section 9.13.4.2.2 specifies a minimum electrofishing
survey length of 50 meters.
AQTRANS-03 FERC 11/14/2012 “In its August 31, 2012, comment letter, ADF&G stated that if the
Denali route is chosen, existing stream crossings on the Denali
Highway would need to be improved or replaced to accommodate
traffic associated with the project. ADF&G also stated that it would
require a comprehensive survey of stream crossings so that stream
crossings currently hindering or obstructing fish passage can be
repaired or replaced with culverts or bridges. You state in your
October 24, 2012, RSP consultation table that section 9.13.2 has
been revised to indicate that upgrades to existing stream crossings
on the Denali Highway would be necessary to accommodate project
traffic, and that reviewing these crossings would be completed
outside of the current assessment, when required. Because such
upgrades would be part of the project proposal, we will need to
evaluate the need and benefits of such measures. Therefore, please
Section 9.13.2.1 includes text as follows:
“From 2006 to 2007 ADF&G conducted a Level 1
assessment of stream crossings for central and Interior
Alaska road systems including the Denali Highway
(O’Doherty, 2009). The ADF&G methodology followed a
standardized protocol focusing on juvenile salmonid fish
passage. Culverts were surveyed for type, size, slope,
outfall height and other physical parameters. Of the 1,591
culverted stream crossings evaluated throughout the state,
the Denali Highway crossings were classified among
those “having the greatest potential to pass juvenile fish”
(O’Doherty, 2010). If the Denali Corridor is chosen, all
crossings will be re-inventoried and surveyed to the
ADF&G Level 1 standard. This survey work will be
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
ensure that your RSP includes an evaluation of stream crossing
surveys along the Denali Highway if the Denali route is chosen, and
includes a detailed plan with the proposed methods and schedule
for conducting the surveys.” –pdf page 18
completed in 2014.”
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Genetic Baseline Study for Selected Fish Species
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
GENE-01 USFWS 11/14/2012 “In light of AEA’s 2012 findings of numbers of Chinook salmon capable
of navigating above the proposed dam site, and in order to adequately
inform federal fishway prescription authorities under the Federal Power
Act, we refine our genetics study request to determine: 1) whether or
not Chinook salmon above Devil’s Canyon are genetically distinct; 2)
the effective Chinook spawning population size above Devil’s Canyon;
and 3) the proportional contribution of the genetically distinct Chinook
salmon above Devil’s Canyon to the Susitna River spawning
population.” - pdf pages 139-140
The proposed Objectives 1 and 2 have been added to the
RSP (Objective 3; Section 9.14.1.1). The proposed third
objective will be addressed in the Salmon Escapement
Study (Section 9.7) using the numbers of radio-tagged
Chinook salmon above Devils Canyon and estimates of
the mark rate on fish in the Middle River (tagged at Curry).
In addition, independent or separately-derived estimates
can be made (although less precise) by examining the
mark rate from fish radio-tagged in the Lower River and
the numbers of those tags located above Devils Canyon.
Each dataset will have the estimate of the mark rate
numbers of fish above Devils Canyon. The mark rate from
the lower river fish will likely be more precisely estimated
but there will be fewer of these tagged fish located above
Devils Canyon. Fish tagged at Curry will be more
numerous above Devils Canyon but it is likely that a less
precise estimate of the mark rate will be available
compared to fish tagged in the Lower River.
GENE-02 USFWS 11/14/2012 “The Service agrees with this objective to support the GSA database
for resident and anadromous fish species of the Susitna River. AEA
plans to take these samples “opportunistically” during capture events.
Acquiring genetic samples opportunistically at capture sites and at
sites using differing gear types is reasonable for an initial season
(2012) in order to identify species and their spatial and temporal
utilization of riverine habitats. However, beyond the first season (2012),
a more formal sampling design should be established by resource
agency fish biologists, geneticists, and AEA in order to develop a
scientifically sound operational plan for continued sampling. The
sampling design should state needed sample sizes by species,
methodologies, along with temporal and spatial sampling
considerations.” – pdf page 140
The scope of the Genetics Study has been revised to
include a dedicated sampling crew to encompass the
spawning period. In addition, a detailed project operation
plan will be provide to the TWG by April 30 of 2013 and
2014. The text in the RSP has been revised to reflect this
additional scope (Section 9.14.2.2).
GENE-03 USFWS 11/14/2012 “Finally, AEA’s genetic sampling efforts should be stated to clearly
include fish species found to be utilizing the lower, middle and upper
Susitna River (RM 0-233).” – pdf page 141
Text has been added to RSP Sections 9.14.1.1 and
9.14.4.1 stating sampling will occur in the entire Susitna
River. In addition, the extent of current and desired sample
coverage of Chinook salmon stocks is provided in RSP
Table 9.14-1.
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
GENE-04 USFWS 11/14/2012 “The addition of genetic “markers” in this objective makes this a
different study than intended; as well as a more expensive study. This
objective should be rewritten to state that this study will “contribute to
the development of genetic baselines for each of the five species of
Pacific salmon spawning in the Susitna River drainage”. Genetic
markers are used to differentiate between species, or for use in
differentiating a new species that does not already have markers
developed.” – pdf page 141
The word “markers” has been removed from the objective
so it now reads: “Contribute to the development of genetic
baselines for each of the five species of Pacific salmon
spawning in the Susitna River drainage.”
GENE-05 USFWS 11/14/2012 “This objective attempts to answer the question, “Are the Chinook
salmon that spawn above Devil’s Canyon genetically distinct?” AEA’s
(and ADF&G) Objective 3 cannot occur without some baseline
distribution and biological information about the Chinook spawning in
the extreme upstream areas of the Susitna, Talkeetna, and Chulitna
River where the greatest genetic divergence is expected to occur. It is
important to understand the biology of the [target] species so that
potential sampling issues can be avoided as much as possible
(Waples and Gaggiotti 2006). This information is a data gap for Susitna
River Chinook salmon. Once the needed distribution and biological
baseline is available, we recommend AEA follow a robust genetic
sampling design in cooperation with the state and federal fish
geneticists’ recommendations. If the Chinook salmon above Devil’s
Canyon are determined to be a genetically distinct spawning
population, then a mark recapture study is needed to get a population
estimate in order to identify the proportion Susitna basin Chinook
passing/migrating above Devil’s Canyon (above the dam site). A
minimum of three years of mark-recapture data is necessary to
determine an average number of fish migrating above the dam site.
Multiple years of data are also needed in order to assess 1) temporal
variation, 2) and run timing variation.” – pdf page 142
Baseline data on the distribution of Chinook salmon will be
obtained through fish distribution studies (RSP Sections
9.5 and 9.6) and the escapement study (RSP Section 9.7)
and this includes the application of 1,800 radio
transmitters into Chinook salmon in each of 2013 and
2014. (Objectives 1 and 8 in RSP Section 9.7, Salmon
Escapement Study). Combined with approximately 800
radio-tagged Chinook salmon in 2012, the baseline
distribution of spawning Chinook salmon will be based on
approximately 2,600 tagged fish. These tagging programs
and tag recovery efforts will be used to estimate the
abundance of Chinook salmon above Devils Canyon.
Added to the results from 2012, there will be three years of
escapement estimates that can provide insight into the
variation in behavior, including run timing, of fish that
migrate above Devils Canyon.
GENE-06 USFWS 11/14/2012 “To assess population genetics stability, AEA should consult with
Service and ADFG fisheries geneticists to establish a recommended
number of genetic samples and number of years required to establish
a temporal stability of allele frequencies. For smaller populations, such
as the Chinook salmon above Devil’s Canyon, more information is
needed in order to answer that question. High statistical power is
necessary when attempting to estimate the contribution of stocks
Agreed, more information is needed and the types of
information needed will be a function of what is learned
each year. Two sections (RSP Sections 9.14.2.1 and
9.14.2.2) have been added to the RSP to outline how new
information will influence sampling needs. AEA proposes
an approach of collecting sufficient samples to address as
many inevitabilities and hypotheses as may emerge. In
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
which contribute, at small proportions, to a mixture in order to detect
the presence of these stocks (Jasper et al 2009). Generally, statistical
power is increased by increasing sampling sizes within strata.
However, for small populations, sampling across one to two
generations (e.g., 10 years) is more powerful in establishing
generational and environmental effects and the effects of genetic drift
(Waples 1990).” – pdf page 142
this way, the samples will be in hand and will be analyzed
as needed to address the questions for an impact
assessment of the Project. AEA has consulted extensively
with ADF&G’s gene lab, including Habicht, Templin, and
Jasper, to develop the approach outlined in the RSP. In
addition, a detailed operational plan will be available for
review annually by the TWG (RSP Section 9.14.2.2).
GENE-07 USFWS 11/14/2012 “Susitna River Chinook salmon have a 5-7 year overlapping life history,
so changes in gene frequency are relatively slow. This is because
Chinook salmon age-at-return is widely spread out, such that spawning
returns from any given year overlap with those from other year classes.
Therefore, we recommend that genetic samples be collected for a
minimum of five consecutive years in order to capture one generation
of the Chinook salmon dominant 5-year age class (ADF&G 2012).” –
pdf page 142
Also, samples collected from 2012-14 will represent three
calendar years and fish from at least 4 brood years, and
possibly 5 brood years. There may be a need for five
consecutive years of sampling to ensure sufficient sample
sizes, but this will depend on at least the five factors
outlined in the RSP Sections 9.14.2.1 and 9.14.2.2.
GENE-08 USFWS 11/14/2012 “Some knowledge of effective population size (Waples 1990a; Waples
1990b) is also required to estimate proportional rates of exchange from
allelic frequency data (Allendorf and Phelps 1981). Estimates of the
effective spawning population of Chinook salmon above Devil’s
Canyon are needed to sort out the genetic differentiation. In order to
best inform Federal resource agencies FPA authority, we recommend
a generational timeframe for genetic sample collections in order to
analyze:
1) stability of allele frequencies (Allendorf and Phelps 1981)
2) variation in effective parental numbers;
3) as a means of estimating the number ofspawners above
Devil’s Canyon (Waples 1990).”
- pdf pages 142-143
The RSP has been revised to include estimating the
effective population size (Section 9.14.4.2.1).
GENE-09 USFWS 11/14/2012 “Genetic samples limited to 10 Chinook have heightened probability of
indicating a high degree of variation from Chinook above the dam site.
It is therefore, in AEA’s best interest to support the request for
adequate sample sizes over appropriate temporal and spatial scales.
To support and ensure better collaboration toward this common goal,
the Service urges AEA to meet with state and federal fisheries experts
to develop robust sampling efforts that address resource agencies
The commitment to estimate EPS has been made more
explicit in the RSP (New Objective 3 and in Section
9.14.4.6.4). The commitment to meet with state and
federal experts has been made in Section 9.14.2.1.
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respective management authorities. This is also needed to
appropriately inform the proposed Project of potential considerations
related to facility design and construction.” – pdf page 143
GENE-10 USFWS 11/14/2012 “Similar to Objective 3, AEA’s (and ADF&G) Objective 4 cannot occur
without acquisition of baseline distribution and biological information
about the Chinook salmon spawning in the extreme upstream areas of
the Susitna, Talkeetna, and Chulitna River where the greatest genetic
divergence is expected to occur. Without this baseline information, we
do not know where the level of genetic distinction may exist or how to
structure sampling efforts. ADF&G requested information specific to
habitat utilization below Devil’s Canyon by Chinook salmon progeny
originating upstream of Devil’s Canyon. If the results of the Chinook
salmon genetics studies conducted during the summer of 2012
indicate that the Chinook salmon spawning upstream of Devil’s
Canyon can be characterized as an identifiable genetic reporting
group, then the Service recommends AEA conduct a study to estimate
the percent of juvenile Chinook salmon downstream of Devil’s Canyon
that originated from upstream of Devil’s Canyon by taking sufficient
and representative genetic samples of these juveniles. Juvenile
Chinook salmon have recently been observed above the proposed
dam site (Buckwalter 2011), further substantiating study requests for
juvenile Chinook salmon. The Service recommends this genetics-
based approach over a traditional passive integrated transponder (PIT)
tag study, where fry are marked upstream of Devil’s Canyon with PIT
tags, because there is no need to address mark–recapture handling
and tag loss assumptions.” – pdf page 143
See AEA’s response to comment GENE-06 on the extent
of baseline data collection from adult Chinook salmon
distribution. Table 9.14-1 documents the extent of the
existing baseline sample sizes and the goals of the
proposed sampling efforts. Regarding the juvenile fish
redistribution from the Upper to the Lower Susitna, the
suggested work is part of Objective 5.
GENE-11 USFWS 11/14/2012 “ADF&G Objective 3: For 2 years, annually estimate the minimum adult
escapement of Chinook that spawn upstream of Devil’s Canyon. The
Service recommends that this study objective be included in the project
study request determination. We also request that annual spawning
escapement estimates be conducted for a minimum of 3 years in order
to assess: 1) temporal variation, and 2) run timing variation.
Escapement numbers are so variable between years that a minimum
of three years is necessary in order to provide some sense of this
variation.” – pdf page 143
See AEA’s response to comment GENE-06.
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
GENE-12 USFWS 11/14/2012 “ADF&G Study Request # 1 Adult Chinook and coho salmon spawner
distribution and abundance studies, requested specific objectives
related to Susitna River coho salmon. The Service supports and
reiterates the request which addresses basic spatial and temporal
biological information needed to begin to address genetic studies for
Susitna River coho salmon. The related objectives should be included
as follows:
Objective 5. “Estimate the in-river abundance of adult coho salmon in
the Susitna River upstream of the confluence of the Yentna River for a
minimum of three years.”
Objective 6. “Identify coho salmon spawning locations in the mainstem
of the Susitna River upstream of the confluence with the Yentna River
for a minimum of three years.” The Service recommends that these
objectives will be incorporated into the PSP in order to inform genetic
sampling efforts should coho salmon be found to migrate above the
proposed dam site. Like Chinook salmon, coho salmon are known to
breach significant gradient and velocity impediments to reach
spawning grounds.” – pdf page 143
Baseline studies done in 2012 and studies proposed to
continue through 2013-14 will obtain spatial and temporal
biological information on coho salmon. Among this work,
the Salmon Escapement Study (RSP Section 9.7) will
place radio transmitters in up to 600 adult coho salmon (as
part of objectives 1, 2, 3, 6 and 8 in RSP Section 9.7).
These studies will provide three years of data to inform
genetic sampling efforts of coho salmon.
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Analysis of Fish Harvest in and Downstream of the Susitna-Watana Hydroelectric Project Area
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
FHARV-01 CWA 11/14/2012 Include TK into RSP. –pdf page 8 As explained in the Subsistence Resources Study RSP
(see Section 14.5.4.5, Traditional Knowledge regarding
the physical, biological and social environment, including
fish specifically, is being documented. Each program lead
for the project has the opportunity to provide questions for
the TK workshops. Task 1-4 of the Subsistence
Resources Study RSP address fish harvest and use
areas. Task 5 of the Subsistence Resources Study RSP
incorporates TK questions related to fish and other wildlife
resources.
FHARV-02 FERC 11/14/2012 “In section 7.15, Analysis of Fish Harvest in and Downstream of the
Susitna- Watana Hydroelectric Project Area, you propose to analyze
fish harvest using data from ADF&G records of commercial, sport,
personal, and subsistence fisheries. The data will be used to evaluate
the potential for the project to alter harvest levels and opportunities on
Susitna River-origin resident and anadromous fish. At the August 15,
2012, technical work group (TWG) meeting, it was noted that ADF&G
fish harvest surveys are conducted over large areas. ARRI requested
that you conduct additional fish harvest surveys to provide harvest data
at an appropriate geographic scale for the proposed analysis. In
response, you noted in your October 24, 2012, RSP consultation table,
that no additional fish harvest surveys would be conducted because
such surveys were not necessary to analyze effects of the proposed
project. You provide no further explanation for why you do not intend to
conduct additional fish harvest surveys. It is not clear from your
response how the existing ADF&G records would be sufficient to cover
a geographic area specific to the project. Please include in your RSP
an explanation to support your position that the ADF&G fish harvest
data are of an appropriate geographic scale to permit an analysis that
meets the study objectives. If study objectives cannot be met using the
ADF&G data, please include in your RSP a description of alternative
data collection methods.” –pdf page 19
ADF&G fish harvest data are of an appropriate geographic
scale to permit an analysis that meets the study
objectives. The geographic harvest reporting areas that
will be selected from the Statewide Harvest Survey
(SWHS) data as described in RSP Section 9.15.4.2 will
conform with the area of potential Project effects. If the
fishery size or level of participation is too small to be
adequately assessed by the SWHS, RSP 9.15.4.2
provides that qualitative information on angler success
and participation will be obtained by interviewing guides,
outfitters, fishery participants, and lodge owners operating
in the Upper Susitna.
RSP Section 9.15.4.2 was revised to clarify the
compilation of harvest and effort data from sport fisheries.
FHARV-03 FERC 11/14/2012 “At the August 15, 2012, TWG meeting, ADF&G requested that effects
of emergency fishing closures be included in the analysis of fish
harvest. Please ensure that your RSP describes the approach that will
be used to analyze the effects of emergency closures on fish harvest
As described in Section 9.15.4 of the RSP AEA’s
approach minimizes the affect of emergency closures by
averaging data over a time period. As stated in the RSP,
“ADF&G opens and closes fishing areas each year by
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
levels and opportunities in the commercial, sport, personal, and
subsistence fisheries. If you do not intend to include emergency
closures in your analysis, then please provide an explanation for why it
would not be needed.” –pdf page 19
issuing emergency orders. These orders are necessary to
achieve escapement goals for the various salmon returns
to the Cook Inlet area as well as adhering to regulatory
directives for allocation of harvest between user groups.
To minimize the affect that emergency order closures may
have on a given year, harvest data will be averaged over a
20 year time period.”
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Eulachon Run Timing, Distribution, and Spawning in the Susitna River
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
EUL-01 CWA 11/14/2012 Scope is insufficient in studying the Lower River based on AEA’s
apparent assumption that Project effects will not significantly affect the
Lower River eulachon community. –page 7-8
This study area is sufficient to meet the objectives of the
study. As stated the Section 9.16.1, the objectives of the
Eulachon Run, Timing, Distribution, and Spawning in the
Susitna River study are to collect information that will
facilitate evaluation of the overall potential Project effects
to eulachon run timing and duration (Section 9.16.4.1),
spawning sites (Section 9.16.4.2), and spawning habitat
(Section 9.16.4.3).
The study area extends from the mouth of the Susitna
River to the uppermost extent of spawning, which will be
determined by a combination of telemetry and acoustics.
A split beam sonar device will be positioned at a fixed site
near RM 10 to collect information on run timing and
duration. This is within the area sampled daily in 1983
(RM 4.5 to RM 60; ADF&G 1984). Few spawning locations
were detected below RM 10 (Section 9.16.3 and Figure
9.16-1).
EUL-02 ADNR-
ADF&G 11/14/2012 “For the eulachon (Section 7.16) and boating (Section10.7) studies,
similar information is needed on how the flow-habitat/resource
information will be collected. For example, what is the study area, what
sampling strategy will be used, how many and what range of
calibration-discharge sets will be collected if appropriate, and how will
HSC/HSI data be developed?” –page 21
AEA is not developing an HSC as part of theEulachon
Run, Timing, Distribution, and Spawning in the Susitna
River study. Physical habitat data associated with
spawning locations will be collected over a wide range of
flows and stages. This will enable (1) characterization of
habitat associated with eulachon spawning, and (2)
evaluation of the availability of spawning habitat during
expected post-Project flows and stages. Details are
included in theEulachon Run, Timing, Distribution, and
Spawning in the Susitna River study Section 9.16.4.3.3
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Cook Inlet Beluga Whale Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
CIBW-01 CWA 11/14/2012 “The PSP must discuss the potential impacts to the beluga
and provide recommendations how to ensure that any action
authorized, funded, or carried out by FERC in relation to the
Project is not likely to jeopardize the continued existence of
any endangered species or threatened species or result in the
destruction or adverse modification of critical habitat.” –pdf
page 6
It is premature for the study plan to include this type of discussion.
Instead, AEA will use the information collected from this study and
other studies in the environmental analysis that will support AEA’s
FERC License Application for the Project. This analysis will include
an assessment of whether the project affects CIBW. The goals of
the CIBW study are to document the seasonal and temporal use of
the Susitna River delta by CIBWs, determine the upstream extent
and study possible Project effects on the mudflats where CIBWs
forage. SectionOther studies will analyze the effects on CIBW prey
species (Fish Distribution in the Middle and Lower River Study
(Section 9.6), Salmon Escapement Study (Section 9.7) and
theEulachon Run, Timing, Distribution, and Spawning in the
Susitna River study (Section 9.16). Several studies will also
analyze the potential impacts to beluga critical habitat (Baseline
Water Quality Study (Section 5.5), Water Quality Modeling Study
(Section 5.6), Geomorphology studies (Sections 6.5 and 6.6), Ice
Processes in the Susitna River Study (Section 7.6), and Fish and
Aquatics Instream Flow Study (Section 8.5).
CIBW-02 Ransy, Denis 11/14/2012 “Beluga Whale Studies must be complete and long term. The
Cook Inlet Beluga is an endangered Species, and must be
considered accordingly. Cook Inlet Beluga populations have
been declining for many years, and their continued existence
is not assured. They are known to live in the Susitna River
delta area, and actually go upriver occasionally to catch fish.
They eat salmon and eulachon (hooligan). If either of these
fish species decrease in abundance, it will adversely affect the
beluga population. This could place the state in direct violation
of Federal Law.” –pdf page 1
See AEA’s response to comment CIBW-01.
CIBW-03 FERC 11/14/2012 “In Section 9.17.4.2, Study Methods, you propose to use
video cameras and still camera to document beluga use of the
Susitna River delta. It is difficult to determine whether certain
terms apply to video camera stations, still camera stations, or
both (e.g.,“live-feed cameras,” “remote cameras,” “camera
systems,” “camera”); please use consistent terminology to
distinguish between video- and still-camera stations and be
specific as to which system or systems are being referred to in
AEA has clarified the camera terminology in Section 9.17.4.2.
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the description of study methods. –pdf page 19
CIBW-04 FERC 11/14/2012 Please be specific in describing the camera stations or the
field of view through remote cameras in order to distinguish
from language describing other study sites and areas. Further,
you say “[Li]ve-feed cameras (up to four, depending on
feasibility) will be established at the mouth of the Susitna
River and still cameras (up to four, depending on feasibility)
will be placed up to RM 10.” Later you note that each camera
site will have one or more cameras. Please clarify how many
camera stations are proposed and how many and what type of
cameras would be employed at each. For example, when you
say “[T]he cameras will have more than one path to allow for
independent movement and view of the study area,” are you
referring to the fact that there is more than one camera at
each site and that each can be manipulated separately? See
the discussion provided under “Group Counts” for an example
of the clarity desired.” –pdf page 20
Two video cameras will be located at each station (See Section
9.17.4.2). One video camera at each station will present a wide-
angle overview of the study site and will conduct broad sweeps
over the area to look for other groups while still maintaining the first
group in view. The second camera will focus on each group for
counts and observations. Camera locations will be determined
based on field of view, permits and co-location with instruments
from other studies (i.e. Ice Processes in the Susitna River Study
Section 7.6 and Instream Flow Section 8.5). In 2012, cameras
were established as far downstream as RM 15. The existing
cameras will be used for incidental observations of CIBWs and new
camera locations further downstream will be established for the
CIBW study. The exact locations will depend on site-specific
information which will be determined in early 2013.
CIBW-05 FERC 11/14/2012 “You say “[O]bserver monitoring shifts will be scheduled to
cover up to 7 days a week with a primary focus on high-water
periods.” Clarify whether the term “high-water” in this context
refers to high tide or high instream flows or both. Additional
detail is required regarding frequency, duration, and timing of
monitoring (e.g., months during which monitoring will occur,
number of days per week, number of hours per day, time of
day).” –pdf page 20
Methodology clarified in Section 9.17.4.2, live feed video cameras
will be monitored May through September. Monitoring will average
eight hours per day five days a week. The 8 hours will cover a
range of daylight hours with focus on high tides. The five days a
week will be rotating to cover both weekend and week days.
CIBW 06 FERC 11/14/2012 “Please clarify whether video footage of beluga observations
will be digitally archived.” –pdf page 20
Clarified in Section 9.17.4.2 video footage will be digitally archived.
CIBW 07 FERC 11/14/2012 Where you mention the potential for identifying individual
animals, please describe the previously collected photo-
identification information available for the beluga population.”
–pdf page 20
As explained in Section 9.17.4 a photo identification catalog is
maintained by LGL. This catalog will be referenced to identify
animals with markings. Photo identification is possible but photo
quality and the fact that not a large fraction of the CIBW has large
and obvious marks will limit the number of individuals identified.
CIBW-08 FERC 11/14/2012 “You do not propose conducting winter studies on beluga
distribution or prey availability due to safety and logistical
reasons, but indicate that “subsequent impact analyses will
There is limited data on CIBW winter movements. Hansen and
Hubbard (1999) stated that CIBWs can be found in waters that are
up to 60% ice covered. However, whales are more dispersed in
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assume that whales are present year-round in the Susitna
River delta and that they may be foraging” there at that time.
Shelden et al. (2003) cite Rugh et al. (2000) and Hansen and
Hubbard (1999) as sources of information on beluga winter
habitat use in Cook Inlet. Existing information may be used to
support not conducting a study. Do these reports provide
additional support for not conducting surveys during the winter
months? If so, please summarize their findings on winter
habitat use.” –pdf page 20
winter and are found in offshore waters, further south than the
Susitna River (Rugh 2000). Hobbs et al. (2005) also stated that
CIBWs dive deeper in winter than in summer, suggesting that the
shallow, ice-covered Susitna mudflats are not primary winter
foraging grounds. Further details are included in the Section
9.17.2.
The best methodology for winter movements would involve the use
of satellite telemetry. However, obtaining appropriate permits would
be highly unlikely given their ESA status and proven difficulties
attaching satellite tags to CIBWs.
CIBW-09 FERC 11/14/2012 “Goetz et al. (2012) developed predictive habitat models from
beluga data collected from 1994 to 2008. Beluga presence
was positively associated with fish availability and access to
tidal flats and sandy substrate; group size was positively
associated with tidal flats and proxies for seasonally available
fish. Maps of habitat that could be integral to the sustainability
and recovery of the beluga population were generated. Please
summarize available models of beluga habitat for the study
area and whether they may be used for assessing potential
impacts. –pdf page 20
Project operations may potentially have an influence over the
physical structure of the mudflats, a PCE for CIBWs. The modeling
effort has been revised to include a water surface elevation (WSE)
model (see Section 9.17.4.3). The WSE model will evaluate the
influence of river discharge on water surface elevation under four
operational scenarios. The four scenarios represent the existing
condition, a maximum load-following, an intermediate load-
following, and a base-load scenario. The three with-Project
scenarios will provide bookends and an intermediate assessment
of potential Project effects.
CIBW-10 FERC 11/14/2012 Describe any and all ongoing survey efforts by other
researchers and agencies and how your efforts will compare
or build upon others, where you will collaborate with other
agencies in sharing data, etc.” –pdf page 20
AEA will collaborate with other CIBW studies when possible.
Ongoing CIBW studies in the Susitna River delta include NMFS
aerial surveys which are conducted in June and August. The aerial
survey protocol has been revised in Section 9.17.4.1 such that
there is no longer a need to rely on NMFS aerial data; AEA will
collect sufficient data to analyze spatial and temporal variation in
CIBW presence in the Susitna River delta. The other ongoing
CIBW study is a photo-identification study conducted by boat by
LGL Alaska from May through October. The AEA team will
coordinate with the boat-based work of LGL’s to avoid overlapping
surveys on the days that LGL is on the water (as NMFS aerial team
does).
CIBW-11 FERC 11/14/2012 “Acoustic monitoring was brought up as a potential monitoring
method for beluga (Bob Small, ADF&G, August 19, 2012,
At the August 15, 2012 TWG meeting, ADF&G requested
consideration of acoustic monitoring. AEA has considered this
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meeting), but was dismissed because it was unlikely to result
in significant additional information useful to the beluga study.
Please include the request and a detailed justification for not
including acoustic monitoring in the RSP or your proposed
methodology for conducting the study” –pdf page 21
request, but has determined it will not conduct acoustic monitoring
because several factors would limit the efficacy of an acoustic
array. These include sufficient range/coverage of the survey area,
high in-water noise, and, most importantly, a high probability of
false negatives regarding presence of whales. AEA believes that
the data collected through aerial surveys and video studies are
sufficient to document the distribution, movement patterns and
behavior of CIBWs in the delta to effectively assess potential
project impacts.
See also AEA’s response to comment CIBW-14.
CIBW-12 ADF&G 11/14/2012 “Apparently, as indicated in Section 7.17.4.3, estimated
effects on CIBW will be determined through a modeling
approach, incorporating results on the distribution of CIBW
from this proposed study, and results from other hydrologic,
prey, and habitat studies. The Project may have indirect
effects on CIBW caused by changes in the distribution or
abundance of some prey species, or by restricted access to
prey species. The methodology should describe the general
modeling approach especially as applied to objective number
3.” –pdf page 29
AEA has revised Section 9.17.4.3 to provide more detail for
Objective 3. See AEA’s response to comment CIBW-09.
CIBW-13 ADF&G 11/14/2012 “Section 7.17.4.1 describes the proposed methods for aerial
surveys, apparently to obtain ‘fine-scale’ information on CIBW
seasonal distribution. The specific objective of the surveys
relative to distribution and abundance should be more clearly
defined. If an estimate of abundance is sought, the proposed
survey effort will result in minimal levels of precision and
accuracy. Obtaining relative group size information appears to
be more realistic, and methods other than Hobbs et al. (2011)
that are more consistent with the objectives of this study
should be considered.” –pdf page 29
AEA has revised the aerial survey methodology Section 9.17.4.1.
Data will be collected on relative group sizes. There will be no
attempt to perform abundance estimation.
CIBW-14 ADF&G 11/14/2012 “PAM should be used to collect additional information on the
presence of CIBW, 24 hours per day, 7 days a week,
independent of weather conditions. Information on when and
where belugas are foraging, which can be obtained through
Passive acoustic monitoring (PAM) has been considered as a
method to document CIBWs. However, several factors would limit
the efficacy of an acoustic array, including sufficient
range/coverage of the survey area, high in-water noise, and, most
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PAM, will increase the ability to determine project-induced
changes.” –pdf page 29
importantly, a high probability of false negatives regarding
presence of whales. Additionally, winter PAM monitoring would be
difficult because arrays would need to be placed in deeper,
offshore waters due to ice scour in the river and intertidal areas.
Therefore, data collected offshore of the delta would not be helpful
in evaluating potential impacts from the Project.
While satellite telemetry would be a useful tool to document
movements of CIBWs in the Susitna River delta and throughout
Cook Inlet year-round, obtaining appropriate permits would be
highly unlikely given their ESA status and proven difficulties
attaching satellite tags to CIBWs.
AEA believes that the data collected through aerial surveys and
video studies are sufficient to document the distribution, movement
patterns and behavior of CIBWs in the delta to effectively assess
potential Project impacts.
CIBW-15 ADF&G 11/14/2012 “The over-winter period should not be excluded from the
study. Information exists (Goetz et al. (2012) that indicates
belugas may forage in this area more in winter than summer,
and such over-winter foraging could potentially be very
important to belugas, especially juveniles and
pregnant/lactating females. If data on the presence of belugas
in this area is deemed important, PAM has been used
successfully to detect belugas during the overwinter period in
a similar environment; i.e., outside of Beluga River, to the
west of the Susitna Delta.” –pdf page 30
See AEA’s response to comment CIBW-14.
CIBW-16 TNC 11/14/2012 “Operation Scenarios
The various models that are developed for the study plan
should look at three scenarios: existing (non-project),
proposed load-following operation, and base load operation.”
–pdf page 3
See AEA’s response to comment CIBW-09.
CIBW-17 NMFS 11/14/2012 “NMFS recommends AEA consider alternative methods for
detecting beluga presence/absence of the Susitna River and
Delta for the over-winter period. One possible method AEA
See AEA’s response to comment CIBW-14.
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could consider is the use of passive acoustic monitoring
devices.” –pdf page 182
CIBW-18 NFMS 11/14/2012 NMFS questions how the live-feed and still cameras will
document the northern extent of CIBWs in the Susitna River.
NMFS also requests more information on the camera protocol.
–pdf page 183
Methods have been revised to clarify that more frequent aerial
surveys will also be used to determine the upstream extent of
CIBWs in the Susitna River. See Section 9.17.4.1. Live-feed video
cameras will be used to document group composition and behavior
which may document the presence of young animals and foraging
behavior. Camera locations will be determined based on field of
view, permits and co-location with instruments from other studies
(i.e. Ice Processes in the Susitna River Study [Section 7.6] and
Instream Flow [Section 8.5]). See AEA’s response to comment
CIBW-05.
CIBW-19 NMFS 11/14/2012 “AEA has not proposed to conduct any work to specifically
address these study requests. Instead, AEA has stated that "if
significant project-related impacts to prey are identified" from
the other fish studies, they will collaborate with NMFS to
determine the best model to use to estimate effects to Cook
Inlet beluga whales. There is no discussion regarding what
criteria will be used to determine if impacts to prey are
significant. NMFS contends that any adverse impacts to
beluga prey species (as identified in the critical habitat
designation) should lead to an assessment of impacts to
beluga whales.” –pdf page 184
Section 9.17.4.3 describes the data that will be collected to
evaluate the relationship among potential hydropower related
changes in the Lower River, CIBW In-River Movements, and Prey
availability. If there are any adverse impacts to whales, AEA will
assess those impacts in the environmental analysis supporting
AEA’s FERC License Application.
CIBW-20 NMFS 11/14/2012 “In this PSP, AEA recognizes that belugas may also be
impacted by potential changes to sediment transport and
delivery, stream temperature, water quality, stream flow, and
ice processes. There is no mention how data from the
proposed habitat studies will be used in determining effects to
belugas, or if habitat studies are even planned for the mouth
of the Susitna River. Further, AEA states that project-induced
changes in these factors may prevent, impair, or delay beluga
whale access to delta or river habitats that support known
prey species. While changing belugas' access to the habitats
is one potential effect, changes to the hydrologic and
bathymetric characteristics of the Susitna River Delta may be
See AEA’s response to comments CIBW-01 and CIBW-05.
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sufficient to restrict or prohibit necessary biological activities of
Cook Inlet belugas, including foraging and reproductive
success. The potential for impacts other than changes in
access needs to be addressed.” –pdf page 184
CIBW-21 NMFS 11/14/2012 “AEA proposes to combine the data from the proposed beluga
distribution study with the data from other proposed habitat
studies to "assess the potential effects on salmon and
eulachon habitat, productivity, abundance, and run timing."
While NMFS recognizes and agrees with the importance of
assessing effects to salmon and eulachon, NMFS disagrees
that this should be the sole goal of this proposed study. NMFS
has stated that the PSP must address how the proposed
project may alter the habitat used by Cook Inlet beluga whales
in the Susitna River Delta, how beluga prey species in the
area may be affected, and how changes to habitat or prey
may affect belugas' foraging and reproductive success. NMFS
is not confident that the" proposed PSP will adequately
address these concerns.” –pdf page 184
See AEA’s response to comment CIBW-01.
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Wildlife Resources
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
WILD-01 Various
Individuals
11/07/2012-
11/14/2012
Two year study is inadequate to determine potential project impacts
on ice stability from fluctuating flows and rivers use as a corridor by
people and wildlife.
The Ice Processes in the Susitna River Study (Section
7.6.2.1) addresses the adequacy of the study of ice
stability.
The number of years of winter observation which will be
relied upon for this study is sufficient to meet the goals
and objectives of the study plan. The study plan will rely
upon at least seven years and likely eight years of winters
of observations (including 5 years in 1980’s, 2012-2013,
2013-2014, possibly 2014-2015 (7-8 years)). As
described in Section 7.6.2, these observations span a
range of meteorological conditions. This will allow AEA to
meet study plan goals and objectives.
WILD-02 CCC 11/15/2012 “How will wildlife and fish be impacted by the change in ice conditions
and loss of stable transportation routes?” –pdf page 2
At this time, AEA believes it premature to assume any
impacts due to possible changes in ice conditions.
Potential impacts on terrestrial wildlife due to changes in
ice conditions and stability will be analyzed in the impact
assessment to be conducted in 2015 for the FERC
License Application, drawing on information produced by
the Geomorphology Study (Section 6.5), the Ice
Processes in the Susitna River Study (Section 7.6), the
Fish and Aquatics Instream Flow Study (Section 8.5), and
the Riparian Instream Flow Study (Section 8.6).
WILD-03 USFWS 11/14/2012 PISCIVOROUS WILDLIFE AND MERCURY RISK ASSESSMENT.
“The Service has requested that feathers from piscivorous birds using
the Project area, including Belted Kingfisher and other species, be
collected to provide the baseline information on current levels of
mercury critical to a wildlife and mercury risk assessment. The
Service has also requested that a study be conducted to determine
enough details of these birds’ diets (e.g., amount or percent fish) to
sufficiently inform this risk assessment. We are still in the process or
working with AEA to adequately develop this study.” –pdf page 148
Proposed methods for obtaining feather samples are
described in the RSP under Surveys of Eagles and Other
Raptors (Section 10.14.4), Waterbird Migration, Breeding,
and Habitat Use (Section 10.15.4), and Landbird and
Shorebird Migration, Breeding, and Habitat Use Study
(Section 10.16.4), depending on the bird species of
interest. Hair sampling of river otter and mink is described
under the Aquatic Furbearer Abundance and Habitat Use
(Section 10.11.4). The review of food habits and diets for
piscivorous species of wildlife also are described in these
sections of the RSP.
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Moose Distribution, Abundance, Movements, Productivity, and Survival
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
MOOSE-01 Strasenburgh,
John
11/14/2012 “Ice and snow conditions also affect wildlife movements and winter
refuges important to wildlife survival. For example, the current (no
dam) conditions allow moose to find refuge (e.g., in sheltered areas
near the river or on islands) from the heavy snows and where they
can feed on willow. High volume winter flows, ranging from 2 to 7
times the average winter flow (at Gold Creek), would potentially
eliminate these wintering areas.” –pdf page 2
The RSP includes components of several studies that will
examine ice and snow conditions, flow regimes, and
moose habitat in riparian areas downstream from the
proposed dam. The Riparian Instream Flow Study
(Sections 8.5 and 8.6) and the Riparian Vegetation Study
Downstream of the Proposed Watana Dam (Section 11.6)
will document current conditions and will model future
changes based on LIDAR, ADCP, and flow-stage data
collected during 2012–2014, which then can be used in
the impact assessment that will be conducted in 2015 for
the FERC License Application.
MOOSE-02 CCC 11/15/2012 “How will moose populations that congregate along the river in
winter be impacted by poor ice conditions?” –pdf page 2
The effects of changes in ice conditions and stability on
moose using riparian habitats downstream from the
proposed dam will be assessed in 2015 in the FERC
License Application after analyzing information produced
by the Ice Processes in the Susitna River Study (Section
7.6) and the Instream Flow Studies (Sections 8.5 and 8.6).
MOOSE-03 BLM 11/14/2012 “BLM acknowledges that most previous comments have been
adequately addressed and believes that the combined results from
the four study methods, namely the Moose Browse Survey and
Habitat Survey (8.5.4.3), will help sufficiently calculate mitigation
measures for the proposed inundation zone that will be assessed, if
the dam project proceeds. Future issues may be added as new data
becomes available.” –pdf page 3
AEA acknowledges and appreciates that BLM considers
the previous comments to have been addressed
adequately. In accordance with FERC’s ILP regulations,
AEA will propose any needed modifications to the study
plan in the Initial Study Report, if necessary, in response
to any new data that becomes available.
MOOSE-04 BLM 11/14/2012 “The BLM notes that the study plan puts less emphasis on
transportation corridors in the Moose Browse and Habitat Survey, by
stating that the “seasonal habitat use and importance of
the…transportation corridors will be quantified by analysis of radio
and satellite tracking data to determine…habitat preferences”.
Therefore, BLM believes the current study plan does not adequately
address moose habitat that may be lost and/or altered along the
transportation corridors to assist in mitigation measurement, since a
significant portion of the habitat is located on uplands away from the
forested inundation zone. Future issues may be added as new data
becomes available.” –pdf page 3
As is described in Sections 10.5.4.3 and 10.5.7 of the
RSP, two study elements will address the quality of moose
habitats in the road and transmission corridors. First, radio
telemetry for a large number of collared moose will provide
empirical data for the analysis of habitat preferences. The
browse survey will be conducted in a large area
encompassing habitats located both above and below the
proposed dam and reservoir within the extent of the GSPE
survey grid, and will include large areas of the proposed
access corridors. The browse data will be applied to the
wildlife habitat map produced by the Vegetation and
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Wildlife Habitat Mapping Study in the Upper and Middle
Susitna Basin (Section 11.5) and the Riparian Vegetation
Study Downstream of the Proposed Watana Dam (Section
11.6) to inform the habitat quality rankings that will be
produced by the Evaluation of Wildlife Habitat Use
(Section 10.19) for eventual use in the impact assessment
that will be conducted in 2015 for the FERC License
Application. Hence, the browse study information will be
applied to the entire Project area plus the 4-mile buffer
surrounding the corridor alignments.
AEA is confident that the intensive study methods
proposed for the Moose Distribution, Abundance,
Movements, Productivity, and Survival study will provide
solid information for future use in mitigation planning. In
the event new, relevant data becomes available during the
study process, AEA will propose any needed modifications
to the study plan in the Initial Study Report, if necessary,
in accordance with FERC’s ILP regulations.
MOOSE-05 ADF&G 11/14/2012 “ADF&G proposed this study and intends to conduct GeoSpatial
Population Estimation (GSPE) in the fall of 2012. If this is not
feasible due to weather or other constraint, then 2013 project will
need to be amended to include a GSPE component.” –pdf page 30
Unsuitable weather conditions and snow cover in
November 2012 precluded the GSPE effort, so Sections
10.5.4.2 and 10.5.6 of the RSP state that the GSPE
survey will be attempted again in November 2013 or, if
conditions are unsuitable, in March 2014. The late winter
(March) population survey in the reservoir inundation zone
in 2012 provided useful data on use of that area during a
year of record high snowfall, which will provide a good
comparison for the same type of survey planned in March
2013. Deployment of all 40 GPS collars in October 2012
will provide two full years of fine-scale movement data for
the Updated Study Report.
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Caribou Distribution, Abundance, Movements, Productivity, and Survival
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
CBOU-01 BLM 11/14/2012 “At this time, the BLM acknowledges that most previous
comments have been adequately addressed and current
study plan has generally addressed the needs of the BLM
to assess right-of- ways;
however, no current study addresses the cumulative
effects on Nelchina caribou herd (NCH)by the proposed
hydro project, the associated transmission and road
corridors, reasonably foreseeable mineral developments in
surrounding areas within the NCH range, and the
proposed expansion of FOX-3 military operations area.
BLM recommends that these likely foreseeable actions
should be included a cumulative effects analysis.
Future issues may be added as new data becomes
available.” –pdf page 3
AEA agrees that the RSP addresses the needs of the BLM to assess rights-
of-way.
Although cumulative effects will not specifically be analyzed as part of this
study plan, AEA plans to analyze cumulative effects in the environmental
analysis that will be prepared to support its License Application.
In accordance with FERC’s ILP regulations, AEA will propose any needed
modifications to the study plan in the Initial Study Report, if necessary, in
response to new information.
CBOU-02 ADF&G 11/14/2012 “This study was originally proposed to extend through
2016 in order to better characterize year to year variation
in caribou movement patterns, but it was changed to end
with the license application date of 2014. Two years of
data are not expected to sufficiently characterize caribou
movement patterns. This project will likely need to be
extended.” –pdf page 30
AEA believes that two years of data will provide sufficient information to
characterize variation in movement patterns. As explained in Sections
10.6.4 and 10.6.6, refurbished GPS collars will be redeployed late in 2014,
but no additional animals will be collared after 2014. Although ADF&G will
extend the study throughout the battery life of the collars into 2016, AEA
expects that the combination of telemetry data from historical APA studies,
ADF&G studies conducted since the 1980s, and the Caribou Distribution,
Abundance, Movements, Productivity, and Survival study described in the
revised study plan will provide adequate data on the movements of the
Nelchina and Delta caribou herds to support the Project impact
assessment.
However, when evaluating data collected during two years of study
(collected through the 4th quarter of 2014) during preparation of the Updated
Study Report, AEA will evaluate whether any additional information is
needed to assess Project-related effects on caribou movement patterns. At
that time, in accordance with FERC’s regulations, AEA will propose in the
Updated Study Report any needed modifications to the study plan, if
necessary, to sufficiently evaluate this issue.
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Dall’s Sheep Distribution and Abundance
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
DALL-01 ADF&G 11/14/2012 “DWC agreed to conduct Dall’s sheep surveys of suitable sheep
habitat within GMU 13E south of the Denali Highway and east of the
Parks Highway. ADF&G submitted a revised draft study plan that
describes this work.” – PDF page 31
AEA appreciates ADF&G’s input on study design and has
incorporated the material from ADF&G’s revised draft
study plan into AEA’s revised study plan. As described in
Section 10.7.3, the study area for Dall’s sheep consists of
the portion of GMU Subunit 13E south of the Denali
Highway and east of the Parks Highway.
DALL-02 ADF&G 11/14/2012 “The interim draft Dall’s sheep study plan appears to adequately
describe the study area and methods to be employed by ADF&G
during the summer count. The map still needs to be revised to reflect
the redefined study area.” – PDF page 31
The study area map (Figure 10.7-1) has been revised to
reflect the changes discussed with ADF&G in TWG and
small-group meetings in August, September, and October
2012.
DALL-03 ADF&G 11/14/2012 “As discussed at the October 16 Terrestrial Resources working group
meeting, ADF&G believes the proposed survey work along with
analysis of previous studies and site inspection of the Jay Creek and
Watana mineral licks is adequate to assess sheep status. It is not
necessary to intensively monitor the licks in 2013 or to place
radiocollars on sheep in the study area.” – PDF page 31
The revised study plan incorporates ADF&G’s suggested
changes in Section 10.7.4. No radio collars will be
deployed and the mineral licks will not be monitored
intensively.
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Distribution, Abundance, and Habitat Use by Large Carnivores
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
LGCAR-01 ADF&G 11/14/2012 “DWC agreed to conduct spatial modeling of bear density in
cooperation with David Miller of the University of Rhode Island and has
submitted a proposal describing the project.”
This proposed modeling effort was discussed in meetings
on September 13 and October 16, 2012 (see Appendices
3 and 4), was accepted by AEA, and has been included in
the RSP (Sections 10.8.3 and 10.8.4.1.1).
LGCAR-02 ADF&G 11/14/2012 “As noted in the interim draft RSP, DWC would like to be consulted
during sampling design and analysis of hair samples downstream of
the proposed dam for DNA and stable isotope analysis.”
Section 10.8.4.1.2 of the RSP describes consultation with
ADF&G concerning the sampling design and analyses of
hair samples for DNA and stable isotopes; for example,
ADF&G DWC recommended at the small-group meeting
on September 13, 2012 (see Appendices 3 and 4) that
the single-sample hair-snag trap developed by Lavern
Beier of DWC (Juneau) be used in field sampling. This
trap design has been added to Section 10.8.4 of the RSP.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 390 December 2012
Wolverine Distribution, Abundance, and Habitat Occupancy
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
WOLV-01 FERC 11/14/2012 “One of the study objectives is to describe late-winter habitat use by
wolverines. This information would be used, in part, to rank levels of
habitat use and assess direct and indirect loss and alteration of habitat
from project construction and operation activities. In their comments on
the study, ADF&G stated that a single aerial survey would not be
sufficient to develop habitat associations for wolverines and the
objective should be eliminated. ADF&G suggests that if such
information is needed to assess impacts, the most effective way to
obtain habitat associations is by using GIS telemetry. Your response to
this concern, as described in the Table 10.4-1 (Summary of
Consultation on Wildlife Resources Study Plans), indicates that you
eliminated this objective from the study. However, the draft revised
study plan still includes it. Your revised study plan should accurately
reflect your study objectives. Furthermore, your revised study plan
must explain how your study results will allow you to assess project
effects on available habitat and why you are not conducting the GIS
telemetry study in order to achieve the study objectives.” –pdf page 21
The comment by ADF&G on the PSP was acknowledged
and that specific objective was removed from Section
10.9.1 in an earlier draft of the revised study plan.
However, as is documented in Appendix 3 and under the
WOLV-3 comment below, continued consultation with
ADF&G included the addition of occupancy surveys and
modeling to the study methods (Section 10.9.4), which will
adequately address the objective of evaluating habitat
associations.
WOLV-02 ADF&G 11/14/2012 “DWC agreed to conduct a Sample-Unit Probability Estimator (SUPE)
survey for wolverine.” –pdf page 31
AEA agrees with this method, which has been adopted
and is described throughout the RSP (Section 10.9.4).
WOLV-03 ADF&G 11/14/2012 “This proposal includes conducting occupancy modeling in 2013 and
2014 and as such is expected to provide information on habitat
associations. Occupancy modeling will also provide population trend
information in the future.” –pdf page 31
AEA agreed to incorporate this method and the objective
of habitat associations and population trend analysis at the
October 16 TWG meeting. The method is described in the
RSP (Section 10.9.4).
Revised Study Plan
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FERC Project No. 14241 Page 391 December 2012
Terrestrial Furbearer Abundance and Habitat Use
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
TERFUR-01 ADF&G 11/14/2012 “DWC supports this project intended to assess abundance of coyote,
red fox, lynx, and marten with modifications to address concerns
expressed here.” –pdf page 31
AEA is pleased that ADF&G supports the proposed study
and appreciates the opportunity to work with ADF&G in its
development. AEA has addressed ADF&G’s specific
comments separately in the responses to the next three
comments (TERFUR-2, TERFUR-3, and TERFUR-4)
below.
TERFUR-02 ADF&G 11/14/2012 “DWC recognizes that objectives were edited in the interim draft RSP
to reflect that DNA analysis of scats and hair will be used for markers
rather than the raw sources (scat/hair) mentioned in the PSP
objectives. Similarly, the kind of snowshoe hare sign to be quantified in
objective 4 was specified as pellet counts.” –pdf page 32
After further consultation with ADF&G during the follow-up
meeting on September 13, 2012 (see Appendices 3 and
4), the wording of Objectives 1 through 4 was clarified to
reflect these changes (see Section 10.10.1, Study Goal
and Objectives).
TERFUR-03 ADF&G 11/14/2012 “To improve reliability of results the final study plan will need to
address sample sizes, capture heterogeneity, and population closure
for DNA mark-recapture estimates. The final study plan should also
address the length of the study and sample sizes relative to estimation
of vital rates and population size.” –pdf page 32
After further consultation with ADF&G during the follow-up
meeting on September 13, 2012 (see Appendices 3 and
4), more details regarding capture heterogeneity and
population closure for the mark–recapture analyses were
added to Section 10.10.4.4. Although sample sizes cannot
be predicted in advance, sample sizes have been
estimated and the relative effects of sample size and
recapture rate on the precision of mark–recapture
estimates are discussed in the third paragraph of Section
10.4.4. The study will be conducted over two years (2013–
2014) to provide the information needed for the FERC
license application.
TERFUR-04 ADF&G 11/14/2012 “FERC’s Integrated Licensing Process legitimately seeks to document
abundance of a wide variety of wildlife species prior to project
approval. The limitations of abundance data for species that depend on
the hare cycle and are naturally cyclic themselves must also be
acknowledged. This work will likely be conducted during a low in the
hare cycle, and so predator populations will likely be higher after dam
construction begins despite any direct effect of the development. While
the comparison to Denali National Park will help, caution is necessary.”
–pdf page 32
As is described in the 3rd and 4th paragraphs of Section
10.10.4.4, AEA understands that the study will occur
during a low phase of the snowshoe hare population cycle
and discusses the implications of that factor on the study
results and conclusions. Care will be exercised and
uncertainty will be acknowledged appropriately in drawing
conclusions and making comparisons with other areas.
Revised Study Plan
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FERC Project No. 14241 Page 392 December 2012
Aquatic Furbearer Abundance and Habitat Use
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
AQFUR-01 ADF&G 11/14/2012 “The interim draft RSP indicates that river otter track surveys
will be conducted repeatedly 2-3 days after fresh snow fall.
This approach lends itself to transect sampling. Occupancy
modeling from these data may also be feasible depending on
study design. DWC supports this general approach and
should be consulted during study design.” – pdf page 32
After further discussion with H. Golden of DWC (see Appendix 4),
the survey method for river otters (described in Section 10.11.4.2)
has been modified to include transect sampling (but not occupancy
modeling). Mr. Golden suggested that helicopter transects be
oriented perpendicularly to the mainstem Susitna River to sample
otters using areas away from streams, such as lakes and ridges or
passes between adjacent watercourses, rather than following
watercourses, as proposed in the interim draft RSP. AEA considers
the watercourse surveys to have value for detecting and
delineating areas likely to be used most consistently by river otters,
but also recognizes the need to sample areas away from
watercourses. Hence, Section 10.11.4.2 of the RSP has been
revised to state that, in early 2013, both types of surveys will be
flown and the results will be compared, so that further changes in
the survey approach can be made later in 2013 and 2014, if
warranted. In addition, it is expected that the helicopter transect
surveys proposed for the study of Terrestrial Furbearer Abundance
and Habitat Use (see Section 10.10.4.3) will provide additional
information on the occurrence of river otters.
AQFUR-02 USFWS 11/14/2012 “The Service’s study request includes an objective to
document baseline mercury levels in piscivorous wildlife in the
reservoir area, as measured in fur (for mink and river otter)
and feathers (avian piscivores).” – pdf page 48
The RSP (Section 10.11.1, Study Goal and Objectives) includes
acquisition of hair samples for river otter and mink as the fifth
objective of the Aquatic Furbearer Abundance and Habitat Use
study (see Sections 10.14–Surveys of Eagles and Other Raptors;
10.15–Waterbird Migration, Breeding, and Habitat Use; and 10.16–
Landbird and Shorebird Migration, Breeding, and Habitat Use
Study, for details regarding collection of feather samples). River
otter and mink hair samples will be sought from trapper-harvested
animals. If trapper harvests are insufficient, then hair-snags will be
deployed in the reservoir inundation zone and its tributary streams,
as is described in Section 10.11.4.3. Some samples of mink hair
may be obtained incidentally in hair-snag tubes intended for marten
hair sampling as part of the study of Terrestrial Furbearer
Abundance and Habitat Use (Section 10.10).
Revised Study Plan
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FERC Project No. 14241 Page 393 December 2012
Small Mammal Species Composition and Habitat Use
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
SMAM-01 ADF&G 11/14/2012 “The idea of removing the trapping effort from the study design was
discussed. The rationale for not trapping was to avoid killing a large
number of small mammals known to be in the study area from previous
studies.
Small mammal populations are very dynamic and tend to be eruptive.
Small mammals are very important to the prey base for mammals as
well as birds, especially raptors. Long term studies are necessary to
gather meaningful information. Given the limited opportunity to acquire
the necessary long-term information, there is some justification for not
engaging in a large one-time trapping effort.” –pdf page 32
At the TWG meeting on October 16, 2012, AEA proposed
to convert the small mammal study to an office-based
effort only, drawing on the intensive fieldwork conducted
for the original APA project in the early 1980s, which was
a more comprehensive and intensive effort than was
envisioned in the PSP. Based on the consistency of
relative abundance of most species of small mammals
across large portions of Interior and Southcentral Alaska,
the results of more trapping in 2013 likely would have
produced very similar results to the trapping conducted in
the 1980s. AEA concurs with ADF&G that a short-term
field trapping effort would not be likely to produce
significant new information beyond what has already been
well-documented in the Project area. In a telephone
conversation on November 25, 2012, BLM concurred with
the conversion of this study to an office-based effort (see
RSP Appendices 3 and 4).
Revised Study Plan
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FERC Project No. 14241 Page 394 December 2012
Bat Distribution and Habitat Use
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
BAT-01 FERC 11/14/2012 “The bat study has three specific objectives:
(a) assess the occurrence of bats and the distribution of habitats used by
bats within the impoundment zone and project infrastructure areas;
(b) review geologic and topographic data to assess the potential for roosting
sites and hibernacula in the study area; and
(c) examine suitable geological features and human-made structures
(bridges and buildings) for potential roosting sites or hibernacula.
The methods discussion states that ADF&G recommended documenting
seasonal variation in bat occurrence and activity, expanding sampling to
provide habitat-specific indices of abundance, and conducting a more
thorough survey of naturally occurring roosts, maternity colonies, and
hibernacula. [AEA does] not propose to conduct these efforts unless
seasonal concentration areas such as roosting sites, maternity colonies, or
hibernacula are located in 2013 because [AEA agrees] with ADF&G that
anticipated effects on these species are not expected to be great. [AEA
goes] on to say that ground searches for these concentration areas will be
done “to the extent possible” and “if suitable substrates exist.” Identification
of suitable natural substrates (limestone and large diameter trees) would be
based on literature and land-owner information. [AEA’s] statement of little
adverse effects would suggest that this study is not needed. Nonetheless, it
is unclear how [AEA’s] efforts would identify important seasonal
concentration areas for further study in 2014 and why ADF&G’s
recommendations should not be incorporated into the study plan now.
Further, [the] revised study plan should explain what would dictate “to the
extent possible.” –pdf page 21
ADF&G’s recommendations have been incorporated in the
Revised Study Plan (Section 10.13.4.1) to document
seasonal variations and habitat-specific levels of activity in
the study area and to conduct a search for roost sites,
maternity colonies, and hibernacula in 2013. The
proposed study methods (Section 10.13.4.1) include
documenting areas of seasonal concentration such as
maternity colonies and hibernacula, and the study will
continue in 2014 if such sites are discovered. The phrase
“to the extent possible” has been deleted.
BAT-02 ADF&G 11/14/2012 “Need to identify and locate geological features including any karst
topography, caves or abandoned hard rock mines that could serve as
maternity colonies or hibernacula.” –pdf page 33
This request has been addressed in Sections 10.13.1 and
10.13.4.1.
BAT-03 ADF&G 11/14/2012 “Locate any potential human-made structures within the inundation zone
that could serve as maternity colonies or hibernacula.” –pdf page 33
This request has been addressed in Section 10.13.4.1 and
includes coordination with the Cultural Resources Study
(Section 13.5) to locate suitable human-made structures
(see Section 10.13.7).
BAT-04 ADF&G 11/14/2012 “Document level of use for any maternity colonies or hibernacula identified.”
–pdf page 33
This request has been addressed in Section 10.13.4.1.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 395 December 2012
Surveys of Eagles and Other Raptors
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
RAPT-01 USFWS 11/14/2012 “Alaska Energy Authority’s (AEA) Proposed Study Plan (PSP)
addresses the U.S. Fish and Wildlife Service’s (Service) 31 May 2012
study request entitled the same. The goal of our study request was to
address Bald and Golden Eagles and other tree- and cliff-nesting
raptors in order to characterize population, productivity, habitat use
and other important aspects of local raptor species’ life histories, so as
to
(1) inform predictions and quantifications of potential impacts that may
result directly and cumulatively from the proposed Susitna-Watana
Hydroelectric Project, and to
(2) provide information required for a possible application(s) for federal
Eagle Take (lethal or disturbance take – see below) and/or Eagle Nest
Take Permits.” –pdf page 149
AEA appreciates USFWS’s involvement in the
development of this study plan and is pleased that
USFWS is satisfied that the study plan for Surveys of
Eagles and Other Raptors (Section 10.14.1, Study Goal
and Objectives) addresses the goal of USFWS’s study
request.
RAPT-02 USFWS 11/14/2012 “The Service is satisfied that most objectives will be adequately met by
following the basic study outline proposed in AEA’s PSP. Two
exceptions where objectives are not adequately addressed yet are the
lack of intent to survey for early nesting owls, and the lack of any study
plan to collect feathers, dietary information, or other data necessary to
conduct a mercury risk assessment for fish-eating birds, including Bald
Eagles.” –pdf page 149
AEA is pleased that USFWS is satisfied that the Proposed
Study Plan for Surveys of Eagles and Other Raptors
(Section 10.14.1, Study Goal and Objectives) is adequate
to meet most of their objectives. Based on further
meetings held since the filing of the PSP in July 2012 (see
Appendices 3 and 4 for details), further changes have
been made to the Revised Study Plan to address the two
exceptions identified by USFWS, as is explained below in
the responses to comments RAPT-3 and RAPT-4.
RAPT-03 USFWS 11/14/2012 “Mercury toxicity: The most important issue that remains to be
addressed is that there has been no intent reflected in any of the
Migratory Bird study plans, including the Raptor study plan, to collect
feathers and dietary information about Project-area fish-eating birds,
including Bald Eagles, a species that may be at risk from accumulation
of mercury. See PSP Section 5.12. Mercury Assessment and Potential
for Bioaccumulation Study.” –pdf page 149
Sections 10.14.1 (Objective 6), 10.14.4.1, and 10.14.7 of
the Revised Study Plan now include nonlethal collection of
feathers from the nests of piscivorous raptors (Bald Eagle
and, if available, Osprey) for analysis of mercury levels
(also see Section 5.7), as well as review and synthesis of
information on food habits, diets, and effects of mercury
on these birds. Similar methods are specified in the
Revised Study Plan sections for waterbirds (10.15),
landbirds and shorebirds (10.16), and aquatic furbearers
(10.11).
RAPT-04 USFWS 11/14/2012 “Owl surveys: We have also requested meeting with AEA during the
winter to finalize the details of the overall raptor study plan. Details
regarding owl-related issues left to consult on include:
Surveys of early nesting owls were discussed at the TWG
meeting on August 9, 2012, and at the follow-up meeting
on landbirds and shorebirds (and wildlife habitat
Revised Study Plan
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FERC Project No. 14241 Page 396 December 2012
Surveys of Eagles and Other Raptors
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
Further discussion of surveys for early nesting owls (and how these
may be combined with the landbird surveys).
The selection of specific study areas for migration routes that may
occur along planned transmission line routes.” –pdf page 149
evaluation) on September 6, 2012 (see Appendices 3 and
4 for details). AEA explained that it had concerns about
personnel safety because the surveys for certain species
(most notably Boreal Owl) would require intensive
nocturnal sampling during winter to detect a species that
occurs in low density over broad areas. At the September
6 meeting, USFWS agreed that specific surveys of small
cavity–nesting owls would not be needed, provided that
AEA acknowledges their occurrence in the study area and
includes them in the Evaluation of Wildlife Habitat Use
(Section 10.19), which AEA agreed to do. The other early
nesting species using tree cavities (Northern Hawk Owl),
as well as several species of small- to medium-sized
hawks, should be detected incidentally during point counts
for landbirds and shorebirds conducted during the month
of May. Short-eared Owls should be detected incidentally
on aerial surveys for other raptors and waterbirds, on point
counts for landbirds/shorebirds, and on migration visual
watches. Large species of early nesting owls that use stick
nests (Great Horned Owl, Great Gray Owl) will be
detected on aerial surveys for eagles and other tree-
nesting raptors. All of these details are described in
Section 10.14.4 of the RSP, and the coverage of small- to
medium-sized raptors on the landbird and shorebird point
counts is also described in Section 10.16.4.
As is described in RSP Section 10.14.4.1, circular plots for
migration point counts (with a fixed radius of 800 meters)
will be delineated along the length of the transmission line
corridors before the field surveys begin. Specific plots to
be sampled then will be determined by examining
topographical characteristics likely to concentrate flight
activity by migrating raptors. of the terrain.
RAPT-05 USFWS 11/14/2012 “Eagle surveys and permits: Further refinement may be required for
survey and analysis details for all aspects of the study plan, including
information gleaned from 2012 survey experience and results, and any
new information regarding the National Eagle Take Permit program.
AEA recognizes the evolving nature of the National Eagle
Take Permit Program and anticipates working with
USFWS in the coming months and years to ensure that
adequate data are collected on both species of eagles to
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 397 December 2012
Surveys of Eagles and Other Raptors
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
While no substantive new information is available today on the Permit
Program, it is a new and evolving Program, and additional information
may come from the Service’s Washington D.C. Headquarters over the
coming winter.” –pdf page 149
comply with federal laws, regulations, and policies. The
results of the 2012 surveys confirmed the utility of the
survey methods used to locate territories and nest of both
species (see RSP Section 10.14.2). The 2012 results also
underscored the need to allocate more survey time in
2013 and 2014 to assessment of sightability.
RAPT-06 FERC 11/14/2012 “In some cases, [AEA has] developed plans for and are carrying out
studies in consultation with stakeholders to voluntarily collect
information in 2012 that will help you prepare or refine a study plan.
Please describe how these 2012 efforts were or are being incorporated
into the RSP.” –pdf page 5
The results of the 2012 surveys confirmed the utility of the
survey methods used to locate territories and nests of
eagles and other raptor species (see RSP Section
10.14.2). These aerial survey methods are the same ones
described in Section 10.14.4.1 of the Revised Study Plan:
two nest occupancy surveys (late April to late May), two
nest productivity surveys (mid-June to late July), and four
surveys of potential foraging, staging, and communal
roosting areas (primarily for Bald Eagles, from mid-
October to early December). Survey numbers and timing
may be adjusted in 2013 and 2014, based on the results
of the surveys conducted in 2012 (Section 10.14.4.1) and
the phenology of the nesting season each year. The 2012
results also underscored the need to allocate more survey
time in 2013 and 2014 to assessment of sightability.
Revised Study Plan
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FERC Project No. 14241 Page 398 December 2012
Waterbird Migration, Breeding, and Habitat Use Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
WTRBRD-01 CSDA 11/14/2012 “Two years of bird studies are inadequate to understand bird migration
routes in order to determine new transmission line locations and their
impacts on migratory birds.” –pdf page 3
Implementing the study plan will yield information sufficient
to understand Project-related effects, if any, on migrating
birds. Moreover, more than two years of study will be
available to understand bird migration in the Project area.
The two-year bird study conducted for the original APA
Susitna Hydroelectric Project studies concluded that the
Project area was not a major corridor for migrating birds.
Nevertheless, AEA intends to conduct intensive monitoring
of spring and fall migration in the area of the proposed
dam in 2013 (using visual and radar detection methods),
as described in Section 10.15.4.1.2, and will use the
findings of that study as the basis for a decision on
whether to continue the radar monitoring study in 2014.
Aerial surveys of waterbirds will be conducted during
spring and fall in 2013 and 2014, as described in Section
10.15.4.1.1.
WTRBRD-02 Long, Becky 11/13/2012 Two years are inadequate, request for 5 to 7 year study –pdf page 2 See AEA’s response to comment WTRBRD-1.
WTRBRD-03 ADF&G 11/14/2012 “Harlequin duck surveys to be conducted from a R44 type helicopter
along all suitable moving water bodies (i.e. rivers, streams) within
study area. The interim draft RSP states that moving water bodies will
be surveyed as far upstream as practical; even outside of study area.
The number of moving water bodies surveyed and the extent to which
they will be surveyed will become more apparent after the initial survey
period. Question whether practical to follow streams all the way up into
the watershed (Watana Creek has a very large watershed outside of
study area).” –pdf page 33
The comment correctly characterizes AEA’s intent in
conducting helicopter surveys for Harlequin Ducks
(described in Sections 10.15.3 and 10.15.4.2.2), which
were discussed with ADF&G and USFWS at the small-
group meeting on waterbirds on October 4, 2012 (see
Appendices 3 and 4). Whereas ADF&G did not think it is
necessary to extend the Harlequin Duck surveys outside
of the 3-mile study area buffer, USFWS requested that it
be done, so AEA has accommodated the USFWS request
(also see AEA’s response to comment WTRBRD-15
below). AEA agrees with ADF&G that the extent of
suitable habitat will be defined better during the first
survey.
WTRBRD-04 ADF&G 11/14/2012 “DWC consulted with AEA and the USFWS and the interim draft RSP
appears to adequately address concerns discussed during
consultation.” –pdf page 33
AEA is encouraged to see that DWC considers the
concerns discussed during consultation after the release
of the PSP (documented in Appendices 3 and 4) to have
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Waterbird Migration, Breeding, and Habitat Use Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
been addressed adequately in the interim draft RSP.
WTRBRD-05 ADF&G 11/14/2012 “The interim draft does not specify a minimum size for waterbodies to
be surveyed. Surveyed lakes should include those surveyed previously
by Kessel et al. (1982). Experienced observers should also be able to
select waterbodies based on nesting habitat suitability in the immediate
vicinity of the waterbody.” –pdf page 33
Rather than specifying a minimum water body size to
define the sampling universe for the waterbird surveys,
AEA proposes a lake-to-lake survey approach targeting
water body complexes, as discussed at the small-group
meeting on waterbirds on October 4, 2012 (see
Appendices 3 and 4). Further description has been added
to Section 10.15.3. The same section of the RSP states
that surveys will included nearly all lakes surveyed by
Kessel et al. (1982) with the exception of six large lakes
between the Tyone and Maclaren river mouths, which are
well upstream from the area that may be affected by the
Project.
WTRBRD-06 USFWS 11/14/2012 “Objective 1 – Breeding Bird Use: Document, measure, and analyze
occurrence, distribution, abundance, productivity, habitat use, and
indices of waterbird numbers breeding in the Project area, so that
potential impacts of habitat loss and disturbance on breeding bird
number, by species, can be quantified. Most aspects of this objective,
with the exception of Harlequin Duck, appear to be on track towards
being met.” –pdf page 146
AEA is encouraged to see that USFWS considers most of
their stated objectives to be met by the RSP. Section
10.15.1, Study Goal and Objectives, directly addresses
these objectives. With regard to Harlequin Ducks, AEA
plans to employ the survey methods discussed and
agreed to in the small-group meeting on waterbirds on
October 4, 2012 (see Appendices 3 and 4), which are
discussed in more detail below in AEA’s comment to
response WTRBRD-14 and WTRBRD-15.
WTRBRD-07 USFWS 11/14/2012 “Objective 2 – Migration Use: Document, measure, and analyze
occurrence, distribution, abundance, habitat use, and seasonal timing
of waterbirds migrating through the Project area so that potential
impacts of habitat loss, disturbance, and collision with infrastructure on
birds flying across and/or using the Project area as stopovers during
migration may be estimated. Stop-over use is being addressed, but
unless a radar study occurs, the objectives concerning over-flying birds
will not be met.” –pdf page 146
The study plan addresses all aspects of the USFWS
objective concerning migration use, as is described in
several sections of the RSP. The aerial surveys planned
during spring and fall migration will address migratory
stopover use of waterbodies in the study area, as is
described in detail in Sections 10.15.3 and 10.15.4.1.1.
Visual and radar survey methods to investigate migratory
flights across the study area have been added to the RSP,
as proposed at the small-group meeting on waterbirds on
October 4, 2012, and as described in detail in Section
10.15.4.1.2. The radar study component was added by
AEA specifically to address USFWS’s request for more
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Waterbird Migration, Breeding, and Habitat Use Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
information on bird migration through the study area.
WTRBRD-08 USFWS 11/14/2012 “Objective 3 – Mercury Risk Assessment: Support other related
Susitna-Watana Project studies as needed, including the Piscivorous
Wildlife and Mercury Risk Assessment. This objective is not being met
at this time, which is of considerable concern to the Service.” –pdf
page 146
Section 10.15.4.3 of the RSP describes the planned
literature review and synthesis of information on food
habits, diets, and effects of mercury on waterbirds, which
was included as an objective of this study in the PSP.
Section 10.15.4.3 has been updated to include nonlethal
collection of feathers after the nesting season from the
nests of piscivorous waterbirds, as available, and from
prey remains collected at Peregrine Falcon nest sites.
Those samples will be provided to the investigators
conducting the mercury risk assessment for analysis of
mercury levels (described in Section 5.7.4.2.5). Collection
methods for feathers and hair also are described in the
respective study plans for fish-eating species of eagles
and other raptors (Section 10.14.4.1), landbirds and
shorebirds (Section 10.16.4.6), and aquatic furbearers
(10.11.4.3). The RSP includes sampling of feathers and
hair of piscivorous birds and aquatic mammals (Section
5.7.4.2.5), a predictive risk analysis of possible impacts
(Section 5.7.4.2.5.4), fish tissue sampling (Section
5.7.4.2.6), and three modeling methods (Section 5.7.4.3).
WTRBRD-09 USFWS 11/14/2012 Breeding Season: “We believe, that as of the October 4, 2012,
interagency meeting on the Waterbird PSP, we have reached general
agreement on most aspects of the breeding season survey, except
with regard to Harlequin Duck. For most other species, and given that
much of the Project-area terrain is difficult for flying transects and that
there are a relatively finite number of lakes, we are in general
agreement on the adequacy of a lake-to-lake pattern of aerial surveys
to be run continuously and with the same methodology as the
migration surveys. Surveys are planned for a minimum of 7-day
intervals once breeding season is determined to have commenced,
and will continue until more frequent surveys begin for fall migration.” –
pdf page 146
AEA is encouraged that USFWS thinks that general
agreement has been reached on most aspects of the
breeding-season surveys. With regard to Harlequin Ducks,
AEA plans to employ the survey methods discussed and
agreed to in the small-group meeting on waterbirds on
October 4, 2012 (see Appendices 3 and 4), which are
discussed in more detail below under Comments
WTRBRD-14 and WTRBRD-15. The lake-to-lake survey
pattern is described in Sections 10.15.3 and 10.15.4.1.1
and the transition from migration to breeding surveys is
described in Sections 10.15.4.1.1 and 10.15.4.2.1. The
aerial surveys conducted during spring migration will occur
at intervals of 5 days (weather permitting), as was agreed
to at the October 4, 2012 small-group meeting, and the
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decision to transition to breeding surveys will be made
based on the chronology of the season each year and the
species composition and behavior of the waterbirds. AEA
does not propose to conduct weekly surveys throughout
the entire breeding season until fall migration, as
suggested in the comment. Rather, as was discussed in
the October 4 meeting and is described in Section
10.15.4.2.1, two breeding-pair surveys will be flown in
June, with an interval of approximately 10 days between
surveys, to target the expected peaks of breeding by
dabbling ducks and diving ducks, respectively. The next
breeding-season surveys flown after that will be brood
surveys, beginning about mid-July, as is described in
Section 10.15.4.2.3.
WTRBRD-10 USFWS 11/14/2012 Breeding Season: “Clearly describe how actual survey area and extent
will be determined (e.g., how many lakes and which lakes?)” –pdf page
146
As is described in Section 10.15.3, the study area will
encompass all waterbodies located within the 3-mile buffer
portrayed in Figure 10.15-1, plus several other
waterbodies that were sampled by Kessel et al. (1982)
outside of that buffer and the newly delineated transect-
survey block located east of the upper end of the reservoir
inundation zone. Section 10.15.3 describes the process
for selecting the sample of waterbodies to be surveyed
during the migration, breeding-pair, and brood surveys.
The survey will attempt to cover as many of the water
body complexes in the study area as possible (with the
exception of the breeding-pair transect sampling that will
be done in the transect-survey block). All waterbodies
known to have been sampled by Kessel et al. (1982) will
be included, except for six lakes between the Tyone and
Maclaren river mouths, which are located far upstream
from the area of probable impact. Brood surveys will
concentrate on waterbodies within 1 mile of the reservoir
inundation zone and access and transmission corridor
alignments (see Section 10.15.4.2.3).
WTRBRD-11 USFWS 11/14/2012 Breeding Season: “All actual flight lines should be recorded. It is critical Sections 10.15.3 and 10.15.4.1.1 describe the use of GIS
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that the boundaries and sizes of all surveyed lakes and any other
survey areas be clearly delineated so that survey area can be
calculated.” –pdf page 146
and GPS to plan and record survey flight lines. The same
flight path will be followed on each migration and
breeding-pair survey to accomplish consistent survey
coverage and to allow for delineation and calculation of
water body areas for use in density calculations. Brood
surveys will target waterbodies within 1 mile of Project
infrastructure (see Section 10.15.4.2.3).
WTRBRD-12 USFWS 11/14/2012 Breeding Season: “Use brood surveys and other data to back-date and
estimate actual timing of spring migration’s end, and commencement
and end of breeding season each year. Take into account inter-species
differences in timing.” –pdf page 147
As is described in Section 10.15.4.2.3, the age classes of
young waterbirds found on the brood surveys in July will
be used to estimate the probable dates of hatching and
laying by back-dating using standard reference materials
describing developmental stages.
WTRBRD-13 USFWS 11/14/2012 Breeding Season: “Ensure that careful analyses address the
relationship between the numbers or indices obtained and the actual
populations targeted. How will such issues as timing and behavioral
differences among species, turn-over rates, and variable visibility
conditions be addressed?” –pdf page 147
As is described in Section 10.15.4.2.1, standard USFWS
protocols will be followed to convert raw survey counts to
indicated total population indices and species-specific
correction factors will be applied to the indices to derive
population estimates of each species detected in the
transect strips for which correction factors are available.
Breeding-pair surveys will be timed to coincide with the
peak presence of pairs and males of dabbling ducks and
diving ducks to account for the differences in migration
timing and turnover of those two general categories of
ducks. Weather and visibility conditions will be recorded
during surveys to assess the quality of the information
recorded, and surveys will not proceed unless conditions
are suitable.
WTRBRD-14 USFWS 11/14/2012 Breeding Season: “With regard to Harlequin Duck, this species is not
reliably surveyed by the aerial survey methods proposed. While it is
possible that we may come to agree that some aerial survey
methodology will have to be considered adequate, further discussion
about this species is warranted. Some ground-based surveys may be
necessary, and may potentially be combined with riparian
landbird/shorebird surveys, depending on timing and other factors.
Survey effort and timing has been generally discussed as including two
Sections 10.15.3 and 10.15.4.2.2 describe the aerial
survey methods planned for use in Harlequin Duck
surveys to detect pre-nesting pairs and brood groups, as
was discussed and agreed to in the interagency small-
group meeting on waterbirds on October 4, 2012 (see
Appendices 3 and 4). The planned helicopter survey
technique is a standard, efficient method that has been
used successfully by USFWS and others to survey for this
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surveys sometime in May and two later in July or August for broods,
but we expect that actual timing will be determined based on observed
annual environmental conditions and breeding phenology indicators.” –
pdf page 147
species in Alaska and Canada, as is documented in
Section 10.15.5 with relevant citations listed in Section
10.15.9. Hence, no ground-based surveys are planned for
this species, although observers conducting riparian point-
count surveys for the landbird/shorebird study (Section
10.16) may record Harlequin Ducks, because they will
record all bird species detected on those surveys. The
exact timing of the helicopter surveys will be based on the
specific environmental conditions and breeding chronology
observed each year.
WTRBRD-15 USFWS 11/14/2012 Breeding Season: “There is general agreement between AEA and the
Service, that the waterbird study area will likely be modified for
Harlequin Ducks to include portions of streams that extend outside of
the 2-mile buffer of the Project area. All potential Harlequin breeding
streams that cross the Project area (i.e., footprint plus 2-mile buffer)
should be surveyed entirely along the lengths of suitable habitat,
whether or not that habitat (i.e., particular stream reach) extends
outside the project area. This is because breeding birds may travel up
and down their stream, and may be located off-site during a given
survey.” –pdf page 147
Sections 10.15.3 and 10.15.4.2.2 describe the survey area
for Harlequin Ducks as extending outside of the waterbird
study area (which is based on a 3-mile buffer around
Project alignments and the reservoir zone, not a 2-mile
buffer) wherever necessary to cover suitable stream
habitats located upstream from the study area boundary.
AEA notes that ADF&G and USFWS differ in their
recommendations regarding the upstream extent of survey
coverage (see Comment WTRBRD-03 above), but AEA’s
approach will be to cover all suitable habitat along these
streams, which will be better defined on the first pre-
nesting survey in late May 2013.
WTRBRD-16 USFWS 11/14/2012 Migration Use: “The Service believes that as of the October 4, 2012,
meeting we have reached agreement on the basic aspects of the sub-
study that will target waterbirds using the Project-area habitats during
migration. AEA and the Service generally agree that:
• the study area (Project footprint and same 2-mile buffer as
described in the landbird/waterbird PSP comments) is appropriate
as described;
• the concept of a “lake-to-lake” study pattern is appropriate, but
details are still pending;
• survey intensity of every 5 to 7 days beginning in approximately
mid-May for spring migration and early to mid-July through October
for fall migration (with initial spring survey dates based on thaw
AEA is encouraged that USFWS thinks basic agreement
has been reached on the migration surveys.
The waterbird study area is based on a 3-mile buffer
around the reservoir inundation zone and the alignments
for the access and transmission corridors, not a 2-mile
buffer (see Section 10.15.3).
Selection of the waterbodies to be surveyed on the lake-
to-lake surveys during migration and the breeding season
is described in Section 10.15.3 and 10.15.4.1.1,
10.15.4.2.1, and 10.15.4.2.3 (also see entries for
Comments WTRBRD-10 and WTRBRD-11, above).
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degree days or other careful analysis of current local weather data,
and, for fall, the timing results of the preceding breeding season
surveys) is agreeable.” –pdf page 147
As is described in Sections 10.15.4.2.1.1 and 10.15.6,
spring migration surveys will begin in late April, with the
exact start date being determined by field observations of
the timing and progress of break-up, rather than on
thawing degree-days. Fall migration surveys will begin in
mid-August rather than early to mid-July (brood surveys
will be conducted in July and possibly early August,
however). The survey interval between successive
migration surveys will be 5 days.
WTRBRD-17 USFWS 11/14/2012 Migration Use: “The study area will be the same as that for breeding
birds, and, as noted above, details remain to be worked out regarding
the precise extent of lake coverage (i.e., how many and which
waterbodies, and minimum size cut-off of waterbody to be surveyed).
Analysis details also need to be discussed, including derivation of
detectability indices and estimates of abundance, etc.” –pdf page 147
The selection process for waterbodies to be covered by
the lake-to-lake surveys is described in Sections
10.15.4.1.1, 10.15.4.2.1, and 10.15.4.2.3 (also see entries
for Comments WTRBRD-10, WTRBRD-11, WTRBRD-16,
above).
The migration surveys will produce counts of the number
of birds of each species on the survey waterbodies.
Detectability estimation will not be conducted for the
migration surveys (but species-specific population indices
and correction factors will be used for the breeding-season
surveys).
WTRBRD-18 USFWS 11/14/2012 Migration Use: “The Service recommends that AEA develop and
expand a draft proposal for a radar study that addresses birds flying
across the Project area (with coordinated visual surveys). As
discussed in the comments on the landbird/shorebird PSP, one of the
Service’s primary objectives is to survey birds flying across the Project
area during migration. Because of the risk of collisions to birds in flight,
including substantial long-term cumulative impacts, we continue to
recommend that surveys be conducted to identify and characterize
migratory pathways in the Project area. We recognize that the
geographic scale will be difficult to tackle with limited radar capabilities.
At the October meeting, the use of radar at the dam site was verbally
proposed by AEA contractors. This would presumably target all
species, including landbirds, shorebirds, raptors and others, as well as
waterfowl. With further discussion, the Service may find limiting the
The methods proposed for radar and visual surveys of
migratory movements by all species of birds around the
dam site in 2013 is described in detail in Sections
10.15.4.1.2 (and is referenced in Section 10.16.4.4). The
decision to conduct a second year of study in 2014 will be
based on the results obtained during the spring and fall
migration monitoring in 2013.
Regardless of whether one or two years of radar/visual
monitoring surveys are conducted, however, AEA intends
to follow industry standards and best practices (examples
cited in Section 10.15.7) in designing transmission towers
and siting transmission lines to reduce risk to birds, in
marking transmission lines for maximum visibility, and
using bird-safe lighting at all Project facilities to minimize
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radar studies to the dam area as proposed sufficient, IF coupled with:
a) appropriate analyses of existing information to help locate
transmission lines in bird-safe areas, b) commitment to a well-
researched and detailed plan to mark and micro-site all transmission
lines in a bird-safe manner (i.e., avoiding cliffs or drainages, etc., that
may be used by migrating birds), and c) commitment to a well-
researched bird-safe lighting operations plan at all Project facilities.” –
pdf pages 147-148
the attraction of birds, consistent with human safety
considerations dictated by other federal and state
agencies.
WTRBRD-19 USFWS 11/14/2012 Piscivorous Wildlife and Mercury Risk Assessment: “The Service has
requested that feathers of piscivorous birds using the Project area,
including Belted Kingfisher and other species, be collected to provide
the baseline information on current levels of mercury critical to a
wildlife and mercury risk assessment. The Service has also requested
that a study be conducted to determine enough details of these birds’
diets (e.g., amount or percent fish) to sufficiently inform this risk
assessment. We are not yet aware that these studies are being
planned by AEA.” –pdf page 148
The RSP (Section 10.15.4.3) has been updated to
describe the nonlethal method proposed to collect feathers
of piscivorous waterbirds after the nesting season from
nests of loons, grebes, and Arctic Terns, as well as from
prey remains at nest sites of Peregrine Falcons, which
prey on a variety of waterbirds. Feather collections of
other species of piscivorous birds are described elsewhere
in Sections 10.14.4.1 and10.16.4.6. Feather samples will
be provided to the researchers working on the Mercury
Assessment and Potential for Bioaccumulation Study
(Section 5.7) for laboratory analysis of mercury levels. In
addition, a literature review and synthesis of information
on food habits, diets, and effects of mercury on
piscivorous waterbird species will be conducted and that
information will be provided to the researchers working on
the mercury assessment study.
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BREED-01 CSDA 11/14/2012 “Two years of bird studies are inadequate to understand bird migration
routes in order to determine new transmission line locations and their
impacts on migratory birds.” –pdf page 3
AEA believes that two years of data will be sufficient to
understand bird migration movements in the Project area.
A detailed study of bird migration in the area of the
proposed dam (using visual and radar detection methods)
is noted in Section 10.16.4.4 and described in detail in
Section 10.15.4.1.2.
BREED-02 CSDA 11/14/2012 “Two years of data will be insufficient to calculate the densities of land
birds and shorebirds due to the short time period during each season.
This refers to the draft RSP study Breeding Survey Study of Landbirds
and Shorebirds.” –pdf page 3
AEA believes that two years of data will be sufficient to
calculate densities. Point-count surveys will be conducted
for approximately 30 days each season, and with 4 field
teams it is likely that upwards of 800 point-count sites will
be sampled each year. With 1,600 point-count sites,
sufficient data should be available to calculate densities, at
least for the more common species. For uncommon
species for which there will be fewer observations,
removal analyses (as recommended by the USFWS) will
be conducted to improve detectability estimates.
Additionally, detection functions will be “borrowed” from
other studies in the region, as needed, to increase
precision in the density calculations for uncommon
species (see Section 10.16.4.1.3).
BREED-03 Long, Becky 11/13/2012 Two years are inadequate, request for 5 to 7 year study. –pdf page 3 With an intensive point-count study effort in 2013 and
2014, AEA will have sufficient data to calculate densities
for breeding landbirds and shorebirds for the two years of
the study (see AEA’s response to comment BREED-02
above). This information will be used to provide an
estimate of the numbers of birds that could be affected by
Project development, and this estimate will be interpreted
with an understanding of both (1) the variability inherent in
density estimates derived in point-count survey data, and
(2) the known variability in breeding bird numbers in
Alaska among years. Additionally, AEA will have sufficient
information on habitat-use from these same point-count
surveys to quantitatively estimate habitat loss, habitat
alteration, and disturbance effects for breeding landbirds
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and shorebirds.
BREED-04 ADF&G 11/14/2012 “Establishing 3 – 4 or more distance bands instead of requiring
observers to estimate actual distances.” –pdf page 34
All data will be recorded in distance classes in the field as
described in Section 10.16.4.1.2.
BREED-05 ADF&G 11/14/2012 “Observers must be trained, tested and prequalified for species
identification and distance before going afield.” –pdf page 34
All observers will be trained, tested, and prequalified for
bird identification (visual and auditory) and distance
estimation, as described in Section 10.16.4.1.2.
BREED-06 ADF&G 11/14/2012 “Using double observers if densities are to be calculated. Using double
observers has been the subject of debate, most recently at the
Terrestrial Wildlife Working group meeting on October 15, 2012. DWC
continues to recommend use of double observers as it is the best way
to overcome deficiencies described above.” –pdf page 34
AEA concurs with the USFWS perspective (as stated by
the USFWS landbird coordinator for Alaska at the
landbird-shorebird meeting on September 6, 2012 [DWC’s
landbird specialist was not in attendance; see RSP
Appendices 3 and 4]), that a combination of removal and
distance analyses would be adequate to calculate
detection probabilities, and that using double-observer
methods is not likely to result in substantially more reliable
estimates of detectability. Adding double-observer
methods would result in three analyses used to calculate
detection probabilities, which is unnecessarily duplicative.
Moreover, it is well known that the density estimates from
point-count data are highly variable (due largely to
variation in distance estimates, which is independent of
detectability), and AEA believes that adding another
analysis to inherently variable data is unlikely to
substantially increase confidence in the resulting density
estimates. For these reasons, AEA is not planning to
incorporate double-observer methods in the point-count
surveys.
BREED-07 ADF&G 11/14/2012 “DWC supports 2 sampling periods and 2 years of sampling as called
for in plan.” –pdf page 34
AEA is pleased that DWC supports the two sampling
periods in each of two years protocol, as outlined in RSP
Section 10.16.
BREED-08 ADF&G 11/14/2012 “Need specific surveys to inventory shorebirds and cavity nesters in
addition to raptors and water birds as proposed.” –pdf page 34
Point counts have recently been adopted for inventories of
shorebirds by the USGS and others, and have been
recognized by the Alaska Shorebird Group as an
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appropriate method to survey for shorebirds, especially in
forested areas in which shorebird habitat is patchy in
occurrence. Aerial surveys for shorebirds are not suitable
(low identification potential) and plot-based methods for
shorebird surveys (in forested habitats as opposed to
tundra habitats on the North Slope) are likely to result in
few observations of low-density nesting shorebirds. AEA
believes point-count surveys will be adequate to inventory
shorebirds in the largely forested Project area. Specific
surveys for cavity nesters are likely to involve a large effort
for little data in return (for these relatively uncommon
species). The same survey concerns for cavity nesters
also apply to the requested surveys of owls and small
raptors (see AEA’s response to comment BREED-24
below). Cavity nesters are likely to be detected, at least
when in-transit between point-count locations and during
other wildlife survey efforts in the Project area. Cavity
nesters will not be ignored. Project effects on cavity
nesters will be assessed through evaluations of habitat
use and impact assessments of habitat
loss/alteration/disturbance for those species, to be
conducted in the FERC License Application (see Section
10.19).
BREED-09 USFWS 11/14/2012 “The U.S. Fish and Wildlife Service’s (Service) objectives, as outlined
in our May 2012 study request, include conducting field surveys and in-
house assessments to aid estimation of potential Project impacts on
migratory shorebirds and landbirds and their habitats, including birds
breeding in the Project area, migrating across it, and over-wintering
there. A final important objective is to support other Susitna-Watana
Project studies including a Piscivorous Wildlife and Mercury Risk
Assessment. The July 2012 Alaska Energy Authority (AEA) proposed
study plan (PSP) did not include objectives to study birds migrating
across the study area, or overwintering birds. The AEA PSP also does
not adequately meet the shared (between the Service and the AEA)
objectives for breeding bird studies or the Piscivorous Wildlife and
A specific migration study is now proposed, which would
include landbirds and shorebirds (see Section 10.16.4.3).
This study would involve radar and visual surveys of all
migrant birds near the proposed dam site. The USFWS is
aware of this study proposal and appears to approve of it
(see AEA’s response to comment BREED-25 below). At
the September 6, 2012 landbird-shorebird meeting (see
Appendices 3 and 4), the USFWS stated that they did not
believe that surveys for overwintering birds were needed,
and that the data from the 1980s for overwintering birds in
the Project area could be used to determine the
occurrence and abundance of overwintering bird species.
The USFWS also notes (in the comment BREED-20
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Mercury Risk Assessment.” –pdf page 150 below) that they believe surveys for overwintering birds
are not necessary. A specific survey effort for piscivorous
and partly piscivorous landbirds and shorebirds is now
proposed (see Section 10.16.4.2), as well as a literature
review study for those species (see Section 10.16.4.6),
and the data from those two study efforts will be used to
support the Mercury Assessment and Potential for
Bioaccumulation Study.
BREED-10 USFWS 11/14/2012 “Wildlife Habitat Mapping. The PSP proposes to use Viereck et al.
(1992) to classify vegetation, which may be insufficient to address
migratory bird habitat use. We recommend that a combination of
Kessel’s bird habitat classification and Viereck et al.’s systems may be
more appropriate, and recommend utilizing Alaska Landbird Monitoring
Survey (ALMS) developer Colleen M. Handel’s (USGS) experience
with this.” –pdf page 150
The proposed methodology (Viereck et al. 1992, Level IV
vegetation types, plus ABR’s landscape feature additions),
will address habitat parameters beyond plant species
composition and vegetation types (e.g., vegetation
structure, landscape position, disturbance level). The
habitat mapping approach is further described in Section
11.5.4.2. The USFWS has not located the USGS report
that compares the Viereck and Kessel classifications, but
in the absence of that material, AEA has prepared a
“crosswalk” between the two classification systems and
has the following comments. First, some aspects of the
Kessel classification system will be integrated into the
mapping of habitats for the Project (e.g., cliff and bluff
faces for nesting birds will be extracted from barren
vegetation types using DEM data). Second, the low,
moderate, and tall shrub classes used in the Kessel
system cannot be consistently delineated from aerial
imagery. Those fine-scale shrub classes can be used for
on-the-ground vegetation classifications, but those three
shrub classes cannot be reliably identified from aerial
imagery (the Project will use a habitat map derived from
aerial imagery to quantitatively estimate habitat loss and
alteration effects). Lastly, AEA notes that recent Alaskan
landbird data indicate that the clean separations in habitat
use by landbird species in low, moderate, and tall shrub
types, which Kessel refers to in her 1979 paper, are not
common. Rather, many species often show a wide range
in use of shrub types with an emphasis, in some cases, in
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tall or low shrub habitats depending on the species. AEA
will use the complete range in habitat use for each species
(e.g., from low to tall shrub types) in the estimates of
Project-induced habitat effects noted above.
BREED-11 USFWS 11/14/2012 “Study Area. We are in agreement that the primary study area is within
a modified 2-mile buffer zone around the Project footprint.
Modifications include shortening the buffer width in a few areas where
there are prominent barriers or boundaries on the landscape, such as
not crossing the Chulitna River.” –pdf page 150
AEA is pleased that the USFWS agrees on the study area
to be used for the point-count surveys. The 2-mile buffer
has been truncated at the western ends so as to not cross
the Parks Highway, Chulitna River, or the Alaska Railroad
corridor (see Section 10.16.3).
BREED-12 USFWS 11/14/2012 “It would be beneficial to set up comparison plots for field surveys in
off-site areas such as Denali or the Copper River Basin for purposes of
examining relative abundances and even estimations of habitat
availability for calculations of Project impacts on long-term productivity.
We will forego a formal request for this, although AEA should
recognize that this may mean that any future assertions about relative
“values” of Project-area habitat to birds may not be scientifically
supported.” –pdf page 151
Comparative reference plots in an undisturbed region
might be informative in evaluating the Project’s long-term
impacts, but this is a broad, landscape-scale monitoring
question that will have to be addressed later in the
licensing process. Additionally, there may be more
focused methods to evaluate the primary impacts of the
proposed Project on breeding landbirds and shorebirds,
which would be the displacement of birds from their natal
habitats.
BREED-13 USFWS 11/14/2012 “Estimations of Breeding Bird Densities. It is critical that an objective of
this study be a quantification of breeding birds using the Project site
that is more rigorously supported than merely an estimation derived
from assumed habitat associations. At the end of our September
discussion it appeared that AEA had agreed to the use of distance
estimation methodology in order to achieve this quantification.” –pdf
page 151
AEA agreed, at the September 6, 2012 landbird-shorebird
meeting (see Appendices 3 and 4), to use removal and
distance analyses to calculate densities for breeding
landbirds and shorebirds and has included text to this
effect in the RSP (see Section 10.16.4).
BREED-14 USFWS 11/14/2012 “Incorporation of detection probabilities according to habitat types will
be needed in order to address some of the deficiencies of distance
estimation methodologies. Further discussion and work is needed in
order to ensure survey and analysis details are clear and agreed to
prior to the initiation of the first field season.” –pdf page 151
More clarification on the field methods and data analysis
proposed is provided in the revised PSP (see Section
10.16.4). AEA is following the recommendations for field
methods (ALMS protocols) and data analysis for point
counts as provided by the USFWS at the September 6,
2012 landbird-shorebird meeting (see RSP Appendices 3
and 4). Detection probabilities will be calculated using the
two methods (removal analyses and distance analyses)
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recommened by the USFWS landbird coordinator for
Alaska at that same September 6, 2012 landbird-shorebird
meeting.
BREED-15 USFWS 11/14/2012 “Survey Timing and Level of Effort. Unfortunately, it does not appear
that an analysis has been conducted to determine the ideal number of
point counts per habitat type actually needed to provide necessary
data per species. In the absence of that analysis, however, we believe
that an agreement has been tentatively reached to conduct daily early-
morning surveys for fifteen days in April and then basically
continuously (with allowances for weather days) from early to mid-May
through mid-June. A minimum of four two-person crews will each
conduct at least eight point surveys per morning.” –pdf page 151
AEA is not aware of a request for a formal analysis to
determine the optimal number of point counts per habitat.
An optimal number of point counts per species, of course,
depends on their local abundance, which will be
determined in this study. Briefly, given that surveys are
planned over a roughly 30-day period (see below), and
that 4 teams can conduct at least 8 counts per day and
probably more: 32/day x (30 - 5 weather days) = ~800
point counts per year. Assuming 25 habitat types will be
mapped, there could be: 1,600 counts/25 = ~64 point
counts per habitat over two years. At the September 6,
2012 landbird-shorebird meeting (see Appendices 3 and
4), the USFWS landbird coordinator for Alaska indicated
that he did not believe point-count surveys in April were
necessary, and that removal analyses would help correct
the abundance data for resident species, which are
recorded less commonly in point-count surveys than
migrant species. Resident species are typically recorded
(albeit in low numbers) during point counts in May and
June, but they may be more prevalent during May at the
higher elevations typical of the Project area. AEA has
agreed to double the originally proposed survey effort, so
that surveys would be conducted over an approximately
30-day period from mid-May to mid-June. As indicated in
Section 10.16.4, the May surveys would target shorebirds
and early nesting landbirds and the June surveys would
target later nesting landbirds, mostly neotropical migrants.
BREED-16 USFWS 11/14/2012 “It is expected, and was generally agreed to, that exact timing of onset
of surveys will be based each year on careful examination of local
conditions (e.g., snowmelt, current reports of bird movement and
nesting timing locally and off-site, etc.).” –pdf page 151
This is correct. Survey timing will be flexible in each year
to accommodate any variability in the onset of breeding
activities of landbirds and shorebirds because of variability
in environmental conditions. This is described in the RSP
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in Section 10.16.4.1.2.
BREED-17 USFWS 11/14/2012 “Timing and effort protocol issues that may remain as sources of
difference between the Service and AEA include our recommendations
for double count observer methodology to help address detectability
biases,
and for subsets of points to be replicated within a year and between
years to help account for local inter-annual variation in timing of bird-
breeding.
Also because of the potential magnitude of inter-annual variation, we
stress that two years of data is not likely to be sufficient to best meet
study objectives.” –pdf page 151
See AEA’s response to BREED-06, which was prepared in
response to ADF&G’s comment on this same topic. AEA
believes that replicate point-count plots within a year or
between years will be counterproductive to one of the
primary goals of this study, which is to provide abundance
data on the less common species of conservation
concern. To collect adequate data on uncommon species,
which typically are patchy in occurrence, it is important to
conduct point counts in many different locations. Given
that survey timing will be adjusted each year to account for
any variability in the timing of breeding (because of
environmental factors; see AEA’s response to comment
BREED-16 above), AEA believes it is not necessary and
counterproductive, as noted above, to replicate point-
count plots within a year or between years in an attempt to
account for inter-annual variation in the timing of breeding.
BREED-18 USFWS 11/14/2012 “General Methodology. It is expected that ALMS protocol for
conducting surveys be followed.” –pdf page 151
As noted in RSP Section 10.16.4, ALMS protocols for
point-count surveys will indeed be followed, except that
the collection of vegetation data at each point-count
location will not be necessary (see AEA’s response to
comment BREED-19 below).
BREED-19 USFWS 11/14/2012 “Collection of Vegetation Data. Collection of vegetation data during
point counts, especially for two-person crews using double observer
methodology, is not appropriate. We are unclear at this time how or
when AEA plans to collect per-point vegetation data or precisely what
variables will be collected.” –pdf page 151
AEA will not be collecting detailed vegetation data at each
point-count plot because a fine-scale wildlife habitat map
will be prepared for the Project and the map will
encompass the entire point-count study area. The point-
count study will be conducted in close coordination with
the Vegetation and Wildlife Habitat Mapping Study in the
Upper and Middle Susitna Basin (Section 11.5). The
habitat surveyed at each point-count plot will be
determined by the habitat that is mapped at each point-
count site in the wildlife habitat mapping process. Point-
count observers, however, will be asked to record the
habitat that birds are actually using at the time of
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observation, and the habitat records from the point-count
surveys also will be used as additional ground-reference
data for the habitat mapping effort (see Section
10.16.4.1.2).
BREED-20 USFWS 11/14/2012 ““Over-Wintering” Birds. We have come to general agreement that
collection of over-wintering use will not occur, but that resident birds
(including woodpeckers, owls, chickadees, etc.) will be targeted for
breeding surveys during appropriate (i.e., for each given year, based
on actual local peaks of resident bird breeding activity) spring (April
and May) dates. Exact level of effort for these birds has not yet been
determined, but we recommend at least two additional weeks of survey
(prior to those identified above in Survey Timing and Level of Effort).” –
pdf pages 151-152
AEA is pleased that USFWS agrees that surveys for
overwintering birds are not needed. As noted above, AEA
concurs with the perspective of the USFWS landbird
coordinator for Alaska that surveys targeted for resident
species in April are not needed. Surveys in May, however,
will be conducted, as indicated in Section 10.16.4. At the
September 6, 2012 landbird-shorebird meeting, AEA
understood that agreement was reached on the resident
bird issue and that targeted surveys for resident species in
April were not needed, although surveys in May would be
conducted (see Appendices 3 and 4).
BREED-21 USFWS 11/14/2012 “Species of Conservation Concern. Rusty Blackbird, Olive-Sided
Flycatcher, and several shorebird species are Service Species of
Conservation Concern for Bird Conservation Region 4, which includes
the Project site. Special attention should be paid in development of
survey plan details to target these species (i.e., their preferred habitat
types) as much as practical, given their relatively sparse distribution
across the landscape. We appeared, based on general discussion at
the September meeting, to be in agreement on this point but further
detailed discussion is necessary as point count locations are being
pre-mapped.” –pdf page 152
As indicated in AEA’s response to comment BREED-17
above, the point-count study has been designed
specifically with species of conservation concern in mind,
because AEA is aware that these species are of prime
concern to management agencies. For example, the study
protocol calls for surveys to be conducted in as many
occurrences of each habitat type as possible (spread
throughout the study area) to maximize the detection of
uncommon species, which are often patchy in occurrence
across the landscape (see Section 10.16.4.1.1).
BREED-22 USFWS 11/14/2012 “Swallows. Because cliff-nesting swallow species are known to breed
in the banks of the Susitna River (and potentially elsewhere in the
Project footprint) where Project inundation will occur, yet the general
point-count methodology to be employed for most other landbirds and
shorebirds are not recommended for surveying such birds, we
recommend that survey methods be employed to specifically target
these colonies, including the use of boat surveys of the Susitna River
banks. It is unknown whether or not AEA has agreed to this.” –pdf
The landbird-shorebird study plan now includes a targeted
boat-based survey of swallow colonies along the Susitna
River and tributary streams in the reservoir inundation
zone as recommended by the USFWS (see Section
10.16.4.3).
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page 152
BREED-23 USFWS 11/14/2012 “Other Riparian-Associated Birds. We have jointly agreed that several
species of locally-significant (i.e., regularly using or dependent upon
habitats that will be lost or otherwise impacted by the Project) landbirds
and shorebirds are not commonly recorded in the standard point-count
methodology, and that it is important to conduct additional surveys to
target these species. Besides swallows as discussed above, these
include Belted Kingfisher, American Dipper, Semipalmated Plover,
Solitary Sandpiper, Spotted Sandpiper, and Wandering Tattler. It is
therefore expected that additional surveys will be conducted to target
these species. The additional surveys should include, at minimum,
appropriately-timed point count and linear surveys along all impacted
streams in appropriate habitat. Details and agreement, including
precise list of species to be targeted, and any use of linear surveys,
remain to be worked out.” –pdf page 152
As agreed to previously, AEA is proposing to conduct
additional riparian- and lacustrine-focused surveys within
the inundation zone and infrastructure area surrounding
the proposed dam site (see Section 10.16.4.2). Both
riparian and lacustrine habitats will be targeted because
some of the riparian-associated species noted by the
USFWS, especially the shorebirds, also are known to use
lacustrine habitats. A precise list of species to be targeted
could be prepared for these surveys, but the surveys will,
by necessity, have to target habitats (i.e., riparian and
lacustrine habitats will be the focus). All species observed
in these surveys will be recorded. The riparian- and
lacustrine-focused surveys will entail both point counts
and linear walking surveys conducted between point-count
locations in riparian and lacustrine (margin) habitats. For
the linear surveys, a measure of relative abundance
(birds/unit time) will be calculated.
BREED-24 USFWS 11/14/2012 “Owls and Hawks. Small owls and hawks, including Short-Eared Owl
which is a Partner- in-Flight species of conservation concern due to
apparent continental population declines, are also not adequately
surveyed by the standard point-count methodology proposed. We
expect that sufficient efforts will be made to survey these species so
that, at minimum, an adequate measure of abundance can be
obtained, but details of the AEA plan on this point are not yet clear.” –
pdf page 152
Surveys of small owls and hawks were discussed at the
TWG meeting on August 9, 2012, and at the follow-up
meeting on landbirds and shorebirds on September 6,
2012 (see Appendices 3 and 4). AEA explained that it had
concerns about personnel safety because the surveys for
certain owl species (most notably Boreal Owl) would
require intensive nocturnal sampling during late
winter/early spring to detect a species that occurs in low
density over broad areas. USFWS agreed that specific
surveys of small cavity-nesting owls would not be needed,
provided that AEA acknowledges their occurrence in the
study area and includes them in the Evaluation of Wildlife
Habitat Use (Section 10.19), which AEA agreed to do. As
with small owls, AEA is concerned that ground-based
surveys for small hawks also would involve a large amount
of effort (given the large Project area size and the late
winter/early spring snow cover present during the breeding
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period) in return for what is likely to be few observations of
uncommon species. Hence, AEA is not proposing ground-
based surveys focused on these species. All these
species will be assessed for impacts, however, as
described in RSP Section 10.19. Additionally, a large
number of aerial surveys will be conducted for wildlife,
raptors in particular (see Section 10.14), and all small
hawks and owls will be recorded when seen during those
surveys (Short-eared Owls, which are medium sized and
prefer open habitats, are readily observed during aerial
surveys). These species also are likely to be observed, as
incidental observations, during the point-count surveys to
be conducted during spring and summer 2013 and 2014.
(It is common to observe a number of additional species,
not recorded during the point counts themselves, when in
transit between point-counts sites.) AEA’s wildlife
contractors regularly record all observations of uncommon
bird species during field survey efforts (whether those
species are the focus of the survey or not) and that
protocol will be followed on this Project as well.
BREED-25 USFWS 11/14/2012 “MIGRATION SURVEYS. One of the Service’s primary objectives is to
survey birds flying across the Project area during migration, and using
the area for stop-overs during migration. Identifying and describing
flight path use is critical for determining risk of direct mortality from
collisions with Project infrastructure (e.g., power transmission lines and
the dam itself, which may have lights that compound random collision
risks with a disorienting attractant). At this time, no agreement has
been reached to conduct surveys either to identify numbers/species of
landbirds or shorebirds a) flying across the proposed transmission
corridors and dam site during migration or b) using the Project area as
migratory stop-over(s). Because of the risk of collisions to birds in
flight, including substantial long-term cumulative impacts, we continue
to recommend that surveys be conducted to identify and characterize
migratory pathways in the Project area. Because most of the species in
question are primarily nocturnal migrants, the use of radar is
warranted. We recognize that the geographic scale will be difficult to
AEA is pleased that USFWS is considering that the
proposed radar and visual studies of bird movements at
the dam site (see Sections 10.16.4.4 and 10.15.4 .1.2)
may be sufficient to address concerns over impacts to
migrant birds in flight (when coupled with additional work
to site transmission lines in bird-safe areas, mark
transmission lines for maximum visibility to birds, and to
use lighting protocols at all Project facilities to minimize
the attraction of birds). AEA also is pleased that USFWS
recognizes the difficulty in acquiring data on stop-over
and/or staging use of the Project area during migration,
and that they are not recommending such studies at this
time.
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tackle with limited radar capabilities. At the October 4, 2012, meeting
to discuss the Project waterfowl surveys, the use of radar at the dam
site was verbally proposed by AEA contractors. This would target all
species, including landbirds and shorebirds. The Service may find
limiting radar studies to the dam area sufficient, IF these studies are
coupled with: a) appropriate analyses of existing information to help
locate transmission lines in bird-safe areas; b) commitment to a well-
researched and detailed plan to mark and micro-site all transmission
lines in a bird-safe manner (i.e., avoiding cliffs or drainages, etc., that
may be used by migrating birds); and, c) commitment to a well-
researched bird-safe lighting operations plan at all Project facilities.
Regarding stop-over site research, undoubtedly many birds (species
and individuals) use the large Project footprint and general Project
area for stop-overs during migration. We are, however, unaware of any
particular local site of concentration, and acknowledge the tremendous
effort that would be required to identify and quantify stopover habitat
use (particularly for landbirds), given the vast and previously-unstudied
scale of the Project area. Therefore we will agree that surveys focused
on describing landbird and shorebird stop-over habitat use may not be
conducted at this time.” –pdf pages 152-153
BREED-26 USFWS 11/14/2012 PISCIVOROUS WILDLIFE AND MERCURY RISK ASSESSMENT.
“The Service has requested that feathers from piscivorous birds using
the Project area, including Belted Kingfisher and other species, be
collected to provide the baseline information on current levels of
mercury critical to a wildlife and mercury risk assessment. The Service
has also requested that a study be conducted to determine enough
details of these birds’ diets (e.g., amount or percent fish) to sufficiently
inform this risk assessment. We are still in the process or working with
AEA to adequately develop this study.” –pdf page 153
The landbird-shorebird study plan now notes that
nonlethal collections of feathers from the nests of
piscivorous species (Belted Kingfisher) for analysis of
mercury levels will be made if kingfisher nests are found
during the swallow survey (see Section 10.16.4.6).
Additionally, a review and synthesis of information on food
habits and diets of Belted Kingfishers and partly
piscivorous species (e.g., American Dipper and Spotted
Sandpiper) will be conducted, with an emphasis on Alaska
studies, and the information will be provided to the
researchers working on the Mercury Assessment and
Potential for Bioaccumulation Study.
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Population Ecology of Willow Ptarmigan in Game Management Unit 13
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No Comments Received
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
FROG-01 ADF&G 11/14/2012 “DWC has been in consultation with AEA about wood frogs
and is pleased to see the interim draft RSP for Wood Frogs.
Unfortunately, we have not yet had an adequate opportunity
to review the revisions and will continue to consult on study
design.” –pdf page 34
As explained in Section 8.4 of the PSP and 10.4 of the RSP, AEA
has consulted extensively with ADF&G in the development of the
proposed wildlife study plans over the past six months, including
the proposed study of wood frogs. As a result of the Technical
Working Group meetings, focused meetings on individual wildlife
study plans, and development of the interim draft RSP (which
included alterations in the wood frog study design recommended
by ADF&G), AEA believes that the Wood Frog Occupancy and
Habitat Use study plan has been developed to be responsive to all
comments received. AEA proposes a design that is consistent with
generally accepted scientific practice and can be used to assess
potential Project effects on wood frogs. As noted in Sections
10.18.4.2 and 10.18.6 of the RSP, in early 2013 AEA will develop
the sampling protocol for Batrachochytrium dendrobatidis in
consultation with ADF&G and USFWS.
Should ADF&G have any comments or concerns on the proposed
study design in the RSP, it should be sure to submit comments to
FERC by January 18, 2013, as provided by FERC’s regulations, 18
CFR 5.13(b), and FERC’s September 17, 2012 notice extending
the comment deadline.
FROG-02 ADF&G 11/19/2012 “The document says ‘The second survey at each site will be
conducted by a different observer with no knowledge of the
survey results from the first survey.’ This makes sense, but it
goes on to say, ‘However, if detected on the first survey, a
second survey will not be needed.’ The two statements don’t
really jive. The second statement apparently assumes a
detectability of ‘1’. All sites should be surveyed twice to
assess detectability. The draft goes on to explain that a small
number of acoustic monitoring devices will be deployed to
increase accuracy. That is a good approach in addition to
making at least two site visits. The document lists a number of
covariates such as habitat and environmental characteristics
that will be noted. Recording these parameters will be very
useful.” –email from Mark Burch
The Wood Frog Occupancy and Habitat Use study is based on a
removal design (once detected at a site, that site is removed from
further surveys). This is as opposed to a standard occupancy study
design in which each site is surveyed multiple times. We looked in
to this more and based on Mackenzie and Royle (2005 [Designing
occupancy studies: general advice and allocating survey effort. J.
of Appl. Ecol. 42:1105-1114]), it appears that removal designs are
more efficient statistically than standard designs when occupancy
rates and detectability are high. Given an estimated occupancy
rate of ~45–50% (from studies at Denali NP and Pebble) and
detectability of ~27% (Pebble), a removal design is slightly more
efficient than a standard design. The most efficient design,
however, would entail 8 visits to each site for a removal design (6
for a standard design), but that level of repeat sampling would be
counterproductive for a broad, landscape-scale study such as the
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one proposed for the Project. If the Project area were very small,
that level of repeat sampling might be feasible, but in this case, the
goal is not so much to get a highly accurate occupancy estimate as
to sample broadly within the Project area to determine how
widespread frogs are. With a limited number of repeat visits, we
can determine an occupancy rate and also spend more time
surveying additional sites for frogs, which we believe will be more
beneficial.
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Evaluation of Wildlife Habitat Use Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
WLDHAB-01 USFWS 11/14/2012 “Objective 2 is addressed in the Draft RSP section for Impact
Assessment (11.5.4.4). The GIS component of this analysis is
straightforward. The methods for ranking habitat value for each bird
and mammal species of concern are described in the Evaluation of
Wildlife Habitat Use Study (Draft RSP Section 10.19), which is
appropriate if one of the objectives for that RSP is to provide this
ranking.” –pdf page 158
Section 11.5.7 clarifies that impact assessments will be
conducted during the FERC license application process.
Also, AEA further clarified, in Section 11.5, the relationship
between the Vegetation and Wildlife Habitat Mapping
Study in the Upper and Middle Susitna Basin (Section
11.5) and the Evaluation of Wildlife Habitat Use study
(Section 10.19).
WLDHAB-02 USFWS 11/14/2012 ”AEA proposes to calculate average occurrence figures for each bird
species in each habitat type, and to derive 4 habitat categories – low,
mid, high, and negligible. It should be noted that, when deriving these
habitat values, it will be important to avoid confusing “not seen” and
“not surveyed” with “not present” and “not using” data results.” –pdf
page 150
As discussed with USFWS at the September 6, 2012
landbird-shorebird meeting (see Appendices 3 and 4),
AEA is aware of the dangers in determining that a species
is not present when it is simply not observed, and similarly
determining that a species does not use a particular
habitat, for example, when those habitats were not
sampled or undersampled. AEA will correct for these
potential problems when ranking habitat values. In short,
habitat values are ranked for wildlife species independent
of their abundance, primarily because of the problems
inherent in determining habitat use for species that are
only rarely observed. For cases such as these in which
Project-specific data are limiting, as is described in
Section 10.19.4.1, habitat values will be derived by
reference to habitat use information from other studies in
Alaska and/or from field experience with the species in
Alaska.
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Wildlife Harvest Analysis
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
WHARV-01 CCC 11/15/2012 “The subsistence studies are focusing exclusively on a narrow set of
target communities (Talkeetna, Trapper Creek, Chase, etc.). However
the lower Mat Su Valley and Anchorage heavily use game unit 13 in
the region of the Dam. The study needs to be expanded to better
understand the impact on these user groups and the cumulative impact
of the dam, access roads, and other impacts on sustainability of the
wildlife populations.” –pdf page 3
As is described in Section 10.20.3 of the RSP, the Wildlife
Harvest Analysis will summarize all harvest data reported
to ADF&G and USFWS for a large area, including GMU
Subunits 13A, 13B, 13E, 14B, 16A, and part of 20A.
The Subsistence Resources Study Plan (Section 14)
addresses 37 study communities, 25 of which have
planned subsistence fieldwork. Section 14 does address
communities in the lower Mat Su Valley, including Wasilla
and outlying CDPs. Section 14.5.4.1 includes a subtask to
access ADF&G’s “winfonet” database to identify
“subsistence users and communities in Alaska who travel
to the proposed Project area to participate in land mammal
harvest activities and additional information about study
communities’ (including those located in nonsubsistence
area) subsistence activities in the Project area.” Results
from the Wildlife Harvest Analysis (Section 10.20), as well
as results from the variety of physical, biological, and
cultural resource studies, will be compared with
subsistence harvest data to assess impacts on
subsistence uses.
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VWHAB-01 USFWS 11/14/2012 “A number of terms are used to qualify the resolution of aerial/remote-
sensed imagery (high-, moderate-, fine-scale) throughout the study
plan. Please provide a pixel resolution the first time each term is used.
Besides image resolution, the type and wavelength bands used for
photo interpretation, such as true color, false color and color infrared,
should be discussed.” –pdf page 156
The image resolution terminology has been standardized
now throughout Section 11.5. Detailed information on the
image quality and image types to be used for mapping is
presented now in Section 11.5.2.
VWHAB-02 USFWS 11/14/2012 “The general description of the study sets the stage for the study
objectives, methods and products. The description, however, describes
a mapping study and does not include the second objective to quantify
potential impacts to vegetation and wildlife habitats. This information
should be included in the general description to more adequately
describe the full scope of the study.” –pdf page 156
Section 11.5.1 clarifies that the goals and objectives.
Impacts will not be assessed in the Project environmental
studies, but instead will be assessed in the FERC License
Application in 2015. The specific products of the
Vegetation and Wildlife Habitat Mapping Study in the
Upper and Middle Susitna Basin are the maps
themselves, which will be used, in the License Application,
to inform impact assessments.
VWHAB-03 USFWS 11/14/2012 “AEA’s Draft RSP objectives have changed somewhat from the PSP
objectives, possibly due to refinements in the scope of this and the
other Botanical Resources studies. The two Draft RSP objectives (map
vegetation and wildlife habitat, and quantify impacts to vegetation and
wildlife habitats) are similar to three of our five study request
objectives. Our fifth requested study objective (develop mitigation
measures) is likely more appropriate for a later stage in the licensing
process.” –pdf page 157
AEA agrees with this comment, and because the study
does not include development of PM&E measures as a
study objective, no changes to the RSP are needed to
address this comment. While the vegetation and wildlife
habitat maps will be used to inform both the impact
assessments and the preparation of mitigation measures,
those activities will be conducted in the FERC License
Application (in 2015) when Project design details are more
refined.
VWHAB-04 USFWS 11/14/2012 “Not addressed in AEA’s Draft RSP objectives is our 31 May 2012
study request to compare the vegetation mapping results with the 1987
vegetation mapping study conducted in the original Susitna
Hydroelectric Project area. The Service is concerned that vegetation
and wildlife habitat changes during Project operations may be
attributed incorrectly to either Project operations or to some other less
obvious influence. The Botanical Resources Draft RSPs provide
numerous examples where the 1980s data will be used as a starting
point, but these data will need to be updated due to landscape
changes over time such as fires, insect outbreaks, and permafrost
degradation. The justification for AEA not including this objective was
AEA agrees with these points, which do not require
changes to the RSP. The objective for use of the 1987
vegetation map within the structure of the RSP is to refine
it based on currently available imagery, and then use it as
a planning tool for field-plot selection and to assist, if
needed, with the boundary delineation for currently
existing vegetation types. Currently, it is unclear whether
the 1987 vegetation map is accurate enough at a fine
scale to use to address gradual, natural vegetation and
wildlife habitat changes; to assess its accuracy would
involve detailed comparisons of the line-work with the
Revised Study Plan Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority FERC Project No. 14241 Page 423 December 2012 Vegetation and Wildlife Habitat Mapping Study in the Upper and Middle Susitna Basin Reference Number Commenter Date Filed Comment or Study Request AEA’s Response discussed at subsequent technical work group (TWG) meetings (e.g., different methods and study areas), and the Service agreed this objective could be addressed at a later date if subsequent vegetation and wildlife habitat changes may be due to less obvious influences. However, without knowing the trajectory of gradual vegetation and wildlife habitat change before the Project, the cause for any changes during Project operation may be questioned.” –pdf page 157 original 1980s aerial photography used in the 1987 mapping, which is an activity outside the scope of the RSP. AEA believes the potential impacts to vegetation from the proposed Project would be localized and not easily confused broader, landscape-scale changes in vegetation due to natural causes. VWHAB-05 USFWS 11/14/2012 “AEA Study Area (Draft RSP): The proposed study area for the mapping of vegetation and wildlife habitats consists of a 4-mile buffer zone surrounding those areas that would be directly altered or disturbed by Project construction and operations…[, and] include the proposed reservoir impoundment zone, areas for infrastructure of the dam and powerhouse and supporting facilities, the proposed access route and transmission-line corridors, and materials sites (Draft RSP 11.5.3). The Service concurs with reducing the buffer zone from our suggested 5 mile width in our study request to 4 miles. We also appreciate the reference to the Riparian Study (Draft RSP Section 11.6) addressing potential impacts in the floodplain downstream of the proposed reservoir. For the RSP, the word “proposed” should be used only sparingly for the few remaining technical details still under discussion in the TWGs (and the “proposed” dam). Any detail still referred to as “proposed” in the RSP suggests the study plan is still under development.” –pdf page 157 AEA is pleased that USFWS agrees with the modified study area boundaries, which is incorporated throughout RSP Section 11.5. In addition, the RSP does not include the word “proposed” when referencing technical details of the study plan that have been finalized through months of consultation between AEA, USFWS, and other licensing participants. VWHAB-06 USFWS 11/14/2012 “AEA’s methods do not clearly follow the objectives, making it difficult to evaluate the appropriateness of the methods. The methods appear adequate; however, we recommend AEA reorganize the methods to address the objectives. Our comments below are organized by objective, with references to AEA’s section numbers in the Draft RSP.” –pdf page 157 As noted above in AEA’s response to VWHAB-02, the objective for conducting impact assessments has been removed from section 11.5 because that work will occur in the FERC License Application. The single objective of this study is to develop vegetation and wildlife habitat maps that describe baseline conditions in the study area, and the methods describe how those maps will be prepared. VWHAB-07 USFWS 11/14/2012 “If the units of ecological importance mentioned in the introductory paragraph for the methods will be defined in another study, this study should be referenced to help set the stage for collaboration between studies. Please spell-out the first reference to acronyms in major Clarification to the first paragraph of text in Section 11.5.4 was made to define the first use of “ITU.” The units of ecological importance sentence was rewritten to indicate that wildlife habitats will be defined in this study (now
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sections (e.g., “ITU” referenced in the second paragraph of Draft RSP
Section 11.5.4).” –pdf page 158
cross-referenced to the appropriate methods subsection).
Further noted (in Section 11.5.6) that the habitats will be
defined in coordination with wildlife researchers for the
Project and the riparian vegetation study team.
VWHAB-08 USFWS 11/14/2012 “Objective 1 is addressed in the Draft RSP sections for ITU Mapping
and Derivation of Wildlife (11.5.4.2), and Field Surveys (11.5.4.3).
There is substantial detail in the first section discussing how the 1987
data will be updated, but the final product is unclear. We understand
the final product at the end of the study will be based on a combination
of ITU (citation required), a Viereck Level IV (Viereck et al. 1992)
classification, and wetland delineation (Environmental Laboratory
1987, U.S. Army Corps of Engineers 2007), using 2013 high-resolution
imagery for the entire study area with a minimum mapping polygon
size of 1.0 acres for vegetated areas and 0.25 acres for waterbodies.
For consistency with the Wetland Mapping Study (Draft RSP 11.7), the
wetlands classification should also include the Cook Inlet classification
(Gracz 2011) with modifications as required for the Susitna River
basin. The data collected at ground-reference plots will follow the
methods required to delineate wetlands (Environmental Laboratory
1987, U.S. Army Corps of Engineers 2007) for wetlands, and the
methods described in this section for non-wetlands. The methods for
ground-reference plots in wetlands is well documented, however, the
categories used for classifying non-wetlands such as visual cover,
plant community structure, physiography, surface form,
microtopography, site disturbances, and plant phenology should be
described so they can be evaluated.” –pdf page 158
The description of field data collection methods were
clarified and expanded in Section 11.5.4.3 to indicate the
full suite of data collected for this study (Section 11.5) and
the Wetland Mapping Study (Section 11.7), because the
field surveys for both studies will be conducted
concurrently to maximize efficiency. In this study,
however, only maps of vegetation and wildlife habitats will
be prepared, so there is no need to cite the Cook Inlet
wetland classification system, which is discussed in the
RSP for the Wetland Mapping Study (Section 11.7).
Wetlands will not be mapped in this study; they will be
mapped in the Wetland Mapping Study only.
VWHAB-09 USFWS 11/14/2012 “The methods for deriving wildlife habitat types need additional detail.
What wildlife species will be chosen, how will their habitat criteria be
defined, and who will be involved in this process? Including elements
of Kessel’s bird habitat classification system for Alaska (Kessel 1979)
would help, but how will other wildlife habitat needs for other species
be determined? The Service has concluded a potential report by the
USGS comparing Kessel’s classification with Viereck’s Level IV
classification was never prepared, so AEA’s proposal to prepare a
“crosswalk” between the two classification systems will be a valuable
The set of wildlife habitats will be developed using an
iterative process taking into account wildlife
species/habitat associations for all birds, mammals, and
amphibians to be assessed for impacts (see Section
10.19). Elements of Kessel’s (1979) habitat classification
will be used in developing the wildlife habitats to be
mapped (see Section 11.5 in the PSP-to-Draft RSP
comment/response table; Appendix 3). Habitats will be
developed in coordination with the wildlife researchers on
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addition to this portion of the methods.” –pdf page 158 the Project (i.e., Project-specific observations of habitat
use and, when needed, available literature on habitat use
for the birds, mammals, and amphibians known to occur in
the Project area will be used to ensure that the habitats
mapped will be representative of those known to be used
by wildlife in the Project area). Sections 11.5.4.2 and
11.5.6 were modified to clarify this iterative process of
developing the wildlife habitats to be mapped.
VWHAB-10 USFWS 11/14/2012 “Objective 2 is addressed in the Draft RSP section for Impact
Assessment (11.5.4.4). The GIS component of this analysis is
straightforward. The methods for ranking habitat value for each bird
and mammal species of concern are described in the Evaluation of
Wildlife Habitat Use Study (Draft RSP Section 10.19), which is
appropriate if one of the objectives for that RSP is to provide this
ranking.” –pdf page 158
RSP Section 11.5 indicates that impact assessments will
be conducted during the FERC License Application
process, and are not a part of the Vegetation and Wildlife
Habitat Mapping Study in the Upper and Middle Susitna
Basin. The approach for conducting those impact
assessments is detailed in Section 11.5.7. As a point of
further clarification, Section 11.5 describes the relationship
between the Vegetation and Wildlife Habitat Mapping
Study in the Upper and Middle Susitna Basin and the
Evaluation of Wildlife Habitat Use study (Section 10.19).
VWHAB-11 USFWS 11/14/2012 “For the pdf vegetation and wildlife habitat map deliverables, the
Service recommends providing these products in geospatial pdf, so a
sophisticated GIS program would not be required to readily identify
coordinates on the maps.” –pdf page 158
ADNR has developed an interactive online webmap
application specific to this Project:
http://www.dmlwmaps.dnr.alaska.gov/Watana_App/. The
site will have available map layers including current
imagery, archival data layers, draft and final GIS layers
related to the individual Project studies. AEA recommends
that all licensing participants make use of this resource
when reviewing the vegetation and wildlife habitat map
products.
VWHAB-12 USFWS 11/14/2012 “Will 2014 include additional field sampling in areas without high-
resolution imagery until late 2013? Perhaps including a rough estimate
of the area without high-resolution imagery would suggest how much
additional work would be required?”
AEA expects fieldwork to occur in 2013 and 2014 to cover
the substantial Project areas not currently covered by the
existing high-resolution imagery. The 2013 field program
will be conducted primarily using the moderate-resolution
RapidEye imagery (Section 11.5.4.3). Follow-up fieldwork
is expected in 2014 to cover any areas that were not
adequately surveyed in 2013, and AEA’s Initial Study
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Report will include recommendations for 2014 fieldwork
(Section 11.5.4.4).
VWHAB-13 USFWS 11/14/2012 “Why is 2012 included in the timeline for Draft RSP Table 11.5-1 if no
activities are scheduled or performed in 2012?”
The 2012 columns were removed from the timeline in the
schedule (Table 11.5-1) because those columns do not
apply to a study plan describing work to be conducted in
2013 and 2014.
VWHAB-14 USFWS 11/14/2012 “The Draft RSP methods suggest the Study Interdependencies figure
(Draft RSP Figure 11.5-2) should include an input from the Evaluation
of Wildlife Habitat Use Study (Draft RSP Section 10.19) for the bird
and mammal species of concern habitat ranking. This figure suggests
the GIS data layer for wildlife habitats will be developed without
interaction with the Evaluation of Wildlife Habitat Use Study.”
Based on this comment and further review AEA has
modified the interdependency flow chart and text (Section
11.5.7) to indicate that input on habitat use from the
wildlife researchers conducting each of the wildlife studies
for the Project, as noted above in AEA’s response to
comment VWHAB-09, will be used in developing the
wildlife habitats to be mapped.
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
RIP-01 CWA 11/14/2012 Scope is insufficient in studying the Lower River based on AEA’s
apparent assumption that Project effects will not significantly affect the
Lower River riparian plant community. –pdf pages 7-8
AEA is not assuming there are no Project effects on the
Lower River riparian plant community. Both Middle and
Lower River segments are under consideration as part of
this RSP. Although the majority of study elements
described in this RSP are concentrated within the Middle
River Segment, this is because Project operational effects
on hydraulic variables (stage and flow primarily) will likely
be greatest in this segment of the river. These effects tend
to attenuate in a downstream direction as channel
morphologies change, and flows change due to tributary
inflow and flow accretion. That said, the downstream
extent of the study area for the Riparian Vegetation Study
Downstream of the Proposed Watana Dam may be
expanded further into the Lower River, pending the results
of additional modeling of operational effects on hydrology
in the Lower River in Q1 and Q2 2013 (see Section
11.6.3).
RIP-02 USFWS 11/14/2012 “Addressing the downstream effects on riparian habitats in the Draft
RSP Section 11.6 may also be appropriate, however the Service was
under the impression the Riparian Instream Flow Study (PSP 6.6 /
RSP 8.6) would be predicting potential riparian community changes
resulting from Project operations (See our comments in that section for
additional details).” –pdf pages 159-160
As described in Section 11.6.7, these two riparian studies
are interdependent and will be coordinated closely. The
mapping of existing riparian vegetation will be conducted
in the Riparian Vegetation Study Downstream of the
Proposed Watana Dam (see Section 11.6), and the
collection of vegetation data used to predict riparian
community changes will be done jointly by the Riparian
Vegetation Study Downstream of the Proposed Watana
Dam and the Riparian Instream Flow Study (see Section
8.6). USFWS is correct that the predictions of change in
riparian communities will be done in the Riparian Instream
Flow Study (see Section 11.6.7 for an explanation of the
roles of these two studies).
RIP-03 USFWS 11/14/2012 In the USFWS study request (May 31, 2012), the Service had
envisioned that the riparian vegetation study was primarily a mapping
effort that would use products from other studies to map the type and
extent of predicted changes in riparian habitat. However, the riparian
vegetation PSP and RSP include field data collection as an objective, a
The two riparian studies (riparian vegetation and riparian
instream flow) have been revised. In the Riparian
Vegetation Study Downstream of the Proposed Watana
Dam (see Section 11.6), detailed data will be collected on
existing vegetation and soils, existing riparian vegetation
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role that USFWS had envisioned would be entirely within the scope of
the riparian instream flow study. In the Technical Work Group meeting
on October 24, 2012, AEA informally remarked that the riparian
instream flow study team was working closely with the riparian
vegetation study team to address the USFWS study-request objective,
however it was not made clear to the Service that the USFWS
objective was being addressed also by the riparian vegetation study.
The USFWS recommends assigning the data collection and analysis
portion of this objective (i.e., predicting changes in riparian habitats
downstream of the proposed dam) to the riparian instream flow study
since the Instream Flow TWG meetings have been where these topics
have been discussed in detail, not the mapping efforts in the Botanical
Resources TWG meetings. The USFWS suggests that the objective of
up-scaling the riparian habitat predictions from the Focus Areas to the
entire study area may be an appropriate study element for the riparian
vegetation study. Lastly, the USFWS recommends that AEA conduct a
TWG meeting with sufficient time allocated to discuss the proposed
methods for predicting riparian habitat changes before they are
finalized in the RSP. –pdf page 160
in the Susitna River floodplain will be mapped, and
vegetation succession will be modeled. The data collected
in Focus Areas (previously Intensive Study Reaches) and
the successional modeling results from the Riparian
Vegetation Study Downstream of the Proposed Watana
Dam will then be used by researchers in the Riparian
Instream Flow Study (see Section 8.6) to prepare a
spatially explicit model to predict Project-influenced
changes in riparian vegetation across the floodplain study
area. More details on this collaboration between the two
studies are provided in Sections 11.6.4.2, 11.6.4.4, and
11.6.7.
These two riparian studies will continue to be closely
coordinated with the overarching goal of determining how
riparian areas may change because of construction and
use of the proposed dam.
RIP-04 USFWS 11/14/2012 “However AEA eventually chooses to assign this objective, the Service
recommends that AEA conduct a TWG meeting with sufficient time
allocated to discuss the proposed methods for predicting riparian
habitat changes before they are finalized in the RSP.” –pdf page 160
The RSP has been revised to add additional detail on the
methodology for addressing this objective (see Sections
8.6 and 11.6). Through quarterly TWG meetings in 2013,
AEA and licensing participants will have the opportunities
to discuss methods to be used to predict changes in
riparian habitats (see Section 11.6.6).
RIP-05 USFWS 11/14/2012 “Riparian areas and floodplains are often the same; however, many
people visualize riparian areas as a narrow band immediately adjacent
to streams and rivers. We envision this study including the entire
floodplain, and not simply a narrow zone along the Susitna River. To
help minimize this potential misconception, the Service recommends
revising the study plan title and discussion to include the word
“floodplain.”” –pdf page 160
In Section 11.6.3, the RSP defines “riparian areas” to
include all vegetation and soils that are directly (via
flooding and overland flow) or indirectly (via ground water)
influenced by river waters. This definition is inclusive of
floodplains.
RIP-06 USFWS 11/14/2012 “A number of terms are used to qualify the resolution of aerial/remote-
sensed imagery (high-, moderate-, fine-scale) throughout the study
In Section 11.6.2, the pixel resolution for the high- and
moderate-resolution imagery is defined and the formats
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plan. Please provide a pixel resolution the first time each term is used.
Besides image resolution, the type and wavelength bands used for
photo interpretation, such as true color, false color and color infrared,
should be discussed.” –pdf page 161
(true color, false natural color, and CIR) for that imagery,
which will be used for photo interpretation, also are noted.
RIP-07 USFWS 11/14/2012 “AEA Study Goals and Objectives (Draft RSP): The overall goals of the
riparian vegetation study are to prepare baseline maps of local-scale
riparian ecosystems (riparian ecotypes), wetlands, and wildlife habitat
types in areas downstream from the proposed for the Project dam site,
and to assess the extent to which the Project will alter vegetation
succession, wetlands, and wildlife habitats in riparian areas of the
Susitna River. (strikethrough for suggested deletion) The Service did
not provide an overall goal, and instead merged the goals and
objectives into a bulleted list similar to AEA’s objectives discussed
below. To help minimize potential confusion about the scope among
studies, it might be helpful to expand upon the sentence describing
assessment of impacts to riparian ecotypes, wetlands, and wildlife
resources.” –pdf page 161
In Section 11.6.1, the overall goals of the Riparian
Vegetation Study Downstream of the Proposed Watana
Dam are clarified. In Section 11.6.4.4, the approach to
predicting changes in riparian areas is described. In
Section 11.6.7, the interdependencies among the riparian
studies for the Project are described and a discussion of
the approach to assessing the impacts to riparian
ecotypes, wetlands, and wildlife habitats has been
provided.
RIP-08 USFWS 11/14/2012 “The Draft Botanical RSPs make a distinction between their study area
boundaries, including Gold Creek and the proposed dam site. How
does this study differ from the Vegetation and Wildlife Habitat Mapping
Study and the Wetland Mapping Study (Draft RSPs 11.5 and 11.7)?” –
pdf page 161
As noted in Section 11.6.3, “The Riparian Vegetation
Study Downstream of the Proposed Watana Dam will be
focused on riparian areas along the Susitna River and its
tributaries below the proposed dam site.” The study areas
for the Vegetation and Wildlife Habitat Mapping Study in
the Upper and Middle Susitna Basin (Section 11.5) and
the Wetland Mapping Study (Section 11.7) have been
clarified; those studies only involve riparian areas along
the Susitna River upstream of the dam site and do not
include any riparian areas below the dam. There is no
overlap in those two studies with the Riparian Vegetation
Study Downstream of the Proposed Watana Dam (Section
11.6).
RIP-09 USFWS 11/14/2012 “AEA’s Draft RSP first and third objectives are similar to three of the
four objectives in our 31 May 2012 study request (identify and map
riparian communities, quantify potential loss of riparian habitats, and
assess potential changes in riparian habitats). Although our 31 May
Regarding the second objective, as noted in Section
11.6.1, the Riparian Vegetation Study Downstream of the
Proposed Watana Dam involves (1) collecting vegetation
and soils data to map existing vegetation on the Susitna
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2012 study request included elements in our objectives similar to
AEA’s second objective (characterize riparian physical and ecological
processes), as the study plans evolved during TWG discussions, the
Service now believes AEA’s second objective would be more
appropriate in other studies focused on characterizing physical and
biological processes. The products from these studies would then be
used by the Botanical Resources studies to upscale and map the
predicted plant community/habitat changes potentially affected by the
Project. Our fourth requested study objective (develop mitigation
measures) is likely more appropriate for a later stage in the licensing
process.” –pdf pages 161-162
River floodplain, and (2) characterizing sedimentation and
erosion, modeling vegetation succession, and describing
vegetation-soil-landscape relationships, all of which will
feed into the riparian instream flow and Geomorphology
Study objectives of characterizing physical and ecological
processes downstream of the proposed dam. There is an
ongoing collaborative effort between the Riparian Instream
Flow Study, Riparian Vegetation Study Downstream of the
Proposed Watana Dam, and Geomorphology Study leads
to coordinate their respective studies and fieldwork for
maximize efficiency.
Regarding the fourth requested objective, AEA agrees that
this objective need not be included in this study; the
development of any mitigation measures needed, will
occur during the preparation of the FERC License
Application (see Section 11.6.7).
RIP-10 USFWS 11/14/2012 “The Service recognizes the downstream limit of the study area is still
under discussion, and we look forward to participating in this
discussion. For the lateral extent of the study area we requested the
100-year floodplain plus an additional buffer in our 31 May 2012 study
request. The Draft RSP lateral extent proposed above for about a 5- to
25-year floodplain study area is likely barely equal to the effective
recurrence interval for riparian forest establishment, and based on the
2012 flood event shortly before our October TWG site visit, would not
extend very far into or even into some floodplain forest communities.
Few critical structures are engineered for these relatively frequent and
less damaging (environmentally rejuvenating) events. Critical
structures are often engineered for 100-year or more events, so we
don’t understand why the environmental health cannot also be
conservatively engineered by extending the study area to at least the
100-year floodplain width. In addition to considering surface-water
flooding to determine the study area width, we recommend including
the area of groundwater potentially influenced by Project operations.
For the riparian study, the width should be at least as wide as the
expected area of groundwater within the maximum depth of all plant
The 100-year floodplain, the original conception for the
width of the Riparian Vegetation Study Downstream of the
Proposed Watana Dam area, will be used as the lateral
extent of riverine physiography, and will serve as the initial
lateral boundary of the riparian study area. The RSP
provides further details as to the selection of the lateral
extent of the riparian study area (see Section 11.6.3).
The draft riverine physiography layer is expected to be
available for agency review by Q1 2013. Once the
agencies have reviewed the study area, their comments
will be incorporated into the final 2013 study area in late
Q1/early Q2 2013. That study area version may be subject
to change in Q4 2013 based on additional field data and
modeling.
Using the 100-year floodplain limit for the lateral boundary
of the study area should result in the study area width
being at least as wide as the area in which groundwater
could be affected by project operations. As noted in RSP
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roots and influenced by Project operations.” –pdf page 162 Section 11.6.3, the lateral boundary proposed for the
Riparian Vegetation Study Downstream of the Proposed
Watana Dam will be reviewed by the other study leads for
riparian-focused studies and the agencies before a final
lateral boundary is determined.
RIP-11 USFWS 11/14/2012 “Please spell-out the first reference to acronyms in major sections
(e.g., “ITU” referenced in the first paragraph of Draft RSP Section
11.6.4). We understand the wetlands in this study will be classified in
the same manner as wetlands in Draft RSP Section 11.7 (Wetland
Mapping Study), except without the functional analysis. If this is the
case, please clarify in the RSP.” –pdf page 162
In the RSP, AEA has spelled-out the first reference to
acronyms in major sections (i.e., in each individual study
plan section).
Yes, wetlands in this study will be classified in the same
manner as wetlands in the Wetland Mapping Study (see
Section 11.7), but without a functional assessment. This
has been clarified in the RSP (see Section 11.6.1).
RIP-12 USFWS 11/14/2012 “AEA Objective 1 and Methods (Draft RSP): Identify, delineate, and
map riparian ecotypes, wetlands, and wildlife habitats downstream
from the Watana Dam site.
Objective 1 is addressed in the Draft RSP sections for Developing
Mapping Materials (11.6.4.1), Field Surveys (11.6.4.2, excluding the
unnumbered Intensive Study Reaches and Sediment Aging sections),
and ITU Mapping (11.6.4.3). We understand the final product at the
end of the study will be based on a combination of ITU (citation
required), a Viereck Level IV (Viereck et al. 1992) classification, and
wetland delineation (Environmental Laboratory 1987, U.S. Army Corps
of Engineers 2007), using 2013 high-resolution imagery for the entire
study area with a minimum mapping polygon size of 1.0 acres for
vegetated areas and 0.25 acres for waterbodies. These methods are
essentially identical to the methods in the Vegetation and Wildlife
Mapping Study (Draft RSP 11.5). For consistency with the Wetland
Mapping Study (Draft RSP 11.7), the wetlands classification should
also include the Cook Inlet classification (Gracz 2011) with
modifications as required for the Susitna River basin. Although a
formal wetland determination and functional analysis will not be
conducted downstream of the propose dam, the wetlands methods and
classification will be essentially identical to the methods in the Wetland
Wetlands mapped as part of the Riparian Vegetation
Study Downstream of the Proposed Watana Dam will be
classified using the same methods as in the Wetland
Mapping Study (see Section 11.7), and will include a
crosswalk of wetland types mapped similarly to those in
the Cook Inlet classification (with modifications for the
higher elevation wetlands in the Project area). In the
Riparian Vegetation Study Downstream of the Proposed
Watana Dam and the Wetland Mapping Study, wetlands
will be mapped consistently for areas upstream and
downstream of the proposed dam so as to provide a
comprehensive wetland map for the Project. As stated in
Section 11.6.4.3, the minimum mapping polygon size of 1
acre for vegetated areas and 0.25 acres for waterbodies
will be maintained.
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Mapping Study (Draft RSP 11.5).” –pdf pages 162-163
RIP-13 USFWS 11/14/2012 “Objective 2 is addressed in the Draft RSP section for Field Surveys
(11.6.4.2, unnumbered Intensive Study Reaches and Sediment Aging
sections). For readers unfamiliar with the complex details of the
various RSPs, the methods presented here may seem out of place.
There is no justification for “Intensive Study Reaches” (now referred to
as Focus Areas). For reasons like this and the ones discussed above,
the Service recommends this section be moved to the Riparian
Instream Flow Study (Draft RSP 8.6). Our comments here are
preliminary and will likely be updated after reviewing Draft RSP 8.6,
which was released too late to review. Whichever study takes the lead
for this objective, the lead study should provide the detailed methods,
and the supporting study/studies should not include much more than
brief summary of the methods and a reference to the lead study.
Repeating the methods in a study not responsible for the data
collection and analyses is unnecessary and risks confusion if the
methods differ or are inadequate in one of the studies.” –pdf page 163
AEA agrees and this duplication of methods material has
been corrected in the RSP. In the Riparian Vegetation
Study Downstream of the Proposed Watana Dam, AEA
will collect vegetation and soils data to map existing
vegetation on the Susitna River floodplain; AEA also will
collect vegetation and soils data in focus areas, which will
be used to model successional vegetation changes. Those
data and the successional model results will then be used
in the Riparian Instream Flow Study and geomorphology
studies to predict (in a spatially explicit manner) how the
riparian landscape and vegetation is expected to change
across the floodplain because of operational flows, and to
characterize physical and ecological processes in riparian
areas. There is an ongoing effort between the Riparian
Instream Flow Study, Riparian VegetationStudy
Downstream of Watana Dam, and Geomorphology Study
leads to coordinate their respective studies and fieldwork
for maximize efficiency and avoid duplication of effort (see
Section 11.6.4.2).
RIP-14 USFWS 11/14/2012 “Phrases like “Presently, the … methods are…” are unacceptable for
what will become the RSP. At this stage the methods should be
finalized, or a reasonable justification provided for why the TWGs are
still working on the final details” –pdf page 163
In the RSP, the final methods are noted and, when
necessary, reasonable justification is provided for why the
TWGs are still working on the final details (e.g., study area
boundaries; see Section 11.6.3).
RIP-15 USFWS 11/14/2012 “Where possible, references should be provided for methods and
categories such as variably sized circular plots. Without references
with additional details, duplicating this study will likely be very difficult.”
–pdf page 163
References and detailed methods are included in the
RSP, making duplication of this study possible (see
Section 11.6.4). Note also that a detailed methods section
will be prepared in the Initial Study Report and the
Updated Study Report. Any duplication of this study would
best be done by referencing those study reports, as
opposed to a study plan.
RIP-16 USFWS 11/14/2012 “Line intercept is a standard method for sampling shrub cover, and not
often used for shrub density. Transect lengths are also typically much
Transect lengths for the point-intercept sampling are now
the sum of four 16.25-meter transects on the ELS plots
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 433 December 2012
Riparian Vegetation Study Downstream of the Proposed Watana Dam
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
longer than the sum of the two 6-meter transects. The PSP included
forest canopy cover. Has forest canopy cover been dropped for the
RSP?” –pdf page 163
(see Section 11.6.4.2.4). Vegetation sampling methods in
the RSP include measuring forest canopy cover using
densiometers (see RSP Section 11.6.4.2.4).
RIP-17 USFWS 11/14/2012 “Root depth studies that account for all the fine roots that might
penetrate deep into the soil are notoriously difficult to conduct with
confidence. Still, it might be informative to qualitatively note the root
density and depth in the shallow soil pits.” –pdf page 163
In the Riparian Instream Flow Study (see Section
8.6.3.7.2.2), the characteristics of roots in soil pits,
including root depth and width, will be documented.
RIP-18 USFWS 11/14/2012 “As envisioned in the Service’s 31 May 2012 Riparian Instream Flow
request, the ground-surface elevation will also need to be surveyed so
the depth to groundwater regime (not static water level) can be
determined from the Groundwater Study (Draft RSP 7.5).” –pdf page
163
Riparian vegetation elevation surveying will be conducted
in the following manner: All botanical plots and soil pits will
be surveyed in using a transit (elevation) and Trimble
geoXT (GPS location). Transit surveys will be tied into an
intermediate benchmark established at each Focus Area
and all transects outside Focus Areas. The flow-routing
teams will survey in the intermediate benchmark using an
RTK instrument, thus tying the riparian transit survey plot
elevations into the project-wide elevation datum. This is
explained in detail in Sections 8.6.3.7.2 and 11.6.4.2.
RIP-19 USFWS 11/14/2012 “Objective 3 is addressed in the Draft RSP section for Impact
Assessment: Predicting Changes in Riparian Areas (11.6.4.4). The
methods in this section are not nearly as well developed as the
methods described in the Vegetation and Wildlife Habitat Mapping
Study (Draft RSP 11.5) and the Wetlands Mapping Study (Draft RSP
11.7). There is no mention of using GIS to upscale predicted habitat
changes derived from this and supporting studies to the study area.
How will predictions and rankings from the various supporting studies
be incorporated into a GIS from the supporting studies such as riparian
instream flow, ice process, and riverine geomorphology? The Service
envisions this objective providing maps of the study area showing
predicted changes under various Project operation scenarios.” –pdf
page 164
Predicting changes in riparian areas due to Project effects
is now a primary objective of the Riparian Instream Flow
Study (see RSP Section 8.6). As explained in Section
11.6.4.4, the Riparian Vegetation Study Downstream of
the Proposed Watana Dam will be providing existing
vegetation mapping, field data, and vegetation
successional model results to the instream flow riparian
study researchers, who will complete the objective of
spatially modeling and illustrating on maps the predicted
changes in riparian areas.
RIP-20 USFWS 11/14/2012 “For the pdf vegetation and wildlife habitat map deliverables, the
Service recommends providing these products in geospatial pdf, so a
sophisticated GIS program would not be required to readily identify
Geospatial pdf files are handy but are very large in size
and will greatly inflate the size of Project reports. AEA will
provide access to interactive GIS products for the Project
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 434 December 2012
Riparian Vegetation Study Downstream of the Proposed Watana Dam
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
coordinates on the maps.” –pdf page 164 via ADNR’s webmap so that license participants can view
maps of riparian vegetation, wetlands, and wildlife
habitats, zoom in and out, turn layers on and off etc.,
without the need for an expensive GIS program (see
Section 11.6.4.5).
RIP-21 USFWS 11/14/2012 “Will 2014 include additional field sampling in areas without high-
resolution imagery until late 2013? Perhaps including a rough estimate
of the area without high-resolution imagery would suggest how much
additional work would be required?” –pdf page 164
2014 field studies likely will include additional field
sampling in areas where high-resolution imagery will not
be available until late 2013. Fieldwork for 2014 will be
assessed once the 2013 field season is completed, at
which time more information will be available regarding the
availability of high-resolution imagery (some mapping can
be completed on new high-resolution imagery when
received in late 2013) (see Section 11.6.2).
RIP-22 USFWS 11/14/2012 “The Study Interdependencies figure (Draft RSP Figure 11.6-2)
suggests the Riparian wildlife habitat mapping component will not rely
upon any insights gained from the Wildlife Resources (Draft RSP
Section 10). These inputs should be included in the figure if they will be
used. How is the “wildlife habitats” in the Predictions of change in
riparian vegetation, wetlands, and wildlife habitats different than the
element to the right in the figure for Riparian wildlife habitat mapping?”
–pdf page 164
In the revised RSP Section 11.6.7 (including Figure 11.6-
4), the interdependencies of the habitat mapping
component of Riparian Vegetation Study Downstream of
the Proposed Watana Dam and the Project Wildlife
Resource studies are described. The wildlife habitat
mapping in the Riparian Vegetation Study Downstream of
the Proposed Watana Dam will be completed in full
coordination with the researchers conducting the
Vegetation and Wildlife Habitat Mapping Study in the
Upper and Middle Susitna Basin (see Section 11.5), and
will also rely on inputs from the wildlife researchers for the
Project (see Sections 10.5–10.18) and the scientific
literature indicating habitat relationships for wildlife in
Alaskan riparian areas.
Figure 11.6-4 is split now into three charts. The “Riparian
vegetation, wildlife habitat, and wetlands mapping” chart
illustrates the study interdependencies involved in
mapping the current conditions for these resources.
“Prediction of change in riparian vegetation, wetlands, and
wildlife habitats” illustrates the study interdependencies
involved in predicting future conditions due to projected
Revised Study Plan
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FERC Project No. 14241 Page 435 December 2012
Riparian Vegetation Study Downstream of the Proposed Watana Dam
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
Project effects, and “Field study coordination” illustrates
the study interdependencies pertaining to the collection of
field data. These interdependencies are further explained
in RSP Section 11.6.7.
RIP-23 FERC 11/14/2012 “In some cases, you have developed plans for and are carrying out
studies in consultation with stakeholders to voluntarily collect
information in 2012 that will help you prepare or refine a study plan.
Please describe how these 2012 efforts were or are being incorporated
into the RSP.” -pdf pages 5-6
The use of the 2012 data and mapping efforts for the
Riparian Vegetation Study Downstream of the Proposed
Watana Dam has helped to better define the study goals
and objectives (see Section 11.6.1), the study area to be
used to assess potential changes in riparian habitats (see
Section 11.6.3), and to refine the field survey and mapping
methods (see Section 11.6.4).
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 436 December 2012
Wetland Mapping Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
WETLND-01 ADNR-DMLW 11/14/2012 “There is no mention of the source of recharge to the wetlands that
was referred to. Much of the wetland area is inundated during ice
dam events, but the timing of these events are irregular in nature and
the ground surface may be frozen during the events, preventing
regular infiltration. While upwelling groundwater and percolating
precipitation, primarily snowmelt, may account for a significant portion
of the wetlands, both recharge and discharge due to river stage, i.e.
potential horizontal flow to and from the wetlands, may be significant.”
– pdf page 9
Recharge that is related to riverine processes is discussed
in the Riparian Instream Flow Study (Section 8.6) and the
Riparian Vegetation Study Downstream of the Proposed
Watana Dam (Section 11.6).
WETLND-02 ADNR-DMLW 11/14/2012 “During low flow periods in the river, local wetland storage of water
may play a significant role in supporting the small ponds and
interconnections that are typical habitat for small fish. The horizontal
movement of water within the wetlands needs to be addressed as
does the functioning of wetlands within the larger system.” – pdf page
9
Downstream of the proposed dam site, groundwater
movements will be evaluated in the Groundwater Study
(Section 7.5) and the Riparian Instream Flow Study
(Section 8.6). Detailed data on groundwater and surface
water movements will be correlated to existing riparian
vegetation downstream of the proposed dam, and
wetlands will be mapped in the same area, in the Riparian
Vegetation Study Downstream of the Proposed Watana
Dam (Section 11.6).
Upstream of the proposed dam site, wetland functions will
be evaluated in the Wetland Mapping Study RSP (Section
11.7). Wetland water movement patterns for the mapped
wetland types are first addressed through the classification
of wetlands into wetland functional groupings. The
functional groupings are then used in the wetland
functional assessment as described in Section 11.7.4.3.
Water storage capacity, including groundwater recharge
and discharge, is one of the primary functions to be
addressed in the functional assessment. The functioning
of wetlands in the Upper and Middle Susitna Basin will be
specifically evaluated within the broader landscape in the
study area.
WETLND-03 USFWS 11/14/2012 “The U.S. Fish and Wildlife Service’s (Service) 31 May 2012 study
request entitled Wetland Mapping and Functional Assessment Study
differs from Alaska Energy Authority’s (AEA) Proposed Study Plan
AEA agrees that, through consultation with USFWS and
other licensing participants over the months since the May
31, 2012 study requests, the functional analysis question
Revised Study Plan
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FERC Project No. 14241 Page 437 December 2012
Wetland Mapping Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
(PSP) title by including the additional study component (underlined) in
our title. At the time of our study request, the habitat mapping
Technical Work Group (TWG) was concerned about which functional
analysis to use, so emphasizing this in the study title seemed
appropriate. The functional analysis question has now been resolved,
and the new Draft Revised Study Plan (RSP) title (above) qualifying
the study area is more appropriate.” –pdf page 166
has been resolved. The RSP title has been revised to
better differentiate the study area boundaries of the
Wetland Mapping Study (Section 11.7) from the Riparian
Vegetation Study Downstream of the Proposed Watana
Dam (Section 11.6).
WETLND-04 USFWS 11/14/2012 “A number of terms are used to qualify the resolution of aerial/remote-
sensed imagery (high-, moderate-, fine-scale) throughout the study
plan. Please provide a pixel resolution the first time each term is
used. Besides image resolution, the type and wavelength bands used
for photo interpretation, such as true color, false color and color
infrared, should be discussed.” –pdf page 166
The RSP has been revised to note the resolution, type,
and wavelength bands that are currently being used to
support the preliminary mapping effort (Section 11.7.4.1).
Not all of the imagery that will be used to classify and map
wetland and upland boundaries has been acquired, but
AEA has requested 1 ft. resolution, and it is AEA’s
understanding that both true-color and color-infrared will
be available.
WETLND-05 USFWS 11/14/2012 “The general description of the study sets the stage for the study
objectives, methods and products. The lower extent of the study area,
however, is inconsistent with the descriptions that follow. The General
Description (Draft RSP Section 11.7.1) defines the lower limit as the
proposed dam, while the Study Goals and map (Draft RSP Section
11.7.1.1 and Figure 11.7-1) define the lower limit as Gold Creek. This
is roughly a 47-river mile discrepancy, which needs to be clarified.
Although a careful review of the General Description sentence:
“Wetlands in riparian areas along the Susitna River below the
proposed dam will be mapped in a separate study, …” may be
technically correct (emphasis added), open-ended references to the
lower limit of the study area elsewhere in the RSP can be confusing.”
–pdf page 166
Section 11.7.3 has been revised to clarify the study area
boundaries. Wetlands within the 2-mile buffer of the
proposed transmission line routes will be included in the
Wetland Mapping Study (Section 11.7), but wetlands in
the riparian areas along the Susitna River between the
dam site and Gold Creek will not be mapped in that study.
Wetland mapping in the Susitna River floodplain
downstream of the proposed dam site will be mapped in
the Riparian Vegetation Study Downstream of the
Proposed Watana Dam (Section 11.6).
Revised Study Plan
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FERC Project No. 14241 Page 438 December 2012
Wetland Mapping Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
WETLND-06 USFWS 11/14/2012 “The Service did not provide an overall goal, and instead merged the
goals and objectives into a bulleted list similar to the AEA’s objectives
discussed below. The scope of AEA’s PSP included mapping the
entire Susitna-Watana Hydroelectric Project (Project) area, which
could be interpreted as including the entire Lower, Middle and Upper
Susitna River. This refinement in scope to the middle and upper
Susitna basin is appropriate, although it might also be helpful to
qualify the middle Susitna basin as upstream of Gold Creek and
mention the Riparian Study (PSP 9.6 / Draft RSP 11.6) will map
wetlands in the floodplain below the proposed dam.”
See AEA’s response to comment WETLND-05. The study
area in the Wetland Mapping Study (Section 11.7.3) has
been revised to clarify the study area boundaries and the
relationship between the riparian mapping and wetland
mapping studies as it relates to wetland impacts
downstream of the dam.
WETLND-07 USFWS 11/14/2012 “AEA’s three Draft RSP objectives are similar to the first three of our
five objectives in our 31 May 2012 study request (map wetlands,
determine functional values, and quantify impacts to wetlands). Our
fifth requested study objective (develop mitigation measures) is likely
more appropriate for a later stage in the licensing process. Not
addressed in AEA’s Draft RSP objectives is our fourth 31 May 2012
study request objective to evaluate potential changes to wetlands and
wetland functions from Project operations, maintenance and related
activities. The intent of this objective was primarily to evaluate Project
operation effects on wetlands downstream of the proposed dam. As
the study plans evolved, we understand this objective will now be
addressed in the Riparian Instream Flow and Botanical Resources
Riparian studies (Draft RSPs 8.6 and11.6). If our understanding is
incorrect, please address our fourth 31 May 2012 study request
objective.” –pdf page 167
The assessment of impacts to wetlands affected by project
operations, maintenance, and related activities upstream
of the dam (e.g., road dust, spills, impoundments) will be
performed in 2015, as part of the FERC licensing process
and Section 404 wetlands permit application processes
(see Section 11.7.6). Impacts to wetlands downstream of
the dam that relate to changes in flow will be evaluated in
the Riparian Vegetation Study Downstream of the
Propoased Watana Dam (see Section 11.6.6).
WETLND-08 USFWS 11/14/2012 “The Draft RSP study area description is essentially the same as the
PSP, with a few minor updates to reflect changes in the evolving
study plans. The Service concurs with the study area, and we
appreciate the detail provided making the distinction between the
Wetland and Riparian Botanical studies.” –pdf page 167
AEA appreciates the opportunity to work closely with
USFWS and other licensing participants in the
development of this study plan and agrees that the study
area issue has been resolved in this RSP.
WETLND-09 USFWS 11/14/2012 “Objective 1 is addressed in the Draft RSP sections for Wetlands
Classification (11.7.4.1) and Field Surveys (11.7.4.2). Although
mentioned here, presumably the updated 1987 habitat mapping work
described in the Vegetation and Wildlife Habitat Mapping Draft RSP
The Wetlands Mapping Study is using a smaller minimum
mapping size because wetland impacts due to fill
placement will need to be as accurate as possible. The
areas will be tied to mitigation planning and fees. For the
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 439 December 2012
Wetland Mapping Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
11.5 will also be used as a starting point for the wetlands mapping
also. The minimum mapping polygon size will be smaller than for the
Vegetation and Wildlife Habitat Mapping Study (Draft RSP 11.5) and
the Riparian Vegetation Study (Draft RSP 11.6): 1.0 acres for
vegetated areas and 0.25 acres for waterbodies, versus 0.5 acres for
most upland and wetland habitats and 0.1 acres for waterbodies and
other wetlands of ecological importance. Since the 2-mile buffer
Wetland Mapping study area is entirely contained within the 4-mile
buffer Vegetation and Wildlife Habitat Mapping study, the Service is
curious how the two different minimum mapping polygon sizes will be
addressed where the studies overlap? The field data collected for
delineating wetlands is well documented (Environmental Laboratory
1987, U.S. Army Corps of Engineers 2007). What additional field data
will be collected to delineate Viereck Level IV and Cook Inlet basin
habitats (Viereck et al. 1992, Gracz 2011)?” –pdf page 167
Riparian Mapping Study, the slightly larger minimum
mapping boundaries are appropriate because changes to
vegetation are likely to be on more of a landscape scale,
rather than by individual mapped polygon.
The fact that the wetlands study area boundary is within
the Vegetation and Wildlife Habitat Mapping Study in the
Upper and Middle Susitna Basin area boundary is not a
concern because “scaling up” with respect to mapping is
relatively easy to do. For example, habitat maps are often
derived from wetlands maps, and are developed using
landscape position, wildlife use, and vegetation structure
as the primary criteria.
The field data collection protocol detailed in the USACE
1987 and 2007 documents provides sufficient information
to produce a Viereck Level IV map as long as field plot site
selection is focused on upland habitats as well as wetland
habitats. To create a Cook Inlet Basin wetlands crosswalk
and Viereck level IV classes, wildlife habitat types, and to
assist the functional assessment, a variety of parameters
will be assessed at each field plot (Section 11.7.4.1).
WETLND-10 USFWS 11/14/2012 “Objective 2 is addressed in the Draft RSP section for Wetland
Functional Assessment (11.7.4.3). The methods adequately outline a
very complex process potentially fraught with value judgments and
incorporating a mix of documented functional analyses (Magee 1998)
and project-specific wetland functional analyses. After AEA has had a
chance to work with the data, and before progressing too far with the
functional analysis, the Service recommends that AEA conduct a
TWG meeting to review the details of the analysis to ensure the
products will meet stakeholder needs.” –pdf page 168
Opportunities for review on the progress of the functional
assessment will be available during the scheduled,
quarterly Technical Workgroup Meetings as results
become available in 2013 and 2014.
WETLND-11 USFWS 11/14/2012 “Objective 3 is addressed in the Draft RSP section for Wetland Impact
Assessment (11.7.4.4). The GIS component of this analysis is
straightforward. Before the size and number of indirect disturbance
buffer(s) are finalized based on the final specifications for Project
construction, operations and maintenance activities, the Service
The wetland impact analysis will be conducted during the
preparation of the FERC License Application in 2015
based on final proposed Project plans.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 440 December 2012
Wetland Mapping Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
requests a TWG meeting to ensure the products will meet
stakeholder needs.” –pdf page 168
WETLND-12 USFWS 11/14/2012 “For the pdf wetland map deliverables, the Service recommends
providing these products in geospatial pdf, so a sophisticated GIS
program would not be required to readily identify coordinates on the
maps.”
Licensing participants will be able to access Project GIS
data layers via ADNR’s webmap application, which will
provide interactive digital wetland maps without the need
for additional software (Section 11.7.4.4).
WETLND-13 USFWS 11/14/2012 “Why is 2012 included in the timeline for Draft RSP Table 11.7-1 if no
activities are scheduled or performed in 2012? The Service has not
extensively reviewed the Draft RSPs to ensure the studies providing
input to the wetland functional assessment completely overlap their
study areas with the wetlands study (top row in Draft RSP Figure
11.7-2, Study Interdependencies). How will incomplete overlap be
addressed if input studies do not completely overlap with the wetland
study?” –pdf page 168
Since the focus of the RSP is for 2013-2014, the blank
2012 columns have been dropped from Table 11-7.1 to
eliminate confusion. The RSP acknowledges, however
(Sections 11.7.4 and 11.7.4.1), that 2012 data are being
used to guide 2013-2014 planning efforts.
Revised Study Plan
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FERC Project No. 14241 Page 441 December 2012
Rare Plant Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
No Comments Received
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 442 December 2012
Invasive Plant Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
No Comments Received
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 443 December 2012
Recreation Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
REC-01 NPS 11/14/2012 The baseline data collected in the 2012 recreation and aesthetic
studies are required for the stakeholders to determine the adequacy
of 2013-2014 ILP studies. –pdf page 3
The 2012 scope of work concentrated on the collection of
existing data, and an evaluation of the
comprehensiveness and applicability of existing data to
understand the baseline conditions. In addition, field
reconnaissance conducted in 2012 informed the study
plan process, adjusting methods, sampling approaches
and survey design, and the assessment of demand
approach. Many of the outcomes of this research (and the
impact on study plan design) have been presented and
discussed during Technical Working Group meetings
(such as potential intercept sites, intercept survey design,
executive interview protocol and candidates, etc.) The
2012 Study Report will summarize the evaluation of
existing data and will be available 1Q 2013.
REC-02 NPS 11/14/2012 Include the Lower Susitna River Reach in the recreation study area. –
page 5-6 and page 13 (“Ice Processes”)
The study area in the RSP extends to river mile 83 where
the George Parks Highway Bridge crosses the Susitna
River. (RSP Section 12.5.3, Figure 12.5-1) This
termination point was selected based on the influence of
the Chulitna and Talkeetna rivers on the channel shape
and structure of the Susitna downstream of their
confluence. As explained in RSP Section 12.5.3, if studies
conducted in 2013 indicate that there may be Project-
related changes to river flow, sediment transport, and ice
formation, extent, and seasonal availability (i.e,
freeze/thaw cycles) on the portion of the river located
downriver of the Parks Highway Bridge downstream on
the Susitna River that could impact recreation, an
expansion of the Recreation Use Study Area/Recreation
Supply and Demand Analysis Area and associated level of
analysis of recreation resources uses to include the
effected portion will be triggered in time for the 2014 study
season. Any recommended changes to any study areas
will be included in AEA’s Initial Study Report, which will be
prepared and distributed in early February 2014.
REC-03 NPS 11/14/2012 “Recreation Management Plan- We reiterate that a Recreation
Management Plan (RMP) for both land and water-based use of the
AEA agrees with NPS’s comment, and RSP Sections 12.2
and 12.5.7 confirm that the recreational resources studies
Revised Study Plan
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FERC Project No. 14241 Page 444 December 2012
Recreation Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
project area will need to be developed, as required by FERC (18 CFR
4.51(t)(5)).” –pdf page 3
in the RSP will form the basis for a RMP.
REC-04 NPS 11/14/2012 “10.5.4. Study Methods, ID & Analysis of Salient Data from Existing
Survey Research - Existing survey research appears biased towards
large-scale, packaged tourism. Analysis needs to capture use by
independent tourists and local (unguided AK resident) users, many of
whom are able to access the area without relying on air taxis or jet
boat charters. NPS continues to be concerned that because of the
dispersed nature of access and recreation within the project area, and
the necessary reliance by intercept surveyors on commercial service
providers and outfitters, the intercept survey may under sample
independent travelers by favoring packaged tours, whose guests tend
to congregate in easy-to-find locations.” –pdf page 8
Existing survey research, such as AVSP VI and RSVP,
are statistically rigorous research methods that measure
all types of Alaska visitors and are not biased toward
large-scale packaged tourism. The intercept sample plan
as designed captures significant samples of Alaska
visitors, independent visitors, and Alaska residents, in the
study area. Key intercept locations for independent visitors
and residents will be along the Denali Highway, Parks
Highway, at local air carriers and in Talkeetna. The
Regional Resident Household mail survey will capture
additional information about resident use of the area
(Section 12.5.4).
REC-05 NPS 11/14/2012 “In Table 12.4-1 AEA states that it "believes that total project area
visitation will increase with the development of the Project, even if
some types of users may get displaced." NPS remains interested in
the experiential and activity-specific changes in recreational
opportunities that will occur, not just net increases or decreases in
numbers of users.” –pdf page 9
Understanding potential changes in experiential and
activity-specific recreation opportunities is central to the
recreation impact analysis. To complete this assessment,
inputs from all components of the Recreation and
Aesthetics Program (i.e., Use & Demand [including
socioeconomics analysis], Trails & Facilities, River-based
Recreation, Aesthetics, and Soundscape) will be
synthesized to understand changes in (bio)physical,
social, and operational aspects of recreation experience
and potential change to existing opportunities. This
analysis will be spatially explicit, and completed at the
scale of the Study Area. This objective and anticipated
outcome is clarified in the RSP (Section 12.5.4).
REC-06 NPS 11/14/2012 Recreation User Intercept Survey- Eliminate “Don’t Know” and
“Refused” from the mail/online (self-administered) survey instrument.
–pdf page 9
RSP Section 15.5.4 explains that the differences in some
questions (and response code block) are based on the
mode of delivery.
REC-07 NPS 11/14/2012 “Recreation User Intercept Survey- Question 20(t) & (g)- Table should
ask about need for Information and Education resources: kiosks,
signage, trail information, points of interest, geologic, historic and I or
cultural information.” –pdf page 9
The intercept survey draft (Attachment 12-2) includes a
question (Q. 15 m.) that specifically asks if respondents
would like to see more “signage with cultural, historic,
geologic, and points of interests.”
REC-08 NPS 11/14/2012 “Recreation User Intercept Survey- Question 20(t) & (g)- We believe Questions regarding facility management were
Revised Study Plan
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FERC Project No. 14241 Page 445 December 2012
Recreation Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
that user preference for greater management attention (level of
maintenance, staff presence, security, etc.) should be added to this
question.” –pdf page 9
considered, but due to concerns for survey length they
were not included in the current draft. This line of
questioning, however, will remain in consideration until the
intercept and mail surveys are pre-tested and finalized.
As noted in Section 12.5.4, AEA will seek agency input on
the final survey instruments in early 2013.
REC-09 NPS 11/14/2012 “Recreation User Intercept Survey- Question 21(a)- Wording is
awkward. Perhaps the words ‘would not’ could be deleted…” –pdf
page 9
Revision of the survey question will be considered to
remove awkwardness. As noted in Section 12.5.4, AEA
will seek agency input on the final survey instruments in
early 2013.
REC-10 NPS 11/14/2012 “Recreation User Intercept Survey- Question 24.- We believe that the
determination of party size should appear earlier in survey.” –pdf
page 9
Based on experience, group size questions are best
situated close to questions regarding spending. Final
placement of all questions will be determined during pre-
testing of the survey instruments. As noted in Section
12.5.4, AEA will seek agency input on the final survey
instruments in early 2013.
REC-11 NPS 11/14/2012 “Mail/Online User Survey- NPS would like to see the actual survey
instrument.” –pdf page 9
As noted in Section 12.5.4, AEA will seek agency input on
the final survey instruments in early 2013.
REC-12 TCCI 11/07/2012 “TCCI is concerned that AEA has not involved the local Community
Council’s in any of its efforts to collect recreational use data. Again,
we are also concerned that recreational data will only be collected for
2013 and in 2014 only “ as a provision to capture data in the event of
unusual circumstances”. This study duration allows for only one
December study period.” –pdf page 5
The study plan includes executive interviews with key
organizations, associations, etc., including the Talkeetna
Community Council. The purpose of these interviews is to
gather baseline information on historical and current
recreation use and attributes within the Study Area. These
interviews are expected to take place in the 1st and 2nd
quarter of 2013 (Section 12.5.4).
The studies are designed to understand recreation trends
in addition to a 2013 snapshot. The studies in 2013 and
2014 are also intended to collect data from recent years,
in addition to identifying recreation trends and uses, and
quality of experience in past seasons. AEA will also use
2014 to perform further investigations related to recreation
if determined necessary based on 2013 study results. For
example, the Recreation and Aesthetics Studies will
evaluate the extent to which any anticipated changes in
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 446 December 2012
Recreation Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
river flow, sediment transport, and ice processes would
affect these resources (4Q 2013/1Q 2014). If such an
effect may exist, the Recreation Resources Study and
Aesthetics Resources Study areas (including recreation
use and demand, trails and facilities, recreation
experience, river ice-dependent recreation, soundscape
and aesthetics) and associated analyses will be
expanded.to include affected areas.
REC-13 TCCI 11/07/2012 “TCCI supports NPS in expanding the recreational study area to the
Lower River.” –pdf page 5
See AEA’s response to comment REC-02.
REC-14 TCCI 11/07/2012 (NPS-PSP comments) “Goal of executive interviews is to gather more
info about baseline conditions and potential project effects - not ‘sell”
the project to recreationists” –pdf page 5
The interview protocol provides an unbiased, factual
introduction to the project. The purpose of the interviews is
to collect baseline recreation conditions/use/attributes and
not influence opinions, see Attachment 12-3.
REC-15 TCCI 11/07/2012 “TCCI also concurs with NPS that voter registration is not an accurate
survey sampling database. Many Susitna recreationists may come to
the area seasonally form other areas of the state or the Lower 48.” –
pdf page 5
As explained in Section 12.5.4, AEA believes that use of
the voter registration database is a valid sample universe
for the Regional Resident Household Mail Survey. The
voter registration database is readily available, screens for
those over age 18, and also contains a mailing address in
addition to a physical address of those registered to vote.
While it is understood that not all regional residents are
registered to vote, this database represents a wider
diversity of names and addresses than commercially
purchased mailing lists (such as utility customers).
Information about non-Regional residents or non-residents
recreation use will be captured through the intercept
survey method.
REC-16 TCCI 11/07/2012 TCCI supports the inclusion of ice related recreation effects. The
current studies lack methodology for user experience other than a
“preference curve” for ice conditions.
Northern Susitna recreation is subject to highly variable conditions
which will not be accurately represented with “historic” 80’s data.
The Susitna hosts the Iditarod Sled Dog Race as well as the Oosik
An investigation of river ice dependent winter recreation is
included in Section 12.7 of the RSP. The Study will
investigate winter recreation activities occurring within the
bounds of the Susitna River channel that are dependent
on river ice formation. The purpose of the 2013 ice-
dependent recreation portion of the winter recreation
program is to determine existing ice-dependent recreation,
the purpose (i.e., transportation or recreation) and the
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 447 December 2012
Recreation Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
Classic ski race and stable ice is required for both popular events.
–pdf page 5
conditions under which these activities occur. The ice
dependent recreation activities are likely to include
snowshoeing, skiing, dog sledding, trapping and
snowmobiling as well as use of river ice for winter
transportation corridor. Additional activities observed
during the field investigations will be documented as well.
A list of winter recreation and competitive events
dependent on river ice formation will also be compiled and
analyzed.
The river ice dependent winter recreation study will
document winter recreation activity on the Susitna River
ice using a combination of field observations, executive
interviews and analysis of recreation and competitive
events. The executive interviews and analysis of events
will include data beyond the current 2-year field data
collection period. Use patterns will be analyzed to
determine spatial and temporal use preferences as well as
frequency of use by month.
REC-17 Various
Individuals
11/07/2012-
11/14/2012
Two year study is inadequate to determine potential project impacts
on ice stability from fluctuating flows and recreational use for
activities, such as, snowshoeing and dogsledding skiing.
AEA believes that two years is sufficient time to assess
potential Project-related effects on recreational resources.
The purpose of the 2013 ice-dependent recreation portion
of the winter recreation program is to determine existing
ice-dependent recreation, the purpose (i.e., transportation
or recreation), the demand, and the conditions under
which these activities occur. The winter recreation study,
including the river ice dependent winter recreation study,
will document winter recreation activity on the Susitna
River ice using a combination of field observations,
executive interviews and analysis of recreation and
competitive events. The executive interviews and analysis
of events will provide data that extends beyond the 2-year
field data collection period.
This work will be completed through coordination with the
Ice Processes in the Susitna River Study (Section 7.6).
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 448 December 2012
Recreation Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
The extent to which impacts to ice-dependent recreation is
expected as a result of the proposed Project will be
dependent on the outcome of modeling completed by the
ice-processes work. Preliminary results from the Ice
Processes in the Susitna River Study will be reviewed
early in the 4th quarter of 2013 to determine the
downstream effects of the Project on river ice formation.
REC-18 FERC 11/14/2012 “In section 7.15, Analysis of Fish Harvest in and Downstream of the
Susitna- Watana Hydroelectric Project Area, you propose to analyze
fish harvest using data from ADF&G records of commercial, sport,
personal, and subsistence fisheries. The data will be used to evaluate
the potential for the project to alter harvest levels and opportunities on
Susitna River-origin resident and anadromous fish. At the August 15,
2012, technical work group (TWG) meeting, it was noted that ADF&G
fish harvest surveys are conducted over large areas. ARRI requested
that you conduct additional fish harvest surveys to provide harvest
data at an appropriate geographic scale for the proposed analysis. In
response, you noted in your October 24, 2012, RSP consultation
table, that no additional fish harvest surveys would be conducted
because such surveys were not necessary to analyze effects of the
proposed project. You provide no further explanation for why you do
not intend to conduct additional fish harvest surveys. It is not clear
from your response how the existing ADF&G records would be
sufficient to cover a geographic area specific to the project. Please
include in your RSP an explanation to support your position that the
ADF&G fish harvest data are of an appropriate geographic scale to
permit an analysis that meets the study objectives. If study objectives
cannot be met using the ADF&G data, please include in your RSP a
description of alternative data collection methods.” –pdf page 19
The ADF&G data is collected at the tributary level.
Because the majority of this sport harvest occurs at the
confluences of these tributaries with the Susitna, the data
is relatively site specific, meaningful, detailed, and
adequate for analysis. Review of baseline data conducted
and field reconnaissance research in 2012 suggests sport
fishing use in the Upper Susitna and lakes within the
watershed is very light and dispersed. Sections 12.5.4
(Recreation Supply, Demand and Use) and 12.5.7 explain
the adequacy of ADF&G fish harvest data in context to its
geographic extent and its ability to meet the needs of the
Project.
REC-19 FERC 11/14/2012 “The study area map and descriptions provided in section 12.5.3,
particularly the “Recreation Use Study Area,” are not entirely clear.
Place names used in the text should be labeled on the map.” –pdf
page 22
The recreation study area figure (12.5-1) has been revised
to more clearly indicate study areas and to include place
names used in the text.
REC-20 FERC 11/14/2012 “You propose to identify and map trails based on aerial imagery,
existing GIS datasets, field identification, agency interviews, and
Existing trails in the immediate project area will be
mapped at a scale that will ensure sufficient accuracy for
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 449 December 2012
Recreation Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
surveys, but you do not define the scale at which these trails will be
mapped and reported. To ensure sufficient accuracy for analysis,
existing trails in the immediate project area should be mapped, where
practical, to the 1:24,000 national map accuracy standard of +/- 40
feet.” –pdf page 22
analysis across studies. See Section 12.5.4.
REC-21 FERC 11/14/2012 “The Study Interdependencies chart on page 12-51 illustrates this
integration; please describe how and when this integration will occur
in the study methods.” –pdf page 22
Section 12.5.7 has been added to the RSP and provides a
detailed description of study interdependencies.
REC-22 FERC 11/14/2012 “The recreation demand analysis should also consider latent demand
for new facilities or opportunities that could result from development
of the project.” –pdf page 22
Section 12.2. has been clarified to state that the
Recreation Resources Study will identify existing and
foreseeable future recreation opportunities, including
latent demand. Although there are no specified
developments associated with this Project to consider
latent demand, AEA recognizes that it will be important to
consider latent demand for new facilities or opportunities
that might result, and the draft intercept survey has a
question regarding a development scenario (Attachment
12-2). Additionally, the interdependency between Social
Conditions and Public Goods and Services Study (Section
15.6.4) and the Recreational Resource studies will
address latent demand. See Section 12.5.7.
REC-23 FERC 11/14/2012 “It appears that intercept and mail surveys are intended to provide
data on guided versus unguided use (i.e., commercial outfitter/guided
user vs. non-commercial independent user). However, it is not clear
in the draft survey instrument how this information would be obtained.
For example, the table at the top of page 12-90 combines
guide/outfitter spending with transporter spending. Also some users
may hire a guide for one type of activity, require transportation only
for another activity, and recreate independently for another activity.
The table on page 12-86 should be modified to distinguish between
guided versus unguided use. If this is not practical in terms of your
survey design, please explain why and provide an alternative
approach to understanding commercial versus non-commercial
recreational use in the project area.” –pdf page 22
Preliminary draft survey design ascertains whether
respondent used a guide or not. It does not capture what
activity or activities were guided. Survey length is of great
concern and compromises need to be made. Baseline
data revised in 2012 suggest that the level of guided
fishing in the area is low. Likely, there is more guided
hunting and perhaps some small amount of
hiking/backpacking and other activities. The random
intercept surveys will capture a proportionate share of
these guided users while they are in the field, at air
carriers, or in Talkeetna. Executive interview research and
ADF&G data will also supplement data on guided vs.
unguided use.
REC-24 BLM 11/14/2012 “This section specifically excludes the North side of the Denali AEA has not adopted BLM’s recommendation that the
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 450 December 2012
Recreation Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
Highway and the headwaters of the Susitna River. The BLM
recommends that these areas be included. Inclusion of the
headwaters of the Susitna is needed on order to provide information
for WSR suitability study.” –pdf page 4
North side of the Denali Highway and the headwaters of
the Susitna River be included in the study area for the
Recreation Resources Study. The operation of the Project
is not anticipated to affect recreation resources, facilities,
and uses north of the Denali Highway; therefore, there is
no nexus between Project operations and effects on
recreation resources, facilities, and uses on the Susitna
River north of the Denali Highway and on or along the
headwaters of the Susitna River.
However, the licensing studies may provide useful
information for BLM’s WSR suitability study. The
Aesthetic Resources Study area includes all lands located
within a 30 miles radius of the viewshed of Project
components, and therefore will extend north of the Denali
Highway (Section 12.6.3). The impact analysis will include
the potential change to aesthetic attributes within the WSR
study area should visibility of Project components be
determined to extend to this area, or changes in
soundscape anticipated. In addition, the Recreation
Resources Study will include al campgrounds and
infrastructure located on the north side of the Denali
Highway; however recreation demand will not be
assessed beyond these locations (Section 12.5.3).
REC-25 BLM 11/14/2012 “BLM requests prior notification to Glennallen Field Office prior to
conducting campground surveys.” –pdf page 4
The Recreation Resources Study plan (Section 12.5.4)
has been updated to accommodate BLM’s request.
REC-26 BLM 11/14/2012 “Correction to text; ‘Only 21 miles of road on the eastern end and
three miles on the western end are Paved’” –pdf page 4
This reference is no longer included in the RSP.
REC-27 BLM 11/14/2012 “BLM suggests adding the Susitna River Bridge as an intercept
location.” –pdf page 4
Figure 12.5-2 includes this intercept point.
REC-28 BLM 11/14/2012 “Delta Wayside is located at mile 21 (not MP 16). (adjust maps
accordingly)” –pdf page 4
Delta Wayside is located at mile 21.5 in the RSP (Section
12.5.4).
REC-29 BLM 11/14/2012 “Page 3 – Correction: Tangle River Inn owners are Jack and Nadine
Johnson. BLM also suggests that these additional candidates be
considered for interviews based on their past history of dispersed
AEA appreciates receiving this information. Current
owners will be identified and considered for interviews.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 451 December 2012
Recreation Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
recreational use in the area: Ray Adkins, Bailey – Stephan Lake
Lodge, National Outdoor Leadership School (NOLS), Talkeetna Air,
Denali Air, Jake Jefferson, and Braun Kopsak.” –pdf page 4
REC-30 BLM 11/14/2012 On PSP Page 4 – “BLM GFO recreation contacts are: Field Manager
-Beth Maclean, Assistant Field Manager-Elijah Waters, and Outdoor
Recreation Planners- Cory Larson, Denton Hamby, Heath Emmons,
and Marcia Butorac.” –pdf page 4
See AEA’s response to comment REC-29.
REC-31 ADNR-DPOR 11/14/2012 “1. The impacts the Gold Creek and Chulitna proposed transmission
and road corridors will have on Denali State Park; specifically the
potential for providing unauthorized access to the park. 2. If
constructed, the western end of the Gold Creek and Chulitna
proposed corridors will also provide a direct access corridor to the
park, increasing park access. The management implications of this
access are of concern to the DPOR. 3. Visual impacts to the aesthetic
resources of the park as a result of transmission line construction. 4.
Potential conflicts among recreational users during construction and
maintenance of transmission line and road corridors.” –pdf page 3
AEA agrees with the four points highlighted within the
comment and they are addressed within the study plan.
The Recreation Use Study Area includes the Denali State
Park (RSP Section 12.5.3) and the study plan is designed
to assess the potential impacts to recreational and
aesthetic resources as a result of the Project (RSP
Section 12.5.4), including potential conflict among
recreational users and increased access and visual
impacts to the Denali State Park east of the Parks
Highway.
REC-32 ADNR-DMLW 11/14/2012 In PSP section 13.7.2 “Pages 13-17 For river transportation the study
will evaluate non-recreation or subsistence transportation uses in the
Susitna River corridor from the Denali Highway to the river mouth.
This statement should be clearer. From reading the Recreation
Section the only Guide/Tour activity discussed are the tours to the
base of Devils Canyon. The use of the Susitna River in the Lower
Reach by Guides and Lodges during open water and ice road should
be analyzed. None of the other Guides or Lodges are discussed in
the recreation section. “–pdf page 11
The Recreation Resources Study and River Recreation
Flow and Access Study (RSP Section 12.7) will analyze all
guide and tour activities within the study area, including all
river based operators.
However, the study area does not include portions of the
river downstream from the Park Highway Bridge, as
explained in AEA’s response to REC-02. Also, please see
Ice Processes in the Susitna River Study Plan (Section
7.6) for further details.
REC-33 ADNR-DMLW 11/14/2012 In PSP section 13.7.4 “Pages 13-18 to 13-20 Document Existing
Conditions: There is no mention of tracking or documenting use of
these RS2477 and easements in the study plan.
Three valid RS2477 Rights-of-Way cross or are within the Susitna
River. Two of these ROW's utilize the frozen surface of the Susitna
River, RST-199 Susitna-Rainy Pass and RST-200 Susitna-Tyonek.
The third RST-1509 Curry Landing Strip Lookout crosses the river
and climbs the ridge to the lookout location. All of these RS2477
Rights-of-Way are valid interests owned by the State of Alaska.
RSP Section 12.5.4 (Trails) outlines the study methods
that will be used to assess and analyze impacts to all
RS2477 and 17(b) easement within the Recreation Use
Study Area. This analysis will focus on trails and access
routes that may be affected by development of the Project.
This includes RST-199, RST-200, RST-1509, all of which
fall within the Recreation Use Study Area.
However, the study area does not include portions of the
river downstream from the Park Highway Bridge, as
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 452 December 2012
Recreation Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
There are also existing State and Private easements that cross or
utilize the Susitna River in the lower portion such as the State owned
Amber Lakes - Trapper Lake easement leaving from Susitna Landing.
These easements provide access to Homesteads and commercial
lodges on the West side of the Susitna River.
There is also significant use by the Western Cook Inlet oil and gas
industry for utilizing the Susitna River as an ice road in the winter.
There is no mention of tracking or documenting use of these RS2477
and easements in the study plan. The potential of utilizing the frozen
surface of the Susitna River post dam construction may possibly
impact the ability of the river to be utilized as an ice road or crossing.
The potential need for bridge crossings in the lower sections of the
river should be analyzed as a possibility if flows impact the ability of
the river to be used as a frozen highway.“ –pdf page 11
explained in AEA’s response to comment REC-02.
REC-34 ADF&G 11/14/2012 “More detailed information is needed to better understand what data
will be collected, and how it will be summarized, analyzed, and results
generated. In particular, more information is needed on the following
components:
a) Incidental Observation Survey
b) Telephone Survey of Railbelt Residents
c) Intercept Surveys and Structured Observation Visitor Counts
ADF&G recommends that AEA conduct a technical review with
interested agencies on the preliminary results generated by the
proposed recreation use and demand surveys noted above (after
data collection and preliminary analyses) to identify possible concerns
related to the detailed analyses prior to development of the final
reports. It is often the case that errors in data analysis can be spotted
at this phase prior to interpretation and reporting.” –pdf page 35
The RSP contains considerably more detail that the PSP
and no longer includes mail and internet survey instead of
the telephone survey presented in the PSP (Section
12.5.4). As noted in Section 12.5.4, moreover, AEA will
seek agency input on the final survey instruments in early
2013.
REC-35 ADF&G 11/14/2012 Section 10.5.4 Recreation Use and Demand (pg.10-6) “Paragraph #1,
Sentence #2: The sentence “visitors to the area participate in a wide
variety of activities, including…” should also mention all-terrain
vehicle (ATV) and/or off-road vehicle (ORV) use, hiking, and wildlife
viewing. The activities noted are certainly not inclusive and more
detailed lists and inclusive language are used elsewhere in this
document.” –pdf page 35
Section 12.5.4 includes ATV, ORV, hiking and wildlife
viewing recreation activities.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 453 December 2012
Recreation Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
REC-36 ADF&G 11/14/2012 Section 10.5.4 Recreation Use and Demand (pg.10-6) “Paragraph #3,
Sentence #2: “Effects of the project features (e.g. reservoir and
access roads) on…..” is rather non-inclusive of the various
recreational activities in the project areas and the language probably
should be modified. Fishing and berry picking are other “consumptive”
recreation activities that should be mentioned. Bird-watching, as an
example of non-consumptive use, should be broadened to wildlife-
viewing.” –pdf page 35
Section 12.5.4 includes fishing and berry picking as
“consumptive” recreation activities and bird watching is
included as “wildlife viewing” under non-consumptive
uses.
REC-37 ADF&G 11/14/2012 Section 10.5.4 Recreation Use and Demand (pg.10-6) “Paragraph #3,
Sentence #4: The sentence that reads “There are also potential
effects of induced recreation along the Denali Highway….” doesn’t
make sense. Are they trying to say “there is also the potential for
induced effects on recreation from the project along the Denali
Highway”? This statement should be clarified if left in the document.”
–pdf page 35
This sentence no longer appears in the RSP.
REC-38 ADF&G 11/14/2012 Section 10.5.4 Recreation Use and Demand (pg.10-6) “Paragraph #4:
Regarding the reference to the Socioeconomic Resource Study and
the economic contribution of recreation in the study area. AEA should
be aware of the following study related to economic contributions of
sport fishing to the Alaska economy. Southwick Associates Inc. and
W. J. Romberg, A. E. Bingham, G. B. Jennings, and R. A. Clark.
2008. Economic impacts and contributions of sportfishing in Alaska,
2007. ADF&G, Professional Publication No. 08-01, Anchorage.
Although the regional analysis may not provide direct estimates
related to the proposed project, it is a template for estimating
expenditures associated with recreation use in Alaska. This study will
likely be repeated in 2014 or 2015.” –pdf page 35
These studies were reviewed in 2012 and will be
considered in the recreation demand assessment
analysis.
REC-39 ADF&G 11/14/2012 “Section 10.5.4 Identification and Analysis of Salient Date from
Existing Survey Research
The Alaska Visitor Statistic Program (AVSP) is a reasonable survey
instrument and data source for non-resident recreation use in and
around the project area. Other relevant sources of salient data for
both non-resident and resident recreation use which are not noted in
this proposed study plan, include:
ADF&G Statewide Harvest Survey. Annual survey of resident and
These studies were reviewed in 2012 and will be
considered in the recreation demand assessment
analysis.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 454 December 2012
Recreation Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
non-resident sport fishing households. Survey provides annual
statewide, regional and watershed estimates of sportfishing days
fished by species by residency, guided/unguided. Estimates available
for the past 30 yrs. Published report through 2010, available data
through 2011. See:
Jennings, G. B., K. Sundet and A. E. Bingham. 2011. Estimates of
participation, catch, and harvest in Alaska sport fisheries during 2010.
ADF&G, Fishery Data Series No. 11-60, Anchorage.
Alaska Resident Statistics Program (ARSP). Survey commissioned in
2000 to estimate Alaska resident recreation behavior patterns and
preferences. See:
Fix, P. J. (2009). Alaska Residents Statistics Program Final Report.
Fairbanks, Alaska: School of Natural Resources and Agricultural
Sciences, Department of Resources Management, University of
Alaska Fairbanks.” –pdf page 36
REC-40 ADF&G 11/14/2012 “Section 10.5.4 Incidental Observation Study (p.10-8)
The description of this study (IOS) states that this survey will not have
statistical value, but will be used throughout the study. How will the
IOS feed into other studies and decision making? Will the results of
the incidental observation just be a map with points indicating
observed recreation for reference, or are there some other methods
that could be employed to otherwise use the results of the IOS. There
should be more explanation and details on how else this information
could be useful in the process.” –pdf page 36
The purpose of the IOS is to capture information from field
researchers about dispersed recreational use within the
Recreation Use Study Area. The survey helps to identify
types and patterns of recreation use and is considered
qualitative. AEA will review the IOS results prior to and
throughout survey fielding to identify any potential gaps in
survey sampling. There are no plans to map reference
points; however, data results of the IOS will be included in
the ISR and/or USR, as appropriate.
REC-41 ADF&G 11/14/2012 “Section 10.5.4 Telephone Surveys of Railbelt Residents (p.10-8)
Paragraph #1, Sentence #2: The plan says that a statistical sample of
600-900 randomly-selected Railbelt residents will be drawn and later
that estimates for possible sub-groups will be developed (and sample
adjusted). It is our experience with public surveys that likely response
rates to the survey will be relatively low (less than 40% of drawn
sample), so we believe that the 600-900 sample size is probably too
low to provide sufficient responses for sub-group estimates to be
developed with any degree of precision. Suggest identification of sub-
groups during study development and adjustment of sample size and
sampling protocol as needed. Question: what are the sub-groups
likely to be based on – location of residence, recreation type or mode
After initial consultation, the telephone sampling
methodology was reviewed and subsequently changed to
a mail survey. Rationale for this approach is included in
the Recreation Resources Study RSP (Section 12.5.4).
Subgroup analyses will include residence, day/overnight
users, transportation mode, party size, length of stay, and
recreation activity.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 455 December 2012
Recreation Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
of travel? Please explain in subsequent detailed study plan. The
ARSP study plan (noted above) may provide useful background for
sub-group identification. Given that statistical estimates of resident
recreational use and other recreation variables are to be developed
from this study, it is recommended that a detailed study plan for the
telephone survey be developed and review by relevant agencies and
organizations for adherence to current social science research
practices prior to implementation.” –pdf page 36
REC-42 ADF&G 11/14/2012 “Section 10.5.4 Intercept Surveys and Structured Observation Visitor
Counts (p.10-9)
Paragraph #1. Although the list of specific recreation access modes
mentioned in this paragraph does not appear to be exclusive, it
seems that ATV/ORV access should be mentioned among those
listed given the large number of ATV/ORV access points along the
Denali Hwy south as well from the Talkeetna area. If in paragraph #2
the plan is going to mention specific mode examples, it should list an
ATV/ORV major access trail as well.
It appears that this will be a non-probability sample of recreation
users (paragraph #4 last sentence) - since there appears that a
statistical sampling process will not be employed. Please explain how
the resulting data from this particular sub-study would be summarized
and integrated with other recreation data.” –pdf page 37
ATV/ORV trailheads and access points are considered in
the survey intercept plan (see RSP Section 12.5.4).
ATV/ORV users will be randomly surveyed at both
developed and undeveloped trail heads.
As described in Section 12.5.4., stratified random
sampling will be used to collect a statistical sample of
recreation users. The sample plan will first be stratified by
month, day, and to some degree day parts. This will be
overlaid with selected survey locations throughout the
study area.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 456 December 2012
Aesthetic Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
AES-01 NPS 11/14/2012 Include the Lower Susitna River Reach in the aesthetics
study area. –pdf page 5
The study area in the RSP extends to river mile 83 where the
George Parks Highway Bridge crosses the Susitna River. (RSP
Section 12.6.3, Figure 12.6-1) This termination point was selected
based on the influence of the Chulitna and Talkeetna rivers on the
channel shape and structure of the Susitna downstream of their
confluence. As explained in RSP Section 12.6.3, if studies
conducted in 2013 indicate that there may be Project-related
changes to river flow, sediment transport, and ice formation, extent,
and seasonal availability (i.e, freeze/thaw cycles) on the portion of
the river located downriver of the Parks Highway Bridge downstream
on the Susitna River that could impact aesthetic resources, an
expansion of the Aesthetic Resources Study Area and associated
analyses will be triggered in time for the 2014 study season. Any
recommended changes to any study areas will be included in AEA’s
Initial Study Report, which will be prepared and distributed in early
February 2014.
AES-02 NPS 11/14/2012 “Unresolved issues: 10.6.4. Study Methods, Seasonal
Surveys of Ambient Sound Levels- What if the results of
visitor experiential surveys indicate there need to be more
surveys or surveys in different locations in order to quantify
baseline resources? This is another example of a situation
where the lack of reconnaissance level data makes survey
design a guessing game.” –pdf page 10
The baseline noise/soundscape analysis (RSP Section 12.6.4) takes
into account existing trails and areas of dispersed used. As
explained in Section 12.6.7, coordination with Recreation,
Subsistence, and Wildlife Resources is planned for first quarter 2013
to ensure all baseline data pertaining to soundscapes (i.e, location
of receptors) is accounted for. In addition, areas that could be
affected by increase in Project-related and non-Project-related traffic
will be assessed for baseline measurements.
AES-03 FERC 11/14/2012 “You propose to conduct a soundscape analysis to
characterize ambient conditions and estimate the effects of
project construction and operation. Noise from induced
activities (e.g., increased non-project traffic, ATVs,
snowmachines, motorized boating, float planes, etc.) and
potential effects of project noise on dispersed recreation do
not appear to be included in the analysis; these potential
noise sources and effects should be included in the
analysis so that environmental effects can be fully
evaluated.” –pdf page 23
The following Statement has been added to Section 12.6.4:
Soundscape Analysis: “The analysis will include an assessment of
Project-induced effects based on the assessment of future
recreation use and demand and Project-related opportunities
(Section 12.5.4).” The Interdependencies figure has been updated to
indicate this objective, including coordination with Wildlife
Resources. See Figure 12.6-2.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 457 December 2012
Aesthetic Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
AES-04 NPS 11/14/2012 NPS would like to verify that the sound analysis is
consistent with NPS guidelines. –pdf page 10
AEA looks forward to receiving any comments NPS may have on
the study methods proposed in Section 12.6 in RSP comments filed
with FERC by January 18, 2013. See Section 1.2.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 458 December 2012
River Recreation Flow and Access Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
RECFLW-01 NPS 11/14/2012 “NPS suggested that focus groups be used to assess
optimum and acceptable flow alternatives for the project.” –
pdf page 11
As part of the Recreation Resources Study (RSP Section 12.5) AEA
has elected to conduct executive interviews with commercial and
non-commercial users familiar with river recreation flows in the three
river recreation reaches extending from the Denali Highway Bridge
to the George Parks Highway Bridge at Sunshine. The large study
area and dispersed nature of the river recreation activities, both in
space and time, are not practical for focus group sessions. Flow
preference questions will be asked during executive interview
sessions.
RECFLW-02 NPS 11/14/2012 10.7 .3. Study Area (and following bullet) - Clarify the study
area determination process/rational. Expand the
Recreation Study area to include all river miles of the Lower
Susitna River Reach (to Cook Inlet). –pdf page 11
As explained in Section 12.7.3 of the RSP, AEA has proposed to
study river recreation downstream to river mile 83 where the George
Parks Highway Bridge crosses the Susitna River. This termination
point was selected based on the influence of the Chulitna and
Talkeetna rivers on the channel shape and structure of the Susitna
downstream of their confluence coupled with proximity of egress for
non-motorized watercraft on the Susitna River.
Also as explained in Section 12.7.3 of the RSP, if studies conducted
in 2013 indicate that there may be Project-related changes to river
flow, sediment transport, and ice formation, extent, and seasonal
availability (i.e, freeze/thaw cycles) on the portion of the river located
downriver of the Parks Highway Bridge downstream on the Susitna
River that could impact recreational uses in the lower reach of the
river, an expansion of the River Recreation Flow and Access Study
and associated analyses will be triggered in time for the 2014 study
season. Any recommended changes to any study areas will be
included in AEA’s Initial Study Report, which will be prepared and
distributed in early February 2014.
RECFLW-03 NPS 11/14/2012 “10.7 .6. Schedule-We continue to maintain that one year of
study is not an adequate sample size to support
conclusions about important flow-dependent activities like
sport fishing, and float hunting.” –pdf page 12
AEA believes that implementation of the study plan, as proposed in
the RSP, will support conclusions about flow-dependent activities.
Flow records on the Susitna extend 56 years. While the study plan
contemplates the collection of users’ experience on the Susitna
River beginning in 2013, respondents will be encouraged to provide
information on current trips in 2013 as well as trips made in previous
years (Section 12.5.4).
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 459 December 2012
River Recreation Flow and Access Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
RECFLW-04 TCCI 11/07/2012 “TCCI supports NPS in expanding the recreational study
area to the Lower River.” –pdf page 5
Please see AEA’s response to comment RECFLW-2.
RECFLW-05 FERC 11/14/2012 “In section 12.7.4, Study Methods, in the fifth paragraph
under Surveys, the text refers to the Devils Canyon stretch
of Reach 1. It appears this should be Reach 2.” –pdf page
23
Section 12.7.3 clarifies that Devils Canyon is in Reach 2. See also
Figure 12.7-1.
RECFLW-06 ADNR - ADF&G 11/14/2012 “For the eulachon (Section 7.16) and boating (Section10.7)
studies, similar information is needed on how the flow-
habitat/resource information will be collected. For example,
what is the study area, what sampling strategy will be used,
how many and what range of calibration-discharge sets will
be collected if appropriate, and how will HSC/HSI data be
developed?” –pdf page 21
The study will examine the stage-flow relationships developed by
the fisheries group, in particular, the results of the HEC-RAS model
(RSP Section 8.5.4.3). This information will help determine the
downstream influence of the project on recreation.
Channel cross-sections measuring water depth and velocity will not
be used for the recreation flow study. Numerous recreation
instream flow studies have documented the deficiencies associated
with this approach and the associated assumptions. Whittaker et al.
(1993) reported that depth and velocity have proven to be unreliable
for predicting recreation instream flow needs. This method assumes
that (i) all critical transects (shallow areas) have been identified for
all watercraft; (ii) the channel bed shape will remain static
maintaining a consistent path for boat passage through time; and (iii)
boat passage is the definitive attribute for river recreation quality.
The Susitna River channel is dynamic typically changing course on
an annual basis. Because of this dynamic nature, channel cross-
section analysis for navigation purposes is not applicable.
Furthermore, suitability curves are not available for all the watercraft
utilizing the Susitna.
RECFLW-07 NMFS 11/14/2012 “This PSP proposes to address NMFS' s concerns about
baseline recreational resources valuation as commented on
in our scoping comments. It is our understanding that
intercepts surveys and plans for their deployment are
presently being developed for inclusion in the revised study
plans. NMFS would like the intercept surveys to include
lower Susitna (below confluence of Talkeetna River)
intercept sites where river boats are commonly launched. It
The boat launch at Ship Creek is primarily used to access the Lower
Susitna River at the mouth, not the reaches of the Susitna River
currently included in the Study Use area. If, as explained in AEA’s
response to RECFLW-2, results of the other resource disciplines
studies (e.g., ice processes, etc.) indicate possible Project-related
effects on recreation in the lower Susitna River, AEA will
recommend expansion of the study area in the ISR. As part of any
such recommendation, AEA will consider conducting intercept
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 460 December 2012
River Recreation Flow and Access Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
may also be advantageous to reconnoiter the Anchorage
launch ramp at Ship Creek to determine whether it is a
significant access point for the lower Susitna fishermen and
hunters. If so, it should be included as an intercept site.
Further, the study should consider conducting intercept
surveys at substitute sites such as the Kenai River in order
to estimate the potential impact on substitute sites of
closure of the Susitna to retention of, for example, Chinook
salmon.” –pdf page 186
surveys at the Ship Creek boat launch.
AEA has not adopted NMFS’s request to add intercept sites at
substitute sites, such as the Kenai River. AEA believes that the
proposed surveys are comprehensive in breadth to obtain reliable
information within the vicinity of the Project area, without relying on
surrogate sites that are unlikely to produce applicable information
related to the Project area.
RECFLW-08 NPS 11/14/2012 Study title and initial statements about its scope appear
contradictory, study goal should look at all forms of
recreation that could be affected by flow changes. –pdf
page 11
AEA agrees with this comment, and the objectives of this study
encompass forms of recreation other than boating and access,
providing that "recreation use and experience for the respective river
recreation and transportation opportunities on three mainstem
Susitna River reaches" (Section 12.7.1). Section 12.7.4
provides: "Survey participation will be solicited by advertising the
river recreation survey electronically through a multitude of forums
including but not limited to national and regional whitewater groups,
forums for outdoor recreation including adventure races, fishing,
hunting, motorized and non-motorized user groups, message
boards, commercial outfitters and guides, adventure schools and
transportation services to the study area."
RECFLW-09 NPS 11/14/2012 “Section 12.7.4., Study Methods, Winter River Recreation
Preferences “The Susitna River during the winter ice period
provides motorized and non-motorized winter recreation
opportunities and serves as a transportation corridor for
residents along the Susitna. Construction and operation of
the Project may alter the timing and longitudinal extent of
ice formation, and impact such uses. Under any of the
currently proposed project operations scenarios, the Project
will have that effect.” –pdf page 12
Before completing the Ice Processes in the Susitna River Study
(Section 7.6), AEA believes it is premature to conclude whether and
to what extent flow changes in the Lower River attributable to
Project-related operations will affect recreational use.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 461 December 2012
Cultural Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
CUL-01 BLM 11/14/2012 “The BLM would like to ensure that Off Highway Vehicle trails,
which currently access or could potentially access the initial APE
study area, will be included in the expanded APE for areas of
potential direct or indirect effects.” –pdf page 1
The RSP (Section 13.5.3) defines the indirect APE to
include: 1) areas likely to be affected by induced dispersed
recreational activity extending from existing trails, including
all-terrain (ATV, or OHV – Off Highway Vehicle) trails, and
recent campsites observed during the 2012 field
investigations; 2) areas near or related to known sites
including APE-mapped trails and recreation use areas; and
3) areas of high cultural resource potential adjacent to APE-
mapped trails and recreation areas.
CUL-02 ADNR-OHA 11/14/2012 “The Cultural Resources Study section initially seems to imply
that the entire APE will be intensively inventoried for cultural
resources. However, the methods for identifying areas of high
probability for the presence of cultural resources are then
discussed later, which shows that select areas will be more
intensively inventoried than others. Please clarify this earlier in
this section – the Section 106 process does not require intensive
(e.g., 100%) pedestrian inventory across the entire APE, but
rather a “reasonable and good faith identification effort.” –pdf
page 6
AEA concurs that the Section 106 process does not require a
100 percent pedestrian inventory across the entire APE and
did not intend to imply such a level of effort. The RSP
(Sections 13.5.4.2, 13.5.4.5, and 13.5.4.6) explicitly defines
the intensity of pedestrian survey methods according to
environmental variables within the study area and their
probability for revealing cultural resources.
CUL-03 ADNR-OHA 11/14/2012 “Recommendation: Recent concern with climate change
encourages us to compare our archaeological data to past
climatic conditions and fluctuations, to better understand how
human societies have dealt with past climate change. Because
of this need for paleoenvironmental data, lake core and bog core
data should be utilized. If not already available, bog cores should
be taken in the project area. –pdf page 4
Benefit: These cores will generate chemical signatures and ages
for tephras, past vegetation types and frequency through pollen
data, grain size analysis for wind regimen, etc.” –pdf page 5
The RSP (Section 13.5.4;4) includes a lake-coring
component in the field investigations, to produce information
on pollen frequencies and other paleoenvironmental data
through time and thus help establish the context in which to
evaluate and interpret the archaeological inventory.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 462 December 2012
Cultural Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
CUL-04 BLM 11/14/2012 “This section [PSP 11.5.1.1., Study Goals and Objectives] does
not treat whether AEA and its contractors will investigate local
paleo-environment and sediment data, which can provide a
contextual framework for understanding the area’s
archaeological record in terms of past environmental changes
and associated shifts in subsistence or other land use
strategies.” –pdf page 1
Please see AEA’s response to CUL-03.
CUL-05 BLM 11/14/2012 PSP 11.5.1.1: “Additionally, AEA and its contractors should
similarly consult with the BLM during implementation of the
2013-2014 cultural resources survey.” –pdf page 1
The RSP (Section 13.5.1.1) includes consultation with BLM
as a specific objective.
CUL-06 BLM 11/14/2012 PSP 11.5.2.1: “”What is intention of these statements regarding
prioritization of radiometric dating? Are there limitations on the
number of radiometric tests that will be conducted? If so, how
many will be allocated through-out the project? Is it possible that
sites that meet the above criteria will not be chronometrically
dated? The BLM expects that sites with well-preserved organics
or multiple components will be radiometrically dated as part of
the process for determining their eligibility for the National
Register of Historic Places, regardless of any other
prioritization.” –pdf page 1
The RSP (Section 13.5.2.1) clarifies that sites which will be
evaluated for National Register eligibility, and which have
well-preserved organics or multiple components, will be
radiometrically dated to assist in the eligibility evaluation.
CUL-07 ADNR-OHA 11/14/2012 In PSP section 11.5.2.1 Page 11-9 states that only a sample of
sites will be dated. It is hoped that all sites that can practically be
dated, will be dated. –pdf page 7
Please see AEA’s response to CUL-06.
CUL-08 BLM 11/14/2012 PSP 11.5.4.2: “Has there been any consideration of participating
in the Alaska Federation of Natives (AFN) annual meetings to
ensure that a broad range of interested Alaska Natives can
attend? Most tribes and villages have a number of members
attending AFN and the BLM has been asked several times to
schedule consultation meetings complementary with those
meetings.” –pdf page 2
AEA desires that a broad range of interested Alaska Native
parties have the opportunity to participate in the
ethnogeography investigations, and that the effort be efficient
and sensitive to participants’ scheduling constraints. To that
end, the regional elders’ conference (RSP Section 13.5.4.8)
is planned to be held in the Ahtna region (since most Native
contributors are from that region) with invitations to others,
and scheduled so as not to interfere with the AFN annual
meeting. A conference date in early March of 2013 will avoid
traditional Ahtna and Dena’ina subsistence activity windows
and will be scheduled concurrent with other community
meetings or gatherings for maximum efficiency and courtesy.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 463 December 2012
Cultural Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
CUL-09 CIRI 11/14/2012 “AEA's Revised Interim Draft Cultural Resources study plan is an
improvement over the Draft Cultural Resource study plan but
leaves room for meaningful improvement relevant to FERC's
responsibilities. In several places, the Revised Interim Draft
Cultural Resources study plan recognizes the need to take into
account Dena'ina place names, ethnography, history and
culture. In other places, the Revised Draft Cultural Resources
study plan takes a narrow approach to the history, anthropology,
archaeology and ethnography of the Project area, studying some
ethnographic groups or languages, but not Dena'ina, calling for
interviews of some Native Alaska elders, but not Dena'ina
elders, calling for supplemental study of Dena'ina tribal practices
"as appropriate," and suggesting less intensive study of Dena'
ina tribal practices. It is common for an area to have been used
by more than one Native group either over different time periods
or more or less at the same time and for different purposes. It is
not necessary or appropriate, therefore, to treat the significance
of an area to one indigenous, ethnographic community as
excluding or precluding its historic significance to other
indigenous communities. CIRI's comments should not be
understood as suggesting that the study of other ethnographic or
tribal groups should not go forward as proposed. AEA's Revised
Interim Draft Cultural Resources study plan fails to adequately
take into account that history and culture often are complicated
by significance of a place to more than one community at the
same or different times and for different purposes. This failing
results in part from AEA's inadequate consultation with CIRI
regarding cultural resources of concern to CIRI and its
shareholders.” –pdf page 4
The Cultural Resources Study plan is intended to document
Historic Properties and Traditional Cultural Properties that
may be affected by the Project, whether resulting from
prehistoric or contemporary practices of Ahtna or Dena’ina.
AEA concurs with the principle suggested by CIRI that all
such resources should be considered. In Section 13.5.1, the
RSP states: “For the Dena’ina communities of Chickaloon
and Knik, AEA will build on the existing Upper Cook Inlet
Dena’ina place names work (Kari and Fall 2003),
supplemented by additional interviews with knowledgeable
Dena’ina elders.” The RSP notes that the ethnogeographic
study addresses many topics, “with emphasis on Ahtna tribal
practices, supplemented by information on Dena’ina and
Lower Tanana tribal practices as appropriate.” As a practical
matter, Ahtna tribal practices are less represented in the
published scientific literature, and so the RSP addresses this
shortfall while including both Dena’ina and Lower Tanana
tribal practices. AEA welcomes the collaboration of CIRI in
identifying source materials and Dena’ina elders to be
interviewed for the Cultural Resources Study.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 464 December 2012
Cultural Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
CUL-10 ADNR-OHA 11/14/2012 “Recommendation: The 2013 survey will need to test multiple
locations across the project area that have deep aeolian
sediments, to better understand the types of soil profiles that will
be encountered on the project. This testing must take place at
the start of the field season, and in locations that are near
sources of high aeolian sediment, namely braided locations
along the Susitna River, to get good stratigraphic separation.
Benefit: These soil profiles will help inform on what soil horizons
may be in the region, and may include paleosols and volcanic
ash falls as well as periods of high and low sediment deposition.
This testing may be profitably coupled with information on past
and current caribou studies and aerial survey to put soil test
locations” –pdf page 4
The RSP (Section 13.5.4.5) states that pedestrian surveys
are conducted in areas that have a high potential for cultural
resources and high potential for deep aeolian sediments,
especially during the 2013 field season.
CUL-11 ADNR-OHA 11/14/2012 “Recommendation: All individuals on survey crews need
appropriate training to adequately record and interpret the
sediments they encounter. Each crew needs at least one
individual with advanced training who can guide crew members
on the soils and tephras that they will encounter.” – pdf page4
As explained in Section 13.5.5, all survey crews will meet the
personnel standards of the Secretary of the Interior’s
Standards and Guidelines for Archaeology and Historic
Preservation. Also as noted in Section 13.5.5, survey crews
will receive classroom/laboratory instruction on tephra
identification and its importance, as well instruction on soil
stratigraphy.
CUL-12 ADNR-OHA 11/14/2012 “Coupled with the model information on high and low probability
areas given to the crews should be explanations of why areas
are modeled high probability…in order to better plan survey of
that area.” –pdf page 5
The RSP (Section 13.5.4.2) states that prior to fieldwork,
field crews will be briefed on the criteria for defining high and
low probability areas in order to better execute the survey.
CUL-13 ADNR-OHA 11/14/2012 “…part of the Susitna survey should include use of some type of
random sampling, possibly stratified random sampling, to test a
variety of location types, in an attempt to insure that unknown
site types are not missed.” –pdf page 5
As explained in the RSP, a variety of multivariate location
types are created by the locational model using a variety of
environmental data sets (RSP Section 13.5.4.2 and Tables
13.5-1 and 13.5-2), leading to probabilistic definitions of high
and low potential for cultural resources, with the realization
that such statistical models have limitations in application.
Consequently, survey will not be exclusively devoted to high
potential zones but will also be conducted in a smaller
sample of areas deemed low potential.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 465 December 2012
Cultural Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
CUL-14 ADNR-OHA 11/14/2012 “The Cultural Resources Study section does not mention a
Programmatic Agreement (PA). Given the scope and magnitude
of this complex undertaking, a PA may be an appropriate
approach to dealing with the Section 106 process. As noted at
36 CFR 800.14[b][1][ii], PAs may be used ‘when effects on
historic properties cannot be fully determined prior to the
approval of an undertaking’; and ‘when nonfederal parties are
delegated major decision-making responsibilities’.” –pdf page 5
Because FERC’s standard practice in hydropower licensing
processes is to enter into a Programmatic Agreement (PA)
with the State Historic Preservation Officer (SHPO), AEA
agrees with ADNR-OHA that a PA is appropriate for this
undertaking. AEA expects FERC to circulate a draft PA
following the completion of the Cultural Resources Study,
and likely shortly after its issuance of the draft environmental
impact statement. For these reasons, Sections 13.2.1 and
13.5.6 reference the development of a PA between FERC
and ADNR-OHA.
CUL-15 ADNR-OHA 11/14/2012 PSP section 11.1 Page 11-1 Introduction, first paragraph,
second sentence: Suggest slightly rewording to: “Information
from these studies will be used to assist in identifying
appropriate protection, avoidance, minimization, mitigation, and
enhancement measures…” –pdf page 6
The RSP (Section 13.1) includes this language, although the
“protection, mitigation and enhancement” language is
standardized throughout the RSP and the other types of
measures listed in ADNR-OHA’s comment are subsumed
within this standardized language.
CUL-16 ADNR-OHA 11/14/2012 PSP section 11.1 Page 11-1 Introduction, second paragraph,
second sentence:
Recommend defining “historic properties” right up front (use
definition from 36 CFR 800,16[l]). Also, it may be helpful to
distinguish the difference between “cultural resources” and
“historic properties” early on as they are often (and
inappropriately) used interchangeably. –pdf page 6
The RSP (Section 13.1) incorporates ADNR-OHA’s
comment, as suggested.
CUL-17 ADNR-OHA 11/14/2012 PSP section 11.2 Page 11-2 Header: The use of the words
“Nexus” and “Existence” seems a bit odd. Is the intention to
express effects throughout the life of the project (from planning
through to operations and beyond?). Suggest using the phrasing
“Consideration of Immediate and Long-Term Effects on Historic
Properties” or similar. –pdf page 6
FERC regulations use this term, 18 CFR 5.9(b), which has
been standardized for consistency in all the study plans in
the RSP.
CUL-18 ADNR-OHA 11/14/2012 PSP section 11.5.1.1 Page 11-7 Study Goals and Objectives:
Suggest slight rewording of the first paragraph and
accompanying bulleted list. Recommended changes are
highlighted below:
The goals of the 2013-2014 cultural resources study plan are to
systematically inventory cultural resources within the APE (36
CFR 800.4[b]), evaluate the National Register eligibility of
As a general matter, AEA agrees that cultural resources that
are expected to be affected by the construction and
operation of the project will require evaluation for National
Register (NR) eligibility. As recognized in ADNR-OHA’s
comment, however, in this early phase of the licensing
process it is not clear whether the direct APE proposed in the
RSP precisely delineates every location of expected Project-
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 466 December 2012
Cultural Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
inventoried cultural resources within the APE that have not been
previously evaluated (36 CFR 800.4[c]), and assess Project-
related effects on National Register-eligible historic properties
within the APE (36 CFR 800.5[a]). These goals ensure
evaluation of cultural resources identified within the APE for
NRHP eligibility. NRHP evaluation should not just be done for
those that may be adversely affected (as this may change and
assessment of adverse effects comes at the next step). If they
are located within the APE, that presumes the potential for
effects and cultural resources identified therein should be
evaluated for NRHP eligibility.
Similar adjustments should be made to the corresponding
bulleted list of items that immediately follow this paragraph. –pdf
page 6
related direct effects. By necessity, as AEA’s licensing study
program progresses, the direct APE may need to be refined
to ensure that it is limited to those areas of actual project-
related effects. If licensing studies conducted in 2013
indicate that there may be Project-related effects to cultural
resources in areas currently outside the APE, the APE may
be further adapted to encompass these areas. Any
recommended changes to the APE will be included in AEA’s
Initial Study Report, which will be prepared and distributed in
February 2014 (Section 13.5.3).
In addition, the “Guidelines for Development of Historic
Properties Management Plans for FERC Hydroelectric
Projects,” issued jointly by FERC and the Advisory Council
on Historic Preservation (ACHP), recognize that it is not
always possible for FERC to determine all of the effects of
various activities that could affect cultural resources over the
course of a long license term. As such, these Guidelines
provide for the development of a project-specific Historic
Properties Management Plan (HPMP) that will specify
procedures for the continued identification and evaluation of
cultural resources, as well as for the management and
protection of historic properties, for the term of the license.
As noted in Section 13.5.6 of the RSP, AEA will develop the
HPMP in consultation with ADNR-OHA during the licensing
process. The Programmatic Agreement (PA) between FERC
and ADNR-OHA is expected to require AEA to implement the
HPMP upon FERC’s issuance of the license.
For these reasons, AEA does not believe it appropriate to
presume at this early juncture that Project-related effects will
occur at every location within the proposed direct APE.
Where necessary, the direct APE will be refined to
encompass only areas that are expected to be directly
affected by the Project. Moreover, as authorized by ACHP
regulations, 36 CFR 800.14, FERC’s use of a PA in this case
allows some flexibility in the sequencing of the steps typically
employed to inventory, evaluate, and assess effects to
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Cultural Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
historic properties. In the HPMP, AEA anticipates the
development of procedures and options—such as avoidance
and management measures—that would allow AEA, in
consultation with ADNR-OHA, to adequately protect cultural
resources in areas affected by the Project without having to
undertake a formal National Register evaluation in every
instance.
CUL-19 ADNR-OHA 11/14/2012 In PSP section 11.5.2.1 the bulleted second sentence on p. 11-8
was left unfinished: “document hydrological concepts embedded
in place names, directional system, and landscape narratives;
and…”
Please complete this sentence. –pdf page 7
The sentence is complete in the RSP (Section 13.5.1.1).
CUL-20 ADNR-OHA 11/14/2012 In PSP section 11.5.4.3 - This project has the potential to
generate multiple products that will stand as a legacy to the all
the effort and funding involved.
Hopefully NLUR will go beyond the stated goal of “Updat(ing)
cultural chronology” to make sure in their final report that they
generate a synthesis of regional prehistory that will be useful for
workers in the region for decades to come. While this synthesis
should integrate Ahtna land perspectives and Ahtna place name
data, other publications should encapsulate the Ahtna data, with
one or more of these written for the general public. –pdf page 7
The RSP (Section 13.5.4.9) includes additional detail about
the Cultural Resources Study reports. The reports will go
beyond updating cultural chronology to develop the Project’s
archeological data within a synthetic regional framework for
the comprehensive, but restricted, volume on the cultural
resources investigation.
CUL-21 FERC 11/14/2012 “In some cases, [AEA has] developed plans for and are carrying
out studies in consultation with stakeholders to voluntarily collect
information in 2012 that will help [AEA] prepare or refine a study
plan. Please describe how these 2012 efforts were or are being
incorporated into the RSP.” – pdf page 5
Sections 13.5.1 and 13.5.4.2 explain AEA’s 2012 efforts and
how the results of these efforts have been incorporated into
the RSP.
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Cultural Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
CUL-22 Ahtna 05/02/2012 Ahtna requested that a non-technical volume summarizing the
cultural resource investigation results be produced for public
distribution. –pdf page 5
To meet regulatory requirements, AEA is required to produce
a technical report on cultural resources. For this reason, the
requested non-technical volume is beyond the scope of this
RSP. AEA recognizes, however, that the Native
communities are sharing their knowledge and expertise with
the goal that the resulting documentation of their heritage,
showing how they lived and thrived in this landscape through
time, would be available as a teaching tool for their
communities. AEA looks forward to further consultation with
Ahtna on these matters.
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Paleontological Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
PALEO-01 BLM 11/14/2012 PSP Section “11.6.1.1., First Paragraph, “…Paleontological
Resources Protection Act of 2009…” Should be changed to
“…Paleontological Resources Preservation Act of 2009.” –pdf
page 2
The RSP refers to the Paleontological Resources Preservation
Act in Section 13.3.
PALEO-02 BLM 11/14/2012 Regarding PSP Section “11.6.2, First Paragraph, “The potential
for Pleistocene faunal remains needs to be reviewed…” How will
this be accomplished? It does not seem that a literature review
alone will be effective in this regard. Will exposed bluff faces
similar in context to this find be examined in the field?” –pdf
page 2
The potential for Pleistocene faunal remains will be determined
not through literature review alone but in conjunction with
paleontological field survey, augmented by the results of the
geology and geomorphological studies. The RSP (Section
13.6.4) elaborates upon field methods and sampling
approaches informed by the literature review.
PALEO-03 ADNR-OHA 11/14/2012 In PSP Section 11.6.3- Study area for Paleontological
Resources: The archaeological survey plan has included the
areas along to the Susitna River between the Denali Highway
and the impoundment as part of the indirect APE because of the
concern for negative impacts from increased recreational traffic.
The paleontological study should include the same indirect APE
for the same reason, namely concern for the unauthorized
collection of these resources. The PSP mentions the 29,000
year old mammoth remains found at the confluence of the
Susitna and Tyone rivers (Thorson et al. 1981), but doesn’t
suggest including this area in survey. Because of this concern
with unauthorized collection, Pleistocene exposures along the
Susitna River should be examined for possible paleontological
resources. –pdf page 7
The RSP (Section 13.6.3; Figure 13.6-1) defines the study area
for paleontological investigations to be the same as that for the
direct and indirect APE of the cultural resource investigations,
including the confluence of the Susitna and Tyone rivers.
PALEO-04 ADNR-DGGS 11/14/2012 Page 11-17 in the PSP Section 11.6.2 “The first sentence in this
sub-section implies that the Hadrosaur fossils are Pleistocene in
age, which is not the case. Suggest rewording the beginning of
the sentence to ‘The potential for vertebrate faunal remains
should be reviewed.” –pdf page 14
The language in the RSP (Section 13.6.2) better describes the
temporal range of specimens.
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Subsistence Resources Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
SUB-01 CWA 11/14/2012 Include TK into RSP. –pdf page 8 Traditional Knowledge regarding the physical, biological and social
environment, including fish specifically, is being documented as part of the
Subsistence Resources Study, see RSP Section 14.5.4.5.
SUB-02 CWA 11/14/2012 “The Subsistence Section Does Not Consider Mitigation
or Prevention of Project Impacts” –pdf page 10
Section 14.5.4.7 notes that the impact analysis will identify potential
protection, mitigation, and enhancement measures, as necessary.
SUB-03 CCC 11/15/2012 “The subsistence studies are focusing exclusively on a
narrow set of target communities (Talkeetna, Trapper
Creek, Chase, etc.) However the lower Mat Su Valley and
Anchorage heavily use game unit 13 in the region of the
Dam. The study needs to be expanded to better
understand the impact on these user groups and the
cumulative impact of the dam, access roads, and other
impacts on sustainability of the wildlife populations.” –pdf
page 3
The Subsistence RSP addresses 37 study communities, 25 of which have
planned subsistence fieldwork. The RSP does address communities in the
lower Mat Su Valley, including Wasilla and outlying CDPs. In addition, RSP
Section 14.5.4.1 includes a subtask to access to ADF&G’s Winfonet
database to identify “subsistence users and communities in Alaska who
travel to the proposed Project area to participate in land mammal harvest
activities and additional information about study communities’ (including
those located in nonsubsistence areas) subsistence activities in the Project
area.” Harvest by residents of the lower Mat-Su Valley and Anchorage
areas will be analyzed as part of the Wildlife Harvest Analysis study (RSP
Section 10.20). Results from the Wildlife Harvest Analysis study, as well as
results from the variety of physical, biological and cultural resource studies
will be compared with subsistence harvest data and for impacts to
subsistence uses.
SUB-04 BLM 11/14/2012 “BLM requests more clarity on the “Impact Analysis” to
analyze the effects of more access to BLM managed lands
to subsistence users, particularly possible conflicts
between subsistence users and major increases in non-
rural resident/non-resident users” –pdf page 2
The Subsistence Study will collect baseline subsistence data and document
traditional and contemporary subsistence harvest, which—in combination
with other study results—to evaluate Project-related impacts on BLM and
other lands (Section 14.5.7).
SUB-05 BLM 11/14/2012 “The BLM also requests more clarity on the effects of how
lands lost to reservoir inundation and
transportation/transmission corridors will affect
subsistence users by the redistribution of fish, wildlife, and
plant resources within and around BLM managed lands.
(i.e.: what analysis tool(s) will you use?).” –pdf page 3
See AEA’s response to comment SUB-4.
SUB-06 BLM 11/14/2012 “The BLM requests an analysis of the potential short and
long term increased user base of federally qualified
subsistence users as a result in population growth in the
Cantwell area.” –pdf page 23
See AEA’s response to comment SUB-4.
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Regional Economic Evaluation Study
Reference
Number Commenter Date Filed Comment or Study Request AEA’s Response
ECON-01 Long, Becky 11/13/2012 The RSP should reference the work prepared by ISER regarding the
Susitna-Watana Cost of Power Analysis Discussion Paper which
indicated that power from natural gas-fired generation could be lower
than power from the Project –pdf page 2
AEA does not believe it appropriate to reference the ISER
Discussion Paper, as some of the assumptions used in the
model for the Discussion Paper were incorrect. For
example, the Susitna-Watana Hydroelectric Project is not
subject to RCA regulatory authority; the Project will not
charge depreciation to power purchasers; the capital costs
used in the Discussion Paper are too high; and interest
rates may be too high.
ECON-02 TNC 11/14/2012 “Objectives for 15.5 Regional Economic Evaluation Study seem to
presuppose only benefits from power generation and ignore the
possibility of economic loss from the project. An analysis by ISER
(Colt 2012) predicted higher electrical rates with the project.” –pdf
page 4
See AEA’s response to comment ECON-1.
ECON-03 FERC 11/14/2012 “One of the objectives of this study is to describe the effects of the
project on the regional economy that would result from improvements
in the reliability of the electrical power grid. In section 15.5.4.1, Data
Collection and Analysis, you discuss the need to identify actions that
will affect the economy of Alaska through interviews with
knowledgeable individuals. The section goes on to say that “[t]he
categories of persons to be interviewed and types of interview
questions that will be used to develop REMI [Regional Economic
Model Inc.] model assumptions are presented in the Appendix”. While
the appendix does include two tables that show the categories of
persons that would be interviewed and topics that would be
discussed, no example interview questions are provided.” –pdf page
23
Interview questions are included in RSP Section 15,
Attachment 15-1.
ECON-04 FERC 11/14/2012 “To improve the readability and clarity of your study plan, please
combine tables 1 and 2 to show what information is expected to come
from each person (a similar approach was used in the HIA [Health
Impact Assessment] section 15.8.2) and provide some example
questions as indicated in the main body of text. In addition, please
include a line item in the schedule provided in Table 15.5.1 that
shows when the interviews will be completed. You should also
provide an explanation on how these interviews will be documented
The tables in RSP Section 15, Attachment 15-1 have been
combined as Table 15.A-1 to show the type of information
that is anticipated from each individual/organization;
proposed questions are included.
A line item in RSP Table 15.5.1 shows when the
interviews will be conducted and completed.
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Regional Economic Evaluation Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
and whether this information will be available as part of the Initial
Regional Economic Evaluation Study Report, similar to what is being
proposed under the HIA.” –pdf page 23
Documentation of the interviews will be provided in the
Regional Economic Evaluation Study (Section 15.5.6).
ECON-05 FERC 11/14/2012 “The forecast analysis that would be performed using the REMI
model will compare with-project and without-project conditions. The
without-project conditions would be defined based on a mix of
electrical generation sources developed through production cost
modeling with Railbelt utilities and an appropriate alternative that
does not include a large hydroelectric project. Your methods do not
define what utilities would be consulted, what cost data would be
obtained from the utilities, how the production costs would be
modeled, and, if known, what assumptions would be applied to the
model” –pdf page 24
As explained in Section 15.5.4.1, as part of its ongoing
responsibilities separate and apart from licensing and
developing the Project, AEA will provide information on
power generation, transmission, and demand in the
Railbelt, which will be used in the REMI model. As part of
this effort, AEA will collect or develop information on the
historic electricity rates and system average interruption
duration index reliability minutes for Railbelt utilities, as
well as power generation costs for the gas-fired plants that
are presently under design or construction.
Other assumptions used in the REMI model will come
from several different sources and engineering feasibility
studies that will provide information on Project
construction and operations cost and the amount spent
locally, the cost of power, amount of power available and
similar information. In addition, the interviews described in
Section 15.5.4.1 will provide information for developing
assumptions regarding the future for both the With Project
and Without Project alternatives. Information collected for
the Social Conditions and Public Goods and Services
Study (RSP Section 15.6.4.1) will also provide information
to be used in the regional economic modeling.
As provided in Section 15.5.6 of the RSP, the assumptions
will be provided during quarterly TWG meetings in 2013
and 2014 and the Regional Economic Evaluation Study.
ECON-06 TNC 11/14/2012 “Socioeconomic Analysis
A full analysis of the economic values of this proposed project should
include the costs of constructing the dam and related infrastructure,
the expected price of the power generated, and the change in
economic value of the current goods and services provided by an
The RSP made no changes to the RSP based on this
comment. The Regional Economic Evaluation Study will
address the cost of constructing the dam and related
infrastructure and the expected price of power generated.
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Regional Economic Evaluation Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
undammed river; the no-action alternative should also be analyzed.
The goods and services of the Susitna River that are important to
Alaskans include sport and commercial fisheries, tourism, recreation,
subsistence, and winter transportation for local residents. The river
and upper watershed also supply a host of nationally and globally
important ecosystem services (e.g. climate regulation through carbon
sequestration, fish and wildlife habitat). A full socioeconomic analysis
should quantify all of the existing economic values of the Susitna
River and predict how they will change with construction of the
proposed project. The local and national interests should be
addressed.” –pdf page 4
In addition, nothing in the Federal Power Act requires
FERC to place a dollar value on non-power benefits, even
if FERC assigns a dollar value to the licensee's economic
costs. Moreover, the public interest balancing of
environmental and economic impacts cannot be done with
mathematical precision, and FERC’s statutory obligation to
weigh and balance all public interest considerations would
not be served by trying to reduce it to a mere
mathematical exercise. Where the dollar cost of
measures can be reasonably ascertained, AEA will do so.
However, for non-power resources such as aquatic
habitat, fish and wildlife, recreation, and cultural and
aesthetic values, to name just a few, the public interest
cannot be evaluated accurately or adequately only by
dollars and cents.
ECON-07 NMFS 11/14/2012 AEA should model the Project once the cost and funding are known
to ascertain the change in power rates, the subsequent effect on the
regional economy, and the effect on other areas of the state in the
event that state funding is used for the Project. In the latter event,
spending on the Project would mean fewer funds available for other
projects or programs throughout the state. –pdf page 186
The REMI model will include information on the capital
and operating cost of the Project and this model will be
used to determine the regional economic effect from
changed power rates in the Railbelt region as described in
Section 15.5.3. With regard to NMFS’s comment related
to alternative uses of state funding, such speculative
investigations would not lead to any quantifiable, reliable
information that could inform measures to address Project
effects.
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FERC Project No. 14241 Page 474 December 2012
Social Conditions and Public Goods and Services Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
SOC-01 AHP, AS,
CSDA, NHI,
HRC
11/14/2012 “National-level Economic Valuation Study Request” AEA does not propose a National-Level Economic
Valuation Study as explained in Section 3.1 of the RSP.
SOC-02 TCCI 11/07/2012 A National Valuation Study, or National-Level Economic Valuation
Study, should be undertaken. “–pdf page 4
See AEA’s response to comment SOC-01.
SOC-03 Various
Individuals
11/14/2012 Support for a national valuation study. See AEA’s response to comment SOC-01.
SOC-04 TU 11/14/2012 “A comprehensive economic valuation study should be required in
order for regulating agencies and the public to adequately evaluate
the project’s potential impacts and to come to an informed opinion on
the matter.” “–pdf page 4
See AEA’s response to comment SOC-01.
SOC-05 CSDA 11/14/2012 Request for a National-level Economic Valuation Study. “–pdf page 5 See AEA’s response to comment SOC-01.
SOC-06 CSDA 11/14/2012 “The Social Conditions and Public Goods and Services Study needs
to evaluate and monetize the Ecosystem Services that the Susitna
River watershed provides to communities in and visitors to the
Railbelt. “–pdf page 8
The RSP made no changes to the RSP based on this
comment. Nothing in the Federal Power Act requires
FERC to place a dollar value on non-power benefits, even
if FERC assigns a dollar value to the licensee's economic
costs. Moreover, the public interest balancing of
environmental and economic impacts cannot be done with
mathematical precision, and FERC’s statutory obligation to
weigh and balance all public interest considerations would
not be served by trying to reduce it to a mere
mathematical exercise. Where the dollar cost of
measures can be reasonably ascertained, AEA will do so.
However, for non-power resources such as aquatic
habitat, fish and wildlife, recreation, and cultural and
aesthetic values, to name just a few, the public interest
cannot be evaluated accurately or adequately only by
dollars and cents.
SOC-07 CCC 11/15/12 “The Chase Community Council continues to believe that one of the
most important studies missing from the Study Plan is an assessment
of the cost/benefit, loss/reward of the value of a free flowing river
versus a dammed Susitna River. We believe this study is necessary
to give equal consideration to the non-power values of this river
system and the scope of the proposed net benefit calculations of the
non-power uses does not allow for adequate characterization of a
See AEA’s response to comment SOC-6.
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
diverse, healthy and fully functioning ecosystem.” “–pdf page 4
SOC-08 TNC 11/14/2012 “Socioeconomic Analysis
A full analysis of the economic values of this proposed project should
include the costs of constructing the dam and related infrastructure,
the expected price of the power generated, and the change in
economic value of the current goods and services provided by an
undammed river; the no-action alternative should also be analyzed.
The goods and services of the Susitna River that are important to
Alaskans include sport and commercial fisheries, tourism, recreation,
subsistence, and winter transportation for local residents. The river
and upper watershed also supply a host of nationally and globally
important ecosystem services (e.g. climate regulation through carbon
sequestration, fish and wildlife habitat). A full socioeconomic analysis
should quantify all of the existing economic values of the Susitna
River and predict how they will change with construction of the
proposed project. The local and national interests should be
addressed.” “–pdf page 4
See AEA’s response to comment SOC-06.
SOC-09 TNC 11/14/2012 “Objectives for 15.6 Social conditions and Public Goods and Services
Study do not seem to include quantification of economic value of non-
power effects of the project, which puts an analysis of costs and
benefits on unequal footing. Again, there seems to be a bias toward
primarily the potential positive and not the negative impacts to the
existing economy.” “–pdf page 4
See AEA’s response to comment SOC-06.
SOC-10 Long, Becky 11/13/2012 An important component of these studies should be the National-
Level Economic Valuation. …Also, the Social Conditions and Public
Goods and Services Study needs to include an ecosystem service
component. …These considerations are directly connected to
economic benefits and economic costs. “–pdf page 2
See AEA’s response to comments SOC-01 and SOC-06
SOC-11 FERC 11/14/2012 “The last paragraph in section 15.6.2 discusses the fact that little
published data are available on “non-economic, socio-cultural values,
quality of life, and needs of study area residents”. To fill this data gap,
you are proposing a series of “informal interviews” with “community
council members, residents, Real Estate professionals, MSB [MatSu
Borough] officials and other knowledgeable people.” It is unclear
whether the use of informal interviews, as described, meets agency
Section 15.6.4.1 clarifies that the methodology is
consistent with that used in the analysis by Braund and
Lonner (1982), which successfully collected information on
the values, attitudes, and lifestyle preferences of residents
in the Talkeetna, Trapper Creek, Cantwell, and “railroad
community” areas as far north as Hurricane through
informal interviews with community residents, MSB
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
requests to “survey residents to evaluate potential changes in quality
of life” (June 7th workgroup meeting). Please provide more detail on
the number of interviews planned, how individuals will be identified
and selected for interview, and the types of questions that will be
asked. The interview protocol developed for the Recreation Study
Plan has a similar process. Please explain why informal interviews
will be successful in collecting the agency-requested information.” “–
pdf page 24
officials, and other knowledgeable people. The interviews
will be conducted using the Recreation Study Plan
interview protocol (Attachment 12-4) as a template.
Section 15.6.4.1 also includes more detail on the number
of interviews planned, how individuals will be identified
and selected for interview, and the topic focus of the
questions that will be asked.
SOC-12 TNC 11/14/2012 “Informal interviews are not appropriate for conducting a
comprehensive and unbiased analysis of impacts to local residents
and communities. If “little published information on non-economic,
socio-cultural values, quality of life, and needs of study area
residents”(p 14) exists for the area, a formal survey of random-
selected individuals is required to produce an unbiased analysis of
impacts to communities. A survey can be designed to produce
descriptive and quantifiable results using methods such as
willingness-to-pay and contingent valuation.” “–pdf page 5
AEA’s proposed methodology has been expanded and
clarified in Section 15.6.4.1. See also AEA’s response to
comment SOC-11.
SOC-13 FERC 11/14/2012 “The schedule provided in Table 15.6.1 should include a line item for
the informal interviews and show when they will be completed. In
addition, please explain how the results will be documented and
integrated into other studies and whether or not they will be provided
in the Initial Social Conditions and Public Good and Services Study
Report.” “–pdf page 24
Table 15.6.1 in the RSP includes a line item for the
informal interviews showing when they will be conducted
and completed. The RSP text (Section 15.6.4) has been
changed to provide more discussion regarding
documentation of the results and the integration of the
results into other studies. The text has also been changed
to indicate that the results of the informal interviews will be
contained in the Social Conditions and Public Goods and
Services Initial Study Report.
SOC-14 FERC 11/14/2012 “Under section 15.6.7, Level of Effort and Cost, there is some
discussion of “the collection of secondary data for many communities
that will be collected through phone calls and executive interviews.”
Please clarify if these are the same as the informal interviews
discussed earlier in this section?” –pdf page 24
Section 15.6.8 (Level of Effort and Cost) does not propose
any additional data collection than specified in the earlier
sections of the study plan. Rather, it is a general
statement to inform the estimate of effort and cost.
SOC-15 FERC 11/14/2012 “In response to agency study requests, you have discussed at various
times during work group meetings the possibility of using a Random
Utility Model (RUM) to assess economic impacts of changing
recreational activities associated with the project. Use of the RUM is
As described in the Social Conditions and Public Goods
and Services Study plan (Section 15.6.4.1) the team will
use RUM methodologies to estimate changes in welfare
and recreator behavior. The RUM will use pre-existing
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Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
not discussed in the draft revised study plan. If you plan to use RUM,
you should provide an explanation of the methodology, data needs,
assumptions and other aspects of the model and how it will be
applied to the project. If you have decided not to use the RUM, please
explain why you are not using it and how agency study requests will
be accommodated by your proposed methods.” –pdf page 24
preferences functions for the appropriate recreation
activities from peer reviewed literature combined with
locally available estimates of recreator trip numbers from
secondary sources. The RUM efforts will be further
informed by the work conducted in the Recreation Study
plan (Section 12) and by estimates in changes in
biological processes by other study groups.
SOC-16 NMFS 11/14/2012 “This PSP proposes to address our concerns regarding subsistence
resources as commented on in our scoping comments. The PSP
states that "Approximate cash expenses to generate each pound of
subsistence harvest will be based on published information
(Goldsmith 1998)." The reference cited here is outdated and is
derived in a different region of Alaska where transportation costs are
considerably higher than in the study area. This study should obtain
study area specific cost parameters for current conditions. This data
could be collected as part of the survey plan and/or via consultation
with the ADFG, Division of Subsistence.” “–pdf page 186
See AEA’s response to comment SOC-15.
SOC-17 TNC 11/14/2012 “AEA’s economic studies should use the same population estimates
that the Mat-Su Borough and Alaska Department of Transportation
are using for various planning projects in the area. The borough has
developed build-out scenarios with these population estimates that
would be useful to AEA’s analyses.” “–pdf page 5
The RSP text (Section 15.6.4) indicates that the Without
Project alternative will have population estimates similar to
those prepared by the Mat-Su Borough and the Alaska
Department of Transportation.
SOC-18 TNC 11/14/2012 “How will AEA’s economic studies include the potential loss of salmon
due to habitat loss due to the project and the resulting reduction in
commercial, sport, and subsistence fishing economic value in its
market-based natural resources analysis?” “–pdf page 4
As described in the Social Conditions and Public Goods
and Services Study plan (Section 15.6.4), the team will
use RUM methodologies to estimate changes in welfare
and recreator behavior. The RUM will use pre-existing
preferences functions for the appropriate recreation
activities from peer reviewed literature combined with
locally available estimates of recreator trip numbers from
secondary sources. The RUM efforts will be further
informed by the work conducted in the Recreation Study
plan and by estimates in changes in biological processes
by other study groups. This work will include changes in
angler behavior. Changes in commercial fisheries will
depend on combining recent historical ex-vessel values
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with estimates of changes in fish populations from biology
studies.
SOC-19 TNC 11/14/2012 “The Social Conditions and Public Goods and Services Study (15.6)
does not reference Benefit Transfer Method yet it is mentioned in the
consultation table (15.6.4.1). The use of this methodology should be
clarified in the study plan.” “–pdf page 5
As described in the Social Conditions and Public Goods
and Services Study plan (Section 15.6.4.1), benefits
transfer involves the application of unit value estimates,
functions, data, and/or models from one or more
previously conducted valuation studies to estimate
benefits associated with the resource under consideration
(Black et al. 1998). The benefits transfer approach will be
used to apply recreation preference functions from the
published literature to the random utility model and to
estimate changes in non-use values (existence value,
bequest value, option value) and values associated with
ecological functions in the study area.
SOC-20 NMFS 11/14/2012 “This PSP proposes to address our concerns about baseline
recreational resources valuation as commented on in our scoping
comments. The PSP provides limited information on the planned
methodology for estimation of recreational demand and potential
changes in economic welfare measures that may occur with impacts
from the proposed project. However, it is our understanding that the
contractors are planning to develop a Recreational Utility Model
(RUM) to assess economic welfare values associated with the study
area. NMFS supports this approach because recreational use could
be significantly affected by the project. NMFS expects that the revised
study plan will contain significantly more information on development
of the RUM, the contractors that will be doing the work, and the
planned linkages between results of other study plans (e.g. fisheries
resources, aesthetics etc.) and the site selection and value
parameters to be modeled for each site. Of critical importance to the
development of the RUM will be ensuring that the model addresses
the importance of Susitna drainage Chinook salmon as a relatively
unique recreational opportunity. The methodology needs to capture
the reality that the Susitna River Chinook run and the Kenai River
Chinook run are really the two in-river recreational Chinook harvest
opportunities in the Cook Inlet area. The analysis should identify what
impact declines in Susitna River Chinook, and other salmon, will have
As described in Section 15.6.4, AEA will use RUM
methodologies to estimate changes in welfare and
recreator behavior. Please see AEA’s response to SOC-
15. In addition, Section 15.6.7 denotes that study plans
that are interrelated and the interdependencies are noted
therein.
The RUM model will evaluate changes in fisheries in
different areas, including Chinook Fisheries. This will
include not only the Susitna River Chinook run and the
Kenai River Chinook run referenced in NMFS’s comment,
but also runs in the Little Susitna River, Ship Creek, the
Kasilof River, the Anchor River, the Eklutna Tailrace, and
the Westside Cook Inlet streams and rivers. Anglers
frequently substitute trips between rivers near their
preferred location when closures affect their preferred
location. It is unclear how much the Kenai Rivers and
Mat-Su valley rivers act as substitutes for each other given
the complexity of management regimes on the Kenai.
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on recreationally derived economic welfare values but also what
substitution behavior may mean for other areas such as the Kenai
River and whether management structures at substitution sites will
actually allow substitution to take place.” “–pdf page 185
SOC-21 NPS 11/14/12 “In Table 12.4-1 AEA states that it ‘believes that total project area
visitation will increase with the development of the Project, even if
some types of users may get displaced.’ NPS remains interested in
the experiential and activity-specific changes in recreational
opportunities that will occur, not just net increases or decreases in
numbers of users.”
Do not make the assumption that visitation will increase due to the
Project, and be specific of activity when discussing
increase/decrease. “–pdf page 9
Understanding potential changes in experiential and
activity-specific recreation opportunities is central to the
recreation impact analysis. To complete this assessment,
inputs from all components of the Recreation and
Aesthetics Studies (Section 12) (i.e., Use & Demand
[including socioeconomics analysis], Trails & Facilities,
River-based Recreation, Aesthetics, and Soundscape) will
be synthesized to understand changes in physical, social,
and operational aspects of recreation experience and
potential change to existing opportunities. This analysis
will be spatially explicit, and completed at the scale of the
Study Area. This objective and anticipated outcome is
clarified in the Social Conditions and Public Goods and
Services Study plan RSP (Section 15.6.4).
The Social Conditions and Public Goods and Services
Study RSP (Section 15.6.4) indicates that visitation will
change by activity and that these changes will be identified
by specific activity.
SOC-22 TCCI 11/07/2012 Socio-Economic Studies need to be broader than proposed. Impacts
to fish and wildlife will impact local economies, and the impacts to
local people's livelihoods and life styles need to be studied. “–pdf
page 4
As described in the Social Conditions and Public Goods
and Services Study Plan (Sections 15.6.1 and 15.6.3), the
analysis will describe effects of Project operations and
features (i.e., reservoir and access roads) on the local or
regional economy, including changes in commercial
opportunities related to fishing, hunting, boating, wildlife
viewing, mountaineering, and other recreation. In addition,
the study plan states that the results of the analyses of
Project effects on population, local economies,
subsistence, recreation, and transportation will be used to
evaluate the overall effects on the quality of life of
residents of the region (Section 15.6.4)
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SOC-23 ADNR-DMLW 11/14/12 Similar impacts are possible in the summer months with boat traffic to
lodges and guides utilizing the lower river for the operation of their
businesses. Sufficient flows must be maintained to support these
businesses which are also tied to the viability of salmon runs. “–pdf
page 11
As described in Section 15.6.4.1 of the Social Conditions
and Public Goods and Services Study plan, the economic
impact of the Project on local tourism establishments (e.g.,
river sport fishing, whitewater boating) and the regional
economy will be estimated.
SOC-24 ADNR-ADF&G 11/14/12 AEA should be aware of the following study related to economic
contributions of sport fishing to the Alaska economy. Southwick
Associates Inc. and W. J. Romberg, A. E. Bingham, G. B. Jennings,
and R. A. Clark. 2008. “–pdf page 35
As described in the Social Conditions and Public Goods
and Services Study plan, the analysis will review an
extensive number of previously conducted studies,
including the referenced study that estimated the value of
sport fishing in Alaska and elsewhere (Section 15.6.4.1).
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TRAN-01 Various
Individuals
11/07/2012-
11/14/2012
Two year study is inadequate to determine potential project impacts
on ice stability from fluctuating flows and rivers use as a corridor by
people and wildlife.
The Ice Processes in the Susitna River Study (Section
7.6.2.1) addresses the adequacy of the study of ice
stability.
The number of years of winter observation which will be
relied upon for this study is sufficient to meet the goals
and objectives of the study plan. The study plan will rely
upon at least seven years and likely eight years of winters
of observations (including 5 years in 1980’s, 2012-2013,
2013-2014, possibly 2014-2015 (7-8 years)). As
described in Section 7.6.2, these observations span a
range of meteorological conditions. This will allow AEA to
meet study plan goals and objectives.
TRAN-02 CCC 11/15/2012 “What are the potential detrimental impacts of varying flows on safety
and transportation? Will ice be unsafe to travel on with the lower
water levels and predicted warmer water?” –pdf page 2
Changes in ice formation will be evaluated as part of the
Ice Processes in the Susitna River Study (Section 7.6.4).
Evaluation of the effects of changes in ice formation on
river transportation uses is included in the Transportation
Resources Study (Section 15.7.4.5).
TRAN-03 FERC 11/14/2012 “The schedule summarized in Table 15.7.6 should include a line item
for interviews. In addition, please indicate how the results of the
interviews will be documented and whether the results will be
provided in the Initial Study Report.” –pdf page 25
The schedule (Section 15.7.6) includes a line item for
interviews. Interviews will be conducted during data
collection. Interview summaries will be included in an
appendix of the Initial Study Report and will be used to
support the existing conditions discussion in the report.
TRAN-04 ADNR-DMLW 11/14/2012 “DMLW requests an in-depth analysis and discussion of decreased
flows to determine the impact to timing and extent of river access and
navigation within and downstream of the reservoir, including, but not
limited to launch sites at Deshka Landing, Susitna Landing, Susitna
Bridge, and Talkeetna River.” –pdf page 8
Information from the Recreation Boating Access Study
(Section 12.7) and Instream Flow Study (Section 8.5) will
be used to evaluate the effects of transportation from
relevant launch sites as noted in Section 15.7.4.5.
TRAN-05 ADNR-DMLW 11/14/2012 “Of great concern to the Alaska Division of Mining, Land and Water is
the interconnected nature of the post construction ice processes on
the Social and Transportation Resources as well as the Water
Resources. The potential impacts to ice road formation may
potentially impact the length of the river downstream of the dam,
detrimentally impacting the delivery of fuel and supplies to lodges,
homesteads and cabins from tidewater upstream. This would
The stability of ice will be evaluated in the Ice Processes
in the Susitna River Study (Section 7.6.4). The potential
for effects on ice road formation will be evaluated as noted
in Section 15.7.4.5 of the Transportation Resources Study.
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translate to increased costs of doing business and costs of living on
the west side of the Susitna River downstream of the Parks Highway
Bridge. The potential need to construct ice bridges over the Susitna
River in response to this impact should be analyzed.” –pdf page 9
TRAN-06 ADNR-DMLW 11/14/2012 In PSP section 5.1 “Page 5.1 "The potential effects of the Project on
ice formation, surface and groundwater….."
Consideration for winter ice stability and maintenance should also be
considered. The statement should state: "The potential effects of the
Project on ice formation and stability, surface and groundwater…" For
the Susitna River to continue to be utilized as a frozen highway and
bridge to the Western Cook Inlet oil and gas industry, commercial
lodges and homesteads the stability of the ice is an important
consideration that is not addressed in this section, the recreation
section or the transportation section.“ –pdf page 10
The stability of ice will be evaluated in the Ice Processes
in the Susitna River Study (Section 7.6.4). The
Transportation Resources Study will evaluate potential
effects of changes in ice formation on transportation uses
by the oil industry, lodges and homesteads (Section
15.7.4.5).
TRAN-07 ADNR-DMLW 11/14/2012 In PSP section 5.2 “Page 5.1 Changes to ice processes and flows in
the Susitna River
The impacts to the flow regime and pulsing in the winter months has
a strong potential to impact ice formation below the proposed dam.
As the ice is utilized as road and bridge crossings the safety of the ice
becomes highly important. The downstream ice processes in the
lower river are important for this reason as they have the potential to
impact the economic viability of lodges on the west side of the
Susitna River. Similar impacts are possible in the summer months
with boat traffic to lodges and guides utilizing the lower river for the
operation of their businesses. Sufficient flows must be maintained to
support these businesses which are also tied to the viability of salmon
runs. “–pdf page 11
The stability of ice will be evaluated in the Ice Processes
in the Susitna River Study (Section 7.6.4). The
Transportation Resources Study will evaluate potential
effects of changes in ice formation on transportation uses
by commercial lodges (Section 15.7.4.5)
The Transportation Resources Study will also use
information from the Instream Flow Study (Section 8.5)
and the Recreation Boating Access Study (Section 12.7)
to evaluate potential effects on transportation use of the
river during the summer (Section 15.7.4.5).
TRAN-08 ADNR-DMLW 11/14/2012 In PSP section 13.7.2 “Page 13-14 to 13-15 Tables
The existing Mat-Su Borough Recreational Trails Plan adopted in
March of 2000 is not listed in any of the tables of reviewed
documents.“ “–pdf page 11
This Plan has been added to the list of documents to be
reviewed in Section 15.7.2 Table 15.7-1.
TRAN-09 ADNR-DMLW 11/14/2012 In PSP section 13.7.2 “Pages 13-17 For river transportation the study
will evaluate non-recreation or subsistence transportation uses in the
Susitna River corridor from the Denali Highway to the river mouth.
This statement should be clearer. From reading the Recreation
Section 15.7.4.2 discusses the information that will be
used for the Recreation Boating/Access Study (Section
12.7. Section 15.7.4.3 describes how interviews with
knowledgeable individuals, including individuals
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Section the only Guide/Tour activity discussed are the tours to the
base of Devils Canyon. The use of the Susitna River in the Lower
Reach by Guides and Lodges during open water and ice road should
be analyzed. None of the other Guides or Lodges are discussed in
the recreation section. ““–pdf page 11
representing guides and/or lodges to evaluate recreational
transportation use.
TRAN-10 ADNR-DMLW 11/14/2012 In PSP section 13.7.4 “Pages 13-18 to 13-20 Document Existing
Conditions: There is no mention of tracking or documenting use of
these RS2477 and easements in the study plan.
Three valid RS2477 Rights-of-Way cross or are within the Susitna
River. Two of these ROW's utilize the frozen surface of the Susitna
River, RST-199 Sustina-Rainy Pass and RST-200 Susitna-Tyonek.
The third RST-1509 Curry Landing Strip Lookout crosses the river
and climbs the ridge to the lookout location. All of these RS2477
Rights-of-Way are valid interests owned by the State of Alaska.
There are also existing State and Private easements that cross or
utilize the Susitna River in the lower portion such as the State owned
Amber Lakes - Trapper Lake easement leaving from Susitna Landing.
These easements provide access to Homesteads and commercial
lodges on the West side of the Susitna River.
There is also significant use by the Western Cook Inlet oil and gas
industry for utilizing the Susitna River as an ice road in the winter.
There is no mention of tracking or documenting use of these RS2477
and easements in the study plan. The potential of utilizing the frozen
surface of the Susitna River post dam construction may possibly
impact the ability of the river to be utilized as an ice road or crossing.
The potential need for bridge crossings in the lower sections of the
river should be analyzed as a possibility if flows impact the ability of
the river to be used as a frozen highway.“ “–pdf page 11
Documentation of RS2477 easements and other recorded
easements will be incorporated into the data collection and
documentation of existing conditions as documented in
Section 15.7.4.2.
Representatives of the Western Cook Inlet oil and gas
industry are considered knowledgeable individuals for
documenting existing uses of the river for transportation
(Section 15.7.4.3) and for evaluating potential impacts
based on results from the Ice Processes in the Susitna
River Study.
TRAN-11 CIRI 11/14/2012 “Section 15.7.1.1 of AEA's Revised Draft Transportation Resources
Study would assess the construction and operational direct and
indirect impacts of the Project, including demands for road, railroad,
aviation, port and river traffic. Text following Table 15.7-5 notes that
additional information needed to complete the Transportation
Resources Study includes Project information on proposed access
corridor alternatives. Table 15.7-2 references a report "Access
Corridor Evaluation," describing its year published as 2012 and "in
AEA acknowledges CIRI’s comments on the Draft Watana
Transportation Access Analysis, which is listed in Section
15.7.2, Table 15.7-2.
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progress," and the publishing agency as ADOT&PF. It is unclear from
the Draft Transportation Resources Study whether the Draft Watana
Transportation Access Analysis is the report described in Table 15.7-
2. Out of an abundance of caution, CIRI has included its comments
on the Draft Watana Transportation Access Analysis in Appendix B.
“–pdf page 5
TRAN-12 CIRI 11/14/2012 An October 15, 2012 letter from the U.S. Fish and Wildlife Service
(USFWS) to AEA reviewing AEA's Draft Watana Transportation
Access Analysis at FERC's docket states that USFWS learned during
a "26 July 2012 AEA-sponsored agency site reconnaissance that the
Butte Creek (East) alternative has been dismissed." The Butte Creek
corridor described in the Draft Watana Transportation Access
Analysis is not a reasonable transportation access alternative. CIRI
supports dropping it from further study, if USFWS correctly
characterizes AEA's position. “–pdf page 6
Except with regard to the Butte Creek corridor, which is no
longer being considered. AEA has not made any final
decision on transportation access corridors. All three
remaining corridors are under consideration as shown in
Figure 1.2-1 of the RSP. These three corridors will be
evaluated in the Transportation Resources Study.
TRAN-13 CIRI 11/14/2012 Recommendation. CIRI spent considerable time analyzing the Draft
Watana Transportation Access Report. AEA should clarify whether it
has dropped the Butte Creek transportation access alternative. AEA
should consider CIRI's comments on the Draft Watana Transportation
Access Report in its Transportation Resources Study, including
CIRI's very strong and unwavering opposition to both northern access
alternatives and recommendation for more substantial study of the
western access alternatives. CIRI recommends dropping the Butte
Creek transportation access alternative, if not already done, from
further study as it is not a reasonable access alternative.” “–pdf page
6
As noted in its response to comment TRAN-12, AEA is no
longer considering the Butte Creek corridor. With regard
to the northern access alternatives, AEA understands and
appreciates CIRI’s concerns. At this early phase of the
Project licensing, however, it is premature to deem any as
unreasonable and eliminate it from further evaluation. To
fulfill responsibilities under the National Environmental
Policy Act, FERC and other federal action agencies must
consider alternatives. While CIRI’s concerns with the
northern access alternatives certainly will be analyzed as
part of this process, until AEA completes a more
exhaustive analysis of potential Project-related effects
within each of these corridors, as proposed in the suite of
studies proposed in the RSP, all three corridors will remain
under consideration.
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Health Impact Assessment Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
No comments received
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Air Quality Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
AIR-01 CSDA 11/14/2012 A comprehensive evaluation of greenhouse gas (GHG) emissions
was not addressed in the project, specifically the Air Quality Study. –
pdf page 9
AEA has not adopted CSDA’s request to conduct a
comprehensive evaluation of greenhouse gas (GHG)
emissions that possibly could be associated with the
proposed project reservoir. Quebec Hydro and more
recently Manitoba Hydro (July 2012) have conducted
significant studies on GHG emissions and concluded that
GHG emissions from boreal hydroelectric reservoirs
appear to be low. GHG emissions increase rapidly after
flooding and then return towards levels similar to natural
water bodies within 10 years (Tremblay et. al. 2009). AEA
will estimate GHG emissions in its License Application
based on guidelines for boreal reservoirs.
Tremblay, A., Demers, C & J. Bastien. 2009. GHG fluxes
(CO2, CH4) of the first three years flooding on the
Eastmain reservoir (Quebec, Canada). Proceeding of the
Annual Conference on Hydraulic Engineering, Waterpower
& Climate Change, Necessary Strategies – new
technologies. March 12-13, 2009. Dresden Germany.
P.179-187.
AIR-02 Ransy, Denis 11/14/2012 “A Greenhouse Gas Emissions Study must also be done. There is
significant documentation of GHG production in hydroelectric
reservoirs, caused by rotting of the drowned vegetation. The resulting
methane and carbon dioxide emissions have been found to be
comparable to fossil fuel power plants.” –pdf page 2
See response to comment AIR-01.
AIR-03 ADEC 11/14/2012 Page 13-27 in PSP section 13.9.1.1 “States the analysis will evaluate
impacts from the Project and how Project emissions compare to the
Without-Project alternative.
Recommend also compare to current conditions.”
Baseline emissions will be estimated for fossil fuel sources
per Section 15.9.4.3.
AIR-04 ADEC 11/14/2012 Pages 13-27 to 13-28 in PSP section number 13.9.2 “The primary air
quality concern in the area is particulate matter (PM10 and PM 2.5)
from fugitive dust, volcanic ash, and wildfire smoke.
There are also concerns from wood-heating or wood-burning
devices.” –pdf page 16
Wood-heating and wood-burning devices are included in
the discussion of particulate matter emissions in Section
15.9.2.
AIR-05 ADEC 11/14/2012 Page 13-28 in the PSP section 13.9.2 “There are some limited data The NPS currently operates two monitoring sites, one near
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available from a site in Denali National Park.
There are two Denali monitoring sites. To which site is this statement
referring?” –pdf page 16
the park headquarters and one located at Trapper Creek.
Data from these sites will be used when preparing the
baseline air quality assessment as discussed in Section
15.9.2
AIR-06 ADEC 11/14/2012 In PSP section 13.9.2 “13-28A table comparing the Project emission
with Without-Project alternative emissions will be generated.
Also include in table current emissions.” –pdf page 16
The table includes baseline emissions from fossil fuels
sources per Section 15.9.4.3.
AIR-07 ADEC 11/14/2012 Page 13-28 in PSP section 13.9.2 “If site specific monitoring data is
required… How would the need for site specific monitoring data this
be determined? What are the criteria for determining the pollutant of
concern or will all pollutants be monitored? Is there a clear
understanding of the cost and effort needed to collect data?” –pdf
page 16
AEA does not believe there is a need to conduct
background air quality monitoring as there are no major
emission sources in the area (Section 15.9.2).
AIR-08 ADEC 11/14/2012 Page 13-28 in PSP section 13.9.2 “It is anticipated that at least one
year’s worth of data will be collected consistent with methods outlined
in 18 AAC 50.035. The citation should be 18 AAC 50.215(a).” –pdf
page 16
Section 15.9.2 includes this citation.
AIR-09 ADEC 11/14/2012 Page 13-28 in PSP section 13.9.2 “The area is likely considered
unclassifiable under18 AAC 50.015, as there may be insufficient data
to determine whether it is in attainment with respect to all criteria
pollutants. The classification should not be in question.
Nonattainment areas are clearly defined in 18 AAC 50.015. This area
should fit either the criteria for an attainment or nonattainment area.”
–pdf page 16
Section 15.9.2 states that the area has not been identified
as a nonattainment area. The lack of existing data results
in classification as an unclassifiable/ attainment based on
18 AAC 50.015.
AIR-10 ADEC 11/14/2012 Page 13-28 in PSP section 13.9.2 “EPA maintains a list of non-
attainment areas for all six criteria pollutants on their Green Book
website: (http://www.epa.gov/oar/oaqps/greenbk/index.html).
The Alaska Administrative Code 18 AAC 50.015 also lists the non-
attainment areas.” –pdf page 16
Section 15.9.2 includes this information.
AIR-11 ADEC 11/14/2012 Page 13-28 in PSP section 13.9.4 “The study assumes emission
estimates from the Project are expected to be below major source
thresholds, therefore a PSD and Title V permit are not anticipated for
the Project.
In order to construct a dam consistent with the project description
provided in http://www.susitna-watanahydro.org/project/project-
It has not been determined if a Portland cement facility will
be required. Section 15.9.4.2 addresses how the potential
emissions from a Portland cement facility would be
evaluated against Federal and State permitting thresholds.
Emissions from the plant would be estimated and air
quality dispersion modeling would be conducted to ensure
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description/ , it may be necessary to build a Portland cement plant on-
site.
Per 40 CFR § 51.21(b)(1)(i)(a ) Portland cement plants have a 100
tpy threshold of any regulated NSR pollutant for PSD permit
applicability. Additionally per 40 CFR § 51.21(b)(1)(i)(c )(iii)(c ) and 40
CFR § 71.2, Portland cement plants are stationary sources whose
fugitive emissions must be included in determining whether or not the
plant is a PSD major stationary source or Title V major stationary
source.
Even if not subject to PSD or Title V permitting the source may be
subject to minor permitting requirements under Article 5 of 18 AAC
50.
The Division of Air Quality will need more specific information about
the type(s) of operation planned before the permit requirement can be
determined.” –pdf page 16
the emissions comply with the NAAQS.
AIR-12 ADEC 11/14/2012 Page 13-29 in PSP section 13.9.4 “The air quality study will assess
the existing conditions of the area against applicable state and
national air quality standards and evaluate the Project’s air quality
impacts against these standards. The analysis will include evaluation
of both short-term and long-term impacts from the Project and a
comparison of Project emissions to the no-action alternative.
This can be a substantive task. What are the proposed methods to be
used for this analysis and what are the criteria for determining the
pollutants to be analyzed? Is there adequate meteorological data
available? How will it be determined if an air quality study this
extensive is needed for a hydroelectric project?” –pdf page 17
An extensive air quality study is not being proposed. The
existing conditions will be assessed per Section 15.9.4.1.
Short-term and long term impacts will be evaluated as
described in Section 15.9.4.2 to 15.9.5.4.
AIR-13 ADEC 11/14/2012 Page 13-29 13.9.4 “States the analysis will include evaluation of both
short-term and long-term impacts from the Project and a comparison
of Project emissions to the no-action alternative.” –pdf page 17
Baseline emissions will be estimated for fossil fuel sources
per Section 15.9.4.3.
AIR-14 ADEC 11/14/2012 Page 13-29 in PSP section 13.9.4.1 “States that once a non-
attainment area meets the standards, the EPA will re-designate the
area as a “maintenance area”.
This brief statement is an oversimplification of the process required to
develop a maintenance plan for a previously designated
The text in Section 15.9.4.1 is designed to simply
summarize the types of attainment designation and not
detail the processes for developing each type of
designation or redesignation. The summary presented in
Section 15.9.4.1 is similar to the ADEC definition under 18
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nonattainment region and the process should be outlined to avoid
misunderstanding.” –pdf page 17
AAC 50.990(51).
AIR-15 ADEC 11/14/2012 Page 13-29 in PS section 13.9.4.2 “Lists fugitive particle matter
emissions from the handling and storage of raw materials and wind
erosion during construction to be quantified according to
methodologies specified in EPA’s Compilation of Air Pollutant
Emission Factors (AP-42) or similar source of emissions factors.
Particle should be particulate.” –pdf page 17
Section 15.9.4.2 reads “fugitive particulate matter”.
AIR-16 ADEC 11/14/2012 Page 13-29 in PSP section 13.9.4.2 “states if a state license is
required, air quality dispersion modeling may also be required and will
be performed consistent with 18 AAC 50 dispersion modeling
guidelines.
License should be permit.” –pdf page 18
Section 15.9.4.2 reads “state permit”.
AIR-17 ADEC 11/14/2012 Page 13-29 in PSP section 13.9.4.2 “States emissions from
construction equipment and related activities will be estimated for
comparison to appropriate state licensing criteria.
Secondary emissions do not count towards "potential to emit" per 40
CFR 51.166(b).” –pdf page 18
Although secondary emissions may not count toward
potential to emit for permitting, these emissions will be
addressed as part of the overall study of project effects.
Emissions from construction equipment will be estimated
per Section 15.9.4.2.
AIR-18 ADEC 11/14/2012 Page 13-30 in PSP section 13.9.4.2 “States if the Project generates
average daily traffic volumes that exceed a state mobile source
threshold for CO, PM10/PM2.5, or mobile source air toxics (MSATs)
analyses, then a mobile source evaluation may be required.
There are no mobile source thresholds in permitting.” –pdf page 18
Although secondary emissions may not count toward
potential to emit for permitting, these emissions will be
addressed as part of the overall study of project effects
(Section 15.9.4.2)
AIR-19 ADEC 11/14/2012 Page 13-31 in PSP section 13.9.7 “States existing monitoring data
may not be representative of the area and a program of air quality
monitoring would need to be implemented to gather baseline data.
There is no regulation that requires a program of air quality
monitoring to gather baseline data. What criteria would be used to
determine if baseline data is necessary?” –pdf page 18
AEA does not believe there is a need to conduct
background air quality monitoring at the site as there are
no major emission sources in the area (Section 15.9.2).
AIR-20 ADEC 11/14/2012 Pages 13-27 to 13-28 in PSP sections 13.9.1.1, 13.9.2, and 13.9.4
“contain multiple citations of Alaska Administrative Code Title 18,
Chapter 50, various Sections, but does not reference Alaska statutes.
Please cite the applicable Alaska Statutes in addition to the Alaska
Regulations.” –pdf page 18
The appropriate Alaska Statutes are cited in Section
15.9.1.1 and listed in the references for the study plan.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 490 December 2012
Probable Maximum Flood Study
Reference
Number Commenter Date Filed Comment or Study Request AEA’s Response
FLOOD-01 ADNR-DGGS 11/14/2012 Page 14-2, 14-3 in PSP section numbers 14.5.1.1 and 14.5.4.1 “Who
comprises the Board of Consultants and how are members
selected?“
–pdf page 14
Members of the Board of Consultants are selected
pursuant to Part 12, Subpart D of FERC’s regulations, 18
CFR 12.30 et seq. For the Susitna-Watana Hydroelctric
Project, FERC approved the following individuals as the
Board of Consultants: Dr. Alfred J Hendron, Jr., P.E.
(Geotechnical); Mr. Brian Alistair Forbes (Concrete); Ms.
Ellen Faulkner, P.E. (Hydrology); Mr. George Taylor
(Meteorologist); Mr. Joseph L. Ehasz, P.E. (General
Hydroelectric); and Dr. Yusof Ghanaat, P.E. (Structural).
FLOOD-02 ADNR-DGGS 11/14/2012 Page 14-4 in PSP section 14.5.4.1 “Will the results of the glacier
runoff study be included in determining the 100 year snowpack and
snow water equivalent?” –pdf page 14
The PMF study has very specific requirements that include
snow water equivalent by 1000-ft elevation band, by sub-
basin and by month. The PMF study also has its own
schedule needs. If timely and detailed snowpack results
are made available to us, they will be reviewed and
considered.
FLOOD-03 ADNR-DGGS 11/14/2012 Page 4-7 in PSP section 14.5.4.13 “Will the freeboard analysis be
conducted using initial construction parameters only or will it also be
calculated for a suite of reservoir sedimentation/infill scenarios post-
construction?” –pdf page 14
Reservoir sedimentation will be analyzed as part of the
Geomorphology Study (Section 6.5.4.8). AEA will
consider the sedimentation profile generated after 50
years of operation. However, based on sedimentation
patterns at other reservoirs, sedimentation is expected to
largely occur in the dead storage area of the reservoir,
with little effect on the freeboard volume.
FLOOD-04 ADNR-DGGS 11/14/2012 Page 14-7 in PSP section 14.5.4.13 "The study of freeboard will take
into account unusual circumstances." It would be useful to provide
one or more examples of what would be considered an unusual
circumstance.“–pdf page 14
Unusual circumstances could involve equipment failure
scenarios or unusual combined events such as wind from
an unusual but critical direction. These scenarios are yet
to be determined, but will be detailed in the PMF report.
FLOOD-05 ADNR-DGGS 11/14/2012 Page 14-8 in the PSP section 14.5.6 “The PMP/PMF anticipated
completion predates the anticipated completion of other portions of
the Study Plan such as geologic mapping. Will there be any effort to
update the flood model in 2014 with improved information from the
ongoing studies (this may refine estimated infiltration rates, include
longer stream gauge records and incorporate fluvial-geomorphic
findings). –pdf page 14
It is not anticipated that later completion of other portions
of the Study Plan will result in an update to the PMF study
in 2014. Analytically determined parameters are subject
to calibration in the PMF study. If critical information, such
as a rare flood, becomes available during 2013-2014, the
need to incorporate it into the PMF study will be revisited.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 491 December 2012
Site-Specific Seismic Hazard Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
SEIS-01 TU 11/14/2012 “The project site is near multiple active faults and the Proposed Study
Plan is inadequate for evaluating the potential seismic risk and project
stability. TU supports the U.S. Geological Survey’s comment that
nearby seismic features have not been sufficiently studied to
determine the credible risk of earthquake. The Proposed Study Plan
fails to adequately evaluate these risks.” –page 4
A thorough and complete Site-Specific Seismic Hazard
Study for the Susitna-Watana Project is underway and will
be used as input to develop seismic design criteria for the
site that are only just beginning (Section 16.6). These
studies will include seismic source characterization,
including paleoseismic studies of lineaments and faults,
improved seismic monitoring networks in the project area,
site-specific PSHA and ground motion evaluations, and an
assessment of reservoir triggered seismicity, and a
Probabilistic Site Hazard Analysis (PSHA) for the Susitna-
Watana site. Additional seismic monitoring stations are
being installed in the project area in conjunction with the
Alaska Earthquake Information Center to provide
increased monitoring and detection capabilities of any
local earthquakes and provide additional information for
use in understanding the seismic hazards in the project
area. The geologic, geophysical, and seismic network data
will all be used to provide thorough and complete
evaluations of seismic hazards for the project including
evaluation of the potential for reservoir triggered
seismicity.
SEIS-02 Ransy, Denis 11/14/2012 “Seismic studies must be intensive and complete. There are several
earthquake faults near the dam-site. Their proximity creates a very
high-risk environment for dam construction. The 2002 Denali Fault
Quake created lateral earth movements of 16-30 feet according to the
US Geological Survey finding reported 11/8/12 on Alaska News
Nightly. This quake caused damage throughout Interior Alaska.
Recent findings point to the possibility of a Deadman Fault, which
may be virtually at the dam-site. This must be determined with
absolute certainty; a fault at the dam itself would create unacceptable
dangers to population and property downstream. The presence of a
Deadman Fault would point to increased danger from reservoir-
induced seismicity. The weight of millions of gallons of water directly
on or very near a fault could spell disaster. This factor must be
included in any seismic study.” –paragraph 8
See AEA’s response to comment SEIS-1.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 492 December 2012
Site-Specific Seismic Hazard Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
SEIS-03 ADNR-DGGS 11/14/2012 “The Pass Creek fault, west of the dam should also be considered in
seismic hazards analysis. This fault is associated with a large (~3 m)
scarp that offsets latest Wisconsin-age glacial deposits. This fault is
an active structure capable of producing large ground motions at the
site. It is recommended that the independent consultant also consider
the Pass Creek fault in addition to other sources that have already
been described.” – PDF page 12
The Pass Creek crustal fault is within the 125-mile buffer
of the dam site, and therefore will be considered in the
preliminary and on-going seismic source characterization
and for site-specific ground motion evaluations of the
Watana Dam site (Section 16.6.3).
SEIS-04 ADNR-DGGS 11/14/2012 Page 14-9 in PSP section 14.6.1.1 “The components outlined are
adequate and represent state of the practice for assessing seismic
safety of dams. “ – PDF page 14
AEA appreciates ADNR-DGGS’s review and comment of
this study plan and agrees that it will appropriately assess
the seismic safety of the proposed Project.
SEIS-05 ADNR-DGGS 11/14/2012 Page 14-10 in PSP section 14.6.2 “The section clearly outlines the
previous studies conducted at the site except for the seismic hazards
study conducted by Fugro in Dec. 2011.” – PDF page 14
AEA appreciates the comment, and notes that Site-
Specific Seismic Hazard Study is on-going. AEA will
continue to collect and develop a more complete geologic
and seismic-tectonic information.
SEIS-06 ADNR-DGGS 11/14/2012 Page 14-10 in PSP section 14.6.2 “Example topics in the proposed
studies do not include assessment of the Pass Creek fault. This fault
should be considered. Additionally, probabilistic seismic hazards
maps (Wesson 2007) should be augmented with a site specific
ground motion assessment. “ – PDF page 14
See AEA’s response to comment SEIS-3.
AEA is proposing a deterministic and probabilistic seismic
hazard evaluation to update the seismic hazard studies
from the 1980s in order characterize the seismic sources,
to define site-specific earthquake ground motion
parameters, and to develop seismic design criteria for the
Project structures (Section 16.6.4.4).
SEIS-07 ADNR-DGGS 11/14/2012 Page 14-10 in PSP section 14.6.3 “The Pass Creek fault should be
added to the list of potential faults to study. Additionally, the relative
activity of the Talkeetna Thrust and other parallel faults mapped in
bedrock such as the Bull River fault, Broxson Gulch fault, and Broad
Pass fault should also be considered.” – PDF page 14-15
See AEA’s response to comment SEIS-3. In addition, all
of these faults are being considered in the evaluations of
potential seismic sources in the site region. The relative
level of activity and significance to site-specific ground
motion evaluations at the Susitna-Watana site is a factor
in determining the level of study accorded different
features within the region.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 1 Alaska Energy Authority
FERC Project No. 14241 Page 493 December 2012
Site-Specific Seismic Hazard Study
Reference Number Commenter Date Filed Comment or Study Request AEA’s Response
SEIS-08 ADNR-DGGS 11/14/2012 Page 14-11, 14-12 in PSP section 14.6.4.4 “Most of the proposed
work has already been performed by Fugro (Dec. 2011). A notable
exception is the conducting of geologic studies using the recently
acquired lidar data. These data should be evaluated with a
combination of field and office assessments.” – PDF page 15
The recently-acquired LiDAR and INSAR data in the
region is currently in review and initial desktop mapping
will be followed by field based recon, geologic mapping,
and subsurface investigations as dictated by the initial
studies (Section 16.6.4.4). Future studies will also include
an update to the seismic source characterization, site-
specific ground motion evaluations and PSHA.
SEIS-09 ADNR-DGGS 11/14/2012 Page 14-11 “Who comprises the Board of Consultants and how are
members selected? We recommend that a ADNR-DGGS geologist
be part of the Board of Consultants review panel for seismic hazard
studies.”
–pdf page 14
Members of the Board of Consultants are selected
pursuant to Part 12, Subpart D of FERC’s regulations, 18
CFR 12.30 et seq. For the Susitna-Watana Hydroelctric
Project, FERC approved the following individuals as the
Board of Consultants: Dr. Alfred J Hendron, Jr., P.E.
(Geotechnical); Mr. Brian Alistair Forbes (Concrete); Ms.
Ellen Faulkner, P.E. (Hydrology); Mr. George Taylor
(Meteorologist); Mr. Joseph L. Ehasz, P.E. (General
Hydroelectric); and Dr. Yusof Ghanaat, P.E. (Structural).
While a ADNR-DGGS geologist was not included on the
Board of Consultants, AEA welcomes the participation of
ADNR-DGGS to participate in the implementation of the
studies for the licensing of the Project.