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Susitna-Watana Hydroelectric Project Document
ARLIS Uniform Cover Page
Title:
Appendix 2, FERC-filed letters coded with comment identifiers
SuWa 78
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 78
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:
Pagination:
652 p. in various pagings
Related work(s):
Comments to:
Alaska Energy Authority. Proposed study plan (SuWa 82)
Appendix 2 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 2
FERC-filed Letters Coded with Comment Identifiers
December 2012
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 2 Alaska Energy Authority
FERC Project No. 14241 December 2012
Appendix Arrangement: Comment Letters in Appendix 2 are provided in the following order:
1. Federal Energy Regulatory Commission (FERC)
2. State of Alaska
3. United States Department of the Interior – National Park Service (NPS)
4. United States Department of the Interior – Fish and Wildlife Service (USFWS)
5. United States Department of Commerce – National Oceanic and Atmospheric Administration (NMFS)
6. United States Department of the Interior – Bureau of Land Management (BLM)
7. United States Environmental Protection Agency (EPA)
8. Cook Inlet Region, Inc. (CIRI)
9. Alaska Hydro Project (AHP), Alaska Survival (AS), Coalition for Susitna Dam Alternatives (CSDA)
10. Natural Resource Defense Council (NRDC)
11. Trout Unlimited (TU)
12. Chase Community Council (CCC)
13. Copper County Alliance (CCA)
14. The Center for Water Advocacy (CWA)
15. Talkeetna Community Council, Inc. (TCCI)
16. The Nature Conservancy (TNC)
17. Talkeetna Defense Fund (TDF)
18. Jennifer Barnett
19. Donnie Billington
20. Donnie Billington
21. Will Boardman
22. Greg Campbell
23. Shelly Campbell
24. Coalition for Susitna Dam Alternatives (CSDA)
25. Tony Crocetto
26. Davis B. Downey
27. Lara Gentzel
28. Sarah Kohe
29. Jen Latham
30. Becky Long
31. Brian Okonek
32. David and Sandra Porter
33. Denis Ransy
34. Mary L. Rachel
35. Cari Sayre
36. Douglas Smith
37. John Strasenburgh
38. Cathy Teich
39. Cathy Teich
40. Ellen Wolf
41. Ruth Wood
42. Katie Writer
43. Diane Ziegner
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 2 Alaska Energy Authority
FERC Project No. 14241 December 2012
Comment Code, RSP Study Title, and RSP Section Number Key:
Comment
Codei 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
DALL Dall’s Sheep Distribution and Abundance 10.7
LGCAR Distribution, Abundance, and Habitat Use by Large
Carnivores 10.8
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 2 Alaska Energy Authority
FERC Project No. 14241 December 2012
Comment
Codei RSP Study Title (Resource Area) RSP Section Number
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
i Code corresponds to Appendix 2 coding of comment letters.
FEDERAL ENERGY REGULATORY COMMISSION
WASHINGTON, D.C. 20426
November 14, 2012
OFFICE OF ENERGY PROJECTS
Project No. 14241-000—Alaska
Susitna-Watana Hydroelectric Project
Alaska Energy Authority
Wayne Dyok
Susitna-Watana Project Manager
Alaska Energy Authority
813 West Northern Lights Boulevard
Anchorage, AK 99503
Reference: Comments on Proposed Study Plan
Dear Mr. Dyok:
Commission staff’s comments on your proposed studies are included in the
attached schedule A and are based on our review of the Susitna-Watana Hydroelectric
Project proposed study plan filed on July 16, 2012,participation in various work group
meetings, and our review of the draft revised study plans posted on AEA’s web page.
To avoid future coordination and reporting concerns expressed by the National
Marine Fisheries Service in their October 31 filing, as well as other agency
representatives during the work group meetings, 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.
20121114-3024 FERC PDF (Unofficial) 11/14/2012
2If you have any questions, please contact David Turner at (502) 202-6091 or
david.turner@ferc.gov.
Sincerely,
Jennifer Hill, Chief
Northwest Branch
Division of Hydropower Licensing
Enclosures: Schedule A
cc: Mailing list
Public Files
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A-1
Schedule A
Comments on Proposed Study Plan
Unless stated otherwise, our comments are based on our review of the draft revised
studies posted on Alaska Energy Authority’s web page (http://www.susitna-
watanahydro.org/project/draft-revised-study-plan-status-listing/) as of November 7, 2012.
We first address some global concerns in our general comments, then turn to study-
specific needs. Please address our requests and comments in your revised study plan
(RSP), which must be filed with the Commission by December 14, 2012.
General Comments
Tracking Study Disagreements
Section 5.11(b)(4) of the Commission’s regulations states that your proposed study
plan (PSP) must include an explanation for why any requested studies are not adopted. In
your PSP, you state that agencies and other licensing participants made a total of 52
individual study requests. You also state that the PSP includes a proposal to undertake all
but one of the requested studies, with some alterations and adjustments. Therefore, you
contend that the overwhelming majority of the study requests are incorporated into the
PSP.
While it is true that the PSP includes studies that address most of the resource
areas that were identified in the study requests filed by agencies and other licensing
participants, there are numerous instances in which components of the study requests
were not adopted in the PSP, and you do not provide an explanation for why the study
components were not adopted. We provide the following examples of study components
that were not adopted in your PSP and no explanation as to why they were not adopted
was provided: (1) the Fish and Wildlife Service (FWS) requested that you analyze the
contribution of marine derived nutrients from non-salmon anadromous species, (2) FWS
requested that you characterize the use of biological flow cues to complete life-history
strategies, and (3) the National Marine Fisheries Service (NMFS) and FWS requested that
riverine habitat be characterized for the entire project area from the mouth to the dam site.
Section 5.13 (a) of the Commission’s regulations requires you to include
comments on the PSP and how you attempted to resolve disagreements regarding study
needs. This includes any components of the study requests that are not adopted in your
RSP. We frequently heard from stakeholders during the study meetings, primarily in the
aquatic working group, that it was not always possible to determine how a study request
component was addressed. To ensure that all differences in perceived study needs are
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identified and addressed, we recommend that your RSP clearly track all differences
between your study proposal and the requested studies, as well as any future comments
you receive on the draft RSP. Your filing must include an explanation of why any
components of the study requests are not adopted.
Adaptive Study Implementation
In multiple study plans, you propose to modify the methods or 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.
Flow-routing Model
Numerous study plans (e.g., Geomorphology, Fish and Aquatics Instream Flows,
Ice Processes, etc.) refer to development of a flow-routing model that, when completed,
will be used to determine the geographic scope (i.e., downstream extent) of several other
studies and modeling efforts. The flow-routing model is only vaguely defined and
referenced throughout various study plans. There is no specific study plan that describes
its implementation, a schedule for reporting on its results, or how or when such results
would inform or result in modifications to the other study plans. You suggest that, based
on the initial results of the flow-routing model, you may need to add additional transects
to improve its performance between river mile (RM) 184 and RM 75, and to possibly
extend the downstream extent of the model past RM 75.
It is important to define the flow-routing model and the downstream extent of the
flow-routing model because a number of studies are dependent on its results to inform
various aspects of their implementation (e.g., geographic scope, additional sampling areas
if the flow-routing model indicates that project effects would occur downstream of
proposed sampling areas). Therefore, please 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.
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Precedence for Multiple Models
Several studies (e.g., Fluvial Geomorphology Modeling below Watana Dam,
Geomorphology, Ice Processes in the Susitna River, Instream Flow, and Riparian
Instream Flow) discuss hydraulic, flow-routing, habitat-specific, and sediment-transport
models. Some of these studies describe the use of one-dimensional and two-dimensional
models. Because the focus of each study is different, it is possible that multiple models
would be used to assess conditions for a common reach of the river. Where this is the
case, please 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.
Study Framework and Relationships between Studies
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.
Your RSP should provide a clear description of the relationship between studies.
You provided flow charts depicting the interrelationships of the various studies.
However, it is still not always clear where information is coming from or how it will be
used in the various 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.
Reach and Habitat Stratification and Study Site Selection and Location
Your RSP should clearly describe the exact number, location, and spatial extent of
your proposed focus areas for each proposed study. In addition, the RSP should provide
justification for the number of proposed sites selected for detailed 2-D hydraulic
modeling and other intensive study elements. Please include criteria to be used for
selecting focus areas and study-specific rationale for co-locating sites.
Integrating 2012 Study Efforts into the Project Study Plan
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
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being incorporated into the RSP.
Water Quality
Baseline Water Quality (Section 5.5)
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.
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.
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.
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.
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.
Water Quality Modeling (Section 5.6)
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
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referred to a without project scenario as initial condition or existing condition.
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.
In section 5.6.4.8, please clarify what is meant by the statement: measuring additivity 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.
Section 5.6.6, Schedule, contains two different versions of the schematic titled
Interdependencies for Water Resource Studies. Please 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.
Mercury Assessment and Potential for Bioaccumulation (Section 5.7)
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…”
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.
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.
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Section 5.7.4.2,Collection and Analyses of Soil, Vegetation, Water, Sediment,
Sediment Pore Water, Avian, Terrestrial Furbearer, and Fish 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.
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.”
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.
GEOMORPHOLOGY
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.
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
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component 5 will be used to quantify total or usable habitat area under a range of flows as
part of the instream flow study.
INSTREAM FLOW
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 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.
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 fish habitat” in the reach.
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.
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 def ining the mainstem flow-routing model.
Presumably, the additional transects will be used to expand the model for the purpose of
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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 flow-
routing 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 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.
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.
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.
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).
Understanding the effects of load following on fish egg incubation, egg and alevin
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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
evaluated.
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 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.
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.
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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.
In section 8.5.4.6.1.5, you describe 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 your 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.
Riparian Instream Flow (Section 8.6)
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.
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.
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
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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.
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.
FISH AND AQUATIC RESOURCES
Fish Distribution and Abundance in the Upper Susitna River (Section 9.5), and
Middle and Lower Susitna River (Section 9.6)
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 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).
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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.
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 Fish Distribution and Abundance in the
Upper Susitna River (9.5) that includes the sampling frequency for each method.
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.
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.
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
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adopted in your study plan.
Salmon Escapement (Section 7.7)
In our May 31, 2012, study requests and comments, we requested that you include
in your PSP the specific methods, objectives, and timing for implementing your proposed
study of a system-wide Susitna River adult salmon escapement and run apportionment.1
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 Yetna River and the Susitna River, with two fish wheels deployed at each
capture site. You also propose to 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.
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:
(1) a description of what is meant by a commonly applied two-event, capture recapture
experiment;
(2) 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); and
(3) 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.
River Productivity (Section 9.8)
In section 9.8.4.1 of the River Productivity Study, you propose to review,
1 The preliminary study plan only included a placeholder that did not provide any
details on the proposed system-wide adult salmon escapement study.
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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.).
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 long-
term 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.
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. Your draft RSP states that detailed foraging parameters and bioenergetics model
parameters are available for these three species. Although fish capture methods, target
numbers, and sampling schedule are not provided in section 9.8.4.5, it is apparent that you
intend to capture individuals of each of these species to collect necessary data for model
input. However, during the October 25, 2012, fish and aquatics study meeting, 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). Please address whether sufficient
information is available on the alternative species’ foraging and bioenergetics parameters
or if model parameters would need to be developed. Please also describe the methods
you propose for capturing each fish species, the number of individuals required, sampling
site locations, and a sampling schedule.
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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.
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. Please include in your RSP the frequency and timing of fish and macroinvertebrate
sampling for this analysis.
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.
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.
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Characterization and Mapping of Aquatic Habitats (Section 9.9)
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.
A number of sections of the plan were incomplete or indicated that they will be
refined in the RSP. We expect these sections to be completed in the final RSP.
Aquatic Resources Study within the Access Alignment, Transmission Alignment,
and Construction Area (Section 7.13)
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.
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 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
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conducting the surveys.
Analysis of Fish Harvest in and Downstream of the Susitna-Watana Hydroelectric
Project Area (Section 7.15)
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.
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 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.
Cook Inlet Beluga Whale Study (Section 9.17)
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 the description of study
methods. Further, you say “[Li]ve-feed cameras (up to four, depending on feasibility)
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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. 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. 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.
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).
Please clarify whether video footage of beluga observations will be digitally
archived. Where you mention the potential for identifying individual animals, please
describe the previously collected photo-identification information available for the beluga
population.
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 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.
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. Describe any and all ongoing survey efforts by other
researchers and agencies and how your efforts will compare or build upon others, where
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you will collaborate with other agencies in sharing data, etc.
Acoustic monitoring was brought up as a potential monitoring method for beluga
(Bob Small, ADF&G, August 19, 2012, 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.
Wildlife Resources
Distribution and Abundance of Wolverines (Section 10.9)
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, ADFG stated that a single aerial survey would not be
sufficient to develop habitat associations for wolverines and the objective should be
eliminated. ADFG 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.
Bat Distribution and Habitat Use (Section 10.13)
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 ADFG 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. You do not propose to conduct
these efforts unless seasonal concentration areas such as roosting sites, maternity
colonies, or hibernacula are located in 2013 because you agree with ADFG that
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anticipated effects on these species are not expected to be great. You go 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. Your
statement of little adverse effects would suggest that this study is not needed.
Nonetheless, it is unclear how your efforts would identify important seasonal
concentration areas for further study in 2014 and why ADFG’s recommendations should
not be incorporated into the study plan now. Further, your revised study plan should
explain what would dictate “to the extent possible.”
Recreation and Aesthetic Resources
Recreation Resources Study (Section 12.5)
In section 12.5.1, General Description, in the second bullet, the first use of the
word “future” is redundant.
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.
You propose to identify and map trails based on aerial imagery, existing GIS
datasets, field identification, agency interviews, and 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.
The assessment of future recreation supply and demand does not appear to
integrate relevant socioeconomic data that will be gathered or developed from other
studies. The Study Interdependencies chart on page 12-51 illustrates this integration;
please describe how and when this integration will occur in the study methods. The
recreation demand analysis should also consider latent demand for new facilities or
opportunities that could result from development of the project. For example, a large new
reservoir accessible to the public could create new recreation demand (e.g., boating,
fishing, sightseeing) that is not otherwise apparent in existing data.
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
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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.
Aesthetics Resources Study (Section 12.6)
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.
River Recreation Flow and Access Study (Section 12.7)
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.
Socioeconomic and Transportation Resources
Regional Economic Evaluation Study (15.5)
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.
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
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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 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.
In addition, 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.
Social Conditions and Public Goods and Services Study (15.6)
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 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.
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.
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?
Transportation Resources Study (15.7)
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A-23
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.
Random Utility Model
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 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.
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Document Content(s)
P-14241-000Letter Dyok111.DOC.........................................1-25
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DEPARTMENT OF NATURAL RESOURCES
OFFICE OF PROJECT MANAGEMENT AND PERMITTING
SEAN PARNELL, GOVERNOR
14 November 2012
Ms. Kimberly Bose, Secretary
Federal Energy Regulatory Commission
888 First Street
Washington D.C. 20426
Subject: Comments on Proposed Study Plan and Scoping Document 2 for Susitna-Watana
Hydroelectric Project, FERC No. 14241
Dear Ms. Bose:
The State of Alaska comments on the Proposed Study Plan and Scoping Document 2 for the
Susitna-Watana Hydroelectric Project (Project No. 14241).
The State appreciates the 30-day time extension to 14 November 2012 for submittal of comments
on proposed study plan (PSP) dated 16 July 2012, and the delay of the comment deadline for the
forthcoming revised study plan (RSP) to 18 January 2012. Due to complexity of the issues and
the large number of proposed studies, the state supports the due diligence shown by Federal
Energy Regulatory Commission (FERC) in providing the time extensions for these reviews.
The State would also like to recognize the effort the Alaska Energy Authority (AEA) has
expended in holding several public technical work group meetings and providing site access in
order to assist the resource agencies and other stakeholders in understanding the PSP proposed
methodology and approach. Incorporating the feedback from these meetings, AEA was able to
further refine the PSP and post an updated PSP (referred to as an interim draft RSP) on the
Susitna-Watana Hydroelectric Project website shortly before the comment deadline.
While recognizing AEA had no obligation to produce an interim draft RSP, which is outside the
scope of the integrated licensing process (ILP), and acknowledging a review of the interim draft
RSP in any substantive manner would be challenging due to the limited time available prior to
the PSP comment deadline, the FERC Project Manager indicated that the resource agencies and
other stakeholders were welcome to submit comments on the interim draft RSP to FERC, even if
beyond the mandated PSP comment deadline. The state resource agencies would like to
commend FERC on this unique collaborative approach.
550 W. 7TH AVENUE, SUITE 1400
ANCHORAGE, ALASKA 99501
PH: (907) 269-8431 / FAX: (907) 334-8918
tom.crafford@alaska.gov
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As a practical matter, many of the state resource agency reviewers providing comments herein
have attended the technical work group meetings and have worked with AEA to discuss and
refine the PSP, leading to the updated interim draft RSP. The attached comments, while
referencing the PSP filed with FERC on 16 July 2002, which is the subject of this review period,
reflects the current level of knowledge of outstanding issues and acknowledgement of issues that
have been satisfactorily resolved.
The State of Alaska remains a strong proponent of timely decision-making and a collaborative
working relationship among state and federal agencies for the remainder of the EIS process, as
well as any subsequent permitting of the proposed project. We look forward to working with the
cooperating federal agencies toward that end.
Sincerely,
Tom Crafford, Director
Office of Project Management and Permitting
cc:
Daniel Sullivan, Commissioner, Department of Natural Resources
Cora Campbell, Commissioner, Department of Fish and Game
Larry Hartig, Commissioner, Department of Environmental Conservation
Joseph Balash, Deputy Commissioner, Department of Natural Resources
Ed Fogels, Deputy Commissioner, Department of Natural Resources
Kelly Hepler, Special Projects Coordinator, Department of Fish and Game
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The Alaska Departments of Natural Resources (ADNR), Environmental Conservation (ADEC),
and Fish and Game (ADFG) provide the following comments on the Proposed Study Plan (PSP)
and Scoping Document 2 (SD2) for the Susitna-Watana Hydroelectric Project (FERC No.
14241).
I. ALASKA DEPARTMENT OF NATURAL RESOURCES
DIVISION OF PARKS AND OUTDOOR RECREATION
General Comments
The Division of Parks and Outdoor Recreation (DPOR) has a vested interest in the recreation and
socioeconomic research being conducted by the Susitna-Watana Hydroelectric Project and
requests to be included in the distribution list for the relevant documents and data being
produced by the project. It is further requested the project planners consult directly with DPOR
in regards to Aesthetic and Recreational Resource study plans and activities.
At this time many of the studies occurring in or near the Denali State Park are taking place on the
eastern boundary of the park, along the Susitna River. DPOR has issued permits for studies
associated with hydrology and fisheries. A wide variety of recreational activities occur in the
Denali State Park and the DPOR offices will be monitoring the project closely to ensure that
studies related to hydro research do not displace recreational use in the park.
Comments regarding the Proposed Study Plan
Identified Project Area
The following comments are submitted regarding the identified project area:
1. Denali State Park lands have been identified and included in the project area.
2. The Susitna River flows for approximately 21 miles through the Denali State Park on its
east boundary.
3. Gold Creek flows into the Denali State Park.
Proposed Transmission and Road Corridors
The following comments are submitted regarding the concerns DPOR has with the transmission
and road corridor study areas:
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
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implications of this access are of concern to the Division of Parks and Outdoor
Recreation.
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.
The Division of Parks and Outdoor Recreation requests the Susitna-Watana Hydroelectric
Project mitigate to the maximum extent possible these impacts to the Denali State Park.
DIVISION OF FORESTRY
Comments regarding the Proposed Study Plan
Impoundment Area
The Division of Forestry 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 ensure salvage is
undertaken. The Division of Forestry is available to offer assistance with this assessment of the
impoundment area.
OFFICE OF HISTORY AND ARCHEOLOGY
Comments regarding the Proposed Study Plan
Section 11 Cultural and Paleontological Resources
One of the deficiencies of the 1980’s Susitna Project archaeological research was the lack of
attention to stratigraphic markers for guiding archaeological field testing.
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 near known or projected locations
where caribou regularly cross the Susitna River.
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
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with advanced training who can guide crew members on the soils and tephras that they will
encounter.
Benefit: Verifiable interpretation and repeatability of data.
A second deficiency of the 1980’s research was the lack of coupling of the archaeological data
with paleoenvironmental data, leaving the archaeological data largely un-interpreted, and
generating little explanation of lifeways or human-environmental interaction.
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.
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.
Probability Modeling
Archaeological site probability modeling is very useful for making the best use of resources
when surveying large tracts of land. This modeling should explicitly attempt to address how past
humans may have used of the region at different times and with different resources. Hypothesis
testing should be employed, coupling the archaeological and paleoenvironmental data, to
generate testable locations of where people may have lived at different times, and to get at how
people lived in the past and why they utilized the locations on the landscape that they did. It is
hoped that the survey planners stay abreast of the biological, ethnographic and other studies
being conducted concurrently that can provide data to refine these exploratory and explanatory
models.
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. Crew chiefs need to know what
makes an area high probability in order to better plan survey of that area.
Probability modeling is a commonly used tool for finding the kinds of archaeological sites that
we are already aware of. But in Alaskan archaeology we are regularly finding site types that we
previously were unaware of: ice patches in alpine areas utilized by prehistoric caribou hunters;
raised beach terraces in southeast Alaska with mid or early Holocene archaeological sites, etc.
Consequently, 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.
Cultural Resources Study Planning
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
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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’.
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.”
Additional Comments and Edits
Additional comments and edits on Section 11 Cultural and Paleontological Resources are
correlated in Table 1 to the specific locations in the PSP.
Table 1 Additional Comment for Section 11 Cultural and Paleontological Resources
Section 11.0 Cultural and Paleontological Resources
Sub-Section Comment
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…”
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.
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.
Section 11.5 Cultural Resources Study
Sub-Section Comment
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
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inventory cultural resources within the APE (36 CFR 800.4[b]), evaluate the National
Register eligibility of 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.
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.
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.
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.
Section 11.6 Paleontological Resources Study
Sub-Section Comment
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.
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DIVISION OF MINING, LAND AND WATER
Comments regarding the Scoping Document 2
Sections 4.2.6 Recreation Resources and Land Use and 4.2.9 Socioeconomic Resources
Two project-specific resource issues identified in the FERC Scoping Document 2 as having
potential for substantial environmental effects were: 1) Effects of altered hydrologic regimes and
ice cover on timing and extent of river access and navigation within and downstream of the
reservoir, and 2) Effects of altered flows and ice conditions on river-dependent transportation
along or across the Susitna River.
To address these issues, the Division of Mining, Land and Water (DMLW) recommends a
detailed analyses of the altered hydrologic regimes, ice cover, and ice safety be conducted for the
Lower and Middle Susitna River from tide water to the bottom of Devils Canyon. This area is
currently, and has historically, been utilized as a highway of commerce. The BLM determined
the Susitna River navigable to Indian River based on steamship use.
Currently the Susitna River is navigated from tide water to the base of Devils Canyon for
commercial purposes by a number of guides and tour operators. In the lower river, lodge owners
and operators as well as fishing and hunting guides utilize the river to make their living. Boats
and ice roads are utilized on the lower Susitna River from multiple locations such as Deshka
Landing and Susitna Landing to transport fuel, supplies and customers for commercial lodges,
homesteads, and recreational cabins.
The potential impacts of flow pulsing and other flow fluctuations on ice formation, layering and
overflow to ice roads should be analyzed and solutions proposed prior to construction. 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.
Section 5.0 Proposed Studies
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 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.
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Comments regarding the Proposed Study Plan
Fluvial Geomorphology
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.
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)?
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?
Instream Flow, Hydrology, Groundwater and Glacial Runoff
The following comments are submitted regarding Surface Water Hydrology:
1. Most surface water hydrologic aspects are covered by the plan, with a well designed
network of streamflow measurements to facilitate understanding the drainage system.
2. There are no large lakes in the project 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
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.
3. 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.
4. 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.
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The following comments are submitted regarding Groundwater Hydrology:
1. There is a plan in place to drill shallow groundwater monitoring wells and to attempt to
relocate the prior set of observation wells that were drilled during the 1980’s study; so,
the shallow groundwater, which may be locally confined, has been addressed.
2. 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.
3. 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 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.
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.
Additional Comments and Edits
Additional comments from the Division of Mining, Land and Water on Sections 5.0 Water
Resources and 13.7 Transpiration Resources are correlated in Table 2 to the page locations in the
PSP.
Table 2 Comments for Sections 5.0 Water Resources and 13.7 Transportation Resources
Section 5.0 Water Resources Study
Sub-Section Comment
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
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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.
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.
13.7 Transportation Resources Study
Sub-Section Comment
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.
13.7.3 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.
The US Supreme Court in PPL Montana LLC v Montana Decision upheld and
supported the use of recreational use of a water body as a valid test for navigability.
Therefore recreational use of the Susitna River within the entire length of the
impacted portion of the Susitna River should be evaluated.
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
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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.
DIVISION OF GEOLOGICAL & GEOPHYSICAL SURVEYS
Comments regarding the Scoping Document 2
Sections 2.2 Geology, Seismicity, and Dam Failure
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.
Comments regarding the Proposed Study Plan
The Division of Geological & Geophysical Surveys (DGGS) has reviewed Sections 4.5, 5.8,
5.11, 11.6, 14.5, and 14.6. DGGS comments and edits are correlated in Table 3.
Table 3 Comments for Sections 4, 5, 11, and 14.
Section 4.5 Geology and Soils Characterization Study
Sub-Section Comment
4.5 Page 4-4 Necessary laboratory tests of physical and strength properties of rock
and soil should include solubility testing of component minerals.
Section 5.8 Geomorphology Study
Comment
5.8.1 Page 5-58 It is unclear whether due consideration is being given to the Upper
River and the dam's potential impact on geomorphologic conditions there.
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5.8.4.3.3 Page 5-69 Will there be an opportunity to comment on the Geomorphology
report?
5.8.4.6.1 Page 5-77 Will the potential impact of wildfires on sediment load be factored into
this study?
5.8.4.8.2.3 Page 5-88 Proper terminology would be 'thawing of permafrost', not 'melting of
permafrost.'
5.8.4.10.2 Pages 5-93 to 5-94 Suggest including an evaluation of potential icings (aufeis) at
stream crossing locations.
Section 5.11 Glacial and Runoff Changes Study
Comment
5.11.1.1 Page 5-147 P3 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.
5.11.2.1 Page 5-148 P2Definition 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').
5.11.2.1 Page 5-148 P2 Reference needed for statement "Alaska glaciers with the most
rapid loss are those terminating in sea water or lakes."
5.11.2.3 Page 5-149 P1 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.
5.11.9 Page 5-159 13 Fig. 5.11-1 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.
5.11.9 Page 5-160 14 Fig. 5.11-3 Suggest labeling Susitna Glacier
5.11.9 Page 5-161 15 Fig. 5.11-5 Caption should read "Mean annual temperature and
total annual precipitation at Talkeetna…"
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Section 11.6 Paleontological Resources Study
Comment
11.6.2 Page 11-17 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…"
Section 14.5 Probable Maximum Flood (PMP) Study
Comment
14.5.1.1,
14.5.4.1
Page 14-2, 14-3 Who comprises the Board of Consultants and how are members
selected?
14.5.4.3 Page 14-4 Will the results of the glacier runoff study be included in determining
the 100 year snowpack and snow water equivalent?
14.5.4.13 Page 4-7 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?
14.5.4.13 Page 14-7 "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.
14.5.6 Page 14-8 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).
Section 14.6 Site Specific Seismic Hazard Evaluation Study
Sub-Section Comment
14.6.1.1 Page 14-9 The components outlined are adequate and represent state of the
practice for assessing seismic safety of dams.
14.6.2 Page 14-10 The section clearly outlines the previous studies conducted at the site
except for the seismic hazards study conducted by Fugro in Dec. 2011.
14.6.2 Page 14-10 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.
14.6.3 Page 14-10 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
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Broad Pass fault should also be considered.
14.6.4.2 Page 14-11 Who comprises the Board of Consultants and how are members
selected? We recommend that a DNR-DGGS geologist be part of the Board of
Consultants review panel for seismic hazard studies
14.6.4.4 Page 14-11, 14-12 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.
II. ALASKA DEPARTMENTOF ENVIRONMENTAL CONSERVATION
DIVISION OF WATER
General Comments
The ADEC Division of Water Quality will review the SAP/QAPP when it is published.
Comments regarding the Proposed Study Plan
The Division of Water has reviewed Section 5.5 of the Proposed Study Plan (PSP) dated 16 July
2012 and submits the following comments in Table 4 which have been correlated to the specific
location in the PSP.
Table 4 Section 5.5 Baseline Water Quality Study Comments
Section 5.5 Baseline Water Quality Study
Sub-Section Comment
5.5.4.3.1 Page 5-14 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.”
DIVISION OF AIR QUALITY
Comments regarding the Proposed Study Plan
The Division of Air Quality has reviewed Section 13.9 and submits the following comments in
Table 5 which have been correlated to the specific location in the PSP.
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Table 5 Section 13.9 Air Quality Study Comments
Section 13.9 Air Quality Study
Sub-Section Comment
13.9.1.1 Page 13-27 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.
13.9.2 Pages 13-27 to 13-28 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.
13.9.2 Page 13-28 There are some limited data available from a site in Denali National Park.
There are two Denali monitoring sites. To which site is this statement referring?
13.9.2 13-28A table comparing the Project emission with Without-Project alternative
emissions will be generated.
Also include in table current emissions.
13.9.2 Page 13-28 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?
13.9.2
Page 13-28 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).
13.9.2
Page 13-28 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.
13.9.2
Page 13-28 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.
13.9.4
Page 13-28 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
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Section 13.9 Air Quality Study
Sub-Section Comment
http://www.susitna-watanahydro.org/project/project-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.
13.9.4
Page 13-29 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?
13.9.4
Page 13-29 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.
13.9.4.1 Page 13-29 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 nonattainment region and the
process should be outlined to avoid misunderstanding.
13.9.4.2 Page 13-29 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.
13.9.4.2 Page 13-29 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
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Section 13.9 Air Quality Study
Sub-Section Comment
modeling guidelines.
License should be permit.
13.9.4.2 Page 13-29 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).
13.9.4.2 Page 13-30 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.
13.9.7 Page 13-31 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?
13.9.1.1
13.9.2
13.9.4
Pages 13-27 to 13-28 contains 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.
III. ALASKA DEPARTMENT OF FISH AND GAME
To the best of our abilities, the 29 October 2012 draft interim Revised Study Plans were
reviewed but more time will be needed to fully assess. Consequently, most of the comments
reference the Proposed Study Plan and include preliminary comments on the recent Revised
Study Plans when possible.
General Comments
While portions of the study plans have been developed according to criteria identified in 18 CFR
5.11, other parts of these plans lack sufficient specificity and detail. Following are general
comments.
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
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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.
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.
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.
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.
Comments regarding the Proposed Study Plan
Section 5.5 Baseline Water Quality Study
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 project lead.
Information is needed on the availability of the “Sampling and Analysis Plan” and the
“Quality Assurance Project Plan”.
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.
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.
Section 5.7 Groundwater-Related Aquatic Habitat Study
We support the goals and general approach of the groundwater study. Information collected
during this study and incorporated with other related studies will help to evaluate project effects
on aquatic and terrestrial resources. Following are additional information needs.
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
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investigation is needed and if it is determined feasible, how additional thermal imaging data
will be collected and calibrated.
Dissolved oxygen should also be measured as a parameter for HSC and HSI development.
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.
Section 6.5 Fish and Aquatics Instream Flow Study
We support the goal to provide quantitative indices of existing aquatic habitats and resources that
will enable an evaluation of the effects of alternative project operational scenarios. We also
support close coordination and integration with related studies to provide a comprehensive
evaluation.
Following is a list of information needs and comments.
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.
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.
Information is needed on flow ranges that will be collected to evaluate flow-habitat
relationships for each modeling approach.
Information is needed on criteria that will be used to identify cover types and substrate sizes.
For PHABSIM and similar transect-based methods, will transects be hydraulically
independent, dependent or a combination and accordingly, what water surface elevation
models and composite suitability index will be used?
What criteria will be used to select and weight transects used to provide information for
habitat-flow models?
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.)?
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
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inventory data scheduled to be collected this year and summarized according to the above
classification system for future decision-making.
How will the data be aggregated from the different models to evaluate single flow
recommendations?
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.
Information is needed on equipment that will be used and calibration protocols.
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?
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.
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?
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.
Intergravel, over-winter temperature monitoring of redds should be expanded to include
measurements of dissolved oxygen.
Fish Stranding and Trapping – an evaluation of fish stranding and trapping is needed.
Stranding typically involves the beaching of fish on low gradient shorelines as a result of
declining river stage. Salmonid stranding associated with hydropower operations has been
widely documented (Hunter 1992 provides a list citations). Trapping is the isolation of fish
in pockets of water with no access to the free-flowing surface water (Hunter 1992). The
evaluation should include, at minimum, the following information:
1. 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.
2. 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
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at hourly time increments to assess stranding and trapping potential. Simulation
should include existing and alternative operation scenarios under normal, dry and wet
hydrologic conditions. Factors that may contribute to stranding and/or trapping
should be considered including: aquatic species/lifestage, cover, duration of a
stranding/trapping event, and time of year.
3. 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.
Bauersfeld, K. 1978. Stranding of juvenile salmon by flow reductions at Mayfield Dam on
the Cowlitz River. WDF, Olympia, WA, Tech. Rep. 36:36 pp.
Beck Associates, R.W. 1989. Skagit River salmon and steelhead fry stranding studies.
Prepared by R.W. Beck Associates for the Seattle City Light Environmental Affairs
Division, March 1989. Seattle, WA 300 pp.
Hunter, M.A. 1992. Hydropower Flow Fluctuations and Salmonids: A Review of the
Biological Effects, Mechanical Causes, and Options for Mitigation. State of
Washington Tech. Rep. 119. 58 pp.
Section 7.5 Study of Fish Distribution and Abundance in the Upper Susitna River
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.
7.5.1.1. Study Goals and Objectives (Page 7-9 & 7-10)
“The overarching goal of this study is to characterize the current distribution, relative abundance,
run timing, and life history of resident and non-salmon anadromous species (e.g., Bering cisco,
Dolly Varden, humpback whitefish, northern pike, and Pacific lamprey), and freshwater rearing
life stages of anadromous fish (fry and juveniles) in the Susitna River above Devils Canyon.”
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?mode=awc
Baseline metals and mercury assessment are not the same. What is being sampled and to
what standards? What metals are being studied?
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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.
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. Documentation of all fish collected during sampling shall include species and length.
Species listing in this section does not match species list on Table 7.5.9. Update table with
current information.
7.5.2. Existing Information and Need for Additional Information (Page 7-11)
“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.
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.
“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.
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 nets be deployed? What is the targeted time
duration for each set.
Electrofishing (Page 7-13)
“Conduct monthly, boat-mounted, barge, or backpack electrofishing surveys using standardized
transects.”
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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.
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.
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.
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.
“In all cases the electrofishing unit will be operated and configured with settings consistent with
guidelines established by ADF&G.” (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.
Field protocols and site selection/justification is needed. Length of transects, type of
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.
Trot Lines (Page 7-14)
“Trot line sampling was one of the more frequently used methods during the 1980s and was the
primary method for capturing burbot.”
Trot line sampling is terminal, recommend use of alternative, non-lethal methods of burbot
sampling whenever possible.
More information needed on site selection and rationale.
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.
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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.
Minnow Traps (Page 7-14)
Salmon eggs are required to be sterilized or disinfected in iodine solution under conditions of
ADF&G sampling permits.
When and where will minnow traps be deployed and how will areas for deployment be
selected?
Winter deployment of minnow traps should be considered.
Snorkeling (Page 7-14)
“Two experienced biologists will conduct snorkel surveys along standardized transects in clear
water areas during both day and night during each field survey effort.”
Will two or one biologist snorkel during each snorkeling survey event?
What is the sampling schedule? When? Seasons? Site selection criteria/rational needed.
Will block nets be used?
Fyke/Hoop Nets (Page 7-15)
What is the mesh size, hoop size, number of hoops, length of nets, etc.?
“The nets will be operated continuously for a two-day period.”
Is this continued sampling or a single event? What time of year? How many sampling
events? List protocols.
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?
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.
Will different substrate types be sampled? Identify geomorphic areas to be sampled.
Will sampling include all time periods including daylight, twilight and periods of darkness?
Identify protocols.
Outmigrant Trap (Page 7-15)
Identify if traps will be manned during deployment.
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DIDSON and Video Cameras (Page 7-15)
Recommend that these cameras be used to identify burbot spawning in these areas.
Identify camera locations.
Location of all video and DIDSON surveys should be located by GPS and identified on aerial
photos and project maps.
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?
“Tissue or whole fish samples will also be collected in the mainstem Susitna River for
assessment of metals concentrations (Objective 4) (see Mercury Assessment and Potential for
Bioaccumulation Study, Section 5.12).”
Goals for assessment of baseline metal studies and mercury studies may be vastly different
and require different age classes.
Due to subsistence uses of whole fish, whole fish samples should be processed.
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..
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.
The likelihood of unintentional human consumption of PIT tags needs to be addressed.
Section 7.6 Study of Fish Distribution and Abundance in the Middle and Lower Susitna
River
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.
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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.html?mode=awc
Identify target species
Section Is goal #1 for juveniles only?
Section 7.6.4.1.2. Outmigrant Traps (Page 7-27)
Identify locations of outmigrant traps and if traps will be manned during deployment.
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?
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.
Section 7.6.4.2.1. Radiotelemetry (Page 7-27)
“Radio transmitters will be surgically implanted in up to 10 fish of sufficient body size of each
species from five habitat types in the middle and lower river.”
Identify species to be tagged.
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?
Section 7.7.4.1.1 Fish Capture, Page 7-36
Removing fishwheels at Curry in the first week of September likely misses a substantial
portion of the coho and chum runs. Should consider operating fishwheels through September
into October.
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Section 7.8 River Productivity Study
Overall, more information needed on sampling methodology.
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.
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.
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.
Section 7.8.4.2.2 Benthic Algae Sampling
Describe the methods that will be used for sampling and analysis.
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.).
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?
What sample preservation will be used? Need to consider prey condition after flushing. To
what level of taxonomic resolution will samples be identified?
Section 7.8.4.9 Macroinvertebrate Colonization
What is the artificial substrate material and likelihood it will influence colonization results?
Section 7.17 Cook Inlet Beluga Whale Study
Three objectives have been identified for this study:
1. Document the presence of all marine mammals in the Susitna River delta, focusing on Cook
Inlet Beluga whales (CIBW) distribution within Type 1 critical habitat;
2. Determine marine mammal utilization of the Susitna River, focusing on the upstream extent of
CIBWs; and
3. Evaluate the relationships between potential hydropower-related changes in the lower Susitna
River, CIBW in-river movements, and CIBW prey availability.
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Section 7.17.4 Study Methods
The basic approach to the draft proposed CIBW study plan is to obtain additional information on
CIBW distribution and group size during the months of open-water. Other studies will gain
information on some open-water period prey species; i.e., eulachon and salmon.
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.
Section 7.17.4.1 Document CIBW and other Marine Mammal Presence within Susitna River
Delta (Page 155 – 156)
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.
Section 7.17.4.1 describes the proposed methods using video and still cameras to determine the
upstream extent of CIBWs in the Susitna River. Our preferred approach is to use satellite
telemetry backed up with Passive acoustic monitoring (PAM). Satellite tags will allow
estimation of the proportion of time individuals are using the Susitna as opposed to other areas.
This will complement the other methods efforts to estimate spatial extent and total amount of use
of the Susitna. Those efforts should include PAM for the following reasons:
The proposed methodology (video and still cameras) will limit data collection to the day light
hours, and periods of good visibility (i.e., not during heavy rain or fog). 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.
Determining if project-induced changes in prey distribution and prey habitat will affect
CIBW is problematic when only knowing the distributions of CIBW and their prey.
Information on when and where belugas are foraging, which can be obtained through PAM,
will increase the ability to determine project-induced changes. CIBW foraging behavior is
extremely difficult to identify through visual methods due to the turbidity of the water in
Upper CI.
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When visual and PAM methodologies are used concurrently at the same locations, acoustic
behavioral information (e.g., foraging) from those locations can be applied to acoustic
datasets from areas where no visual observations are collected.
Substantial detail is provided on video data collection, including behavior logs and group
counts, yet the rationale for this level of detail to the primary objective of the study is not
clear. Substantial costs will be incurred to complete the processing of large amounts of video
and still imagery collected. PAM should be considered an alternative to reduce costs and
obtain results more quickly and consistently (e.g. continuous sampling independently of
weather and daylight). Specifically, existing software that has been used in similar river
environments within Cook Inlet (i.e., Eagle River, Knik Arm) successfully detected beluga
whales and provided automatically processed data, and semi-automated analysis methods
have been successful at sites near Beluga River and the within the Little Susitna River.
Further, based on visual vs. acoustic comparisons in Eagle River, an index to relative
abundance based on acoustic data of CIBW was established. A similar index could be
established for the Susitna Delta, and be applied to acoustic data in areas where visual data
are not collected.
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.
Section 8.5 Study of Distribution, Abundance, Productivity, and Survival of Moose
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.
The interim draft RSP appears to adequately address concerns with the moose study plan.
Section 8.6 Study of Distribution, Abundance, Movements, and Productivity of Caribou
ADF&G Division of Wildlife Conservation (DWC) proposed this study and intends to take
responsibility for implementation. Except as noted below, the interim draft RSP appears to
adequately address concerns with the caribou study plan.
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.
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Section 8.7 Study of Distribution, Abundance, and Habitat Use of Dall’s Sheep
DWC agreed to conduct Dall’s sheep surveys of suitable sheep habitat within GMU 13E
south of the Denali highway and east of the Park’s highway. ADF&G submitted a revised
draft study plan that describes this work.
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.
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.
Section 8.8 Study of Distribution, Abundance, and Habitat Use by Large Carnivores
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.
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 8.9 Study of Distribution and Abundance of Wolverines
DWC agreed to conduct a Sample-Unit Probability Estimator (SUPE) survey for wolverine.
A study plan has been submitted that deals with the issues identified in the interim draft RSP
consultation table version 10/15/2012.
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.
The recently released interim draft RSP for Wolverines appears to adequately incorporate
these changes.
Section 8.10 Study of Terrestrial Furbearer Abundance and Habitat Use
DWC supports this project intended to assess abundance of coyote, red fox, lynx and marten
with modifications to address concerns expressed here.
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)
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mentioned in the PSP objectives. Similarly, the kind of snowshoe hare sign to be quantified
in objective 4 was specified as pellet counts.
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.
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.
The interim draft RSP includes more details describing the proposed sampling design and the
statistical analysis to address concerns about population closure and heterogeneity. DWC is
encouraged to see these changes.
Section 8.11. Study of Aquatic Furbearer Abundance and Habitat Use
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.
Section 8.12. Study of Species Composition and Habitat Use of Small Mammals
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.
Section 8.13. Study of Distribution and Habitat Use of Little Brown Bat
The specific objectives of the bat baseline study are to:
1. Assess the occurrence of little brown bats and the distribution of habitats used by bats within
the impoundment zone and infrastructure areas for the Project;
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2. Review geologic and topographic data for potential roosting and hibernacula sites; and
3. Examine human-made structures (bridges and buildings) for potential roosting or
hibernacula.
Flooding is biggest threat to hibernacula and maternity colonies. Timing of inundation could
affect level of loss and therefore any necessary mitigation.
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.
Locate any potential human-made structures within the inundation zone that could serve as
maternity colonies or hibernacula.
Document level of use for any maternity colonies or hibernacula identified.
Section 8.14 Waterbird Migration, Breeding, and Habitat Study
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).
DWC consulted with AEA and the USFWS and the interim draft RSP appears to adequately
address concerns discussed during consultation.
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.
Section 8.16. Breeding Survey Study of Landbirds and Shorebirds
DWC has previously commented that “distance estimation techniques suggested have been
recently shown to produce very problematic density estimates (Alldredge et al. 2007a, Alldredge
et al. 2008, Efford et al. 2009). Detectability is notoriously difficult with auditory surveys. At a
minimum a double count observer method should be employed. Differences in auditory distance
estimation can still lead to profoundly unstable results (Alldredge et al. 2007b). Despite these
concerns, the protocols should be compatible with Alaska Landbird Monitoring System (ALMS),
and the data should be made available to USGS for inclusion in ALMS for inventory and habitat
associations after completion.”
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To deal most effectively with these concerns, we suggest:
1. Establishing 3 – 4 or more distance bands instead of requiring observers to estimate actual
distances.
2. Observers must be trained, tested and prequalified for species identification and distance
before going afield.
3. 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,
Alldredge, M. W., T. R. Simons, K. H. Pollock. 2007. A Field Evaluation of Distance
Measurement Error in Auditory Avian Point Count Surveys. The Journal of
Wildlife Management. 71(8).
Alldredge, M. W., T. R. Simons, K. H. Pollock, and K. Pacifici. 2007. A field evaluation
of the time-of detection method to estimate population size and density for aural
avian point counts. Avian Conservation and Ecology - Écologie et conservation
des oiseaux 2(2): 13. [online] URL: http://www.ace-eco.org/vol2/iss2/art13/
Alldredge, M.W., K. Pacifici, T.R. Simons and K. H. Pollock. 2008. Blackwell
Publishing Ltd. A novel field evaluation of the effectiveness of distance and
independent observer sampling to estimate aural avian detection probabilities.
Journal of Applied Ecology 45: 1349–1356.
Efford, M.G. and D.K. Dawson. 2009. Effect of Distance-related Heterogeneity on
Population Size Estimates from Point Counts. The Auk 126(1):100–111.
Kessel, B., S. O. MacDonald, D. D. Gibson, B. A. Cooper, and B. A. Anderson. 1982.
Susitna Hydroelectric Project environmental studies, Phase I final report—
Subtask 7.11: Birds and non-game mammals. Report prepared by University of
Alaska Museum, Fairbanks, and Terrestrial Environmental Specialists, Inc.,
Phoenix, NY for Alaska Power Authority, Anchorage. 149 pp.
Section 8.16.4 Study Methods (Page 8-95)
DWC supports 2 sampling periods and 2 years of sampling as called for in plan.
Need specific surveys to inventory shorebirds and cavity nesters in addition to raptors
and water birds as proposed.
Section 8.18 Study of Distribution and Habitat Use of Wood Frogs
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.
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Section 10. Recreation and Aesthetic Resources
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.
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.
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.
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.
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.
Alaska Department of Fish and Game, 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.
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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 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. Alaska Department of
Fish and Game, 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.
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.
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 of
travel? Please explain in subsequent detailed study plan. The ARSP study plan (noted above)
may provide useful background for sub-group identification.
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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.
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.
This concludes the current SD2 and PSP comments from the State of Alaska.
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United States Department of the Interior NATIONAL PARK SERVICE IN RLI'I Y RH1:/{ '10: L7425 (AKRO-EPC) AI:"ka Rc 1011 :!.JO We'IS'" AWIIIIC, Room 114 Allciwr,lgc, Ala.ka 99S0 I VIA ELECTRONIC MAIL: NO HARD COpy TO FOLLOW (FERC eFile P-14241-(00) Kimberly D. Bose Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C. 20426 NOV 092012 Subjel:t: General and Study-spel:ific CommenLS on the Draft Revised 2013-14 Study Plans (DRSP) 10.5 (Recreation Resources), 10.6 (Aesthetics Resources), and 10.7 (River Recreation Flow and Access) for the Susitna-Watana Hydroelectric Project (P-14241), Susitna River, Matanuska-Susitna Borough, Alaska Dem' Sel:retary Bose: The National Park Service (NPS), Alaska Region offers the following comments in response to the Federal Energy Regulatory Commission's (FERC) Notice of Soliciting Comments on the 2013-14 Proposed Study Plans (PSP). The NPS Hydropower Recreation Assistance program consults with license applicants and stakeholders providing technical assistance in assessing impacts on public recreational resources during the FERC licensing process. The program draws its authority from the Federal Power Ac"t and technical assistance provisions of the Outdoor Recreation Act of 1962, the Wild and Scenic Rivers Act of 1968, and the National Trails System Act of 1968. General Comments To date, NPS has been fully engaged with the Alaska Energy Authority (AEA) and their consultanLs. Our comments build on the prior comments and engagement by NPS in this process. We have commented on the Prelimimu'y Permit Application and Pre-Application Document (PAD), submitted detailed study requests; and examined numerous preliminary study plans, induding the PSPs and three DRSPs. We arc encouraged that many of our comments and recommendations have been considered and adopted. and arc confident that the consultant team chosen by AEA (URS, Oasis-ERM, and the McDowell Group) possesses the competence, cooperative spirit, and energy needed to ensure successful planning and implementation of the recreation and aesthetic resource studies.
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In the area of Aesthetic Resources, we are supportive of the current, progressive approach being taken by AEA's consultant, URS, in using an expanded/modified version ofBLM's basic Visual Resources Management method. URS's presentation during the October 3, 2012 work group meeting was highly informative and we look forward to future collaboration on this study. To aid stakeholders and FERC in assessing progress towards agreement on the scope, design and execution of the project's recreation and aesthetics studies, AEA and its consultant team have developed a table outlining issues we and other stakeholders have raised and AEA's response. This table -Table 12.4-1 of the Recreation and Aesthetics DRSP -is a very helpful tool in support of our mutual interest in resolving outstanding study plan issues. We appreciate the work involved in producing this table, and agree with many of the applicant's responses to our questions and concerns. There remain some areas, however, where NPS continues to have concerns. Our comments, below, focus on these areas, and are based on a somewhat rushed review ofthe applicant's most recent versions of the various study plans and survey instruments, rather than the original PSP filed in July 2012. AEA and its consultants have indicated that NPS and other stakeholders will be consulted as critical milestones approach, such as 2012 study results dissemination, further development of recreation survey instruments and methodology, and revisions to study scope or methods that may be necessary following the first field season of Integrated Licensing Process (ILP) studies in 2013. We look forward to maintaining a collaborative relationship with AEA, its consultants, and other stakeholders. We do believe, however, that 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." We understand the massive workload associated with preparing a PSP that includes 58 separate studies of a remote area where previous studies are either dated, or non-existent. The State of Alaska nonetheless chose to use the ILP in its ambitious licensing and construction schedule. Given our own capacity, it is already proving difficult for NPS to fully engage, covering technical working group (TWG) meetings that have been scheduled at short notice without first polling stakeholder availability, and with last minute agendas; and checking the project website multiple times a day to see if new documents have been posted. We have endeavored to review and respond in a meaningful manner to interim work products that have been released at, rather than prior to, workgroup meetings, but have not always been able to give these documents the level of scrutiny they deserve. We believe that better use could be made of AEA, consultant, resource agency, and other stakeholder time if individual workgroups had more autonomy to decide where and when to meet, and if meetings were timed to allow advance review of important interim work products. In addition, as we note in more detail below, we believe this project would benefit from following the Communication Protocol mentioned in the PAD and resource study specific schedules and communications plans to reduce conflicts, confusion and delays about "the manner and extent to which information will be shared." 2
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Baseline Data and Information -In our comments on the 2012 (pre-ILP) studies, we underscored the need for baseline information on both recreation and aesthetic resources in the area potentially affected by the project. Very limited field work for these resources was compiled for the previous Watana project in the 1980s. The 2012 field reconnaissance work represents the first effort to collect data using methods consistent with current hydropower licensing requirements. However, because the results of the 2012 studies have not yet been released, NPS and other stakeholders have had to develop our recreation and aesthetic resource study requests without benefit of solid baseline resource information, e.g. without knowing for certain which recreational activities take place in the project area, or which routes and sites are particularly important to recreational users. Our study requests reiterated the need for more detailed information concerning the Watana project area's existing recreation and aesthetics resources, as well as the likely effects ofthe project on these resources over a 50-year license period. Much of our subsequent agreement and confidence in the direction of the 2013-14 studies is predicated on the effectiveness of the data collection and compilation of historic information, plus the rigor ofthe reconnaissance effort currently underway (2012 studies). Our concern about this issue was noted in Table 12.4-1 (see fifth comment). AEA summarized this concern as follows: "According to current published schedule, agencies and stakeholders will not have results of critical 2012 reconnaissance, baselining studies that are key to determining scope, adequacy of the 2013-14 ILP studies before NPS's final opportunity to comment on ILP studies." AEA's response is: "AEA study teams are using information gathered in 2012 to inform the study plan process in those instances that such information is applicable to customize or alter specific methodologies. Much of the work being done in 2012 has to do with collection of baseline information which by itself does not necessarily alter the study methods proposed" (emphasis added). NPS notes that no 2012 study reports have yet been released. Perhaps AEA and its consultants "are using" internal drafts of the reports to inform the D RSPs, but if so, this information is not available to resource agencies, the public, and presumably FERC. If our own analysis of the 2012 results leads us to believe that certain activities, locations, or issues may have been overlooked in the Revised Study Plans (RSP), NPS reserves the right to request amendments to the relevant study plans, even if the ILP deadline has passed. Without such amendments, data gaps may make it difficult for us develop appropriate license condition recommendations to protect, mitigate and enhance outdoor recreation resources. While we agree that some aspects of study methodology are independent of baseline information about the spatial and temporal distribution of recreational activities in the 3
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project area, other aspects are not. For example, AEA is not currently proposing to perform intercept surveys during the coldest, darkest quarter of the year (during the three month period from mid-November to mid-February), citing contactor safety concerns and likely low numbers of recreational users at this time of year. Yet without the 2012 reconnaissance study results, we do not yet know what those numbers are. In addition, the value of a recreational resource is more than a function ofthe number of its users. Resources that provide rare or distinctive opportunities, e.g. viewing the Northern Lights in near complete silence on New Year's Eve from an ice-covered river accessed by dog-sled, snow machine, or ski, cannot be said to be less important than summer activities that also see low participation rates, such as paddling one of North America's few relatively accessible Class V+ rivers at 29,000 cfs. It is possible that the 2012 reconnaissance work will tell us that some areas potentially affected by the project do see important use during this period, or are significant for aesthetic opportunities unavailable during the other nine months. We encourage the study team to consider ways to survey recreationists visiting the study area during these months that don't involve intercepts at remote locations. We remain concerned about whether this kind of2012 survey result will be applied correctly to the ILP study plans in the absence of any involvement by stakeholders, the public, or, potentially, even FERC's own recreation specialists. Our concerns also apply to Aesthetic Resources and River Recreation Flow and Access PSPs. NPS and other resource agencies, along with the public, are effectively being asked to take AEA's word that if results of2012 studies indicate a need to modify ILP studies, such modifications will be made voluntarily, after the ILP study plan resolution period has concluded. This points to the larger problem, unique to original projects that are being licensed using a process designed for existing projects with abundant baseline resource information (i.e., the ILP), of trying to finalize study plans for a project before reconnaissance level work is complete. The DRSPs are replete with references to the integration of2012 study results having been taken into consideration, using the past tense. To date, we have not seen any results from the 2012 recreation and aesthetics studies, although it appears that AEA is making progress in consolidating baseline information. At one of the workgroup meetings this fall, AEA's Project Manager suggested that 2012 preliminary results might be released for our review prior to the November 14,2012 PSP comment deadline, provided we understood that the data were subject to change and corrections and were not ready for release to the general public. While we can appreciate that emerging data and information is being integrated into the revised study plans piecemeal, we anxiously await a report from the 2012 studies that satisfies our original request for comprehensive reconnaissance and assessment of baseline information for this project. Because we do not yet have this report, we are filing these comments without the benefit of information about recreational and aesthetics issues that the 2012 study report might contain. We have one more opportunity under the ILP to submit formal comments about this project's study plans: comments on the applicant's RSP, which are due in mid-January. And since no workgroup meetings are planned between the release of the RSP on December 14, 2012, and the deadline for our comments on January 18, 2013, there will be 4
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no opportunity to consult with AEA and its team of specialists regarding the implications ofthe 2012 study reports. It is not known when these reports will be made available -possibly not until after we've written our RSP comments, which are due for internal agency processing by mid-January 20l3. Inclusion of Lower River in Recreation and Aesthetics Study Area -From the beginning ofNPS's involvement in this project we have maintained that the proposed project may significantly alter the character and supply of recreational opportunities currently provided within the proposed project area. We also believe that aesthetic values (e.g., visual resources and natural sounds) will be altered. Changes in flows, channel and floodplain morphology, riparian vegetation and winter snow and ice cover downstream of the proposed project may affect recreational access to those areas, e.g., recreational boating and winter travel along and across the Susitna River. While we understand that two large tributaries to the Susitna -the Chulitna and Talkeetna rivers -contribute substantial volumes of flow and sediment to the system from Talkeetna downstream to the mouth of the Susitna River, we note that the preliminary revised study plans for ice processes, instream flows, riparian vegetation, etc. nonetheless continue to include the "lower river" (i.e. reach from Talkeetna to Cook Inlet) in their geographical scope. For example, on pages 18-19 of the October 28,2012 DRSP for Instream Flow, AEA states: "The lower extent of the Project Area will be assessed by the flow routing modeling to the extent of Project operational influence. The final Lower River study area extent will be determined by examining the flow routing model results in consultation with the TWG." NPS continues to question why the study area extent for recreation and aesthetics is being prematurely constrained by AEA to the upper and middle rivers when this decision is being deferred, and delegated to the appropriate TWG, for other resources. Recreation and aesthetics resources are highly dependent on biophysical conditions, such as the continued availability of sport fish, the navigability of the river in summer, the existence of sloughs and gravel bars for fishing and camping, and of course the existence of stable ice for winter travel. NPS contends unless and until the results of these biophysical studies prove conclusively that project operations will have no significant effect on flows, sediment transport, fluvial geomorphology, water quality, sport fish migration and habitat, game and furbearer species habitat, riparian vegetation, and ice formation, the lower river should not be excluded from the scope of the recreation and aesthetics studies. While AEA has stated that, if necessary (i.e., if the flow studies etc. show that project operations will have a measureable effect on lower river conditions), recreation and aesthetics studies along this reach can be added at a future date, this means that the intercept portions of such studies would not be conducted under the same variable baseline flow, weather, fishing, etc. conditions as the proposed 2013-2014 studies. Nor would it be possible for the mail-in or executive surveys to sample the exact same population as will be surveyed in 20l3-2014. From an experimental design 5
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standpoint, not including the lower river in the 2013-14 studies will unnecessarily add systematic error to the study results when, as seems likely, this area is later added and sampled in 2015 or later. This approach also risks delaying project readiness for environmental analysis. NPS strongly recommends that baseline boating, fishing, hunting, recreational trapping, and winter use of the Susitna River corridor from Talkeetna to its mouth be assessed in order to determine the project's impacts on recreation and aesthetics. Only if studies of the river's post-project flows, morphology, ice processes, fish habitat, etc. determine that there will be no effect on relevant biophysical conditions in the river corridor downstream of Talkeetna should the recreational and aesthetics study areas be restricted to the river corridor upstream of the confluence with the Talkeetna and Chulitna rivers. Recreation Management Plan -We reiterate that a Recreation Management Plan (RMP) for both land and water-based use of the project area will need to be developed, as required by FERC (18 CFR 4.51(t)(5». This plan should be developed in cooperation with NPS, BLM, other appropriate Federal and State agencies, landowners, and the public, and should include recommendations for access policies, new facilities, and safety measures. We linderscore the importance of the following recreation activities and programs known to exist within the proposed project area: sport fishing and sport hunting, recreational boating, and land-based recreation. ILP Process Plan -In our previous comments, NPS questioned elements of AEA's ILP process plan. AEA has combined a number of diverse resources under the general title of "Social Resources" and has generally scheduled all associated TWG meetings for all these resources on a single day. "Social Resources" include recreation, aesthetics, socio-economics, cultural, transportation, subsistence, and land use. NPS has previously noted, and continues to believe, that this approach is inherently unmanageable and inefficient due to the magnitude and diversity of study topics and details that must be squeezed into a seven or eight hour day. While we are pleased that AEA and its consultants have sometimes scheduled meetings focused solely on recreation and aesthetics in addition to the general work group meetings, we recommended that the Social Sciences TWG be divided into logical sub-groups so that this becomes the norm rather than the exception. Communications Protocol -In our previous comments and on numerous occasions, NPS has requested that a formal communications protocol be developed by AEA in cooperation with stakeholders to address the communication needs. AEA continues to use a website to share documents (e.g. its own draft study requests, meeting notices, meeting agendae, meeting minutes, etc.). Currently there is no provision for automatic notifications for important new documents to allow for downloading by stakeholders, including resource agency staff, making it necessary to check the website frequently (multiple times per day in some instances) to try to ascertain if new documents are there. Due to the complexity of the project and the file naming conventions sometimes used by AEA, it can also be quite difficult to differentiate between older and newer documents. 6
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In addition, there is no consistency in the posting of meeting minutes. Some minutes are posted almost immediately after TWO meetings, other meetings that took place months ago still have no minutes available. As a stakeholder involved in resources that are dependent on numerous other biophysical resources, NPS is interested in the TWO discussions for these other resources. We do not have the capacity to attend all Watana TWO meetings on every topic, so we rely on meeting minutes to provide an overview of important discussions. It would be extremely helpful to us, and presumably, to other stakeholders and the public, if AEA could commit to recording and posting meeting minutes within a few days of each TWO meeting. Again, we urge AEA to explore ways to ensure that stakeholders, particularly resource agencies, receive email notices whenever materials relevant to their interests are updated. We also suggest that a full description of what each file contains be included in the file name used by AEA, e.g., version number, date, and document type. A communications protocol would help all involved in this project know what to expect, and would give stakeholders recourse for tracking down the occasional document that slips through the cracks, e.g. the 2011 Recreation Data Oap Analysis. Tracking Interdependent Studies -NPS recognized early on in this proceeding that many of the proposed studies are related and interdependent. Various studies are scheduled within different timeframes, yet our ability to make decisions and proceed with specific inquiries is contingent on the results generated from these other studies. With limited field seasons and finite study schedules, it is imperative that such a system is developed and maintained by AEA. On October 17, 2012 AEA posted graphic illustrations of the study interdependencies with study completion dates by calendar quarter. These are also included as attachments to the DRSPs. While we believe that this process needs to be further refined, the October 2012 graphic does allow for tracking these disciplinary interdependencies. Comments on AEA's Draft Revised 2013-14 Study Plans for Recreation and Aesthetic Resources and River Recreation Flow and Access NPS has been encouraged by the level of effort AEA and its consultants have devoted to drafting and refining the recreation and aesthetics resource study plans. The consultants have been very responsive to our comments and interactions. On October 17, 2012 AEA posted a comprehensive table which addressed virtually all of our previous comments and concerns. We are pleased that a majority of our differences have been reconciled and are reflected in the DRSPs. The following comments reflect a comparison of the goals and objectives from our May 2012 study requests with the most recent 2013-14 DRSPs for Recreation and Aesthetics, which were distributed on October 25,2012. We also address instances where we still have unresolved concerns based on our read of Table 12.4-1. DRSP 12.5, Recreation Resources -NPS's Recreation Resources Study Request stated the following goals and objectives: 7
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"The purpose of this study is to evaluate the impacts of the proposed hydropower project on existing and potential recreation use and the quality of recreational experience provided, and to determine potential recreation mitigation, use, demand, and needs over the term of the license. The Recreation Resources Assessment should include all of the necessary components to develop a comprehensive RMP: (1) recreation impact and opportunities analysis on existing water-borne, flow dependent and snow and ice-cover dependent river experiences (including all forms of boating and fishing and winter use), and terrestrial recreation activities known to occur in the project area (including hunting, trapping, hiking, backpacking, and all forms of Off Highway Vehicle (OHV)) use; (2) current and projected recreation visitor use; (3) existing developed and dispersed recreation inventory (including access roads, trails, and developed recreation facilities) and condition assessment; (4) future and potential recreation needs assessment and analysis; (S) recreation carrying capacity; (6) economic impacts due to loss of existing and addition of new recreational opportunities." Generally, we believe that the DRSPs address these goals and objectives. Unresolved issues (listed by the section number from NPS's August 2012 preliminary comments on AEA's PSP): • 10.S.2. Existing Information and Need for Additional Information -Agencies, stakeholders and the public will not have results from the "2012 data gathering efforts" until after the November 14,2012 due date for these PSP comments. • 10.5.4. Study Methods, Regional Recreation Analysis -2012 information will be used to develop the RSP. Will NPS see this prior to the November 14, 2012 due date for agency and public PSP comments? If not, how will agencies and public ensure that 2012 data is applied correctly? This timing issue points to larger problem of trying to finalize study plans for a project before reconnaissance level work is compete. This also applies to Aesthetics and River Recreation Flow and Access PSPs. • 10.S.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. • AEA contends that Sections 12.S.3, 12.6.3, 12.7.3 have been revised to indicate that the study area may be changed during study implementation if specific findings from other study disciplines indicate resource effects will extend beyond currently anticipated study boundaries. We refer you back to our comment above regarding "Study Area" and ask that the recreation and aesthetics resources study area include the lower river, just as numerous other resource studies do. 8
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• NPS disagrees with Northern Economics' assumption that Susitna-Watana Hydroelectric Project will lead to "increases in visitation." Some types of uses in the baseline project area will likely decrease or disappear post-project, e.g. hunting in the area inundated by the project reservoir, floating the upper Susitna River downstream from Denali Highway, and, potentially, activities dependent on the existing amount of fish habitat and existing extent and duration of stable winter ice cover. 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. • Recreation User Intercept Survey -We continue to question the value of noting "Don't Know" and "Refused" responses to every question in the survey. These responses do not appear to add value to the survey once initial testing is complete. We definitely want to see these fields eliminated from the mail/online (self-administered) survey instrument. -Question 20(t) & (g) -The table should ask about need for Information and Education resources: kiosks, signage, trail information, points of interest, geologic, historic and / or cultural information. The revised question continues to limit itself to signage. We believe that users may seek a broader array of information such as boundary information, applicable rules and regulations, etc. -Question 20(t) & (g) -We believe that user preference for greater management attention (level of maintenance, staff presence, security, etc.) should be added to this question. -Question 21(a) -Wording is awkward. Perhaps the words ''would not" could be deleted from the question, resulting in "If you were somewhat likely or not likely to return to this area ... " -Question 24. -We believe that the determination of party size should appear earlier in survey. This important recreational attribute should be captured before subjects potentially abandon the interview. This is still not adequately addressed in DRSP. • Mail/Online User Survey -We have not seen a draft of this survey. The original PSP stated that it would be similar to the Intercept Survey and workgroup discussions suggested the only difference would be that this self-administered survey would omit the "don't know" and "refused" options from each question. NPS would like to see the actual survey instrument. DRSP 12.6, Aesthetic Resources -NPS's Aesthetic Resources Study Request stated the following goals and objectives: 9
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"The overall goal of this study is to identify baseline aesthetic resources, examine the impacts of the proposed project construction and operation on these visual and auditory resources, and evaluate potential mitigation opportunities. This exceeds AEA's proposed tasks of 'identifying BLM visual resource management designations or other visual resource management plans for the Project vicinity and identifying potential key view points and key viewing areas for proposed Project facilities' which are the subject of the 2012 Aesthetic Resources Study." Unresolved issues: • 10.6.4. Study Methods, Seasonal Surveys of Ambient Sound Levels -What ifthe 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. • 10.6.4. Study Methods, Seasonal Surveys of Ambient Sound Levels -NPS would like to have enough advance detail to involve our specialized soundscapes staff in reviewing this methodology. The consultants indicated in the "Consistency with Generally Accepted Scientific Practice" section of the DRSP that "The sound analysis is consistent with NPS Guidelines." We would like to verify that with our soundscape specialists. DRSP 12.7, River Recreation Flow and Access One specific objective ofNPS's original study request for recreation included an assessment of the impact of the project on flow-dependent recreation: " ... recreation impact and opportunities analysis on existing water-borne, flow dependent and snow and ice-cover dependent river experiences (including all forms of boating and fishing and winter use)". We consider this to be a major concern for this project. We are encouraged by the choice ofOasis/ERM to conduct this assessment and have been pleased to work with John Gangemi directly on this specific DRSP. We were first introduced to this study plan during John's presentation at the October 3,2012 work group meeting but did not receive a draft ofDRSP until October 25, only a week before these comments were prepared for agency review. Thus NPS's collaboration with AEA and its consultants on this study has not progressed as far as on the other two studies we are involved with. Nonetheless, we are pleased, at first glance, to note that several of our recommendations and interests have been adopted in this draft. While there are no more TWG meetings scheduled before FERC renders its study plan decision next February, we request the ability to work directly with John to refine this draft as soon as possible. 10
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Unresolved issues: • We noted that this study's title and some initial statements about its scope appear contradictory. We believe that the study goal should not merely be to contribute data concerning recreational boating and access -it is to look at all fonns of recreation that could be affected by flow changes caused by project operations. This includes activities like fishing regardless of whether recreationalists are angling in a boat or from shore. We recognize that the DRSP has been modified to assess impact on most fonns of flow-dependent recreation in all seasons. • At the October 3, 2012 meeting (see p. 4 in meeting notes), NPS suggested that focus groups be used to assess optimum and acceptable flow alternatives for the project. AEA's consultant agreed that this would be beneficial but proposed to wait to convene the groups until 2014, when more infonnation about operations alternatives would be available. The DRSP does not include focus groups. NPS hopes this omission can be rectified in the RSP. • 10.7.3. Study Area -The following statement lacks clarity: "areas where the proposed reservoir would create the most flow changes." What is threshold for "most"? Who decides? When? Even assuming consensus on the standard to be used, how can this decision be made before the results ofthe instream flow, flow routing, ice processes, etc. studies are in hand? What ifNPS or others disagree with AEA's geographic scope decision? This should have been detennined before the DRSPs were released. We caution the applicant that it risks having to spend additional field seasons collecting baseline data if the results of these other studies, which won't be completed until 2014 or later, alter the area predicted to be affected by project operations. • We note that the study area for this DRSP extends downstream to the Parks Highway Bridge at Sunshine. While this would include the upstream portion of the lower Susitna River, it still fails to address the rest of the river to Cook Inlet. Regardless of whether there would be detectable changes in flows, fluvial geomorphology, ice processes, and riparian vegetation in the lower river due to project operations, resources such as migratory sport fish are likely to be affected by changes in flows, habitat, and the physical barrier created by the dam in the upper and middle river. Sport fishing is a flow-dependent fonn of recreation known to occur throughout the lower river, as are numerous fonns of winter recreation (e.g. skiing, biking, snowmachining, and mushing races crossing the river on the Iditarod Trail route) that depend on the fonnation of stable ice across the lower river. By excluding most of this reach from the proposed River Recreation Flow and Access study, AEA again runs the risk of having to re-do this study if the results of other studies indicate that project operations will affect resources in the lower reach. NPS believes that the ILP requires study plans to address all areas reasonably anticipated to be affected by a project. Ifthe Watana project involved a smaller dam that did not present a major impediment to salmon migration, and was intended to be operated in run-of-the-river mode, the decision to exclude the Lower River from the three recreation and aesthetics study areas would be more 11
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reasonable, but this is not the case. Without information about baseline recreational and aesthetics resources along the lower river, NPS will be unable to formulate recommendations for license terms and conditions to minimize or compensate for project impacts on these resources. • 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. • 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. The Susitna's flow magnitudes, timing, durations, and rates of change vary significantly from year-to-year, as do other conditions affecting recreational use and access. We note, for example, that there was an emergency Chinook closure this year. How can AEA study the most highly valued fish species in Southcentral AK if harvest is prohibited during the only year of study? Likewise, since most recreational users use the road network to get to and from the river, road closures such as the four-day Parks Highway closure at the Troublesome Creek and Chulitna bridges in 2006, and closures of the Parks and Denali Highways in September 2012, inevitably affect recreational use in the project area. Weather patterns (e.g. late break-up, early snow, persistent rain) and wildfires also affect use. One season is not enough to document baseline opportunities and experiences when they are dependent on highly variable interannual conditions. AEA's response to this concern is ''There is a provision to capture data in 2014 in the event that unusual circumstances or events do not allow the capture of data in 2013." NPS believes that factors such as the interannual variability in the timing of Chinook salmon runs and return rates, which in turn affect sport fishing timing and level of effort, are not "unusual circumstances." They are known attributes associated with a resource having a multi-year life span and that is dependent on variable oceanographic conditions that are also poorly understood. We contend that the decision to rely on a single year of study for this complex and variable resource is not scientifically valid, and we request FERC to caution AEA that failure to document baseline resources adequately will delay initiation of the required environmental analysis of the project. Comments on AEA's Proposed 2013-14 Study Plans for Other Resources Socioeconomic Study -NPS was encouraged to learn about the Random Utility Model (RUM) approach to monetizing the value of recreation in the project area. We commented on our disagreement with the assumption that the project will lead to "increases in visitation." It is almost certain that there will be trade-offs in levels of participation among different types of recreation, as well as gains or losses in the value of each kind of recreational opportunity or experience even if numbers of participants remain the same. 12
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Some kind~ of haseline project area u~es will likely decrease or disappcar post-project, c.g. moose and caribou hunting in the area inundated by the reservoir, and float trips on the flooded portions of the Susitna downstream from the Denali Highway. Potentially, opportunities dependent on the existing amount of fish habitat and existing extent and duration of stahle winter ice cover may also decrease. At our last work group meeting. we were assured that ABA will consider all changes in visitation due to the project. However, the recently released DRSP appears to return to the as~umption that visitation will increase. NPS restates its concern that by treating recreation as a one-dimensional commodity, the socio-economic study risk~ a failure to capture the economic effects of project-related changes. Ice Processes -NPS is pleased to see acknowledgement of the need "to understand the potential effects of the project on winter transportation access and recreation, which depend on ice cover on the lower Susitna River" (Section 7.6.3.4 of Interim Draft Revised Study Plan, emphasis added). We are, however, puzzled about the inclusion of this objective for the lower river in the icc processes study but not in the River Recreation Flow and Access study (with the exception of a ten mile stretch of the lower river from Talkeetna to Sunshine). Why are the study areas for these two studies different? How will AEA understand the project's icc-cover related effects on winter transportation access and recreation if it does not collect data on winter recreation use from Sunshine downstream to Cook Inlet? Water Quality -Again, NPS is pleased to see acknowledgement of the nexus between water quality and recreational opportunities, as stated twice on the first page of the DRSP for Water Quality. Aesthetics are, of course, also affected by changes in water quality pm·ameters. The NPS appreciates the opportunity to comment on the 2013-14 Draft Revised Study Plans. We look forwm·d to working with FERC, AEA. its consultants, and stakeholders in the licensing process. If you have any questions, please contact Cassie Thomas at 907-350-4139 or Harry Williamson at 423-322-4151 with questions regmding these comments. Sincerely, ~\~~ Nancy Swanton Interim Team Manager Environmental Planning and Compliance cc: Wayne Dyok (wdyok@aidea.org) Susitna-Watana Project Manager Alaska Energy Authority 813 West Northern Lights Boulevard Anchorage, Alaska 99503 13
Document Content(s)
NPS_Comments_FERC_14241.PDF...........................................1-13
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K. Bose
most pertinent to the Service's resource responsibilities. The enclosure includes specific
comments on the topics by PSP section number and title.
General Comments
2
The Service appreciates AEA's request and FERC's concurrence in granting the resource
agencies a comment period extension for reviewing the PSP. The Service also l,rreatly appreciates
AEA's provision of Supporting Services to the Service and the National Marine Fisheries
Service (NMFS) under the terms of our June 2012 Memorandum of Agreement among AEA , the
Service , NMFS, and the Alaska Department of Natural Resources. Because of the geographic
scope of the project, the inter-related complexities of the physical and temporal scale of scientific
infonnation to be collected , and the valuable fish, wildlife, and habitat resources of the Susitna
River watershed , the Service has a substantial interest and responsibility in ensuring conservation
of these valuable fish and wildlife resources.
The Service's comments focus on the PSP submitted by AEA on July 16 ,2012. Since that time,
the Service, NMFS, and our Supporting Services, have participated with AEA and their
consultants in a number of technical working group (TWG) meetings to work toward
understanding and consensus on sound study plans. However, not all areas of agreement have
been subsequently documented. AEA began issuing draft revised study plans (RSP) October 31,
2012 , which do incorporate several areas of agreement. However, there was insufficient time for
the Service to adequately review all of the draft RSPs, and update our nearly complete comments
on the PSP , prior to the November 14,2012, due date for comments on the PSP. We
acknowledge and appreciate AEA's efforts to maintain an iterative process while continuing to
refine the PSP to meet agencies' study re~uests. Where possible, our comments reference
agreements reached since AEA's July l6t PSP or the further details provided in the RSP.
The Service recommends future TWG meetings be more interactive and less focused on
Powerpoint presentations. This would allow for effective discussions on all topics, leading to
mutual understanding. We also recommend that documentation be provided for agreements
reached at these meetings , so that there is a common frame of reference for all involved parties.
At this time it is difficult to provide written comments on these meeting discussions without the
details that a written document provides.
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 affinned 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.
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At the same time, there is a need to ensure that all study requests are integrated , with the overall
findings appropriately influencing design of project alternatives.
3
Project Design and Study Inter-relatednessllnterdependency: The proposed Project is a large and
complicated unde11aking that will involve numerous individual studies, agencies, consultants,
and individuals throughout the licensing process. Study requests were developed individually,
and have not fully benefitted from consideration of how they should be integrated with other
studies, including for efficiencies in time and cost of implementation. 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 and their respective Principallnvestigator(s). This integration plan s hould discuss
how model results will be documented and how the infornlation 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 .
The PSP individual studies are numerous and complex. We recommend that AEA develop a
cross-walk for all the studies to help clarify their inter-relationships , and then clearly describe
how each stu dy may depend on other studies. During the October 2012 technical work group
meetings , AEA started to include helpful graphics and charts depicting study interdependencies ,
including interactions between different studies and how products from one study feed into
another, and timelines indicating when relevant models and other products will be available.
AEA will need to continue to refine this product and the Service will need to provide further
review. At this stage, studies of biological resources and physical habitat parameters have not
yet been interrelated with engineering studies and design considerations. Such integration and
collaboration will be essential to ensure the licensing process is efficient, economical, and results
in a project that best addresses environmental , economic, and power generation factors.
Many of the individual PSPs rely upon or provide data from/for other studies. Recogni zing these
relationships is an important part of the Integrated Licensing Proces s (lLP); however , the study
providing the data should describe the methodology and oversee the data collection and analyses,
while the study requiring the results should restrict its discussion to the types of data/results
required from other PSPs. 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. For example, since the Groundwater PSP 5.7 will be providing data to
other studies, the Groundwater PSP should describe the methods as well as list the data/results
that will be provided to other studies (e.g., 6.5 Fish and Aquatics Instream Flow, and 6.6
Riparian Instream Flow studies).
Besides interdependency figures, AEA must provide timelines showing how and when the
various st udy components (both among major studies and within studies) will feed into other
stud ies and study components. TIle Service is concerned the sequencing of some study
components ma y be out of sync with the required products from other studies and study
components.
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
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K. Bo se
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.
4
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 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 thi s 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 ent ertain 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.
Historic Data and Study Results: The Service remains concerned that AEA has not yet
adequately evaluated and characterized all available historic (1980s) infonnation 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 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 proposed
Project. Past studies only concentrated on a few fish species and potential effects to their macro-
habitats; 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 infonn the design of a Project with fewer, environmental impacts,
and to better assess those potential impacts. Finally, the 1980 s project studies were discontinued ,
therefore those study results were never evaluated or completed to develop final
recommendations.
Integrated Licensing Process: AEA has laid out a process plan, schedule and communications
protocol prescribing the specific timeframes , deadlines , and responsibilities of FERC, AEA, and
other stakeholders in the ILP that extends from filing of the Notice oflntent (December 29,
20 II) through filing of the application for license (anticipated September I I, 2015) (Chapter 2 of
the Pre-Application Document). Adherence to this plan is essential for guiding the application
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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 (Section 2 , Pre-Application Document , December 20 II).
5
AEA's Licensing Website (http ://w ww.susitna-watanahydro.orgl) lacks copies of written
communications and other pertinent materials to date. These documents should be added and the
site regularly updated. Examples of missing documents include agency and other stakeholder
study requests filed by the initial May 31 ,2012 , due date, and any updates, as well as FERC
documents (e.g., FERC Scoping Documents). A complete set of Preliminary Application
Document (PAD) Reference Documents is not available; according to AEA these documents are
to be distributed via the website or on the Alaska Resources Library and Infonnation Services
(ARLlS) website. There are currently few to no such documents on the website. Updates on
additions of historic documents and studies as they are added to ARLiS should also be noted and
linked. The Service recommends that all reference documents used by the project be distributed
via the website, not just those used in the PAD . The website also lacks meeting summaries for
several Technical Workgroup Meetings including those held in August.
With regard to ILP Meetings , AEA has not fully complied with the regulatory requirements for
study planning meetings as described. The PAD communications protocol states AEA will:
so licit input from participants on meeting dates, agenda items and objectives; notify participants
of meetings at least 30 days in advance unless circumstances are unavoidable (this should be the
exception not the standard); establish draft meeting agendas and post them two weeks in advance
so that participants may submit comments on the agenda up to one week before the meeting; and ,
make available literature citations , documents and other infonnation needed for consultation two
weeks prior to the scheduled meetings . It is critical for AEA to follow the communications
protocol and the ILP meeting guidance, in order for stakeholders to be able to fully and
adequately participate in the study planning process.
Thank you for considering our comments and recommendations. If you have que s tions on these
comments, please contact our Susitna-Watana Project Lead , Catherine Berg at (907)271-2787 , or
via email at catherine_berg@fWs.gov. We look forward to working with FERC and AEA to
refine , integrate , and collaborate on recommended studies and project design as more
infonnation about the project becomes available.
Enclosure
Sincerely,
Ann G . Rappoport
Field Supervisor
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PROPOSED STUDY PLAN – USFWS COMMENTS
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FERC No. 14241 Page 1 Save Date: November 13, 2012
5. Water Resources
5.5. Baseline Water Quality Study
The May 31, 2012 Water Quality Study request submitted by the U.S. Fish and Wildlife Service
(Service) combined baseline water quality and water quality modeling into one study. In our
review of Alaska Energy Authority’s (AEA) Proposed Study Plan (PSP) we will address the
baseline water quality and water quality modeling study plans separately.
The baseline water quality PSP proposes: (a) to characterize baseline water quality conditions,
(b) to develop a monitoring program to characterize surface water physical, chemical, and
bacteriological conditions in Susitna River downstream of the project area, and (c) measure
baseline metals concentrations in sediment and fish tissues.
In general, the PSP adequately addresses the water quality issues. The Service recommends
specific improvements, as follows:
General Comments by Subtopic:
Standard Operating Procedures:
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.
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.
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.
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.
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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.
Water Quality Standards
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 (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.
Specific Comments: Methods/Analysis Evaluation
1) 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.
2) Our study request indicated that “Additional temperature monitoring locations will be
identified in cooperation with Fish Studies, the Groundwater Study, and the Instream Flow
study to identify areas of thermal refugia for fish”. This does not appear in the study plan.
3) 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.
4) 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.
5) 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.
6) The Service’s study request included three MET station parameters 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.
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PROPOSED STUDY PLAN – USFWS COMMENTS
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7) 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.
8) 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.
9) 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.
10) Page 5-13, paragraph 3, the PSP states: “Metals monitoring for total and dissolved fractions
in surface water include the full set of 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.
11) 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.
12) 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.
13) 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
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such as iron, but would be completely ineffective for toxic inorganic elements present in
relatively “trace” concentrations.
14) 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.
15) As a general note, reference to USGS guidance for conducting water quality sampling has
been deleted throughout the AEA PSP.
16) 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 aquatic life, and for
mixture toxicity (the elements are not present in isolation). Metals do not have to
bioaccumulate to have a toxic effect.
17) 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.
18) 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.
19) 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.
20) Page 5-17, paragraph 4, the PSP states: “Results will be reported with respect to applicable
Alaska State and federal standards”.
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
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laboratory experiments, using the same or comparable piscivorous avian and
mammalian species.
21) 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.
22) 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 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. Likewise, macroinvertebrates need to be added to the
current study plan.
23) 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.
Literature Cited
Lewis, M.E. and M.E. Brigham. 2009. National Field Manual for the Collection of Water-Quality
Data (TWRI Book 9). Chapter A5. Processing of Water Samples, Section 5.6.4.B -- Low-level
Mercury (dated 10/04).
United States Environmental Protection Agency (EPA). 1996. Method 1669. Sampling Ambient
Water for Trace Metals at EPA Water Quality Criteria Levels. July 1996. U.S. Environmental
Protection Agency, Office of Water, Engineering and Analysis Division (4303) 401 M Street
S.W. Washington, D.C. 20460.
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United States Environmental Protection Agency (EPA). 1997. Mercury Study Report to
Congress. EPA-452/R-97-003, December 1997
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5. Water Resources
5.6. Water Quality Modeling Study
General Comments:
The May 31, 2012 Water Quality Study request submitted by the U.S. Fish and Wildlife Service
(Service) combined baseline water quality and water quality modeling into one study. In our
review of Alaska Energy Authority’s (AEA) Proposed Study Plan (PSP) we will address the
baseline water quality and water quality modeling study plans separately.
The PSP Water Quality Modeling Study proposes to utilize the information collected from the
Baseline Water Quality Study to develop a model in which to evaluate potential impacts of the
proposed Project and operations on various parameters within the Susitna River watershed.
In general, the PSP adequately addresses the water quality issues. The Service recommends
the following improvements.
Specific Comments by Subtopic:
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.
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.
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.
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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 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.
Literature Cited
Altenburger, R., M. Nendza, and G. Schϋϋrmann. 2003. Mixture toxicity and its modeling by
quantitative structure-activity relationships. Environmental Toxicology and Chemistry, 22(8):
1900-1915.
Borgmann, U., W.P. Norwood, and D.G. Dixon. Modelling bioaccumulation and toxicity of metal
mixtures. Human and Ecological Risk Assessment: 14(2): 266-289.
Jho, E.H., J. An, and K. Nam. 2011. Extended biotic ligand model for prediction of mixture
toxicity of Cd and Pb using single metal toxicity data. Environmental Toxicology and Chemistry,
30(7): 1697-1703.
Kamo, M. and T. Nagai. 2008. An application of the biotic ligand model to predict the toxic
effects of metal mixtures. Environmental Toxicology and Chemistry, 1479-1487.
Khan, F.R., W. Keller, N.D. Yan, P.G. Welsh, C.M. Wood, and J.C. McGeer. 2011. Application
of the Biotic Ligand and Toxic Unit Modeling Approaches to Predict Improvements in
Zooplankton Species Richness in Smelter-Damaged Lakes near Sudbury, Ontario.
Environmental Science and Technology, 46z: 1641-1649.
Kortenkamp, A., T. Backhaus, and M. Faust. 2009. State of the Art Report on Mixture Toxicity.
Final Report, Executive Summary. Prepared for the European Commission, Directorate General
for the Environment. December 22, 2009.
Mumtaz, M.M., C.T. De Rosa, J. Groten, V.J. Feron, H. Hansen, and P.R. Durkin. 1998.
Estimation of toxicity of chemical mixtures through modeling of chemical interactions.
Environmental Health Perspectives, 106: 1353-1360.
Sasso, A., S. Isukapalli, S.W. Wan, and P.G. Georgopoulos. 2006. Physiologically-based
toxicokinetic models for toxic metal mixtures: Development and demonstration of a
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mechanistically-consistent framework. Poster presented at Society for Risk Analysis meeting,
Baltimore Maryland, December 5, 2006.
Schmidt, T.S., W.H. Clements, K.A. Mitchell, S.E. Church, R.B. Wanty, D.L. Fey, P.L.
Verplanck, and C.A. San Juan. 2010. Development of a new toxic-unit model for the
bioassessment of metals in streams. Environmental Toxicology and Chemistry, 29(11): 2432-
2442.
Stockdale, A., E. Tipping, S. Lofts, and S.J. Ormerod. 2010. Modelling multiple toxic effects in
the field – evaluation of the Toxicity Binding Model (TBM). Final report to the International
Copper Association (ICA). Centre for Ecology and Hydrology, Natural Environmental Research
Council. February 2010.
Van Genderen, E., E. Rogevich-Garman, R. Dwyer, J. Gorsuch. 2012. Incorporating
bioavailability into risk assessment for metal mixtures; results of a comparative evaluation.
SETA Globe, 13(6).
Vijver, M.G., E.G. Elliott, W.J.M. Peijnenburg, and G.R. de Snoo. 2011. Response prediction for
organisms water-exposed to metal mixtures: A meta analysis. Environmental Toxicology and
Chemistry, 30: 1482-1487.
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5. Water Resources
5.7. Groundwater-related Aquatic Habitat Study
General Comments:
The U.S. Fish and Wildlife Service’s (Service) 31 May 2012 study request entitled Groundwater-
Related Aquatic and Floodplain Habitat Study more accurately encompasses the scope of our
study request by including both aquatic and floodplain in the title. 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.
Many of the individual PSPs rely upon or provide data from/for other studies. Recognizing
these relationships is an important part of the Integrated Licensing Process (ILP); however, the
study providing the data should describe the methodology and oversee the data collection and
analyses, while the study requiring the results should restrict its discussion to the types of
data/results required from other PSPs. 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. 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 Instream Flow
studies).
At the 24 October 2012 Groundwater Technical Workgroup (TWG) meeting, AEA provided a
draft study interdependency figure showing which additional studies would provide data for the
study, the expected information produced by the study, and which studies will rely upon output
from the study. 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.
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.
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.
The 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
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providing sufficient detail so the methods can be evaluated without having to refer to the
citation.
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.
Specific Comments by Subsection:
The following review of AEA’s proposed Groundwater-related Aquatic Habitat Study Plan uses
the structure of the plan and compares the plan to the Service’s study-request objectives to
determine if our intent is met, where improvements can be made, and which requested
objectives are not addressed.
AEA Study Goals and Objectives: The overall goal of the study is to understand the effects of
the Project on groundwater and surface-water (GW/SW) interactions as they relate to habitat for
aquatic species (e.g., fish, riparian vegetation) in the Susitna River.
AEA’s overall study goal is similar to the Service 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.
AEA’s PSP objectives are similar to the Service study-request objectives, except for some minor
wording to qualify the scope of the objective. The objectives and wording will be discussed
along with their methods below. For now, it’s important to recognize that some objectives are
really tasks (e.g., 1, 4), rather than true objectives (e.g., 5, 6).
AEA Study Area: The Susitna River from the Parks Highway bridge (RM 84, located near
USGS Gage on Susitna River at Sunshine) to an area just upstream of the dam (RM 184) for
detailed studies.
The Service recognizes the downstream limit of the study area is still under discussion, and we
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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.
AEA Objective 1 and Methods: Synthesize historical data available for Susitna River
groundwater and groundwater related aquatic habitat, including the 1980s and other studies.
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.
The first objective is very similar to our study request objective. The goal of our objective is to
review existing information on Susitna River groundwater and groundwater-dependent aquatic
and floodplain habitat, and to gain insights from other hydro projects with a focus on cold-region
projects.
Not included in AEA’s methods is a review and 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.
AEA Objective 2 and Methods: Use available information to characterize the large-scale
geohydrologic process-domains/terrain of the Susitna River (e.g., geology, topography,
geomorphology, regional aquifers, shallow ground water aquifers, GW/SW interactions).
Service Objective 2 (meaningful differences - none): “Use available information to characterize
the large-scale geohydrologic process-domains/ terrain of the Susitna River (e.g., geology,
topography, geomorphology, regional aquifers, shallow ground water aquifers, surface-water /
groundwater interactions).”
The second objective is identical to our study request objective. The goal of our objective is to
characterize large-scale geohydrologic process-domains (Montgomery 1999) within the Susitna
River Basin that influence surface-water / groundwater interactions in the Susitna River and
floodplain.
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.
Citing recognized methods is encouraged, such as ASTM standards D5979 and D6106, but the
study plan must include enough information about the cited methods so reviewers can evaluate
the appropriateness of the proposed methods without referring to the citation.
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AEA Objective 3 and Methods: Assess the effect of Watana Dam/Reservoir on groundwater
and groundwater related aquatic habitat in the vicinity of the dam.
Service Objective 3 (meaningful differences underlined): “Assess the effect of Watana
Dam/Reservoir on groundwater and groundwater-related aquatic and floodplain habitat in the
vicinity of the dam, and the downstream extent of the reservoir’s influence on groundwater.”
Although the wording of AEA’s third objective differs from our request, the methods are identical
to our study request. The goal of our objective is to assess the effect of the Watana Dam and
reservoir on downstream groundwater-related aquatic and floodplain habitat, and to assess the
downstream extent of the reservoir’s influence on groundwater potentially bypassing the dam.
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 groundwater.
AEA Objective 4 and Methods: Map groundwater influenced aquatic habitat (e.g., upwelling
areas, springs).
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.
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.
Aquatic groundwater-influenced habitat on the 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.
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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 ground-
truthing 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 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.
AEA Objective 5 and Methods: Determine the GW/SW relationships of floodplain shallow
alluvial aquifers at Riparian Instream Flow study sites.
Service Objective 5 (meaningful differences underlined): “Determine the surface-water /
groundwater relationships of floodplain shallow alluvial aquifers at Riparian Instream Flow Study
sites, including relationships with both the river and the adjacent uplands (e.g., gaining or
loosing stream).”
The goal of our objective is to understand how floodplain shallow-alluvial groundwater interacts
with the surface water from the Susitna River and with the adjacent upland groundwater. This
study component will provide the necessary groundwater information for the Riparian Instream
Flow Study to develop plant community response curves (similar to HSC), which can be used to
predict the effects of Project operation on floodplain plant communities.
AEA’s methods for this groundwater objective (Section 5.7.4.5) and the Riparian Instream Flow
Objective (Section 6.6) confuse responsibilities and methods between the two studies. For
example, the last two bulleted paragraphs in the groundwater study (Section 5.7.4.5) describe
riparian methods, while Section 6.6.4.5 in the riparian study describes groundwater methods.
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.
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 areas. A master matrix of studies, data needs
and data products would greatly facilitate this process and stakeholder acceptance.
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
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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.
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 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 surface-
water 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 surface-
water 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.
The products of this study objective should be sufficient to provide water-level summary
statistics for each location (e.g., point, plot, transect, water-table surface) that will be used to
test and fit plant response curves, such as growing season cumulative frequency, 7-day moving
average, 10-day moving average, 14-day moving average, and arithmetic mean (see Henszey
et al. 2004, Table 1). The Service understands that calculating these summary statistics will be
the responsibility of the studies responsible for using the groundwater data (24 October 2012
TWG meeting). This is possible for individual wells, but we suspect the other studies will have
some difficulty calculating these summary statistics for the water-table surface and recommend
the groundwater study conduct this analysis.
AEA Objective 6 and Methods: Determine GW/SW relationships of upwelling/downwelling at
Instream Flow Study sites in relation to spawning, incubation, and rearing habitat (particularly in
the winter).
Service Objective 6 (meaningful differences underlined): “Determine the surface-water /
groundwater relationships of upwelling/downwelling at Aquatic Instream Flow Study sites in
relation to spawning, incubation, and rearing habitat (particularly in the winter).”
The goal of our objective is to understand how surface-water / groundwater interactions
influence salmonid habitat use and biological functions, including selection of spawning and
rearing habitats, egg/alevin survival, and overwintering. This goal fits in naturally with the next
study objective (Objective 7) to characterize water quality and probable flow paths of
groundwater for habitats where groundwater is important for fish habitat. The source and flow
path of water are important factors influencing its temperature and chemistry (Johnson 2003).
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). The results of this objective should
facilitate predicting Project operation effects on surface-water / groundwater interactions both
temporally and spatially.
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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.
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 methods for extrapolating
surface-water/ groundwater study results from the focus areas to the river segments are
unclear.
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).
The data collected for understanding the surface-water / groundwater relationship at each
aquatic instream flow study site must consider all the key biologic functions and time periods
(particularly in winter), as stated. The aquatic study site data will include empirical data related
to surface-water / groundwater interactions (e.g., piezometers, water levels, water temperature
and conductivity, tracer studies). Surface-water / groundwater interaction data will be collected
at the intensive study reaches utilizing multiple transects of arrays of groundwater wells,
piezometers and stage gages. The surface-water / groundwater data will be used to quantify,
and model, the relationship between the shallow surface aquifers and aquatic habitat types. At
each of the aquatic study sites, surface-water / groundwater interaction models will be
developed to allow for temporal analysis of project operations effects on surface-water /
groundwater exchange that may influence habitat utilization by aquatic species. This modeling
may include the use of MODFLOW (USGS 2005 and Feinstein et al. 2012) surface-water /
groundwater interaction models of floodplain shallow alluvial aquifer and surface-water
relationships. MODFLOW surface-water / groundwater interaction models will be used to model
surface-water / groundwater relationships using empirical monitoring data collected at intensive
study reach surface-water / groundwater monitoring stations.
AEA Objective 7 and Methods: Characterize water quality (e.g., temperature, DO, conductivity,
nutrients) of selected upwelling areas where groundwater is a primary determinant of fish
habitat (e.g., incubation and rearing in side channels and sloughs, upland sloughs).
Service Objective 7 (meaningful differences underlined): “Characterize water quality (e.g.,
temperature, DO, conductivity, nutrients) and age (i.e., indication of potential source) of
representative upwelling areas where groundwater is a primary determinant of fish habitat (e.g.,
incubation and rearing in side channels and sloughs, upland sloughs).”
The Service listed this objective separately, but chose to include the methods along with
Objective 6 because the requested investigated water-quality attributes will be used to
supplement Objective 6 by further refining fish habitat quality and surface-water / groundwater
relationships. AEA’s methods (Section 5.7.4.7) state the work for this objective will be
accomplished by the Baseline Water Quality Study (Section 5.5). If this is the case, then these
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methods belong in that section and not in both sections. Our comments here pertain solely to
the methods presented in this PSP.
Characterization of water quality must have a temporal component to assess surface water
influences on groundwater quality parameters (temperature, dissolved oxygen (DO),
conductivity, pH, dissolved carbon, nitrogen, phosphorous, alkalinity and hardness). This
temporal component is especially important where anadromous fish species spawn and
overwinter due to the effects associated with load following operations. Spatial and temporal
water quality data should be collected to understand processes that contribute to river
productivity, habitat quality, thermal refugia, and how surface-water / groundwater processes
are influential to those processes. Additionally, we recommend the relative age of water be
determined, this may be achieve through several methods that must be described in the study
plan. How long the water has been underground will help identify the groundwater source, such
as from the active hyporheic zone (recent groundwater) or from a potential upland source (older
groundwater).
AEA Objective 8 and Methods: Characterize the winter flow in the Susitna River and how it
relates to GW/SW interactions.
Service Objective 8 (meaningful differences underlined): “Characterize how winter surface-
water / groundwater interactions may differ from ice-free interactions for both the existing and
the projected Project Susitna River flow regimes.”
The Service listed this objective separately, but chose to include the methods along with
Objective 6 because the requested investigated season (winter) supplements Objective 6 by
continuing the period of record throughout the year for determining fish habitat surface-water /
groundwater relationships, not just during the ice-free season.
The Service agrees with the applicant that surface-water / groundwater interactions are critical
to aquatic habitat functions, and the Project operations will have an impact on winter flow
conditions, including surface-water / groundwater exchange effects on the habitat quality used
by anadromous species. The methods associated with Objective 8 include data collection at
stream gages and at specific study areas. It may be implied by this study objective, but we
request that both baseline and Project-operation winter flow characterizations are necessary.
This should include developing surface-water / groundwater exchange models that include
winter operation scenario analyses, accounting for changes in ice thickness and cover, and
changes in water quality (temperature, DO, nutrients, specific conductivity); all associated the
mixing of surface-water and groundwater, and potentially affected by the proposed winter
operations (either load following or baseload).
This objective should also characterize how ice formation affects surface-water and
groundwater stage for both the main and off channels of the river. Our understanding of how
surface ice affects the routing of surface water or how the location and thickness of ice may
influence surface-water and groundwater stage in off channel locations is inadequate. This
understanding must be improved, since this process can drastically alter winter fish habitat.
Occasional ice-thickness measurements and 2D modeling will likely be insufficient to calibrate
the model.
AEA Objective 9 and Methods: Characterize the relationship between the Susitna River flow
regime and shallow groundwater users (e.g., domestic wells).
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Service Objective 9: Not requested.
Although this objective does not directly relate to Service trust resources, we believe the
information gained from this objective will aid in the overall understanding of the Susitna River
groundwater system.
Literature Cited
Feinstein, D.T., M.N. Fienen, J.L. Kennedy, C.A. Buchwald, and M.M. Greenwood. 2012.
Development and application of a groundwater/surface-water flow model using
MODFLOW-NWT for the Upper Fox River Basin, southeastern Wisconsin: U.S.
Geological Survey Scientific Investigations Report 2012–5108. 124 pp.
Henszey, R.J., K. Pfeiffer, and J.R. Keough. 2004. Linking surface- and ground-water levels to
riparian grassland species along the Platte River in Central Nebraska, USA. Wetlands
24(3):665-687. (ne.water.usgs.gov/platte/reports/wetlands_24-3.pdf)
Johnson, S.L. 2003. Stream temperature: scaling of observations and issues for modeling.
Hydrological Processes 17:497-499.
Johnson, S.L. and J.A. Jones. 2000. Stream temperature responses to forest harvest and
debris flows in western Cascades, Oregon. Canadian Journal of Fisheries and Aquatic
Sciences 57:30-39.
Mellina, E., R.D. Moore, S.G. Hinch, J.S. Macdonald, and G. Pearson. 2002. Stream
temperature responses to clearcut logging in British Columbia: the moderating
influences of groundwater and headwater lakes. Canadian Journal of Fisheries and
Aquatic Sciences 59:1886-1900.
Montgomery, D. 1999. Process domains and the river continuum. Journal of the American
Water Resources Association 35(2):397-410.
Moore, R.D., P. Sutherland, T.Gomi, and A. Dhakal. 2005. Thermal regime of a headwater
stream within a clearcut, coastal British Columbia, Canada. Hydrological Processes
19:2591-2608.
Rothwell, E.L. 2005. The influence of hyporheic flow on the temperature of a riffle-step-pool
stream. Thesis (M.S.), Boise State University.
U.S. Geological Survey. 2005. MODFLOW-2005, The U.S. Geological Survey modular
groundwater model - the Ground-Water Flow Process: U.S. Geological Survey
Techniques and Methods 6-A16.
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5. Water Resources
5.8. Geomorphology Study
General Comments:
The May 31, 2012 Geomorphology Study request submitted by the U.S. Fish and Wildlife
Service (Service) combined geomorphology and fluvial geomorphology into one study, as the
data collected and models developed for both of these topics were directly linked to aquatic
habitats in the Susitna River system. In our review of Alaska Energy Authority’s (AEA)
Proposed Study Plan (PSP) we will address the geomorphology and the fluvial geomorphology
modeling study plans separately.
During the August 15-17, 2012 technical working group (TWG) meetings AEA described fish,
instream flow, and water resource study plans. These study plans 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.
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.
Specific Comments by Subsection:
The following review of AEA’s Geomorphology Study Plan (2012) uses the structure of the
plan’s stated objectives and compares them to the Service’s study request objectives to
determine if the intent is met, where improvements can be made, and which request objectives
are not addressed.
AEA Study Objective 1. Determine how the river system functions under existing conditions.
This is a good overarching objective that includes several of the Service’s more specific
objectives. 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.
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Characterize and map the fluvial geomorphology of the Susitna River.
Describe and identify the primary geomorphic 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.
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
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.
AEA Study Objective 2. Determine how the current system forms and maintains a range of
aquatic and channel margin habitats
The applicant’s second study objective relates to the Service’s requests for understanding the
primary geomorphic processes that create and influence fluvial geomorphic features. This
information along with the delineation and characterization of riverine habitat types for the
project area will provide a good understanding of which geomorphic processes create and
maintain aquatic habitats. A description of how habitat utilization will inform the habitat
characterization should also be included. For example the main channel is currently one of the
macro-habitat classifications, but if, through utilization and fish distribution study, it is found that
there are unique main channel features that are important, then the classification should identify
the processes that maintain those features and substrate composition. This provides a
foundation for development of operation effects to habitat, specifically the flows necessary to
create and maintain habitats. The Service 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. 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.
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
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understanding of sediment transport associated with the large and small tributaries and
dispersed sediment input associated with hillslope and mass wasting processes.
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).
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 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.
AEA Study Objective 3. Identify the magnitudes of changes in the controlling variables and how
these will affect existing channel morphology in the identified reaches downstream of the dam.
Empirically characterize Susitna River sediment supply and transport conditions;
Assess channel and study site stability/change (1980s versus current conditions).
This study objective is critically important to the assessment of Project operational effects on
riverine habitats by assessing the potential for geomorphic change. This goal should be
achieved through conceptual and numerical modeling which is further described in AEA’s Fluvial
Geomorphology modeling PSP and in our study request under G-7 Modeling Magnitude and
Trend of Geomorphic Response.
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.
AEA Study Objective 4. Determine the likely changes to existing habitats through time and
space.
This objective is similar to our request to evaluate geomorphic stability and change (objective 6
in the Geomorphology study request). All of the data collection proposed in AEA’s PSP, in
addition to the data we request, will be used to understand the likely changes to existing habitat.
AEA proposes to calculate effective discharge for the Susitna River, similar to the methods
requested by the Service. This is important as quantification of the range of flows that transport
the most sediment provides useful information to assess the current state of adjustment of the
channel, and to evaluate the potential effects of altered discharge and sediment delivery to
channel behavior. This is a good example of study information that must be integrated with
other studies, specifically instream flow, for overall project analysis.
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For the lower river, the PSP describes a reconnaissance level assessment (by assessing
geomorphology and habitat via aerial photography). AEA 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 AEA and requested by the Service is
defined in Grant et al. (2003). 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. This will rely on the development of the hydraulic flow routing models (see
our comments on instream flow) and may require the extension of this modeling effort. The
decision process and threshold to extend the mapping, models, and more qualitative
assessments in the lower river must be described and should include the determining factor for
extension of these study components. 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.
The characterization of bed material mobilization will be necessary to populate sediment
transport models and to assess the likely geomorphic changes associated with reducing the
sediment supply, by trapping sediment behind the dam, and by altering the natural flow regime.
This information will be used by the Service to make instream flow recommendations under our
10(j) authority. A critically important product listed in AEA’s PSP is the calculation of effective
discharge for the pre- and post-project conditions, and the likely effects on channel morphology.
This is further described in section 5.8.4.4 of the PSP to assess geomorphic change in the
middle and lower rivers.
Literature Cited
Alaska Energy Authority (AEA). 2012. Proposed Study Plan Susitna-Watana Hydroelectric
Project FERC No. 14241. July 15, 2012.
Buffington, J. M., and D. R. Montgomery. 1999. A procedure for classifying textural facies in
gravel-bed rivers. Water Resources Research 35: 1903-1914.
Grant, G.E., J.C. Schmidt, and S.L. Lewis. 2003. A geological framework for interpreting
downstream effects of dams on rivers. AGU, Geology and Geomorphology of the Deschutes
River, Oregon, Water Science and Application 7.
Wolman, M.G., 1954. A method of sampling coarse river-bed material. Trans. Am. Geophys.
Union 35, 95 – 956.
U.S. Fish and Wildlife Service. 2012. Letter and study requests to Secretary Bose, Federal
Energy Regulatory Commission. May 31, 2012.
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5. Water Resources
5.9. Fluvial Geomorphology Modeling below Watana Dam Study
General Comments:
The AEA PSP stated goal for the Fluvial Geomorphology Modeling below Watana Dam Study is
“to model the effects of the proposed Susitna-Watana Hydroelectric Project on the fluvial
geomorphology of the Susitna River; with the Geomorphology study to assess the impacts of
the project on the dynamic behavior of the river downstream of the proposed dam, with
particular focus on potential changes in instream and riparian habitat.”
AEA proposes four questions to be answered by the fluvial geomorphology and geomorphology
studies:
Is the system currently in a state of dynamic equilibrium?
If the system is not currently in a state of dynamic equilibrium, what is the expected
evolution over the term of the license?
Will the Project affect the morphologic evolution of the Susitna River compared to pre-
Project conditions?
If the Project will alter the morphology of the river what are the expected changes over
the term of the license?
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.
Specific Comments by Subsection:
AEA Study Objective 1. Model channel formation processes in the Susitna River downstream of
the proposed Watana Dam site.
AEA describes three study components: 1) bed evolution model development and calibration; 2)
model existing conditions and with-Project conditions; and 3) coordination of model outputs.
This objective will provide operating flow analysis over a range of flows to assist the Service in
making recommendations regarding instream flow conditions for channel maintenance. In this
study request the applicant lists three factors in choosing appropriate geomorphology models:
1) the level of detail required to meet the overall study objectives; 2) the class, type, and regime
of flows that are expected to be modeled; and 3) the availability of necessary data for model
development and calibration. 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 1D movable boundary sediment transport model to address reach-scale issues and 2D
models to address local scale issues. Both of these should be tied back to effects on habitat by
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associated changes to geomorphic form and process. The 1D 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.
One of the models proposed for 1D 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.
The 2D 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 2D 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.
AEA Study Objective 2. Estimate the potential for channel change for with-Project operations.
The channel change associated with Project operations, assessed with the operating flow
analysis, will provide the Service with data to make operational recommendations to maintain
riverine habitats. AEA describes using the calibrated models to model existing and with-Project
conditions (5.9.4.2). The with-Project scenarios will be evaluated over a 50 year continuous
operating scenario. The scenarios should represent a variety of operational scenarios to
provide the Service with the full operating range from a “no Project” scenario to the current
proposal. This information must be coordinated with the other studies (see below).
Additional information 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.
AEA Study Objective 3. Coordinate with other studies to provide channel output data.
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.
In the Service’s study request the goal of the model coordination is to: “… provide necessary
output to the various other studies that will need to consider channel change. Early coordination
with the Instream Flow, Instream Flow Riparian, Ice Processes, Productivity, and Fish studies
will be conducted to inventory the information needed within those studies will become available
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with results of the bed evolution modeling and predicted changes in channel conditions for the
various Project scenarios.”
As previously recommended in our study requests and during TWG meetings we would like to
see how the results from the geomorphology study will be integrated into the instream flow
study to achieve the objectives that the Service requested in both the instream flow and
geomorphology study requests.
Literature Cited
Alaska Energy Authority (AEA). 2012. Proposed Study Plan Susitna-Watana Hydroelectric
Project FERC No. 14241. July 15, 2012.
Buffington, J. M., and D. R. Montgomery. 1999. A procedure for classifying textural facies in
gravel-bed rivers. Water Resources Research 35: 1903-1914.
Grant, G.E., J.C. Schmidt, and S.L. Lewis. 2003. A geological framework for interpreting
downstream effects of dams on rivers. AGU, Geology and Geomorphology of the Deschutes
River, Oregon, Water Science and Application 7.
Wolman, M.G., 1954. A method of sampling coarse river-bed material. Trans. Am. Geophys.
Union 35, 95 – 956.
U.S. Fish and Wildlife Service (Service). 2012. Letter and study requests to Secretary Bose,
Federal Energy Regulatory Commission. May 31, 2012.
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5. Water Resources
5.10 Ice Processes in the Susitna River Study
General Comments
May 31, 2012 the U.S. Fish and Wildlife Service (Service) filed a study request with FERC titled
Ice Processes in the Susitna River, with the stated goal to characterize and document ice
processes of the Susitna River and to use that information to analyze project effects on ice
formation, location, persistence, and spring breakup. Changes in the ice processes may directly
influence instream flows, habitat availability and quality, river and floodplain morphology,
vegetation, and water quality, all of which are important to fish. This study will be used to
predict the project’s effects on ice processes in the project area and will be integrated with other
studies to assess the how these effects will alter instream flow, winter time surface
water/groundwater exchange, fluvial and floodplain geomorphology and vegetation, riverine
habitat and quality of that habitat, and water quality in the Susitna River ecosystem. This
document is a review of the ice processes proposed study plan (PSP) provided by Alaska
Energy Authority (AEA) on July 15th within their broader Water Resources study plan (AEA
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 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.
During the August 17, 2012 technical working group meetings agencies 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.
At this meeting the applicant described two potential ice processes models, but did not describe
the data necessary to populate, calibrate and validate the models. It is not known if the
proposed models will have the ability to extrapolate to proposed winter operational flow
conditions well outside the natural flow regime to understand the effects of the project.
Regardless of the modeling method implanted, hydraulic routing and accurate determination of
discharge under ice cover requires direct measurement. 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).
The Service requested a review and summary of information from existing studies of cold-region
hydropower projects around the world that describe the effects of hydro operations on ice-
covered rivers. This request was meant to inform potential implications for the proposed project.
The PSP provides a general overview of river ice processes that would be applicable to a typical
northern river, citing textbook publications. In addition, ice observations and some key findings
from the 1980s studies are listed. Further on in the PSP, five ice modeling studies are
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referenced and the reader may interpret that the study would only produce a white paper
summarizing these five references.
We offer the following comments on the literature review:
A general overview of river ice processes should be presented with reference to the
study reach. River ice processes should be presented in a context relevant to the study
reach.
The literature review should provide more than a “white paper” summary of the five listed
modeling studies (refer to PSP Section 5.10.4.6). Consider expanding the review to
include international project sites (e.g. Northern European) and other large non-
hydropower instream infrastructure projects.
The review should provide greater insight into understanding river ice processes in the
context of the study reach with consideration of the following:
- Impacts of the project on river ice processes.
- Methods of analysis and tools used to understand and assess impacts of the
project on river ice processes, fish, and fish habitat.
The study of river ice processes invokes the use of terminology that may be unfamiliar to
some readers. Further, there is often a lack of consistency on the use and meaning of
river ice process terminology among authors with differing areas of expertise. To
illustrate, consider the following terminology: aufies and anchor ice; ice dams and ice
jams; frazil, slush ice, and snow ice; shore ice, shelf ice, and border ice; and, breakup
described as mild, severe, dynamic, thermal, eventful, or uneventful. The project would
benefit from a consistent use in terminology and a glossary of adopted river ice process
terms.
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 limitations of the physical processes and fish
studies may present difficulties for the agencies in making recommendations regarding
protection, minimization, and enhancement. Without adequate knowledge of project affects the
Service will require the project to operate along the natural flow regime; this would result in
recommendations that require operations to maintain stable winter flows.
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.
Specific Comments by Subsection
The following review of AEA’s Ice Processes Study Plan uses the structure of the plan’s stated
objectives and compares them to study request objectives to determine if the intent is met,
where improvements can be made, and which request objectives are not addressed.
AEA Study Objective 1. Document the timing, progression, and physical processes of freeze-up
and breakup during 2012-2014 between the Oshetna River confluence (River Mile [RM] 233.4)
and tidewater (RM 0).
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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.
AEA Study Objective 2. Develop a modeling approach for assessing ice processes in the
Susitna River.
The proposed winter operations will be an extreme alteration of the currently existing flow
regime, with associated effects to anadromous fish and their habitat. A detailed understanding
of the project effects caused by winter operations is necessary. If study results are not
adequate for the Service to determine project effects, then the study period will need to be
extended until an adequate understanding can be gained. If this is not accommodated, then the
winter project operations will need to be altered to mimic the natural flow regime (i.e. no load
following and baseloads within the range of the natural flows).
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.
The PSP emphasizes the application of a computational river ice process model. It is expected
that the adopted river ice process model will be a valuable assessment tool. However, it is
important to provide context to the adopted tool and clearly set out the expectations and
potential limitations of the adopted tool. It is recommended that the PSP outline the overall
methodology for analyzing project impacts. There may be merit it developing a conceptual
assessment framework where the model resides as a powerful tool within the framework. One
role of the framework would be to enable strategies for dealing with potential limitations of the
model, data, or general understanding of the nexus between river ice processes and related
processes. Specifically:
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 they similar or very different than current needs?); and, their limitations (what
limitations are we overcoming with the proposed model(s)?).
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)
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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”.
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.
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.
The PSP proposes to use an ice process model, CRISSP1D (or equivalent), to carry out winter
flow routing. Comments on the ability of this model to meet the study objectives listed above
are:
1. The use of one model to carry out both flow routing and ice 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.
2. Hourly time steps are feasible with CRISSP1D and even desirable from the ice process
modeling perspective due to the diurnal fluctuations in air temperature.
3. A one-dimensional flow model will not be able to simulate the effects of open leads if
they only occupy part of a channel width. If these locations are important due to
groundwater inflows, a secondary two-dimensional model should be considered to
provide more detailed simulations at selected sites.
4. In some instances, it may be appropriate to extend the 1D model results with very
judicious application to address 2D problems.
5. No mention is made of modeling the reservoir and upstream tributaries. Large changes
in flow rates can cause changes in reservoir levels that could affect water levels in
upstream tributaries. Ice process in these tributaries may also be affected by the ice
conditions in the reservoir. Has modeling of flow routing and ice processes within the
reservoir and upstream tributaries been considered and will it be included in the final
study plan?
6. It is important to be able to model the thermal regime of the reservoir including
characterization of: temperature variations; ice thickness; and ice-in / ice-out dates.
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:
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1. Generally the data collection approach is appropriate to meet the objectives.
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 2D model calibrations.
Review on the methodology for developing an appropriate tool or model is partially addressed in
the previous section. The following review comments are offered for additional consideration.
It is important to emphasize that physically-based, process models are recommended for
assessing project impacts. This basic principle behind the modeling effort warrants recognition
and explanation in the PSP. A valuable feature of using this approach is that, with suitable
analogues of the various river ice processes, we can reasonably extend their application to
assessing project impacts.
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.
The PSP would benefit from a plan outline of the proposed data collection program. The above
considerations do not represent a 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.
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AEA Study Objective 3. Calibrate the model based on existing conditions.
We agree that each of the models must be calibrated based on existing conditions. The data
necessary to adequately calibrate and test the models must be described, as discussed
previously. 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. Although AEA Study objective 3 is directed towards the ice
processes model, the calibration of the ice processes it is also true for the winter hydraulic flow
routing model. The calibration and then extrapolation of results from the ice processes model
will be used to predict winter load following operations effects downstream of the dam.
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.
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”.
AEA Study Objective 4. Determine the potential effect of various Project operational scenarios
on ice processes downstream of Watana Dam.
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.
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.
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AEA Study Objective 5. Determine the extent of the open water reach; and
AEA Study Objective 6. Determine the changes in timing and ice-cover progression and ice
thickness and extent.
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 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.
AEA Study Objective 7. Provide observational data of existing ice processes and modeling
results of post-Project ice processes to the fisheries, instream flow, riparian instream flow,
fluvial geomorphology, and groundwater studies.
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.
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.
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 as, “Ice processes
influence both the channel morphology and riparian vegetation. For example, ice can prevent
vegetation from establishing on bars by annually shearing off or uprooting young vegetation.
Similarly, ice can scour vegetation from the banks, increasing their susceptibility to erosion. In
both examples these influences affect channel morphology. Ice jams can also directly influence
the channel morphology by diverting flows onto floodplain where new channels can form,
particularly when the downstream water surface elevations are low, allowing the return flows to
headcut back into the floodplain. Ice can also move bed material that would normally not be
mobilized by rafting large cobbles and boulders. There will be close collaboration between the
Geomorphology and Ice Process studies to identify the key physical processes that interact
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between the two. Working together to analyze the conditions at the detailed study sites will be a
key part of this collaboration. A significant portion of the influences of ice processes on
morphology are directly related to their effects on riparian vegetation. Additionally, influences of
ice processes beyond the riparian vegetation issues that may be incorporated directly into the
fluvial geomorphology modeling may include:
Simulating the effects of surges from ice jam breakup on hydraulics, sediment
transport and erosive forces using unsteady-flow 2D modeling with estimates of
breach hydrographs.
Simulating the effect of channel blockage by ice on the hydraulic and erosion
conditions resulting from diversion of flow onto islands and the floodplain.
Use of the detailed 2D model output to assess shear stress magnitudes and patterns
in vegetated areas, and the likelihood of removal or scouring.
Use of the detailed 2D model output to assess shear stress magnitudes and patterns
in unvegetated areas, and the likelihood of direct scour of the boundary materials.”
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 the 2D geomorphic models during
winter conditions.
Literature Cited
Alaska Energy Authority (AEA). 2012. Proposed Study Plan Susitna-Watana Hydroelectric
Project FERC No. 14241. July 15, 2012.
Northwest Hydraulic Consultants Ltd (NHC). 2012. Alaska Department of Natural Resources
Topic 7 Ice processes and Winter Flow Routing Study Plan Review (DRAFT October 2012).
U.S. Fish and Wildlife Service. 2012. Letter and study requests to Secretary Bose, Federal
Energy Regulatory Commission. May 31, 2012.
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5. Water Resources
5.11. Glacial and Runoff Changes Study
General Comments:
The U.S. Fish and Wildlife Service (Service) has adopted and presents these comments as
provided by the National Marine Fisheries Service (NMFS) on the Alaska Energy Authority
(AEA) proposed study plan (PSP) for glacial and runoff changes as it purports to address in
part, NMFS’s request for a comprehensive study of Susitna River Project effects under
changing climate.
This PSP only partially addresses NMFS’ request entitled “Susitna River Project Effects under
Changing Climate Conditions.” It does not address the main objective of NMFS’ climate change
study request, which is expressed more fully in §1.3.1 of the request. In brief, the objective of
NMFS’ request is to assess the potential Project effects combined with impacts of climate
change on the Susitna watershed ecosystem in order that a project license can be properly
conditioned in anticipation of these changes.
The study plan is incomplete. It addresses some elements of NMFS’ study request, but other
elements are not addressed in this or any of AEA’s other PSPs. Because the proposed Project
is designed for long-term utility and is located in an area vulnerable to continued climate
change, it is necessary to understand the cumulative impacts from the project and climate
change in order to develop license conditions that protect anadromous fish species and their
habitat. Some climate change induced effects of the Susitna River and Susitna watershed
include continued warming of stream temperatures, reduction in permafrost affecting
groundwater storage and discharge and channel incision, and glacier melting and reduction of
summer flow. These climate-induced and project influenced changes in habitat would affect
fish in the Susitna River. Informing the likelihood of these events will allow NMFS, and the
Service, to make decisions on the effects that a dam would have if it were to block the passage
of fish from the upper watershed, where refugia from negative effects on habitat may persist.
Thus, NMFS seeks information from their requested climate study in order to inform our
decision of whether prescription of fish passage is needed. Without such an understanding of
climate change, project operations mistakenly would be considered as though future conditions
were to be static. The project license would be outdated from the outset.
NMFS, and the Service, seek the information specified in its climate change study request in
order to analyze the project effects, in the context of variable and changing climate conditions,
on NMFS and Service trust resources. As explained more fully in §1.3.4 of NMFS’ request, the
main reason for this analysis is to incorporate the results of current climate science into
comprehensive decision making, and provide information NMFS, and the Service, can use to
develop, and in turn FERC can incorporate into any license order it issues, appropriate and
efficiently tailored:
Federal Power Act (FPA) section 18 fishway prescriptions for passage of anadromous
fish;
FPA section 10(j) recommendations to protect, mitigate damage to, and enhance fish
and wildlife resources; and
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FPA section 10(a) recommendations to ensure that the project is best adapted to
comprehensive plans for developmental and non-developmental resources.
In order to fulfill their duties under the Federal Power Act and other relevant mandates, NMFS,
the Service, and FERC must obtain and apply the best available science, data and techniques
to assess the potential effects of the proposed project on riverine processes, fish, and fish
habitat. Applying recent advances in climate science, including scenario analysis and
projections, to project analysis will result in more accurate and informed resource decision
making (Brekke, 2009; Fowler 2007; Vicuna et al., 2010; Viers, 2011).
Recent advances in climate science and its application in other hydrologic risk analyses
underscore the need for FERC’s licensing process to utilize accurate predictions of the effects
of climate change on changes in glacial wasting and on the timing and availability of water in the
Susitna River. In the past, FERC has relied on historical data to evaluate project effects; in the
context of changing climate a broader approach is needed. However, the best available science
now includes the presently observed and projected future impacts of climate change on water
resources. Congress recently emphasized the need for a broader scope of understanding, by
directing the Secretary of Interior, via the SECURE Water Act, to coordinate with NOAA and its
programs to ensure access to the best available information on climate change [(§) 9503 (c)(4)
of the SECURE Water Act, (Pub.L. 111-11, Title IX, § 9501 et seq., Mar. 30, 2009, 123 Stat.
1329.)] stating, in part:
Congress finds that--
(1) adequate and safe supplies of water are fundamental to the health, economy,
security, and ecology of the United States;
(2) systematic data-gathering with respect to, and research and development of, the
water resources of the United States will help ensure the continued existence of
sufficient quantities of water to support--
a) increasing populations;
b) economic growth;
c) irrigated agriculture;
d) energy production; and
e) the protection of aquatic ecosystems;
(3) global climate change poses a significant challenge to the protection and use of the
water resources of the United States due to an increased uncertainty with respect to
the timing, form, and geographical distribution of precipitation, which may have a
substantial effect on the supplies of water for agricultural, hydroelectric power,
industrial, domestic supply, and environmental needs.
It is now considered routine for hydropower, dam and water management projects in the United
States and around the world to consider projections of climate variability and climate change in
project planning and operations (Viers, 2011), and FERC should do so here. In order that
FERC may fulfill its duties, AEA should provide the information NMFS has requested.
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
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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.
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 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).
FERC should also consider its responsibilities under the National Environmental Policy Act
when determining the need for information about potential climate change. In issuing any
license order, FERC should be informed about climate change’s effect on the Project and its
suitability, as well as how the project may affect trust resources already potentially compromised
by climate change. NMFS, with support from the Service, seeks assessment of the effects of
climate change on the Project and on the resources affected by the Project in order to
adequately prepare and support appropriate license terms and conditions, inform the need for
fishway prescription and to develop effective measures to protect, mitigate and possibly
enhance resources for which we have statutory responsibilities.
NMFS’ study request has demonstrated a reasonable nexus between Project operations and
effects on resources resulting in cumulative effects of the Project and climate change on
important habitat components such as water temperatures, groundwater patterns, timing of fish
migration, spawning, hatching and food availability. But to simplify the consideration of nexus,
NMFS offers this hypothetical example of a cumulative effect of the project and climate change
on the Services’ trust resources: Assume that, as projected, glacial recession and wastage
continues to the point where summer flows from ice melt are reduced and eventually lost.
Without the information NMFS has requested, FERC cannot determine to what extent the
natural partial velocity barriers to upstream passage of Chinook salmon would remain barriers to
fish passage, independent of the project. In other words, as glaciers melt and contribute less
water to summer high flows, lower flows in Devils Canyon might naturally allow more Chinook
salmon and possibly other species of salmon to swim upstream through the Canyon and access
now marginal habitat. Or, as stream temperatures continue warming, current summer rearing
habitat for juvenile salmon may become unsuitable causing species’ range to move to higher
elevations and/or further upstream. But without information about these possibilities, a license
order would likely be unable to account for it. Accordingly, the project could block a natural
wildlife response to climate change and create significant future effects unanticipated by a
license order based on conditions as they currently appear.
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AEA understands that water is the fuel for the proposed Project, and that the amount, timing
and variability of flows due to changes in glacial wastage have resulted in documented climate-
related changes in recent decades. Models that project future climate, and usually, change, are
readily available in currently in use across Alaska and northern latitudes as described in our
study request at §1.3.3 and 1.3.5.
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 analysis 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.
In particular, we are concerned about the failure to consider the detailed content of this study
request by FERC in its Scoping Document 2 (SD2), and the only partial adoption of the request
by AEA. In the SD2, FERC states that its common practice is to evaluate a range of flow
release alternatives that take into consideration both high and low water years and to condition
any license that may be issued to adaptively manage for these variations in water years. FERC
asserts that its practice sufficiently addresses NMFS concerns and study request. It does not.
NMFS study request addressed the limitations of FERC’s practice to analyze historic high and
low water years:
“The concept of a stationary environmental baseline with fluctuations (high and low
water years) around a relatively stationary mean (as previously used by FERC and other
regulators) is an outdated concept given the current level of scientific certainty of climate
change (Milly et al. 2008; Viers 2011). Given the current trends (described below in
1.3.4), there is need to document the environmental baseline of the project, and to
develop a realistic projection of the range of potential future trends in order to effectively
evaluate the impacts of the project on NMFS resources and allow NMFS to make
accurate conservation recommendations, license terms and conditions, and to develop
recommended protection, mitigation and enhancement measures to address likely
project effects.
Both precipitation and temperatures are projected to increase significantly, resulting in
an increase in evaporation and evapotranspiration. In addition, rather than snowpack
accumulating over the winter, increased temperatures will result in melting the snowpack
“storage.” The alteration of rain and snowfall timing and intensity, evapotranspiration
and groundwater and surface flows, translates into changes in the annual hydrograph
and potentially less water availability. Considering a static environmental baseline in
project planning will not capture these projected changes. These changes need to be
considered in project planning. Alaska’s freshwater resources are increasingly at risk
from climate change and preparing for this future is of escalating importance. Thus,
studies are needed to connect the trends and projected changes in climate to variables
needed for project planning.”
NMFS and the Service disagree with FERC’s suggestion that adaptive management can be
used for variations in water years for the reasons described in the study request and reiterated
above. Adaptive management could, more appropriately, be applied to climate change.
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Adaptive management is one way to address the multiple uncertainties in the future faced by
the Sustina project – not only climate change. However, an adaptive management framework,
including monitoring and experiments, must be built into the Project in the beginning (Gregory et
al., 2006) including the issues for which adaptive management is more or less likely to be a
viable option.
The Susitna project has characteristics that may make it a good candidate for using adaptive
management (in fact, DOI uses the case of re-licensing of the Tallapoosa dam as a case study),
but has other characteristics that may make it more difficult. In a recent review by Gregory et al
(2006), challenges to an active, experimental, adaptive management approach include:
“(a) designing statistically powerful experiments capable of discerning external effects and
effectively considering issues of duration (i.e., using titration designs),
(b) articulating all the costs, benefits, and risks of alternative experimental and non-
experimental management plans, and again
(c) ensuring that sufficient staff capacity and institutional flexibility exist.”
One of the examples presented by Gregory et al. (2006), as more complex and difficult, involves
climate change and a multi-objective project of land planning. Adaptive management does not
relieve the need for adequate baseline information in an original licensing proceeding - and in
fact requires it. Adaptive management is a decision-making process that promotes flexible
decision making that can be adjusted in the face of uncertainties as outcomes from
management actions and other events become better understood.
Careful monitoring of these outcomes both advances scientific understanding and helps adjust
policies or operations as part of an iterative learning process. Adaptive management also
recognizes the importance of natural variability in contributing to ecological resilience and
productivity. It is not a “trial and error” process, but rather emphasizes learning while doing.
Adaptive management does not represent an end in itself, but rather a means to more effective
decisions and enhanced benefits. Its true measure is in how well it helps meet environmental,
social and economic goals; increases scientific knowledge; and reduces tension among
stakeholders. It is vital that adaptive management is the paradigm for both pre-licensing study
plans and post-licensing conditions for long-term monitoring.
To be effective, adaptive management requires a deliberate, intentional process, including set
up and iterative phases, and within these, decision making, post-decision monitoring,
assessment of monitoring data, learning and feedback, and institutional learning, according to
Williams and Brown (2012) in a recent DOI guidebook to adaptive management. Monitoring and
experiments must be built into the project in the beginning (Gregory et al., 2006), and they lay
out a set of criteria that suggest problems for which adaptive management is more or less likely
to be a viable option. They also point out the dilemma of “clearly documenting what we do not
know as the basis for experimenting with valued and, in many cases, fragile ecosystems.”
The information on climate change that NMFS has requested is necessary to prior to FERC
determining whether the license order should include adaptive management measures. NMFS
and the Service recommend FERC order development of an adaptive management approach
for all aspects of decision making associated with the proposed Study Plan and license
application decisions.
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Specific Comments by Subsection:
5.11.4.1. Review Existing Literature.
This literature review should be expanded to include a review of climate projections and glacial
regions, permafrost changes, and other existing research relevant to the impacts of climate
variability and change on the water dependent resources of the region. This is because the
current literature review is limited to physical processes affected by climate change, and does
not cover the reasonably foreseeable cumulative effects of those changes on the natural
resources that will also be affected by project operations.
5.11.4 Study methods.
NMFS and the Service appreciate that AEA 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. Because the PSP is confusing where it discusses study
methods, NMFS and the Service request clarification or perhaps clarification of the following
details.
The study proposes to analyze changes in glacial systems, temperature, and precipitation, and
their impacts on watershed hydrology, including future runoff projections. The changes in runoff
will be translated into time series data summarizing changed hydrology and temperature
dynamics in the Susitna basin.
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.” At a minimum, potential effects
of climate change should be evaluated on a relative basis (as in the Lake Powell Pipeline
study), with effects on stream flow and water supply associated with climate change being
applied to all interrelated and affected Susitna studies and project alternatives. For example,
changes in stream flow associated with climate change should be included for each study
planned for the project that would be used by NMFS and the Service in making fish passage
determinations and prescriptions and its conservation recommendations pursuant to §§18, 10(a)
and 10(j) of the FPA and the Essential Fish Habitat provisions of the Magnuson-Stevens Act
§305(b)(2), 16 U.S.C. 1855(b)(2). This is true for each project alternative that may be
assessed. Including effects of climate change in all potential studied resource areas that are
likely to be affected by project construction and operations studies will result in a relative
comparison between alternatives where effects of climate change apply equally to each
alternative.
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5.11.4.2. Develop a Modeling Framework
From the PSP, it is unclear how future hydrologic simulations will be developed. The PSP
mentions forcing using “Max Planck Institute for Meteorology ECHAM5 model (3 hour time
steps) and SNAP (daily) models. The SNAP dataset includes the years 1980-2099, with data
downscaled to 2 km grid cells. Future projections from SNAP are derived from a composition of
the five best ranked General Circulation Models (out of 15 used by the Intergovernmental Panel
on Climate Change [IPCC]) models for Alaska. Based on how closely the model outputs
matched climate station data for temperature, precipitation, and sea level pressure for the
recent past, their individual ranking order for overall accuracy in Alaska and the far north was as
follows: 1) ECHAM5, 2) GFDL21, 3) MIROC, 4) HAD, and 5) CCCMA.” The PSP proposed to
use a five-model composite from these and three emissions scenarios.
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 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.
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.
Literature Cited
Brekke, L.D., Kiang, J.E., Olsen, J.R., Pulwarty, R.S., Raff, D.A., Turnipseed, D.P., Webb, R.S.,
and White, K.D., 2009, Climate change and water resources management—A federal
perspective: USGS Circular 1331, 65 p. Available at http://pubs.usgs.gov/circ/1331. Accessed
25 May 2012
Fowler, H.J., Blenkinsop, S., and Tebaldi, C., 2007, Review: Linking climate change modeling to
impacts studies—Recent advances in downscaling techniques for hydrologi¬cal modeling:
International Journal of Climatology, v. 27, p. 1547–1578.
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5. Water Resources
5.12. Mercury Assessment and Potential for Bioaccumulation Study
General Comments:
This Alaska Energy Authority (AEA) proposed study plan (PSP) was developed in response to
the U.S. Fish and Wildlife Service’s (Service) concerns about the risks posed by mercury to fish-
eating wildlife in the project area, as detailed in our study request entitled, “Piscivorous Wildlife
and Mercury – Risk Assessment Study”. We are encouraged that AEA is planning to conduct a
study to predict how project operations may affect future mercury levels in the reservoir’s
sediments, water and biota. AEA’s PSP addresses some, but not all, aspects of our study
request. In these comments we identify which study request needs have not been met, and
offer suggestions for improvement of the AEA’s study plan. First we present over-arching
concerns, and then follow with several technical comments related to the PSP.
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 method used for predicting potential impacts to water quality conditions in both the
proposed reservoir and the riverine portion of the Susitna basin.”). Rather, 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.
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.
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 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.
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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.
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 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.
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, 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.
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Baseline mercury levels should be determined in fish-eating birds from the study area, by
measuring mercury in feathers. This objective is not contained within any Applicant PSP.
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). The PSP does include an objective to collect and analyze mercury
levels in fur samples from river otters and mink (in PSP 8.11, “Study of Aquatic Furbearer
Abundance and Habitat Use). However, it does not include this component for avian piscivores.
Bird feathers are an excellent tissue for determining mercury body burden in birds, and feathers
can be collected non-invasively. Please refer to section 1.6.3 of our study request for a
complete discussion of this topic. It is very important to document baseline mercury levels in
fish-eating birds in the study area, for at least two reasons. First, baseline mercury levels are
needed as a foundation for interpreting future feather mercury levels after project operations
begin. Baseline feather mercury values are also needed to determine the degree of risk posed
by additional mercury inputs to the system. Risk assessors need to know how much
“assimilative capacity” exists in fish-eating birds in the project area. Are current body burdens of
mercury close to levels causing toxicity, or can the birds be exposed to additional mercury
inputs from the project without experiencing toxic effects?
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.
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 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. The ingested mercury levels should be compared to toxic levels, based on
species-specific data from the scientific literature, to assess project-related risks to piscivorous
wildlife in the study area.
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Continuous monitoring.
A one-time, late-summer fish survey is inadequate to monitor dynamic background mercury
concentrations. 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.
Specific Comments by Subsection:
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).
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).
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, 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.
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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.
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
Literature Cited
Bloom, Nicholas S. 1992. On the methylmercury content of fish and marine invertebrates. Can.
J. Fish Aquatic Sci. 49:1010.
Mailman, M., L. Stepnuk, N. Cicek, and R. A. Bodaly. 2006. Strategies to lower methylmercury
concentrations in hydroelectric reservoirs and lakes: a review. Science of the Total Environment
368:224–235.
Porvari P. & Verta M. 1995. Methylmercury production in flooded soils: a laboratory study.
Water Air Soil Pollut. 80: 765–773.
St. Louis, V. L., J. W. M. Rudd, C. A. Kelly, R. A. Bodaly, M. J. Paterson, K. G. Beaty, R. H.
Hesslein, A. Heyes, and A. R. Majewski. 2004. The rise and fall of mercury methylation in an
experimental reservoir. Environmental Science and Technology 38:1348–1358.
Verbrugge, Lori A. 2007. Fish consumption advice for Alaskans: A risk management strategy to
optimize the public’s health. State of Alaska Epidemiology Bulletin Vol. 14 No. 4, 39 pgs. At:
http://www.epi.hss.state.ak.us/bulletins/docs/rr2007_04.pdf
U.S. Fish and Wildlife Service. 2012. Letter and study requests to Secretary Bose, Federal
Energy Regulatory Commission. May 31, 2012.
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6. Instream Flow Studies: Fish, Aquatics, and Riparian
6.5. Fish and Aquatics Instream Flow Study
General Comments:
On May 31, 2012, U.S. Fish and Wildlife Service (Service) filed a study request with FERC
entitled “Susitna River Instream Flow and Habitat Utilization”. The stated goals of the study
request are to: (a) characterize the existing flow regime and its relationship to riparian and
aquatic habitats and organisms; (b) use this information to quantify potential changes to aquatic
and riparian ecosystems due to Project operations over the initial licensing period; and (c)
determine effects of the Project on fish, in order to prescribe fishways and recommend
mitigation needed to conserve fish populations of the Susitna watershed. In contrast to the
Service’s goal, Alaska Energy Authority’s (AEA) Instream Flow Proposed Study Plan (PSP) goal
is to “provide quantitative indices of existing aquatic habitats and the effects of alternate Project
operation scenarios”. The intent of AEA’s goal is not clear and the PSP lacks the specificity
needed to isolate and guide the characterization of fundamental ecological relationships
underpinning the river’s floodplain ecosystem. Changes (losses of habitat) to the floodplain
ecosystem cannot be addressed through indices of existing habitat. The AEA study plan must
characterize the natural flow regime that creates and maintains habitats. The ability of AEA to
quantitatively predict changes/ losses of habitat important to the production of species
dependent upon the Susitna River floodplain ecosystem is necessary to specifically address
agencies’ resource management goals.
USFWS Study Request
In the Service’s Instream Flow and Habitat Utilization Study submittal, we requested hierarchical
habitat mapping, fish distribution surveys, the characterization of microhabitat utilization
patterns, and flow-habitat modeling to predict Project impacts. The Service requested a
hierarchal nested habitat mapping (e.g., Frissel et al. 1986) framework to structure fish
distribution surveys, the instream flow study and physical process studies.
In addition, we requested fish distribution surveys within the habitat mapping framework to
assess the full lateral and longitudinal profile of seasonal fish distribution, life stage periodicity,
and identification of micro-habitat criteria that are influential in fish habitat site selection.
The Service also requested that site-specific habitat criteria 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. We stated the need
to determine what criteria are important to fish habitat site/suitability and selection before we
can choose an appropriate flow-habitat model.
Although the Service has participated in the AEA technical work group (TWG) sessions to work
through these issues, and some accommodations have been verbally expressed to meet the
Service’s study request, further collaboration is needed to ensure that AEA’s instream flow
study plan is amenable to the Service’s request. We have not yet had the opportunity to review
the most recent draft revised study plan to determine if our issues have been adequately
addressed.
Study Duration
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.
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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).
Habitat-flow relationships should also be developed over a minimum temporal scale to address
the 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.
Study Plan Integration
During the August 16, 2012 technical working group meeting NMFS, USFWS and other
attendees requested a more detailed study frame work from AEA to gain understanding as to
how the individual studies will be integrated to demonstrate baseline vs. Project- related effects.
AEA has made some headway toward this issue by drafting figures depicting study plan
interrelationship and interdependencies. The Service has not yet had time to fully vet these
figures and cannot comment on their completeness at this time.
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.
Each study component should have clear objectives and methods. Along with the study
integration, AEA must state what each study can and will determine, and the degree of relative
associated uncertainty in each study component. In other words, AEA must demonstrate how
sampling protocols will yield samples that are representative of the full diversity of aquatic
habitat. Each study component should explain the expected representativeness (spatial and
temporal), precision, and accuracy of data results and model output calculations. If the study
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component is dependent on, or supplies another study then the uncertainty analysis must take
that into context to report cumulative uncertainty statistics. For example, an assessment of
Project operational effects on overwintering fish will rely on an understanding of winter habitat
utilization and variables that influence habitat utilization (biologic understanding) and on the
winter hydraulic flow routing and water quality models, which will rely on results from ice
process modeling. It is unclear how the associated additive and cumulative error of each of
these study components is proposed to be quantified. Also unclear, is the degree of certainty
surrounding the analysis of the resulting integration of Project-effects.
Alternative Instream Flow Tools/Methods
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).
The requested natural flow regime characterization is necessary to consider the ecological
consequences of altering one or more flow parameters under the Project’s proposed operating
schedule (Richter et al. 1998). If the inter annual variability of the hydrograph is eliminated or
altered, the ecological function of the Susitna River is invariably altered (Trush et al. 2000). The
general and specific characterization is critical as the proposed operations may effectively
reverse the natural hydrograph of the Susitna River substantially increasing winter base flows,
and reducing summer flows.
Existing hydrologic data for the Susitna Watershed has been summarized by MWH (2011),
including results from stations operated by the USGS in the Susitna River watershed. Historic,
current, and proposed Susitna River watershed gages are summarized in (Table 1) of MWH
(2011). The USGS has used these gages with the adjoining Little Susitna watershed, to
generate a combination of measured and synthetic streamflows for a 63 year period from 1949
through 2011 (USGS, in press 2012).
The characterization of the Susitna River period of record will use the existing data, updated
annually with the addition of new information and gages. The characterization of the natural
flow regime (Lytle and Poff 2004; Poff et al. 1997) of the Susitna River should include the
magnitude, frequency, duration, timing and rate of change of hydrologic conditions; including
large and small floods, and high and low flows (Assani et al 2010; Bragg et al. 2005). High,
median, and low flow year statistics should be summarized. This characterization will provide
baseline conditions and form the basis for setting flow regime targets (Bragg et al. 2005) and
resource management objectives.
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.
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The use of environmental flow methods that are based on the attribution of seasonal ecological
flow components and statistical analysis of the natural flow regimen requires the assessment of
fish habitat utilization and hydrologic connectivity. Some aquatic habitats important to fish are
seasonal and some are perennial. Interactive use of thresholds of hydrologic connectivity and
statistical characterization of the natural flow regime can yield the creation of seasonal habitat
series.
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.
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.
Specific Comments by Subsection:
AEA Study Objective 1. Map the current aquatic habitat in mainstem and lateral habitats of the
Susitna River affected by Project operations.
The initial subdivision of habitat mapping proposes to occur at a macro-habitat level consistent
with those of 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).
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, 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.
During the September 14, 2012 TWG meetings, an approach to instream flow site selection was
presented by AEA. In AEA's PSP for instream flow the idea of “intensive study reaches” (now
referenced as “focus areas”) was proposed conceptually to examine physical processes at
“representative” habitats” (referenced on page 8 of this same document for the list of
representative habitats). The intended purpose of selecting specific sites for focused and
overlapping studies is to gain an understanding of physical processes at “representative”
locations, allowing for covariant analysis of Project-effects on these processes and
subsequently on fish and their habitats. During the TWG meeting, selected sloughs from the
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1980s studies were proposed by AEA as focus areas. The Service expressed concern with the
proposed approach to study site selection. The 1980s approach did not use the hierarchical
nesting of habitats and therefore, did not determine the habitat criteria influential to fish habitat
site selection. During the 1980s studies, only utilization functions for water depth and velocity, or
depth and substrate were captured. 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.
Secondly, 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 habitats, studied at
multiple scales, including macro-, meso- and micro-habitat scale.
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
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.
We encourage AEA continue to work in collaboration with agencies and stakeholders to develop
a scientifically robust study site selection methodology that addresses resource concerns.
AEA Study Objective 2. Select study sites and sampling procedures to measure and model
mainstem and lateral Susitna River habitat types.
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. The
general process for habitat-specific model development is to use the spatial habitat mapping
effort to select transects/study segments with representative habitat conditions based on
channel morphology and major habitat features. AEA also proposed selecting additional study
“focus areas” to describe distinct habitat features such as groundwater areas, spawning and
rearing habitats, overwinter habitats, distinct tributary mouths/deltas, and potential areas
vulnerable to fish trapping/stranding (AEA 2012, 6.5.4.5).
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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 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.
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.
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. Potential candidates for this may include Kosina Creek, and Portage and Indian
Creeks. 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 habitat from multiple consecutive years of utilization information starting in
2012. This will likely require additional sites to be selected at the conclusion of the 2013 studies
to be implemented in 2014.
AEA Study Objective 3. Develop a hydraulic routing model that estimates water surface
elevations and average water velocity along modeled transects on an hourly basis under
alternate operational scenarios.
NMFS submitted an independent study request for hydraulic flow routing because the routing
model and associated data is the basis for cohesive understanding of many of the instream flow
modeling efforts. The Service supports NMFS in the study request for flow routing, and the
specific objectives contained within. An understanding of Project operation effects on instream
flow from the dam downstream is necessary to understand Project impacts to habitat of fish and
other aquatic organisms within the river system. NMFS May 31, 2012 study request, Susitna
River Flow Routing Study Request, has four objectives:
1. collect instream flow data throughout all seasons to characterize instream flow and
develop a flow routing model;
2. develop and calibrate an ice free period flow routing model that is capable of modeling a
range of operating conditions and scales (hourly, daily, weekly, seasonally);
3. develop and calibrate a winter flow routing model that incorporates ice effects that is
capable of modeling a range of operating conditions and scales (hourly, daily, weekly,
seasonally); and
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4. inform and integrate with other studies the Project operation effects on instream flow in
the reservoir and downstream of the Project.
Currently, the number of discharge measurements and location of discharge measurement to
develop and calibrate the winter hydraulic flow routing model is not well described within AEA’s
PSP. The natural winter flow regime is stable after ice-up until break-up with very little flow
fluctuation relative to the ice-free period. Winter hydraulic flow routing efforts will rely on the ice
processes study to incorporate changes to ice cover under Project operations. A detailed
description of how that data will be delivered and incorporated into the hydraulic flow-routing
analysis is still needed. Also needed is an analysis of the applicability of winter hydraulic flow
routing to assess effects of Project operations to fish and their habitat. Winter ice cover and ice
processes are significant regulators of winter habitats. Because ice cover and thickness will
affect the hydraulic roughness and discharge in the river, it is necessary that discharge
measurements appropriately replicate a number of the cross-sections used in the hydraulic flow
routing models and over a range of flows to allow for development of winter ice processes and
flow routing models that will be relevant to assess Project effects on overwintering fish and their
habitat. Additional discharge measurements may be necessary at the USGS gage locations.
Model sensitivities, assumptions and limitations should be thoroughly described to allow
transparency and accuracy of results. A sensitivity analysis should also be conducted (Turner et
al. 2001; Steel et al. 2009).This is important because model results may be used to inform
Section 18 (Federal Power Act) decision-making processes related to potential Project impacts
to fish and wildlife resources and their habitats. The winter hydraulic flow routing will also
incorporate a water quality component that will project downstream changes to flow (timing,
quantity, and water quality).
AEA Study Objective 4. Develop seasonal, site-specific Habitat Suitability Curves (HSC) and
Habitat Suitability Indices (HSI) for species and life stages of fish selected in consultation with
licensing participants. Criteria will include observed physical phenomena that may be a factor in
fish preference (e.g., depth, velocity, substrate, embeddedness, proximity to cover, groundwater
influence, turbidity, etc.). If study efforts are unable to develop robust site-specific data,
HSC/HSI will be developed using the best available information and selected in consultation
with licensing participants.
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.
The objective of the HSI and HSC (micro-habitat utilization) study component is to develop
robust site-specific criteria related to fish habitat site-selection. Habitat suitability indices (HSI)
and criteria (HSC) should come from an assessment of environmental criteria (physical,
chemical, and biological) that are influential to fish distribution in the Susitna River for each
species and life stage. Fish surveys need to be conducted throughout their spawning
distribution and well outside their spawning distribution (Connor et al 2003) in order to assess
the ecological relevance of criteria. Once the relevance of the criteria is demonstrated, curve
development may proceed. The Service considers the assessment of habitat influential to fish
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habitat site-selection, to be a specific and necessary objective of the Instream Flow and Habitat
Utilization study request.
For example, some fish species demonstrate significant population variability in response to
environmental heterogeneity. Ruff et al (2011) showed that thermal heterogeneity in an Alaskan
sockeye stream promotes spatial and temporal variability in spawning sockeye populations.
Because such spatial and temporal variability is also accompanied by variability in traditional
habitat suitability criteria (e.g. water depth and velocity; substrate size), it is important that all the
environments supporting each target species and life stage are surveyed. This is necessary for
statistical discernment of habitat criteria that are influential to habitat selection.
Some fish are known to move great distances or utilize specific habitats on a seasonal basis. As
an example Alaskan burbot (Lota lota), in glacial systems, can move extreme distances in
association with spawning (Breeser et al 1988). Juvenile salmon that seasonally inhabit shallow
margin and off-channel floodplain habitats, where they find important access to terrestrial inputs
(Eberle and Stanford 2010), serve as another important example of seasonal movements and
habitat use patterns. It is important that surveys be conducted with sufficient replication in both
space and time, such that the seasonal distributions of important species and life stages are
adequately surveyed. Assessment of criteria influential to habitat selection must also be
conducted in all seasons and at all representative flow levels.
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 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.
The AEA study plan describes an order of preference for information used to develop HSI/HSC
(micro-habitat utilization):
1. new site specific data collected for selected target species and life stages (seasonally if
possible (e.g., winter));
2. existing site specific data collected from the Susitna River during the 1980s studies;
3. site specific data collected from other Alaska rivers and streams; and
4. HSC curves, data and information from other streams and systems outside of Alaska.
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
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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).
In addition to collecting environmental information it is necessary to consider behavioral habitat-
use strategies of juvenile fish used to minimize risk of predation. Behavioral studies are
becoming increasingly important in assessing impacts to aquatic species as a result of
proposed hydro projects in both the marine and freshwaters. Lovtang (2005) found that juvenile
Chinook would rarely be found in mid-channel during the day but would be found in mid-channel
at higher abundance at night, independent of water temperatures, suggesting that the fish were
using a strategy to minimize predation. The tendency for salmon to return to their natal site for
breeding leads to reproductive isolation, in space and time. It also leads to local adaptation to
the local spawning and incubation environment (Doctor and Quinn 2009). More specifically,
spawning salmon are thought to select redd sites based on physical variables important to the
completion of their intra-gravel life stages (Montgomery et al. 1996; Quinn 2005). Temperature
during incubation has been demonstrated as one variable that is important to the distribution of
spawning salmon (Connor et al. 2003). In fact, variability in temperature, even within the same
stream can lead to genetically distinct populations that spawn in distinct physical environments
(Ruff et al. 2011). Habitat utilization functions are not transferrable between these populations
because the variability in spawning sites is too great.
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.
AEA Study Objective 5. 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):
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.
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
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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 for use in forecasting the environmental
impact of the proposed Project.
For example, burbot (Lota lota) is an important sport and subsistence fish species inhabiting the
main channel of the Susitna River. Burbot are known to spawn in association with undercut and
hollow banks, and the hydraulic micro-habitat associated with these habitat features, where it
has been studied, has been demonstrated to be of no relevance to the selection of these
features for spawning (Mouton et al 2012). If this general pattern holds true for burbot spawning
in the Susitna River, traditional hydraulic habitat modeling (i.e., PHABSIM) will not be an
appropriate model to forecast burbot habitat associations brought about by the proposed
Project. Similarly, hydraulic habitat data collected by USGS on side sloughs of the nearby
Matanuska River (Curran et al 2011) demonstrate that sockeye and chum salmon select
spawning sites without regard to water depth and velocity. This would make PHABSIM, or any
other traditional hydraulic habitat modeling approach an inappropriate tool for these settings.
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.
We also question whether the two-year study period is adequate to develop robust models with
relevant site-specific data. The purpose of this objective should be to represent the analysis of
Project effects on ecological relevant metrics for fish and aquatic ecosystems.
The Service appreciates the plan to use integrated aquatic habitat models that produce a time
series of data for a variety of biological metrics. AEA lists several of these metrics; and each of
these should be clearly linked to ecological significance. 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). This frame work will result in the development of a series of
flow sensitive models that will be able to translate effects of Project operations on the riverine
processes and biological resources.
In our study request (May 31, 2012), the Service outlined an integration framework to include all
riverine study components. This integration of the following components is necessary for
resource management agencies to assess Project-effects on fish and their habitat:
1. Instream Flow routing – The foundation of riverine processes studies depends on the
Susitna River flow routing models (HEC-RAS, CRISSP1D) that will provide hourly flow
and water surface elevation data at numerous locations longitudinally distributed
throughout the length of the river extending from RM 184 downstream to RM 75 (about
23 miles downstream from the confluence with the Chulitna River).
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2. Water Quality – This model/study, incorporating flow routing, will provide analysis on
flows necessary to maintain stream temperature, turbidity, and other water quality
indices within a biologically relevant range for aquatic species, using the baseline
information as targets.
3. Geomorphology – Model/study will provide analysis/constraints on flows important to
geomorphic processes that form/maintain fluvial morphology and vegetation (including
riparian, floodplain and woody debris recruitment functions).
4. Riparian/floodplain function – This model/study will provide an analysis of flows
necessary to maintain floodplain function and riparian plant community composition. This
study will be directly informed by both the instream flow and groundwater studies.
5. Surface/groundwater interaction – This study/model will analyze the effect of Project
operations on the exchange timing, quantity, and quality. This will inform/analyze the
instream flow needs to sustain groundwater interaction necessary to sustain habitat
quality and quantity.
6. Ice processes – This model/study will provide analysis and identify constraints on flows
important to ice freeze-up, ice thickness, persistence, and breakup. The results will
inform other studies and winter time instream flow needs, including a description of
winter time load following effects.
7. Aquatic habitat models - As described in study component ISF-6. If specific habitat
models are not successful in identifying Project effects on habitat and suitability for
specific species, then alternative methods may need to be considered including studies
of population dynamics and river productivity.
8. Passage/connectivity – This study will encompass accessibility of flow-dependent
riverine habitat types throughout the Project area, including tributary confluences; and
Devil’s Canyon and above.
9. Climate – The framework will incorporate climate variability and climate change
projections to assess the cumulative effects of Project operations in consideration of
PDO and ENSO climate variation and longer term climate change (the anticipated life of
the project – at least 100 years) that are expected to continue to change the hydrograph
and water quality, among the many variables influenced by climate change.
10. Biological Cues – Behavioral, population, community, and ecological studies relative to
fish distribution, relative abundances, timing, river productivity, and the trophic
interactions of the biotic and physical environment.
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. The results
of the operations analysis will be used in the comparative framework 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.
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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 would be provided to resource agencies. These include:
comparisons of habitat quantity and quality (e.g., habitat exceedance plots)
ramping rates (e.g., changes in flow versus time);
juvenile fish stranding/trapping;
habitat sustainability (effective habitat analysis); and
distribution and abundance of benthic macro-invertebrates under alternative
operational scenarios.
The Service recommends that AEA develop integrated aquatic habitat models that produce a
time series of data for biological metrics under existing conditions and alternate operational
scenarios. These metrics include:
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.
AEA Study Objective 6. Evaluate existing conditions and alternate operational scenarios using
a hydrologic database that includes specific years or portions of annual hydrographs for wet,
average and dry hydrologic conditions and warm and cold Pacific Decadal Oscillation (PDO)
phases.
The Service appreciates the work product “tabular summaries of selected IHA-type statistics”
and looks forward to working with AEA to develop this list relevant to Susitna River
hydrography. The Service’s study request includes objectives to characterize the natural flow
regime of the Susitna River and tributaries in the Project area and to identify, characterize, and
integrate the timing, quantity and function of instream flow to riverine processes. This will
require characterization of the relationship between the Susitna River flow regime and climatic
PDO. The Service appreciates the description of the various IHA statistics proposed, and
emphasizes the need to examine hourly rate and frequency of change for winter flow conditions,
to compare to the proposed operations.
AEA Study Objective 7. Coordinate instream flow modeling and evaluation procedures with
complementary study efforts including riparian (Section 6.6), geomorphology (Section 5.8
and 5.9), groundwater (Section 5.7), water quality (Section 5.5), fish passage (Section 7.12),
and ice processes (Section 5.10). If channel conditions are expected to change over the
license period, instream flow habitat modeling efforts will incorporate changes identified and
quantified by riverine process studies.
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
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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 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.
AEA Study Objective 8. Conduct a variety of post-processing comparative analyses derived
from the output metrics estimated under aquatic habitat models. These include (but are not
limited to):
juvenile and adult rearing;
adult holding/adult in-river residence time;
habitat connectivity;
spawning and egg incubation;
juvenile fish stranding and trapping;
ramping rates; and
distribution and abundance of benthic macro-invertebrates.
This objective should provide a comparative temporal and spatial analysis of riverine process
studies and model results for a range of alternative operations. But 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. AEA’s study plan includes riverine processes in
its proposal but it is unclear how they will be integrated and at what habitat scale. The issue of
scale is of critical relevance to fish and fish habitat
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.
Literature Cited
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habitat classification: viewing streams in a watershed context. Environmental management
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Holm C. C., J. D. Armstrong, D. J. Gilvear. 2001 Investigating a major assumption of predictive
instream habitat models: is water velocity preference of juvenile Atlantic salmon independent of
discharge? Journal of Fish Biology. 59: 1653-1666.
Lovtang, J.C. 2005. Distribution, Habitat Use and Growth of Juvenile Chinook Salmon in the
Metolius River Basin, Oregon. MSc Fisheries Science. Oregon State University.
Matthews, R. and Richter, B.D. 2007. Application of the indicators of hydrologic alteration
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Mims M. C. and J. D. Olden. 2012. Life history theory predicts fish assemblage response to
hydrologic regimes. Ecology 93(1), pp. 35-45.
Montgomery, D. R., Abbe, T. B., Peterson, N. P., Buffington, J. M., Schmidt, K. M., and J.D.
Stock. 1996. Distribution of bedrock and alluvial channels in forested mountain drainage basins.
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Mouton, A.M., A. Dillen, T. Van den Neucker, D. Buysse, M. Stevens. J. Coeck. 2012. Impact of
sampling efficiency on the performance of data-driven fish habitat models. Ecological Modeling
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MWH. 2011. Watana Hydroelectric Project: Susitna Watershed Historical Hydrology. Technical
Memorandum No. 3, Alaska Railbelt Large Hydro Engineering Services. Prepared for Alaska
Energy Authority by MWH, Bellevue Washington, June 1, 2011.
Olden, J.D., and N.L. Poff. 2003. Redundancy and the choice of hydrologic indices for
characterizing streamflow regimes. River Research and Applications 19:101-121.
Pichon, C. L., G. Gorges, P. Boet. 2006. A spatially explicit resource-based approach for
managing stream fishes in riverscapes. Environmental Management 37(4):322-335.
Poff, N.L., J.D. Allen, M.B. Bain, J.R. Karr, K.L. Prestegaard, B.D. Richter, R.E. Sparks, and
J.C. Stromberg. 1997. The Natural Flow Regime. BioScience, V.47, No. 11, 769-784.
Poff, N.L. and J.K. H, Zimmerman. 2010. Ecological responses to altered flow regimes: a
literature review to inform environmental flows science and management. Freshwater Biology
55:194-20.
Pollock, Michael M., George Press, Timothy J. Beechie, and David R. Montgomery. 2004. The
Importance of Beaver Ponds to Coho Salmon Production in the Stillaguamish River Basin,
Washington, USA. North American Journal of Fisheries Management 24:749-760
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Stanford, B.R. Boer, and T. J. Beechie. 2008. Hydrologic spiraling: the role of multiple
interactive flow pathways in stream ecosystems. River Research Applications 24: 1018-1031.
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discontinuum. Freshwater Biology. 47:641-660.
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Washington Press.
Richter, B.D., J.V. Baumgartner, J. Powell, and D.P. Braun. 1996. A Method for Assessing
Hydrologic Alteration Within Ecosystems. Conservation Biology 10:1163-1174.
Richter, B.D, J.V. Baumgartner, R. Wigington, and D.P. Braun. 1997. How Much Water Does a
River Need? Freshwater Biology 37, 231-249.
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Ruff, C.P., D.E. Schindler, J.B. Armstrong, K.T. Bentley, G.T. Brooks, G.W. Holtgrieve, M.T.
McGlauflin, C.E. Torgersen, J.E. Seeb. Temperature-associated Population Diversity in Salmon
Confers benefits to Mobile Consumers. Ecology, 92(11), 2073-2084.
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6. Instream Flow Studies
6.6. Riparian Instream Flow Study
General Comments:
The U.S. Fish and Wildlife Service’s (Service) 31 May 2012 study request entitled Instream
Flows for Floodplain & 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.”
Many of the PSPs rely upon or provide data from/for other studies. Recognizing these
relationships is an important part of the Integrated Licensing Process (ILP); however, the study
providing the data should describe the methodology and oversee the data collection and
analyses, while the study requiring the results should restrict its discussion to the types of
data/results required from other PSPs. 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. Since the Riparian Instream Flow Study will rely upon data
from the Groundwater Study, among other studies, the Riparian Instream Flow Study Plan
should describe only the results required from the Groundwater Study, and then describe how
those results will be used in the Riparian Instream Flow Study (e.g., 5.7 Groundwater PSP
should be the only study describing groundwater methods). This applies to other studies, such
as the habitat mapping studies, providing data for the Riparian Instream Flow Study Plan.
At the 24 October 2012 Riparian Instream Flow Technical Workgroup (TWG) meeting, AEA
provided a draft study interdependency figure showing which additional studies would provide
data for the study, the expected information produced by the study, and which studies will rely
upon output from the study. 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.
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.
The 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
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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
these improvements in the Revised Study Plan (RSP).
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 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.
Specific Comments by Subsection:
The following review of AEA’s proposed Riparian Instream Flow Study Plan uses the most
recent structure of the plan (24 October 2012 TWG meeting), which closely resembles the
Service’s study request structure. AEA’s original PSP included objectives that were wholly, or
at least partially, the objectives for other PSPs, and did not address all our study request
objectives. This new study plan structure and proposed methods are based on a combination of
both AEA’s and the Service’s proposed methods, as well as additional insights gained during
the TWG meetings and site visits. Although some of these improvements have not yet been
fully documented, our review below is based on the expectation they will be included in the
RSP, and what we believe will be carried forward from the original PSP requiring additional
revision.
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.
AEA Study Area: The study area includes the Susitna River active valley that would be affected
by the operation of the Project downstream of Watana Dam. The active valley is the geographic
area that is flooded with a frequency and duration corresponding with current unregulated
conditions.
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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 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.
AEA & Service Objective 1 and Methods: Synthesize historical physical and biological data for
Susitna river floodplain and riparian vegetation, including the1980s studies and other hydro
projects that may provide insights for project operation.
The goal of this objective is to review existing information on physical and biological data (e.g.,
seedling establishment requirements, effects of river ice, relationship between sediment
deposition and plant succession, and required surface-water / groundwater regime) for Susitna
River floodplain and riparian vegetation. Although this is really a task rather than a research
objective, this is still an important study component. W e also appreciate AEA honoring our
11 September 2012 email recommendation to include a review of relatively undisturbed riverine
systems.
AEA & Service Objective 2 and Methods: Select and design study sites.
The goal of this objective is to select sites necessary for this study, and to ensure these sites
will also complement and take advantage of the information from the other studies (e.g., flow
routing, groundwater, fluvial geomorphology, and ice processes). 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.
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.
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.
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 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,
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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.
AEA & Service Objective 3 and Methods: Characterize seed dispersal timing, water-level
regime required for establishment, and frequency of establishment, and then predict potential
plant community change resulting from project operations.
The goal of this objective is to characterize the seed dispersal timing, the required water-level
regime for establishment, and the frequency of establishment for dominant riparian species
(e.g., balsam poplar, willows). This objective has two primary components. The first is to
characterize the requirements for seedling germination and establishment, and the second is to
characterize the frequency of survival and recruitment into the plant community. The methods
for the second component (recruitment into the population) were sufficiently described in the
PSP.
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”
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.
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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 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.
The Service also asked how the results from this objective will be used to predict potential
Project-related changes in 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
Project 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.
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.
AEA & Service Objective 4 and Methods: Characterize the role of river ice in the establishment,
survival and recruitment of dominant riparian species, and then predict potential plant
community change resulting from project operations.
The goal of this study objective is to characterize the role of river ice in the establishment
(colonization), survival (first 3 years) and recruitment (into the future reproductive population;
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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, 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
ice scar 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.
AEA & Service Objective 5 and Methods: Characterize the role of sediment deposition in the
formation of floodplain and riparian soils, and then predict potential plant community change
resulting from project operations.
The goal of this study objective is to characterize the role of sediment deposition in the
formation of floodplain and riparian soils, and how sediment deposition affects the rate and
trajectory of plant community succession.
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. The characterization of the
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role of sediment deposition in the formation of soils will be conducted in three ways:
1. Sediment rates will be determined throughout the project area by dating floodplain
sediments to determine rates of sedimentation.
2. Sediment dating techniques will include dendrochronology (tree age of alluvial surface),
and sediment isotopic analyses (Cs137, Pd210), and soil stratigraphic descriptions and
vertical profile measurement.
3. Probabilistic models will be developed characterizing the relationship between plant
community successional stage, soil type and sediment depositional history.
Additional details provided by AEA include stratified random sampling in the focus areas and
entire project area, excavating soil trenches from surface to gravel (historic channel bed), and
describing soil stratigraphy and grain size by sieve analysis for the entire sediment profile. The
fluvial geomorphology 2-D sediment transport models will be used to predict the effects of
Project operations on sediment transport and depositional patterns. The rate of deposition,
depth of sediment, and soil profile development required for natural floodplain plant community
succession will be characterized, and then the predicted sediment deposition characteristics
from the Fluvial Geomorphology Study will be used to predict the effects of Project operation on
floodplain plant communities.
AEA & Service Objective 6 and Methods: Characterize the water-level regime required to
maintain floodplain and riparian plant communities, and then predict potential plant community
change resulting from Project operations.
The goal of this study objective is to characterize the relationship between floodplain water
levels (surface-water and groundwater) and floodplain plant communities, and then use this
understanding to predict Project-operation effects on floodplain vegetation. This is a critical
objective that has not been sufficiently discussed in past workgroup meetings, possibly due to
lack of time, and the PSP methods are insufficient to evaluate if the Service’s requested
objective will be met. In our 11 September 2012 email we suggested discussing this objective
near the beginning of future meetings to allow sufficient time for discussion. At the 24 October
2012 TWG meeting, however, this objective was again discussed last and with insufficient time
to discuss the topic. Although this may be listed as the last objective, this is not the least
important objective. The health and survival of plants is likely to express a response to Project-
regulated flows long before the other objectives such as succession and sediment deposition
changes are observed. For example, the preliminary estimated three to four foot decrease in
peak growing season river stage near Gold Creek due to Project-regulated flows (AEA 2012)
could potentially cause a substantial change in plant community composition and/or landform
position if the change in plant-community water levels (surface-water and groundwater) respond
similar to river stage and the herbaceous species respond similar to other regulated rivers (e.g.,
Henszey et al. 2004).
Objective 6 combines hydrologic information from the groundwater study (PSP 5.7) and the
plant community information from this study (PSP 6.6) and possibly the habitat mapping studies
(PSPs 9.6 and 9.7) to produce plant species/community response curves. Our Objectives 3 to 5
target critical stages in plant community succession, while Objective 6 targets critical instream
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flows required for maintaining plant communities as succession progresses (i.e., both
succession and maintenance are important).
Although this objective relies on groundwater information, the groundwater methods described
in the Riparian Instream Flow study plan belong in the Groundwater methods study plan
(PSP 5.7). AEA plans to comply with our request (11 September 2012 email) and move the
groundwater methods to the Groundwater Study Plan (24 October 2012 TWG meeting). We
have not discussed the surface-water component of floodplain “water levels,” but the surface-
water information will be required for communities that experience flooding and for wetland
communities where the water-levels routinely cycle between surface-water and groundwater.
At the 1 October 2012 Riparian Instream Flow Study TWG meeting, we briefly discussed
potential methods for developing plant community water-level response curves, but the notes for
this meeting have not been posted on AEA’s website and this portion of the objective was not
discussed in the more widely attended 24 October 2012 TWG meeting. We understand
methods similar to Henszey et al. (2004) will be employed, and we look forward to seeing these
methods in the RSP. PSP Section 6.6.4.7 (Succession Models and Flow Response Guilds)
appears to potentially address our Objective 6. The concept of response guilds is similar to our
request to develop plant community response curves, but the PSP methods are insufficient to
evaluate if our requested Objective 6 will be met. We requested evaluating specific water-level
summary statistics (e.g., growing season cumulative frequency, 7-day moving average, 10-day
moving average, 14-day moving average, and arithmetic mean) with a rigorous curve-fitting
technique similar to Henszey et al. (2004). The methods should provide sufficient detail to
construct quantifiable (not qualitative) hydrologic (surface-water and groundwater) gradients
showing the optimum and range of favorable water levels required for maintaining floodplain
species/communities.
It may also be possible to pool results across process-domain focus areas (i.e., increased
sample size) if there is no statistical difference between response-curve coefficients (e.g.
Henszey et al. 2004), potentially producing more broad-based response curves. Hydrology is
likely the most dominant physical factor influencing floodplain plant communities across the
various process-domains, and baring some other dominant physical factor (e.g., soil parent
material, ice scour, etc.) it may be possible to use data from additional sample areas to build
response curves (see Henszey et al. 2004, Figure 7 for an indication of the number of data
points required to build a response curve).
Literature Cited
Alaska Energy Authority (AEA). 2012. Preliminary Susitna River pre-project and post project
flow stages. Prepared by MWH. Technical Work Group Meetings 23-25 October 2012.
(http://www.susitna-watanahydro.org/wp-content/uploads/2012/10/Downstream-Stages-
TWG-Oct-16-2012-R1-pptx.pdf).
Henszey, R.J., K. Pfeiffer, and J.R. Keough. 2004. Linking surface- and ground-water levels to
riparian grassland species along the Platte River in Central Nebraska, USA. Wetlands
24(3):665-687. (ne.water.usgs.gov/platte/reports/wetlands_24-3.pdf)
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Green, R.H. 1979. Sampling Design and Statistical Methods for Environmental Biologists.
John Wiley and Sons, New York. 257 pp.
Hurlbert, S.H. 1984. Pseudoreplication and the Design of Ecological Field Experiments.
Ecological Monographs 54:187–211. (http://dx.doi.org/10.2307/1942661)
Montgomery, D. 1999. Process domains and the river continuum. Journal of the American
Water Resources Association 35(2):397-410.
Rood, S.B., L.A. Goater, J.M. Mahoney, C.M. Pearce, and D.G. Smith. 2007. Floods, fire, and
ice: disturbance ecology of riparian cottonwoods. Canadian Journal of Botany
85(11):1019-1032. 10.1139/B07-073.
U.S. Fish and Wildlife Service. 2012. Letter and study requests to Secretary Bose, Federal
Energy Regulatory Commission. May 31, 2012.
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7. Fish and Aquatic Resources
7.5. Study of Fish Distribution and Abundance in the Upper Susitna River
General Comments:
The overall stated goal of Alaska Energy Authority’s (AEA) Fish Distribution and Abundance
Proposed Study Plans (PSP) is to characterize the current distribution, relative abundance, run
timing, and life history of resident and non-salmon anadromous species (e.g., Bering cisco,
Dolly Varden, humpback whitefish, northern pike, and Pacific lamprey), and freshwater rearing
life stages of anadromous fish (fry and juveniles) in the Middle and Lower Susitna River, as well
as the Upper River, above Devils Canyon.
The creation of a reservoir when full will inundate 39 miles or more of the Susitna River and
tributary streams. This will directly affect the abundance of fish residing in flowing waters. The
reservoir could inundate important spawning habitat for resident fish, and Chinook salmon and
other anadromous fish that currently migrate through Devils Canyon. Alternately, the reservoir
could provide rearing habitat for resident Arctic grayling, which often migrate downstream from
spawning areas to low velocity habitats for rearing. The quality of this reservoir habitat is
unknown, particularly during the winter. Creation of a reservoir could provide habitat for lake
trout—a predatory species that could affect the abundance and distribution of other resident
fish.
Upper River fish studies should be directed toward quantifying the total amount of tributary
habitat that will be converted to a reservoir. Information regarding the population or relative
abundance of selected fish species within the inundation zone should be obtained to determine
the significance of direct effects. Lower tributary reaches, tributary mouths, and mainstem
locations within the inundation zone may provide important seasonal habitat for resident and
anadromous species. For example, resident Dolly Varden and grayling overwinter in the
mainstem Susitna River and tributary mouths may provide important Dolly Varden summer
habitat. 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. The U.S. Fish and Wildlife Service
(Service) recommends that the Upper River study objectives be refined to reflect specific
information needs for evaluating potential Project effects to the fish community.
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.
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Specific Comments by Subsection:
AEA Study Objective 1. Describe the seasonal distribution, relative abundance (as determined
by CPUE, fish density, and counts), and fish-habitat associations of resident fishes, juvenile
anadromous salmonids, and the freshwater life stages of non-salmon anadromous species;
This objective is broad suggesting that methods will be developed to quantify the seasonal
distribution, relative abundance, and fish habitat associations of all fish within the Upper River
study area. Seasonal distribution as stated in the objective will be determined by catch per unit
of effort (CPUE), density and counts. The need for this information and the purposes of these
studies is not provided. The primary objective of Upper River studies should be to determine
resident and anadromous fish use of the inundation zone for key life history periods (i.e.,
spawning and overwinter). Documenting Chinook salmon spawning and rearing habitats is
especially important. Determining fish-habitat relationships will require analyses of fish
community metrics (e.g., relative abundance, growth rates) as a function of physical, chemical,
and biological habitat characteristics. However, methods to accomplish this objective are not
provided.
The 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 selected 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.
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.
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.
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
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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.
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.
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. Off-
channel 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 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.
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.
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.
A combination of gill netting, electrofishing, angling, trot lines, minnow traps, snorkeling,
outmigrant traps, beach seines, fyke nets, DIDSON, and video camera techniques will be used
to sample or observe fish. The level of effort, water temperature, and DO at sampling locations
will be recorded. All captured fish will be identified to species, measured, weighed, and
scanned for a PIT tag. Comments on general methods for each species are described below
(Section 7.6, Objective 2).
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As described in the PSP, sampling methods do not include measurement of habitat variables to
determine fish distribution among sites and among sampling events. A general classification of
“pool, riffle, or backwater” will likely not provide enough information to characterize fish-habitat
relationships or to evaluate potential Project effects. Determining Dolly Varden, Artic grayling, or
burbot spawning habitat characteristics and their distribution relative to the inundation zone will
be important for the evaluation of potential Project effects. This will likely require more
information than differences in water velocities. Other habitat variables that may explain
resident fish distribution, and should be measured concurrent with fish sampling, include water
velocity, discharge (of the mainstem and sampled tributaries), turbidity, availability of cover, pH,
conductivity, groundwater, and invertebrate drift and productivity.
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 are to passage for each migrating life stage and species.
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.
AEA Study Objective 2. Determine whether Dolly Varden and humpback whitefish residing in
the upper river exhibit anadromous or resident life histories;
The PSP states that otoliths will be collected from Dolly Varden and humpback whitefish >200
mm to test for marine derived elements indicative of an anadromous life history pattern
(Objective 2) with a target of 30 for each species.
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).
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Zimmerman (2005) found that strontium (Sr) or strongtium-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 fresh water 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, then ratios should be compared to known resident upper river
fish and known marine species. Larger individuals of each species are most likely to exhibit
anadromous life-stages and should be selected for sampling as proposed.
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.
AEA Study Objective 3. Collect tissue samples to support the Genetic Baseline Study for
Selected Fish Species (Section 7.14);
See comments on Section 7.14 Genetic Baseline Study for Selected Species.
AEA Study Objective 4. Determine baseline metal concentrations in fish tissues for resident fish
species in the mainstem Susitna River (see Mercury Assessment and Potential for
Bioaccumulation Study, Section 5.12);
See Comments on Section 5.12 Mercury Assessment and Potential for Bioaccumulation Study.
AEA Study Objective 5. Use biotelemetry (PIT and radio tags) to describe seasonal movements
of selected fish species (including rainbow trout, Dolly Varden, whitefish, northern pike, burbot,
and Pacific lamprey if present) with emphasis on identifying spawning and overwintering
habitats within the hydrologic zone of influence upstream of the project;
This objective was developed to provide an understanding of the seasonal migration patterns of
resident fish species found in the Upper River. Specifically, studies should determine migration
timing and locations of spawning and overwintering. However, the PSP does not describe how
this will be accomplished. Sampling methods have not been developed based on what is
currently understood about the migration patterns and life histories of the selected fish species,
but appear to be a by-product of other study plans. The study plans contain no information on
how the efficiency of the study methods will be evaluated. PIT tagged fish often pass antennae
arrays without being detected (Bryant et al. 2009) and an array can detect a tagged fish in close
proximity that may not be moving into or out of a study location. There is no discussion of the
study statistical design or how migration data will be analyzed or applied to evaluating or
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mitigating (i.e., avoiding or minimizing) potential Project effects. 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.
The PSP states that all captured fish will be identified to species, measured, weighed, and
scanned for a PIT tag, with crews installing PIT tags in all untagged fish >60 mm. Antenna
arrays will be installed at up to six sites, shortly after ice-off in 2013, and three swim-over arrays
will be installed prior to ice-over on an experimental basis. Radio tags will be surgically
implanted in up to 30 individuals of each species. Locating radio tagged fish will be via fixed
receiver stations and aerial surveys, with up to four fixed receivers established at tributary
mouths along the mainstem of the Upper Susitna River and serviced in conjunction with the
Salmon Escapement Study (July through October). The Salmon Escapement Study will provide
weekly aerial surveys. At other times of the year, the frequency of aerial surveys of the study
area will be at least monthly.
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.
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.
AEA Study Objective 6. Document the timing of downstream movement and catch for fish
species via outmigrant traps;
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 Sevice 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 location. There is no description of data analyses or a discussion
of how the results will be applied to Project operation.
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
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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.
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.
It is possible that northern pike have already been introduced to shallow lakes or streams along
the Denali Highway and within the Upper Susitna River drainage. Increased access following
Project construction along with the creation of a reservoir could result in the introduction or
increased distribution of pike. If pike are not currently present, pike found in post-Project
monitoring could be due to Project construction. Determining if pike are present may be a
necessary objective and appropriate sampling methods should be developed.
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 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.
Literature Cited
ADF&G (Alaska Department of Fish and Game). 1981a. Subtask 7.10: Resident Fish
Investigation on the Upper Susitna River. Phase 1 Final Draft Report for Acres American Inc.,
Buffalo, New York.
____. 1981b. Phase 1 final draft report. Subtask 7.10. Resident fish investigtion on the Lower
Susitna River. ADFG/Susitna Hydro Aquatic Studies. Anchorage.
____. 1983. Resident and Juvenile Anadromous Fish Studies on the Susitna River Below Devil
Canyon, 1982. Volume 3 of Phase II Basic Data Report. ADFG/ Susitna Hydro Aquatic Studies
Program. Anchorage.
____. 1985. Resident and Juvenile Anadromous Fish Investigations, May-October 1984 Report
No. 7. ADFG/Susitna Hydro Aquatic Studies Program. Anchorage.
Beechie, T.J., Liermann, M., Beamer, E.M. and R. Henderson.Transactions of the American
Fshieries Society Bryant, M.D. M.D. Lukey, J.P. McDonnell, R.A. Gubernick, and R.S. Aho.
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2009. Seasonal movement of Dolly Varden and Cutthroat trout with respect to stream discharge
in a second-order stream in Southeast Alaska. North American Journal of Fisheries
Management 29: 1728-1742.
Buckwalter, J.D. 2011. Synopsis of ADF&G’sADFG’s upper Susitna drainage fish inventory,
August 2011. Alaska Department of Fish and Game, Anchorage.
Doucett, R. R., Hooper, W. & Power, G. 1999. Identification of anadromous and non-
anadromous adult brook trout (Salvelinus fontinalis) and their progeny in the Tabusintac River,
New Brunswick, using multiple stable-isotope analysis. Transactions of the American Fisheries
Society 128: 2, 278-288.
Kline, T. C., Jr, Wilson, W. J. & J.J. Goering. 1998. Natural isotope indicators of fish migration at
Prudhoe Bay, Alaska. Canadian Journal of Fisheries and Aquatic Sciences 55(6): 1494–1502.
Limburg, K.E. 1998. Anomalous migrations of anadromous herrings revealed with natural
chemical tracers. Can. J. Fish. Aquat. Sci. 55: 431-437.
Rutz, D.S. 1999. Movements, food availability and stomach contents of northern pike in selected
susitna river drainages 1996-1997. Alaska Department of Fish and Game, Fishery Data Series
No. 99-5, Anchorage.
Schmidt, D. and M. Stratton. 1984. Population dynamics of Arctic grayling in the upper Susitna
basin. 1984 Report No. 4, Part 2. Alaska Department of Fish and Game, Anchorage.
Suchanek, P.M., R.L. Sundet, and M.N. Wenger. 1984. Part 6: Resident fish habitat studies.
1984 Report No. 2, Schmidt, D.C., Hale, S.S., Crawford, D.L. and P.M. Suckanek (eds).
ADFG/Susitna Hydro Aquatic Studies, Anchorage.
Thedinga, J. F., M.L. Murphy, S. W. Johnson, J. M. Lorenz and K. V. Koski. 1994.
Determination of Salmonid smolt yield with roatary-screw traps in the Situk River, Alaska, to
predict effects of global flooding. North American Journal of Fisheries Management 14:4, 837-
851.
Thibault, L., R.D. Hedger, J.J. Dodson, J.-C. Shiao, Y. Lizuka, W.-N. Tzeng. 2010. Anadromy
and the dispersal of an invasive fish species (Oncorhynchus mykiss) in Eastern Quebec, as
revealed by otolith microchemistry. Ecology of Freshwater Fish 2010: 19, 348-360.
Zimmerman, C.E. 2005. Relationship of otolith strontium-to-calcium ratios and salinity:
experimental validation for juvenile salmonids. Canadian Journal of Fisheries and Aquatic
Sciences 62: 1, 88–97.
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7. Fish and Aquatic Resources
7.6. Study of Fish Distribution and Abundance in the Middle and Lower Susitna River
General Comments:
This individual Alaska Energy Authority (AEA) proposed study plan (PSP) addresses parts of
several U.S. Fish and Wildlife Service (Service) study requests related to anadromous and
resident fish, fish distribution and juvenile fish, that we provided to FERC, May 31, 2012. The
overall stated goal of AEA’s Fish Distribution and Abundance PSP is to characterize the current
distribution, relative abundance, run timing, and life history of resident and non-salmon
anadromous species (e.g., Bering cisco, Dolly Varden, humpback whitefish, northern pike, and
Pacific lamprey), and freshwater rearing life stages of anadromous fish (fry and juveniles) in the
Middle and Lower Susitna River, as well as the Upper River, above Devils Canyon. However,
for the distribution and abundance of fish in the Middle and Lower River, the PSP is not yet
sufficiently developed for all seasons, species and life stages to reflect the effort that will be
directed and is needed for these studies.
The Service maintains that documenting juvenile anadromous fish-habitat and resident fish-
habitat relationships is one of the most important Project-related studies. The proposed Project
can directly and indirectly affect the fish community through multiple pathways. Understanding
how the proposed Project may alter the fish community is essential to developing protection,
mitigation, and enhancement measures.
Although progress has been made in AEA’s technical work group (TWG) meetings, since the
July 16th filing of the PSP, in fully addressing our study request, several study methods are still
not sufficiently developed to meet the intent of the Service’s objectives, and appropriate study
designs have not been fully established. For instance, a one-year pilot study to assess winter
fish sampling methods has been proposed, but does not appear adequate to address sampling
of post-emergent fish less than 60 mm, which as stated in our study request is a critical period
in the life history of salmonid populations. In addition to missing or not collecting potentially
important information on a critical life stage, the pilot study essentially eliminates a year of study
under the Integrated Licensing Process (ILP) timeframe. There is also 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 techniques are listed
but specific methods that will be used to sample different species or life stages are not
presented.
Sampling locations refer to the different geomorphic classification types but there is only recent
indication at the October TWG meetings that sampling locations may be selected in proportion
to the distribution of classification types and that sample locations will be randomly selected
among all available sites with similar classification types. There is no mention of variability in
sampling efficiency among habitat types and how this variability will be accounted when
evaluating differences in fish distribution or habitat associations. Monthly sampling and, more
recently, some semi-monthly sampling is proposed, but this sampling frequency may not be
adequate to address many of our study request objectives. There is no indication of how habitat
characteristics will be measured or the metrics that will be used to evaluate causal factors
influencing habitat selection and habitat quality. The analytical methods have not been provided
to date, so it is not yet clear which statistical tests, if any, will be applied to determine if there are
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differences in fish community metrics between geomorphic classification types. There is no
indication of how the data from these studies will be used to evaluate potential project effects.
The Service recommends AEA provide more detailed information on the development of the
Habitat Suitability Curves (HSC). Instream flow analysis of habitat suitability is proposed as the
analytical method to be applied. This requires development of species and life-stage specific
habitat suitability curves. The development and application of habitat suitability curves has
been a subject of debate since publication of the instream flow increment methodology (Mathur
et al. 1985, Kondolf et al. 2000). However, the methods that will be used to develop HSC and
how they will address the limitations of this methodology are not provided. There is mention of
HSC in Study 6.5, but the study request objective is not addressed in the Upper, Middle, or
Lower River studies for juvenile salmonids, resident fish, and non-salmonid anadromous fish. It
is still unclear how HSC information will be collected, particularly in winter for post-emergent fish
up to 60 mm when fish would 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. There is also a general reference to developing HSC
models in Study 6.5 for these species and life stages, but the source of that information is
unclear.
The study area for the Middle and Lower River fish studies in the PSP is from the Watana Dam
site downstream to river mile 28. However, during a fall TWG meeting, it was suggested that
the study area could initially 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 would ignore potential indirect Project effects. The Service and National
Marine Fisheries Service (NMFS) believe that Lower River fish studies are necessary to
evaluate potential biotic effects due to species displacement from Middle River habitats and to
document the relative contribution to fish production and use between these two river segments.
It would also provide replicate measures of fish-habitat relationships and provide information for
post-project comparisons and monitoring.
Habitat quality and differences in growth rates or fish condition among habitats can be related to
fish density. Higher fish densities can increase intra- and inter-specific competition. Project
operations, like winter load-following operations, could displace Middle River fish thereby
increasing fish densities at Lower River sites. Higher fish densities in the Lower River could
exceed available resources thereby reducing fish fitness and survival. Similarly, concentrations
of transported organic matter or macronutrients may differ between the Susitna, Talkeetna, and
Chulitna Rivers, and changes in Susitna River concentrations could extend Project-related
effects downstream. The differences in dissolved and transported matter between the Susitna,
Talkeetna, and Chulitna Rivers should be determined to see if Project effects beyond flow and
sediment would change Lower River habitat quality.
Lower River fish and aquatic studies are necessary to documents the relative importance of
these two stream segments. Differences in chemical and physical water characteristics could
result in differences in habitat quality. For example, in the 1980s greater numbers of juvenile
Chinook salmon were found overwintering within the Middle River compared to Lower River
sites; even though total available habitats were more limited (ADF&G 1981).
Lower River sampling may be necessary to provide adequate replication of macrohabitats to
determine fish-habitat relationships. Tributary mouths have been identified as one of the
geomorphic classification types that may provide important juvenile salmon overwintering
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habitat. However, there are considerable biological, water quality, and physical differences
among tributaries. For example, Whiskers Creek is a moderately sloped stream characterized
by low pH, high dissolved carbon, coho spawning, and coho and Chinook overwintering habitat.
However, it is the only Middle River tributary with these characteristics. 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, or Kroto Creek/Deshka 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
together accounted for most of the Chinook salmon spawning in the 1980s, but these would
provide only two sample replicates of this stream type. Additional replicate sites could be found
in the Lower River including Montana Creek, Willow Creek, Sheep Creek, and possibly the
Kashwitna River.
Proposed study plans for post-Project monitoring are not provided. However, Lower River sites
could be selected as long-term monitoring locations. Lower River sites may have many of the
same biological, chemical, and physical characteristics as Middle River locations. Lower River
sites could be used to differentiate between changes in relative abundance due to 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 would need to be made with little
or no information on fish and aquatic resources in the Lower River.
Specific Comments by Subsection:
AEA Study Objective 1. Describe the seasonal distribution, relative abundance (as determined
by CPUE, fish density, and counts), and fish-habitat associations of juvenile anadromous
salmonids, non-salmonid anadromous fishes and resident fishes;
This study objective is broad and 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 and methods have not been developed for specific study
objectives. 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.
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, non-
salmonid 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.
Methods for all three of these study components can vary among species and their life stages
and with environmental conditions. The stated purpose for this study in the PSP is to support
the physical modeling and provide supporting information for the instream flow modeling study.
Therefore, specific detailed quantitative information is necessary for all three study components.
In addition, 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.
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Juvenile Salmon Seasonal Distribution
It is important to understand the distribution of fish species by life stage both spatially and
temporally. The direct effects of the construction and operation of the proposed Project will be
limited to those fish species present within the affected area. The Project could also indirectly
affect fish species by altering the physical, chemical or biological habitat characteristics.
However, identification of the seasonal distribution of fish species is presumed to be related to
direct Project effects. Direct Project effects can vary over time based upon different operational
scenarios, and the response to those effects can vary by fish species and life stage. In addition,
the magnitude of Project effects likely will decrease with distance from the dam site, and among
different geomorphic reaches and physical habitat types.
The change in the spatial and temporal distribution of fish is due to movements or migration of
fish among habitats during different life stages which can be influenced by environmental
variables. Adult resident and anadromous fish migrate to spawning areas, and juvenile fish
emerge and migrate to seasonal summer, fall, and winter rearing areas. These movement
patterns often are influenced by environmental factors. Adult salmon migration can be
influenced by water temperatures or flows (Macdonald et. al. 2000; Torgersen et. al. 1999).
Embryo development and fry emergence is dependent on thermal energy (Murray et. al. 1988;
Wangaard et al. 1983) but can be influenced by flows (Milner 1985), and juvenile migration to
winter habitats and smolt outmigration can be related to changing flows or light (Bustard and
Narver 1975, McDonald 1960). The temporal distribution of fish may vary from year to year due
to environmental conditions which can be influenced by Project operations. Therefore, we not
only need to understand the spatial and temporal distribution of fish species by life stage, but
also those factors than initiate and modify movement or migration rates.
The seasonal distribution of adult anadromous salmon and salmon eggs will be determined
through the Adult Escapement Studies (Section 7.7). However, the temporal distribution of
salmon fry will be influenced by egg development rates. The presence of chum, sockeye, or
other salmon fry within the Susitna River or off-channel habitats will depend upon egg
development and emergence timing. The Service’s request for the evaluation of spawning and
egg development is not addressed in the PSP and has not been fully addressed in subsequent
TWG meetings, but is the subject of multiple agency study plan objectives outlined below.
Juvenile Salmon Distribution and Movement from Spawning to Rearing Locations
Understanding the timing and influence of environmental variables on juvenile salmon migration
from spawning to rearing habitats is critical to the Service’s evaluation of the Project. Newly
emergent salmon fry are weak swimmers and the availability and access to low velocity
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. Understanding the seasonal distribution of juvenile salmon will likely require
multiple sampling methods, sampling locations, and sampling frequency for different species.
Environmental conditions such as temperature, discharge and water velocity influence the
timing of sockeye and chum migration to sea or Lower River rearing habitats. Studies have
shown a stronger positive response to discharge by sockeye and chum fry compared to
Chinook and coho fry (Hoar 1954). Chum had the highest correlation (r=0.89) with discharge in
the 1980s studies at mainstem inclined plane trap locations (Roth et al 1986). Less is known
about juvenile river-rearing sockeye and their dependence on discharge ,but results from 1980s
studies suggest that large numbers of age 0+ sockeye migrated out of the Middle River in late
May and June coinciding with high spring time flow. The percentage of migrants travelling to
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Cook Inlet or to Lower River rearing habitats was not known (Schmidt et al 1985). The PSP
does not indicate where fyke nets or other migrant traps should or will be used to capture
migrating juvenile salmon. Migrant traps such as fyke nets and inclined plane traps should be
used with a sufficient level of effort and frequency to determine the timing and conditions (e.g.,
water temperature and flow) of chum and sockeye migration.
The Service recommends that placement of migrant traps (i.e., fyke nets, screw or incline plane
traps) occur near adult salmon spawning locations in such a manner 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 (i.e., fry per spawning female x
fecundity). The use of migrant traps for sockeye salmon fry may be preferable to other
sampling methods (electrofishing, beach seines, and minnow trapping) based on results of
1980s studies. The results of proposed adult salmon spawning and potential incubation, and
emergence studies should be used to identify sampling locations and the timing of migrant trap
operation.
Migrant traps near the confluence of tributaries or near other identified spawning areas and
Susitna River should be used with other methods to document juvenile Chinook and coho
salmon movement from spawning to rearing areas. In addition to providing detailed run timing
information, migrant traps could allow for population estimates (if needed) using mark-recapture
methods and provide a method to calculate spawning success in tributary streams.
Juvenile Salmon Distribution among Summer Rearing Habitats
The seasonal distribution of juvenile salmon within the Middle and Lower Susitna River during
summer rearing likely will be determined using the relative abundance or catch per unit effort
(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. The Service
recommends that timing and frequency of sampling, sample locations, and sampling methods
be appropriate to species life histories and to address specific project-related questions.
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 should also consider the relationship to spawning areas and microhabitat
characteristics as well as the timing of fry movement from spawning to rearing areas. Sampling
mainstem habitats immediately upstream and downstream of spawning areas before or after fry
move from spawning to rearing areas would result in substantial differences in CPUE. Similarly,
if salmon spawning locations are predominantly on one bank (e.g., Slough 8A and Slough 11),
then salmon 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 would be less likely to determine differences among habitat types. Whereas, if
these were discrete sampling areas based upon a stratified sampling approach, it would provide
a much better understanding of salmon fry distribution among mainstem habitat locations. At
the October 2012 TWG meetings, a stratified random approach was outlined and an initial
schedule presented for fish sampling. However, a description of the methods, the link from
methods to the study objectives, the analytical approach, and the metrics used for the analysis
are still unknown and should be described in the revised study plan.
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,
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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.
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.
An alternate approach would be to develop specific hypotheses regarding distribution and
develop a sampling approach to test these hypotheses. For example, studies could address
whether juvenile sockeye salmon use mainstem habitats in summer for rearing or use mainstem
habitats primarily as a transportation corridor from spawning to rearing habitats (sensu Galat
and Zweimuller 2001). Studies could determine if there is a difference in juvenile sockeye
salmon residence times among macrohabitat locations, and if there is a difference in juvenile
sockeye salmon abundance between left and right bank macrohabitats.
The timing and frequency of sampling can also influence our understanding of juvenile salmon
distribution within the Susitna River and should be specific for each species or for specific
Project-related objectives. For example, if the objective is to determine when and how long
juvenile sockeye salmon are present in mainstem habitats, then sampling could be initiated in
early June, and weekly or semi-weekly sampling may be necessary to document sockeye
salmon residence times within mainstem habitats. For Chinook and coho salmon, sampling of
mainstem habitats could also begin in June, with initial monthly sampling, but more frequent
weekly or semi-weekly sampling in August and September to determine if mainstem habitats
are migration corridors or are important fall and winter rearing areas.
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, and following similar natural variations in flow.
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Juvenile Pacific Salmon Migration to Overwintering Habitats
The objective for the distribution of juvenile salmon during winter should determine if fish
maintain site fidelity from summer through winter, or if and when they emigrate from summer
rearing locations, and the locations that they select for overwintering. 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 declined or in response to fall storms. PIT tags could also be used to determine site
fidelity within upland and side sloughs with tag detection at stationary arrays near the slough
mouth.
Based upon 1980s Susitna River sampling, juvenile salmon in winter were found in tributary
mouths, mainstem, and off-channel habitats. Monthly winter fish sampling at sites randomly
stratified by geomorphic classification types could be used to identify distribution during winter.
However, a variety of sampling methods are likely needed to infer differences in relative
importance of overwintering habitat locations. The use of video and PIT tagging may be useful
to document the presence or absence of juvenile salmon at multiple sampling locations, but it is
unknown whether video observations of fish are proportional to fish densities or would otherwise
provide useful quantitative information.
Juvenile salmon emigrate from summer rearing to fall and winter rearing habitats. Juvenile
sockeye, Chinook, and coho salmon overwinter in the Susitna River and associated off-channel
habitats. Juvenile salmon may move to winter rearing locations or remain in summer rearing
locations if characteristics are favorable in winter. Migration is often associated with declining
water temperatures but may be linked to changes in discharge or light levels (Bjorn 1971,
McMahon and Hartman 1989). Movement from summer rearing areas may be initiated by low
flows in fall, winter freshets, or the loss of open water as small tributaries freeze to the bottom
(Prowse 1994). Juvenile salmon generally select winter habitats with cover, low water velocity,
and relatively warmer water due to springs or upwelling groundwater (Giannico and Hinch 2003,
Hillman et al. 1987, Cunjak 1996). Winter habitat selection is based on the need to minimize
energy expenditure and avoiding adverse physical or chemical conditions (e.g., anchor ice,
floods, low oxygen) (Cunjak 1996).
Chinook and coho salmon likely prefer different winter habitats, but little is known about winter
habitats used by stream-type sockeye salmon. Substrate with interstitial spaces that provide
cover and lower water velocities may be important for overwintering Chinook salmon (Hillman et
al. 1987, Bjorn 1971). Bjorn (1971) found fewer juvenile Chinook salmon migrated out of
streams with large cobble substrates than those with gravel or finer substrates. Juvenile
Chinook salmon were found in association with macrophytes and undercut banks during winter
and the addition of cobble substrate increased overwinter abundance (Hillman et al. 1987) in the
Lemhi River (Northern Idaho). Juvenile steelhead and Chinook were found overwintering in
deep pools and the interstitial spaces of riprap cover in a large river in British Columbia (Swales
et al. 1986). Bustard and Narver (1975) found juvenile coho salmon and steelhead trout in
waters less than 0.15 cm/s when water temperatures were below 8°C whereas Hillman et al.
(1987) found Chinook salmon in water velocities less than 20 cm/s during winter with larger fish
using higher water velocities.
Seasonal Distribution of Resident Fish
See comments under AEA Objective 2 of Section 7.6.
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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.
Juvenile Salmon Habitat Associations
Determining habitat characteristics that are important for fish species in the Susitna River and
evaluating how construction and operation of the proposed Project may alter those habitat
characteristics is a fundamental purpose of the proposed studies. The development and
completion of extensive studies to measure and model geomorphological changes, ground
water flow paths, productivity, and water quality may have little utility if a relationship between
physical and biotic processes and fish habitat characteristics is not clearly understood.
One PSP objective is to describe fish-habitat relationships for juvenile anadromous, non-
salmonid anadromous, and resident fish species. However, the PSP does not outline how
these data would be used, how habitat characteristics would be measured, or how statistical
methods would be used to determine the relationships between fish and characteristics of their
habitats. Therefore, critical evaluation of the PSP is difficult. As potential habitat suitability
criteria and indices have not been identified, there is no indication of what parameters may be
included to develop weighted usable area for instream flow analyses.
The Service recommends that AEA review the numerous published studies available to
determine the characteristics that define habitat quality from egg deposition through juvenile
summer and winter rearing for most fish species present in the Susitna River (See summaries in
Bjorn and Reiser 1991, Quinn 2006). There are few studies that evaluate juvenile salmon and
resident fish-habitat characteristics in large glacial rivers (Murphy et al. 1989). Although these
sources may not provide the information necessary to define fish-habitat associations, they can
provide an understanding of those parameters that should be incorporated into the revised
study plans.
The important characteristics of fish-habitat relationships can be physical, chemical, or
biological. Physical, chemical and biological characteristics used to define fish-habitat
relationships should be measured and not obtained from model estimates. Fish-habitat
characteristics should define conditions when fish are sampled at the microhabitat scale (m2);
however, sampling frequency and locations should be based upon the variability of the
measured parameter. For instance, channel geometry will not likely change within a season so
annual measures should be adequate; however, water velocity and water depth, and most water
quality parameters should be measured at the same time as fish sampling. Similarly, sample
locations should be representative of the physical habitat sampled for fish.
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AEA Study Objective 2: Describe seasonal movements of selected fish species such as
rainbow trout, eulachon, Dolly Varden, whitefish, northern pike, Pacific lamprey, and burbot)
using biotelemetry(PIT and radio-tags) with emphasis on identifying foraging, spawning and
overwintering habitats within the mainstem of the Susitna River and its associated off-channel
habitat;
This PSP study objective partially addresses the Service’s study requests for resident fish
species. Our study objectives for resident fish included the following:
1. “Characterize the seasonal (spring, summer, fall, winter) distribution, relative abundance,
and habitat utilization in the Susitna River mainstem (RM 0-RM 233) for all life stages of
non-salmon anadromous, resident, and invasive fish species. [Documenting both
hierarchal nested habitat type and use-type as described in the resource agency
Instream Flow Study and Habitat Utilization Study Request].
2. Characterize the seasonal (spring, summer, fall and winter) movement patterns of all
subject fish species and life stages as they relate to foraging, spawning, rearing and
overwintering habitats. The characterization of seasonal movements includes run timing
(immigration and emigration) and extent (periodicity) of non-salmon anadromous species
in the Susitna River (RM 0-RM 233) and movement into and out of tributary streams.
[Interface with resource agency Instream Flow and Habitat Utilization Study Request
hierarchal nested habitat types and habitat mapping].
3. Characterize the flow-related or synchronized life history strategies (migration,
movement, spawning, rearing, hatching, emergence) of non-salmon anadromous,
resident and invasive species, and their biological behavorial response (e.g., potential
for false attraction, delayed migration or increased holding time, synchrony of spawning,
relative hatching and emergence timing) to Project-affected flow alterations (flow,
temperature, habitat, water quality).
This study objective also only partially addresses the Service’s study requests for juvenile
anadromous, and juvenile resident fish. Our study objectives for juvenile fish included the
following:
1. Describe the seasonal movements and migratory patterns of juvenile anadromous and
resident juvenile fish species among mainstem habitats and between tributaries and mainstem
habitats with emphasis on identifying foraging and overwintering habitats.. [Enclosure 13: Early
Life History and Juvenile Fish Distribution and Abundance in the Susitna River].
The PSP objective is to characterize seasonal distribution, relative abundance, and habitat
associations of resident fish and their migration. However, PSP methods do not support the
intent of the Service’s study request. The PSP has not been developed to characterize flow-
related, or synchronization of resident fish migration and life histories to other physical,
chemical, or biological environmental variables. Specific methodologies will need to be
designed to accomplish these objectives. Incidental catches of fish through seasonal samples
will not be sufficient, nor will the resulting data be useful for evaluating Project effects.
The fish collection methods do not appear to be related to this 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 can result in high fish mortality for
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some species, therefore, it may not be an appropriate method to collect fish for tagging and
tracking.
The PSP study methods do not clearly identify those species that will be evaluated. However, a
partial list of potential species is provided, which, in part is covered under other study objectives
(i.e., seasonal movement of northern pike). The PSP provides only cursory information on the
general life-history patterns of the potential fish species and does not include any site-specific
information. Study methods do not adequately identify when, where, or how specific fish
species will be captured. The location and operation of receivers does not appear to consider
the life history patterns for many species. PIT tagging is identified in the study objective, but the
limitations on installation and operation of arrays could limit the results. PIT tagging is also
limited to fish >60 mm, and therefore, will not provide any information on the early life stages
that will be most vulnerable to Project operations. The study does not identify any of the other
biological, chemical, or physical characteristics that may explain movement patterns. There is
also no description of how the analyses of the data obtained from this study will be conducted to
meet the study objective.
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 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.
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 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.
The number of fish to be tracked in the PSP may not be sufficient to document spawning
migration patterns, summer foraging areas, and overwintering habitats to meet the study
objective. The use of radio receivers has not been designed to track resident species. 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.” The description of
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methods in the PSP is not detailed enough for the Service to provide meaningful evaluation.
More information is needed regarding: which fish species will be tagged; what determines
“sufficient” sizes for radio transmitters; and how movements of smaller, juvenile fish (<60 mm)
will be monitored. If fish selection is stratified equally among five different habitat types, this
would only provide information on movements for two fish from each habitat type below Devils
Canyon. It is unclear if this level of effort will be sufficient to understand general movements
and seasonal habitat utilization by species. The plan to maintain fixed receiver stations during
July through October, to coincide with adult salmon migrations will miss fish species movements
or migrations that occur in the spring. If the objective for the biotelemetry studies is to include
tracking seasonal movements of resident and non-salmonid anadromous fish, the observation
period should not be based solely on adult salmon migration periods. Monthly winter and spring
aerial surveys have the potential to miss movements and migration timing from spawning areas
to juvenile fish rearing habitats. Therefore, more frequent surveys are likely needed. In
addition, because radio-tagging 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 may be an inadequate sample size.
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.
AEA Study Objective 3: Document the timing of downstream movement and catch for all fish
species using outmigrant traps;
This study objective is broad, with no stated purpose, and is limited to a single method. One
purpose could be to document outmigration timing and abundance of anadromous salmon smolt
from the Susitna River. However, “all fish species” are listed as the study objective. The PSP
states that sites within side channels that are open continuously throughout the ice-free season
will be selected for outmigrant traps and traps will be operated for 48 hours off. As described, it
appears that two traps will be deployed and all captured fish will be recorded, but there is no
discussion of how these data will be used.
Although we agree that documenting the timing of downstream movement of fish should be a
study objective, the objective should be expanded and the purpose clarified. This will ensure
that appropriate methods are selected and avoid collecting data that cannot be used in the
evaluation of Project effects. For example, salmon smolt migration is likely different than
downstream movement of emergent fish to rearing locations. Also, the velocities used by out-
migrating smolt may be species specific. Therefore, the timing and location of out-migrant traps
will depend upon specific study objectives.
AEA Study Objective 4: Characterize the age structure, growth, and condition of juvenile
anadromous and resident fish by season;
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An understanding of the seasonal age structure, growth, and condition of anadromous and
resident fish is needed by the Service to provide baseline information and to evaluate or monitor
potential Project effects.
The PSP does not provide information on why age structure, growth rates, or condition factors
are being collected or calculated, or how these metrics will be used in Project evaluation. The
recapture of PIT-tagged fish is the only method that is suggested for measuring growth rates.
Specific objectives will affect study design, sampling locations and frequency, the sample size
and data analyses. Therefore, specific study objectives must be identified with appropriately
selected sampling and analytical methods. For example, flow fluctuations and the potential for
stranding may vary in relation to proximity to the dam site and channel morphology. A Project
objective may be to determine if there are longitudinal differences in juvenile salmon growth
rates. Study designs could be developed to test for differences in growth rates or condition
factors among groups of different geomorphic classification (i.e., mainstem, sloughs, side
channels, and tributaries). In this case, growth rates will need to be calculated for each of these
replicate locations. Growth rates and condition factors are an indication of habitat quality, thus
regressions with habitat characteristics will require measuring growth rates at locations with
variable habitat characteristics. Growth during winter may be an important measure of habitat
quality and differences in growth and condition among overwintering sites should be determined
at multiple replicate locations throughout the winter. In addition, growth rates may be used in
addition to juvenile salmon density or relative abundance when determining weighted usable
area for instream flow analyses (Beecher et al. 2010).
In collaboration with the Services, AEA should identify the specific objectives and information
needs that require juvenile anadromous and resident fish growth rates. Based upon these
objectives, study designs should be developed to document the species, locations, and
methods that will be used to calculate growth rates and the analyses that will be applied to the
data. Site selection and the use of growth rates without considering data analyses and
application likely will not result in useful data.
AEA Study Objective 5: Document the seasonal distribution, relative abundance, and habitat
associations of invasive species (northern pike);
This AEA objective is directed toward any invasive species but refers specifically 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, then
detailed procedures should be provided on how this would be accomplished.
The PSP does not describe the 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 information on northern pike and habitat
associations and identify how the proposed Project may affect current distribution, relative
abundance, and available habitats. The PSP 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.
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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.
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.
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.
AEA Study Objective 6: Collect tissue samples from juvenile salmon and opportunistically from
all resident and non-salmon anadromous fish to support the Genetic Baseline Study.
The evaluation of the effectiveness of the PSP in meeting this objective is discussed in section
7.14: Genetic Baseline Study for Selected Species.
Related USFWS/NMFS (Services) Study Objectives
Services Study Request Objective 7. Evaluate salmon incubation (embryo development,
hatching success, and emergence times) and monitor associated water quality conditions (e.g.,
temperature, DO, pH) at existing spawning habitats (slough, side channel, tributary, and
mainstem) in areas with and without groundwater upwelling in the middle and lower reaches of
the Susitna River.
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, 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)
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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.
Services Study Request Objective 8. Evaluate the potential for stranding of juvenile fish and
stranding mortality under proposed operational conditions.
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.
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, freezing of juvenile fish, and their habitats.
This Study Request Objective 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.
Literature Cited
ADF&G (Alaska Department of Fish and Game). 1981a. Adult anadromous investigations,
sockeye, pink, chum, and coho report. ADFG/Susitna Hydro Studies. Anchorage, Alaska.
ADF&G. 1981b. Juvenile Anadromous Fish Study on the Lower Susitna River. Phase I Final
Draft Report. ADFG/Su Hydro Aquatic Studies Program. Anchorage, Alaska.
ADF&G 1981c. Phase 1 final draft report. Subtask 7.10. Resident fish investigation on the
Lower Susitna River. ADFG/ Susitna Hydro Aquatic Studies. Anchorage, Alaska.
ADF&G. 1983a. Susitna Hydro Aquatic Studies phase II final report, volume 2; Adult
anadromous fish studies, 1982, ADFG/Susitna Hydro Aquatic Studies. Anchorage, Alaska.
ADF&G. 1983b. Resident and juvenile anadromous fish studies on the Susitna River below
Devil Canyon, 1982. Phase II Basic Data Report, Vol. 3. ADFG/Susitna Hydro Aquatic Studies.
Anchorage, Alaska.
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ADF&G. 1983c. Susitna Hydro aquatic studies Phase II data report. Winter aquatic studies
(October 1982 - May 1983). ADFG/ Susitna Hydro Aquatic Studies. Anchorage, Alaska.
ADF&G. 1983d. Susitna Hydro aquatic studies phase II final report. Adult anadromous fish
studies, 1982, volume 2. Susitna Hydro Document No. 588, Anchorage, Alaska.
ADF&G. 1983c. Susitna Hydro Aquatic Studies; Phase II report: synopsis of the 1982 aquatic
studies and analysis of fish and habitat relationships-Appendices. Alaska Department of Fish
and Game, Susitna Hyrdro Aquatic Studies, Anchorage, AK.
ADF&G. 2012. Fish Resource Monitor; Available URL:
"http://gis.sf.adfg.state.ak.us/FlexMaps/fishresourcemonitor.html?mode=awc" [Accessed
10/23/2012]. Alaska Department of Fish and Game, Division of Sport Fish.
Barrett, B.M., F.M. Thompson, and S.N. Wick. 1984. Report No. 1: Adult anadromous fish
Investigations, May - October 1983. ADFG/ Susitna Hydro Aquatic Studies. Anchorage, AK.
Barrett, B.M., F.M. Thompson, and S.N. Wick. 1985. Report No. 6: Adult salmon investigations
(May-October 1984). ADFG/ Susitna Hydro Aquatic Studies. Anchorage, Alaska.
Beechie, T.J., Lierman, M., Beamer, E.M. and R. Henderson. 2005. A classification of habitat
types in a large river and their use by juvenile salmonids. Transactions of the American
Fisheries Society 134:717-729.
Bjorn, T. C. 1971. Trout and salmon movements in two Idaho streams as related to
temperature, food, stream flow, cover and population density. Transactions of the American
fisheries society, 100:3, 423-438.
Bjornn, T. C., and D. W. Reiser. 1991. Habitat requirements of salmonids in streams. Pages
83-138 in W. R. Meehan (editor) Influences of Forest and Rangeland Management on Salmonid
Fishes and their Habitats. American Fisheries Society Special Publication 19, Bethesda, MD.
Breeser, S. W., F. D. Stearns, M. W. Smith, R. L. West, and J. B. Reynolds. 1988. Observations
of movements and habitat preferences of burbot in an Alaskan glacial river system.
Transactions of the American Fisheries Society 117(5):506-509.
Brown, R. J. 2004. A biological assessment of whitefish species harvested during the spring and
fall in the Selawik River Delta, Selawik National Wildlife Refuge, Alaska; Alaska Fisheries
Technical Report Number 77. U. S. Fish and Wildlife Service, Fairbanks Fish and Wildlife Field
Office, Fairbanks, AK.
Brown, R. J. 2006. Humpback whitefish Coregonus pidschian of the Upper Tanana River
drainage; Alaska Fisheries Technical Report Number 90. U. S. Fish and Wildlife Service,
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Brown, R. J., C. Lunderstadt, and B. Schulz. 2002. Movement patterns of radio-tagged adult
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Kepler, P. 1973. Population studies of northern pike and whitefish in the Minto Flats complex
with emphasis on the Chatanika River. Federal Aid in Fish Restoration, Annual Performance
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1997. Alaska Department of Fish and Game, Fishery Data Series No. 98-37.
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selected Susitna River drainages, 1996-1997. . Fishery data series no. 99-5, ADFG/Division of
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Studies. Anchorage, Alaska.
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salmonids in two interior rivers in British Columbia. Canadian Journal of Zoology 64: 1506-1514.
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1985. Report No. 13. ADFG/Susitna Hydro Aquatic Studies. Anchorage, Alaska.
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habitat associations of chinook salmon in northeastern Oregon. Ecol Appl 9:301-309.
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Underwood, T., K. Whitten, and K. Secor. 1998. Population characteristics of spawning inconnu
(sheefish) in the Selawik River, Alaska, 1993-1996, Final Report; Alaska Fisheries Technical
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interior Alaska, Informational Leaflet 124. Alaska Department of Fish and Game, Division of
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7. Fish and Aquatic Resources
7.7. Salmon Escapement Study
General Comments:
The U.S. Fish and Wildlife Service’s (Service) 31 May 2012 study request entitled Adult Salmon
Distribution, Abundance, Habitat Utilization and Escapement in the Susitna River is addressed
in part by Alaska Energy Authority (AEA) Proposed Study Plan (PSP), Section 7.7 Salmon
Escapement Study. 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 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.
Specific Comments by Subsection:
AEA Study Objective 1: Capture, radio-tag, and track adults of five species of Pacific salmon in
the middle and upper Susitna River in proportion to their abundance. Capture and tag Chinook
and coho salmon in the lower Susitna River.
The Service recommends that AEA provide additional detail in describing methods for selecting
fish for tagging and how the 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 non-
random in order to selectively tag fish that are not equally represented.
Additionally, it is unclear why only Chinook and coho salmon will be tagged in the lower Susitna
River, whereas all five salmon 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.
AEA Study Objective 2: Characterize the migration behavior and spawning locations of
radiotagged fish in the lower, middle, and upper Susitna River.
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 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
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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.
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).
It is unclear why coho and Chinook salmon will be tagged more intensively than other species. 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.
The 1985 salmon escapement study found that fish captured and tagged at the fish wheels
were non-random, and thus non-representative of the population (Thompson et al. 1986). Data
were stratified for the escapement estimates at the Flathorn Station due to recapture of
numbered tags, but estimates for the other stations did not have enough data for this approach.
This can greatly bias escapement estimates to the Middle River. Thompson et al. (1986)
suggests that length data be collected for individuals (as compared to a subsample of each
days catch) to stratify by size groups because larger fish are less susceptible to fish wheel
capture.
AEA Study Objective 3: Characterize adult salmon migration behavior and timing within and
above Devils Canyon, and AEA Study Objective 4: If shown to be an effective sampling method
during the 2012 study, and where feasible, use sonar to document salmon spawning locations
in turbid water in 2013 and 2014.
Tiffan et al. (2004) described DIDSON as a useful tool for identifying fall Chinook salmon redds
in the Columbia River, but stated that this method is unable to detect smaller redds and may
mis-identify bottom features other than redds if the river bottom is not generally smooth. In that
study, they were able to verify results with video, a method not feasible in the highly turbid
Susitna River mainstem. The Columbia River mainstem and Susitna River, are very different,
and may reduce the effectiveness of sonar surveys for spawning locations. Even when
conditions are good, this method could miss large portions of present spawning populations.
Additionally, it is not clear if this method can accurately provide results by species or simply give
a count of total fish in an area. 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.
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AEA Study Objective 5: Compare historical and current data on run timing, distribution, relative
abundance, and specific locations of spawning and holding salmon, and AEA Study Objective 6:
Generate counts of adult Chinook salmon spawning in the Susitna River and its tributaries.
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.
AEA Study Objective 8: Estimate system-wide Chinook and coho salmon escapement to the
Susitna River and the distribution of those fish among tributaries of the Susitna River.
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.
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.
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).
Related USFWS/NMFS Study Objectives not addressed by the PSP
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 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.
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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.
Literature Cited
Barrett, B.M., F.M. Thompson, and S.N. Wick. 1985. Adult salmon investigations6 May-October
1984 Susitna Hydro Aquatic Studies. Prepared for Alaska Power Authority. Anchorage, Alaska.
Carlson, S.M., and T.P. Quinn. 2007. Ten years of varying lake level and selection on size-at-
maturity in sockeye salmon. Ecology 88(10): 2620-2629.
Keefer, M.L., C.C. Caudill, E.L. Johnson, C.T. Boggs, B. Ho, T.S. Clabough, M.A. Jepson, and
M.L. Moser. 2010. Adult pacific lamprey migration in the lower Columbia River: 2009
radiotelemetry and half-duplex PIT tag studies. For U.S. Army Corps of Engineers. Portland
Oregon. Study Code ADS-P-00-8.
Neilson, J.D., and G.H. Geen. 1981. Enumeration of spawning salmon from spawner residence
time and aerial counts. Transactions of the American Fisheries Society 110(4):554-556.
Thompson, F. M., S. Wick, and B. Stratton. 1986. Adult Salmon Investigations, May–October
1985. Report No. 13. Susitna Hydro Document No. 3412, Anchorage, Alaska.
Tiffan, K.F., D.W. Rondorf, and J.J. Skalicky. 2004. Imaging fall Chinook salmon redds in the
Columbia River with a dual-frequency identification sonar. North American Journal of Fisheries
Management 24:1421-1426.
Yanusz, R., R. Merizon, M. Willette, D. Evans, and T. Spencer. 2011. In river abundance and
distribution of spawning Susitna River sockeye salmon Oncorhynchus nerka, 2008. Alaska
Dept. of Fish and Game, Fishery Data Series No. 11-12. Anchorage, Alaska.
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7. Fish and Aquatic Resources
7.8. River Productivity Study
General Comments:
Although this Proposed Study Plan (PSP) has the same title as the U.S. Fish and Wildlife
Service’s (Service) 31 May 2012 study request, it does not adequately address river productivity
as a whole but is primarily limited to addressing macroinvertebrates and algal abundance.
Studies that document the variability in the sources of carbon and energy transfer to higher
trophic levels are the most important for understanding fish distribution and production, and are
most likely to be directly affected by project construction and operation. Within-stream primary
production, organic matter from terrestrial plants, and adult salmon carcasses provide the food
base for all aquatic life within the Susitna River. There is a substantial body of literature
directed at understanding factors influencing primary productivity, the delivery, storage, and
processing of organic matter, and the influence of carbon sources and production on
macroinvertebrate community composition, production, and density.
Over the past 30 years, there has been an increasing number of studies documenting a shift in
our understanding of fish distribution from one based solely on reducing energy costs (habitat
based on water temperature, and velocity) and avoiding predation (proximity of cover), and
competition, toward one that maximizes food intake while minimizing energy lost and the risk of
predation (Dill and Fraser 1984, Fausch 1984, Dolloff 1987, Duncan et al. 1989, Adams and
Breck 1990). In some cases the abundance of macroinvertebrate drift alone has explained the
distribution and growth of salmonids (Lovetang 2005, Urabe et al. 2010). Food availability can
affect the depths and velocities selected by drift-feeding fish which has implications toward the
validity of habitat suitability indices based on these parameters (Rosenfeld et al. 2005,
Rosenfeld and Taylor 2009).
Primary productivity, benthic organic matter, and macroinvertebrate abundance can be modified
by hydroelectric development and, therefore, should be addressed by Alaska Energy Authority
(AEA) as part of the Federal Energy Regulatory Commission (FERC) license application.
Suspended sediment can limit light available for primary production (Davis-Colley et al. 1992,
Lloyd et al. 1987) particularly in turbid glacial rivers (LaPerriere et al. 1989, Davis et al. 2009).
Sediment storage within a reservoir can reduce turbidity and increase primary productivity
immediately downstream (Blinn et al. 1998); however, even in clear water, nutrients can be lost
within the reservoir through biotic uptake or adsorbed to sediment and deposition thereby
limiting downstream productivity (Snyder and Minshall 1995). Primary productivity can vary with
changes in water depth (Bensen et al. 2012) or be reduced due to varial zone flow fluctuations
(Binn et al. 1998). Transported organic matter is retained within reservoirs reducing
downstream carbon availability (see below) and transport and storage can be further affected by
flow modifications. The macroinvertebrate community can be altered due to modifications in
food sources or food availability or directly through changes in flow and habitat modification.
Primary productivity and benthic organic matter provide the energy base for stream ecosystems.
Macroinvertebrates transfer energy from autotrophs or heterotrophs to higher fish and other
secondary consumers. Macroinvertebrate drift densities play a large role in fish habitat
selection and production and can modify the use different water velocities and depths.
Hydroelectric development can directly or indirectly modify productivity rates, organic matter
input and storage, and macroinvertebrate production (Gislason 1985), particularly in a glacial
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system where suspended sediment plays such a large role in species distribution and
abundance. If we are to make informed decisions regarding this proposed project,
understanding these relationships should be a priority.
Specific Comments by Subsection:
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.
AEA Study Objective 2: Characterize the pre-project benthic macroinvertebrate and algal
communities with regard to species composition and abundance in the lower, middle and upper
Susitna River.
As stated in the PSP and above, ecosystem productivity from autochthonous or allochthonous
derived organic matter, along with import of marine nutrients, provides the energy sources for
the productivity of all other upper trophic levels. Macroinvertebrates transfer energy from
primary producers or heterotrophic communities to fish and other secondary consumers.
Variability in macroinvertebrate abundance in the drift can be directly linked to the distribution
and production of drift-feeding fishes. In addition, macroinvertebrate community composition on
the benthos or in drift has been used to evaluate changes in water quality, biotic communities,
and physical habitats.
Measures of macroinvertebrate emergence timing and biomass among macrohabitat locations
have been suggested by AEA as an additional project objective. As invertebrate development
and emergence is 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.
Sampling Locations
The PSP states that benthic and algal samples will be collected at 9 mainstem and 18 off
channel habitats above and below the proposed dam site, stratified by geomorphic reach and
macro-habitat classification, side channel, side slough, upland slough, tributary, and tributary
mouth [study plan only identifies mainstem, side channels, and sloughs]. Six replicates will be
collected at each sampling location, and samples will be collected on three sampling dates from
April through September. “Woody snags” would be removed from the stream and invertebrates
collected from the snags and identified. Measures of depth, water velocity, turbidity, and
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substrate would be collected at all algal sampling locations. Samples would be collected on
three sampling events for two years.
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.
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.
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 habitat values to upper classification levels will require sampling
relative to, or quantification of, the abundance of these habitat characteristics within each
macro-habitat.
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
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locations and a minimum of 5 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.
Algal sampling locations within the Middle River, including meso- and microhabitats should be
selected independent of macroinvertebrates, as algae respond to different environmental
variables and project effects will vary. However, results should be able to provide information
that can be used to 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.
In order to calculate the production potential within sampling locations, samples also must be
stratified by meso- and microhabitats. For example, collection of algal samples only on cobbles
within Slough 8A would overestimate the productivity of that location. Samples will need to be
collected on different substrate types and then the relative abundance of those habitat types
determined in order to estimate production potential for that location. This goes beyond
measuring water depth, velocity, and substrate at sampling locations, but requires selecting
sampling locations based upon the distribution of water velocities, depths, and substrates.
Similarly, Slough 6A (below the beaver dam) more closely resembles a small lake, and
phytoplankton (and zooplankton) may explain the apparent high productivity and quality of fish
habitat at that location. Measures of ecosystem metabolism may be a simpler and more direct
approach (Young et al. 2008) and should be considered as a method to measure differences in
productivity.
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.
Sample Timing and Frequency
Benthic macroinvertebrate sampling for monitoring purposes is generally conducted in early
spring prior to emergence and in late fall to allow for summer growth. Summer sampling will be
used to estimate differences in food availability among locations, which is important for
understanding the distribution of juvenile bottom-feeding resident fish (e.g. burbot and longnose
suckers). Additional sampling would be necessary to measure secondary production or to
determine if there are multiple cohorts in a season. Sample collection frequency should
document potential project effects, particularly changes in flow and temperature. Sampling prior
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to and following storm events could be used to evaluate the response of the community to the
flow regime.
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.
Sampling Methods
The PSP states that benthic macroinvertebrates will be collected from riffles within each
macrohabitat unit. Samples will be collected with a Hess, Surber, or Slack sampler. Six
replicates will be collected at each sampling location.
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 contain riffles to sample.
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 sub-
sampling method should be included in the study plan.
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 should
describe how samples will be collected from the multiple different available substrates,
including:
Sample substrate must be based upon predetermined criteria;
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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;
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.
AEA Study Objective 3: Estimate drift of benthic macroinvertebrates in habitats within the lower,
middle and upper Susitna River to assess food availability to juvenile and resident fishes.
A large number of studies have shown the importance of macroinvertebrate drift in explaining
the distribution, abundance, and growth of drift-feeding fishes including most salmonids. Project
operations including direct effects of variable flows and indirect effects on primary production
and organic matter storage can influence invertebrate drift density. Therefore, understanding
the relationship between Project operations, drifting invertebrates, and fish distribution is an
important project objective.
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.
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.
Sample Timing and Frequency
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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 quality for juvenile salmonids. Sample collection should occur in the early morning and
evening to document densities during peak fish feeding activity.
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.
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 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.
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.
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.
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.
AEA Study Objective 4: Conduct a literature/data search to identify existing river systems that
could act as surrogates in evaluating future changes to productivity in the Susitna River.
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-
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Project evaluation. AEA should develop a study plan for post-Project monitoring that includes
an assessment of Susitna River productivity.
AEA Study Objective 5: Conduct a review on the feasibility of a trophic analysis to describe
potential changes in the primary and secondary productivity of the riverine community following
Project construction and operation;
Hydroelectric facilities have the potential to reduce the carbon food base which effect fish
production. Dam effects to the organic matter base have been found to be responsible for the
decline in Kootenai River sturgeon (Perry and Perry 1991, Snyder and Minshall 2005) and in
productivity in the Colorado River (Minkley 1991, Blinn et al. 1999). Pre- and post-Project
trophic analyses would provide a method to evaluate potential Project effects to the Susitna
River. 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.
AEA Study Objective 6: Generate habitat suitability criteria (HSC) for Susitna River benthic
macroinvertebrate and algal habitats to predict potential changes in these habitats downstream
of the proposed dam site.
The Service believes that the PSP does not provide enough information to evaluate whether the
stated objective will be met. The PSP states that habitat suitability criteria would be determined
concurrent with macroinvertebrate and algal sampling at the 27 sampling locations above and
below the dam stratified by macrohabitat type and collected three times from April to
September. HSC would be determined from measures of water velocity, substrate, and depth
concurrent with macroinvertebrate and algal sampling.
As stated previously, the level of effort (sampling locations, replication among macro and meso-
habitats, and sampling frequency) described within the PSP is insufficient to provide an
adequate HSC. The sampling plan needs to be more developed to evaluate the response of the
macroinvertebrate community to changes in these three parameters and to include, and control
for, the numerous other parameters that influence invertebrate community composition,
richness, or diversity.
Macroinvertebrate communities are composed of multiple different species that occupy areas of
variable velocity and depth. Within the Susitna River, tolerance for highly turbid waters or
differences in dissolved oxygen could result in shifts in macroinvertebrate habitat preferences.
Diet preferences of target fish in the Susitna River should be used to determine
macroinvertebrate species for HSC in order to determine changes to food availability for fish.
Macroinvertebrates in the diet of burbot and longnose suckers and juvenile whitefish are likely
much different than those selected by drift-feeding fishes. The portion of terrestrial
invertebrates also will vary among drift-feeding fishes (e.g., juvenile sockeye salmon versus
Dolly Varden).
HSC for fish are generally not transferable among stream locations (Persinger 2003, Guay et al.
2001) and this generalization is likely true for macroinvertebrates as well, particularly when
there are large differences in physical and chemical stream characteristics. The 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, sampling timing and frequency that will
be used to meet this objective. Water velocity at 0.6 x water depth is unrelated to the velocity,
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sheer stress, and boundary conditions experienced by macroinvertebrates. Therefore, methods
to measure velocity at scales applicable to organisms under investigation should be established.
Alternately, Froude number or sheer stress could be used to represent stream bed flow
conditions
AEA Study Objective 7: Characterize the benthic macroinvertebrate compositions in the diets of
representative fish species in relationship to their source (benthic or drift component).
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.
AEA Study Objective 8: Characterize organic matter resources (e.g., available for
macroinvertebrate consumers) including course particulate organic matter, fine particulate
organic matter, and suspended organic matter in the lower, middle, and upper Susitna River.
Benthic organic matter is likely the most important source of carbon within the Susitna River.
Bacterial colonization increases the nutrient content and quality of BOM and initiates
decomposition thereby facilitating macroinvertebrate ingestion and metabolism. Construction
and operation of hydroelectric facilities can influence the transportation, storage, and processing
of BOM through multiple different pathways.
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?
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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 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?
The PSP states that in order to quantify the amounts of organic matter available in the Susitna
River for river productivity, Coarse Particulate Organic Matter (CPOM) to Fine Particulate
Organic Matter (FPOM) (specifically FBOM) will be collected concurrently with all benthic
macroinvertebrate sampling (Objective 2, Section 7.8.4.2.1). Suspended FPOM (Seston) [27
locations 3 times from April through September] will be collected at same time and alongside
invertebrate drift sampling (Objective 3, Section 7.8.4.3). Organic matter collection will be
conducted using methods compatible with other Alaska studies, to allow for comparable results.
State and federal protocols will be considered as study plans are developed, in consultation with
resource agencies.
While perhaps not all of the list of questions raised in regard to BOM can be addressed, it is
unclear how the PSP will address any of them. The purposes for BOM sampling are not clear,
nor are the reasons behind the selection of sampling locations, sample timing, or sampling
frequency. Sample collection methods and analyses are not provided and there is no
discussion on how the resulting data would be used to evaluate Project effects.
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 Transported Organic Matter (TOM) and tributary discharge, the role of
tributaries in the organic matter budget. Replicate seasonal samples 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 (Ultrafine Particulate Organic Matter
(UPOM), FPOM, and 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
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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.
AEA Study Objective 9: Estimate benthic macroinvertebrate colonization rates in the middle and
lower reaches to monitor baseline conditions and evaluate future changes to productivity in the
Susitna River.
Project operations will modify the daily and seasonal hydrograph. Flow fluctuations will be
greatest during winter periods of load-following. Dewatering of substrates can result in the loss
or reduction of macroinvertebrate density (Perry and Perry 1986, Hunter et al. 1992). The
effects of flow fluctuations will vary with differences in channel morphology. Determining
colonization rates is an important objective and colonization time lags have been incorporated
into instream flow analyses (Hardy and Addley 2003).
Using a stratified sampling approach, a field study proposed to be conducted by AEA will
estimate potential benthic macroinvertebrate colonization rates for different seasons in the
Susitna River. Sets of three to five preconditioned artificial substrates will be deployed
incrementally for set periods of colonization time (e.g., 12, 8, 6, 4, 2, and 1 weeks) and then
pulled simultaneously at the conclusion of the colonization period. Artificial substrates will be
deployed at three depths at fixed sites along the channel bed. Benthic macroinvertebrate
colonization rates may be conducted in a variety of habitats (e.g., turbid vs. non-turbid areas,
groundwater upwelling areas vs. areas without groundwater upwelling). Benthic
macroinvertebrate processing protocols would be identical to those used in sampling.
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.
Unaddressed Service objective
An additional benthic resource that the PSP does not yet address is the primary food source,
Macoma balthica, of overwintering Rock Sandpipers in the Susitna River Flats. While most
shorebirds migrate outside of Alaska for the winter, the intertidal habitats of Upper Cook Inlet,
and chief among them the Susitna River Flats area, support virtually the entire population (ca.
25,000 birds) of the nominate race of the Rock Sandpiper (Calidris ptilocnemis ptilocnemis)
during the winter (Gill et al. 2002). Because of its highly restricted distribution (breeding and
wintering), this subspecies is listed as a species of high conservation concern in both the U.S.
Shorebird Conservation Plan (Brown et al. 2001) and the Alaska Shorebird Conservation Plan
(Alaska Shorebird Group 2008), and is one of only three ‘red list’ North American shorebird
species of global conservation concern in the National Audubon Society’s Watchlist program
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(Butcher et al. 2007). It is also listed as a Bird of Conservation Concern by the Service (U.S.
Fish and Wildlife Service 2008).
The food supply that supports this unusual overwintering population is the bivalve Macoma
balthica. Gill and Tibbitts (1999) suggest that these birds prefer the Susitna River Flats because
of the overall high densities of clams, with tidal currents in this part of the Inlet affecting benthic
community productivity through ice scour. They have found densities of 2,000-3,000 clams per
square meter in the area. Any Project operations that were to adversely impact this population
of bivalves, whether via changes in sedimentation patterns or other effects, could have
substantial adverse impacts on this important migratory bird population. Therefore, it is an
important objective of the Service’s to study potential Project impacts to the Macoma balthica
population of the Susitna River Flats.
The Service recommends that AEA develop a study plan to:
survey Macoma balthica in the Susitna River Flats,
better understand the factors influencing their abundance, distribution, and availability for
overwintering shorebirds (e.g., ice, wind, and tidal conditions), and
determine how Project operations may affect their abundance and distribution.
To aid in this, we suggest consultating with local Rock Sandpiper experts including Bob Gill and
Dan Ruthrauff of the U.S. Geological Survey’s Alaska Science Center, and literature reviews of
potential impacts of hydro-electric dam operations on downstream populations of Macoma
balthica.
Literature Cited
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and Peter B. Moyle, editors: 389-415.
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Shorebird Group, Anchorage, AK. [Online.] Available at
http://alaska.fws.gov/mbsp/mbm/shorebirds/plans.htm.
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Behn, K. E., T. A. Kennedy, and R. O. Hall. 2010. Basal resources in backwaters of the
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Benenati, E. P., J. P. Shannon, J. S. Hagan, and D. W. Blinn. 2001. Drifting fine particulate
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Benson, E. R., M. S. Wipfli, J. E. Clapcott, and N. F. Hughes. 2012. Relationships between
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Blinn, D. W., J. P. Shannon, P. L. Benenati, and K. P. Wilson. 1998. Algal ecology in tailwater
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Blinn, D. W., J. P. Shannon, K. P. Wilson, C. O'Brien, and P. L. Benenati. 1999. Response of
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Davis, J.C. G.A. Davis, and N.R. Ettema. 2009. Water Quality Evaluation of the Lower Little
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Environmental Conservation. ACWA 09-02. Talkeetna, AK..
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discharges on streams 1. optical properties and epilithon. Hydrofiologia 248:215-234.
Dill, L.M. and A.H.G. Fraser. 1984. Risk of predation and the feeding behavior of juvenile coho
salmon (Oncorhynchus kisutch). Behavioral Ecology and Sociobiology 16: 65-71.
Dolloff, C.A. 1987. Seasonal Population Characteristics and Habitat Use by Juvenile Coho
Salmon in a Small Southeast Alaska Stream, Transactions of the American Fisheries Society
116:6, 829-838
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evaluation of altered riparian vegetation in three southeast Alaskan streams. Water Resources
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energy gain. Canadian Journal of Zoology 62: 441-451.
Gislason, J.C. 1985. Aquatic Insect Abundance in a Regulated Stream under Fluctuating and
Stable Diel Flow Patterns. North American Journal of Fisheries Management 5: 1,39-46.
Jakob, C., Robinson, C.T. and U. Uehlinger. 2003. Longitudinal effects of experimental floods
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Colorado River, southwestern USA. Regulated Rivers 8: 323-334.
Lovtang, J.C. 2005. Distribution, habitat and growth of juvenile Chinook salmon in the Metolius
River Basin, Oregon. Masters Thesis. Oregon State University, Corvallis, OR.
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Major, E.B., and M.T. Barbour. 2001. Standard operating procedures for the Alaska Stream
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Chapter two in: T.D. Fontaine and S.M. Bartell (eds). Dynamics of lotic ecosystems. Ann Arbor
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impoundment on particulate organic matter in a river system. In: J. V. Ward and J. A. Stanford
(eds.) The Ecology of Regulated Streams. Plenum Press, New York: 339-364.
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continuum concept. Canadian Journal of Aquatic Sciences 37: 130-137.
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ecosystem metabolism: functional indicators for assessing river ecosystem health. Journal of
North American Benthological Society 27: 605-625.
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7. Fish and Aquatic Resources
7.9. Characterization of Aquatic Habitats in the Susitna River with Potential to be
Affected by the Susitna Watana Project
General Comments:
The goal of this Alaska Energy Authority (AEA) proposed study plan (PSP) is to “characterize all
aquatic habitats with the potential to be altered and/or lost as the result of reservoir filling,
hydropower operations, and associated changes in flow, water surface elevation, sediment
regime, and temperature” for the Susitna Watana Hydroelectric Project (Project). Due to the
size of the study area, the PSP proposes to use different data collection methods at different
locations, based upon the degree of potential impact and hence, differences in data quality.
Study objectives subdivide the study area into mainstem and tributary habitat in the middle and
the lower river (River Mile (RM) 28), the reservoir inundation zone, and the upper river tributary
and lakes upstream from the dam site to the Oshetna River currently accessible to fish or that
will be accessible from the reservoir.
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 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”.
Initial habitat classifications have been based upon descriptions developed previously by the
Alaska Department of Fish and Game (ADF&G) including main channel, side channel, off-
channel, tributary mouth, and tributary (in AEA Table 7.9.1, but not in Figure 7.9.10). Off-
channels would be further classified as side sloughs, upland sloughs, and other off-channel
types in Figure 7.9.10, but subdivided differently in the Table, with three types of “other off-
channel types” listed.
The difference and importance of differentiating between main channel and side channel is not
defined, but is presumed to be due to the portion of flow in each. Similarly, the differences
between side sloughs, upland sloughs, and other off-channel habitat are not defined, but may
be retaining the initial ADF&G system and be based upon a connection to the main channel at a
defined flow or stage. To this point, the classification is based upon differences in geomorphic
and hydrologic process and to some extent water quality (portion of main channel turbid flow).
All of these locations provide habitat for different fish species and life stages, and should not be
used as a “habitat” classification for any given species. Fish distribution at this scale is likely
more related to different levels of tolerance to turbid water, which varies among these locations
but also seasonally within the main channel. Upper River tributaries are not further classified
geomorphically based on slopes, confinement, width/depth, or substrate (sensu Rosgen 1994)
or by stream order or link (Strahler 1957).
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The next level of classification is defined as “meso-habitat” and the PSP argues that meso-
habitat 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.
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.
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.
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 would be
compromised if some habitats are missed due to the inability of aerial imaging to capture them.
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.
It is most concerning that the video mapping data will only be collected in mid to late September
when flows are expected to 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
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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.
Specific Comments by Subsection:
AEA Study Objective 1: Characterize the existing upper mainstem Susitna River and tributary
habitat within the proposed inundation zone.
AEA’s purpose in applying this classification method to Upper river tributaries and mainstem
locations within the inundation zone is unclear. 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. However, this may be at a larger scale. 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.)
The objective only addresses the mainstem and tributaries of the upper reach. 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. 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 abundant suitable habitat for a variety of species and
should be addressed. Previous impoundment studies in the upper river have caught burbot,
longnose suckers and round whitefish in backwaters and sloughs off the main channel (ADF&G
1983).
The PSP does not contain any review of the time-based frequency method proposed.
AEA Study Objective 2: Characterize the middle (RM 98 to RM 184) and the lower (RM 28 to
RM 98) mainstem Susitna River channel margin and off-channel habitats using the Susitna-
Watana Project habitat classification system and standard USFS protocols, with modifications to
accommodate site-specific habitats.
The Fish and Aquatics Technical Work Group (TWG) is developing a Susitna River
classification system based on the U.S .Forest Service (USFS) Aquatic Habitat Surveys
Protocol (USFS 2001). The Service previously recommended the use of 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, its associated tributaries, and off-channel habitats.
If AEA’s objective is to apply a classification method that can be used to describe the
distribution of fish, then other criteria must be considered. Sources of water and water quality
appear to be important characteristics of fish distribution in glacial rivers (Curran et al. 2011,
Murphy et al. 1989, Lorenz et al. 1989). Classification of main channel, tributary, and off-
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channel locations should be used as a macro-habitat level classification, as described in
Service-recommended hierarchal nested habitat table. Differences in spawning locations are
primarily clear-water tributaries, groundwater dominant side channels, and the mainstem
(including side channels dominated by turbid mainstem water). Spawning is limited within the
mainstem, presumably due to high turbidity and high percent fines, when spawning gravels are
present. Similarly, mainstem rearing increases in the winter months when turbidities are low.
Summer juvenile rearing occurs in tributaries and off-channel habitats with surface-water
connections. 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. Moderate slope clear-water tributaries
(Indian, Portage, and Gold Creek) have much higher specific conductivity and dissolved oxygen
concentrations and are important Chinook spawning streams. Brown-water tributaries which
drain wetland soils with much lower conductivity and high dissolved carbon concentrations, and
lower pH and dissolved oxygen, are warmer and support coho spawning and rearing and some
Chinook rearing.
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 unvegetated 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.
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. The Service remains concerned with the stunting of the proposed Project-
effects boundary at RM 28. AEA refers to RM 28 as the “potential zone of Project hydrologic
influence” without adequate documentation of this claim. The Service recommends that this be
confirmed through study prior to finalizing this characterization.
AEA Study Objective 3: Characterize the tributary and lake habitat upstream from the proposed
Watana Dam site to the Oshetna River (RM 184 to RM 233.4) that is currently accessible to fish
from the Susitna River or that would be accessible due to inundation of existing fish passage
barriers after the reservoir is filled.
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. 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.
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Related USFWS/NMFS Study Request Objectives
This PSP for aquatic habitat survey and characterization is insufficiently designed to account for
the basic ecology of floodplain fishes or the diversity of aquatic habitats in the Susitna River, or
any large floodplain system at these latitudes. These systems are characterized by a dynamic
ground and surface water hydrology and geomorphology that interact with cold climates. Upon
these fundamental layers of complexity, the distributions of fish species shift seasonally
between ground and surface water dominated habitats and between channel networks of the
primary and off-channel environments. Surveys and classifications (characterizations and
delineations) of these seasonal distributions and habitats should pursue a strict hierarchical
habitat classification that allows for the separation and comparison of the basic physical drivers
of habitat selection.
AEA proposes to characterize (delineate and map) habitats of the project area by mesohabitats
and states that fish distributions are primarily structured at this level. This is not entirely correct
for large floodplain systems at these latitudes. Mesohabitat delineation is based on the
hydraulic continuum of a channel’s riffle-pool sequence. Characterization of habitat, at this
level, ignores the fundamental influences of ground and surface water exchanges and the
dramatic differences in habitat that are found amongst the various macro-habitats of the river’s
floodplain. It is at this level, that the distributions of fish are primarily structured (e.g., spawning
in side sloughs, overwintering in the mainstem). Within these macro-habitat levels, the
distributions of fish are responsive to mesohabitats, but perhaps of greater importance are the
local manifestations of hydrology and geomorphology at the microhabitat level. The Service
finds that a systematic assessment of the ecological relevance of local variables requires a
hierarchical characterization of habitat. We recommend the habitat be characterized through
the following hierarchy:
1. Geomorphic units: Large-scale geomorphic and hydraulic controls.
a. Bedrock controlled single-channel units with shallow hyporheic exchange and
thermal homogeneity.
b. Unconfined, multiple channel floodplain units with expansive hyporheic exchange
and thermal heterogeneity.
2. Macrohabitats: Primary, flood, and spring channel networks.
a. Primary channels—Perennial channels.
b. Flood channels—seasonally connected channels.
c. Spring channels (clear water)—Disconnected sloughs that discharge groundwater.
d. Floodplain ponds—Ponded spring channel networks.
e. Tributary mouths
3. Mesohabitats: Bed and bank morphological controls; hydraulic features.
a. Riffle-pool sequences—Run, riffle, pool, glide, tailout.
b. Backwaters, alcoves, shallow meander margins.
4. Microhabitats: Hydraulics, water quality, substrate, cover.
a. Water depth, velocity, bulk flow characteristics (e.g., Reynolds and Froude #’s).
b. Vertical hydraulic exchange (ground and surface water exchange).
c. Bed, or intragravel temperature and dissolved oxygen.
d. Substrate size, heterogeneity.
e. Elements of wood, vegetation, and rock structure.
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The PSP states that the mesohabitat scale is the most meaningful to fish and that macro-habitat
delineations will only be considered to perform “some level of comparison over time”. Though
we agree 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. It
confuses scales of organization (e.g., refers to beaver complexes and ponds as meso-habitats
and uses a different hierarchy than that referred to in the PSP. It contains meso-habitats that
are not well represented, or absent in large floodplain systems (e.g., pools and cascades), and
omits those that are (e.g., glides and tail-outs), but it contains habitat categories that aren’t
relevant to a large floodplain systems. AEA needs a habitat hierarchy that is developed for
large northern floodplains and directs the systematic characterization of habitats important to
the distributions and life history patterns of fishes of the Susitna River. The Service
recommends that AEA adopt the hierarchical model developed and supported by the agencies.
Literature Cited
ADF&G (Alaska Department of Fish and Game). 1983. Phase II Basic Data Report Vol. 5:
Upper Susitna Impoundment Studies 1982. ADF&G/Susitna Hydro Studies. Anchorage, Alaska.
Beechie, T. J., M. Lierman, E. M. Beamer, and R. Henderson. 2005. A classification of habitat
types in a large river and their use by juvenile salmonids. Transactions of the American
Fisheries Society. 134: 717-729.
Curran, J.H., McTeague, M.L., Burril, S.E., and Zimmerman, C.E., 2011. Distribution,
persistence, and hydrologic characteristics of salmon spawning habitats in clearwater side
channels of the Matanuska River, southcentral Alaska: U.S. Geological Survey Scientific
Investigations Report 2011–5102, 38 p.
Lorenz, J.M., and J.H. Eiler. 1989. Spawning habitat and red characteristics of sockeye salmon
in the glacial Taku River, British Columbia and Alaska. Transactions of the American Fisheries
Society 118:495-502.
Murphy M. L., J. Heifetz, J. F. Thedinga, S. W> Johnson, and K. V. Koski. 1989. Can. J. Fish.
Aquat. Sci. 46
Rosgen, D.L., 1994. A Classification of Natural Rivers. Catena 22:169-199.
Strahler, A. N. 1957. Quantitative analysis of watershed geomorphology. Transactions of the
American Geophysical Union 8 (6): 913–920 .
U.S Forest Service (USFS). 2001. Chapter 20-Fish and Aquatic Stream Habitat Survey. FSH
2090-Aquatic Habitat Management Handbook (R-10 Amendment 2090.21-2001-1).
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7. Fish and Aquatic Resources
7.11. Study of Fish Passage Feasibility at Watana Dam
General Comments:
On September 24 and 25, 2012, the National Marine Fisheries Service (NMFS) convened Fish
Passage meetings and began to informally resolve study issues with Alaska Energy Authority
(AEA) and other state and federal agencies, including U.S. Fish and Wildlife Service (Service),
and stakeholders per Section 5.11 of the Federal Energy Regulatory Commission (FERC)
Integrated Licensing Process (ILP). This process is ongoing. On October 31, 2012, AEA
posted a draft Revised Study Plan (RSP) on its website. A cursory review of the draft RSP
indicated that AEA has revised their July 2012 Fish Passage Feasibility Proposed Study Plan
(PSP). Notably, the PSP has been revised to include development of three conceptual
alternatives for fish passage. This fish passage consideration and evaluation process that has
begun is nearly a year earlier than AEA had initially proposed. However, the Service has not
yet had sufficient time to review the draft RSP that was provided less than two weeks before
comments on the PSP are due to FERC. Thus, our comments are based upon AEA’s July 16,
2012, PSP and how well they address the goals and objective of the May 31, 2012, Fish
Passage study request.
While efforts have been made to mention some of the revisions developed at and since our
September Technical Work Group (TWG) meetings, the Service is adhering to the FERC
mandated ILP process. Cursory review of the draft RSP indicates that AEA is referring to
results from some of the 2012 fisheries studies. These reports have not yet been provided to
the Service for review. Lacking these reports limits our ability to begin adequate review of the
RSPs.
The Fish Passage Feasibility PSP proposes to address information needs for the Service to
determine the feasibility of developing mandatory fishway prescriptions. This differs from the
Service’s objectives in the Fish Passage Study Request which also includes, if warranted,
developing preliminary fishway prescriptions, as described in the Interagency Guidance for the
Prescription of Fishways Pursuant to Section 18 of the Federal Power Act (USFWS and NMFS
2002).
Section 18 of the Federal Power Act (FPA) states that FERC “shall require the construction,
maintenance, and operation by a licensee at its own expenses of such…fishways as may be
prescribed by the Secretary of the Interior or the Secretary of Commerce, as appropriate (16
U.S.C. § 811).” Section 18 authority is delegated to the NMFS within the Department of
Commerce and to the Service within the Department of Interior. For resources under its
jurisdiction, the Service may prescribe fishways as necessary to maintain all life stages
impacted by the project. Congress has provided guidance that fishway prescriptions are limited
to physical structures, facilities, or devices necessary for such protection; and project operations
and measures related to structures, facilities, or devices necessary to ensure effectiveness.
Pub. L. 102-486, title XVII, § 1701(b), Oct. 24, 1992, 106 Stat. 3008. The Commission shall
incorporate these mandatory conditions in a hydropower project license, or the Services may
reserve their authority to include a fishway prescription in the future.
Discussion
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The central features of the proposed project are the 750 foot high dam at river mile 184 and the
reservoir extending about 43 miles upriver of the dam. The dam as proposed would block the
upstream and downstream passage of Chinook salmon (Oncorhynchus tshawytscha), possibly
other salmon species and resident fish that migrate through and use the proposed Susitna-
Watana dam site; and upstream habitat in the river and its tributaries. The reservoir would
inundate some tributary spawning habitat, alter or remove rearing habitat, affect migration both
up- and down-stream for juveniles and adults, isolate tributaries from the mainstem as water
levels rise and fall, and change the bioenergetics, temperatures, turbidity and physical and
biological characteristics of the river below the dam as the natural hydrograph is altered by
project operations.
Chinook salmon are known to migrate to the Upper Susitna River as far above the proposed
dam site as the Oshetna River and to successfully spawn and presumably rear there. The
upstream extent of Chinook migration is not known definitively, nor is use of tributary or
mainstem habitats. It is unknown but suspected that some Chinook salmon that are spawned in
the upper river migrate downstream and rear in the middle river. Little else is known about
anadromous species use above the dam site in either the Susitna River or its tributary streams.
The Service adopted AEA’s 2012 baseline data collection study objectives for the distribution of
Chinook salmon and other fish species above Devils Canyon in its study request for fish
passage. This baseline data collection effort is planned as a multi-year fish study that includes
data collection beginning in 2012 as pre-ILP studies, with two additional years proposed by AEA
under the ILP study process.
The Service requested the following modifications to the 2012 and ILP baseline data collection
study objectives:
Fish surveys should 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 necessary to obtain the minimum amount of biological information about the
population to develop and design mitigation, and determine the need for fish passage.
Fish surveys should be designed and conducted to determine the occurrence and timing
of all species and life stages of anadromous and resident fish that migrate both
upstream and downstream of the proposed dam site. Data without all species and life-
stages is insufficient to inform passage due to the variability in year-class strength as
evidenced by the recent Alaska-wide downturns in productivity and abundance of
Chinook salmon stocks.
Genetic samples collected from Chinook salmon should be analyzed to assess the
genetic makeup and viability of this population, and thus inform the need for fish
passage of Chinook salmon for this project. It is necessary to collect and analyze
sufficient numbers of genetic samples from Chinook salmon adults and juveniles from
tagging sites, spawning sites and rearing sites to determine if they are differentiated from
other Susitna Chinook salmon populations. It is unknown whether fish migrating into the
upper river are genetically distinct from fish spawning elsewhere in the Susitna
watershed. It is also unknown if fish spawned in the upper river rear in the upper river
habitat or migrate downstream to rear in the middle or lower river areas. Collection and
analysis of genetic material from these fish is needed for the Service to determine the
contribution of upper river Chinook salmon to the Susitna River populations.
The Service provided generic guidance on methodology and information needs for determining
fish passage feasibility and design from NMFS’s Anadromous Salmonid Passage Facility
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Design document (NMFS 2011). Given the height of the proposed dam however, we advised it
would be prudent to involve resource agencies fish passage engineers directly in determining
the feasibility of fish passage at the Susitna-Watana dam. NMFS and the Service offered to be
available to discuss the criteria in general and in the context of the specific site. AEA was
encouraged to initiate coordination with NMFS fish passage specialists early in the development
of the preliminary design to facilitate an iterative, interactive, and cooperative process.
NMFS and the Service requested that feasibility planning for fish passage facility design begin
with early coordination with resource agencies Fish Passage Engineers, starting with site
reconnaissance and review of preliminary engineering designs. Collection of baseline biological
information, site information, and project operations information essential to determine the need
to prescribe fish passage for the proposed project was described and requested as follows:
Design Development Phases:
1) Conduct a reconnaissance study - An early investigation of one or more options for project
design, siting and suitability of the proposed project design and construction of some type of
fish passage facility.
2) Conceptual alternatives study - List the types of facilities that may be appropriate for
accomplishing objectives at the proposed project site. It should result in a narrowed list of
alternatives that merit additional assessment or explain the need for development of a novel
alternative.
3) Feasibility study - An incrementally greater amount of development of each design concept
(including a rough cost estimate), which enables selection of a most-preferred alternative.
4) Preliminary design - Additional and more comprehensive investigations and design
development of the preferred alternative, and results in a facilities layout (including some
section drawings), with identification of size and flow rate for primary project features. Cost
estimates are also considered to be more accurate. Completion of the preliminary design
commonly results in a preliminary design document that may be used for budgetary and
planning purposes, and as a basis for soliciting (and subsequent collating) design review
comments by other reviewing entities. The preliminary design is commonly considered to be
at the 20% to 30% completion stage of the design process.
5) Detailed design phase - Use the preliminary design as a springboard for preparation of the
final design and specifications, in preparation for the bid solicitation (or negotiation) process.
Once the detailed design process commences, the Service must have the opportunity to
review and provide comments at least at the preliminary design, 30%, 60% and 90% design
completion stages. If substantial changes are still needed beyond the 90% stage, the
Service will review and comment on these as well. These comments usually entail
refinements in the detailed design that will lead to operations, maintenance, and fish safety
benefits. Electronic drawings accompanied by 11 x 17 inch paper drawings are the preferred
review medium.
Preliminary Design Development – Required Site Information:
1) Functional requirements of the proposed fish passage facilities as related to all anticipated
operations and river flows. Describe median, maximum, and minimum monthly flow rates
through the planned hydro facility, plus any special operations (e.g., use of flash boards,
seasonal storage or drawdown etc.) that modify forebay or tailrace water surface elevations
or river flows. Identify proposed project operational information that may affect fish migration
(e.g., powerhouse flow capacity, period of operation, etc.).
2) Site plan drawing showing potential location and layout of the proposed downstream and
upstream passage facilities relative to planned project features facilities.
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3) Topographic and bathymetric surveys, particularly where they might influence locating
fishway entrances and exits, and personnel access to the site.
4) Drawings showing elevations and a plan view of planned flow diversion structures, including
details showing the intake configuration, location, and capacity of project hydraulic features.
5) Basin hydrology information, including daily and monthly streamflow data and flow duration
exceedence curves at the proposed fish passage facility site based on the entire period of
available record. Where stream gage data is unavailable, or if a short period of record exists,
appropriate synthetic methods of generating flow records may be used.
6) Project forebay and tailwater rating curves encompassing the entire operational range.
7) Predict river morphology trends. Because the fish passage facility is proposed at a new
diversion, describe the potential for channel degradation or channel migration that may alter
stream channel geometry and compromise fishway performance. Use results from the
instream flow and geomorphology studies to describe whether the stream channel is stable,
conditionally stable, or unstable. Estimate the rate of lateral channel migration and change in
stream gradient that has occurred over the last several decades. Describe what effect the
proposed fish passage facility may have on existing stream alignment and gradient and the
potential for future channel modification due to either construction of the facility or continuing
natural channel instability.
8) Special sediment and/or debris problems. Describe conditions that may influence design of
the fish passage facility, or present potential for significant problems, such as glacial silt
loads.
9) Provide other site-specific or species-specific information that will inform the fishway designs
and operations, such as accretion, earthquake fault zones, and permafrost conditions.
10) Derive hydrographs showing daily average river flow over the entire period of record for the
proposed project area extrapolated for future projected change in hydrology.
11) Measure and report the stream bed profile (feet per mile) and composition, including the
river from its mouth (River Mile (RM) 0) to the proposed project site for each species listed
above. In the vicinity of the proposed project impoundment, provide three-dimensional
topography/bathymetry including proposed location of the dam (spillway, power intakes, non-
flow areas) and reservoir up to the maximum inundation expected.
Preliminary Design Development – Required Biological Information:
1) Identify each species and life stages to be passed downstream.
2) For each downstream migrating species and life stage, estimate the start and end date of the
downstream migration. Identify how future project operations (reservoir storage, powerhouse
flow and spillway flow) may alter migration timing. Identify effects of future project features,
such as altered prey or predator concentrations, temperature changes, lighting changes, flow
alteration and other physical, chemical and biological parameters.
3) For each downstream migrating species and life stage, determine the range of fish size,
swimming ability (darting, sustained and cruising speeds) over the range of environmental
conditions, run size, operational conditions and behavioral constraints to downstream fish
passage.
4) Derive the standard downstream fish passage design flows for the passage season by
calculation of the 5% (high design flow for fish passage) and 95% (low design flow for fish
passage) exceedence flows (based on daily average flow) for the downstream passage
season for each species and life stage.
5) Identify each species and life stages to be passed upstream.
6) For each annual upstream migrating species/life stage, determine the start and end date of
the upstream migration.
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7) For each upstream migrating species and life stage, determine the range of fish size,
swimming ability (darting, sustained and cruising speeds) over the range of environmental
conditions, run size, operational conditions and behavioral constraints to upstream fish
passage. Identify spawning location for each salmonid species present at the site.
8) Identify other anadromous species and their life stages that are present at the proposed
project site that also require intermittent passage.
9) Identify predatory species (avian, terrestrial, and aquatic) that may be present and prey on
juvenile or adult anadromous species, and describe how the proposed project could affect
populations or concentrations of these predators.
10) High and low design passage flow for periods of upstream fish passage. Derive the
upstream fish passage design flows for the passage season by calculation of the 5% and
95% exceedence flows (based on daily average flow) for the passage season for each
species and life stage to be passed upstream.
11) Identify any known behavioral factors that might affect salmonid passage. For example,
most salmonid species pass upstream through properly designed orifices, but other species
that are unable to pass through orifices may impede salmonid passage. In addition, some
salmonid species may not pass through orifices. Other examples of behavioral factors that
should be considered include schooling behavior, migration depth, preferred water
temperatures, potential reaction to natural and artificial vertical structure and cover, reaction
to lighting, diel passage patterns, reaction to flow velocity gradients and others.
12) Identify what is known and what needs to be researched about upstream and downstream
fish migration routes approaching the proposed project.
13) Compile available information on the minimum and maximum streamflow that will allow
upstream migration up to the proposed project.
14) Describe the degree of activity (fishing/bears/otters) in the area of the proposed project and
the need for measures to reduce or eliminate fishing activity.
15) Identify water quality factors that may affect fish passage at the site. For each species/life
stage migration, estimate the start and end date of the migration and assess the potential
variation in migration season based on environmental factors (e.g., Changes in water
temperature, impoundment effects, forebay delay, water temperature (average and reservoir
profile), egg hatch timing, dissolved oxygen, low river flow, high river flow, etc.). Fish may not
migrate if water temperature and quality are marginal, and may instead seek holding zones
until water quality conditions improve.
Assessment of Operational Impacts on Fish Passage for the proposed project will require the
following project-specific information:
1) Forebay rating curve - Provide the expected operation of the forebay for the migration season
for each species and life stage to be passed downstream. Include expected operations for
future years given the climate forecasting hydrology study results (snow pack, stream gaging,
glacial meltwater). The rating curve should display day of year as the independent variable
and forebay elevation as the dependent variable, and should also include appropriate bands
identifying each migration season.
2) Tailwater rating curve - Provide the expected tailwater operation for the extent of the
upstream migration season. The rating curve should display day of year as the independent
variable and tailwater elevation as the dependent variable, and should also include
appropriate bands identifying each upstream migration season.
3) Turbines - Turbine design should maximize fish survival through the turbine, and minimize
turbulence and total dissolved gas uptake in the tailrace. Derive the expected effects of
passage through turbines for the range of sizes of fish expected in the project forebay.
Include blade strike, scraping of fish (between the blades and hub and between the blade tips
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and turbine housing), the pressure change within the turbine, and the pressure profile from
fish migration depth through the turbine intake, through the turbine, through the draft tubes
and into the tailrace.
4) Draft tube velocity - Calculate draft tube velocity range for all standard operations, including
turbine up ramp rates and turbine shut down rates. Identify turbine intake locations, in
elevation relative to the range of forebay elevation. Identify draft tube discharge depth and
locations in relation to tailrace.
5) Sediment capacity - By collection of stream samples over the entire range of expected
stream flows, model the change in reservoir bathymetry over a 50-year period in annual
increments.
6) Reservoir hydraulics - By computational fluid dynamic model, demonstrate the reservoir
velocity contours in increments of 0.01 feet/second (or as appropriate) for each forebay level
expected over the downstream migration season, in five foot increments. Include
powerhouse flows, spillway flows and seasonal flow storage volumes. Include the entire
reservoir, but data is most important and therefore should be the most detailed around the
dam structure.
7) Flow continuation - Identify means of providing continuous instream flow if turbine and/or
spillway becomes inoperable.
8) Upstream passage flows downstream of the project – Identify minimum instream flow that will
provide optimal upstream passage up to the proposed project, including habitat impacts from
proposed project revising the flow regime downstream of the project.
9) Describe range of forebay fluctuation, relative to preliminary plans for power operations.
10) Describe range daily tailrace fluctuation, relative to preliminary plans for power operations.
11) Describe river ramping rates, relative to preliminary plans for power operations.
12) General layout of planned hydro project. Include dam layout (in plan, elevation and typical
cross sections), flow direction (for the entire operational scenario), powerhouse location,
spillway location, top, submerged spill routes (include longitudinal profile and cross sections
of conveyance structures) and any appurtenant structures.
13) General operating plan. Identify expected power production on an annual basis, based on
the expected water use for power production and spill. For the spillway, derive from flow
records the expected frequency, duration and seasonal occurrence of spill. For the
powerhouse, derive the hourly and seasonal operation schedule, in terms of flow used for
power production. For the reservoir, based on the expected operation schedule, identify daily
and seasonal changes in storage.
14) Describe design capacities for hydraulic conveyance structures.
The PSP does not address the Service’s study request and information needs in sufficient detail
to determine what parts of our study request are adopted, what parts are not, and if not, why
not. The Service recommends AEA identify the differences between our study request and their
PSP and provide an explanation where, and why, they did not address our request.
Specific Comments by Subsection:
7.11.1.1 Study Goals and Objectives
The study plan articulates fish passage study goals and states "A variety of engineering,
biological, sociological, and economic factors may need to be considered." The study plan
further indicates that feasibility analysis of fish passage alternatives (last bullet under first
paragraph in 7.11.4 page 7-92) will be conducted. This section also states that AEA will
"generally follow" NMFS 2011 guidance in the Anadromous Salmonid Passage Facility Design
document.
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With regard to “economic factors,” the referenced NMFS guidance document states: “Instances
will occur where a fish passage facility may not be a viable solution for correcting a passage
impediment, due to biological, sociological, or economic constraints. In these
situations, removal of the impediment or altering operations may be a suitable surrogate for a
constructed fish passage facility. In other situations, accomplishing fish passage may not be an
objective of NMFS because of factors such as limited habitat or lack of naturally occurring runs
of anadromous fish upstream of the site. To determine whether NMFS will use its
various authorities to promote or to prescribe fish passage, NMFS will rely on a collaborative
approach, considering the views of other fisheries resource agencies, Native American Tribes,
nongovernment organizations, and citizen groups, and will strive to accomplish the objectives
in watershed plans for fisheries restoration and enhancement.”
This guidance is intended for the restoration of fish passage, not for the initial blockage of fish
passage through construction of a new dam. The guidance indicates that economic factors may
be used to evaluate various alternatives that all achieve fish passage should the agencies
determine that fish passage is necessary and thus prescribe fish passage under authority of the
Federal Power Act. This guidance does not indicate 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 revised to clarify that the consideration of economic
factors is limited to evaluating the cost effectiveness of various fish passage alternatives and will
not be a factor in the Service’s determination of whether fish passage will be prescribed.
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.
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.
7.11.4.1. Compile, Review and Summarize Information
The Service has not concurred with AEA’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. The following information has not been provided or reviewed:
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the 2012 Upper Susitna River Fish Distribution and Habitat Study;
the Salmon Escapement Study;
the Middle and Lower River Fish Production Study, and
the Fish Passage Barriers Study; along with
any outstanding historical data and reports that are not yet available from the 1980s
historical studies; and
a comprehensive literature review,
Once the above information is provided, it may be desirable and possible to select a smaller
range of target species and life stages. The target fish species should include both anadromous
and non-anadromous and resident species that require passage at the site (juvenile and adult
passage both upstream and downstream passage and the timing) because fishways by
definition consist of the physical structures, facilities, or devices necessary to maintain all life
stages of fish by enabling fish to safely bypass the dam. 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 (for both upstream and downstream
passage).
7.11.4.3. Define and Document a Development Process
The Service 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 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. This could be a valuable tool to
decide between various alternatives.
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 cost at the feasibility stage. If that process were to be followed, then the ability to
develop and prescribe fish passage would be seriously limited or even excluded from the onset.
The process to develop a fishway feasibility assessment should be constructed in a manner that
helps federal fishery agencies make decisions regarding fishway prescription without eliminating
options prematurely and diminishing the authority of federal fishery agencies to require FERC
licenses to include fishway prescriptions.
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 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.
Outstanding Information Needs and Unresolved Issues
Study reports from AEA’s 2012 Fisheries Studies are expected to add to the available
information; this information is not yet available for agency review and is a serious constraint on
the agency’s ability to timely and effectively assess the proposed studies. These reports should
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be made available, even if in draft form, as soon as possible to facilitate a more informed and
effective study plan development process.
NMFS has initiated involvement of their Fish Passage Engineers in the project, beginning with a
series of meetings and a site visit to the Susitna River in late September. NMFS Senior Fish
Passage Engineer from the Northwest Region, Ed Meyer, traveled to Anchorage and met with
Alaska Region staff, AEA, and the Service on September 24, 2012. On September 25, NMFS
convened a meeting of state and federal agency staff and the applicant to discuss Section 18
Fish Passage Authority, fish passage at other hydro facilities, and the formation of a Fish
Passage Technical Working Group. On September 26 NMFS conducted a site visit to the
proposed Watana dam site. NMFS developed an information-needs list working with AEA’s
Fish Passage Engineering contractor, Dennis Dorratcague of Montgomery Watson/Harza. The
Service supports and agrees with NMFS steps to address our agencies fish passage concerns
pursuant to our joint federal authorities under the FPA.
In these meetings on September 24 and 25, NMFS, AEA, the Service and ADFG agreed to hold
brainstorming meetings as a first step to identify and discuss potentially viable fish passage
design concepts for the Susitna-Watana Project. A group of experienced fish passage
engineers will convene to develop design concepts for both upstream and downstream fish
passage. Project concepts will be developed during the course of studies for two alternative
approaches listed below, to compare with the current proposal, which does not include passage
structures.
1. Develop concept designs for fish passage facilities integral with the design development
of the dam and outlet works.
2. Develop fish passage concept designs that could be added to the preferred design for
the dam and outlet works later.
It was also decided in the meetings that upstream passage may likely be trap and haul.
However, design specifications have not been provided to support the feasibility of this concept
relative to the topography of the Susitna River basin. Brainstorming sessions will address both
downstream and upstream passage. This approach conforms to the PSP, Section 7.11.
Much of the data required for the concept designs of the passage facilities is listed in 7.11.4.1 of
the PSP. Therefore, it is anticipated that the design proposals will be informed by early results
of data gathering efforts, lessons learned from other streams, and results from early runs of the
project operations model. Any and all assumptions will be stated and validated. Additional
information and guidance will be obtained from NMFS, Northwest Region, “Anadromous
Salmonid Passage Facility Design”, July 2011 and other accepted fish passage design books
and topical scientific literature.
USFWS Recommendations
1. 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.
2. The Service continues to recommend that fisheries surveys be 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
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information about the population that is necessary to develop and design mitigation, and
determine the need for fish passage for this project.
3. 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.
4. The study plan should be revised 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. The Susitna-Watana dam would be a new project on a free-flowing glacial salmon
river, with no preexisting facilities, thus the project must incorporate features into its initial
design and operations that increase the likelihood of successful fish passage. The RSP
should include three dam design alternatives at the site:
(1) A design that incorporates fish passage facilities as an integral part of the design,
(2) The currently proposed design with fish passage retrofitted into the project and,
(3) The current design with no fish passage.
With this in mind, we recommend that the list of necessary baseline data be revised to
provide information necessary for the design of all three project options. To aid in this
development, we recommend that the Fish Passage Workgroup be convened at the earliest
opportunity to help identify the necessary baseline data. The proposed schedule (7.11.6)
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. AEA has agreed with the Service’s request that the study plan for fish passage
begin with early and regular consultation with agency fish passage engineers and the TWG.
As part of the Fish Passage Workgroup, a group of experienced fish passage experts
should be convened for an initial multi-day (3 to 4 day) "brainstorming session" to help
identify any additional baseline information needs, as well as ideas for fish passage
alternatives for the project. We recommend scheduling this meeting as early as possible,
ideally in early January 2013.
5. 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
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.
6. 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
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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.
Literature Cited
Barrick, L., B. Kepshire, and G. Cunningham. 1983. Upper Susitna River Salmon Enhancement
Study. Alaska Department of Fish and Game, Division of Fisheries Rehabilitation Enhancement
and Development. 156 pp.
NMFS (National Marine Fisheries Service). 2011. Anadromous Salmonid Passage Facility
Design. NMFS, Northwest Region, Portland, Oregon.
Interagency Guidance for the Prescription of Fishways Pursuant to Section 18 of the Federal
Power Act,May 2002. Prepared by: The U.S. Fish and Wildlife Service and National Marine
Fisheries Service. 19 pp.
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7. Fish and Aquatic Resources
7.14. Genetic Baseline Study for Selected Fish Species
General Comments:
These comments address the Genetic Baseline Study for Selected Fish Species Proposed
Study Plan (PSP) submitted by Alaska Energy Authority (AEA) for the Susitna Watana
Hydroelectric Project (Project). The U.S. Fish and Wildlife Service (Service) and National
Marine Fisheries Service (NMFS) submitted a general request for baseline fish genetics to
FERC on May 31, 2012 for anadromous and resident fish. The Alaska Department of Fish and
Game (ADF&G) also submitted a Fish Genetic study request relevant to their fisheries
management goals. Both the Service and ADF&G have fish conservation genetics laboratories;
collaboration and partnering between the two agencies and other resource organizations is
critical to the success of the genetic programs. Alaska’s conservation genetics laboratories
emphasize characterization of population structure and mixed-stock analysis. Because ADF&G
has management authority over the waters of the Susitna River basin they are the resource
agency that is responsible for developing and maintaining the genetic stock analysis (GSA) for
fisheries resources of the basin. The Service supports ADF&G in this effort to conserve
biodiversity of Alaska’s fisheries resources.
It is from this perspective that the Service comments on the PSP, with occasional reference to
the ADF&G Fish Genetics study request. Our comments are based on PSP review findings,
coupled with those from recent AEA’s preliminary 2012 study efforts specifically related to adult
Chinook salmon above Devil’s Canyon near the proposed Watana dam site (River Mile (RM)
184).
Historically, it was assumed that Chinook salmon were not capable of navigating above Devil’s
Canyon and beyond the proposed dam site. However, ancillary reports support 2012 field effort
findings that adult Chinook salmon do indeed migrate above the proposed dam site. Relative
abundance of these Chinook salmon is unknown. During the 2012 field work, 84 Chinook were
visually observed above the proposed dam site. In light of this recent information, and with
consideration given to its potential relevance to federal agencies mandatory conditioning
authority under the Federal Power Act (FPA), we emphasize the need for the baseline fish
genetics study for Chinook salmon. Specifically, the Service recommends AEA focus on the
detail contained within ADF&G’s study request, along with additional objectives for adult
Chinook salmon.
We recognize that the Devil’s Canyon area likely creates a fish passage impediment during a
range of flows, however, the specific range of flows that restrict fish passage are not known, nor
have they been investigated. It is not known whether the adult Chinook salmon that migrate
above Devil’s Canyon to spawn are an established spawning population, or whether they are
comprised of annual strays able to navigate the canyon during opportunistic flows. Acquiring
baseline biological information to answer these questions are key to informing our decision-
making process pursuant to the FPA.
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;
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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.
This more detailed request is in addition to our prior request for the development of a repository
of genetic samples for anadromous and resident fish species within the Susitna River drainage.
The impetus for this additional information comes from preliminary results of the 2012 fish
sampling efforts. These results, some of which are a direct result of newer technologies,
provide specific information requirements for resource agency review of the proposed project.
Low returns for Susitna River salmon in recent years provide additional justification for resource
concern. During the 2012 season, Northern Cook Inlet area Chinook salmon runs were well
below average leading to significant restriction of the Northern District set gillnet fishery and the
in-river Chinook sport fisheries. Restriction of the sport and commercial fisheries had significant
economic impact on commercial fishers, processors, guides, lodges and other businesses that
depend on these fisheries.
Specific Comments by Subsection:
AEA Objective 1. Develop a repository of genetic samples for fish species captured within the
Susitna River drainage, with an emphasis on those species found in the middle and upper
Susitna River.
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.
Alaska lacks baseline genetic samples for most of its fish species and consequently the Service
has specific resource concerns related to several of the Susitna River fish species. In our prior
study request, the Service noted our concerns for Pacific lamprey. Since that time, our
Regional Director has signed the Pacific Lamprey Conservation Initiative. The recent
development of the Service Region 1 Pacific lamprey Conservation Initiative, which includes
Alaska, highlights conservation concerns related to Pacific lamprey across their range. The
Pacific Lamprey Conservation Initiative is the Service’s specific strategy to improve the status of
Pacific Lamprey throughout their range by helping implement research and conservation
actions. This initiative specifically states the need for genetic information and analyses related
to Pacific Lamprey. Lamprey species are also state species of concern described in Alaska’s
Comprehensive Wildlife Conservation Strategy (ADF&G 2006).
The Susitna River Bering cisco comprises one of only three Bering cisco populations worldwide.
The Susitna River Bering cisco is the most genetically distinct of the three populations (R.
Brown, Service, personal communication). Consequently, they are a state species of concern
(ADF&G 2006) based on significant biological data gaps related to the species. There is also
an increasing commercial interest in this species nationally.
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Eulachon are known to spawn in the lower river, but the upper extent of their distribution is
unknown. There are two eulachon runs annually. The first initiates after ice break-up in late
May, and the second migration occurs in early June. A study conducted in1983 recorded
several hundred thousand eulachon during the first run, and several million returning eulachon
during the second run (Barrett et al 1984). The documented upper extent of these return runs is
approximately RM 50 of the Susitna River. Some of the returning eulachon enter tributaries
including the Yentna River (Barrett et al 1984). In addition to supporting local fisheries,
eulachon are a major prey item for the federally listed Cook Inlet beluga whale, and a significant
source of marine-derived nutrients to the Susitna River. There is no genetic baseline for
eulachon.
Susitna River rainbow trout support a valuable trophy sport fishery in the middle river. ADFG
acquired recent telemetry data for one year of adult rainbow trout; however, the results of this
information have not yet been summarized. Data gaps exist for rainbow trout related to
spawning locations, overwintering areas, hatching and emergence timing, and rearing habitat
(Rich Yanusz, ADF&G, personal communication). Currently, there is no genetic baseline for
Susitna River rainbow trout.
Additional resource concerns for Susitna River resident and andromous species are outlined in
part in the Service’s adult and juvenile non-salmon anadromous, resident and invasive species
study request (Service Study Request 14.1) previously submitted to FERC on May 31, 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).
AEA Objective 2. Contribute to the development of genetic baseline markers for each of the five
species of Pacific salmon spawning in the Susitna River drainage.
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.
ADF&G does have genetic markers, genetic samples, and completed analysis for Chinook
salmon which should be considered as a limited baseline. Although this existing Chinook
salmon genetic baseline is not complete, it does indicate that there is variation among
populations of Susitna River Chinook salmon. There are eight genetic reporting groups for
Upper Cook Inlet Chinook salmon. The eight reporting groups are further grouped into 2 broad-
scale regions: 1) Northern (West, Susitna, Yentna, Knik and Turnagain groups, and 2)
“Southern” (Kenai, Kasilof, and south Kenai Peninsula groups). Overall, within the Northern
region, the Susitna group has the most divergent populations (Barclay et al 2012). And within
the Susitna River genetic analysis demonstrate that Chinook salmon from Portage Creek and
the Chulitna River are the most genetically unique in the basin (C. Habicht, ADF&G fisheries
geneticist, personal communication).
Currently, there are no baseline genetic markers for coho salmon. ADF&G has a few Susitna
River genetic coho salmon samples, but markers have not yet been developed in order to
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differentiate between coho salmon populations. There are no existing genetic markers for chum
or pink salmon. ADF&G has a limited genetic baseline for Susitna River sockeye salmon.
AEA Objective 3. For 2013 and 2014, quantify the genetic variation among upper and middle
river Chinook salmon for use in mixed-stock analyses, including analyses of lower river samples
of the entire Susitna Chinook salmon population.
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.
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 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).
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).
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)
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2) variation in effective parental numbers; as a means of estimating the number of
spawners above Devil’s Canyon (Waples 1990).
During the 2012 field season, genetic sampling efforts for Susitna River Chinook salmon above
the proposed dam site were to occur through reconnaissance and structured collaboration
between ADF&G and AEA. However, ADF&G staff was only able to collect one day (July 31,
2012) of Chinook salmon genetic samples. This one day of effort resulted in the collection of
genetic samples from 10 (of 16 observed that day) Chinook salmon from Kosina Creek, located
above the proposed dam site (ADF&G trip report memo, September 20, 2012). Additional
collaborative opportunities exist for future genetic sample collection.
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 respective management authorities. This is also needed to appropriately inform the
proposed Project of potential considerations related to facility design and construction.
AEA Objective 4. In 2013 and 2014, estimate the annual percent of juvenile Chinook salmon in
selected lower river habitats that originated in the middle and upper Susitna River.
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.
Additionally, we support ADF&G’s request for a traditional mark-recapture study to be used to
assess downstream movement of juvenile Chinook salmon from above Devil’s Canyon, if the
Chinook salmon upstream of Devil’s Canyon are not an identifiable genetic reporting group.
Objectives not included in AEA’s Fish Genetics PSP:
ADF&G Objective 3: For 2 years, annually estimate the minimum adult escapement of Chinook
that spawn upstream of Devil’s Canyon.
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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.
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.
Literature Cited
ADF&G (Alaska Department of Fish and Game). 2012. Draft Gap Analysis. Alaska Chinook
Salmon Knowledge Gaps and Needs. October 08, 2012.
ADF&G (Alaska Department of Fish and Game). 2006. Our wealth maintained: a strategy for
conserving Alaska’s diverse wildlife and fish resources. Alaska Department of Fish and Game.
Juneau, Alaska. xviii+824 p.
ADF&G (Alaska Department of Fish and Game) 1985. Genetic Policy. ADFG, FRED.
Allendorf, F. W. and S. R. Phelps. 1981. Use of allelic frequencies to describe population
structure. Can. J. Fish. Aquat. Sci. 38: 1507-1514.
Barrett, B. M., F. M. Thompson and S. N. Wick. 1984. Adult anadromous fish investigations:
May-October 1983. Susitna Hydro Aquatic Studies, report No. 1. APA Document No. 1450.
Anchorage: Alaska Department of Fish and Game.
Barclay, A., C. Habicht, R. A. Merizon, and R. J. Yanusz. 2012. Genetic baseline for Upper
Cook Inlet Chinook salmon: 46 SNPs and 5, 279 fish. Alaska Department of Fish and Game.
Divisions of Sport Fish and Commercial Fisheries.
Buckwalter, J. D. 2011. Synopsis of ADF&G Upper Susitna drainage fish inventory, August
2011.
Jasper, J., C. Habicht, and W. Templin. 2009. Western Alaska salmon stock identification
program, Technical Document No. 3. September 10, 2009.
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Waples, R. S. 1990a. Temporal changes of allele frequency in Pacific salmon: implications for
mixed-stock fishery analysis. Can. J. Fish. Aquat. Sci. 47.
Waples, R. S. 1990b. Conservation genetics of Pacific salmon. II. Effective population size and
the rate of loss of genetic variability. 81: 267-276 p.
Waples, R. S. and O. Gaggiotti. 2006. Molecular Ecology. 15: 1419-1439.
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8. Wildlife Resources
8.14. Waterbird Migration, Breeding, and Habitat Study
General Comments:
The U.S. Fish and Wildlife Service (Service) stated three primary objectives within our waterbird
study request. These objectives are listed here along with a brief summary of how they are
addressed within Alaska Energy Authority’s (AEA) proposed study plan (PSP), with further detail
below:
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.
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.
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.
Specific Comments by Topic
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.
We have not yet seen a detailed survey plan, but have the following requests:
Clearly describe how actual survey area and extent will be determined (e.g., how many
lakes and which lakes?)
All actual flight lines should be recorded. It is critical that the boundaries and sizes of all
surveyed lakes and any other survey areas be clearly delineated so that survey area can
be calculated.
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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.
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?
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 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.
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.
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 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.
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.
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
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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 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.
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.
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8. Wildlife Resources
8.15. Survey Study of Eagles and Other Raptors
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.
General Comments:
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.
Specific Comments by Subsection:
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.
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:
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.
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. 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.
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8. Wildlife Resources
8.16. Breeding Survey Study of Landbirds and Shorebirds
General Comments:
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 over-
wintering 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 Mercury Risk
Assessment.
AEA, the Service, and other stakeholders met on September 6, 2012, to discuss differences
regarding the landbird and shorebird studies. While we have not yet had an opportunity to
review details of a revised written document, we currently believe that some important
differences were verbally resolved as of the end of that meeting, including: the intensity of
breeding season surveys; the use of distance estimation techniques in order to estimate
densities; and appropriate objectives and basic survey methodologies regarding “over-wintering”
birds. It appears that other important study plan components may still be missing or inadequate,
including, but not limited to: a documented plan or agreement to survey birds migrating across
the area in order to help assess risk of collision with Project infrastructure; an adequately
detailed plan to survey riparian-associated breeders; and appropriate support for the Mercury
Risk Assessment. Details of these and other remaining differences are specified below.
Specific Comments by Topic
BREEDING BIRD SURVEYS
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.
Also, 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.
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.
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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.
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.
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.
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.
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.).
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.
General Methodology.
It is expected that ALMS protocol for conducting surveys be followed. For example, surveys
should commence within 30 minutes of local sunrise and cease within 4-5 hours of initiation.
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.
“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
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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).
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.
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.
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.
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.
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
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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 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.
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.
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9. Botanical Resources (RSP 11.)
9.1 to 9.4. Introduction to Summary of Consultation (RSP 11.1 to 11.4.)
General Comments:
The U.S. Fish and Wildlife Service’s (Service) did not request this introduction to the Botanical
Resources, however, this introduction helps set the stage for the Botanical Resources studies
and we appreciate Alaska Energy Authority (AEA) including these introductory sections. Our
comments are based on the Proposed Study Plan (PSP) and, in part, on AEA’s Draft Revised
Study Plan (Draft RSP) dated 23 October 2012. Since we have not had sufficient time to fully
evaluate these recently available Draft RSPs, we reserve the opportunity for additional
comment. Section numbering follows the PSP for consistency with our other PSP comments,
but includes the revised Draft RSP numbering in parentheses.
The section numbering for the Draft RSPs 11.5, 11.6, and 11.7 all start with 11.1, which is
confusing and suggests the automatic numbering needs to be reset for each of these studies.
Please use the correct section numbers in future drafts. Our comments will be based on the
correct number, substituting 11.x with the correct section number.
Please spell-out the first reference to acronyms in major sections (e.g., “RSP” referenced in the
second sentence of Draft RSP Section 11.3, and “PSP” referenced in the first sentence in the
Draft RSP Section 11.1).
Some sections of text are nearly identical across Draft RSPs 11.5, 11.6, and 11.7 (the sections
reviewed by the Service for PSP comments). This is necessary so the studies can stand alone.
However, if we provide comments in one study that shares nearly identical text with other
studies, we request these comments be addressed in the other studies also, even if we did not
repeat our comments in the other studies.
Specific Comments by Subsection:
9.1. Introduction (RSP 11.1.): The introduction refers to five studies with a brief summary
starting with: “Two of,” “A third,” “A fourth, and “a fifth” study. It would be helpful if the study
sections were included in parentheses. This is especially the case for the first reference to “Two
of these studies,” which is followed by a description involving three study elements that could be
confused with the three Draft RSPs 11.5, 11.6, and 11.7.
Much of the discussion between AEA and the stakeholders to date has focused on the mapping
aspect of the Botanical Resources studies, leaving the impression the Botanical Resources is
solely a mapping effort. Lost in the detailed discussions of the many AEA studies has been the
modeling and predictive component of the Botanical Resources studies. For example, 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. However,
the “third study” in the Botanical Resources section appears to involve modeling efforts to
predict potential changes. Perhaps the Botanical Resources section with its substantial
mapping effort would be the study best suited to predicting Project effects, but this needs to be
made very clear in both studies. The Service’s preference would be to retain the predictive
component for the riparian resources in the Instream Flow Studies like the aquatic resources.
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Similarly, this may also be the case for predicting wildlife habitat changes due to Project
operations.
9.3. Resource Management Goals and Objectives (RSP 11.3): The third paragraph references
the Aleutian shield fern (Polystichum aleuticum) as the only plant species in Alaska listed as
endangered under the federal Endangered Species Act (please include underlined text).
9.4. Summary of Consultation with Agencies, Alaska Native Entities and Other Licensing
Participants (RSP 11.4):
Table 9.4-1. Summary of consultation on Botanical Resources study plans (RSP Table 11.4-1):
We appreciate this consultation summary, but the Draft RSP table only includes comments
since the PSP. The table title should be revised to be more specific, or the table should be
inclusive since consultation began. Our comments regarding the Comments/Responses in this
table are included in their respective Draft RSP sections.
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9. Botanical Resources (RSP 11.)
9.5. Vegetation and Wildlife Habitat Mapping Study in the Upper and Middle Susitna
Basin (RSP 11.5.)
General Comments:
The U.S. Fish and Wildlife Service’s (Service) 31 May 2012 study request entitled Vegetation
and Wildlife Habitat Mapping Study is identical to Alaska Energy Authority’s (AEA) Proposed
Study Plan (PSP) title, however, the Draft Revised Study Plan (RSP) title listed above more
accurately describes the study scope. Our comments below are based on the PSP and, in part,
on AEA’s Draft RSP dated 23 October 2012. Since we have not had sufficient time to fully
evaluate this recently available Draft RSP, we reserve the opportunity for additional comment.
Section numbering follows the Proposed Study Plan (PSP) for consistency with our other PSP
comments, but includes the revised Draft RSP numbering in parentheses.
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.
The section numbering for the Draft RSP 11.5 all start with 11.1, which is confusing and
suggests the automatic numbering needs to be reset for this study. Please use the correct
section numbers in future drafts. Our comments will be based on the correct number,
substituting 11.1.x with the correct section number (11.5.x).
Specific Comments by Subsection:
The following review of AEA’s proposed Vegetation and Wildlife Habitat Mapping Study plan
uses the structure of the plan and compares the plan to the USFWS’s study-request objectives
to determine if our intent is met, where improvements can be made, and which requested
objectives are not addressed.
AEA General Description of the Proposed Study (Draft RSP):
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.
AEA Study Goals and Objectives (Draft RSP): The overall goals of the vegetation and wildlife
habitat mapping study are to prepare baseline maps of the existing vegetation and wildlife
habitats in the upper and middle Susitna basin (upstream of Gold Creek).
The Service did not provide an overall goal, and instead merged the goals and objectives into a
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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
the Draft RSP scope to the middle and upper Susitna basin upstream of Gold Creek is
appropriate, although it might also help to mention the Riparian Study (PSP 9.6 / Draft RSP
11.6) will map the floodplain below the proposed dam.
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.
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 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.
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.
AEA Methods (Draft RSP):
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
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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.
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
sections (e.g., “ITU” referenced in the second paragraph of Draft RSP Section 11.5.4).
AEA Objective 1 and Methods (Draft RSP): Identify, delineate, and map vegetation and wildlife
habitat types in the upper and middle Susitna basin using the vegetation map prepared in the
1980s for the Alaska Power Authority’s Susitna Hydroelectric Project (APA Project) as a starting
point, and updating that mapping to reflect current conditions as indicated on recent aerial
imagery for the study area.
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.
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 addition to this portion of the methods.
AEA Objective 2 and Methods (Draft RSP): Quantify the potential direct, indirect, and
cumulative impacts to vegetation and wildlife habitats from Project construction and operations.
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. 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
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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).
AEA Reporting and Data Deliverables (Draft RSP):
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.
AEA Schedule and Study Interdependencies (Draft RSP):
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?
Why is 2012 included in the timeline for Draft RSP Table 11.5-1 if no activities are scheduled or
performed in 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.
Literature Cited
Environmental Laboratory. 1987. Corps of Engineers Wetlands Delineation Manual. Technical
Report Y-87-1, U.S. Army Engineer Waterway Experiment Station, Vicksburg, MS.
90 pp + appendices.
Gracz, M. 2011. Cook Inlet Lowland Wetlands. Available from http://cookinletwetlands.info/
Accessed September 2012.
Kessel 1979. Avian Habitat Classification for Alaska. The Murrelet 60(3):86-94.
http://www.jstor.org/stable/3534270?origin=JSTOR-pdf
U.S. Corps of Engineers (USACE). 2007. Supplement to the Corps of Engineers Wetland
Delineation Manual: Alaska Region Version 2.0. Wetlands Regulatory Assistance
Program, U.S. Army Engineer Research and Development Center, Vicksburg, MS.
72 pp. + appendices.
Viereck, L.A., C.T. Dyrness, A.R Batten, and K.J. Wenzlick. 1992. The Alaska vegetation
classification. Gen. Tech. Rep. PNW-GTR-286. Portland, OR: U.S. Department of
Agriculture, Forest Service, Pacific Northwest Research Station. 278 pp.
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9. Botanical Resources (RSP 11.)
9.6. Riparian Vegetation Study Downstream of the Proposed Susitna-Watana Dam
(RSP 11.6.)
General Comments:
The U.S. Fish and Wildlife Service’s (Service) 31 May 2012 study request entitled Riparian
Habitat Mapping Study suggests a much stronger emphasis on mapping than Alaska Energy
Authority’s (AEA) Draft Revised Study Plan (RSP) title listed above. Our 31 May 2012 Riparian
Habitat Mapping Study request envisioned primarily a mapping effort using products from other
studies to visually display, in map format, the type and aerial extent of predicted riparian habitat
changes resulting from operations of the Susitna-Watana Hydroelectric Project (Project). The
Proposed Study Plan (PSP) and the Draft RSP go beyond the inventory and display of riparian
resources by collecting “the necessary data to enable predictions of how development of the
Project could alter downstream riparian areas.” Collecting data to enable predictions of riparian
and floodplain changes is a crucial objective in our 31 May 2012 study request entitled Riparian
Instream Flow Study, and is in line with the data collection objectives to predict Project effects in
AEA’s Fish and Aquatics Instream Flow Study (Draft RSP 8.5). Moreover, collecting data to
enable Project-related predictions in this Botanical Resources study is not in line with AEA’s
other Botanical Resources studies which rely upon products from other studies to spatial map
potential Project-related effects on botanical and habitat resources.
At the 24 October 2012 Technical Workgroup (TWG) meeting, AEA stated their Riparian
Instream Flow Study Plan would follow the structure of the Service’s study request, which
included an objective to characterize the water-level regime required to maintain floodplain and
riparian plant communities, and then predict potential plant community change resulting from
Project operations. Although informal remarks by AEA that the Riparian Instream Flow research
team was working closely with the Riparian Botanical Resources research team to address our
study request objective, it was not made clear our study request objective had been moved to
the Botanical Resources. Subsequently, this objective was never discussed in the Botanical
Resources TWG meetings, and there was never sufficient time in the Instream Flow TWG
meetings to adequately discuss this objective’s methods. The USFWS recommends assigning
the data collection and analysis portion of this objective to the Riparian Instream Flow study like
the Fish and Aquatic Instream Flow study. 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. Upscaling the riparian habitat predictions from the Riparian Instream Flow
study to the entire riparian and floodplain downstream of the proposed dam, however, could be
a legitimate element of the Riparian Botanical Resources study like the Draft RSPs for the
Vegetation and Wildlife Study and for the Wetlands Study. 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.
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.”
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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.
Since we have not had sufficient time to fully evaluate this recently available Draft RSP, we
reserve the opportunity for additional comment. Section numbering follows the Proposed Study
Plan (PSP) for consistency with our other PSP comments, but includes the revised Draft RSP
numbering in parentheses. The section numbering for the Draft RSP 11.6 all start with 11.2,
which is confusing and suggests the automatic numbering needs to be reset for this study.
Please use the correct section numbers in future drafts. Our comments will be based on the
correct number, substituting 11.2.x with the correct section number (11.6.x).
Specific Comments by Subsection:
The following review of AEA’s proposed Riparian Vegetation Study Downstream of the
Proposed Susitna-Watana Dam uses the structure of the plan and compares the plan to the
Service’s study-request objectives to determine if our intent is met, where improvements can be
made, and which requested objectives are not addressed.
AEA General Description of the Proposed Study (Draft RSP):
The general description of the study sets the stage for the study objectives, methods and
products. Our concern about which RSP will be assigned the second activity to collect data to
enable Project-related riparian habitat changes is discussed above in the General Comments.
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. 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)?
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 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
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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.
AEA Study Area (Draft RSP): [The] downstream location [of the study area] will be determined
(in the riparian instream flow study … As a starting point for delineating the lateral extent of the
riparian vegetation study area, the extent of riverine physiography along the Susitna River will
be mapped. Riverine physiography includes those areas of the valley bottom directly influenced
by semi-regular to irregular overbank flooding (~5–25 year intervals), and will include off-
channel water bodies).
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 roots and influenced by
Project operations.
AEA Methods (Draft RSP):
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.
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.
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.
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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 Mapping Study (Draft RSP 11.5).
AEA Objective 2 and Methods (Draft RSP): In coordination with the instream flow, ice
processes, and riverine geomorphology studies, characterize the physical and ecological
processes downstream from the Watana Dam site that are likely to affect vegetation succession
in riparian areas.
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.
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.
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.
Line intercept is a standard method for sampling shrub cover, and not often used for shrub
density. Transect lengths are also typically much 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?
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.
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).
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The sediment aging methods essentially duplicate what was presented at the 24 October 2012
TWG meeting for the Riparian Instream Flow study and demonstrate our concern for duplicating
study methods in the lead and supporting studies. Our comments for sediment aging are
provided in our Riparian Instream Flow PSP 6.6.
AEA Objective 3 and Methods (Draft RSP): Predict potential changes in riparian areas due to
Project construction and operations, including changes to vegetation successional pathways,
riparian ecotypes, wetlands, and wildlife habitats, which could result from alterations in instream
flow, ice processes, and riverine geomorphology.
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.
AEA Reporting and Data Deliverables (Draft RSP):
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.
AEA Schedule and Study Interdependencies (Draft RSP):
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?
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?
Literature Cited
Environmental Laboratory. 1987. Corps of Engineers Wetlands Delineation Manual. Technical
Report Y-87-1, U.S. Army Engineer Waterway Experiment Station, Vicksburg, MS.
90 pp + appendices.
Gracz, M. 2011. Cook Inlet Lowland Wetlands. Available from http://cookinletwetlands.info/
Accessed September 2012.
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U.S. Corps of Engineers (USACE). 2007. Supplement to the Corps of Engineers Wetland
Delineation Manual: Alaska Region Version 2.0. Wetlands Regulatory Assistance
Program, U.S. Army Engineer Research and Development Center, Vicksburg, MS.
72 pp. + appendices.
Viereck, L.A., C.T. Dyrness, A.R Batten, and K.J. Wenzlick. 1992. The Alaska vegetation
classification. Gen. Tech. Rep. PNW-GTR-286. Portland, OR: U.S. Department of
Agriculture, Forest Service, Pacific Northwest Research Station. 278 pp.
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9. Botanical Resources (RSP 11.)
9.7. Wetland Mapping Study in the Upper and Middle Susitna Basin (RSP 11.7.)
General Comments:
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 (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. Our
comments below are based the PSP and on AEA’s Draft RSP dated 24 October 2012. Since
we have not had sufficient time to fully evaluate this recently available Draft RSP, we reserve
the opportunity for additional comment. Section numbering follows the Proposed Study Plan
(PSP) for consistency with our other PSP comments, but includes the revised Draft RSP
numbering in parentheses.
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.
The section numbering for the Draft RSP 11.7 all start with 11.3, which is confusing and
suggests the automatic numbering needs to be reset for this study. Please use the correct
section numbers in future drafts. Our comments will be based on the correct number,
substituting 11.3.x with the correct section number (11.7.x).
Specific Comments by Subsection:
The following review of AEA’s proposed Wetland Mapping Study in the Upper and Middle
Susitna Basin uses the structure of the plan and compares the plan to the Service’s study-
request objectives to determine if our intent is met, where improvements can be made, and
which requested objectives are not addressed.
AEA General Description of the Proposed Study (Draft RSP):
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.
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AEA Study Goals and Objectives (Draft RSP): The overall goal of the wetland mapping study is
to prepare a baseline map of the existing wetland habitats in the upper and middle Susitna
basin (upstream of Gold Creek).
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.
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.
AEA Study Area (Draft RSP): The proposed study area for wetlands mapping consists of a
2-mile buffer surrounding those areas that would be directly altered or disturbed by development
of the Project. … The alteration of wetland habitats downstream of the dam (due to changes in
instream flow, ice processes, and riverine geomorphology in the Susitna River) will be
addressed in the riparian study (see Section 11.6).
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.
AEA Methods (Draft RSP):
AEA’s methods generally follow the order of the objectives, with a section added to describe
field surveys. Our comments below are organized by objective, with references to AEA’s
section numbers in the Draft RSP.
AEA Objective 1 and Methods (Draft RSP): Identify, delineate, and map wetlands in the upper
and middle Susitna basin in GIS.
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
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mapping work described in the Vegetation and Wildlife Habitat Mapping Draft RSP 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)?
AEA Objective 2 and Methods (Draft RSP): Determine functional values for the mapped
wetland types.
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.
AEA Objective 3 and Methods (Draft RSP): Quantify the potential direct, indirect, and
cumulative impacts to wetlands and wetland functions from Project construction and operations
activities, which will include any new wetlands that may be created by the proposed reservoir.
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 requests a TWG meeting to ensure the
products will meet stakeholder needs.
AEA Reporting and Data Deliverables (Draft RSP):
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.
AEA Schedule and Study Interdependencies (Draft RSP):
Why is 2012 included in the timeline for Draft RSP Table 11.7-1 if no activities are scheduled or
performed in 2012?
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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?
Literature Cited
Environmental Laboratory. 1987. Corps of Engineers Wetlands Delineation Manual. Technical
Report Y-87-1, U.S. Army Engineer Waterway Experiment Station, Vicksburg, MS.
90 pp + appendices.
Gracz, M. 2011. Cook Inlet Lowland Wetlands. Available from http://cookinletwetlands.info/
Accessed September 2012.
Magee, D.W. 1998. A rapid procedure for assessing wetland functional capacity based on
hydrogeomorphic (HGM) classification. Bedford, NH.
U.S. Corps of Engineers (USACE). 2007. Supplement to the Corps of Engineers Wetland
Delineation Manual: Alaska Region Version 2.0. Wetlands Regulatory Assistance
Program, U.S. Army Engineer Research and Development Center, Vicksburg, MS.
72 pp. + appendices.
Viereck, L.A., C.T. Dyrness, A.R Batten, and K.J. Wenzlick. 1992. The Alaska vegetation
classification. Gen. Tech. Rep. PNW-GTR-286. Portland, OR: U.S. Department of
Agriculture, Forest Service, Pacific Northwest Research Station. 278 pp.
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Document Content(s)
NMFS Susitna P-14241 PSP review cover letter.PDF......................1-3
Executive Summary NMFS comments Susitna PSPs.PDF......................4-25
NMFS comments on Susitna PSPs.PDF.....................................26-187
20121114-5112 FERC PDF (Unofficial) 11/14/2012 1:18:57 PM
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C. 20426
Subject: Comments on the Proposed Study Plan, Susitna-Watana Hydroelectric Project
Dear Ms. Bose:
The Glennallen Field Office (GFO) of the Bureau of Land Management (BLM) offers the following
comments on the proposed Study Plan, Susitna-Watana Hydroelectric Project FERC Project No. 14241 on
the State of Alaska’s Susitna-Watana Hydroelectric Project website (http://susitna-
watanahydro.org/Studies.html) as of November 14, 2012. The comments are organized by resource
area of concern.
Cultural and Paleontological Comments to the Susitna Watana Proposed Study Plan, November 2012
Section 11.5 Cultural Resources Study
11.5.1, Second Paragraph.
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.
11.5.1.1., Study Goals and Objectives.
This section 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.
11.5.1.1., Major Objectives, First Bulleted Item, “consult with the SHPO and Alaska Native entities
throughout implementation of the 2013-14 cultural resources survey;”
Additionally, AEA and its contractors should similarly consult with the BLM during implementation of the
2013-2014 cultural resources survey.
11.5.2.1., Archaeological Resources, Paragraph 2, “Only a sample of sites will be prioritized for
radiometric dating.” “Those sites that do contain well-preserved materials, such as animal bone or
charcoal, and especially sites that have multiple occupations would be given a higher priority for dating
analyses.”
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
20121115-5022 FERC PDF (Unofficial) 11/14/2012 9:39:09 PM
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.
11.5.4.2., Ethnogeography-Related Activities, First Bulleted Item, “Hold regional Elders conference…”
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.
Section 11.6 Paleontological Resources Study
11.6.1.1., First Paragraph, “…Paleontological Resources Protection Act of 2009…”
Should be changed to “…Paleontological Resources Preservation Act of 2009…”
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?
Subsistence
In order to adequately address federal subsistence resources and issues involved in issuing Right-of-Way
permits to AEA (namely ANILCA sec. 810 analysis), GFO needs accurate and up-to-date information
involving significantly affected subsistence resources and the short-term and long-term impacts/effects
to BLM managed lands. BLM’s management goals as stated in R-1 of the East Alaska Resource
Management Plan are to;
1. Conserve healthy populations through management and protection of habitat and Federal
subsistence harvest permitting and regulations.
2. Provide reasonable access to subsistence resources.
3. Maintain a viable and accessible Federal subsistence unit in Unit 13 in order to provide a rural
preference to the residents of the Copper Basin.
12.5. Subsistence Baseline Documentation Study:
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
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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?)
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.
Wildlife Resources
In order to adequately address wildlife resources and issues involved in issuing Right-of-Way permits to
AEA, GFO needs accurate and up-to-date information involving adversely affected wildlife habitat and
the short-term and long-term impacts/effects to affected BLM lands. BLM’s management goals as
stated in Y-1 of the EARMP are to;
1. In cooperation with the Alaska Division of Fish and Game (ADF&G), ensure optimum
populations and a natural abundance and diversity of wildlife resources, including those species that are
considered BLM sensitive status species.
2. Perpetuate a diverse and abundance of waterfowl and wetland habitat.
8.5. Study of Distribution, Abundance, Productivity, and Survival of Moose:
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.
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.
8.6. Study of Distribution, Abundance, Movements, and Productivity of Caribou:
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.
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The following comments are specific to the Summary of Recreation Resource Survey Methodology
(dated 9.19.2012)
Recommended Definition of the Study area, page 1.
This section specifically excludes the North side of the Denali 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.
Campgrounds and Trailheads, page 4.
BLM requests prior notification to Glennallen Field Office prior to conducting campground surveys.
Denali Highway Intercept Locations, page 7.
Correction to text; “Only 21 miles of road on the eastern end and three miles on the western end are
paved”
BLM suggests adding the Susitna River Bridge as an intercept location.
Delta Wayside is located at mile 21 (not MP 16). (adjust maps accordingly)
2013 Executive Interview Protocol
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 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.
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.
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Document Content(s)
GFO consolidated comments Susitna Hydro Nov 14.DOCX...................1-4
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 10
ALASKA OPERATIONS OFFICE
222 West 7th Avenue, #19
Anchorage, AK 99513-7588
November 14, 2012
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, DC 20426
RE: EPA comments on proposed PSP/RSP for the Susitna-Watana Hydroelectric Project No. 14241,
EPA Project #12-4162-FERC
Dear Ms. Bose:
The U.S. Environmental Protection Agency (EPA) has reviewed the Proposed Study Plan (PSP) and
Revised Study Plan (RSP) filed by the Alaska Energy Authority (AEA) for the Susitna-Watana
Hydroelectric Project in the Matanuska-Susitna Borough, Alaska (FERC Project #14241-00). The
current proposal is for construction of a single, 750’ dam, as well as a transmission line and access road
to the Watana site along the Susitna River. We began our review of the PSP as filed with the Federal
Energy Regulatory Commission (FERC) on July 16, 2012. Once revisions to the PSP were posted by
AEA on their project website, we evaluated the most recent information.
The EPA reviewed only a few individual studies in detail. Resource limitations precluded reviewing the
majority of the proposed studies. A letter recently filed by the National Marine Fisheries Service
(October 31, 2012) articulates some of the challenges faced by agencies trying to review project
documents and participate effectively in Technical Work Group meetings.
Our review focused on the ‘Geomorphology’ and ‘Fluvial Geomorphology Modeling below Watana
Dam’ sections of the PSP and RSP as well as the ‘Instream Flow’ study Section 8.5. Sections 5.8 and
5.9 of the PSP were renumbered and became 6.5 and 6.6 of the RSP. Section references will be to 6.5
and 6.6 hereafter. We selected these sections to review because flow pattern and sediment supply are
significant drivers of river form and therefore the physical, chemical, and biological characteristics of a
river. Changes to these variables give rise to a cascade of ecological changes via alterations of the
channel and habitat properties and ultimately the biotic response of the plant and animal assemblages.
As ranked by Fischenich (2006), the ‘General Hydrodynamic Balance’ function, defined as the
provision of proper flow conditions at the appropriate seasons for support of the biotic community, is the
single function that directly or indirectly supports all other functions critical to stream and riparian
ecosystem health. This is why the outputs of studies 6.5 and 6.6 become the inputs for a series of related
studies and analyses, including for the Instream Flow study.
To support our review of these sections of the PSP/RSP, we consulted with Dr. David P. Braun of Sound
Science LLC, and Ms. Marit Larson. Dr. Braun is one of the original authors of the Indicators of
Hydrologic Alteration (IHA; TNC 2009) methodology. The Instream Flow PSP/RSP (see Section
8.5.4.4.1.3) states that the IHA program will be used to compare the potential regulated flow to the
current flow patterns, so Dr. Braun’s insights are of particular relevance.
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The proposed studies are generally intended to: 1) establish the baseline, pre-project environmental
conditions; and 2) allow for modeling of how the Susitna River (and associated riparian and upland
habitats) may be affected by the project. The study outputs should be adequate to describe the affected
environment and the environmental consequences of the project in the Environmental Impact Statement
(EIS). We previously filed detailed scoping comments relative to the required National Environmental
Policy Act (NEPA) document ((May 22, 2012).
As we stated in our scoping comments, the ability to evaluate and compare alternatives is critical to
ensuring that the EIS provides the public and the decision-maker with information that sharply defines
the issues and identifies a clear basis for choice among alternatives as required by NEPA.
Quantification of the change to habitat variables and the resultant effects on resources of concern
associated with each alternative is the best way to provide meaningful disclosure and discussion of
potential environmental impacts.
Our scoping comments contained a list of suggested topics for inclusion in the alternative analysis.
Some of these are repeated below. Inclusion of these topics would facilitate the direct comparison
between alternatives that is fundamental to the NEPA process.
Definitions used;
Desired goals and conditions;
Process to ensure that ecosystem health is sustained; and rationale of why the selected process is
expected to maintain ecosystem health (include "indicators" or “criteria” used to judge the health
of the ecosystem and rationale of why they are considered to be representative of the health of
the ecosystems);
Identification of characteristics and species which need to be separately tracked to ensure
protection (e.g., listed species and their habitat);
Identification and protection of the unique, small but ecologically important sites that function as
key elements of the ecosystem (i.e., springs, wetlands);
A monitoring program and its objectives (what, how much, how often, data and analysis needs,
level of data and analysis required/analyzed, including how is monitoring improved compared to
current plans); and
Adaptive management (process to measuring effects and detect problems and feedback
monitoring results to make changes/corrections to protect, restore and sustain resources);
In addition to supporting FERC’s licensing decision, study outputs ideally will be adequate to support
decision-making by other agencies. For example, construction of the project will require a Clean Water
Act (CWA) Section 404 permit from the U.S. Army Corps of Engineers (Corps). The Section 404
permit review includes a series of factual determinations (e.g., physical substrate determinations, water
circulation, fluctuation, and salinity determinations) relative to whether the project may "cause or
contribute to significant degradation" of a water of the U.S.
Our previous comments noted that the scale of the proposed project in terms of its physical size and
degree of alteration of the natural hydrograph of the Susitna River raises the distinct possibility that it
would cause significant degradation and not be permittable under Section 404. For this reason, the EPA
strongly recommend that the EIS evaluate and disclose the impacts to the specific aquatic resources and
functions listed in the Guidelines at 40 CFR 230.10(c).
‘The Notice of Extension of Time to File Comments on the Proposed Study and Revised PSP/RSP,’ dated
September 17, 2012, cited the complexity of the issues and large number of proposed studies as two
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reasons why extending the review period was appropriate. We concur with FERC’s assessment that the
issues associated with licensing this large, original project are complex. Furthermore, we found
assessing the adequacy of the PSP/RSP to generate outputs that will meet the NEPA, licensing and
permitting needs of the project difficult without an assessment framework. To facilitate our review, we
couched the study objectives in the context of the regulatory needs and asked a series of questions that
are listed below.
The specific PSP/RSPs 6.5 and 6.6 are intended to: 1) describe how aquatic habitats are created and
maintained under the pre-project conditions (in part, through geomorphic classification of aquatic
habitats); and 2) allow modeling of geomorphic changes due to project-induced changes to the drivers of
channel form, discharge and sediment supply. If the PSP/RSP achieves these objectives, they can
support the NEPA alternatives analysis and analyses contained within the other regulatory processes.
As mentioned above, the geomorphic classification of habitats and the model outputs of post-project
channel form will be used to analyze project impacts to a variety of resources, including fisheries.
Model results could potentially be used as inputs to analyses that would examine specific resource
questions such as the percentage of main channel chum salmon spawning redds that will experience bed
mobilization during the months of egg incubation or which tributary mouths will aggrade during adult
migration. The adequacy of the specific PSP/RSPs 6.5 and 6.6 will affect the accuracy of numerous
integrated project-affect analyses.
Available fish habitat-use data for the Susitna River indicates that the use of macro- (e.g., main channel,
side slough) and meso-habitats (e.g., riffle, pool) by fish is not consistent. The disproportionate use by
fish of a limited number of discreet habitats indicates that habitat suitability, quality, accessibility and
actual use by aquatic organisms are determined at the microhabitat scale (e.g., water depth, velocity, and
substrate). The initial question we posed for our PSP/RSP review was whether the proposed studies are
intended to or capable of capturing and describing these fine-scale, seasonal channel dynamics.
The four questions we posed for our review of the specific studies are as follows:
1. Are PSP/RSPs 6.5 and 6.6 intended to or capable of capturing and describing the fine-scale,
seasonal channel dynamics that affect habitat suitability, quality, accessibility and actual use by
aquatic organisms?
2. Are PSP/RSPs 6.5 and 6.6 adequate (in terms of level of detail and ecological process mechanisms)
to describe how aquatic habitats are created and maintained under the pre-project conditions (in
part, through the geomorphic classification of aquatic habitats)?
3. Are PSP/RSPs 6.5 and 6.6 adequate to allow modeling of project induced geomorphic changes to
the Susitna River at ecologically-meaningful scales?
4. Will PSP/RSPs 6.5 and 6.6 generate outputs that may be used for factual determinations pursuant to
the Section 404(b)(1) Guidelines (e.g., physical substrate determinations, water circulation,
fluctuation, and salinity determinations)?
The answers to these four questions are best summarized in a single answer, because all four point to a
single set of underlying limitations in the PSP/RSP with respect to aquatic biological and ecological
resources. We provide a summary answer here. More detailed review comments of Sections 6.5 and
6.6, as well as aspects of Section 8.5, are found in Enclosure I.
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EPA Comments, Revised PSP/RSP Sections 6.5 and 6.6 page 4
Posing the four questions was helpful, but we soon realized that we needed to take an even broader view
in order to capture the ‘big-picture’ purposes of the PSP/RSPs. We needed to go beyond the
suggestions we had previously made regarding the alternatives analysis (see above). Specifically, we
needed to ask what information was proposed to be collected, why it was being collected, and how it
would be used to assess the proposed project.
For help in articulating these needs, we turned to an EPA document entitled A Framework for Assessing
and Reporting on Ecological Condition (Framework; USEPA Science Advisory Board 2002).
We found in reviewing the PSP/RSP that it does not explicitly discuss or include any organized process
for assessing how the hydrologic and geomorphic variables proposed for measurement are causally
related to (or predictive of) the conditions that support species assemblages in the Susitna River. More
broadly, the PSP/RSP does not discuss or include conceptual ecological models for the key aquatic
resources (e.g., species, assemblages, ecological characteristics or processes) of the Susitna River. Nor
does it identify any process or timeline for developing conceptual models.
As described in A Framework for Assessing and Reporting on Ecological Condition (Framework),
conceptual ecological models are needed to:
1.Identify the biological and ecological resources of concern;
2. Identify key attributes of each resource that characterize or shape its integrity, including natural
driving processes and natural environmental constraints, i.e., the attributes that “affect habitat
suitability, quality, and accessibility;”
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.
The conceptual model for each resource then provides the scientific basis for the following five
additional, equally crucial steps in any impact assessment:
6. Identifying gaps in our understanding of the natural conditions and dynamics of each resource,
and our understanding of the best indicators of these conditions and dynamics;
7. Identifying potential stresses to the resource, consisting of potential alterations to key attributes
or introductions of foreign ingredients that could result in conditions outside the natural range of
variation for individual key attributes;
8. Identifying likely sources of such stress (aka stressors) and causal mechanism (e.g., geomorphic
processes) by which they act or could act;
9. Guiding field-based and data-mining studies to assess the existing condition and dynamics of
their key attributes, and the status of individual stressors; and
10. Establishing clear criteria (hypotheses and information needs) for assessing how the proposed
project could affect the key attributes and associated indicators for each resource.
The lack of conceptual ecological models is the primary, systemic flaw we identified in the
PSP/RSP. Without articulation of the ecological context within which to assess the collected data
and modeling results, we cannot tell whether the plans will achieve their stated objectives or be
adequate to meet the regulatory needs of the project.
Developing explicit, measurement-oriented conceptual models is the responsibility of the project
proponent. This deficiency is addressed in the first of twelve specific comments contained in our
Enclosure I. Some of the twelve comments are in response to specific information contained in sections
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EPA Comments, Revised PSP/RSP Sections 6.5 and 6.6 page 5
6.5, 6.6, and 8.5. Other comments contain recommendations that stem from the ten steps identified in
the Framework document. The comment topics are listed below.
1. Lack of conceptual ecological models with linked indicators for important resources
2. Key variables affecting fish utilization of the Susitna River and tributaries
3. Indicators for key fish habitat variables
4. Acceptable ranges of variation in indicator condition
5. Environmental flow assessment methodology
6.Selection of environmental flow components, including “effective discharge”
7. Quantifying habitat turnover rates versus qualitative assessment of channel “stability”
8. Other surrogate measures of habitat condition and area
9. Incorporating large woody debris into geomorphic modeling
10. Incorporating ice movement as erosive force in geomorphic modeling
11. Incorporating stochasticity in geomorphic modeling
12. Downstream extent of hydraulic and geomorphic modeling below RM 75
The PSP/RSP (e.g., Section 8) provides some of the information required for Steps 1 and 2 (see above).
Specifically, it indicates that the most important key attributes of habitat for the aquatic ecosystem –
here using the salmonid assemblage as the template – consist of both specific microhabitat conditions
affected by flow and the abundance and quality of macrohabitats that are used differentially by different
aquatic species and their individual life stages. Presumably, individual species differentially use specific
macrohabitats based on their provision of suitable microhabitat conditions for different life stages and
activities. The PSP/RSP (Section 8) provides some information on the relationship of suitable
microhabitat conditions with macrohabitat type. However, the PSP/RSP does not formally organize or
integrate information on the associations between micro- and macrohabitats to specifically articulate
these relationships. Finally, connectivity between the main channel and sloughs, and between the main
channel and tributaries, constitute additional key variables related to the spatial relationships and
connectivity among macrohabitat types.
The PSP/RSP indicates that these two scales (i.e., micro and macro) of habitat variables constitute key
ecological attributes for fishes and other aquatic species. However, the PSP/RSP does not propose
quantitative studies focused on any of the key variables of microhabitat; and mostly does not define how
microhabitat conditions vary among macrohabitats. Instead, the Geomorphology study (Section 6.5),
Fluvial Geomorphology Modeling below Watana Dam study (Section 6.6) and Instream Flow study
(Section 8.5) focus on measures of possible drivers or surrogate variables that are (a) potentially related
to key microhabitat or macrohabitat attributes and (b) potentially amenable to quantification and
modeling. These measures of possible drivers or surrogate variables include measures related to river
discharge, ice cover, sediment supply and size class distribution, substrate particle size class distribution,
channel planform (including braiding and wetted area), channel stability, and bed aggradation-
degradation.
Some of the proposed measurements might provide (or could be designed to provide) unambiguous
information concerning the status and distribution of the microhabitat and macrohabitat conditions of
greatest relevance to aquatic ecosystem integrity. In addition, the usefulness of the information obtained
during the field studies also could be amplified through literature reviews of comparable studies,
although the PSP/RSP does not contain plans for such comparative studies.
It is a common practice in aquatic ecosystem assessments to focus measurements on key drivers of
habitat dynamics, because of the difficulties of measuring finer-scale conditions. Geomorphic analyses,
in particular, can provide key information of long term ecological significance more effectively than
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EPA Comments, Revised PSP/RSP Sections 6.5 and 6.6 page 6
shore term biotic studies (Ligon 1995). However, neither Section 6.5 nor Section 6.6 explicitly states
how the variables they propose to measure will provide surrogate information about the key
microhabitat and macrohabitat variables of interest. Without such an explicit “map” of causal or
predictive relationships, stakeholders must independently determine whether the proposed surrogates are
the right ones to study. In many instances – as discussed in our extended comments below – the
PSP/RSP does not provide enough information to make this determination. In other instances, we
present information suggesting that a specific proposed surrogate is not the right one to study, because it
does not have a clear connection to key ecological variables for the aquatic system or would not have as
clear a connection as some other measure.
Critically, the PSP/RSP does not explicitly discuss, and presents no process for estimating, the
ecologically acceptable range of variation for any of the variables it proposes to measure. As a result,
even for the variables it proposes to measure, the PSP/RSP provides no information concerning how
much change in a given variable might affect the ecological integrity of the aquatic system. Such
estimates are crucial for assessing the potential impacts of specific project actions. (Here, again, there is
a need to bring to bear comparative information). Without such estimates, stakeholders must
independently determine whether the proposed studies will provide information on the potential impacts
of the Project. And here, too, the PSP/RSP does not provide enough information to allow stakeholders
to make this determination.
It is never possible to create a ‘perfect’ study design, or to collect ‘all’ the necessary data to completely
remove uncertainty. Nonetheless, without a guiding framework based on conceptual ecological models
and associated hypotheses, an extremely detailed program of field sampling, remote sensing, data
mining, and computer modeling will always run a much greater risk of collecting more information than
is needed about some features/environmental characteristics, and less information than needed about
others. This will be true even with a high level of coordination among studies. A guiding framework
based on conceptual ecological models and hypotheses is all the more critical given the short time frame
of the proposed studies, including the short field seasons, and the high degree of variability of the
measured parameters. Without this framework, we will never know if the shotgun approach will
produce the information necessary to understand the risks posed by the project for specific resources of
concern.
The PSP/RSP does a good job of ‘connecting the dots’ among the numerous technical studies it
proposes. Integrated Resource Analysis diagrams, for example, display the close relationships and flow
of information among studies of hydrology, geomorphology, and fish habitat use. We suspect this is at
least partly in response to repeated agency requests for this information. What the PSP/RSP does not
do, however, is ‘connect the dots’ from this information back to conceptual models of the ecological
requirements and sensitivities of biological and ecological resources. There is no connection to the
indicators for key microhabitat and macrohabitat variables for these resources, and the acceptable ranges
of variation in these indicators. As a result, the studies 6.5 and 6.6 may intend to address “the fine-
scale, seasonal channel dynamics that affect habitat suitability, quality, accessibility and actual use by
aquatic organisms” but they do not provide sufficient information to determine if they are capable of
achieving this objective.
Thank you for the opportunity to provide comments on the PSP/RSP. Please feel free to contact me at
(907) 271-1480 or lacroix.matthew@epa.gov if you have questions or would like additional information
regarding our comments. I will be your primary contact for Clean Water Act Section 404-related issues;
Jennifer Curtis also here in the EPA Alaska Operations Office will be your primary NEPA contact.
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EPA Comments, Revised PSP/RSP Sections 6.5 and 6.6 page 7
Sincerely,
Matthew LaCroix, Biologist
Aquatic Resources Unit, Alaska Operations Office
Office of Ecosystems, Tribal and Public Affairs
Cc: Wayne Dyok, AEA
David Turner, FERC
Enclosure I
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EPA Comments, Revised PSP/RSP Sections 6.5 and 6.6 page 8
ENCLOSURE 1
EPA DETAILED COMMENTS FOR THE FERC SUSITNA-WATANA HYDROELECTRIC
PROJECT, REVISED PSP/RSP SECTIONS 6.5, 6.6, AND 8.5
Comment 1: Lack of conceptual ecological models with linked indicators for important resources
It is standard practice in natural resource impact assessments to begin with five crucial steps (e.g.,
USEPA Science Advisory Board 2002; Parrish et al. 2003; Unnasch et al. 2008) (see also
http://www.nature.nps.gov/water/nrca/frameworks.cfm), which are lacking in the Proposed PSP/RSP.
These five Steps are as follows:
(1) Identify the biological and ecological resources of concern;
(2) Identify key attributes of each resource that characterize or shape its integrity, including
natural 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.
The identification of the resources of concern, their key attributes, their indicators, and their reference
ranges of variation requires development of a conceptual ecological model of the project area overall
and, more importantly, a conceptual model for each individual focal resource (e.g., USEPA Science
Advisory Board 2002). The biological or ecological resources may be individual species or stocks,
habitat types (e.g., waterfowl overwintering areas) or species assemblages, natural communities, or
ecological processes. Key attributes for a freshwater ecosystem, for example, typically address
hydrology, vertical hydraulic exchange, physical habitat and connectivity, water temperature and
chemistry, forms and magnitudes of primary productivity, uniquely adapted species, and characteristic
and dominant species at different levels in the food web. The conceptual model for each resource then
provides the scientific basis for the following five additional, equally crucial Steps in an y impact
assessment:
(6) Identifying gaps in our understanding of the natural conditions and dynamics of each
resource, and our understanding of the best indicators of these conditions and dynamics;
(7) Identifying potential stresses to the resource, consisting of potential alterations to key
attributes or introductions of foreign ingredients that could result in conditions outside the
natural range of variation for individual key attributes;
(8) Identifying likely sources of such stress (aka stressors) and causal mechanism by which they
act or could act;
(9) Guiding field-based and data-mining studies to assess the existing condition and dynamics of
their key attributes, and the status of individual stressors; and
(10) Establishing clear criteria (hypotheses and information needs) for assessing how the
proposed project could affect the key attributes and associated indicators for each resource.
The PSP/RSP lacks any such conceptual models or integrating framework. Instead, it focuses
exclusively on the technical studies needed to fill in gaps in knowledge, without providing any explicit
framework for assessing how filling those particular gaps will affect understanding of the resources and
the potential effects of the Project on them. In effect, the PSP/RSP jumps to “Step 6” in the above
sequence of 10 assessment steps, without any of the guidance that would be provided by having first
gone through the preceding five crucial steps.
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EPA Comments, Revised PSP/RSP Sections 6.5 and 6.6 page 9
The PSP/RSP includes Integrated Resource Analyses (IRAs), to show how the technical Study
components relate to each other. However, the IRAs do not show how these Study components relate to
core questions about how the project will affect specific biological or ecological (or social-cultural or
economic) resources. Each IRA is specifically intended to show how various Study components will be
brought together to assess the current (baseline) condition and likely impacts of the proposed Project to
all potentially important resources. However, without any explicit conceptual model of what resources
matter – nor any explicit conceptual model for each such resource, its key ecological attributes, the
indicators for these key attributes, and estimated reference ranges for these indicators – the IRAs provide
no structure for this integrated assessment of baseline resource condition and potential impacts for each
resource. The IRAs thus provide no structure for assessing whether the Project has the potential to affect
the integrity of any particular resource, let alone reduce that integrity beyond some acceptable level.
Without such an explicit framework, each stakeholder must independently review the entire PSP/RSP
and its individual Study components, in order to assess how the knowledge produced by the proposed
studies might affect understanding of the resources of concern to the stakeholder and the potential
effects of the Project on these resources. For example, each stakeholder must independently seek
information regarding the potential significance of various indicators, such as changes in the flood
frequency distribution overtime. Ordinarily, explicitly developing and presenting foundational
conceptual models for key resources – including documenting the rationale for all elements of each
conceptual model based on literature reviews, comparative studies, and expert judgment – is the
responsibility of the scientific teams assembled by the project proponent. Here the burden is shifted and
scattered among stakeholders, and left for the external comment process rather than incorporated
directly ‘up front’ in the planning process.
The Corps and EPA both share responsibility under the CWA for safeguarding the “physical, chemical,
and biological integrity” of U.S. waters, but there is no conceptual model anywhere in the PSP/RSP that
explicitly describes, let alone explains, how the proposed studies will lead to critical information on the
present and possible future condition of the integrity of the aquatic ecosystem or any of its individual
species. This is the case even though the PSP/RSP recognizes the aquatic/riparian ecosystem and
several of its individual fish species as important resources that the project could affect. The PSP/RSP
also contains no discussion of tools available to help link information on hydrology and geomorphology
back to information on habitat condition, even though it explicitly mentions the existence of such tools
in its discussion of modeling software (see below, Point 4).
Information with which to begin building conceptual models for key resources (see the list of five initial
planning Steps 1-5, above) is present throughout the Plan. However, this information is scattered, not
integrated. The Proposed PSP/RSP nowhere uses this information to link the proposed Studies back to a
framework for asking pivotal questions about the potential impacts of the Project, based on the key
attributes of key resources and their acceptable ranges of variation. Such questions might include, How
will the project affect the abundance or spatial distribution of spawning gravel for adult Chinook salmon
and rearing habitat (in backwaters and sloughs) for juvenile Chinook salmon along the river; affect
periphyton or benthic invertebrate productivity in different macrohabitat settings; or affect riparian
community vegetative composition and use of the riparian zone by different animal species?
Thus, the PSP/RSP puts the burden of such integration on the shoulders of the stakeholders rather than
on the scientific and engineering teams preparing the Plan. This is contrary to current best practices for
environmental impact assessments and planning. This does not mean that the specific proposed technical
studies will not interact extensively, in the coordination of data collection and computer modeling, etc.
(e.g., see Section 6.6.4.2.2.4). However, this extensive interaction is not a substitute for a guiding
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framework for all the studies that focuses on explicit questions about what biological and ecological
resources are potentially at stake, how they function under natural conditions, and how the project could
affect them. Nor does this extensive interaction eliminate the need to also review the literature and
findings of hydrogeologically and ecologically comparable studies to supplement and amplify the
findings of the proposed field studies. Each section of the PSP/RSP (e.g., Geomorphology, Section 6)
should not simply lead to products that are left to be interpreted as best as possible in light of the others.
Rather, the key ecological attributes, indicators, acceptable ranges of variation, and controlling factors
should be identified at the outset, so that each study is specifically and explicitly aimed at answering key
questions concerning potential impacts to those key ecological attributes, indicators, ranges of variation,
or controlling factors.
Comment 2: Key variables affecting fish utilization of the river system
The PSP/RSP, Section 8 (file version of 2012.10.26) provides guidance on existing knowledge
concerning fish habitat along the Middle and Lower Susitna River (Watana Canyon downward). There
is legitimate debate about the accuracy of this existing knowledge, but this information can be integrated
to identify some of the key ecological attributes for the Middle/Lower Susitna River fish assemblage as
a whole, at both the micro- and macro-habitat scales. As described in the PSP/RSP, key variables
include:
Microhabitat needs for different species depend on “…a suite of different parameters
influenced by flow. These include specific conditions of water depth, water velocity,
substrate, upwelling occurrence, and turbidity.” Winter microhabitat conditions are
particularly important, with depth, temperature, and velocity strongly shaping egg incubation
and juvenile survival and development. Inter-gravel flow and vertical hydraulic exchange are
also important for egg and emergent fry survival, in part by sustaining water temperatures
above freezing. Egg and fry viability are also sensitive to gravel instability, bed exposure,
and extreme winter flow velocities. The exact microhabitat preferences and sensitivities of
individual species may not be known, but we do know that the natural range of variability in
conditions along the Susitna historically provided a suitable distribution of microhabitat
settings with the right ranges of conditions for several species.
Different fish species and their individual life stages show different patterns of use of six
macrohabitat classes – main channel, side channel, side slough, upland slough, tributary
mouth, and tributary. Main channel habitat is further divided into four sub-types
(mesohabitats): riffle, pool, run, and glide. Presumably, individual species differentially use
these macrohabitats based on their provision of suitable microhabitat conditions for different
life stages and activities. The PSP/RSP (Section 8) provides some information on the
relationship of suitable microhabitat conditions with macrohabitat type. For example, side
sloughs provide lower flow velocities and shallower depths than the main channel. However,
the PSP/RSP does not formally organize or integrate information on microhabitat-
macrohabitat associations to specifically articulate these relationships. Finally, connectivity
between the main channel and sloughs, and between the main channel and tributaries,
constitute additional key variables related to the spatial relationships and connectivity among
macrohabitat types.
This discussion addresses fish (particularly salmonid) assemblage integrity, for convenience. It is not
intended to suggest that flow depth and velocities are the most important variables in determining
microhabitat use by fish. 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 insects, birds, and mammals; etc. – would result in the identification of other key
ecological attributes for the aquatic (or aquatic + riparian) ecosystem as a whole.
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EPA Comments, Revised PSP/RSP Sections 6.5 and 6.6 page 11
Comment 3: Indicators for key fish habitat variables
Ideally, indicators for the key fish microhabitat and macrohabitat variables would provide quantitative
information about the availability of suitable habitat – on average and over space and time – and its
condition for different species and life stages, particularly the most abundant, better known species.
However, the available scientific knowledge may not be sufficient to support defining a range of values
for each variable that characterize “good” habitat condition for each species – even after completion of
the PSP/RSP components for aquatic resources. This shortfall would occur because of the inherent
difficulties in acquiring such knowledge, particularly over a short research period, particularly for less
abundant species or species whose life history and habitat requirements are not as fully understood.
(Nevertheless, the PSP/RSP should call for a thorough integration of the literature, findings of
comparable studies, and expert judgment to assemble the available knowledge).
Further and perhaps more importantly, the available scientific knowledge and tools (e.g., modeling
methods) may not be sufficient to support modeling the future condition of fish microhabitat and
macrohabitat indicators under the Project (see Point 2, above, for discussion of key microhabitat and
macrohabitat variables). Consequently, the PSP/RSP would be expected to identify other indicators that
provide at least surrogate information on the actual key habitat variables of interest. Such surrogate
indicators must meet two criteria: (1) they must be amenable to measurement and modeling; and equally
importantly, (2) they must provide unambiguous information concerning the likely availability and
abundance of microhabitat and/or macrohabitat conditions suitable to the fish species of concern.
Typically in such circumstances (common in ecological impact assessments), surrogate indicators
consist of measures of the key environmental drivers that create and maintain the microhabitat and
macrohabitat conditions of interest. And, indeed, the Geomorphology study and Fluvial Geomorphology
Modeling below Watana Dam study (Sections 6.5 and 6.6, respectively) address such potential surrogate
indicators (even if they do not explicitly identify them as surrogates for the key ecological attributes of
actual interest). These potential surrogate indicators include measures related to river discharge, ice
cover, sediment supply and size class distribution, substrate particle size class distribution, channel
planform (including braiding and wetted area), channel stability, and bed aggradation-degradation. In
some river systems, for example, the ratio of spawning female salmon to the number of redds indicate
that the availability of suitable spawning gravels could be limiting for the population (Ligon et al. 1995).
Based on this critical link between the physical habitat and the biota, a fluvial geomorphic study analysis
would then focus on how spawning gravel area would be impacted due to reduced upstream sediment
load, and less frequent channel avulsion, and thus less gravel recruitment from the banks, due to reduced
peak flows. However, neither Section 6.5 nor Section 6.6 provides a “map” of how the variables they
propose to measure provide information on the actual key microhabitat and macrohabitat variables of
interest, let 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.
This review of the PSP/RSP is not the appropriate place to develop an alternative “map” or conceptual
model of potential surrogate indicators for the key microhabitat and macrohabitat variables of interest.
Developing such conceptual models should be the responsibility of the teams developing the PSP/RSPs
and their partner Technical Working Groups. These experts need to identify potential surrogate
indicators based on how the habitat dynamics work, and on the causal or predictive relationships that
may exist between the proposed surrogate indicators and the actual microhabitat and macrohabitat
variables of interest. And they need to support the resulting conceptual models with reviews of current
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knowledge, not only about the Susitna-Watana system but about comparable systems in general. This
will provide the information needed to assess the suitability of the proposed surrogate indicators for
assessment under the plans for the Geomorphology Study and Fluvial Geomorphology Modeling below
Watana Dam Study (Sections 6.5 and 6.6) or the Instream Flow Study (Section 8.5). “Suitability” in this
context refers to the correspondence (causal and/or predictive relationship) between the actually
proposed hydrogeomorphology indicators (i.e., measures related to river discharge, ice cover, sediment
supply and size class distribution, substrate particle size class distribution, channel planform – including
braided and wetted area, channel stability, and bed aggradation-degradation – and the key microhabitat
and macrohabitat variables noted above.
Our preliminary review suggests there is not a close correspondence between the proposed measures and
the actual microhabitat and macrohabitat variables of interest. The Geomorphology PSP/RSP (Section
6.5) has ten Study Components:
(1) Delineate Geomorphically Similar (Homogeneous) Reaches;
(2) Bedload and Suspended Load Data Collection at Tsusena Creek, Gold Creek, and Sunshine
Gage Stations on the Susitna River and Chulitna River near Talkeetna;
(3) Sediment Supply and Transport Middle and Lower River;
(4) Assess Geomorphic Change Middle and Lower Rivers;
(5) Riverine Habitat versus Flow Relationship Middle River;
(6) Reconnaissance-Level Assessment of Project Effects on Lower River Channel;
(7) Riverine Habitat Area versus Flow Lower River;
(8) Reservoir Geomorphology;
(9) Large Woody Debris; and
(10) Geomorphology of Stream Crossings along Transmission Lines and Access Alignments.
These ten components focus on the need to assess the natural flow and ice cover regimes; quantify
natural sediment supply and transport, including substrate particle size class distributions; classify reach
types and assess riverine habitat types in relation to flow; assess channel planform variation, channel and
habitat stability, and bed aggradation-degradation over the last decades; assess large woody debris
(LWD) recruitment and distribution; and assess potential geomorphic impacts of the reservoir and
stream crossings.
Nowhere does the PSP/RSP for these ten Geomorphology study components explicitly state how
indicators for these particular conditions or dynamics are causally related to predictive of the key
microhabitat and macrohabitat variables that actually affect the suitability of the river for its native
fishes. Similarly, the PSP/RSP for these ten Geomorphology study components does not explicitly
discuss whether or how the studies will estimate the acceptable range of variation in any metrics, in
order to provide a basis for assessing whether project impacts will exceed such ranges of variation. For
example, the plans do not explicitly provide information organized so that stakeholders can tell how a
change in the sediment budget or channel braiding in a given reach might affect fish habitat availability
along that reach, and whether such changes would warrant concern for the integrity of any specific fish
species or the fish assemblage overall. Such relationships potentially could be estimating using computer
modeling or other methods, but only if based on sound conceptual models in the first place, which in
turn should rest on reviews of current knowledge about the Susitna River system and comparable
systems in general.
The content of the proposed Geomorphology study (Section 6) and the Instream Flow study-Fish,
Aquatics and Riparian (Section 8) suggest that the scientific teams responsible for these plans had
implicit conceptual models in mind when they prepared these PSP/RSPs. Without making these
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conceptual models explicit, however, the PSP/RSPs provide insufficient information with which to
assess their adequacy.
Of course, decades of scientific and engineering studies worldwide of rivers with and without dams
demonstrate that the independent variables (drivers) such as flow regime, ice cover regime, sediment
supply; and the response variables of bed grain, channel pattern, and the channel conditions of lateral
stability and bed aggradation/degradation all do affect the availability of microhabitat conditions and
macrohabitat types in rivers in general. These variable and their relationships to habitat conditions and
availability are implied in the proposed assessments of macrohabitat distributions described in Sections
6.5, Study Components 1-7, and in Section 6.6 (see also Section 8.5).
However, the PSP/RSP does not explicitly address how these variables, and the ways in which they will
change with the Project, specifically and quantitatively will affect macrohabitat type abundance and
distribution (let alone suitable microhabitat conditions) in this river, the Susitna system. For example,
the PSP/RSP does not explain how it will connect (a) predictions of expected lower peak annual floods,
the load-response discharge regime in the winter, and reduced sediment and LWD supply from the
mainstem to (b) estimates of the likely distribution of macrohabitats with suitable inter-gravel
flow/upwelling, substrate stability, water depth (especially related to even brief exposure or excessive
inundation), and flow velocity for fish egg and juvenile viability during the critical winter season. The
PSP/RSP may embody implicit assumptions about such causal relationships but the absence of explicit
models forces stakeholders to surmise these assumptions in order to evaluate the plans.
Comment 4: Acceptable ranges of variation in indicator condition.
For the sake of argument, Point 4 here assumes that the indicators proposed for actual measurement –
e.g., indicators of the flow regime, ice cover regime, sediment supply and transport, substrate particle
size class distribution, channel planform, channel stability, and bed aggradation-degradation – are the
right indicators to measure. That is, simply for the sake of argument, it assumes that the implicit strong
causal and predictive relationships discussed under Point 3 (between surrogate indicators and the
microhabitat and macrohabitat variables of actual interest) exist, and that measuring these indicators will
provide appropriate data, with which to assess project impacts on the ability of the Susitna River to
provide sufficient habitat for all key fish species within their natural ranges of abundance. Making this
assumption, we then must ask: What is the acceptable range of variation in these variables?
The PSP/RSP does not ask nor attempt to answer any questions concerning the acceptable range of
variation with respect to any of the hydrologic and geomorphologic variables that are proposed for
study. Consequently, the PSP/RSP says nothing about how the proposed studies will provide
information on the likely distribution and severity of ecological impacts from the Project. Thus, the
PSP/RSP does not ask and provides no pathway to answering questions such as: Is there a threshold
duration of above-water exposure of redds due to winter flow variation, beyond which the eggs would
experience some specific percent (e.g., 50%) mortality; and what would be the frequency and spatial
distribution of such conditions under the different flow release alternatives, as assessed by the hydraulic
modeling for specific reaches? Or, Are there minimum and maximum inter-gravel flow rates that define
suitable habitat for Chinook salmon, and what is the relationship between the overall substrate particle
size class distribution and the likely availability of habitat with suitable ranges of inter-gravel flow
rates? Or, Is there a hydrogeomorphic threshold, or combination of thresholds, where channel incision
resulting in the disconnection of the river from its flood-channel network is likely to occur?
Admittedly, questions of this sort may test the limits of present knowledge. However, without asking
such questions, the proposed investigations will have no chance of developing even preliminary
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estimates that could be used to assess project impacts. The PSP/RSP does not raise such questions, and
presents no process for studying or answering them using some combination of field studies and reviews
of past studies and expert judgment. As a result, it is not possible to assess whether the proposed
PSP/RSP components will produce information truly useful for assessing potential Project impacts on
the aquatic biological or ecological resources of concern.
Tools may be available to assist in asking such questions. For example, the discussion in Section 6.6 of
the PSP/RSP, concerning 2D fluvial geomorphology modeling software, points in this direction. The
discussion there indicates that at least two of the programs under consideration include modules for
assessing fish habitat availability based on the hydraulic-geomorphic output of the main program.
Specifically, the MD_SWMS Modeling Suite includes “…a Habitat Calculator for assessing fish habitat
under 2D conditions,” and the River2D program “… also has the capability to assess fish habitat using
the PHABSIM weighted-usable area approach.” The PSP/RSP does not mention a third option: the U.S.
Army Corps of Engineers HEC-EFM (Ecosystem Functions Model) program
(http://www.hec.usace.army.mil/software/hec-efm/index.html).
This program provides a range of tools for assessing the potential ecological impacts of flow and habitat
changes based on the hydrologic and geomorphic output of other HEC modeling tools, such as the HEC-
RAS program already recommended for use in the Study. The PSP/RSP should include: (a) an
evaluation of the potential to use such tools to assess the crucial causal connections noted above; and
(b), if any of these tools are found suitable, a plan for their use in the quantitative assessment of potential
Project impacts to the aquatic biological and ecological resources of concern. Incorporating computer
modeling of physical habitat into the PSP/RSP would require careful planning at a very early stage in
the Study process, because such computer models require very specific inputs and data for calibration
and validation. Further, computer modeling of physical habitat typically is carried out at a relatively fine
scale, such as at individual reaches or cross-sections. Consequently, the PSP/RSP would need to
establish criteria for selecting the habitat modeling sites, perhaps based on the priority habitat
requirements identified for specific species (e.g., key ecological attributes). The results from such local-
scale modeling would yield products (such as weighted usable areas or hydraulic habitat suitability) that
can be used to extrapolate impacts quantitatively to larger scales
An alternative investigative strategy might also be feasible, for assessing the suitability of expected
variations in variables, such as flow regime and LWD dynamics. This alternative strategy would focus
on the relationships between field-measured variables and integrated indices of biological condition at a
range of sites in the region encompassing the Project, from relatively pristine reference conditions to
more impacted conditions. Hydrologic indicators have also been established that are linked to
geomorphic characteristics and ecological functions based on investigation of pre-and post project
conditions (Graf 2004). Although these examples are of indices that are not necessarily easily linked to
specific species, they can be used to assess the likely deviation of these indicators from target ranges as
a result of the project. Information on index values from reference rivers can also be used to set target
ranges for management and operations (or mitigation), if they can be statistically associated with
gradients of alteration of habitat.
Comment 5: Environmental flow assessment methodology
Reviewing the proposed Geomorphology Study or Fluvial Geomorphology Modeling below Watana
Dam Study (Sections 6.5 and 6.6) also requires reviewing the proposed Instream Flow Study (Section
8.5), because the three are closely related. Specifically, the Mainstem Flow Routing study (e.g., Section
8.5.4) and its associated hydraulic model (HEC-RAS) are key ingredients in the two geomorphology
studies. For example, the hydraulic modeling is a necessary foundation for the fluvial geomorphology
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modeling. Further, water depth and velocity are crucial microhabitat variables shaping the availability of
suitable macrohabitat for fish assemblage integrity (see above); and there not be a 1:1 correspondence
between macrohabitat type and water depth/velocity conditions. Consequently, 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 modeling with the results of the geomorphic studies.
The HEC-RAS flow routing model below the proposed Watana Dam site will incorporate a series of
cross-sections, at which the program calculates daily (and perhaps hourly or finer) stage, velocity,
energy gradient and other hydraulic variables (and calculates output values for discharge based on these
variables), between River Miles (RM) 75 and 184. [The question of whether the hydrologic and
geomorphic modeling should stop at RM 75, or continue to the Bay has been debated among the
PSP/RSP team, TWGs, and stakeholders; we return to this question separately, below.] The modeling
for each of these cross-sections will produce output not only for each alternative model of flow
regulation but also for existing conditions (historic period of record). The modeling process will
necessarily involve calibration and validation of the model based on flow data at the existing gage
points. However, the model will include many cross-sections other than at the existing gage locations,
and the choice of these non-gaged cross-sections will be important: the USGS places its gage at
locations with specific geomorphic characteristics (e.g., stable planform, straight run, etc.), and these
locations therefore do not constitute a representative sample of all channel and habitat conditions. The
selection of additional cross-sections for the HEC-RAS modeling needs to produce a geomorphically
representative sample of locations.
In turn, 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.
Assuming that the assessment of potential flow alteration will proceed as just described, we must also
ask, How will the comparisons be carried out between the unregulated and potential regulated flow
records? The Instream Flow PSP/RSP (see Section 8.5.4.4.1.3) states that it will use the Indicators of
Hydrologic Alteration (IHA; TNC 2009) program to carry out the necessary comparisons. This specific
proposal should be reviewed, for several reasons (the present reviewer is one of the original authors of
the IHA methodology):
The present suite of 33 IHA parameters represents a “kitchen sink” of variables that can be
compared between records. Some or many of these variables may not be ecologically
relevant to the Susitna-Watana project. Comparing all 33 variables may produce results for
some variables indicating a lack of impact (small or no difference between the records being
compared). However, if these latter variables are not ecologically relevant to the project,
including them in the assessment will give an inaccurate picture of the project impacts. The
analysis must focus only on 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 (e.g.,
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Olden and Poff 2003; Poff et al. 2010) – a step seemingly missing from the PSP/RSP (see
also Point 6, below).
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. For example, a
10% change in the frequency of extreme Summer high flows may or may not be ecologically
significant, depending on the natural range of variability of the system. Further, 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.
Percent difference values are particularly unhelpful for assessing change in the average
timing of specific 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.
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).
The present version of the IHA program has known bugs. The PSP/RSP team should consult
with the support team for the software.
Comment 6: Selection of environmental flow components, including “effective discharge”
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 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.
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
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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.
The PSP/RSP presents an extended argument for assessing the impacts of the Project on Effective
Discharge. 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.
Effective Discharge is the discharge rate that, over the course of years and decades, cumulatively
transports the largest mass of sediment along a river. However, Effective Discharge does not accomplish
this feat by being able to mobilize and transport more sediment per instant than flows at other
magnitudes of discharge. It does its work by mobilizing and transporting a moderate amount of
sediment, but doing so often enough that it has a large cumulative effect. In contrast, extreme flow
events (e.g., 50-, 100-, or >100-year high-flow events) cause channel avulsion, change meander lengths,
change channels from singular to braided planforms, create sloughs and natural levees, rework channel
bed aggradation and degradation at large scales, shift tributary deltas, and so forth. In the Susitna-
Watana system, ice jams and the flow pulses that result when the river escapes these jams, conceivably
could be counted among such high-flow events with significant geomorphic consequences (e.g., see
papers by Beebee, Davis and Davis, and Mouw presented at the 2011 Mat-Su Salmon Science &
Conservation Symposium,
http://conserveonline.org/workspaces/matsusalmonsymposium/documents/withkeyword-
documents.html?keyword=00002011%20symposium; and see also Shields 2000; Clipperton et al.
2003). And the geomorphic disturbance caused by such extreme events may well play an important role
in shaping the biodiversity of the river. 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 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.
Comment 7: Quantifying habitat turnover rates versus qualitative assessment of channel
“stability”
The Geomorphology study (Section 6.5) includes a discussion of a proposed qualitative assessment of
channel “stability.” This assessment will involve a visual comparison of overlaid digitized maps of the
channel zone from the 1980s versus the present. Two questions arise for this particular study
component: (1) Why is “channel stability” a variable of interest at all; and (2) Why not directly measure
overall aquatic habitat turnover rates with the same map data, thereby providing a more useful
ecological and also quantitative analysis?
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Our assumption is that the project team is asking about “channel stability” because of the need to
distinguish project-induced geomorphic change from pre-project conditions of instability or directional
trends. Key to addressing this need is a quantification of the rate of geomorphic change.
As noted earlier, channel stability represents one of a suite of variables that the PSP/RSP proposes for
the Geomorphology study. However, the PSP/RSP does not identify how information on channel
stability reveals the ways in which the project could affect the abundance and distribution of suitable
microhabitat conditions and macrohabitat types for different fish species. At best, information on
channel stability provides only surrogate information on the actual key habitat variables of interest; and
at worst, provides no information on these key habitat variables at all. The PSP/RSP needs to make clear
why the assessment of channel stability is important to understanding Project impacts on key resource
attributes; and doing so will require building the conceptual models described earlier.
The Fluvial Geomorphology Modeling below Watana Dam study (Section 6.6) also raises the topic of
channel stability, and poses the question, “[Will] the existing channel morphology …remain the same or
at least be in “dynamic equilibrium” under post-project conditions…?” This question is unnecessary.
There is no question about whether the project will influence channel morphology. It is not possible to
completely alter the controlling variables (hydrology and sediment load) on a fluvial system and not
change the channel morphology. Decades of investigations of the impacts of dams on river hydrology,
sediment transport, and geomorphology make this abundantly clear (e.g., Williams and Wolman 1984;
Kellerhalls and Church 1989; Ligon et al. 1995; Friedman et al. 1998; Collier et al. 2000; Shields et al.
2000; Graf 2005, 2006). This modeling study component needs to be directed at much more specific
questions concerning the magnitude and scale of impacts to key attributes in the system.
The study authors state that it is important to understand whether the river is currently in dynamic
equilibrium, to get at the question of channel stability. But a snapshot comparison of habitat distribution
between 1980 and 2011 is not useful by itself for understanding the dynamic equilibrium of a system.
Instead, the investigations must also assess whether any changes took place in the factors that control
channel morphology over that timespan. Only an analysis of the hydrologic and sediment regimes
preceding those two periods of observation, or of other disturbance regimes and biotic controls (fire,
temperature, predation, herbivory, species competition, exotic species etc.), can inform the question of
dynamic equilibrium. Potential indirect influences on these controls, such as changes in land use,
development, land management, hunting, beaver trapping, etc. must also be assessed.
Given the hydrology and substrate material of the Susitna River, a certain degree of channel planform
instability is natural to the system. The Susitna’s channel morphology is naturally dynamic, wherever
permitted by an absence of valley confinement and bedrock grade control (i.e., outside of Devils
Canyon). And, because of the way that river ecosystems work, this dynamism may well be important to
sustaining the biological richness of the system. Therefore, the ecologically more relevant question may
not be, Is the channel stable, but rather, How much “instability” is natural to the system? And this can
be quantified. The same digitized maps of the river valley can be used to measure, for individual
reaches, 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 of the area covered by water today was land versus
covered by water in the 1980s.
The resulting transition matrixes can be used to calculate a “turnover rate” (water to land and land to
water, in hectares per year) for each reach, for the period between the 1980s and 2012 aerial imagery.
The resulting reach-scale data can then be used to define the frequency distribution of reach-scale
turnover rate values, and associated measures of central value. And, for those reaches with aerial
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imagery from the 1950s, similar data can be compiled for the period between the 1950s and 1980s. The
resulting quantitative data on turnover can be compared statistically to hydrologic metrics, such as the
frequency of extreme high-flow events, to assess how the rate of turnover may have varied in relation to
potential hydrologic drivers, and in relation to the effects of the three large tributaries to the lower river
(Talkeetna, Chulitna, Yentna Rivers).
The resulting quantitative data on turnover can also be compared statistically to data on other potential
determinants of channel planform, such as gradient, bedrock confinement, and magnitudes of sediment
inputs from tributaries. This will result in a more robust, quantitative model of the factors that affect
turnover rate, for incorporation into the understanding of the geomorphic modeling results. Such a suite
of quantitative analyses would be directly relevant to the ultimate purposes of the Study and both
methodologically more sound and ecologically more relevant than a qualitative assessment of channel
planform stability.
Comment 8: Other surrogate measures of habitat condition and area
The PSP/RSP proposes measurements of channel braiding, bar area, and wetted area, as additional tools
for assessing habitat abundance and distribution. The PSP/RSP does not, however, explain how or why
these measurements will provide information on the ways in which the project could affect the
abundance and distribution of suitable microhabitat conditions and macrohabitat types for different fish
species. For example, will these measurements be used to construct indices of habitat condition relevant
to microhabitat conditions and macrohabitat types, or to calibrate a 2D model of physical habitat
changes with changes in flow regime? Because the PSP/RSP does not address such questions, it is not
clear whether these measurements are proposed simply because they can be measured, or because they
actually provide unambiguous information concerning the likely availability and abundance of
microhabitat and/or macrohabitat conditions suitable to the fish species of concern (see Point 3, above).
The PSP/RSP needs to make clear why these are potentially useful measurement approaches; and doing
so requires building the conceptual models described earlier.
It does seem that some measures of at least macrohabitat areas by type will be used to inform the fluvial
geomorphic modeling effort and, presumably, used to predict Project impacts on aquatic habitat based
on the modeling output. However, in the reviewers’ experience, the deterministic approaches proposed
for these modeling efforts (discussed more below) are best suited for application to environments where
natural geomorphic controls simplify the system. Examples of such simpler systems include bedrock
dominated systems, where vegetation plays little or no role in controlling riparian geomorphology; and
arid systems, where vegetative extent is more predictable.
Where systems are very complex and dynamic, however, modeling ideally should be augmented with
other study approaches to help predict impacts. For example, a “space for time” (or “space for
modeling”) approach also should be considered for the Susitna study. 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.
More generally, the PSP/RSP lacks discussions of opportunities to pursue comparative approaches in
lieu of or to complement and extend the usefulness of field studies along the Susitna itself. As noted
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earlier (see Point 7, and citations therein), investigations worldwide and especially in North America
over the past few decades have produced a wealth of knowledge of the downstream hydrologic and
fluvial geomorphic effects of dams. Some of these investigations address systems comparable in one or
more factors to the Susitna – for example, systems with highly braided natural channels and significant
involvement of ice (e.g., Shields et al. 2000; Clipperton et al. 2003). Shields et al. (2000) also
specifically note that “Since channel migration is episodic, migration rates measured over shorter time
periods (20–30 yr) exhibit greater scatter than those over 100–200 yr …, particularly for streams with
banks that experience mass wasting …”
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 hydro-
geologic settings, including studies of long-term dynamics (see also Wellmeyer et al. 2005). The
experiences of analogous river systems can provide insight into the river variables that might be affected
and can help AEA to develop specific studies to assess potential impacts. The experiences of analogous
rivers can also serve as independent validation of AEA's assumptions and modeling results.
Comment 9: Incorporating Large Woody Debris into geomorphic modeling
The Geomorphology study (Section 6.5) proposes a study component addressing Large Woody Debris
(“LWD,” Study Component 9). The Plan states that “Large wood and wood jams can create pool
habitat, affect mid-channel island and bar development, and create and maintain anastomosing channel
patterns and side channels … [and] can provide cover and holding habitat for fish and help create
habitat and hydraulic diversity.” 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). Doing so would not substitute for the analysis of the larger-scale geomorphic processes of channel
widening and lateral channel migration that supply LWD to the system. It would, however, 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.
In addition to identifying LWD functional roles, the proposed studies could estimate/quantify the
volume of sediment (and 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.
Comment 10: Incorporating ice movement as erosive force in geomorphic modeling
The ice cover regime clearly is an important variable shaping the aquatic ecosystem of the river. The ice
cover regime potentially influences fish egg and juvenile maturation and the distribution of suitable
microhabitat conditions and macrohabitat settings for this maturation. However, 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
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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.
Comment 11: Incorporating stochasticity in geomorphic modeling
The 1D and 2D modeling proposed for the Fluvial Geomorphology Modeling below Watana Dam study
(Section 6.6) appear to involve deterministic modeling. That is, a given set of input and boundary
conditions will produce a single solution. The inputs and parameter values can be varied to produce a
range of results, but there is no actual stochastic, or random, parameter included that makes it possible
for the modeling to produce varying outputs for a given set of inputs. Statistical likelihood enters into
most of the proposed models through manipulation of the input parameters (e.g., by running the models
for storms with selected recurrence intervals). The boundary conditions are fixed, or change based on
outputs from other models (e.g., coarser-scale sediment transport models) that are also deterministic.
Other input parameters are determined based on an understanding of field conditions, such as bed
particle size, or roughness coefficients.
River system dynamics, however, are naturally somewhat stochastic, in that chance conditions – e.g., the
arrival of a piece of LWD or the timing of a tributary inflow pulse – can change local and reach-scale
conditions in ways that may persist for many years. This is particularly true in the case of braided-
channel systems such as the Susitna River. Ideally, simulation of such systems would include some
stochasticity, in that each simulation run would describe a particular possible but not absolutely
deterministic outcome. The output of multiple runs would then describe the range of possible outcomes.
A statistical analysis of the resulting range of variation would then provide a more robust representation
of the way the system might work under a given future scenario. This type of analysis should consider
where in the river network stochastic disturbances may play the greatest role in creating geomorphic and
habitat heterogeneity, such as at tributary confluences (Benda et al. 2004).
Alternatively, 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). Even the additional sampling proposed in Section 6.5.4.2 is likely
to produce an average with a wide standard deviation. The field sampling protocols for recording the
size of bed material are not well described in the PSP/RSP. It is likely, however, that sampling results
will reflect the wide range of variability in such parameters. This should be particularly true for sub-
surface particle size distributions.
The 1D and 2D 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.)
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EPA Comments, Revised PSP/RSP Sections 6.5 and 6.6 page 22
Comment 12: Downstream extent of hydraulic and geomorphic modeling below RM 75
The hydrologic and geomorphic modeling is currently proposed to stop at RM 75. As noted earlier, the
question exists as to whether the modeling should continue to the river’s mouth at Cook Inlet. The
PSP/RSP, including the Summary of Consultation with Agencies, Alaska Native Entities, and Other
Licensing Participants (Section 6.4) indicates that this has been a subject of debate among the project
team, TWGs, and stakeholders. The PSP/RSP repeatedly states that the results of the 1D and 2D
geomorphic modeling to RM 75 will be evaluated to determine if the detailed study area needs to extend
further downstream. Section 6.6.3.2 presents the proposed process for making this important
determination.
It has been well-documented that the effects of dams on sediment size distribution and other channel
characteristics have the potential to extend hundreds of km downstream (Williams and Wolman 1984;
Shields et al. 2000; Schmidt and Wilcock 2008). These effects may emerge over time spans of decades
to centuries, depending on basin geology and geomorphic and runoff processes from the hillslopes,
valleys and channels throughout the basin network (Grant et al. 2003; Benda et al. 2004). Given the
complex linkages and the natural variability in the system and in bedload sampling, an estimate of
bedload sediment balance for the river from a single comparison (1980s versus 2012) is not sufficient
for deciding whether or not to extend the modeling downstream (DeVries 1970). The PSP/RSP
proposes developing an analytical framework that takes into account the dynamics of sediment and
water fluxes throughout the river network (Section 6.5.4.6.). However, this analysis must be conducted
and the results reviewed in time to allow implementation of any recommended additional studies in the
Lower River in 2013.
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 1D or 2D 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. The
persistent uncertainty over whether to extend the modeling downstream from RM 75 appears to be a
consequence of the failure of the PSP/RSP to include development of such conceptual models.
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dynamics hypothesis: How channel networks structure riverine habitats. BioScience 54(5):413-
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Booth, D. B., D. R. Montgomery, and J. Bethel, 1997, Large woody debris in urban streams of the
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Needs Determinations for the South Saskatchewan River Basin, Alberta, Canada. Alberta
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DeVries, M. 1970. On accuracy of bed-material sampling. Journal of Hydraulic Research 8(4): 523–
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EPA Comments, Revised PSP/RSP Sections 6.5 and 6.6 page 23
Doyle, M.W., E.H. Stanley, D.L. Strayer, R.B. Jacobson, and H.C. Schmidt. 2005. Effective discharge
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Fischenich, J. C. (2006). "Functional Objectives for Stream Restoration," EMRRP-SR-52, U.S. Army
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Friedman, J.M., Osterkamp, W.R., Scott, M.L. & Auble, G.T. 1998. Downstream effects of dams on
channel geometry and bottomland vegetation: regional patterns in the Great Plains. Wetlands
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Graf, W.L. 2005. Geomorphology and American dams: The scientific, social, and economic context.
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Graf, W.L. 2006. Downstream hydrologic and geomorphic effects of large dams on American rivers.
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Grant, G.E., Schmidt, J.C. and Lewis, S.L. 2003. A Geological Framework for Interpreting Downstream
Effects of Dams on Rivers. In J.E. O'Connor and G.E. Grant eds. A Peculiar River. Water
Science and Application 7. American Geophysical Union, p203-219.
Henriksen, J.A., J. Heasley, J.G. Kennen, and S. Niewsand. 2006. Users’ manual for the hydroecological
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Geological Survey, Biological Resources Discipline, Open File Report 2006-1093. Reston, VA.
Kennen, J.G., J.A. Henriksen, J. Heasley, B.S. Cade, and J.W. Terrell. 2009. Application of the
Hydroecological Integrity Assessment Process for Missouri Streams. U.S. Geological Survey
Open-File Report 2009-1138. Reston, VA.
Kellerhals, R., and M. Church. 1989. The morphology of large rivers: characterization and management.
Can. Spec. Fubl. Fish. Aquat. Sei. 106: 31-48.
Ligon, F.K., W.E. Dietrich,,and W.J.Trush. 1995. Downstream ecological effects of dams. BioScience
45 (3): 183-192.
Montgomery, D.R., J.M. Buffington, R.D. Smith, K.M.Schmidt, and G. Pess. 1995. Pool spacing in
forest channels. Water Resources Research 31(4):1097-1105.
Montgomery, D.R., B.D. Collins, J.M. Buffington, and T.B. Abbe. 2003. Geomorphic effects of wood in
rivers. In The Ecology and Management of Wood in World Rivers, edited by S. Gregory, K.
Boyer, and A.M. Gurnell, American Fisheries Society Symposium 37:21-47.
Olden, J.D. and N.L. Poff. 2003. Redundancy and the choice of hydrologic indices for characterizing
streamflow regimes. River Research and Applications 19: 101-121.
Parrish, J.D., D.P. Braun, R.S. Unnasch. 2003. Are we conserving what we say we are? Measuring
ecological integrity within protected areas. BioScience 53(9): 851-860.
Poff, N.L., B.D. Richter, A.H. Arthington, S.E. Bunn, R.J. Naiman, E. Kendy, M. Acreman, C. Apse,
B.P. Bledsoe, M.C. Freeman, J. Henriksen, R.B. Jacobson, J.G. Kennen, D.M. Merritt, J.H.
O’Keeffe, J.D. Olden, K. Rogers, R.E. Tharme, and A. Warner. 2010. The ecological limits of
hydrologic alteration (ELOHA): a new framework for developing regional environmental flow
standards. Freshwater Biology 55: 147-170.
Schmidt, J.C. and P.R. Wilcock. 2008. Metrics for assessing the downstream effects of dams. Water
Resources Research. 44(W04404). 19.pp.
Shields, F.D., Jr, A. Simon, and L.J. Steffen. 2000. Reservoir effects on downstream river channel
migration. Environmental Conservation 27(1): 54-66.
The Nature Conservancy (TNC). 2009. Indicators of Hydrologic Alteration Version 7.1, User's Manual.
Arlington, VA. Online: http://conserveonline.org/workspaces/iha.
Unnasch, R.S., D.P. Braun, P.J. Comer, and G.E. Eckert. 2008. The Ecological Integrity Assessment
Framework: A Framework for Assessing the Ecological Integrity of Biological and Ecological
Resources of the National Park System. Report to the National Park Service.
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USEPA Science Advisory Board. 2002. A Framework for Assessing and Reporting on Ecological
Condition. U.S. Environmental Protection Agency, Science Advisory Board (SAB), EPA-SAB-
EPEC-02-009, June 2002 www.epa.gov/sab. Washington, D.C.
Wellmeyer J. L., M.C. Slattery, and J.D. Phillips. 2005. Quantifying downstream impacts of
impoundment on flow regime and channel planform, lower Trinity River, Texas.
Geomorphology 69: 1-13.
Wilcock, P. R., J. C. Schmidt, M.G. Wolman, W.E. Dietrich, D. Dominick, M.W. Doyle,G.E.
Grant,R.M. Iverson, D.R. Montgomery, T.C. Pierson, S.P. Schilling, and R.C. Wilson, 2003.
When Models Meet Managers: Examples From Geomorphology, in Prediction in
Geomorphology, P.R. Wilcock and R.M. Iverson eds. American Geophysical Union,
Washington, DC, pp. 41-50.
Williams, G. P., and M. G. Wolman, Downstream effects of dams on alluvial rivers, Geol. Surv. Prof.
Pap. 1286, 83 pp., 1984.
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ENCLOSURE 2
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Document Content(s)
12-4162-FERC StudyPlanComments1.DOCX..................................1-25
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20121113-5031 FERC PDF (Unofficial) 11/12/2012 9:35:33 PM
IRI
J<i mberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, DC 20426
November 12, 2012
Re: Cook Inlet Region, Inc. Comments on Alaska Energy Authority Proposed Study Plans and
Revised Draft Interim Study Plans, Scoping Document 2, Board of Consultants Approval,
Requests for Designation of CIRI as a Consulting Party, and Requests for Meeting with
FERC Staff for the Susitna-Watana Hydroelectric Project (FERC P-14241-000)
Dear Secretary Bose:
Cook Inlet Region, Inc. (CIRI) appreciates the opportunity to provide these comments on Alaska
Energy Authority's (AEA) Proposed Study Plans (PSPs) and Revised Interim PSPs, the Federal Energy
Regulatory Commission's (FERC or the Commission) Scoping Document 2 (502), and the
Commission's October 23, 2012 approval of a Board of Consultants for the Susitna Hydroelectric
Project (Project) (FERC P-14241-000). In addition, ClRI requests designation as a consulting party
with respect to effects of the Project on historic properties and a meeting with Commission staff.
CIRI is an Alaska Native regional corporation owned by more than 7,300 Alaska Native
shareholders. CIRI was established as an Alaska law corporation pursuant to the Alaska Native
Claims Settlement Act of 1971 (ANCSA), 43 U.s.c. § 1601 et seq. As the Commission is aware,
CIRI owns or controls, on behalf of itself and various Alaska Native village corporations pursuant
to Public Laws No. 94-204 and No. 94-456 (see especially §12(e) and § 4 thereof, respectively),
over 200,000 acres in the vicinity of the Project, including approximately 25,000 acres that would
be directly affected by the Project's dam and reservoir. A map depicting CIRI land ownership in
the Project vicinity is found at Figure 13.1-1, AEA Revised Interim Draft Cultural Resources Study
Plan at 13-13 (10/25/2012), copy enclosed with this letter, as Attachment A.
As ClRI has stated in prior comments, ClRI is conditionally supportive of the Project. One key
condition involves ensuring that the Project, if licensed, is designed, constructed, operated and
maintained in a manner protective of CIRI lands and resources. The Commission's licensing
process should ensure that CIRI and all involved ANCSA village corporations and their respective
shareholders are routinely informed about the full range of the proposed Project's potential and
anticipated environmental and resource impacts, with an explanation of how unavoidable adverse
impacts of the Project are both minimized and adequately mitigated. To these ends, CIRI's
comments are primarily focused on ensuring that Project impacts are fully and adequately studied,
described and evaluated in the Commission's National Environmental Policy Act (NEPA) review
process and are fully and adequately evaluated and protected in accordance with the Federal
Power Act, ANSCA, the federal government's unique obligations to Alaska Natives, and other
applicable laws and policies in the Commission's license and permit, terms, conditions, approvals
and authorizations other agencies may issue for the Project.
~~;)2,"i "(" STREl~T, SUITE SOD ~ P.O. BOX l):)330' ANC]-IORN3E, ALASKA l)()50!)-3:no
(907) 274-g63R· I;AX (l)07) 279"gB36· Web Sill': www.ciri.colll
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Kimberly D. Bose, S(x:retary
Federal Energy Regulatory Commission
November 12, 2012
Page 2 of 12
I. PROPOSED AND REVISED INTERIM DRAFT STUDY PLANS AND COMMENTS ON SD 2
A. Draft PSPs and Revised Interim Draft PSPs
AEA issued its Draft PSPs in July 2012 and the document is available at FERC's website docket for
the Project and AEA's website. Sometime in October 2012, AEA began loading a partial set of
Revised Interim Draft PSPs. AEA is to be commended for its efforts to respond to some of the
comments it has received on the Draft PSPs.
AEA's October 31, 2012 letter to Commission Secretary Bose "encourages" comments on the
Revised Draft PSPs. In footnote 3 to that letter, AEA indicated that it "publicly released
comments/response tables, to allow all resource agencies and stakeholders to track how AEA
addressed their prior comments on the PSI) in the interim draft RSI)" The Revised Draft Cultural
Resources Study Plan does not include a responsiveness document or track changes that make it
readily apparent as to what changes have been made to the Draft lOS lOs. Accordingly, a reader
trying to determine changes set forth in the Revised Interim Draft Cultural Resources Study Plan
has to conduct a side-by-side comparison of the Draft PSPs and Revised Draft I)SPs. It is a difficult
and time consuming effort. We recommend that future changes to the study plans include or be
accompanied by a document clearly describing changes, as well as the reasons for and effect of
the changes. This is needed to ensure clarity, transparency, responsiveness and consultation by
AEA on behalf of the Commission with CIRI and others.
B. Geology and Soils (Minerals Resources Assessment Study Plan)
1. AEA's Draft Geology and Soils Study Plan
ClRI's May 30, 2012 comments on Scoping Document 1 (SOl) requested that AEA conduct a
Minerals Resource Assessment Study. AEA's July 2012 Draft Geology and Soils study plan
acknowledges ClRI's request as well as comments submitted by FERC staff on May 31, 2012
requesting that AEA prepare a geology and soils report. AEA's Draft Geology and Soils study plan
states that "the FERC and CIRI study requests correspond to AEA's proposed geology and soils
characterization study, and through this study plan AEA is attempting to meet the expectations and
objectives of those study requests." Draft Geology and Soils study plan at 4-2. AEA has not
posted a Revised Draft Geology and Soils study plan at its web site as of November 6, 2012.
AEA's Draft Geology and Soils study plan is a good start. However, ambiguities in AEA's proposed
study could fall short of what CIRI requested and FERC's regulations governing geology and soil
studies at 18 C.F.R. § 4.41 (I), as well as what FERC needs to complete its NEPA assessment.
As context, FERC regulations require a license application's Exhibit A Environmental Report to
contain a report on geological and soils resources: "The applicant must provide a report on
geological and soil resources in the proposed project area and other lands that would be directly
or indirectly affected by the proposed action and the impacts of the proposed project on those
resources." 18 C.P.R. § 4.41 (I) (emphasis added). Among other things, the report must contain
"A detailed description of geological features, including bedrock lithology, stratigraphy, structural
features, unconsolidated deposits and mineral resources; land] ... A description of any proposed
measures or facilities for mitigation of impacts on soils."
2
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Kimberly D, Hose, Secretary
Federal Energy Regulatory Commission
November 12, 2012
Page J of 12
The basis for CIRI's Minerals Resource Assessment Study Plan request is ClRI's concern about
potential Project impacts on exploitability of mineral resources owned by CII<.I both within and
outside the proposed Project boundary. The ability of CII<.I to explore for and develop these
mineral resources could be significantly impaired during the terrn of the original license, terrns of
any subsequent FERC licenses, and thereafter so long as the Project dam and reservoir rernain,
following license surrender or decommissioning. See 60 Federal Register 339, 340 (January 4,
1995) (Cornrnission's policy on decornrnissioning recognizes a range of possible decornmissioning
alternatives "frorn sirnply shutting down power operations to tearing out all parts of the project,
including the dam, and restoring the site to its pre-project condition.").
As recornrnended by ClRI, AEA states that AEA will consult the 13ureau of Land Managernent (I3LM)
and United States Geological Survey (USGS) "in review of this study plan to determine the most
appropriate rnethods and evaluation techniques are used for the mineral resources investigation."
Proposed Study Plan, Section 4.5.4 at 4-5. Ilowever, the text preceding this staternent states that
"A survey of the rnineral resources will be performed to assess mineral potential and mining
activity in the impoundment area." Id. (emphasis added). Other statements suggesting that AEA is
proposing too narrow a scope include Section 4.5.2 (study will examine "specific information on
the properties of Project-site-specific rock and soil units that would be affected by the newly
proposed Project") and Section 4.5.3 (noting that FERC regulations require a report to demonstrate
that proposed structures are safe and adequate, but no rnentioning irnpacts to rnineral resources on
adjacent lands).
ClRI requested a Minerals Resource Assessrnent of: "known or exploitable mineral resources ...
in the vicinity of the proposed Project," CIRI Study Request Section 5.9(b)(1); "in the Project area,"
Section 5.9(b)(4); whether the "Project ... may make mineral exploration and development
beneath or near the Project technically or economically infeasible," Section 5.9(b)(5); seeking BLM
and USGS assistance for a mineral resource assessrnent of "ClRI subsurface interests in the Project
area," Section 5.9(b)(6); of "CIRI subsurface interests ... in the Project area." Section 5.9(b)(7). As
noted above, FERC's regulation requires an Exhibit E report on geology and soils "in the project
area and other lands that would be directly or indirectly affected by the proposed action and the
impacts of the proposed project on those resources." AEA's Section 4.5.1 Ceneral Description of
the Proposed Study acknowledges that FERC requires Exhibit E to provide such a report and that
AEA's geology and soils report "will provide the basis for the information needed for the Exhibit
E." Further, Section 4.2.1 of SD 2 includes the following new environrnental issue to be addressed
in the Commission's NEPA environmental impact statement: "Effects of project construction and
operation on access to proven or probable mineral deposits." To the extent AEA's study proposal
would not meet CIRI's objectives or FERC's requirements, the study would be deficient.
2. Recommendation
AEA's Geology and Soils minerals assessment study plan cornponent is a good start but is
ambiguous in part. It includes statements that would lead to a study "consistent" with CIRI's
Minerals Resource Assessment Study request and FERC's regulation. It also includes language that
could lead to a narrow study scope that would be inconsistent with CIRI's recommended study
and FERC's regulation. We recornmend that AEA consult with CIRI toward the goal of seeking
clarification or agreernent that the scope of the minerals resource assessment component of the
Ceology and Soils study plan will be as broad as requested by CIRI, as required by FERC's
regulations, and as proposed by FERC in section 4.2.1 of SD 2.
3
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Killlberly D. Bose, Secretary
Federal Energy Regulatory Commission
November 12, 2012
Page 4 of 12
C. Cultural Resources
1. AEA's Draft and Revised Cultural Resource Study Plans
AEA's web site includes AEA's July 30 Draft Cultural Resources Study Plan and a Revised Draft
Cultural Resources Plan, dated "10/25/2012." In response to comments on the Draft Cultural
Resource study plan, AEA included a map showing Alaska Native corporation land ownership
interests in the proposed Project area. CIRI land ownership in the dam, reservoir, Cold Creek!
Southern access and Chulitna I Hurricane access alternatives, and other areas within the proposed
Project boundary are depicted on the map. Figure 13.1-1, AlA Revised Draft Cultural Resources
Study Plan at 13-13, copy enclosed as Attachment A.
CIRI is a steward of all cultural resources on land owned or controlled by CIRI as well as those
cultural resources located outside ClRI land that are of traditional importance to the Dena'ina
Athabascan Indians represented among CIRI's Native Alaskan shareholders. In the area of the
proposed Project dam and reservoir alone, approximately 25,000 acres are owned or controlled
by CIRI. Some cultural resources of concern to ClRI and its shareholders have been identified in
prior studies. Many others remain unidentified as well as unevaluated for the historic value or
significance to CIRI and its shareholders, independent of whether they are eligible for listing on
state or federal registers of historic places. Among cultural resources of concern to ClRI but not
identified in many prior studies are traditional cultural properties (TCPs, first acknowledged in
National Register Bulletin 3B, Cuidelines for Evaluating and Documenting Traditional Cultural
Properties, first issued in 1990, cited in Revised Draft Cultural Resources at 13-B), Native Alaskan
human remains, and sacred sites and objects that have only recently been recognized as eligible
for protection under federal and state laws, regulations, executive orders, and guidance
documents.
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'ian 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'ian 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. E.g., Navajo Nation v. Forest Service, 535 F.3d
103B, 1063 n.2 (9th Cir. 2008) (San Francisco Peaks in Northern Arizona has impOrlance to 6
Indian tribes). 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.
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Fedcral Energy Regulatory Commission
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CIRI is no ordinary stakeholder in the FERC licensing process. As noted above, ClRI owns
approximately 25,000 acres in the area of the proposed dam and reservoir, and other land where
access and transmission line corridors may be located. CIRI owns and manages these lands in
accordance with the intent of ANCSA, a unique federal law. CIRI has a unique legal and
economic relationship to FERes undertaking and the property to be affected by the Project and
thus should be engaged as a consulting party with respect to Project impacts on cultural and
historic properties under the National 1·listoric Preservation Act (NHPA) section 106, 16 U.s.c. §
470f, Advisory Council on Historic Preservation implementing regulations, 36 C.F.R. § 800.2(c)(5),
NEPA,42 U.s.c. § 4331(a) (federal government cooperation with concerned public and private
organizations) and (b)(2) (federal government responsibility to improve and coordinate functions to
assure culturally pleasing surroundings) and (4) (federal government responsibility to improve and
coordinate functions to preserve important historic, cultural and natural aspects of our national
heritage), and NEPA implementing regulations, 40 C.F.R. § 1502.1 (d)(2) (federal agency
consultation under NEPA with appropriate "interested private persons and organizations"),
incorporated by the Commission, 18 C.F.R. § 380.1. Meaningful and good faith consultation with
a consulting party uniquely situated in respect to this Project requires more than sending out letters
or documents, posting documents at a web site, inviting comments, and invitations to meetings
along with the general public.
2. Recommendation
AEA should consult with ClRI directly and meaningfully regarding reasonable and good faith
efforts on behalf of FERC to identify and evaluate impacts upon cultural resources of concern to
CIRI that may be affected by the Project that should be studied by AEA and taken into account by
FERC in its NHPA section 106 and NEPA compliance efforts for the Project licensing process.
D. Transportation Resources" Draft Watana Transportation Access Corridor Report
1. Draft Watana Transportation Access Corridor Report
AEA posted to its web site a June 2012 Draft Watana Transportation Access Analysis prepared by
the Alaska Department of Transportation and Public Facilities (ADOT&PF). Four transportation
access corridors with variants were included in that report. The Draft Watana Transportation
Access Analysis available at AEA's web site did not include the Appendices referenced therein.
AEA requested comments on the Draft Watana Transportation Access Analysis by August 31,
2012. CIRI submitted comments on that draft report, copy attached as Appendix B.
AEA subsequently made available a CD copy of Appendices to the Draft Watana Transportation
Access Analysis. CIRI also provided comments on the Appendices, copy attached at Appendix B.
CIRI's comment letters strongly opposed both northern corridors (Seattle Creek and Butte Creek)
described in the Draft Watana Transportation Access Analysis and Appendices. CIRI also
commented on the need for more detailed analysis before any access or transmission line corridor
route selection decisions were made.
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
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Federal Energy Regulatory Commission
November 12, 2012
Page6of12
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 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.
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. ClRI supports
dropping it from further study, if USFWS correctly characterizes AEA's position.
2. Recommendation
ClRI 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 ClRI'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.
E. Geomorphology (Glacial and Runoff Changes Study Plan)
1. Glacial Melt and Runoff Changes Study
AEA's Preliminary Application Document (PAD) states that climate change may accelerate melting
of glaciers (net rate of glacier loss, ["AD at 4-39) and may significantly modify the expected energy
from hydroelectric projects like the Project due to altered seasonal and annual reservoir inflow
regimes. PAD at 3-35. AEA's PAD reports that the Susitna River basin watershed "is in a region
that is projected to have among the highest average annual increases in runoff worldwide," about
a 10 percent increase by 2050. PAD at 3-48. Section 1.0 of CIRI's May 30, 2012 SO 1 comment
letter noted that AEA had not discussed or indicated "plans to evaluate how accelerated glacial
input and associated sediment deposition behind the dam may affect the Project's storage capacity
and load following operations." CIRI recommended that the Commission evaluate the proposed
action in the context of anticipated changes in the hydrologic system in its NEPA analysis.
The Commission's July 16, 2012 SO 2 responded to SO 1 comments from CIRI and others which
suggested the need for glacial wasting and climate change analysis as part of the Comrnission's
environmental review of the Project. SO 2 opined that the Commission was unaware of ways to
accurately predict the effects of changes in climate on glacial wasting and on the timing and
availability of water in the Susitna River based on the current state of science. SO 2 at 18 and 35.
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Federal Energy Regulatory Commission
November 12, 2012
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The Commission added that it would request AEA to reexamine the effects of surging glaciers on
sediment accumulation rates based on historical data and AEA proposed monitoring.
The goal of AEA's Glacial and Runoff Changes Study is to analyze the potential impacts of glacial
retreat on the Project. Specifically, "how glacial retreat, along with associated changes to the
climate, impact the flow of water into the proposed reservoir and water quality." Glacial and
Runoff Changes Study, Section 5.11.1.1 at 5-147. Acknowledging that the glacial retreat trend is
well documented, "and may impact the Project," ici., AEA's Glacial and Runoff Changes Study
states that "understanding how changes to the upper basin hydrology due to glacial retreat and
climate change can affect I'roject operations is necessary to inform the evaluation of potential
protection, mitigation and enhancement (PM&E) measures."
2. Support for Glacial Melt and Runoff Study and NEPA Analysis
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.
II. FERC AND 001 CONSULTATION REQUIREMENTS UNDER US TRUST RESPONSIBILITY
A. FERC Consulting Authority and Requirements
Every agency of the United States is subject to the federal government's trust responsibility, as
FERe' and courts have rccognized.' To bettcr inform these trust obligations, federal agencies
began consulting with Indian tribes on a "governmcnt-to-government" basis. The federal-tribal
government-to-government consultation concept is now recognized in statutes,' regulations;'
executive orders,' Presidentialillemoranda," and agency policies.'
I FERC Policy Statement, 104 FERC '1161,018, Order 635 (2003), and corresponding rule, 18 C.F.R. § 2, Ie.
Parravano v. Babbitt, 70 F.3d 539, 546 (9th Cir. 1995) ("thc trust responsibility attaches to the federal government
as a whole").
3 National Historic Prcservation Act, § 479a(d)(6)(B) ("a Fedcral agency shall consull with any Indian tribe ... that
attaches religious and cultural significance to properties" eligible for listing 011 the National Registcr of' Historic
Places) .
. , Advisory Council on Historic Preservation Act regulations, 36 C.ER. § 800.2(c)(2)(ii)(C) (federal agencies are to
consult with Indian tribes ror projects regardless or location; "Consultation with an Indian tribe must recognize the
governmcnt-to-government relationship between the Fcderal Governmcnt and Indian tribes.").
5 Executivc Ordcr 13175, Consultation and Coordination with Indian Tribal Govcrnments, 65 Federal Register
67249 (Nov. 6, 2000) (Section 2(b), "Thc United States continues to work with Indian tribes on a governmcnt-!o-
government basis .... "); Executive Order 1307, Indian Sacred Sites, 61 Federal Register 26771 (May 29, 1996).
6 President Obama, Memorandum 1::"01' the Heads of Executive Departments, Subject, Tribal Consultation,
November 5, 2009, 74 Federal Register 57881 ("My Administration is committed to regular and meaningful
consultation with tribal olTicials in policy dccisions that havc tribal implications, ... through complete and cffcetive
implementation of Exccutive Order 13 J 75."); Presidcnt ClilllOIl, Memorandum, for the Heads of Executive
(continued ... )
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Federal Energy Regulalory Commission
November 12, 2012
Page B of 12
Shortly before leaving office in 2000, President Clinton issued Executive Order (EO 13175),
Consultation and Coordination with Indian Triba[ Governments. Section 5 of EO 13175 directs
federal executive agencies to have accountable processes to ensure meaningful and timely input
by tribal officials in the development of regulatory policies that have tribal implications. President
Obama's November 5, 2009 memorandum to a[[ federal executive agencies directed those
agencies to develop plans to implement the policies of EO 13175. While EO 13175 does not
apply explicitly to independent agencies such as FERC, Sec. 8. states, "independent regulatory
agencies are encouraged to comply with the provisions of this order."
In 2004, Congress enacted appropriation acts requiring federal agencies to "consu[t with A[aska
Native Corporations on the same basis as Indian tribes under Executive Order 13175.,,8 001 and
the Corps therefore must consult with ClRI when they consult with Indian tribes under EO 13175,
and so should FERC. This should be read in concert with FERC's 2003 tribal policy rule at which
acknowledges FERC's trust responsibility and (b) states that FERC will "endeavor to work with
Indian tribes on a government-to-government basis, and will address the effects of proposed
projects on tribal rights and resources through consultation pursuant to the Commission's trust
responsibi[ity." 18 C.F.R. § 2,1 c(a) -(c).
FERC properly wants to hear from a[[ parties who may have significant interests in the licensing
process. CIRI therefore would [ike to meet with FERC staff to discuss the licensing process, how
CIRI can participate in the licensing process to the fullest extent possible, CIRI's substantial
interests and concerns in the Project area, and how to establish procedures to ensure appropriate
communications between CIRI and FERC.
B. DOl's ANC Consultation Policy
The constitutional, statutory and other bases cited in DOl's Triba[ Consultation Policy go beyond
EO 13175. This is important in evaluating DOl's Policy on Consultation with A[aska Native
Claims Settlement Act (ANCSA) Corporations issued on August 12, 2012 (ANC Consultation
Policy). The Preamble to DOl's ANC Consultation Policy states that it establishes a framework for
consulting ANCs in "comp[iance with Congressional direction," citing the 2004 congressional acts
requiring a[[ federal agencies to consult with ANCs "on the same basis as Indian tribes under
Executive Order No. 13175." The narrower basis for conducting ANC consu[tations-"on the
c ... continued)
Departments and Agencies, Government-to-Govcrnment Relations with Native American Tribal Governments, 59
Federal Register 22591 (May 29,1994) .
., Department 0[" the Interior Policy on Consultation with Indian Tribes, and Secrctarial Order No. 3317 ("The
purpose of this Order is to update, expand, and clarify the Department's policy on consultation with American
Indian and Alaska Native tribes; and to acknowledge that the provisions for conducting consultations in compliance
with Executive Order (E.O.) 13175 [ 1 and applicable statutes are expresscd in the Department 0[" the Interior Policy
on Consultation with Indian Tribes." (December II, 2011).
8 Pub. L. 108-199, Div. H, § 161, Jan. 23, 2004, 118 Stat. 452, as amended by Pub. L. 108-447, Div. E, Title V, §
518, Dec. 8, 1997, 118 Stat. 3267.
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Federal l:ncrgy Regulatory Commission
NOv(~nlbcr 12, 2012
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same basis as Indian tribes under Executive Order No. 13175"-is made explicit in the Preamble
to DO['s ANC Consultation Policy:
The select provisions of the Tribal Consultation Policy are modified below for the purpose
of consultation with ANCSA Corporations. The Department of the Interior distinguishes
the Federal relationship with ANCSA Corporations from the government-to-government
relationship between the Federal Government and federally recognized Indian Tribes in
Alaska and elsewhere, and this Policy does not diminish in any way that relationship and
consultation obligations toward federally recognized Indian tribes.
The Guiding Principles of DO['s ANC Consultation Policy add: "To the extent that concerns
expressed by Indian Tribes and ANCSA Corporations substantially differ, Departmental officials
shall give due consideration to the right of sovereignty and self-governance of federally recognized
Indian tribes."
As DO['s Tribal Consultation Policy does not rely solely on EO 13175, it is possible that DO[ or
Alaska Indian tribes could invoke DO[ consultation with Alaska Indian tribes on a government-to-
government, "trust responsibility" or other basis, not EO 13175. [n short, they may assert that the
2004 congressional acts mandate DO[ consultation with ANCs when DO[ invokes consultations
with Indian tribes under EO 13175.
C[R[ could consult with BLM to advise that it strongly opposes transportation and transmission line
corridors over the Seattle and Butte Creek alternatives on BLM land, urge BLM to advocate for
corridors favored by C[R[, and develop FPA section 4(e) conditions FERC must include in a license
for the Project for the use of BLM land, if authorized by FERC, that might cause FERC and AEA to
choose transportation access and transmission line corridors favored by C[RI. For the reasons
described above, if Indian tribes consulting with BLM advocate corridors opposed by C[R[, DO[
consultations with C[R[ and Indian tribes may not be on a level basis.
[II. BOARD OF CONSULTANTS
A. Support for Board of Consultants
On October 23, 2012, the Commission's Director, Division of Dam Safety and Inspections
(Director), approved a Board of Consultants (BOC) recommended by AEA for the Project. AEA
requested approval of the BOC to oversee and assess the adequacy of AEA's study plans,
investigations, designs and construction for the Project. The Director's approval identified
minimum responsibilities of the BOC.
[n accordance with the BOCs responsibilities, AEA will provide "data packages" to each SOC
member, the Director, and Division of Dam Safety and Inspections (D2S[) Portland Regional
Engineer (Regional Engineer) two weeks before BOC meetings. Within 15 days of SOC meetings,
AEA will provide the Director and Regional Engineer copies of a plan and schedule to comply
with the BOCs recommendations or a statement identifying a plan to resolve any issues, together
with detailed reasons for not doing as BOC recommended.
ClR[ recognizes that some of the information included in "data packages" provided by AEA to
BOC members and documents prepared by AEA following BOC meetings that must be provided to
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Federal Energy Regulatory Commission
November 12,2012
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the Director and Regional Director may include documents or information exempt from disclosure
to the general public under the Freedom of Information Act, 5 U.S.c. § 552, or because it is
Critical Energy Infrastructure Information (CEil), 18 C.F.R. § 388.113.
As noted previously, CIRI owns approximately 25,000 acres in the Project dam and reservoir area
and other land that may be affected by the Project, including unanticipated floods caused or
contributed to by the Project, and floods that could be exacerbated by seismic hazards in the
Project area. See CIRI lands in relation to the Project depicted on Figure 13.1-1, AEA Revised
Interim Draft Cultural Resources Study Plan at 13-13 (10/25/2012), Appendix A. The
Commission's rules provide that a landowner whose property is crossed by or in the vicinity of a
project may receive detailed alignment sheets containing CEil directly from the Commission, 18
C.F.R. § 3SS.113(d)(3), without submitting a non-disclosure agreement under 1 S C.F.R. §
388.113(d)(3).
CIRI's interests in site geology include but are not limited to mineral resources, the exploitation of
which may be adversely affected by the Project design and construction alternatives evaluated by
the BOC and AEA. ClRI's ability to manage lands and resources it owns or controls down-river
from the proposed dam, together with human safety of those entering and using CIRI land will be
affected by Project design, construction and operation considered by the soc.
S. Recommendation
ClRI recommends that the Commission direct AEA to negotiate with CIRI toward the goal of
reaching an agreement regarding CIRI access to SOC "data packages" and AEA reports of SOC
recommendations that takes into account CIRI's unique interests as a major Alaska Native
Corporation ANCSA landowner in the area that will be affected by the Project, and AEA's interests
in protection of CEil information. This recommendation is not itself a request for CEil information.
Neither AEA nor ClRI should be deemed to waive any position it has or could assert regarding
disclosure or nondisclosure to CIRI of SOC "data packages" or reports of SOC recommendation
by reason engaging in the negotiations hereby recommended.
IV. NHPA CONSULTING PARTY DESIGNATION AND MEETING WITH FERC STAFF
A. Request for Designation as NHPA Section 106 Consulting Party
NHPA Section 106, 16 U.s.c. § 470f, requires federal agencies, including FERC, DOl and the
Corps, to take into account the effects of their actions on properties listed on or eligible for listing
on the National Register of Historic Places (National Register). IJroperties "of traditional and
cultural importance to Indian tribes may be eligible for inclusion in the National Register." 16
U.s.c. § 470a(d)(6)(A). The NHPA directs federal agencies to "consult with any Indian tribe ...
that attaches religious and cultural significance to properties" eligible for listing on the National
Register. 16 U.S.c. § 470a(d)(6)(B).
The NHPA also requires agency Section 106 procedures to be consistent with regulations adopted
by the Advisory Council on Historic Preservation (Advisory Council). 16 U.S.c. § 470h-
2(a)(2)(E)(i). Advisory Council regulations establish elaborate, multi-step procedures for extensive
government-to-government consultation with Indian tribes. Among other things, Advisory Council
regulations state that "agency official shall recognize that Indian tribes ... possess special
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Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
November 12, 2012
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expertise in assessing the eligibility of historic properties that may possess religious and cultural
significance to them." 36 C.F.R. § 800.4(c)(1).
With respect to CIRI's interests, the Advisory Council regulations provide that "organizations with
a demonstrated interest in the undertaking may participate as consulting parties due to the nature
of their legal or economic relation to the undertaking or affected properties, or their concern with
the undertaking's effects on historic properties." 36 C.F.R. § 800.2(c)(5). The action agency must
identify any parties entitled to be consulting parties and invite them to participate in the section
106 process. 36 C.F.R. § 800.3(1). Consulting parties have procedural rights under the Advisory
Council's regulations comparable in some but not all respects to those of Indian tribes. See, e.g.,
36 C.F.R. § 800.6(c)(3) (consulting parties may be invited to be concurring parties to a document
resolving adverse effects).
The Advisory Council's regulations also provide that the views of the "public are essential to
informed Federal decisionmaking in the Section 106 process. The agency official shall seek and
consider the views of the public in a manner that reflects the nature and complexity of the
undertaking and its effects on historic properties .... confidentiality concerns of private individuals
and businesses, and the relationship of the Federal involvement in the undertaking." 36 C.F.R. §
800.2(d).
Because the Project dam, reservoir, borrow sites for construction materials, airport, likely
recreation facilities on or around the reservoir, and other I)roject works will be on CIRI land and
certain alternatives for transportation access and transmission line(s) are on CIRI land, ClRI has
interests as a business-landowner in historic properties on its land that may be affected by the
Project, including business confidentiality concerns, and may have organizational interests on
behalf of its shareholders in historic properties on CIRI land. FmC's January 19, 2012 letter
inviting ClRI to consult with I'ERC staff regarding the Project is broad enough to include, but is not
limited to, NHPA Section 106 historic property matters.
CIRI has significant interests in the Project area and by actively engaging as a consulting party with
FERC, AEA, and the Alaska State Historic Preservation Officer in FERC's Section 106 process.
Thus, pursuant to 36 C.F.R. § 800.3(f)(3), CIRI requests that the Commission designate CIRI as a
consulting party to participate in consultations with the Alaska State Ilistoric Preservation Office
and the Commission in the NIWA section 106 process for the Project. This request is based on (a)
the location of the proposed Project on ClRI land, (b) CIRI's stewardship interest in identification,
documentation, evaluation of effects, and resolution of adverse effects of the Project on historic
properties listed on or eligible for listing on the National Register of Ilistoric Places on CIRI land as
well as those historic properties located outside ClRI land of concern to CIRI and its Dena'ina
shareholders, and (c) long-term economic impacts on CIRI of managing its lands taking into
account historic properties affected by or potentially affected by Project development, including
but not limited to regulation of recreation trespass on historic trails on CIRI land attributable to
Project development.
B. Meeting with FERC Staff
On January 19, 2012, the COJnmission invited CIRI to meet with Commission staff to discuss the
Commission's licensing process, how CIRI can participate to the fullest extent possible, ClRI's
interests and concerns in the affected area, and how to establish procedures to ensure appropriate
I I
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ATTACHMENT A
FIGURE 13.1-1 f AEA REVISED INTERIM DRAFT CULTURAL RESOURCES STUDY PLAN
AT 13-13 (1012512012)
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APPENDIX B
ClRI COMMENTS ON DRAFT TRANSPORTATION ACCESS ANALYSIS AND APPENDICES
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Octobcr 15, 2012
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I. Cornrnents on Appendices
A. Overview
The Appendi((~5 confirm concerns expressed by CIRI in its August 31, 2012 cornment
letter. These concerns include but are not limited to: AI:A's evaluation of rail, road,
and bridge alternatives without field-level reconnaissance for the Southern route,
reflecting in part AEA's lack of consultation with ClRl; analyses of road alternatives
without adequate contemporary engineering, geotechnical, 01' other appropriate field
investigations; AEA's failure to take into account transmission line siting cost and other
considerations that could significantly impilCt I'mject construction costs and schedule,
energy security consider'ations, and environmental irnpacts; use of subjective
evaluation criteria; failure to evaluate climate change data and trends on road and
transmission line construction and maintenance costs for all alternatives in Appendix
D; and appearance of prejudgment favoring the Seattle Creek and Butte Creek
alignment alternatives.
13. AppendiX H, Geotechn ical Report
Appendix H confirms that the investigators conducted very limited if anyon-the,
ground geotechnical investigation of the South [Road] Alignment or rail alternative on
CI RI land as part of the work for that Appendices. Appendix 1-1 states, at 4, that the
South Alignment "was not given the sarne attention given other alignments during the
field reconnaissance effort," and that "Subsequently, it has been requested that we
provide evaluation of the South Alignment." The report does not disclose what that
further evaluation involved or how it would compare in scope and detail to
investigations conducted of other access alternatives. Confirmation of the limited
investigation of the South Alignment and I'ail alternative is found in the eighty (80)
geotechnical photographs in Attachment 1-1, including photographs incorporated into
the HUlTicane West, Seattle Creek and Butte Creek site plans. Not one of these 80
photographs depicts South Alignment road or rail geotechnical featur'es. AppendiX H
concecies, at 4, that "the geotechnical evaluation and conclusions regarding the South
Alignment are based on literature review and limited observations in the field," a
qualification not repeated for any other Alignment.
Appendix H concludes, at 25, that each Alignrnent "provides a viable option for
accessing the Watana Hydroelectric Project site," but that "the corridors arc not equal
in their favorability based on several factors." Appendix H gives an "opinion" ranking
alignments in the following order from rnost to least favorable: Butte, Seattle,
Hurricane and South Alignments .. !Q" According to Appendix H, that "opinion" is
"corroborated through the subjective ranlilllg...5ystern presented in Section 7.0 and
discussed in further detail below." Id, (emphasis added). That "opinion" is based on
criteria outlined in Section 6, including permafl'Ost conditions. The Conclusion's
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I)age 3 of 6
unfavorable "opinion" regarding the South Alignment is based in part on "poor
subgrade support conditions [thatl may exist in the form of thaw unstable permafrost."
Appendix H at 28. That conclusion and opinion appear to have been formed in the
absencc~ of any field-level geotechnical reconnaissance and core sampling on CIRI
land.
Appendix H states, atl, that the "rc)sults of our evaluation will be used to supplement
other criteria, such as construction costs and environmental impacts, ill an attempt to
select the optimum alignment corridor to be submitted in the Federal Energy
Regulatory Commission (FERC) application for the Watana Hydroelectric I'roject."
Whatever else may be said of Appendix 1-1, it does not pl'ovide at this point an
adequate technical or scientific basis for a recommendation to make a selection
decision against the South Alignment.
C. Appendix B, Structures Report (13ridges), Appendix D, Cost Estimate, Appendix L
Wetlands
Appendix B focuses on bridges for several South Alignment road alternatives. Like
Appendix 1-1, this Appendix docs not appear to be based on any on-the-ground field-
leve,1 investigations on ClRI land or consultations with ClR!. Some of the pictures in
Appendix 13 appear to be based on aerial over-flights.
The Introduction to Appendix 13 includes a generalized observation that "Even under
ideal circumstances, ... large bridges can add years to the duration of a project." This
is followed in Section 3, captioned South Road Alignment Concerns, by a statement:
"In the case of the South Road alignment, the challenges could prove to be nearly
insurmountable." Section:3 adcls that "the presence of the major structures [for the
South Alignment road bridges] will inflate the schedule of the South Road alignment
relative to other alignments studi(~s." Section 3 adds that "without a feasible concept
in mind the difficulties of construction could render this alignment financially reckless
to achieve." In the absence of on-the-ground investigations and consultations with
CIRI, these statements reinforce the appearance that the Draft Access Analysis and
Appendices are the product of pre-judgment by ;\E;\ favoring the Seattle Creek and
Butte Creek alignment alternatives.
Appendix B notes that design and construction techniques, costs and schedules for
long-span bridges, those over JOO feet, are Significantly different: than those under 300
feet. The cost of constructing "conventional" bridges under 300 feet is calculated
based on a 35 foot wide bridge and a cost per square foot of $350. Bridges over 300
feet are assumed to have the same width but cost $1,000 per square foot, du(, to
different design, construction and access requirements. Whether long-span bridges
could be constructed to a width narrower than 35 feet consistent with the Project
purpose and need and cost impacts of a narrower bridge design are not evaluated in
Appendices 13 or D.
3
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Way"e Dyok
October 15, 2012
Page 4 of 6
The South Alignment, climbing to a higher elevation than the South B Variant, would
bridge Cold Creek (conventional: 200 feet), Cheechako Creek (long-span: assumed to
be 400 feet for Appendix D cost estimate, but could be 500 feet), Fog Creek Tributary
(conventional: 250 feet) and Fog Creek (conventional: 150 feet). The South 13 Variant
would run closer to the Susitna River, making the same crossing as the South
Alignment but adding 800 feet of conventional bridge tributary crossings. The Fog
Creek Variant would cross Cold Creek (conventional), Cheechako Creek (long-span),
and Fog Creek Corge (long-span: 700 feet). The South Alignment would be least-cost
among the three Southern variants.
Appendix 0 adopts the South Alignment for its cost estimate comparisons. Direct and
indirect cost estimates in millions for the road and rail alternatives are as follows:
South $251.2; Ilurricane (Western) -$211.5; Seattle Creek -$164.2: Butte Creek .,
$175.7; rail $400.3 million. These cost estimates do not include life-of..the Project
license maintenance, permitting and mitigation costs of any access alternative or
associated transmission line(s).
For example, there are significant differences in wetlands impacted among the various
alternatives for which no cost is ('stimateci for deSign, permitting and mitigation that
may be required to comply with Clean Water Act section 404, 33 USc. § 1344, and
Corps of Engineers mitigation regulations, 33 C.F.R. Part 332, Compensatory
Mitigation for Losses of Aquatic Resources. See Dr'aft Access Analysis Section 4.2.6.2
("Seattle Creek (North) alternative impacts the greatest total of acres of wetlands ....
Consultation with the Corps will be necessary to further evaluate permit stipulations
and conditions, including potential mitigation options."); Appendix L Wetlands (same).
Table 2, ApPE'rlClix L tabulates Category 3 and 4 wetlands likely requiring greatest
scrutiny fOl' design to avoid and minimize wetland impacts and further evaluation for
permitting and mitigation within the '150 foot right of way buffer l1lost likely to be
impacted by IJroject construction and operation. Of these, 36.3 acres are within the
Southern alternative, compared to 147.3 acres for the Seattle Creek alternative, a four-
fold difference. Even assuming that some of the 316.5 acres of unmapped Southern
alternative lands qual ify as Category 3 and 4 wetlands, the Seattle Creek al ignment is
still likely to be burdened by more wetlands imposing greater costs for design to avoid
and minimize wetland impacts and permitting and mitigation than the Southern
Alignment. With 135 acres of Category 3 and 4 wetlands falling within the 150 foot
right of way buffer for that half of the Butte Creek alternative for which wetland maps
area available, the Butte Creek alternative also is likely to be burdened by 11l01'C costs
for design to avoid wetland impacts and wetland permitting and mitigation than the
Southern alignment. On a subjective professional judgment basis, using a scale from I
to 5 with 1 being "no impact" and 5 being "significant impact," Appendix J
characterizes the Seattle Creek and Butte Creek alternatives as having a value of 3 for
wetlands impacts compared to a value of 2 for the Southern and Hurricane (West)
alternatives. Whether Appendix J subjectively understates the Significance of wetland
4
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Wayne Dyok
October 15, 2012
Page 5 of 6
impacts for the Seattle Creek and Butte Creek could be debated. Regardless, wetland
design, permitting and mitigation costs for the Seattle Creek and 13utte Creek
alternatives are I ikely to be greater' than for the Southem alternative. Appendices B
and D also do not evaluate transmission line alternatives construction, maintenance,
mitigation and permitting costs, wetlands or otherwise.
Appendix D does not estimate impacts of permafrost on road, rail or transmission line
construction and maintenance costs for any access or transmission line alignment or
reasonable alternatives in light of current climate change information, data and trends.
It may be inappropriate to make transportation access and transmission line alignment
cost estimate and selection decisions without consideration of relevant climate change
data and trends information that may be relevant to consideration of those alternatives.
For each access and associated transmission line(s) alternative, "all-in" cost estimates
should include direct and indirect construction, life-oF-the Project license
maintenance, permitting and mitigation costs. Before AEA and FERC make an
irreversible and irretrievable commitment of resources to a preferred access and
transmission line alignment, CIRI recommends that AE/\ and FERC consult with CIRI
regarding (a) appropriate on-the-ground investigation of access road or rail and
transmission line alternatives on or affecting CIRI land, (b) appropriate criteria for "all-
in" cost estimatE:s for each road, rail and transmission line alternative and (c)
consideration of ciirect, indirect anci cumulative environmental impacts, permitting,
mitigation, and energy security considerations which should be factored into any
decision on Project access and transmission line route alternatives.
D. Appendix A, Design Criteria
ClRI anticipates that AEA will rf~quest FERC to issue a license with a 50 year term. Is it
appl'opriate, therefore, to propose a "20-year design" for the Project's access road?
What arf~ the life-of-the Project maintenance and replacement cost estimates that flow
from a "20-year design" for' the F'roject's access road? Are the 22-foot wide lane and
shoulcler road width description on page 4 of Appendix A consistent with the 3,S,foot
wide bridge design described in Appendix 13 used to estimate costs in Appendix D?
Appendix A acknowledges, at 3 and 4, that the access road will open potential
recreation opportunities for the public after construction of the dam is completed.
While certain limited recreation opportunities may be made available to the public
within the Project boundary under the Project license, the Seattle Creek and Butte
Creek alignments and related transmission line will afford the public unregulated and
uncontrolled access to CIRI land. Predictably, this will result in unregulated and
uncontrolled trespass, hunting, fishing and travel on ClRI land, theft of or other harm to
cultural resources, timber and other natural resources on CIRI land, demand for
medical and rescue emergency services on CIRI land, management of unauthorized
waste disposal on CIRI land, and increased risk of human-causes fires endangering
5
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Way ne Dyok
Oc tober 15, 20 12
Page 6 o f 6
l iv es and damag in g natural reso urces o n CIRI l and . These are amo ng th e bases of
ClR I's opp os iti o n to th ose ro utes arti c ulated i n o ur A ugust 3 1,20 12 and M ay 3 0,2 01 2
co mm ent lette rs.
II. Co nclu sio n
As st ated i n Cl RI 's M ay 30, 2 01 2 co mm ent letter to FERC, ClR I is sup po rtive o f th e
Pro j ec t in p r incip le. But, CIRI is interes ted in ensur ing that th e Pro j ec t i s i nves ti ga ted,
co nstr ucted, o perated, m ai nt a in ed and mit iga ted in a mann er t hat is se nsi t iv e to CIRI
land s and reso ur ces, i n vo lv ed A las ka N ati ve vi ll age co rpo rat io n s and th at t he ir
res pec tiv e A las ka N at ive shareho l ders. C IRI ow ns an d manages l and and reso urces fo r
A l as ka Na tive shareho l ders in acco rdan ce with federal law , i ncl ud in g the A laska
Nat i v e Claim s Se tt l ement Act, 43 U .S.c. § 160 3 et seq.
Th us, CIRI is no o rd inary, private land o wn er o r stake ho lde r. FERC an d A EA shou ld
ens ure that ClR I, inv o l ved A las ka N at ive v ill age corpor ation s and th ei r res p ec tive
A l as ka Na ti ve shar ehold ers are inform ed o f th e fu ll range o f pote nti al env i ronm ent al,
natur al res ource, energy, and eco no m i c imp ac ts o f th e Proj ec t, and are co mp ensa ted
appropr iately fo r the Pr o j ec t's use and inu ndat ion of and i mp ac ts on Cl RI lands and
reso u rces . Thro ugho ut th e Pro j ec t li ce nsin g process, FERC and A EA sho u ld co nsul t
w it h CIR I in mea n i ngfu l wa ys and at mea n i ngfu l tim es co nsi stent with th ese goa ls and
th e speci al ro l e t hat CIRI p lay s in o wn ershi p and manage ment of land and reso ur ces
affec ted by the Pro j ec t.
O ur comm ent s o n th e Appendi ces are off ered to th ese end s.
Sin ce rely,
COO K IN LET REG IO N, INC.
By : &$SL
Ethan G. Sc hutt
Sen io r Vi ce-Pr es ident, Land and Energy D evelo pm ent
6
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Susi(na-Watana Draft Access
ClRI Comments
Page 2 of 6
As the following comments will show, the conclusion drawn in the Draft Access Analysis "that the
South Road and Hurricane (West) corridors would be less desirable as the access road corridor
than the other two corridors" is based on (a) no contemporary engineering, geotechnical or other
on-the··ground field investigations of ClRI land of which we are aware, (b) no consultation with
ClRI, possibly in violation of Executive Order ·13 ·175, Consultiltion and Coordination with Indian
Tribal Cowrnments, (c) no other public consultation of which we are aware, (d) erroneous
statements (some attributable to a lack of consultation), (e) data gaps, m sweeping, subjective,
qualitative assumptions in lieu of quantitative data, (g) no current climate change data and trends
which need to be considered in evaluating access corridors on permafrost and other lands, and (h)
a general absence of field verifications at a level sufficient to support access and transmission
corridor planning-level decisions for a project of this character. The Draft Access Analysis glosses
over the importance of co-locating the transmission corridor and access road, and fails to consider
important practical construction concerns affecting the cost and feasibility of each proposed
access route and transmission corridor.
In short, the Draft Access Analysis supports the need for much mOre information, not a fact-based
decision on an aCG)SS corridor for the Project. Therefore, CIRI recommends that the AEA consult
with CIRI, and other public agencies dnd interested parties, including ClRI, to (1) conduct studies
sufficient to support a fact-based, technically-sound decision on an access corridor, including
undertaking a core sampling operation by helicopter along each of the proposed routes with the
consent of the appropriate landowners, (2) develop a model for accurately projecting the cost of
each option, including the cost impact of co-locating (or not) the transmission lirw(s), and (3) select
preferred access and transmission routes.
Detailed Comments
A. Appendices to the Draft Access Analysis Were Not Published; Request to Extend the
Comment Period
The AEA did not publish the appendices to the Draft Access AnalYSis. So that interested parties
may provide comprehensive feedback on the report, including any analysis of cost estimates, CIRI
requests that the AEA make the appendices available and extend the) public comm()nt period on
the Draft Access Analysis to September 30 to permit supplemental comments based on
information in the appendices.
B. Conclusions in the Access Analysis are Not Based on Current Quantitative Data
CIRI has serious concerns that the Draft AcC0?SS Analysis came to its conclusions in the absence of
current quantitative data.
On page 1, the Draft Access Analysis states that "Itlhe information contained in this report is based
largely on existing information that was supplemented by limited field inwstigations performed in
October 2011. No public or agency consultation was conducted in the development of this
report." f'resurnably, the "existing information" referenced by the ADOTPF is the 1982 Access
Planning Study Supplement and other studies used in the 1980s licensing effort. However, that
data is 30 years old. The AEA should not base any access corridor siting decision on a report that
uses 30-year old data and where "Inlo public or agency consultation was conducted" that might
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Susitna-Walana Draft Access
CI RI COll1ment,
Page .3 of 6
have led to relevant site-specific information, and bases its conclusions, even in part, on
subjective, unverified qualitative generalities labeled "criteria."
cor example, the geologic and geotechnical analysis in Section 4.2.2 is, by its own terms, based
on a "lack of quantifiable data." As Mr. Weldin describes in his letter, the rock borrow quality and
availability is crucial to keeping construction costs low; therefore, accurate data on geologic and
geotechnical conditions is very important to the route-selection process. However, the Draft
Access Analysis relies solely on work clone in the 19aos combined with aerial reconnaissance and
hand-sampling of selected locations, and bases its conclusions with r("spect to rock quality on a
geotechnical engineer's qual itative eval uation of that information. Moreover, Table 4-12 states
that rock borrow availability, soil borrow availability, drainage, rock slope stability, and
foundation support are "not used as evaluation criteria." These characteristics of each route must
be included as evaluation criteria in the route-selection pl'Ocess.
Conclusions in the Draft Access Analysis cannot be relied upon without recent, quantitative data,
especially with respect to critical cost-controlling components, like borrow rock quality and
availability ancl natural conditions that are likely to have changed over the last 30 years, like
permafrost conditions.
C. Certain Conclusions are Based on Unfounded Assumptions
In several places, the Draft Access Analysis states unfounded assumptions that are then relied upon
in making its conclusions. First, Section 4.2.7 states that "lllands owned by Native corporations
typically take between 18 and 24 months to negotiate acquisition." rd. at 67. This rings untrue to
CIRI with respect to its lands. As you know, ClRI is a major landowner along the South Road
cOITidor alternative as well as in the dam and reservoir area. However, the Draft Access Analysis
runs with the assumption, characterizing the South Road and Hurricane (West) corridors as "not
preferable." CIRlr8COll1mends that AEA and ADOTI)F consult with ClRI about access over CIRI
land for the Project corridor before preparing a final Access Analysis report.
Second, in Section 4.2.1.4, the Draft Acc()ss Analysis assumes that construction on the access
corridors will not take place during the winter months "becaus(> of the need to achieve
compaction with moisture ancl density controls." ref. 1'1.'13. Such an assurnption, if proven invalid,
would have a substantial impact on the construction schedule for each route. In fact, based on
his 35 years of construction experience, it is Mr. Weldin's professional opinion that "dealing with
permafrost, high ground wat"", Ci"e()k crossings, and excavating waste and overburclen is best
accomplished in the winter months under most circumstances" (emphasis added).
D. Climate Change and Permafrost
Section 2.2.2.6 discusses permafrost conditions. No consideration of permafrost as a construction
factor is adequate without an evaluation of current cIata and projections relating to climate change.
The access road needs to support access to the Project site for heavy equipment during
construction, operation and maintenance for the initial license period, which could bee up to 50
years. Regardless of cause, reasonably foreseeable warming climate conditions over the next 50-
60 years will likely affect permafrost, making an area that might be suitable for access in the near
term unsuitable or unreasonably more expensive to operate and maintain during later stages of the
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Susilna~Watana Draft Access
CI RI Comments
Page 4 of 6
Project license. The final Access Analysis report needs to analyze this issue based on best
available science. That analysis may affect the access corrielor selection.
E. The Access Analysis Glosses Over the Importance of Co-Locating the Access RO'lcl and
Transmission Corridor
Co-location of the access road and the transmission corridor will be v'"'y important to minimizing
the overall cost of the Project. Section 4.2.1.7 states that the advantages of co-location include
"lower transmission line construction and maintenance costs and reduced project footprint." Draft
Access Analysis at 33. CIRI agrees and believes the Draft Access Analysis did not properly
consider the cost and logistical impacts of (1) constructing the i3utte Creek ([ast) corridor when the
AEA has stated that it is not considering locating a transmission lin(~ there or (2) the total number of
linear miles of transmission line that would be requir(~d above 3,000 feet in each corridor.'
The Draft Access Analysis indicates that the Butte Creek (East) corridor is not being considered as a
location for a potenti,)1 transmission line. lei. at 93. Based on this information and pending
confirmation that sc'parately locating the accc~ss road and transmission corridor would result in a
substantial increase in total Project costs, the ilutte Creek (East) corridor should be rejected.
The Draft Access Analysis also indicates that the elevation of the transmission line should be less
than 3,000 feet, likely because of potential snow loading and icing on the lines. See id. at 13.
Although the Draft Access Analysis indicates that short segments above 3,000 feet may be
acc(~ptable, id.at JJ, it presents no justification for recommending the Seattle Creek (North)
corridor, which woulcllocate 32 of its 43.3-l11ilo length above the 3,OOO-foot level. Similarly, the
Draft Access Analysis does not take into account the potential additional cost of locating only a
portion of the transmission line within the, Seattle Creek (North) corridor. See icl. at 93 ("In a
meeting on October 25,2011, A[A and their consultants indicated ... that the transmission line
could share a corridor with the access road within most of the Seattle Creek (North) corridor.").
Approximately 9.5 miles of the transmission line' would have to be routc'ci on the east side of
Deadman Mountain, while the access road would remain on the west side. The additional costs
of constructing a transmission line ('I) 74'X) of which is located above 3,000 feet and (2) only a
portion of which would be co-located with the Seattle Creek (North) access road, must be
calculated and considered in the Draft Access Analysis.
Conclusion
Even a cursory review of the red ("not preferable") and green ("favorable") designations in Table 5 ..
1 of the Draft Access Analysis reveals that the analysis improperly weighted its chosen criteria. For
~ In an October 25, 2011 meeting with the ADOTPF project team, the At" indicated it would prefer
to locate the transmission line in the 5Jme corridor as the road but would pref<~r 10 remain under an
elevation of 3,000 feet. Draft Access Analysis at 13 n.7.
1 Calculated based on the route deSCription on pp.13-14 of the Draft Access AnalYSiS, which states
that the Seattle Creek (North) corridor would split near MP 1 n.5 and, presumably, reconnect as the corridor
drops down into the Deadman Creek drainage at MP 28.
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Susilna-Watana Dra(! /\ccess
CI RI Comments
Page 1 of 6
72259014.4 0034044-00006
APPENDIX A
letter from Richard Weldin
[Follows this page.)
20121113-5031 FERC PDF (Unofficial) 11/12/2012 9:35:33 PM
C= I R I Services Corporation·
August 29, 2012
Dara Glass
Land Manager
COOK INLET REGION, INC.
2525 C Street
Anchorage, Alaska 99503
2525 C Street, Suite 500 CI PO Box 933.30
Anchorage, AK 99509·3330 CI 9072.74.8638
Re: Comments on Draft Watana Transportation Access Analysis
Dear Ms. Glass:
I have had an opportunity to review the Draft Watana Transportation Access Analysis document
as you requested. At this time, I do not believe it is possible to make an accurate determination
as to the proposed access routes. At page 34, paragraph 4.2.2, the report states:
Due to the lack of quantifiable data to evaluate the geologic and
geotechnical conditions, the project team decided to develop a set
of specific development criteria assign each criterion a value
between 1 and 5, with 1 being most favorable. These values,
assigned by a geotechnical engineer, represent the overall
suitability of the criteria for a road corridor and are shown in Table
4-12 (located at the end of this section). The remainder of this
section describes each criterion considered. (Emphasis added.)
From my perspective, building a good road largely depends on the availability of suitable
material in the quantities necessary and within a reasonable hauling distance to the construction
site. This factor is not quantified in the report. Another factor is the disposal of waste material,
which would be of considerable volume on this project. Simply "assuming" this material can be
deposited in an alluvial borrow pit or a rock quarry is not a good basis for a detennination.
I disagree with the assumption that construction on the access corridors will not take place
during the winter months. In my 35 years of construction experience, dealing with pel1nafrost,
high ground water, creek crossings, and excavating waste and overburden is best accomplished
in the winter months under most circumstances.
The routes with the shortest overall distance to Anchorage should be given initial priority
consideration because Anchorage is the largest city with the biggest port and would, therefore,
result in a better value for initial construction costs, as well as use and maintenance over time.
20121113-5031 FERC PDF (Unofficial) 11/12/2012 9:35:33 PM
August 29, 20J2
Page 2
The report is misleading and is formatted in a way that makes it difficult to interpret. The
comparison factors, see attached Table 5-1, appear to be based in a malmer consistent to support
a pre-determined selection.
• Tn the Travel Time section, if the basis is moved to Anchorage, the favorable rating
moves over to the South Road and Hurricane (West) routes. I do not understand why
Cantwell was used as a point of basis for the other two routes.
• Combining the road work (new and upgrade) on the Seattle Creek (North) and Butte
Creek (East) options completely changes the view and moves the favorable colors on the
sheet over to the South Road and Hurricane (West) routes.
• Using linear feet of bridge to give the Seattle Creek (North) and Butte Creek (East) routes
a favorable rating is a poor basis. The height and complexity is a mow accurate
measurement, and could easily change the ratings.
$ Under the Geologic and Geotechnical section, the Seattle Creek (North) and Butte Creek
(East) options are given a favorable rating despite the fact there is simply no quantifiable
data to back this rating up.
• Transporting equipment to the dam site will involve extremely heavy loads, alld I sec no
comments regarding the possibility of upgrading the bridges on the Denali Highway
route.
• I believe that the travel time ii'om the railroad to the dam should have given the Hurricane
(West) route a ftlvorable rating, yet the report gave no rating.
Clearly a few factors in the basis and the way the routes were rated could be changed, and the
most favorable route would be different.
This report is subjective in my opinion because no quantitative data was provided, and numerous
qualifying statements were made. It appears to me the authors of this report were allowed to
select their own criteria, and this was accomplished in a manner that allowed a specific route to
be chosen.
Please feel free to contact me if you have questions or wish to discuss the report further.
Attachment: Table 5-1
Very truly yours,
Richard Weldin
President
crRI Services Corporation
Document Content(s)
CIRI Comments re AEA Study Plans_SD2 11-12-2012.PDF...................1-33
20121113-5031 FERC PDF (Unofficial) 11/12/2012 9:35:33 PM
November 14, 2012
7511 Labrador Circle
Anchorage, AK 99502
jan@hydroreform.org
To: Kimberly D. Bose, Secretary, Federal Energy Regulatory Commission
Fr: Jan Konigsberg, Alaska Hydro Project; Becky Long, Alaska Survival; Rick Leo,
Coalition for Susitna Dam Alternatives.1
Ref: Comments on Alaska Energy Authority Proposed Study Plan for Susitna
Dam FERC project #14241.
1. National-Level Economic Valuation Study Request
In July, both FERC and Alaska Energy Authority rejected the rationale for the national-
level economic valuation study.2
Essentially, FERC, while acknowledging that economic valuation of natural resources and
non-power values is an imperfect exercise, suggests, moreover, there is no acceptable
methodology for assigning value to many non-power values, which means that FERC will
ultimately decide what value will be assigned to the natural and other non-power values
without having articulated the process by which they derived the value(s). In doing so,
FERC seems to be opting for an even more imperfect approach to valuation than the
various methodologies that many economists would employ in ascertaining value of
non-market goods and services.
Below we address the FERC’s and AEA’s arguments rejecting the study request.
1 The study request was submitted under the auspices of Natural Heritage Institute (NHI). Jan
Konigsberg is no longer affiliated with NHI, and now directs Alaska Hydro Project with support
from Hydropower Reform Coalition.
2 See Federal Energy Regulatory Commission, “Scoping Document 2, Susitna-Watana
Hydroelectric Project, FERC Project #14241-000,” July 2012, Washington D.C. pp. 8-9. “Proposed
National-Level Valuation,” pp. 3-1 3-8 of AEA’s “Proposed Study Plan,” July 2012 in which
Alaska Energy Authority mistakenly refers to American Whitewater as the study’s instigator;
American Whitewater specifically states it is supporting NHI et al. study request.
20121114-5114 FERC PDF (Unofficial) 11/14/2012 1:33:03 PM
2
A. “Equal Consideration” by the Commission is Procedural and Substantive
Congress amended the Federal Power Act in 1986 requiring the Commission give equal
consideration to non-power values when deciding to license a hydropower project.
Historically, the Commission’s licensing decisions and licensing conditions took little or
no account of the jeopardy the project posed to the extant environmental, social, and
cultural values. Consequently, the 1986 amendment imposed equal consideration not
only as a procedural requirement, but also a substantive one: In its decision on appeal
by the Platte River Whooping Crane Critical Habitat Trust, the US Court of Appeals
reasoned that
. . . equal consideration must be viewed as a standard, both procedural and
substantive, that cannot be satisfied by mere consultation or by deferring
consideration and imposition of environmental conditions until after licensing.
Protection, mitigation and enhancement of fish and wildlife, energy conservation,
and the protection of recreational opportunities are a potential cost of doing
business for hydropower projects.3
In other words, we understand the Court of Appeals to say that the Commission must
not only have considered the non-power values, but also be able to demonstrate its
licensing decision has been substantially informed by its consideration of non-power
values.
Further, the Court of Appeals, when explaining that a key objective of the ECPA was to
give environmental factors equal weight as power production in licensing deliberations,
refers to the Conference Committee report to elucidate the historic import of the equal-
consideration amendment:
The conferees believe that as a Nation we have come a considerable distance in
recognizing the importance of our heritage. This legislation extends that "distance" a
bit more. The amendments expressly identify fish and wildlife protection, mitigation
and enhancement, recreational opportunities and energy conservation as
nondevelopmental values that must be adequately considered by FERC when it
decides whether and under what condition to issue a hydroelectric license for a
project. We agree that there are instances in which careful and thoughtful
consideration of the impact of a proposed project would and should lead to the
conclusion that an original license ought not to be issued [emphasis added].
Thus, one possible outcome of equal consideration of non-power values is the
Commission’s denial of a license, ostensibly because the public would be worse off with
3 Platte River Whooping Crane Critical Habitat Maintenance Trust v. Federal Energy Regulatory
Commission, 876 F.2d 109, (D.C. Cir.1989).
20121114-5114 FERC PDF (Unofficial) 11/14/2012 1:33:03 PM
3
the project than without it.4 This outcome would seem to be more likely in original-
license proceedings than relicensing, where the baseline condition is the post-project
environment and where environmental improvement is change to project operation
(e.g. increased minimum flow) and/or project infrastructure (e.g. fish passage).
Denying an original license would be a weighty decision for the Commission, presumably
due to the Commission having determined that the nation would be worse off if the
project were built. In other words, the Commission would find that no amount of
compensation for and/or mitigation of the impacts to non-power values from
developing the river for power, irrigation, flood control, water supply results in a net
improvement to society.5
B. Equal Consideration in FERC Practice
Equal consideration of non-power values relies principally upon the information and
analysis provided to the Commission in the license application. In general, FERC’s
practice is to rely upon the information and analyses provided in the license application
to prepare the NEPA document as well as to fulfill the equal-consideration mandate of
the FPA. The Commission’s default licensing process the Integrated Licensing Process
(ILP) integrates FERC hydropower licensing with the NEPA process. In an ILP
proceeding, as Susitna dam is, FERC approves the suite of studies it deems necessary to
fulfill its NEPA responsibility on the assumption that this information is necessary and
usually sufficient for the Commission’s equal-consideration “exercise.”
If it is acknowledged that the public-interest calculus is the determination of whether
the nation is better off with the project than without it, then it would follow the public-
interest calculus involves comparing the value to the nation of the undeveloped
watershed to the value of the watershed if developed as proposed. If so then, a crucial
4 A plausible standard for deciding a project is in the public interest is the gainers must gain
more than the losers lose and further that the gainers must be able to compensate and/or
mitigate the losses and still go along with the change; society must be better off after the
change than before.
See Udall v. Federal Power Commission, 387 U.S. 428 (1967): “The grant of authority to the
Commission to alienate federal water resources does not, of course, turn simply on whether the
project will be beneficial to the licensee. Nor is the test solely whether the region will be able to
use the additional power. The test is whether the project will be in the public interest. And that
determination can be made only after an exploration of all issues relevant to the public
interest.”
5 With respect to a federal hydroelectric license, the “public “ whose interest the Commission is
authorized to ascertain is that of the entire country, not that subset of the public that resides in
Alaska or even more narrowly, that population of Americans residing in the Railbelt, which is
region to be supplied by the electricity from the proposed Susitna dam.
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4
question is how the watershed is to be valued at the national level and whether the
information garnered pursuant to FERC’s ILP study plan, while necessary, is sufficient for
such a valuation calculation.
The geographic bounds for the environmental data required by the FERC study plan is
the area that the proposed project is likely to affect, which in the case of the proposed
Susitna dam is 40 miles upstream of the dam site and up to 184 miles downstream of
the dam site as well as the road and transmission corridors. The geographic bounds for
the socio-economic data required by the FERC study plan is the area that will experience
the economic and social impacts of the project. This area is usually greater than that of
the potential environmental impact of the project. In the case of the proposed Susitna
dam, the region that will be affected stretches from Homer on the southern end of the
Kenai Peninsula, north to Fairbanks, a straight-line distance of around 400 miles.
The major premise of our “National-Level Economic Valuation Study” request is that the
project’s potential costs and benefits to the nation are likely to be significantly different
from the proposed project’s potential costs and benefits to the directly affected
(Railbelt) region. Therefore, we argue that the information FERC typically collects at the
watershed-level and at the regional-level may be necessary but is not sufficient for the
Commission’s equal consideration exercise, especially if the Susitna River in its currently
undeveloped state is assumed to be a river of national, if not global importance,
particularly given its recreational opportunities, 5 species of Pacific salmon and critical
habitat for the endangered Cook Inlet Beluga whale. 6
In determining that a project is best adapted to a comprehensive plan for the affected
waters, FERC considers national as well as regional interests.
Works designed to control our waterways have thus far usually been undertaken
for a single purpose, such as the improvement of navigation, the development of
power, the irrigation of arid lands, the protection of lowlands from floods, or to
supply water for domestic and manufacturing purposes. While the rights of the
people to these and similar uses of water must be respected, the time has come
for merging local projects and uses of the inland waters in a comprehensive plan
designed for the benefit of the entire country. Such a plan should consider and
include all the uses to which streams may be put, and should bring together and
coordinate the points of view of all users of waters. ‘(The plans of the Commission
6 AEA rejects the national-level economic valuation on the grounds that the information to be
gathered for the social economic analysis pursuant to NEPA is sufficient for the Commission’s
determination of the public interest, claiming that “there is simply no evidence that public-
interest balancing of environmental and economic impacts requires a national perspective to
weigh and balance all public interest considerations consistent with FERC’s statutory obligations
under FPA.”
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5
should be formulated) in the light of the widest knowledge of the country and the
people, and from the most diverse points of view.7
FERC (SD2) does “not dispute that the existence of a free-flowing, wild Susitna River that
supports salmon and other resources would have intrinsic value to Alaskans and others
nationally.” This begs the question of how, then, is FERC to adjudge the intrinsic value
of the free-flowing, wild Susitna River in relation to a dammed, regulated river.
We do not deny the Commission has discretion in determining the public interest and its
public-interest calculus is necessarily subject to professional judgment. Yet, if the
Commission is, in the Court of Appeals words, to “give these nondevelopmental values
the same level of reflection as it does to power and other developmental objectives,”
such reflection is unlikely to be productive if the information about the non-power
values is of poor quality. In other words, if equal consideration is to be meaningful, the
information about non-power values provided to the Commission must be as complete,
accurate, and precise as the information for development objectives, which we argue
includes information about the value the nation places on an undeveloped Sustina
watershed.8
FERC (SD2) asserts:
. . . 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 adequately only by dollars and cents . . . Moreover, the public interest
balancing of environmental and economic impacts cannot be done with
mathematical precision, nor do we think our statutory obligation to weigh and
balance all public interest considerations is served by trying to reduce it to a mere
mathematical exercise.
We agree that the public-interest calculus is not supposed to be a “mere mathematical
7 Scenic Hudson Preservation Conference v. Federal Power Commission,354 F.2d 608 (2d Cir.,
1965)
8 See Scenic Hudson Preservation Conference v. Federal Power Commission: “The Commission
must see to it that the record is complete. The Commission has an affirmative duty to inquire
into and consider all relevant facts.”
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6
exercise.”9 Our study request acknowledges that total economic value an individual
derives from a natural resource, such as a river basin, can be conceptually divided into
use and nonuse values. The point is to measure the overall value the public places on
the benefits from the undeveloped watershed. We also fully understand that the value
of public goods cannot be fully evaluated using market-based methods, and nonuse
values cannot be captured by analyzing data on observed choices. We also understand
a methodologically sound approach exists to measure values that include individuals’
nonuse values for public goods, such as a free-flowing, salmon-bearing river.10
We contend, therefore, that to the extent that an economic valuation of non-market
goods and services is methodologically viable and valid, the less likely it is that the
Commission may either undervalue or overvalue those non-market goods and services,
particularly undervalue, as it compares the value(s) of “non-market” goods and services
to the ostensibly objective market-value of the goods and services from the
hydropower-developed watershed.11 Further, to the extent that monetization of non-
power values can be justified methodologically, such quantification serves to minimize
the subjectivity of the Commission public-interest determination, thereby reducing the
potential of arbitrary judgment.
FERC (SD2), however, questions the efficacy of economic valuation of non-power
resources in the Commission’s public-interest calculus:
9 This assertion, at least in the context of FERC’s rejection of NHI et al.’s study request, is a red
herring: our study request does not suggest nor does it imply that the public-interest
determination is or should be a mere mathematical exercise. We are well aware of the fact that
valuation of non-market goods and services cannot be as precise as the market pricing of goods
and services, and when this acknowledgment is coupled with the fact that some non-market
goods and services have intrinsic value (non-use) that cannot be monetized – but may
nevertheless be assessed (valued) in terms of preferences — there can be no question that the
public-interest calculus cannot be reduced merely to a computational matter. But to conclude,
however, that the public-interest calculus ought to therefore eschew any computational analysis
is simply fallacious.
10 See Namekagon Hydro Co. v. Federal Power Commission, 216 F.2d 509, 511-512 (7th Cir.
1954). The Commission realizes that in many cases where unique and most special types of
recreation are encountered a dollar evaluation is inadequate as the public interest must be
considered and it cannot be evaluated adequately only in dollars and cents’). In affirming
Namekagon the Seventh Circuit upheld the Commission’s denial of a license, to an otherwise
economically feasible project, because fishing, canoeing and the scenic attraction of a ‘beautiful
stretch of water’ were threatened.
11 Non-market goods and services can be valued/monetized, such as wetlands filtering surface
water (a service) and wetlands providing clean water (a good), at the same time the wetlands, in
toto, also have intrinsic value.
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7
In the context of public interest balancing for long-term authorizations, it is not
appropriate to rely too heavily on the accuracy of current dollar estimates of non-
power resource values, calculated using any number of reasonably disputable
assumptions and methods. This is particularly true if we were to try to determine
and weigh national values against the energy needs of Alaskans, as the Natural
Heritage Institute would have us do.
The Commission’s public-interest calculus boils down to Railbelt region’s need for power
and the value the nation ascribes and derives from the undeveloped watershed. We are
admonished by FERC that the public-interest calculation should not rely “too heavily” on
estimates that are based on reasonably disputable assumptions and methods. but
without FERC explaining to what extent these estimates should be relied upon and
without acknowledging that economic valuation of hydropower also relies on
assumptions, if not methods, that may be reasonably disputed (as do the models for
environmental-impact analysis).
We would argue that FERC has a duty to understand the value of the free-flowing
Susitna River to the extent that reasonable methodologies are available to do so.
Still, FERC (SD2) does not agree it has such a duty:
Equal consideration is not the same as equal treatment [emphasis added].
Nothing in the statute requires the Commission to place a dollar value on non-
power benefits, even if the Commission assigns a dollar value to the licensee's
economic costs.12 . . . Where the dollar cost of measures can be reasonably
ascertained, we will do so.
Here, FERC is simply reiterating its traditional cost-benefit analysis for valuing
hydropower projects, where project financing, construction, operations and
maintenance costs, along with the costs of preventive, mitigation and enhancement
measures are compared to the expected benefits from power sales over the life of the
project. In other words, FERC does not agree it is required to value the loss of non-
power resources that would result from construction of the project, albeit some portion
of the loss of value is ostensibly reflected in the cost of mitigation and enhancement
measures required by the license.
While equal consideration might not require equal treatment of non-power resource
values, it does not preclude it and, nonetheless, the statute presumably requires non-
power resource values be treated fairly. Further, FERC is wrong to assume that
12 See Scoping Document 2. In its rebuttal of the NHI et al. study request, AEA is also eager to
point out that not all values can be monetized, implying that we propose monetizing all values,
when, in fact, our study request acknowledged and stipulated not all values can be monetized.
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8
economic valuation of non-power goods and services implies equal treatment: The
valuation of non-power goods and services, which flow from so-called “natural capital”
comprised of the various biological and physical elements and processes of the
watershed, is not the same as the valuation of goods and services that are generated by
hydropower. The latter’s value is set by sellers and buyers in the marketplace, whereas
no market of willing buyers and sellers exists to establish the market price of many non-
power goods and services.13 Nonetheless, methodologies are available to estimate a
reasonable price/cost for some non-market goods and services. Fundamental to our
study request is that economics treats valuation of market and non-market goods and
services differently, not necessarily equally, to enable a valid and informed comparison
of the non-power values to power values to the extent that is methodologically valid.
C. Conclusion
If the licensing process is supposed to ascertain whether the change to the Susitna
watershed from developing hydropower makes Americans as a whole better off, but
neither FERC nor AEA support our request for a national-level economic valuation of the
watershed is justified, we are left to conclude that the Commission will continue to rely
on its traditional approach to cost-benefit analysis, supplemented by its judgment about
the value of those non-power resources to the nation that is not captured by the cost-
benefit analysis. Without incorporating information that would be provided by our
proposed national-level valuation, we believe FERC’s licensing decision will be inherently
more subjective. Admittedly, information provided by the proposed national-level
economic valuation will be based upon disputable assumptions and methods, but is, we
believe, superior to the Commission’s traditional approach to adjudging the value
Americans would place on the free-flowing, salmon-bearing Susitna River.14
13 From the perspective of the market, many non-power resources are perceived to have no
value. In other words when the non-power resources are treated in the same manner as the
goods and services from hydropower, then their value is zero. Economic theory suggests that
valuation of non-market goods and services is not derived by the same (equal) treatment as
accorded to goods and services bought and sold in a market; hence, when non-market goods
and services are valued in the market context, the valuation is invalid and not accurate.
14 See Scenic Hudson Preservation Conference v. Federal Power Commission: “The Commission
must see to it that the record is complete. The Commission has an affirmative duty to inquire
into and consider all relevant facts.”
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9
2. Instream Flow Study
Project construction and operation would have an effect on the flows downstream of
the dam. As the project is intended to operate in a load-following mode, the project
would cause seasonal, daily, and hourly changes in Susitna River flows compared to
existing conditions. The proposed flows would influence downstream resources and
processes, including fish and aquatic biota and their habitats, channel form and function
including sediment transport, water quality, groundwater/surface water interactions,
ice dynamics and riparian and wildlife communities. The Instream Flow Study (IFS) will
characterize and evaluate these effects.
Of particular concern is the effect of fluctuating flows on juvenile salmon, especially
during the winter. An objective of the revised proposed instream flow study is to
ascertain the potential of fluctuating flows to strand or trap juvenile fish, where a
stranded fish is almost always a dead fish and a trapped fish, if trapped long enough, is
also a dead fish.
The potential of fluctuating flows 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.
The juvenile salmon that overwinter in the mainstem would likely be affected by flow
fluctuation when occupying habitat near or at the river’s edge. Flow fluctuation affects
the river stage and river velocity. When the stage changes, so does the river edge.
Presumably, as the river’s edge moves laterally back and forth in response to flow
fluctuations, so do juvenile salmon – moving back and forth in response to flow
fluctuations takes energy, which will likely result in loss of body weight. If fry are
continually moving to and fro in response to changes in stage, then they must increase
food intake to maintain body mass. If body mass cannot be maintain, then the juvenile
mortality rate mortality increases.
Also, if juvenile salmon were to respond to stage fluctuation by moving to habitats that
are not as subject to flow fluctuation, the risk is that the habitat may be marginally
suitable and/or increase in occupation of the habitat leads to density-dependent
mortality.
Presumably, too, the more juveniles are forced to move in response to fluctuations in
stage, whether laterally or downstream, the more subject they are to predation, due to
increased movement which increases the chance of detection by predators.
Further, while reduced body mass is likely to increase the mortality rate of over-
wintering juveniles in the mainstem, reduced body size may also increase mortality of
smolts entering marine waters. Pacific salmon experience relatively high mortality rates
during the first few months at sea and it are believed that the high mortality rates may
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10
be partly related to size. Size dependent marine mortality of juvenile salmon may be
concentrated during two specific early marine life-history stages: The first stage may
occur just after juvenile salmon enter the marine environment, where smaller
individuals are believed to experience higher size-selective predation. The second stage
is thought to occur following the first summer at sea, when smaller individuals may not
have sufficient energy reserves to survive late fall and winter. Thus, larger individuals
within a cohort likely have higher probability of survival, emphasizing the importance of
size during the first summer at sea.
Literature Cited
Farley, E.V., J.H. Moss, and R.J. Beamish, “A review of the critical size, critical period
hypothesis for juvenile Pacific salmon.” N. Pac. Anadr. Fish Comm. Bull. 4: 311–317,
2007.
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Document Content(s)
JK Nov 14 PSP comments..DOC...........................................1-10
20121114-5114 FERC PDF (Unofficial) 11/14/2012 1:33:03 PM
November 14, 2012
Hon. Kimberly C. Bose, Secretary
Federal Regulatory Commission
888 First Street, N.E.
Washington, DC 20426
Via online submission to:http://www.ferc.gov
NRDC COMMENTS ON PROPOSED STUDY PLAN AND REQUESTED MODIFICATIONS
TO THE PROPOSED STUDY PLAN OF THE ALASKA ENERGY AUTHORITY FOR THE
SUSITNA-WATANA HYDROELECTRIC PROJECT (FERC PROJECT P-14241)
Dear Secretary Bose:
On behalf of the Natural Resources Defense Council (“NRDC”) and our more than 1.3 million
members and online activists, we submit to the Federal Energy Regulatory Commission
(“FERC” or “Commission”) the following comments and requested modifications to the
Proposed Study Plan (“PSP”) published on July 16, 2012, by the Alaska Energy Authority
(“AEA”). The PSP consists of over 1,200 pages summarizing 58 proposed studies of potential
impacts on a pristine environment of the construction of a hydroelectric generating facility, dam,
reservoir, access roads and transmission corridor, proposed to be constructed on a remote stretch
of the Susitna River in Alaska (“Project”). The Commission has established November 14, 2012
as the deadline for comments and requested modifications to proposed studies pursuant to its
regulations for the Integrated License Process (“ILP”) under which the license application is
being reviewed. (18 C.F.R. 512.) On November 1, 2012 AEA published a revised “Interim
Draft Revised Study Plan” (“Interim Draft RSP”), and has requested that stakeholders and
resource agencies base their study plan comments on the Interim Draft RSP rather than the “now
largely outdated PSP.”1 The following comments and requested study plan modifications apply
equally to both the PSP, dated July 16, 2012, as well as the AEA’s Interim Draft RSP, published
November 1, 2012.
Neither stakeholders nor resource agencies have had sufficient time to adequately analyze,
assess, and provide comments on the recent revisions to the PSP, considering that publication of
the most revision occurred November 1 and the deadline for comments is November 14. As the
National Marine Fisheries Service (“NMFS”) points out: “A period of only 14 days is
insufficient for NMFS to review and to provide comments to FERC on the revisions to the PSP
potentially affecting over a dozen studies for this proposed large original hydropower project.”2
Letter from AEA to Hon. Kimberly D. Bose, FERC, October 31, 2012.
Letter from NMFS to Kimberly D. Bose, October 31, 2012, p.2.
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November 14, 2012
Hon. Kimberly C. Bose, Secretary
Page 2 of 8
As noted above, AEA has requested stakeholders and agencies to respond to the Interim Draft
RSP, rather than the version of the PSP published July 16, 2012. This shifting goal line for
comment only two weeks before the deadline precludes meaningful public and agency comment
on the proposed studies.
NRDC has a vital interest in this Project. NRDC is a non-profit organization that has as its
established purpose to safeguard the Earth, its people, its plants and animals, and the natural
systems on which all life depends. Among NRDC’s priorities are to curb global warming and
create a clean energy future; revive the world’s oceans; defend endangered wildlife and wild
places; protect our health by preventing pollution; ensure safe and sufficient water for people and
the environment; and to foster sustainable communities. NRDC is concerned that the Susitna
hydroelectric project will likely have serious and significant adverse impacts on the surrounding
complex, pristine environment due to the project’s magnitude and location. We appreciate the
opportunity to provide comments on the PSP and Interim Draft RSP, and to provide suggested
modifications to the studies proposed in the plan and the Interim Draft RSP. These comments
and requested study proposal modifications should be read in conjunction with NRDC’s
comments and study requests pertaining to the Project submitted to FERC on May 30, 2012.
1. The ILP is an Inappropriate Process for an Application for a New Hydroelectric License,
and the Issue is not Addressed in the PSP or the Interim Draft RSP.
As noted in our May 30th, 2012 letter, the two-year study time-frame built into the ILP process
does not provide sufficient time to study the baseline conditions in the Susitna River basin. Due
to the time constraints built into the ILP, AEA is now asking stakeholders and resource agencies
to respond to hundreds of pages of technical study plan revisions in a matter of weeks, something
that would take months for meaningful review. This has been a consistent problem since the
outset of the Project. In reviewing the comments and study requests submitted in May by the
federal agencies in response to the AEA’s Pre-Application (“PAD”) and Scoping Document 1
(“SD1”), the most consistent comment provided by the resource agencies was that the ILP does
not allow adequate time to design and execute studies necessary to establish baseline
environmental conditions. However, despite the agencies’ attention to this critical issue, neither
the July 16 PSP nor the November 1 Interim Draft RSP include a response by AEA to the
assertion by agencies and stakeholders that the ILP, with its two-year study time frame, is
inappropriate for licensing of a new, large scale, hydroelectric generating facility in an isolated,
undeveloped area.
The United States Fish and Wildlife Service (“USFWS”) stated in its May 31st comments on the
PAD and SD1 that, “the time limits imposed by the ILP have prevented a fully integrated
discussion and review of the study requests by federal resources agencies”; and further noted that
the agency was “unable to create Study Requests for all fish, wildlife and habitat under our
purview, within the time constraints imposed by the ILP process.”3
3
USFWS “Scoping Comments, Recommendations, and Study Requests,” May 31, 2012, FERC
Project No. 14241, p. 11
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November 14, 2012
Hon. Kimberly C. Bose, Secretary
Page 3 of 8
The National Marine Fisheries Service (“NMFS”) echoed the comments of USFWS regarding
the inadequacy of the ILP process to accommodate a project of this scale within the time
constraints of the ILP. In its May 30th Comments on the PAD and SD1, NMFS states, “the ILP
timeframes are a poor fit for this project. An adequate amount of time must be allowed for
necessary rigorous impact assessments in support of FERC’s ultimate licensing decision.”4 The
ILP abbreviated study time-frame has prevented NMFS from performing its statutory duty to
provide comments and study requests, as it states, “NMFS lacked time and staff resources to
create Study Requests for all fish species and issues related to their habitat, within the time
constraints imposed by the ILP process.”5 The agency points out that the staff at FERC
acknowledged during planning meetings that the ILP was designed more appropriately for
relicensing existing facilities where the baseline conditions are known, rather than for a new
license application.6 In fact, as pointed out by NMFS, a new hydroelectric generating facility
license application is unprecedented at this scale and latitude, and is the first of its kind generally
to be proposed in the past 40 years, largely due to scientific evidence of the hugely adverse
ecological impacts of large hydroelectric projects on previously undammed rivers.7
NMFS’ October 31st letter to FERC reinforces its prior contention that the ILP is unworkable for
the agency, and that such an abbreviated time frame for study of a project of this size, located
within an ecosystem the complexity of the Susitna River basin, is inadequate. The agency states,
“NMFS must alert FERC to the problems posed by the short two-week turnaround expected for
NMFS’ comments on redrafts of plans which were originally filed and distributed for review on
July 16, 2012.”8 NMFS notifies FERC in its October 31 letter that it “will likely not be able to
review [the] revised plans” because of the applicant’s rush to complete the study proposals to
meet the ILP’s strict deadlines.9
Given the inability of federal agencies charged with developing, responding to, and commenting
on study requests to actually prepare these study requests within the ILP timeframe, the ILP is a
demonstrably inappropriate process for licensing of the Susitna project. FERC should either
substantially extend the too-short deadlines of the ILP, or, on its own motion, select an
alternative licensing process for the Susitna project pursuant to FERC’s regulations under the
Federal Power Act. (18 C.F.R. Subchapter B.)
To this end, the PSP and the Interim Draft RSP prepared by AEA are intended to respond to the
comments and study requests on the PAD and SD1 filed by the agencies and stakeholders in
May, and refined during the Technical Work Group meetings conducted in Alaska since August.
(18 C.F.R. 5.12, 5.13) However, neither the PSP nor the Interim Draft RSP include a response to
4 Letter from NMFS to FERC, May 31, 2012, p. 5 5 Id.; NMFS Study Requests, May 31, 2012, p. 2 6 Id. 7 Letter from NMFS to FERC, May 31, 2012, p. 3 (citing, Graf, William L., (2006) Downstream
hydrologic and geomorphic effects of large dams on American rivers. Geomorphology 79
336-360.) 8 Letter from NMFS to Kimberly D. Bose, October 31, 2012, p. 2. 9 Id., at 2.
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November 14, 2012
Hon. Kimberly C. Bose, Secretary
Page 4 of 8
the comment, consistently raised by the agencies, NRDC and other stakeholders, that the ILP is
inappropriate for analysis of the Susitna project. A response to these comments and their related
study requests should be included in the PSP and RSP. (18 C.F.R. 5.11.) AEA should explain
why it has not requested authorization to use the traditional licensing process, which would
better suit its pre-license application. An applicant has the discretion under FERC’s regulations
to select a process other than the ILP such as “traditional license” or “alternative license” where
there are factors present in the application such as the “complexity of the resource issues,” and
“potential for significant disputes over studies.” (18 C.F.R. 5.2 (c).) The Susitna dam
application invokes a tremendously complex and diverse ecosystem and has already
demonstrated potential for disputes over studies to be implemented, hence the time-frames built
into the ILP are inappropriate for such an application.
2. The Amount of Time Proposed for Study is Insufficient to Provide a Baseline for
Conditions of the Susitna River Fisheries.
The inadequacy of the ILP two-year study time frame is especially apparent with respect to
studying the baseline conditions of the Susitna River fisheries and the anticipated Project-
induced impacts on fish populations, including accurate adult escapement estimates, juvenile
densities, macro invertebrate communities, spawning rates and other critical habitat factors.
NRDC reasserts its study request that FERC require AEA to increase the period of study from
the current two year study to a minimum five year study (preferably 6 to 7) in order to
adequately assess the habitat needs and life spans of affected fish species. This request is
consistent with similar requests made by both USFWS and NMFS during the recent comment
period for the PAD and SD1 for the Project. Specifically, NRDC objects to the study time frame
for studies proposed and described in both the PSP and Interim Draft RSP contained in Section 6
“Instream Flow Studies: Fish, Aquatics and Riparian,” and Section 7 “Fish and Aquatic
Resources,” including all studies and analysis found in those sections. The length or term of
study for these proposed studies should be altered accordingly.
NMFS and USFWS submitted comments on the PAD and SD1 in May which also objected to
such a short time frame for the studies of the Susitna River fisheries. NMFS stated, “It is
important that field studies take place over a temporal scale that includes a range of hydrological
and environmental conditions. For example, Chinook salmon completes their life cycle over a
five-to seven-year range; therefore, a two year study period is inadequate to document biological
baseline conditions and evaluate habitats and biological responses of this population under a
variety of hydrologic conditions.”10
Similarly, USFWS commented that at least 5 years of study of salmon abundance and habitat
must be undertaken to gain sufficient data to provide information to decision makers about fish
resources and develop the scientific basis for fishway prescriptions and mitigation
recommendations. USFWS points out those Chinook salmon populations are “currently
depressed statewide, for unknown reasons. If all baseline studies are conducted under this
temporary period of low Chinook abundance, a significant bias may be introduced into the data
10 Letter from NMFS to FERC, May 31, p. 5.
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November 14, 2012
Hon. Kimberly C. Bose, Secretary
Page 5 of 8
which will hamper accuracy of future modeling outputs and determinations of appropriate
compensatory mitigation.”11
NRDC objects to the two-year study of fisheries because it will not accurately assess baseline
environmental conditions, necessary under NEPA in order to provide an accurate analysis of the
impacts of the project on the environment. Many factors can make the two-year time frame for
studying the impacts unreliable. For example, two years of data collection are insufficient to
characterize Chinook salmon (Oncorhynchus tshawytscha) populations in the Susitna River for
reasons including:
• Chinook salmon occur upstream of the proposed dam site12, but are poorly characterized
due to the inaccurate assumption that Devil’s Canyon served as a migration barrier during
previous studies in the 1980s.
• The life cycle of Chinook salmon up to 7 years13, with 0-2 years in freshwater and 0-5
years at sea. Studies should last for the duration of the dominant life cycle in the Susitna
River in order to characterize productivity (recruits per spawner), a basic and important
fisheries statistic.14 Ideally, studies should characterize productivity long enough to
assess inter-annual variation and thus general trends in productivity.
• Alaska’s Chinook salmon populations—including Cook Inlet populations—are currently
in a period of particularly low returns, prompting a declaration by the state government of
a Fisheries Disaster.15 Because run numbers have fallen dramatically, characterizing
spawning populations in 2012-2013 is vulnerable to underestimation of average baseline
conditions.
• The Susitna valley witnessed exceptionally high flows in September 2012,16 after the
period of Chinook salmon spawning. Floods can scour eggs from salmon redds, increase
juvenile mortality, and increase mortality of aquatic invertebrates which are important
diet items.17 Consequently, juvenile population estimates are vulnerable to
11 Letter from USFWS to FERC, May 30, 2012. 12 Alaska Department of Fish & Game, Anadromous Waters Catalog.
http://www.adfg.alaska.gov/sf/SARR/AWC/index.cfm?adfg=maps.interactive. Accessed 8
November 2012. 13 Groot, C. and L. Margolis. 1991. Pacific salmon life histories. UBC Press, Vancouver. 14 Ricker, W.E. 1975. Computation and interpretation of biological statistics of fish populations.
Bulletin of the Fisheries Research Board of Canada 191: 1-382. 15 United States Department of Commerce, Secretary of Commerce. 2012.
http://www.nmfs.noaa.gov/stories/2012/09/docs/blank_parnell_9_13_12.pdf. Accessed 8
November 2012. 16 NASA Earth Observatory. 2012. http://earthobservatory.nasa.gov/IOTD/view.php?id=79321.
Accessed 8 November 2012. 17 Thorne, R.E. and J.J. Ames. 1987. A note on variability of marine survival of sockeye salmon
(Oncorhynchus nerka) and effects of flooding on spawning success. Canadian Journal of
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November 14, 2012
Hon. Kimberly C. Bose, Secretary
Page 6 of 8
underestimation; resulting skewed baseline data could be useless for the purpose of
detecting future impacts to salmon populations from dam development.
• More generally, studies without multi-year data fail to estimate inter-annual population
variability, making them worthless for the purpose of detecting trends.18 Salmonid fishes
exhibit high levels of inter-annual variability, such that even five years of abundance
estimates or indices may be insufficient for detecting population trends.19
A short duration of study fails to capture the life history of a species, especially one at risk, and
may overlook cyclic or temporary changes to habitat, weather, or other factors. It is crucial to
assess conditions over time to take into consideration the annual variability of hydrological and
environmental conditions. As a result, NRDC restates its request that the time frame be extended
for a minimum period of 5 years for any proposed study analyzing fisheries population,
population health, presence-absence information, spawning, rearing, or incubation patterns,
habitat requirements, or other measure of species health or viability.
3. The PSP and the Interim Draft RSP do not Include an Explanation as to why the
Proposed Study Request for a longer time frame for study of Aquatic Habitat and
Abundance was not Adopted.
Pursuant to ILP regulations, if the AEA decides not to adopt a study request made during the
comment period on its Pre-Application and Scoping process, the PSP should include an
explanation of why it does not adopt the study request. (18 C.F.R. 5.11(b)(4), providing “If the
potential applicant does not adopt a requested study, an explanation of why the request was not
adopted, with reference to the criteria set forth in 5.9(b)” must be included in the PSP.) USFWS,
NMFS, NRDC, and other stakeholders have requested that AEA amend the time-frame for all
aquatic habitat and abundance studies from its proposed two years of study to a period of at least
5 years in order to include one full life-cycle for salmon. However, neither the PSP nor the
Interim Draft RSP address this issue; nor do the proposed study plans offer explanation for
AEA’s decision not to adopt this study request for a longer term of study, as FERC’s regulations
require. NRDC requests that AEA include in its Revised Study Plan a response detailing its
reasons for failing to pursue a minimum 5-year study of aquatic habitat and abundance.
Fisheries and Aquatic Sciences 44: 1791-1795. Elwood, J.W. and T.F. Waters. 1969.
Effects of floods on food consumption and production rates of a stream brook trout
population. Transactions of the American Fisheries Society 98: 253-262.
18 Gibbs, J.P., S. Droege, and P. Eagle. 1998. Monitoring populations of plants and animals.
BioScience 48: 935-940. Shea, K. and M. Mangel. 2001. Detection of population trends in
threatened coho salmon (Oncorhynchus kisutch). Canadian Journal of Fisheries and Aquatic
Sciences 58(2): 375-385. 19 Ham, K. and T.N. Pearsons. 2000. Can reduced salmonid population abundance be detected
in time to limit management impacts? Canadian Journal of Fisheries and Aquatic Sciences
57: 17-24.
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Hon. Kimberly C. Bose, Secretary
Page 7 of 8
4. The PSP does not Explain Why the Proposed Study Request for a 2-year time frame for
study of Aquatic Habitat and Abundance is Consistent with Generally Accepted Practice
in the Scientific Community.
The ILP regulations require the PSP to “explain how any proposed study methodology
(including . . . a schedule including appropriate field seasons and the duration) is consistent with
generally accepted practice in the scientific community. . . .” (18 C.F.R. 5.11(d)(5).) As noted
above both USFWS and NMFS have stated that a minimum 5-year study of the aquatic habitat
and abundance of the Susitna River fisheries is appropriate given the need for data spanning
several seasons over the life-cycle of anadromous fish in order to accurately assess the existing
conditions and predict post project construction conditions. Further, we have presented evidence
in the sections above that two years of data collection are insufficient for study of at least one,
and likely many, fish populations that will be affected by the Project. It is therefore incumbent
on AEA to explain how the proposed two-year timeframe for study would meet the “generally
accepted practice in the scientific community,” the standard called for under the regulations.
5. Data Collected from the 1980’s is insufficient for establishing today’s Baseline
Environmental Conditions.
The AEA is planning to rely on resource data collected in the 1980’s for a previous Susitna dam
project which was abandoned in 1985. As NRDC stated in its May 30 Comments and Study
Requests on the PSP and SD1, such outdated data cannot be relied upon as the basis for
substantial evidence of existing environmental conditions in the Susitna watershed today.
Protocols for how data is collected have evolved since the 80’s; equipment that collects data has
improved, and modeling which was one-dimensional in the 80’s is multi-dimensional today. As
noted by USFWS in its comments on the PAD and SD1, since the 1980’s: “there have been
significant changes in . . . field study technology and methodology (e.g., Geographic Information
System mapping, Light Detection and Ranging remote sensing, GPS, and in stream flow and
habitat modeling techniques); recreational activities and users (including equipment,
demographics, and economics); and our understanding of short and long-term climate variability
(e.g., El Nino/La Nina, the North Pacific Decadal Oscillation and global climate change).”20
This objection is again echoed by NMFS, which characterizes the 1980’s data as “inadequate for
the current proposal” for reasons that include: 1) The 1980’s project encompassed two dams,
with the second dam to regulate downstream flow, while the current project is for one dam
operating in a load following capacity with greater downstream impacts; 2) the studies of fish
species and habitats were focused on only a few species in the 1980’s, while the current project
requires evaluation of impacts on a significantly greater number of species and their life stages
and downstream habitats; 3) the scientific work performed in the 1980’s no longer “represents
the best scientific information necessary for planning such a massive project with potential for
significant impacts to fish, wildlife, and their habitats”; 4) significant amendments made since
the early 1980’s to the Federal Power Act, and the adoption of the Magnuson-Stevens Fishery
Conservation and Management Act (which together require consultation with NMFS), require
20 Letter from USFWS to FERC, May 31, 2012, p. 3
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Hon. Kimberly C. Bose, Secretary
Page 8 of 8
FERC to give equal consideration in making license decisions to environmental quality,
protection of fish habitat and spawning grounds as to the need for the project; and 5) climate
change knowledge was “in its infancy in the 1980’s”, and “climate change has altered many of
the ‘baseline’ measures estimated estimated through the 1980’s studies”.21 The 1980’s data must
be viewed as unreliable for analysis of the existing environmental conditions on the Susitna
River.
CONCLUSION
For the foregoing reasons, NRDC objects to the AEA’s use of the ILP, and to its failure to
properly respond to agency and stakeholder comment or requests for study. NRDC requests that
FERC and the AEA establish a minimum 5-year period for study of fish species and habitat in
the Susitna River, and of the impacts of Project operation on aquatic life and the environment
both upstream and downstream of the Project site. Please do not hesitate to contact us if you
have any questions.
Sincerely,
Noah Garrison
Project Attorney
Natural Resources Defense Council
21 Letter from NMFS to FERC, dated May 31, 2012, pp. 3-4.
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NRDC Comments on PSP (Final 11-14-12) P-14241.PDF.....................1-8
20121114-5158 FERC PDF (Unofficial) 11/14/2012 4:25:00 PM
COMMENTS ON THE PROPOSED STUDY PLAN of Trout Unlimited
Alaska Energy Authority, Susitna-Watana Hydroelectric Project, FERC p-14241
Page 1
November 14, 2012
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426
via Electronic Filing
Re: Comments on Alaska Energy Authority’s Proposed Study Plan and Draft Revised Study
Plans for the Proposed Susitna-Watana Hydroelectric Project. P-14241-000
These comments are submitted on behalf of Trout Unlimited (TU), whose mission is to
conserve, protect and restore North America’s coldwater fisheries and their watersheds. TU is
a national organization comprised of over 400 chapters and more than 140,000 members. TU
has more than 800 members in Alaska, many of whom rely on the important fish, wildlife and
water resources of the Susitna River watershed for fishing, hunting and recreation, and
employment in related industries. TU and its members have serious concerns about potential
impacts from the proposed Susitna-Watana Dam and stand to suffer significant personal,
cultural and economic impacts if the dam is permitted and developed.
In addition to TU’s concerns regarding the dam itself, TU has significant concerns about
the quality and adequacy of the Alaska Energy Authority’s (AEA) Proposed Study Plan. The
most significant of these concerns are as follows:
20121114-5021 FERC PDF (Unofficial) 11/14/2012 4:16:08 AM
COMMENTS ON THE PROPOSED STUDY PLAN of Trout Unlimited
Alaska Energy Authority, Susitna-Watana Hydroelectric Project, FERC p-14241
Page 2
I. The Proposed Study Plan and Integrated Licensing Process must Accurately Evaluate
Potential Impacts to Important Fish, Wildlife and Water Resources.
Large dams, such as the proposed Susitna-Watana Dam, have extremely complex,
unpredictable and long-lasting impacts. Despite this, the AEA and FERC only contemplate two
years of studies in an effort to fast track the permitting process that shortchanges our scientific
understanding of the potential impacts and makes it impossible for the public or regulating
agencies to make informed decisions regarding the project.
This abbreviated Proposed Study Plan is insufficient to provide an adequate baseline or
to evaluate potential impacts to specific species or their ecosystem. For example, the Susitna
River watershed is an important fishery that produces all five of Alaska’s Pacific salmon.
Chinook salmon, which are one of the most important fishes produced in the Susitna River
watershed, have a life history that spans five to seven years and can exhibit significant
differences in abundance from one year to the next. By only conducting two years of studies,
the AEA virtually guarantees that it will be unable to collect sufficient information to form an
accurate baseline or to accurately anticipate potential impacts to Chinook salmon. The
Proposed Study Plan has similar shortcomings with regard to other important fish and wildlife
species, and these shortcoming compound when tying to evaluate complex ecosystem-scale
impacts or cumulative impacts.
Stream flow, water level and winter ice conditions can vary significantly from one year
to the next and will not be adequately studied in the Proposed Study Plan. Just this past fall, for
example, much of Southcentral Alaska, including the Susitna River watershed, experienced
unusually high flows and flooding above what has typified recent years or historical averages.
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COMMENTS ON THE PROPOSED STUDY PLAN of Trout Unlimited
Alaska Energy Authority, Susitna-Watana Hydroelectric Project, FERC p-14241
Page 3
By only conducting two years of studies, the Proposed Study Plan is unlikely to collect sufficient
data to account for unusual seasonal or annual events such as the floods of 2012. Additionally,
if such an unusual event happens to occur during the two year study period, the data will suffer
the opposite fault and not be representative of normal, baseline conditions.
In addition to our concerns regarding the short, two-year study period, the Proposed
Study Plan is insufficient for evaluating the full geographic scope of potential impacts. The
proposed project will require significant road, transmission and other infrastructure
development that will extend well beyond the footprint of the dam and reservoir. Impacts
from development and operation of the dam will extend upstream of the project site and well
downstream clear to Cook Inlet. The project development and how it is operated will affect
water quality and quantity below the dam site, it will have significant sediment and water flow
impacts, and it will affect the connectivity of the watershed and the movement of anadromous
and other migratory fishes. The Proposed Study Plan neglects many of these impacts and, as
such, is inadequate.
Another concern with the Proposed Study Plan is that it fails to adequately evaluate and
synthesize the existing data and information already available about the affected area. Much
of the data AEA relies on is from the 1980s and may be either outdated, incomplete, or
inaccurate. AEA should conduct a biometric review study as was requested by the U.S. Fish and
Wildlife Service and National Marine Fisheries Service to ensure that all of the available data is
considered and that that data is reliable.
II. The Proposed Study Plan and Integrated Licensing Process must Accurately Evaluate
Potential Impacts to other Affected Industries and Economic Sectors.
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COMMENTS ON THE PROPOSED STUDY PLAN of Trout Unlimited
Alaska Energy Authority, Susitna-Watana Hydroelectric Project, FERC p-14241
Page 4
Fishing, recreation and tourism are some of the most important and valuable industries
in the region and to the state generally. People travel from all over the country to visit Alaska
and the proposed project area. Despite this, there is nothing in the current permitting process
to evaluate the socioeconomic impacts of the project to the region, state and country as a
whole. The proposed Susitna-Watana Dam is of a scale and size that is unprecedented in
Alaska. 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.
III. The Proposed Study Plan and Integrated Licensing Process must Address Geologic and
Hydrologic Concerns.
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.
Another significant concern that the Proposed Study Plan overlooks is the potential
changes to local and regional hydrology that are likely to occur from climate change. Climate
change is likely to have significant impacts to local hydrology that could affect the project
productivity. 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.
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COMMENTS ON THE PROPOSED STUDY PLAN of Trout Unlimited
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Page 5
IV. The Integrated Licensing Process makes it Impossible for the Public to Fully Participate
in the Regulatory and Decisionmaking Process.
The Integrated Licensing Process requires multiple processes and studies to occur
simultaneously with overlapping and occasionally conflicting public participation deadlines.
This process does not provide sufficient time to allow studies to be completed to inform
environmental analysis and consideration of potential mitigation or project alternatives.
Specifically, 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.
V. Conclusion.
Thank you for the opportunity to review and provide comments on the Proposed Study
Plan and the related documents. I hope that these comments are helpful in developing a strong
and complete record upon with to evaluate this proposed project. Please do not hesitate to
contact me by email at awilliams@tu.org or by phone at 907.227.1590 if you have any
questions.
Respectfully,
Austin Williams
Trout Unlimited
7770 Jaguar Cir
Anchorage, AK 99502
(907) 227-1590
awilliams@tu.org
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Chase Community Council Comments on Proposed Study Plans 1
Chase Community Council
P.O. Box 205
Talkeetna AK 99676
chasetrail45@gmail.com
November 14, 2012
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C. 20426
Via FERC eFile P-14241-000
Subject: Comments on Alaska Energy Authority Proposed Study Plan (PSP) & Draft Revised Study Plans
for the Proposed Susitna-Watana Hydroelectric Project P-14241-000
Dear Secretary Bose:
The Chase Community Council is the elected local advisory body that represents public interests for the
Community Area of Chase, Alaska, and the first incorporated Community Council downstream of the
proposed Susitna-Watana Dam. Our boundaries are consistent with the Chase Community Planning
Area boundaries represented by the Chase Comprehensive Plan as adopted by Matanuska-Susitna
Borough Ordinance No. 93-071AM. We are bounded to the north by Gold Creek, to the East by the
Susitna River, to the south by the Talkeetna River and to the West by Disappointment Creek and the
Talkeetna River. Our northernmost point is the confluence of the Susitna River and Gold Creek. Our
Southern-most point is the confluence of the Talkeetna River and Susitna River.
On behalf of the residents of the Chase area, we respectfully offer the following comments on the Alaska Energy
Authority's Study Plan and Revised Study Plan for the Proposed Susitna-Watana Hydroelectric Project P-
14241-000.
Inadequate Information and Time Due to The ILP Process
the Integrated License Process selected for review continues to offer inadequate timeframes for a
project of this scope and complexity. As a result of the compressed timeline, FERC and AEA are putting
residents, Agencies and many stakeholders in the position of commenting without adequate
information or review and analysis time. Publication of the most recent revisions occurred November 1
and the deadline for comment is November 14. A period of only 14 days is grossly insufficient for
meaningful review of dozens of study plans and leaves members of the public and residents
downstream of the dam greatly concerned about the potential for critical information to be missed.
Agencies have commented repeatedly about inadequate review time. Without the comprehensive
assessments and insights from public agents the public is at a significant disadvantage and left without
adequate information and representation. Agencies are not able to coordinate among studies to
20121115-5025 FERC PDF (Unofficial) 11/15/2012 2:12:52 AM
Chase Community Council Comments on Proposed Study Plans 2
provide an integrated and holistic approach to assessment, interpretation and data sharing - resulting in
a silo'd approach to the baseline assessments which significantly limits the ability to assess the value and
functions of a healthy ecosystem. Further, it wastes time by forcing reviews to be conducted without
adequate information.
Lack of Integration and Coordination among Study Plans
Overall the study plans present a silo'd approach to the assessment of baseline conditions and do not
allow adequate time, incentive or planning for coordination among major studies. A key example is the
lack of explicit links between the wildlife biology studies and the hydrology studies. How will the wildlife
component be tied to the hydrology studies to show how nesting habits will be impacted by shifting
hydrologic regimes? How will Caribou migration be impacted by the shifting hydrologic conditions not
just above the dam but below also? How will nesting birds be impacted by changing water levels. Will
predation increase as flows decrease during the summer months leaving nesting water fowl more
susceptible to predators? How will the shifting ice conditions impact wildlife migration and
movements? What are the natural hydrologic conditions that are necessary to support wildlife habitat
and behavior? These cross-cutting lines of inquiry seem to be absent.
Inadequate Winter Studies
There continues to be inadequate emphasis on the impacts of the Dam during the winter - the time
during which the most significant impact will be seen on natural conditions. The impacts of a changing
winter flows are not well understood from previous studies and two years does not allow adequate time
to access and characterize the range of conditions that exist throughout the river system in the winter,
which in turn support human and wildlife populations. Specific examples of the questions that need to
be addressed include:
How will the natural floodplain system be impacted if there is no longer a spring flush of ice and
water?
Will the winter ice making and jamming change and if so, how will that impact the system
downstream
What are the potential detrimental impacts of varying flows on safety and transportation?
How will wildlife and fish be impacted by the change in ice conditions and loss of stable
transportation routes?
How will fish studies be conducted in the winter without impacting the behavior of the fish?
What effect will the winter water levels have on ice formation? How will these changes impact
transportation corridors, access to homes private property, local wildlife who tend to
congregate on the river in winter, access to hunting and fishing, recreational activities, including
skiing, snow-mobiling, dog mushing, and camping.
Will ice be unsafe to travel on with the lower water levels and predicted warmer water?
How will moose populations that congregate along the river in winter be impacted by poor ice
conditions?
Inadequate timeframe for the proposed studies
The two-year study period proposed for studies is inadequate, particularly for fisheries and ice
processes. Two years does not allow adequate time to characterize baseline conditions required by
NEPA to assess impacts of the project on the environment and to assess the natural conditions that
would need to be met if the dam were operational. In particular, two years of data collection are
insufficient to characterize Chinook salmon - one of the dominant species in the Susitna watershed and
a critical source of income and food for residents throughout the region. The life cycle of Chinook
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Chase Community Council Comments on Proposed Study Plans 3
salmon is up to 7 years. As documented by many of the agencies, 2 years of study does not allow the
necessary time to characterize and understand the potential impacts on the full life cycle in the Susitna
River. Given the inaccurate assumption from the studies in the 1980s that Chinook could not migrate
above Devils Canyon, adequate data from the upper river does not exist from previous efforts and
therefore cannot be used to supplement the studies being done today. Furthermore, the 2012 summer
returns were the lowest on record and therefore this year does not accurately characterize typical
baseline conditions. Furthermore, the 2012 flood prematurely halted studies, resulting in an incomplete
season of study.
Assessment of Emergency Actions
There is no discussion of the potential impact from emergency actions that could be necessary in the
operation of the dam. What are the possible scenarios and how would they impact residents and
wildlife downstream. For example, if there were a need for an emergency release during the winter or
summer, how would human and wildlife safety be impacted downstream. What are the relative
impacts and how would they be different depending upon the season?
Chulitna River Studies
There does not appear to be any significant study of the Chulitna to help understand how the changes in
the Susitna flow regime might impact the conditions of the Chulitna. For example, if the Susitna flow is
reduced, how will it impact the directional flow of the Chulitna, which is currently pushed westward by
the Susitna river. With a decrease in flow, will the Chulitna move eastward and if so how might that
impact the Alaska Railroad and the town of Talkeetna?
Assumptions about Costs and Rates
It appears that assumptions regarding costs and rates are based only on power optimization scenarios.
Given the potential need to operate the dam to also meet ecosystem functions, there should be
adequate study of alternative scenarios for operation such that a range of costs and rates can used to
reflect reasonable assumptions.
Groundwater Studies
There does not appear to be a clear link between the groundwater and surface water studies and the
engineering studies. How will the ground to surface water interaction at the dam site impact the
stability of the dam? Particularly the groundwater piping and infiltration? Additionally, there does not
seem to be any link between the groundwater studies and the potential impact on surrounding forests,
including both the forests above the dam and also the major forested regions downstream of the dam.
How will changing groundwater conditions impact the health of the forests downstream given the
potential for dropping groundwater levels - particularly given the observed destruction of forest
ecosystems under similar conditions in other parts of the country. How will the riparian zone above the
dam be impacted as water pressure increases with the reservoir?
Narrow Scope of the Subsistence Studies
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.
Water Quality Studies
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Chase Community Council Comments on Proposed Study Plans 4
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.
Inadequate Long-term Economic Valuation
Despite AEA's rejection of this study request, 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 diverse, healthy and fully functioning ecosystem.
We believe that the revised study plans do not adequately evaluate the public's best interest. The
studies should include an assessment of the full, long-term costs of the project to the State of Alaska
and local residents in the form of lost benefits such as:
Subsistence and commercial fishing impacts (set-net permits and cook inlet commercial fishing)
Recreational fishing economic impacts, including the impact to the local small businesses that
support tourism
Personal fishing rights (for subsistence)
Personal subsistence harvest
Access to residences and personal property - including winter access that specifically relies on
river travel and summer travel by boat.
In closing, the Chase Community Council appreciates the opportunity to provide comments on the
Interim Draft RSP, and to provide suggested modifications to the studies proposed in the plan. These
comments compliment and build off of comments and study requests submitted by the Chase
Community Council to FERC on May 31, 2012 and therefore should be read in conjunction with them.
Chase Community Council
Peg Foster, Secretary
P.O. Box 205
Talkeetna AK 99676
chasetrail45@gmail.com
Respectfully submitted on May 31, 2012
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Ruth McHenry, Copper Center, AK.
November 8, 2012
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E., Room 1A
Washington, DC 20426
Re: Susitna-Watana Hydroelectric Project No. P-14241-000
Study Plan
Dear Kimberly Bose:
Copper Country Alliance, a conservation group based in the Copper River
Basin, feels that the Alaska Energy Authority (AEA) has omitted two crucial
points of concern in its study plan. They are as follows:
• The national importance of natural free flowing rivers: Throughout the
Lower 48 dams are being torn down. The people of our nation now see the long
term negative impact of dams and want natural free-flowing rivers, valuing the
resources they provide.
• 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?
Residents of the Copper River Basin, Cantwell, and Talkeetna have a long
history of hunting, fishing, and berry picking between the Denali Highway and
the proposed Watana dam site. Consequently, Copper Country Alliance strongly
feels that AEA needs to contain the above essential components in its study
plan.
Respectfully,
COPPER COUNTRY ALLIANCE
Linda Rutledge, Secretary
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1
P.O. Box 2903
Anchorage, AK 99664
Phone: (907)-299-8821
waterlaw@uci.net
www.centerforwateradvocacy.org
November 14, 2012
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First St., N.E.
Washington D.C. 20426
RE: Susitna-Watana Project (P-14241-000).
Dear Secretary Bose:
Thank you for the opportunity to submit the comments below on the Proposed
Study Plan (PSP) for the above Project. The Center for Water Advocacy (CWA) is a
party to the Federal Energy Regulatory Commission (FERC) licensing process for the
Alaska Energy Authorities (AEA’s) Susitna-Watana Hydropower Project Docket #14241
(Project). In general, we are concerned that the PSP: 1) development process is
procedurally flawed; 2) does not adequately identify, discuss, and summarize all the
readily available information relevant to the existing environment for fish and wildlife or
subsistence uses including all proposed ILP studies that were submitted to AEA; 3) does
not provide a thorough discussion of the environmental baseline and effects of the Project
on aquatic and subsistence resources downstream of the proposed Project; 4) does not
provide recommendations on measures that must be taken to eliminate or mitigate
impacts of the Project; 5) fails to comprehend the scope and dynamics of the Susitna
River watershed ; 6) fails to properly consult with affected Native Alaskan Tribal
Governments and to apply Traditional Environmental Knowledge; and 7) fails to even
mention the impacts of the Project on Instream Flows for Fish, Aquatic, Riparian and
Subsistence resources in association with climate change.
Our specific concerns include the following:
I. The PSP Development Process is Procedurally Flawed
a. Failure to Include Licensing Participant Proposed Study Plans
As part of its comments on the original scoping document and ILP studies, CWA
submitted a proposed study regarding the impacts of the Project on instream flows
(attached) which was not mentioned in the PSP. CWA believes that the elements of all
ILP study requests, including those submitted by CWA and groups other than
governmental agencies must be considered as part of the study plan process.
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That AEA’s failure to consider CWA’s ILP study request is a violation of ILP
regulations, is illustrated by the fact that during some of the August Technical Working
Group (TWG) meetings, FERC staff comments during the meetings were indicative of
the agency's overall concern about the limited quality of many of the proposed studies. In
fact, FERC asked AEA why it failed to adhere to ILP regulations by failing to explain
why it rejected an agency-proposed study element and FERC, itself, admonished AEA
for not adhering to ILP regulations by failing to explain in its proposed studies why it
rejected an agency-proposed study element.
In addition, other federal agencies, including the U.S. Fish and Wildlife Service
(WSFS), the National Marine Fisheries Service (NMFS) and the Alaska Department of
Fish and Game (ADF&G), have expressed concern, during TWG meetings, about the
lack of specificity in the study plans and the 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.
b. Failure to Adhere to ILP Standards
AEA’s recent changes to the Integrated License Process (ILP) for the Project and
process-related issues substantially affect CWA’s participation in the Susitna-Watana
licensing process. Although, for example, comments are due on the PSP by November
14, 2012 just a few weeks before this deadline, AEA drafted substantial revisions to the
PSP, based on input from federal and state agency stakeholders. This has, not only
resulted in a short two-week turnaround expected for CWA’s comments on redrafts of
plans which were originally filed and distributed for review on July 16, 2012, but because
AEA requested informal concessions on these revision prior to the deadline for the
submission of PSP comments, AEA is in violation of the Study Plan notice and comment
standards. The lack of coordination in the Study Plan process has caused state and federal
agencies to complain repeatedly during TWG meetings and in writing. According to as
recent letter to FERC regarding these problems the National Marine Fisheries Service
(NMFS), for example, provides:
A period of only 14 days is insufficient for NMFS to review and to
provide comments to FERC on the revisions to the PSP potentially
affecting over a dozen studies for this proposed large original hydropower
project. NMFS is currently completing its internal review of AEA’s PSP
filed with FERC on July 16, 2012.1
In accordance with FERC regulations governing the ILP [18 CFR Section 5.12]
and the September 17, 2012, order extending by thirty days the deadline for reviewing
1 James W. Balsiger, Administrator Alaska Region NMFS re: FERC Order for Extension of Time to File
Comments on the Proposed Study and Revised Study Plans for the Susitna-Watana Hydroelectric Project
(FERC P-14241), p. 2 (October 31, 2012) (NMFS Letter).
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both FERC’s Scoping Document 2 and AEA’s PSP for the proposed project, CWEA and
other Licensing Participants are required to submit comments on the PSP by November
14, 2012. In addition, although FERC guidelines require that a Revised Study Plan will
be submitted after the comments on the PSP are submitted and reviewed, during the last
week in October and before the PSP comments were even submitted, AEA issued several
RSPs on instream flows, riparian and subsistence resources just a couple of weeks prior
to the November 14 comment deadline.
The submission of RSPs just a before the PSP comment deadline, however, not
only results in much confusion as to whether Licensing Participants should be
commenting on the RSP or the PSP, but turns commenting on the PSP into an excercise
in futility because AEA has asked licensing participants to include any revised
information or study requests concerns and any accommodations reached with AEA
regarding those concerns prior to submitting the comments on the PSP. According to a
resent letter submitted by NMFS to FERC on this issue:
During Technical Work Group meetings held the week of October 22,
2012, AEA presented preliminary information on what its revised PSPs
may contain. Some of these revisions were made available to agencies on
October 29, 2012. AEA has requested that NMFS provide comment by
November 14, 2012 on those as yet uncompleted revised PSPs, and FERC
staff have stated publically during last week’s meetings that FERC
prefers that agency comments address those undocumented changes to the
PSPs.2
This requirement, however, makes the comments on the PSP obsolete in violation
of FERC regulations because AEA is setting up an informal Study Plan review and
commenting process with the agencies that will result in decision making on the Study
Plan even before the comments are filed on the PSP. This “informal review and
resolution process”, therefore, is contrary to the study plan notice and comment process
and FERC regulations because, if the state and federal agencies and AEA have worked
out most of the study plan issues prior to the comment deadline on the PSP, licensing
participants comments who are not involved in the informal decision making process are
excluded from the Study Plan process.
Nor is it possible for CWA or other Non-Governmental Organizations (NGOs) to
participate in the informal decision making process because such organizations do not
have the resources or time it takes to participate in the multiple TWG meetings, field
trips, conference calls that have and will take place on the multiple study plan topics and
in which AEA representatives are asking for our in-put “now, not down the road,” when
formal commenting is supposed to takes place.
According to NMFS, for example, the PSP comment:
2 Id.
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…deadline presents a problem where the accommodations may or may not
have (as NMFS does not yet know) been reached only days before the
comments are due. The period between October 31 and November 14
leaves NMFS with less than 14 days to prepare and submit comments on
the proposed and revised study plans.
NMFS will address, to the extent possible, any accommodations reached
with AEA regarding its concerns with those study plans to date, but likely
will not be able to review revised plans. Unfortunately NMFS has had to
prepare comments on plans which may be outdated and substantially
revised in order to fulfill its duties in the licensing forum. Conversely,
NMFS will not have the benefit of revisions to the PSP which may solve,
or complicate, NMFS’ original concerns.3
AEA’s failure to comply with ILP regulations as part of the Study Plan calls, not
only harms the licensing process as a whole, but calls into question it’s ability to manage
the process at all. This concern is best illustrated by NMFS which states:
AEA’s repeated failures to follow its own ILP meeting guidance
compromises NMFS full participation in the ILP and harms the process as
a whole. NMFS respectfully requests that FERC ensure AEA comply
with its own meeting guidance; including scheduling, adequate notice,
provision of materials in addition to presentations, agendas, and meeting
notes and minutes. If AEA is unable to do so, NMFS is willing to work
with AEA to find a structure which would be efficient and fair to all the
participants in the process, with FERC’s oversight.4
Chapter 2 of AEA’s Pre-application Document (PAD) lays out a process plan,
schedule, and communications protocol. This plan and schedule extends from the filing
of the Notice of Intent through filing of the application for license, and prescribes specific
timeframes, deadlines, and responsibilities of FERC, AEA, and other stakeholders
involved in the ILP. Adherence to this plan is essential for guiding the application
development process in a collaborative, structured, complete, and timely manner. CWA
shares this goal and requests that FERC and AEA comply with this plan and schedule. To
this end, we, hereby incorporate by reference into these comments the comments and
recommendations relate to the specific section in Chapter 2 of the PAD listed in the
NMFS Study Plan Letter.5
Based on the fact that CWA is unable to determine whether it should be
commenting on the PSP, RSP or informal revisions worked out between AEA and agency
stakeholders, we will focus these comments on the PSP only. The PSP, therefore, fails to
ensure the effective participation of CWA and other stakeholders in order to develop an
adequate study planning record for this large and controversial project. Without
3 NMFS Study Plan Letter p. 2.
4 Id. at 3.
5 Id. at 2-3.
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procedural safeguards in place, all the parties to this proceeding risk compromise of their
goals and duties.
II. Failure to Address Endangered Species
Although, FERC’s initial Scoping document for the Project provides that the
“Cook Inlet beluga whale is an endangered species with designated critical habitat in
Upper Cook Inlet, which is located 184 river miles downstream of the proposed dam sit”6
neither the proposed Instream Flow Studies for Fish, Aquatics and Riparian nor the
Subsistence Studies contain any reference to analyzing project impacts on the beluga.
This ignores the fact that the Cook Inlet beluga whale is a genetically distinct and
geographically isolated population that lives only in Cook Inlet.7 It is the smallest
population of beluga whales in Alaska.8 In recent years, the population has plummeted
from approximately 1,300 to 284 whales.9 NMFS has taken various actions over the past
decade in an attempt to halt the decline, but the effort has been unsuccessful.
Similarly, On May 31, 2000, NMFS listed the Cook Inlet beluga whale population
as “depleted” under the Marine Mammal Protection Act (“MMPA”).10 NMFS believed
that the population decline was due to subsistence harvest, and that by restricting harvest,
it could restore the population to healthy numbers.11 However, NMFS restricted
subsistence harvest and the population continued to decline by an average of 1.45% per
year from 1999 to 2008.12
In response to a 2006 petition by conservationists, NMFS evaluated whether the
whale should be listed under the Endangered Species Act. After conducting an expert
status review, NMFS concluded that the whale had a 26% probability of extinction in 100
years and a 70% probability of extinction in 300 years.13 Based on that finding and
evidence that human development, including hydropower facilities, poses a serious threat
to the whale’s survival, NMFS listed the Cook Inlet beluga whale as endangered.14
NMFS also designated critical habitat for the whale. The designation includes
3,013 square miles of marine habitat in Cook Inlet that NMFS determined is biologically
important to the conservation of this small, range-limited population.15 Despite MMPA
and ESA protections, however, the belugas’ numbers have continued to decline.
6 Scoping Document 1 for Susitna-Watana Hydroelectric Project (No. 14241-0000), p. 10 (February 23,
2012).
7 76 Fed. Reg. at 20181 (Apr. 11, 2011).
8 Id.
9 See, The National Marine Fisheries Service (NMFS) 2011 Stock Assessment.
10 64 Fed. Reg. 56298 (Oct. 19, 1999).
11 69 Fed. Reg. 62920 (Oct. 22, 2008).
12 Id.
13 73 Fed. Reg. 62927 (Oct. 22, 2008).
14 73 Fed. Reg. at 62919.
15 76 Fed. Reg. 20180 (Apr. 11, 2011).
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In relation to the Cook Inlet beluga whales, therefore, pursuant to Section 7(a)(2)
of the ESA, 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.
III. Instream Flows
a. Expansion of Study Plan Time Period
The PSP fails to provide a sufficient study plan period for instream flow and
aquatic habitat studies to be consistent with state instream flow data collection
requirements. During TWG meetings as part of the Study Plan process, federal and state
agencies expressed concern regarding the ILP-prescribed, two-year study period.
According to the PSP, for example:
The Instream Flow Riparian Study is planned as a 2 year effort, with field
sampling conducted spring through summers and fall of 2013-2014. Delivery of
Initial Study Report in late 2013 and Updated Study Report in late 2014. Figure
6.5-7 depicts general work flow and key deliverable dates for the ISF and
Riparian ISF Studies.16
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.
In addition, that the PSP’s maximum 2 year study period for analyzing impacts on
instream flows is insufficient in this case, is illustrated by the fact that the Alaska
Department of Natural Resources (DNR), typically, requires a minimum of 5 years of
discharge data prior to issuing an instream flow water right permit under the state water
code because.17 Such 5 year minimum is necessary to determine the average amount of
instream flow necessary for habitat needs for which the water right is requested.
Although, a limited amount of hydrological data exists for some of the river reached
affected by the project,18 this data does not fully address the impacts to instream flows
16 Instream Flows Studies: Fish, Aquatics and Riparin, p. 6-29 (Instream Flows-FA&R). 17 See, 11 AAC 05.010(a)(8).
18 This data includes a 57-year hydrologic record for the Susitna River at Gold Creek (RM 136.5), which
continues to be gaged, and a 17-year hydrologic record for the river at Cantwell (RM 223.7) covering 1961-
1972 and 1980-1986 and in 2011 a new gage was established at Tsuena Creek ~RM 182, about two miles
downriver from the dam site, RM 184.
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that will be affected by the scope of the Project, and therefore, that the need for additional
stream gaging illustrates the need for FERC to require AEA to extend the study period.
Further, due to the practical problems that arise in the field as a result of weather,
equipment failure and other unforeseen factors that might well prevent or curtail some
studies during one or even two of the data collection seasons proposed by AEA, the
supposed two years of study may in fact only be one year for some studies. Even in the
event there are no weather related delays, equipment failures, etc., the critical-path issue
means that some studies presumably cannot begin until the second and last study year.
Moreover, the Study Plan calls for the development of:
…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):
• 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.19
Such models cannot adequately predict a time series of project impacts if such
time series will only address a two year period. Similarly, without extending the study
period beyond, the current, two years, it is not possible to carry out AEA’s planned
“[e]valuation of existing conditions and alternate operational scenarios using a hydrologic
database that includes specific years or portions of annual hydrographs for wet, average
and dry hydrologic conditions and warm and cold Pacific Decadal Oscillation (PDO)
phases…”20
b. Insufficient Scope of the Instream Flow for Fish, Aquatics and
Riparin Study
The PSP fails to study of the change to the hydrogaph for Lower River even
though the Project will sufficiently affect river morphology in such reach. AEA’s
contention, during the TWG meetings, that the project’s change to the hydrograph will
not be significant enough to affect the various physical process that affect river
morphology in the Lower River is questionable because changes in the timing of high
19 PSP Instream Flows-FA&R at 6-9.
20 Id. at 6-10.
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flows affect anadromous species and habitats by altering timing of immigration and
emigration, ability to ascend natural and artificial barriers and overbank habitats that
provide cover and nutrients in juvenile life-stages.
In addition, changes in the stage of the reach below the powerhouse due to project
operations can have numerous effects on anadromous species and their physical habitats.
Down ramping events, for example, can rapidly change the water surface elevation and
wetted perimeter of a reach, stranding juvenile fish or dewatering redds and up ramping
can scour redds and create increased velocities which can be barriers to upstream
migration. Floodplain functions and ecological processes depend on seasonal and
periodic inundation of the floodplain. Finally, alteration of streamflow rates are the
primary predictor of biological integrity for fish and macroinvertebrate communities.
Water uses such as hydroelectric power, therefore, have the potential to change both the
riparian and aquatic habitat conditions needed to by fish.
c. Failure to Include TEK
The PSP’s Instream flow for Fish, Aquatic and Riparian Studies section is
completely devoid of the collection of TEK for determining impacts on instream flows.
TEK will not be applied in any of the listed Study Goals and Objectives for these
studies.21 The PSD, therefore, fails to appreciate a significant tool for addressing potential
project impacts to instream flow, aquatic and riparian resoruces.
In fact, although “[c]riteria will include observed physical phenomena that may be
a factor in fish preference (e.g., depth, velocity, substrate, embeddedness, proximity to
cover, groundwater influence, turbidity, etc.) [and i]f study efforts are unable to develop
robust sitespecific data, HSC/HSI will be developed using the best available information
and selected in consultation with licensing participants,”22 there is no mention of taking
advantage of TEK to fill data gaps or when observed physical information is needed.
IV. Subsistence Resources
a. Failure to Consult With Native Alaskan Tribal Governments
The PSP fails to include the need to consult with Native Alaskan Tribal
Governments as a measure to protect and enhance environmental resources of the project
area. The sole reference to consultation appears in the RSP which provides that
“[c]onsultation efforts to date include discussions with agency representatives, Alaska
Native entities, and other licensing participants at the Project Technical Workgroup
Meetings and other meetings with the Alaska Department of Fish and Game (ADF&G)
held between December 2011 and June 2012.”23
21 PSP Instream Flows FA&R, p. 6-9-10.
22 Instream Flow Studies: Fish, Aquatics and Riparian, p. 6-9. 23 Draft Revised Study Plan Subsistence Resources at 14-3.
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The need to consult with the Tribes, however, illustrated by the fact that there are
a number of regional and village Native corporation lands in the dam project area
including the area slated for submersion by the reservoir. First, a number of the land
holdings of village corporations are not near the villages themselves. This is because
Southcentral Alaska was already very populated by the time the Alaska Native Claims
Settlement Act was passed, so there was little land left to select that was not already
privately owned or otherwise unavailable. That ultimately, put back the schedule of
selections, and also put many land selections at a geographical remove from the villages.
CIRI owns land in the project area that’s essentially held in trust. The land will ultimately
go to village corporations. The fact that future ownership of those lands, some of which
area involved in court proceeding, is unknown, complicates negotiations with AEA and
project development regarding land access and use of the dam project.
In addition, CWA is concerned regarding AEA’s funding of federal and state
agencies so that such agencies can hire contractors to assist them with their Project
related work. Specifically, we understand that AEA recently provided funding to the
federal agencies so that they can secure additional expertise for their Susitna project
work. As we understand the process, AEA is providing the funds to the Alaska
Department of Natural Resources; the federal agencies prepare and announce the
Requests for Proposals and will choose the contractors, but DNR will execute the
contracts and presumably pay the contractors.
While state and federal agencies have been funded by AEA for project related
work, however, it appears that Native Alaskan Tribal Governments have not received any
such funding even though there are several such entities that will be affected by the
project. This is contrary to FERC regulations and policy regarding tribal consultations
which provide that:
Before it files any application for a new license, a nonpower license, an
exemption from licensing, or, pursuant to § 16.25 or § 16.26 of this part, a
surrender of a project, a potential applicant must consult with the relevant
Federal, State, and interstate resource agencies, including … any Indian
tribe that may be affected by the project.24
Similarly, FERC has issued a:
…policy statement to articulate its commitment to promote a government-
to-government relationship between itself and federally-recognized Indian
tribes. The policy statement recognizes the sovereignty of tribal nations
and the Commission’s trust responsibility to Indian tribes…. Finally, the
policy statement establishes certain actions specific to the hydroelectric
program.25
24 18 C.F.R. §16.8 & §4.38. (emphasis added).
25 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION
18 CFR Part 2, (Docket No. PL03-4-000; Order No. 635), Policy Statement on Consultation with Indian
Tribes in Commission Proceedings, (Issued July 23, 2003). (emphasis added).
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That the provision of funding to Native Alaskan Tribal governments so
that they can hire consultants and technical staff and obtain other resources to
meaningfully sit at the table with both AEA and federal state agency technical
staff and consultants regarding hydro-power projects such as the one in question
is illustrated by the fact that:
The policy statement recognizes the unique relationship between the
Federal government and Indian tribes as defined by treaties, statutes, and
judicial decisions. It acknowledges the Commission's trust responsibilities.
It states that the Commission will endeavor to work with the tribes on a
government-to-government basis and will seek to address the effects of
proposed projects on tribal rights and resources through consultation
pursuant to trust responsibilities, the statutes governing the Commission's
authority…and in the Commission's environmental and decisional
documents…. It states that the Commission will assure tribal issues and
interests are considered in making decisions.26
Finally, many of the Technical Working Group meetings, to date, have not
involved tribal technical staff either during the meetings or comments provided by such
staff. We believe this is contrary to the fact that the “Commission will seek to engage
tribes in high-level meetings to discuss general matters of importance, such as those that
uniquely affect the tribes.”27
IV. The Subsistence Section Does Not Consider Mitigation or Prevention of
Project Impacts
The PSP fails to even mention Traditional Ecological knowledge (TEK) and it
does not request information regarding how to mitigate or prevent project impacts.
AEA’s failure to incorporate TEK into potential solutions to the substantial impacts the
Project could have on subsistence resources, however, ignores the primary purpose of the
ILP study requirement and shows a lack of understanding of the definition of TEK.
While, TEK has many definitions, it is generally referred to as a "body of
information about the connected elements of the natural environment which traditional
indigenous people have been taught, from generation to generation"28 In addition, TEk
has been described as “a cumulative body of knowledge and beliefs, handed down
through generations by cultural transmission, about the relationship of living beings
(including humans) with one another and with their environment. Further, TEK is an
attribute of societies with historical continuity in resource use practices; by and large,
26 FERC Policy Statement at 8-9. (emphasis added). 27 Policy Statement at 16.
28 Bombay, H. 1996. Aboriginal forest-based ecological knowledge in Canada. National Aboriginal
Forestry Association, Ottawa, ON.
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these are non-industrial or less technologically advanced societies, many of them
indigenous or tribal”29
That TEK can, therefore, be a valuable tool for preventing or mitigating potential
Project impacts on instream, aquatic and subsistence resources is illustrated by the fact
that it is practical, common sensical,based on teachings and experiences passed on from
generation to generation, and dynamic and changing. Similarly, TEK covers knowledge
of the environment, climate and the relationships between things and unlike conventional
data collection, TEK is holistic. It cannot be compartmentalized and cannot be separated
from the people who hold it.30
At the same time, TEK is qualitative knowledge which is gained through intimate
contact with the local environment, while noting patterns or trends in its flora, fauna, and
natural phenomena. It is based on data collected by resource users through observation
and hands-on experience. Further that the failure to ask native communities about how to
mitigate or prevent impacts to subsistence resources from Project operations, is that TEK
is an authority system. It sets out the rules governing the use of resources such as
respect, an obligation to share.31
IV. The PSP’s Work Products are Incomplete.
The PSP’s Work Products for the PSP Do not Contain Recommendations on how
to Prevent Impacts to Instream, Riparian or Subsistence Resources. The Instream Flow
Studies: Fish, Aquatics And Riparian Study’s Hydraulic Routing and Hydrologic Data
Analysis Work Product section, merely, includes:
• Executable model of the Susitna River to route unsteady flows from the Watana Dam
site downstream to the river reach where the influence of Project operations is dampened
to within the range of natural stage fluctuations;
• Tabular summaries of selected IHA-type statistics;
• Summary charts to provide visual comparisons of selected hydrologic statistics to
29 Berkes, F. 1993. Traditional ecological knowledge in perspective. In Traditional Ecological Knowledge:
Concepts and Cases, J. T. Inglis (ed). Ottawa: International Program on Traditional Ecological Knowledge
and International Development Research Centre. Pp 1- 9.
30 See, Abele, F. 1997. Traditional knowledge in practice. Arctic 50(4):iii-iv.
Berkes, F. 1999. Sacred Ecology. Second Edition. New York: Routledge.
Huntington, H. 1998. Observations on the Utility of the Semi-directive Interview for Documenting
Traditional Ecological Knowledge. Arctic (51)3:237-242. Mayor 1994 (Quoted on ANSC website). The
Alaska Native Science Commission (ANSC)
http://www.nativescience.org/html/traditional_knowledge.html as retrieved on 6 April 2012.
31 See, Menzies, C. (ed.) 2006. Traditional ecological knowledge and natural resource management.
Lincoln: University of Nebraska Press. Stevenson, M. 1996. Indigenous knowledge in environmental
assessments. Arctic 49(3): 278-291. United Nations Environment Programme.
http://www.unep.org/ik/Pages.asp?id=About%20IK as retrieved on 6 April 2012.
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facilitate discussion of the effect of modeled future operational scenarios on the without-
Project hydrologic regime.32
Further, the extent of AEA’s use of such graphs, models and charts and other
results of the hydraulic routing and hydrologic data analyses will be to compile and
present then in a study report.33 The PSP, therefore, leaves out the critical component of
providing recommendations how the instream flow studies: fish, aquatics and riparian
IFS objectives will prevent or mitigation impacts on water, aquatic and subsistence
resources.
V. Failure to Address Climate Change
Regardless of overwhelming evidence of the existence of climate change and that
such change will, almost certainly exacerbate the impacts of the Project on stream flows,
aquatic habitat and riparian and subsistence resources, these sections of the PSP are
completely devoid of any information regarding climate change nor what measures AEA
will take to mitigation such impacts when combined with the effects of the Project.
A recent joint publication of the US Geological Survey (USGS) states that:
Potential climate change impacts affecting water availability include
changes in precipitation amount, intensity, timing and form (rain or snow);
changes in snowmelt timing and changes to evapo-transpiration…The
prudent use of reservoir storage, as well as conjunctive surface water and
ground water management are strategies that water managers employ to
optimize water availability.” Therefore: Because climate change is
traditionally detected over a period that spans multiple decades
(Intergovernmental Panel on Climate Change, 2007), decisions with
application horizon greater than 20 years might reasonably be informed by
climate change information. Examples of such decisions include general
planning studies exploring feasibility, economic benefits and costs, and
estimation of risks to decide alternative actions, infrastructure or long-term
operations criterion; expected benefits and impacts of proposed actions;
environmental conditions and aquatic species likely to be affected by
proposed actions; etc.34
In addition, hydropower facilities are generally licensed for 10 years before they
are eligible for renewal for another 10 year period, therefore, according o the above
statement by the USGS, planning for stream flows and aquatic habitat which are altered
32 Instream Flow FA& R, p. 6-20.
33 Id. 34 K.D. Sharma & A.K. Gosain, Intergovernmental Panel on Climate Change, Application of
Climate
Information and Predictions in Water Sectors; Capabilities, p. 5-6 (2009). (Draft White Paper).
(Attachment 5).
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by hydroppower plant water use can, therefore, reasonably be informed by looking at
climate change information.
In addition, in an article published in the journal, Nature, USGS scientists
examined water-availability projections of climate models. Water availability is directly
related to climate. However, there is no simple relationship between future temperatures
and future water resources that would cover all regions of the world. Some regions may
experience increases in precipitation and run-off while other regions may experience
decreases.
In the USGS study, the scientists compared simulations from an ensemble of 12
global climate models with a century of streamflow measurements from 165 locations
around the world. They determined that the model ensemble is useful for simulating
regional historical longterm trends in streamflow around the world. The model ensemble
was then used to predict the complex pattern of streamflow change that can be
anticipated in the twenty-first century. Results from the models predict 10 to 40 percent
increases in runoff in eastern equatorial Africa, the La Plata basin and high latitude North
America and Eurasia by the year 2050. They also predict 10 to 30 percent decreases in
runoff in southern Africa, southern Europe, the Middle East and mid-latitude western
North America by the year 2050.35
Finally, Dr. Robert Lackey a Certified Fisheries Scientist and a Fellow in the
American Institute of Fishery Research Biologists says:
Changing climate offers another challenge. Some species of current policy
interest (i.e., salmon, bull trout, marbled murlets, northern spotted owl,
etc) are likely doomed to serious threat of extinction in the Pacific
Northwest given the warming climate and decreased snow pack. Other
species will fare much better in the altered environment and exert
competitive on these species.36
VI. Failure to Comprehend the Magnitude of Project Impacts.
By failing to extend the study period, properly apply TEK and to adequately
address the scope of the Project, the impacts of Climate Change when combined with
project impacts, and to study changes in the lower river reach due to Project impacts, the
Study Plan fails to Comprehend the magnitude and implication of the Project on
instream, fish and wildlife, riparian and subsistence resources. The scope and dynamics
of the river watershed is illustrated by the fact that:
the Susitna River [is] divided into six macro-habitat categories consisting
of mainstem, side channel, side slough, upland slough, tributaries, and
tributary mouths…The distribution and frequency of these habitats varies
35 Milly, P.C.D., Dunne, K.A., and Vecchia, A.V., 2005, Global pattern of trends in streamflow and water
availability in a changing climate: Nature, v. 438, no. 7066, p. 347-350.
36 http://oregonstate.edu/dept/fw/lackey/CurrentResearch.htm.
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longitudinally within the river depending in large part on its confinement
by adjoining floodplain areas, size, and gradient.37
In addition, the complexity of the Susitna River Watershed is illustrated by
the fact that these habitat feature types include:
• Mainstem Habitat consists of those portions of the Susitna River that
normally convey streamflow throughout the year…;
Side Channel Habitat consists of those portions of the Susitna River that
normally convey streamflow during the open water season but become
appreciably dewatered during periods of low flow…;
• Side Slough Habitat is located in spring fed overflow channels between
the edge of the floodplain and the mainstem and side channels of the
Susitna River and is usually separated from the mainstem and side
channels by well vegetated bars…;
• Upland Slough Habitat differs from the side slough habitat in that the
upstream end of the slough is not interconnected with the surface waters of
the mainstem Susitna River or its side channels…;
• Tributary Habitat consists of the full complement of hydraulic and
morphologic conditions that occur in the tributaries…;
• Tributary Mouth Habitat extends from the uppermost point in the
tributary influenced by mainstem Susitna River or slough backwater
effects to the downstream extent of the tributary plume which extends into
the mainstem Susitna River or slough.38
Further:
…these habitat types are utilized to varying degrees and at different times
by different species and life stages, with some species seeming to prefer
certain habitat types over others…Importantly, there will likely be both
inter- and intra-habitat: flow response differences between and among
these habitat types, and each will require separate investigation.39
Finally, the enormity of the task in analyzing Project impacts on the highly
complex and dynamic Susitna River Watershed is illustrated by the fact that:
The distribution and proportion of major habitat types in the Susitna River
will be identified using analyses of bathymetric data, aerial photography,
site-specific habitat and biological surveys (e.g., 1980s studies), and
licensing participant knowledge of the Project area This effort will be
coordinated with other riverine process and fish studies (See Sections 5.8-
Geomorphology Study, 5.9 - Fluvial Geomorphology Study, and various
fish studies designed to characterize the distribution, abundance and
37 PSP Instream Flows-FA&R at 6-14.
38 Id. at 6-7-14.
39 Id.
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habitat characteristics of fish populations in the lower, middle and upper
Susitna River…. The location and distribution of distinct habitat types,
areas of intense fish spawning activity/rearing will also be identified using
available information and the results of site-specific surveys….40
Indeed, for the anticipated 2 year study period alone, the Riparian ISF Study
Plan’s total approximate effort/cost: $1.2-1.5 million (not including costs for riparian
groundwater/surface water study instrumentation, field installation and monitoring, and
MODFLOW modeling).
Finally, the need to properly address the scope and impacts of the Project and
making realistic recommendations for mitigating Project impacts on the Susitna River
watershed is illustrated by the need to focus on hydrologically based stream flows in
order to assure that the Project does not harm instream flows needed for the Susitna River
watershed fishery. As we mentioned in our study request, the focus of the instream flow
studies, should be to maintain the natural water quantity and quality at streamflows and
water levels that will provide suitable habitat for fish, migratory waterbirds, and other
wildlife and to protect fish and wildlife aquatic habitat and to protect the natural
biological diversity of the river system and its floodplain by mimicking the natural
hydrological system. A large body of evidence shows that the natural flow regime of all
rivers is inherently variable, and that this variabilitiy is critical to ecosystem function and
native biodiversity”41
Stream characteristics and ecological processes affected by hydrologic regimes,
therefore, include stream channel width and depth, floodplain inundation, transport,
storage, deposition, and recruitment of substrates and organic matter, and development,
recruitment, and persistence of riparian vegetation. In addition, hydrological based
natural (as opposed to minimum) stream flows are now recognized as central to
sustaining and conserving native species diversity and ecological integrity in river and
watershed ecosystems.
CONCLUSION
In addition to failing to comprehend the magnitude of impacts that the Proposed
Susitna-Watana Hydropower project will have on fish, aquatic, riparian and subsistence
resources, by failing to follow ILP regulations, extend the study period, properly apply
Traditional Environmental Knowledge, consult with Native Alaskan tribal governments,
discuss impacts to the endangered beluga whale, adequately address the scope of the
Project, the impacts of Climate Change when combined with project impacts, and to
study changes in the lower river reach due to Project impacts, the Study Plan fails to
adequately analyze how hydrologic regimes substantially influence aquatic habitat and
ecology. Because salmon species native to the Susitna Watershed have evolved in and
adapted to the unique hydrologic regime of the Susitna and Cook Inlet Watersheds.
Changes in the timing of instream flows, therefore, affect anadromous species and
40 PSP at 6-14.
41 Poff et al. 1997.
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habitats by altering timing of immigration and emigration, ability to ascend natural and
artificial barriers, and ability to utilize overbank habitats that provide cover and nutrients
in juvenile life-stages. Also, the timing, or predictability, of flow events, is ecologically
critical because the life cycles of many aquatic and riparian species depend on
environmental cues provided by flow events and are timed to avoid or exploit flows of
variable magnitude. Alteration of streamflow magnitudes is the primary predictor of
biological integrity for fish and macroinvertebrate communities.
Similarly, the Susitna River Watershed is a significant contributor of streamflow
to the larger Cook Inlet watershed. Altered flow from the Hydro-Power Project (Project)
has the ability to affect water quantity and quality downstream to the Inlet. Further, the
Inlet is an important ecosystem from which consumptive water exports are made.
The Project’s potential impacts to instream flows, riparian areas, water quality
and amount and quality of aquatic habitat including data development; alterations of peak
flows; dam spills including the timing, magnitude, duration, and volume of spill events
below the dam; ramping on change in flow and stage and effects of the powerhouse
discharge of affected reaches; floodplains comparing the unimpaired and current
frequency, magnitude and duration of floodplain inundation and how much floodplain
area is currently accessible; natural gradient barriers to adult salmonid migration,
therefore, remain largely unaddressed by the PSP.
Please contact me, if you have any questions regarding these comments.
Respectfully,
s/Harold Shepherd
Harold Shepherd, Director
Center for Water Advocacy
Cc; Licensing Participants
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Talkeetna Community Council, Inc.
PO Box 608
Talkeetna, Alaska 99676
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, DC, 20426
Subject: Comments Re. AEA’s Proposed Study Plan
Susitna-Watana Hydroelectric Project No. 14241-000
These comments are submitted by the Talkeetna Community Council, Inc. (TCCI),
the elected local advisory body that represents public interests for the Community
of Talkeetna, Alaska, an unincorporated National Historic Townsite located within
the Matanuska-Susitna Borough 90 river miles south of the proposed Susitna-
Watana Dam.
The Talkeetna Community Council has many concerns about the proposed
Susitna-Watana Dam; with this statement TCCI presents the most critical concerns
regarding AEA’s Proposed Study Plan. The proposed studies will attempt to
represent base line data for existing Susitna watershed conditions as well as
attempt to identify potential impacts from operations of the proposed project.
The Talkeetna Community Council, Inc. recognizes the gravity of these studies in
their responsibility of encompassing the vast and complex Susitna ecosystem.
These studies require absolute and thorough diligence if the state and the public are
to rely on them to make scientifically based resource decisions. TCCI maintains
the importance of thoroughly examining the natural conditions and resources
present in the current Susitna River watershed and how they determine the
ecological and economic future of the region.
TCCI concerns include, but are not limited to, the following key issues:
Licensing Process Plan - TCCI continues to express disappointment in the
FERC, ILP timeline and AEA’s handling of the public process. Following the
May 31st submission of Scoping comments, stakeholders and agencies have once
again been forced to run the marathon of developing overlapping comments and
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data in a compressed time frame. TCCI has reviewed AEA’s initial PSP submitted
July 16, 2012 and has attended the AEA Technical Workgroup Meetings. We have
attempted to track the evolution of the PSP over the summer and fall as it has
morphed through modified study area boundaries, methodological discrepancies
and various comment tables. AEA did attempt to update some of the changes
through the aforementioned tables - but not until October and yet another extension
of the comments period. ( At this point in the FERC ILP timeframe, every
comment period to date has been delayed by a month - Scoping, Transportation,
PSP etc. proving the skeletal ILP timeline impractical for a proposed project of
Susitna’s scope)
AEA has a responsibility to present timely meeting notes and keep
stakeholders and agencies informed throughout the licensing process. A simple
“red line” or “tracked text changes” format for the Revised PSP would have
benefitted all participants. Mandatory conditioning agencies such as NYMS have
requested that AEA develop a system to facilitate the required transparency
required in the ILP:
“ AEA’s repeated failures to follow it’s own ILP meeting guidance, compromises
NMFS full participation in the ILP and harms the the process as a whole”
( James W. Balsinger, Ph. D., Admin., Alaska Div., NMFS )
2012 Study Results
TCCI has requested results of the 2012 studies from AEA to better inform
comments on PSP studies with interdependencies to results gathered this year and
which also dictate the scope and adequacy of 2013-14 studies. AEA’s inability to
present 2012 data in a transparent manner prior to the PSP Nov. 14 deadline is
unacceptable. Although these studies are not officially part of the FERC process,
their results will be incorporated into the 2013-2014 study scope.
Fish Distribution and Abundance Studies / Habitat Suitability
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
20121107-5006 FERC PDF (Unofficial) 11/7/2012 12:43:21 AM
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:
We, the TCCI, are concerned that the Department’s request did not indicate the need to study the
distribution and abundance of these species through their entire life cycle. Both the National Marine
Fisheries Service and the U.S. Fish and Wildlife Service filed study requests for anadromous fish for a
minimum of the life cycle of each species. According to the federal fisheries agencies, To characterize
the life history needs of a fish community would require at a minimum looking collectively at each
species through at least one life cycle. Chinook salmon, which are the longest lived salmon, typically live
5-7 years (for non-jacks) in the Susitna River drainage. Five years of study would only provide
information for one Chinook salmon return. Aside from being the second least studied salmon in the
Susitna River basin, Chinook salmon are also in a period of low abundance in the Susitna River basin and
statewide. (USFWS, Enclosure #13, p. 3; NMFS, pp. 50-51.)
Further, according to NMFS,
In periods of low abundance, fish may not occupy or use all suitable habitats, and in periods of high
abundance fish may be forced to occupy marginal habitats if habitat is limiting. Therefore, it is
important to understand the factors limiting their distribution and abundance by habitat, particularly
when developing habitat suitability models to evaluate potential project effects. (NMFS, p. 51.)
TCCI asserts that recent events including the 2012 low Susitna Chinook salmon returns and a series
of flooding events in 2006 and 2012, present inaccurate conditions for modeling accurate base line
data in the abbreviated study time frame. TCCI continues to support the federal agencies in their
request for more robust study periods for both anadromous and Susitna resident fish species.
According to the recent Alaska Chinook Salmon Conference / Knowledge Gaps and Needs:
“Chinook salmon are critically important to subsistence, commercial, and sport users across many
diverse fisheries in Alaska. Recent Alaska-wide downturns in productivity and abundance of Chinook
salmon stocks have created social and economic hardships across many communities in rural and
urban areas of Alaska. “
Further....” There is a significant need to AKF&G to.......identify actions that could be taken to lessen
the social and economic hardships being experienced by Alaskans that utilize and depend upon this
important natural resource”.
Abbreviated studies of the Susitna’s most important renewable resource thwarts this goal. Both
Goose Creek and Willow Creek have been identified by the State as Chinook stocks with “yields of
concern”. TCCI notes the proximity of both tributaries to the “middle river” Susitna-Watana study
area.
The Susitna River has been selected as one of the 12 Chinook indicator stocks to be examined.
Recommended research durations ranged from 3 year trawl cruises ( to study near shore abundance
and distribution of juvenile Chinook) to 4-5 year tracking of freshwater and marine survival rates.
Deshka River assessments identify Susitna Chinook ranging in age from 3-7 years but dominated by
20121107-5006 FERC PDF (Unofficial) 11/7/2012 12:43:21 AM
5 year old fish ( “although 4-6 year olds can predominate in some years”) This data supports a study
duration which more accurately reflects the Chinook life cycle.
Another goal for filling Susitna “knowledge gaps” in the data gap survey was to
“ estimate the number of smolt produced by each brood year. There is currently no program to
estimate smolt abundance”. This highlights how much is still unknown regarding such a critical
resource. The impacts of the proposed project operations will undoubtedly effect juveniles during
various life stages - some, like overwintering, can be difficult to model. These juveniles will be most
vulnerable to load-following operations. It is critical that the “Early Life History and Juvenile Fish
Distribution and Abundance in the Susitna River Study” meet all of the goals stated - most notably
stranding, freezing of redds, and scouring of redds.
It is concerning that many of the studies connected to the larger Distribution and Abundance Studies,
will only be run as “pilot” studies in 2013 and refined in the final 2014 period.
National and Regional Resource Valuation -
TCCI supports the study requests from agencies recommending valuation of resources - on both
regional and national levels.
AEA has responded that it “ is not providing a resource valuation because FERC does not require
monetary value be placed on fish and wildlife resources potentially affected by a proposed project”.
We urge AEA and FERC to reconsider resource valuation and the study requests of those agencies
who have stressed the relevance of methodology available. Public trust resources are at stake and
require valuation - if not monetary, than some form which represents resource importance to the
ecosystem at large. TCCI questions how correct PM&E can be assessed without valuating the losses
of specific resources such as fish or game.
(USFWS has requested resource valuation of non-salmon anadromous and resident fish resources )
Socio - Economic Studies -
TCCI requests broader socio-economic studies based on valuation of resource based local economies.
Although FERC does not require monetary valuation of resources under project effects, it must at
least identify those livelihoods which could potentially be affected by limited fish and wildlife.
Ice Process Studies
TCCI supports agencies need for longer study periods for ice studies.
(NMFS - Eric Rothwell 9/12/12 ) “The ice process modeling will need several years of data....I see lack of
time to collect data for models, calibrate the models, and the selections sites and methods to conduct ISF
studies to assess project effects on fish during winter operations under the currently proposed study
period”.
As noted in TCCI’s Scoping comments, the winter conditions of the Susitna River are of paramount
importance to the region’s fish and wildlife habitat as well as the safety and recreation of it’s residents.
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Riparian Studies
TCCI supports USFWS in it’s efforts to conduct thorough studies with the specific goals and objectives to
“characterize the water level regime required to maintain floodplain riparian plant communities.”
There is grave concern in the Northern Susitna region that changes in seasonal flows, daily flow regimes,
and groundwater effects could diminish riparian habitat. This vegetation is crucial for controlling erosion
to property owners and communities in the floodplain, as well as habitat for fish and wildlife. The
operations of the proposed project could have a devastating long range effect on Cottonwood populations
etc. which control riverbank structures.
Recreational Studies - i.e. “Flow Dependent Recreation”
TCCI is concerned that AEA has not involved the local Community Council’s in any of it’s 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.
TCCI supports NPS in expanding the recreational study area to the Lower River.
NOAA also supports the expansion of the study area below Talkeetna.
“Limiting downstream scope of the recreational and other studies to Talkeetna is unfounded” ( NPS -
Recreational study comments 8/12 )
To date, TCCI has not been given an opportunity to preview any of the SCORP, recreational “intercept
surveys”, or executive interview content. It is customary for local council’s to be points of contact for
statewide or regional surveys.
TCCI is disappointed to learn that AEA continues to “sell” their project under the guise of what should
be an unbiased survey by including project benefits that have yet to be determined ( i.e. suggesting 50%
of rail belt electricity will be generated before engineering and operations have been confirmed)
(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”
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.
Ice Related Recreation -
TCCI supports the inclusion of ice related recreation effects.
( NPS re. sec. 12 / Rec.) - “ There is no mention of impacts on recreation access and experiences due to
changed ice/ snow cover resulting from changed flow regimes”
More specifically, the current studies lack methodology for user experience other than a “preference
curve” for ice conditions. AS NPS notes in their comments -
“Unlikely that a preference curve can be developed for winter activities that require stable river ice...It
will either be present or not”.
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TCCI strongly agrees that 1 year of study is not enough to get an adequate sample size
“to support conclusions about important flow-dependent activities like sport-fishing, float hunting- NOTE
emergency Chinook closure” ( NPS )
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
Classic ski race and stable ice is required for both popular events.
Climate Change-
TCCI requests that AEA and FERC reconsider the study requests for climate change studies. Ambient
temperature changes affect glacial wasting, sediment transportation, water quality and water temperature.
Data being used from the 80’s does not reflect the current rising temperatures in the Susitna watershed.
Agencies who requested climate change studies noted relevant methodology and the use of such studies
currently used by Lower 48 utilities.
FERC has a responsibility to require analysis of cumulative conditions - science done by ignoring
relevant changes in baseline temperatures leads to an inaccurate record.
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20121107-5006 FERC PDF (Unofficial) 11/7/2012 12:43:21 AM
tel [907] 276.3133
fax [907] 276.2584
nature.org
The Nature Conservancy in Alaska
715 L Street, Suite 100
Anchorage, Alaska 99501
14 November 2012
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington DC 20426
RE: Susitna-Watana Hydroelectric Project NO. P-14241
I‟m writing on behalf of The Nature Conservancy in Alaska to comment on the Alaska Energy
Authority‟s (AEA) Proposed Study Plans (PSPs) and draft Revised Study Plans (RSPs) for the
Susitna-Watana Hydroelectric Project.
The mission of The Nature Conservancy is to conserve the lands and waters on which all life
depends. For over 50 years, we have pursued this mission by using best available science and a
pragmatic, non-confrontational approach to achieve conservation results. In Alaska, as
elsewhere, we have conducted rigorous biodiversity assessments to identify and prioritize areas
that – if managed to conserve key species – will ensure that Alaska‟s healthy ecosystems will be
passed on to future generations. In south-central Alaska, we work to conserve habitat for five
species of Pacific salmon in the Susitna and Matanuska Basins.
While the proposed hydroelectric project will be built 184 miles from the Susitna River mouth,
what occurs on the upper river has ramifications for the salmon systems downstream and the
salmon themselves as they migrate throughout the basin. We hope to see that the project will
develop in a way that maintains the natural variability of the hydrological processes of the
Susitna River that form spawning, rearing, and overwintering habitat for five species of Pacific
salmon; maintains adequate hydrological flows for adult salmon to migrate to spawning habitat
and for juvenile salmon to access rearing and overwintering habitat in the Susitna River and its
tributaries; and ensures the return of wild Pacific salmon to the Susitna River to continue their
keystone contribution to the aquatic, riparian, and terrestrial habitats that all species in the
Susitna River drainage, including humans, depend upon.
Given our programmatic emphasis on salmon conservation, we have focused our comments on
the study plans that relate to the river and its fisheries. Where available, our comments refer to
the draft RSPs that AEA has posted on its website; where RSPs were not provided, our
comments refer to the PSPs submitted in July. We highlight the following areas for
improvements to the study plans to adequately understand the impacts of this project on the
Susitna River and the habitat that it provides for five species of Pacific salmon.
Integration of Studies to Understand Project Impacts
AEA has proposed a large number of studies of varying complexity and interrelationship. While
interdependency flow charts in many study plans show how multiple studies are related, these
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charts do not clarify how or when data and information will be shared. It is unclear that
information can be integrated into related and subsequent studies within the short time frame of
the study period. The use of 2012 studies in the RSPs is also not clear. In addition, it is not clear
how the studies will be synthesized collectively to answer questions about project impacts to
salmon and salmon habitat and to inform AEA on project design and operation. We suggest that
the Revised Study Plan include a comprehensive process description and timeline for sharing
information between studies, integrating studies, and synthesizing overall results.
Climate Change
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 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.
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
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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.
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.
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.
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.
Late fall flooding this year also brings into question AEA‟s ability to complete complex studies
of a complex system under conditions that make field studies difficult in years with typical
weather conditions. Such extreme events as seen this last year with high snow pack, high spring
runoff, and fall flooding may have effects that skew results from most studies about salmon and
their habitat when only two or three field seasons are employed.
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The horizon of these study plans must look beyond the 50-year licensing period of FERC. The
impacts of the dam can be expected to accumulate over multiple generations of salmon, decades
of changes to human use of the landscape, and the continued alterations from climate change.
The full impact of this project is likely to be seen after 50 years and it is highly unlikely that the
dam will not exist in 50 years.
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.
We are currently undertaking a project to value ecosystem services throughout the Matanuska-
Susitna Borough with the Institute of Social and Economic Research (ISER) at the University of
Alaska Anchorage and with Earth Economics, a consultant in Tacoma, Washington. Our project
has two components which relate directly to the Social Conditions and Public Goods and
Services Study (15.6). First, ISER is developing primary data for the Mat-Su based on
household surveys to find out how residents value the natural places around them. Second, Earth
Economics is using Benefit Transfer Method to value ecosystem services based on studies in
similar geographies. These two components are grounded in well-established methods of
ecosystem services valuation. While valuation does not result in precise figures of economic
value, it does provide an opportunity to compare economic costs and benefits for the project,
including power generations, infrastructure costs, and impacts to local economies and
communities. Ecosystem service valuation provides FERC with information for fulfilling the
requirement under the amended Federal Power Act of 1986 to give equal consideration to non-
power values when deciding to license a hydropower project. We are available to talk with AEA
about our study and how it might better inform the economic studies of this project.
We have a few specific comments about the Regional Economic Evaluation Study (15.5) and the
Social Conditions and Public Goods and Services Study (15.6):
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.
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
20121115-5029 FERC PDF (Unofficial) 11/14/2012 6:04:03 PM
The Nature Conservancy
Page 5 of 6
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.
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.
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.
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?
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.
Thank you for the opportunity to comment on the proposed and revised study plans for the
Susitna-Watana Hydroelectric Project. Please contact me if you have any questions.
Sincerely,
Corinne Smith
Mat-Su Basin Program Director
ecc: Wayne Dyok, AEA
Joe Klein, ADF&G
Monte Miller, ADF&G
Eric Rothwell, NMFS
Sue Walker, NMFS
Ann Rappoport, USFWS
Mike Buntjer, USFWS
Bill Rice, USFWS
20121115-5029 FERC PDF (Unofficial) 11/14/2012 6:04:03 PM
The Nature Conservancy
Page 6 of 6
Cassie Thomas, NPS
Matthew LaCroix, EPA
Jeff Davis, ARRI
Jan Konigsberg, Hydropower Reform Coalition
Richard Leo, Coalition for Susitna Dam Alternatives
Randy Hagenstein, The Nature Conservancy
Dave Albert, The Nature Conservancy
20121115-5029 FERC PDF (Unofficial) 11/14/2012 6:04:03 PM
Document Content(s)
TNC Comment on SuHydro PSP 12Nov14.PDF................................1-6
20121115-5029 FERC PDF (Unofficial) 11/14/2012 6:04:03 PM
Talkeetna Defense Fund, Talkeetna, AK.
PO Box 292
Talkeetna, AK 99676
November 13, 2012
Honorable Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C. 20426
Comments for the proposed Susitna-Watana Hydroelectric Project No.14241-000
Proposed Study Plans and Draft Revised Study Plans
Dear Secretary Bose:
We are submitting these comments on behalf of the Talkeetna Defense Fund; a
group established in the spring of 2009, whose purpose is:
To provide financial assistance that may be needed to maintain and sustain the
quality of life of Talkeetna as outlined in the Talkeetna Comprehensive Land
Plan (1999 edition), or any other similar documented management guidelines of
protective criteria deemed important by the…board of five. The areas of focus
include Talkeetna, the greater Talkeetna area, or those areas in the Susitna
River Valley or the State of Alaska where issues arise that may pose a threat to
the quality of life, character, or environment of Talkeetna.
Here are our major concerns about AEA’s Proposed Study Plans:
The allotted time for most studies of two years of study time is not adequate
for many reasons, perhaps the most important being that salmon life cycles are
three times longer than this. Related to this, we see the Integrated Licensing
Process as the wrong choice for licensing a new dam that would be the largest
built in the nation in decades and the only dam sited in this far north where
impacts will be different than for dams in the contiguous United States.
AEA’s inability to present data from the studies already undertaken (2012) is
unacceptable and throws doubt on how transparent the agency will be with further
study results. It is imperative that data be readily available to the public,
and for peer review.
The question of how winter ice conditions would be impacted by the proposed dam
requires serious consideration and study. Again, this dam would be unique in
its location in a subarctic climate, so there is little or no data from other
dams to pull from. Potential impacts are not trivial for this area. People
depend on Susitna River ice for winter transportation by dogsled, snowmachine
and ski; animals also depend on safe river ice for winter migrations. The dam’s
winter impacts could seriously damage our seasonal commercial, sport fishing,
and subsistence fisheries, with concomitant economic loss.
Finally, National and Regional Resource Valuation should be conducted! The
Susitna watershed is a national treasure. This study to define the value of a
free flowing vs. dammed Susitna has been rejected by AEA; we are adding our
voice to the many who see this as a critical study. The Federal Power Act
requires that equal consideration be given to non-power values of the river
system. Because this river is important locally but is also at the heart of one
20121114-5010 FERC PDF (Unofficial) 11/14/2012 12:23:18 AM
of Alaska’s most-visited tourist areas, valuation studies should be done for
both a local and national constituency.
Thank you for your consideration of our comments.
Sincerely,
Ellen Wolf
Board Secretary
Talkeetna Defense Fund
20121114-5010 FERC PDF (Unofficial) 11/14/2012 12:23:18 AM
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20121114-5010 FERC PDF (Unofficial) 11/14/2012 12:23:18 AM
Jennifer Barnett, Talkeetna, AK.
I oppose the Susitna dam and I think AEA's Proposed Study Plans are not adequate
for understanding the impacts the dam would have on a river system as
biologically rich and complex as the Susitna.
Two years of study is not enough. There has never been a dam so massive,
built so far north, on a river so large. Even the agencies studying the extent
of the dam's impacts and risks say that only two study years cannot return a
full understanding of what would happen if the dam is built. For instance, with
the Susitna running at much reduced summer flows, the Chulitna could push the
main stem of the Susitna toward Talkeetna. What is the likelihood of this, and
what would the impacts of increased erosion be on the town of Talkeetna? Also,
what impacts would the changes in Susitna River water flows have on the five
species of salmon? The life cycle of a Chinook salmon is five to seven years. A
comprehensive, meaningful study that confidently predicts the potential effects
of a dam of this nature on Susitna River salmon simply cannot be conducted in
two years.
Winter water flows are planned to fluctuate across the day, at times
reaching four times average flows. This would make river ice unstable, making
travel dangerous, or even impossible, for both humans (snowmachine, dogsled or
ski) and animals (moose and caribou). It would disrupt winter habitat of
juvenile salmon in the main river, for example by removing still pools where
they would normally rest, making their survival difficult at best and impossible
at worst.
Studies from the early 80's are being used to speed the process, but the
climate of the Susitna Valley has changed dramatically in 30 years, averaging 4
to 5 degrees warmer. Many of the old studies are no longer accurate for today's
conditions. In addition, there are much more sophisticated data collection and
computer modeling techniques that were not available 30 years ago. But still AEA
is insisting that they can use those old studies to... speed the process.
A National Valuation Study has been dismissed by AEA, but the impacts of the
dam should be considered from a national level, not just Alaskan. A free-
flowing Susitna River has value to Alaskans and all Americans. Formally called a
National-Level Economic Valuation Study, this study would fully explore and
define the cost/benefit, loss/reward of the national value of a free flowing
river versus a dammed river, including costs to such factors as recreation,
aesthetics, and culture. FERC is a national agency. The value of an intact
Susitna watershed should be considered on a national scale.
All data should be transparent and available to the public, and it must be
peer reviewed. AEA has not made any of this summer's study data available.
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Donnie Billington, Talkeetna, AK.
I was unable to access your website in order to send copies of my comments to
AEA concerning transportation access. Below is a copy of that comment.
P.O. Box 56
Talkeetna, AK 99676
10-11-12
AEA
susitnawatana@aidea.org
To Whom It May Concern:
RE: Draft Watana Transportation Access Analysis
I would like for it to become a part of public record that I am opposed to all
of your proposed routes for road construction and transmission lines. I am
also opposed to all of your proposed runway/airport possibilities. All of the
options would impact the entire area in a negative way.
I have hunted in that area since 1970. Construction in that area would impact
caribou migration/calving, moose habitat and calving, fishing, berry picking and
all of the traditional/subsistence activities that take place. Traditional
Native land use would be impacted. Subsistence is a big part of Alaskan life
and this proposed project would adversely affect the residents’ abilities to
feed their families.
The state of Alaska would be better off with a number smaller, less destructive
projects, instead of a mega project that would destroy the entire ecosystem of
South Central Alaska.
Sincerely,
Don Billington
907-733-2578
in care of: cathyt@mtaonline.net
(I do not do email...I live off the grid)
20121113-5299 FERC PDF (Unofficial) 11/13/2012 1:45:10 PM
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20121113-5299 FERC PDF (Unofficial) 11/13/2012 1:45:10 PM
Donnie Billington, Talkeetna, AK.
P.O. Box 56
Talkeetna, AK 99676
November 9, 2012
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, N. E., Room 1A
Washington, DC 20426
RE: Susitna-Watana Hydroelectric Project No. 14241-000
Thank you for the opportunity to comment on AEA’s study plan for the proposed
Susitna-Watana Hydroelectric Project No. 14241-000.
1. It is ridiculous to only have studies for a two year period involving a dam
of this magnitude. This dam would impact 5 species of salmon and other species,
such as burbot, grayling, rainbows, dollies, etc. Two years of study is
inadequate to study the life cycles of Chinook salmon, which is 5 to 7 years.
Not enough information could be obtained in a two year period to determine how
Chinooks would be affected.
2. There would be impacts on the Susitna River as a travel corridor for people
and wildlife due to unstable ice resulting from fluctuating flow.
3. There would be impacts on traditional recreational activities such as
snowshoeing, skiing, snowmachining, and dog sledding due to unstable ice
resulting from fluctuating flow.
4. The studies from the ’80’s are no longer appropriate, as the climate of the
upper Susitna Valley has changed since then, warming 4 or 5 degrees. What
impacts would a huge reservoir of water have on the climate of the region and
how would that impact the entire ecosystem? Using the old studies to speed up
the process is inappropriate and would not produce reliable answers to important
questions. It is painfully obvious that AEA wants to fast track this process
and not even begin to do adequate studies. They are not looking at any other
viable options. More smaller projects would be much more sensible than one mega
project where all your money is put into one project. This is insane. Mother
nature could throw us another 9.7 quake like we had in ’64. Who is to say
whether or not that was the big one. Events like hurricane Sandy come along
and humble us. No engineer can make any project bullet proof. It is not worth
the risk.
5. AEA hasn’t agreed to a National Valuation Study. I want to know why. This
region is a national treasure, visited by countless people from all over the
United States and all over the world. The reason they come here is that the
Susitna is a wild river. This would forever be changed if the project goes
forward. You can’t take it back. Everyone benefits from the jobs produced by
the Susitna, the recreation it provides, and the food it provides. The
economics of tourism must be considered. Dams across the lower 48 are being
dismantled at huge costs. There are less expensive ways to generate power,
financially and environmentally. This is the most financially and
environmentally irresponsible proposal that I have ever seen. The cost of
20121113-5005 FERC PDF (Unofficial) 11/9/2012 10:35:20 PM
building the dam and the small amount power it would provide would be
prohibitive. The Susitna is worth much more to our nation as is.
6. This project would completely disrupt the subsistence lifestyles of the
indigenous people and others who live in the region. This is traditional use
and it should be honored.
7. AEA has not made any of the data they obtained from studies this summer
available to the public. Why not?
Thank you for allowing us more time to comment.
Sincerely,
Donnie Billington
in care of: cathyt@mtaonline.net
907-733-2578
20121113-5005 FERC PDF (Unofficial) 11/9/2012 10:35:20 PM
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will boardman, Talkeetna, AK.
As a resident of the upper Susitna Valley I am opposed to the building of the
Susitna-Watana Hydroelectric project due to its large cost, and unforeseen
ecological impacts. Electricity is currently the most inexpensive utility bill
I pay each month and when the costs of building the dam are considered the newly
generated electricity is to costly.
The ecological impacts on the area are to great. While great care may be taken
to mitigate these concerns there is no substitute for a natural free flowing
river. Areas like the Upper Susitna are what make Alaska unique and draw people
to this great state.
I believe the Susitna-Watana Dam to be the wrong direction for Alaska's future
energy needs. Please leave the Susitna River free of dams for future
generations.
Thank you,
Will Boardman
20121113-5018 FERC PDF (Unofficial) 11/12/2012 12:50:29 PM
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20121113-5018 FERC PDF (Unofficial) 11/12/2012 12:50:29 PM
Greg Campbell, Talkeetna, AK.
First of all, I strongly oppose the dam on the Susitna River here in Alaska.
Secondly, I believe AEA’s study plan is not sufficient to understand the impacts
of this huge dam. The Susitna is a complex ecosystem and river, and there needs
to be more rigorous studies to determine the true impact. More time needs to be
spent, 5 years at a minimum.
I am very concerned that the timeline for these studies has been sped up to
force the project through, and that accurate results cannot be obtained in this
short timeline. 5 years would be the minimum time period to understand complex
issues such as Salmon life cycles and impacts.
I would like to see the results of impacts of dams on other rivers in this
study. This is not the first dam to be constructed on a river with Salmon. I
think it is important to see what has happened to Salmon populations on these
other rivers, as well as impacts to recreation, loss of free flowing rivers,
etc. AEA has used known positive outcomes of dams in other places, such as
electricity generation, in their FERC filings to justify the construction of
this dam. Since they have used this evidence to justify their project it is
only fair to include negative impacts of dams from other dams, such as loss of
Salmon populations.
I am very concerned that results of studies done in the 1980’s are being used in
order to speed up the process. Much has changed since the 1980’s in science as
well as the climate of the area. Science has made great leaps and bounds in the
last 30 years, and we cannot use old data to make accurate conclusions. We now
have powerful computer modeling techniques that were not available 30 years ago,
data collection has become more sophisticated, and new study techniques have
been invented. In addition, the climate of the Susitna Valley has changed in the
past 30 years, making the results of studies done 30 years ago somewhat
irrelevant to our current situation.
A National Valuation Study has been dismissed by AEA, but the impacts of the dam
should be considered from a national level, not just Alaskan. FERC is a
national agency, and should be evaluating this project in national terms. This
dam will be built in America, and will impact all Americans, so it should be
looked at with an eye towards national values. Some of these values are the
value of a free flowing river of this size versus a damned river, and include
values such as recreation, scenery, and culture.
Winter impacts of this dam need to be studied better. Fluctuations in winter
river levels will impact ice formation, and these impacts will be felt by
wildlife trying to use the river ice for transportation as well as recreational
users such as snow machiners and skiers. This needs further rigorous study.
I firmly insist that all data be made available to the public in a timely
manner, and that this data and all conclusions go through a peer review process.
In order to have accurate scientific results we need to follow scientific
methods The cornerstone of science is peer review and transparency.
In conclusion, I strongly oppose the dam. I also believe that the study plan
proposed by AEA for this project is not sufficient to understand this complex
river, and that 5 years should be the minimum study period.
20121113-5012 FERC PDF (Unofficial) 11/11/2012 9:32:57 AM
20121113-5012 FERC PDF (Unofficial) 11/11/2012 9:32:57 AM
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20121113-5012 FERC PDF (Unofficial) 11/11/2012 9:32:57 AM
Shelly Campbell, Talkeenta, AK.
I strongly oppose the dam on the Susitna River here in Alaska.
AEA’s study plan is not sufficient to understand the impacts of this huge dam.
The Susitna is a complex ecosystem and river, and there needs to be more
rigorous studies to determine the true impact. More time needs to be spent, 5
years at a minimum.
I am very concerned that the timeline for these studies has been sped up to
force the project through, and that accurate results cannot be obtained in this
short timeline. 5 years would be the minimum time period to understand complex
issues such as Salmon life cycles and impacts.
I would like to see the results of impacts of dams on other rivers in this
study. This is not the first dam to be constructed on a river with Salmon. I
think it is important to see what has happened to Salmon populations on these
other rivers, as well as impacts to recreation, loss of free flowing rivers,
etc. AEA has used known positive outcomes of dams in other places, such as
electricity generation, in their FERC filings to justify the construction of
this dam. Since they have used this evidence to justify their project it is
only fair to include negative impacts of dams from other dams, such as loss of
Salmon populations.
I am very concerned that results of studies done in the 1980’s are being used in
order to speed up the process. Much has changed since the 1980’s in science as
well as the climate of the area. Science has made great leaps and bounds in the
last 30 years, and we cannot use old data to make accurate conclusions. We now
have powerful computer modeling techniques that were not available 30 years ago,
data collection has become more sophisticated, and new study techniques have
been invented. In addition, the climate of the Susitna Valley has changed in the
past 30 years, making the results of studies done 30 years ago somewhat
irrelevant to our current situation.
A National Valuation Study has been dismissed by AEA, but the impacts of the dam
should be considered from a national level, not just Alaskan. FERC is a
national agency, and should be evaluating this project in national terms. This
dam will be built in America, and will impact all Americans, so it should be
looked at with an eye towards national values. Some of these values are the
value of a free flowing river of this size versus a damned river, and include
values such as recreation, scenery, and culture.
Winter impacts of this dam need to be studied better. Fluctuations in winter
river levels will impact ice formation, and these impacts will be felt by
wildlife trying to use the river ice for transportation as well as recreational
users such as snow machiners and skiers. This needs further rigorous study.
I firmly insist that all data be made available to the public in a timely
manner, and that this data and all conclusions go through a peer review process.
In order to have accurate scientific results we need to follow scientific
methods The cornerstone of science is peer review and transparency.
In conclusion, I strongly oppose the dam. I also believe that the study plan
proposed by AEA for this project is not sufficient to understand this complex
river, and that 5 years should be the minimum study period.
20121114-5000 FERC PDF (Unofficial) 11/13/2012 5:27:15 PM
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pg. 1
COALITION FOR SUSITNA DAM ALTERNATIVES
PO BOX 32O, TALKEETNA AK 99676
SUSITNADAMALTERNATIVES@GMAIL.COM
November 5, 2012
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington DC 20426
Subject:Comments on Alaska Energy Authority Proposed Study Plan (PSP)
& Draft Revised Study Plans for the Proposed Susitna-Watana
Hydroelectric Project P-14241-000
Dear Ms. Bose:
The Coalition for Susitna Dam Alternatives (CSDA) is a non-profit corporation
whose mission is to facilitate awareness of alternatives to the Proposal through
stakeholder processes, education, and advocacy. CSDA is dedicated to
research and communication of the state and federal public processes that
involve the licensing and construction of this Proposal.
These studies are being done by the applicant, the Alaska Energy Authority
(AEA) in order for the Federal Energy Regulatory Commission (FERC) to develop
the Environmental Impact Statement and to evaluate license approval and
conditions. The goals of the studies are to develop adequate information about
the existing environment in order to analyze project impacts.
Two Years of Study are Not Enough
The impacts of large dams are extremely complex and difficult to predict. But
AEA and FERC say they will complete all analyses in two years of studies. This is in
spite of official agency and numerous stakeholder objections that the two year
Integrated Licensing Process (ILP) time frame is not appropriate for an important
world class salmon producing river that communities depend upon for their
livelihoods and food.
CSDA surmises that the ILP licensing process was picked due to the short study
plan time frame which fits in with the current state administration’s political goal
20121107-5091 FERC PDF (Unofficial) 11/7/2012 2:56:10 PM
pg. 2
to fast track the project. The ILP was created by FERC for the purposes of
relicensing dam projects and is inadequate for an original project on a free
flowing river with such diverse, complex and interrelated resources.
The ILP is forcing many processes to occur at one time. This has resulted in limited
and less than thorough public comments. For instance, May 31, 2012 was the
comment deadline for the Preliminary Application Document (PAD), the
Scoping Document 1(SD1) and Study Requests. The National Marine Fisheries
Service (NMFS) and the US Fish and Wildlife Service (USFWS) both commented
that since the time frame was so limited, the agencies had to concentrate on
the development of the study requests so that comments on the PAD and the
SD1 were cursory. Furthermore, the agencies and stakeholders did not have
adequate time to thoroughly review to develop the 2012 pre-licensing studies.
The 2012 pre-licensing study results are to inform the development, modification,
and expansion of the official 2013/2014 ILP studies. However, due to the ILP
schedule, the 2012 published results and analysis will not happen before the ILP
study plan process is finalized. Some of the 2013 ILP studies will have started.
The PSP is a massive scientific endeavor of 58 studies. The data from certain
studies provides the framework for other studies. This means that coordination is
essential—and lacking. For instance, the Integrated Resource Analysis which is a
schematic document of “Study Interdependencies for Fish and Aquatic
Instream Flow” show spaghetti-like line flow charts virtually impossible to read. In
essence, this is a very complicated “scientific” process.
This further points to the fast pace of the study plan process. It is antithetical to
good science. Full information disclosure to all stakeholders including state and
federal agencies to make responsible comment and fulfilling state and federal
laws is thus limited.
Besides the fact that the 2012 published reports will not be done before the ILP
Study Plan comment periods occur and the 2013 ILP studies begin, the agencies
do not have the time to comment on the draft Revised Study Plans dated
October 31, 2012 for the November 14 comment period. These draft plans are a
result of Technical Work Group meetings. This is poor planning. Once again the
agencies and the public are being driven by an ILP time frame that makes
adequate, responsible scientific evaluation difficult.
It is highly questionable whether the two year ILP studies will legally fulfill state
policy under AS 46.03.010(a) “to conserve, improve, and protect its natural
resources and environment and control water, land, and air pollution, in order to
enhance the health, safety and welfare of the people of the state and their
20121107-5091 FERC PDF (Unofficial) 11/7/2012 2:56:10 PM
pg. 3
overall economic and social well being.” These studies determine how our
public trust resources will be impacted by a massive development project.
Some Specifics
The first year of a study is at a feasibility and reconnaissance level to determine
and refine sampling methodologies. This limits the availability and interpretation
of study results if there are only two years. For instance, if there are no low water
years or no average water years, there would be no baseline information or
inter-annual variability.
The majority of the Susitna River Watershed is remote which makes access
difficult. Severe weather and wildlife issues during all the seasons can hamper or
delay field activities.
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.
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 Aquatic
Resources.
Instream Flow Studies should be developed over a temporal scale of five
years. This is in order to encompass a representative time frame.
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.
Two years are not enough for the Ice Processes Study.
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.
A minimum of 2 years is needed to establish the site-specific Habitat
Suitability Index (HIS) curves needed for all target fish species.
20121107-5091 FERC PDF (Unofficial) 11/7/2012 2:56:10 PM
pg. 4
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.
Regarding the proposed access routes’ stream crossings, USFWS
recommends a minimum of 3 years of onsite stream gage data.1
Biometric Review of the 1980’s Susitna Hydroelectric Project Studies
A biometric review study is a statistical analysis of biological observations and
phenomena. The USFWS first asked for this analysis in a 12/20/11 letter to AEA
and in their 5/31/12 PAD, SD1, and Study Request comments. The National
Marine Fisheries Service (NMFS) concurred with this request in their own 5/31/12
comments.
Historic and contemporary studies of the Susitna River watershed have not been
comprehensively synthesized. This should have been done in the PAD. Many of
the 1980’s studies have not been made available electronically to the resource
agencies or the public.
A biometric review should have been conducted prior to basing any current
study plans on the 1980’s studies and the results. The review would estimate the
precision and accuracy of the study results and is necessary to determine the
scientific validity. The statistical validity of the results is unknown now. This is
considered a minimum recommendation in order to satisfy concerns about the
assumptions, relevance and applicability of 30 year old studies conducted for a
very different proposal in such a dynamic watershed. An important concern is
that climate change has altered many of the baseline measures from those
studies. The older studies did not consider climate change. Alaska is in the front
line of climate change impacts.
But a biometric study has not been supported by AEA. This is in spite of the fact
that many of the draft RSPs are using data from the 1980’s studies. For instance,
in the Ice Processes Study, AEA consultants are counting on the 1979-1985 data
from the 1980’s studies to complement the 2 year proposed study.
The National-Level Economic Valuation Study Request
1 October 15, 2012 USFWS letter to AEA re: Susitna-Watana Hydroelectric Project Draft Watana Transportation
Access Analysis, “For larger projects such as the Susitna-Watana Dam, the Service recommends estimating peak
discharge for each stream to be crossed by correlating a minimum of three years of onsite stream gage data with
the installation of nearby long-term stream gages.”
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pg. 5
AEA has rejected this study request. Eleven Non-Governmental
Organizations2and several individuals requested this. This study would fully
explore and define the cost/benefit, loss/reward of the value of a free flowing
river versus a dammed Susitna River. It would establish a framework by which this
megaproject’s value to the nation can be weighed.
We request that FERC accept this study in order to carry out their mandate
under the Federal Power Act as amended in 1986 to give equal consideration to
non-power values of a river system. The FERC licensing action is a federal action,
and the relevant population for this action is the national population. This is a
more rigorous implementation of non-power values into the net benefit
calculations.
The scale of the project proposal is unprecedented at this latitude with the
many unique challenges due to climate change, seismic potential and lack of
access due to the remote nature of the watershed.
The Susitna River watershed economies go beyond the constituencies of
Alaskan regional populations. People from all over the US and the world visit,
recreate, hunt, and fish in the watershed. The Susitna River is a national treasure.
The value of the Susitna River wild salmon populations and their unique genetic
diversity is enormous and of national importance.
This study is an important tool for establishing credible information and analysis
into the national public interest in conserving an important free flowing river and
for equal consideration to the non-power uses. This river is a national public trust
resource.
The NMFS supports this study.
NMFS recommends FERC expand socioeconomic analysis for this project
and design and conduct an economic valuation study…the
socioeconomic values, market based and non-market/non-use,
associated with the status quo condition must be fully assessed, at local,
regional, and national levels, so that impacts of the alternatives on the
status quo condition can be properly assessed. What this means is that the
analysis must create a comprehensive socioeconomic baseline of pre-
impact values and compare them with projected post-impact values to
determine the “cost” of the action in terms of socioeconomics effects.
2 These were National Heritage Institute, American Whitewater, Alaska Center for the Environment, Alaska
Survival, Coalition for Susitna Dam Alternatives, Center for Water Advocacy, Cook Inletkeeper, National Wildlife
Federation, Alaska Chapter Sierra Club, Talkeetna Community Council, Inc., Talkeetna Defense Fund.
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pg. 6
NMFS recognizes that the proposed action does not promulgate a federal
regulation and, thus, is not subject to the guidance of Executive Order
(EO) 12866 regarding analysis of socioeconomic impacts of regulatory
actions. However, the new license will have a 50-year life and the project
will have impacts on public welfare at a national level of significance as
well as local level. Thus, NMFS recommends that the analysis of
socioeconomic impacts conform to the requirements of EO 12866.
Specifically, the cost benefit framework is the appropriate methodology
for evaluating the proposed action; however, disparate valuation
methods, some qualitative, will prevent complete monetization of all the
costs and benefits. A well informed qualitative assessment of impacts that
cannot be monetized is also critical to the assessment of potential
socioeconomic impacts. Further, this analysis should consider “all costs
and benefits” of the proposed project, which means consideration of
regional economic impacts, including economic multiplier effects, as well
as national level impacts on economic welfare.3
AEA’s reasons for rejecting a National-Level Economic Valuation study are
without merit. Their proposed socioeconomic study proposals are narrowly
confined to regional populations only.
Ecosystem Functioning Changes from Project Impacts
The May 31, 2012 FERC Office of Energy Projects letter to AEA regarding the PSP
discusses the concerns regarding the relationship between the Wildlife
Resources Investigations and the application to project impacts on the
ecosystem. CSDA also has this concern.
AEA’s fish and wildlife studies are designed to get information about species’
habitats, their distribution and their population numbers. Such data would also
establish baseline environmental conditions for the species. But we are
concerned that there are not adequate impact assessment analyses to
understand the ecological role that species have in the ecosystem. At this point,
it appears that species’ ecological role will be based on literature searches and
not on field work. This is not sufficient.
For instance, it is important to understand how dependent the riparian
vegetation in various drainages is on the marine-derived nutrients from the
carcasses of salmon and non-salmon anadromous species. Another example is
3 Pages 6-7, Enclosure 1 of May 31, 2012 Comments of the National Marine Fisheries Service on the Pre-
Application Document, Scoping Document 1, Study Requests for the Susitna-Watana Hydropower Project P-14241-
000.
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pg. 7
that there are significant predator/prey dynamics when fish move out of the
mainstem river into the tributaries and sloughs. It is important to understand this
in order to understand project impacts.
There needs to be knowledge of complex ecological relationships between fish,
wildlife, and vegetation from field studies. Without this knowledge, project
impacts will likely be underestimated especially over a long period of time. This
means the project benefits could be overestimated. FERC should NOT be
satisfied with literature searches only for ecosystem functioning changes.
Beyond project impacts, this information is necessary for the establishment of
FERC licensing conditions that guarantee the existence of the natural conditions
of the Susitna River watershed in order to have healthy fish, wildlife, and
hydrologic resources.
ILP Study Data
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.
The Glacial and Runoff Changes Study
The study goals are to analyze and predict the effects of glacier wastage and
retreat and non-glacier hydrological processes on the hydrology and the
sediment delivery to the proposed reservoir upstream of the dam site as a result
of climate change. In other words, this would be to predict the amount of water
and sediment that will be in the reservoir up until the year 2100. This is the only
study that deals with climate change impacts on the project area.
This study does NOT fulfill the study requests of NMFS and USFWS “Project Effects
under Changing Climate Conditions.” We support the agencies’ climate
change study requests and urge FERC to consider this. FERC has not accepted
climate change studies in their relicensing activities due to concerns about the
utility, accuracy, and uncertainty of climate projections. However, the recent
advances in climate science should answer FERC’s concerns. Indeed, the
advances in climate change modeling will be used in this study by AEA, but it is
only to be applied to the upper basin above River Mile 184. The study goals
need to be expanded to impacts on the total Susitna River ecosystem. It is
imperative to have temperature and hydrological data due to climate change
in order to have responsible comprehensive decision making regarding project
impacts on fish, wildlife and their habitats.
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pg. 8
The Susitna River watershed is an area vulnerable to climate change. In fact, the
average temperature of the Susitna Valley has increased 4.5 degrees F since the
early 1980’s when prior studies were done. There has to be climate change data
beyond the current study parameters.
Socioeconomic Resources Studies
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. This study does not mention this as
a goal. Ecosystem Services are benefits to society, public goods that include
wildlife habitat and biodiversity, watershed services, carbon storage, scenic
landscape and other natural assets.
Federal agencies such as the US Forest Service and the US Environmental
Protection Agency have accepted the reality of Ecosystem Services and have
promoted such in their programs. EPA’s Healthy Watershed Initiative recognizes
that maintaining the integrity of natural biological systems provides economic
benefits. Degradation of riparian ecosystems can cause negative economic
impacts far from the altered site. For instance, society has found that major
forests are dying off downriver of dams due to low groundwater. Project impacts
on Susitna River forests need to be evaluated because those forests perform
important functions in the ecosystem.
Yes, assigning a monetary value can be a challenge and can be complicated,
but there are methods.
Payment for Ecosystem Services (PES) program that compensate
landowners for conserving land
Citizens Willingness to Pay (WTP) to use or protect land area or ecosystem
services.
Cost Avoidance Scenarios which estimates the avoided costs to society
due to protection of resources.4
Ecosystem Service baseline data is needed to quantify the changes in these
ecological functions due to the changes in the Susitna River ecosystem from
project effects. Will this project compromise the ability of future generations to
meet their needs in light of project effects on river hydrology, plant biodiversity,
aquatic and terrestrial resources?
4 EPA 841-N-12-004
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pg. 9
Also missing from both this study and the Regional Economic Evaluation Study
are the socioeconomic impacts to the area by the very implementation of
these ILP studies. The study emphasizes the goal of assessing community impacts
from workers in the construction phase only. The implementation of these studies
means increase in population, increase in river and air transportation and
effects on lodging. Last summer, the impacts from the 2012 pre-licensing studies
had an estimated ten-fold increase in noise and emissions from increased boat,
fixed wing, and helicopter traffic. It will increase even more in the next two
years.
Comprehensive Evaluation of Green House Gas (GHG) Emissions as a project
effect
There is no indication that this is being considered in any of the studies. Certainly
it is not being addressed in the Air Quality Study.
Hydroelectric dams produce significant amounts of the GHG carbon dioxide
and methane. Dams are not carbon neutral. In some cases, the dams produce
more GHG than power plants running on fossil fuels. Within the last decade, the
GHG dynamics in hydroelectric reservoirs have become the topic of increased
awareness and interest with a need for more complete studies.
GHG’s are produced from the decaying, inundated organic materials in the
reservoir. To be specific, they are produced by direct flux across air-water
interfaces at surface water level, turbulent exchange with the atmosphere
immediately downstream of the hydroelectric turbines, and flux across the air-
water interface in the river outflow downstream of the reservoir. Methane can
be transported by either diffusion or ebullition to the atmosphere. Methane can
also be oxidized in the water column and emitted as carbon dioxide.5
Another source of GHG emissions is thawing permafrost. According to the AEA’s
PAD, permafrost conditions exist to a depth of 120 feet on the south abutment
of the dam and up to 60 feet on the north abutment.
Also the draft Watana Transportation Access Analysis assumes the majority of
the ground in each of the proposed access and transmission line alignments is
permafrost. As permafrost thaws, the bacterial breakdown of the organic
material will either be carbon dioxide under aerated conditions or methane
5 Barros_et_al_NatGeo.pdf, Nature Geoscience 7/31/11
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pg. 10
when oxygen is limited. Well-known scientific data is emerging presently about
this climate change factor in Alaska and the Arctic in general.
This project is being touted as a renewable resource with no GHG emissions. This
needs to be proved.
General Geology Studies Comments
Many of these proposals lack specifics. Most of the geology and soil studies
proposed are dam-site specific, rather than addressing the whole reservoir
area. There is an over-reliance on the geologic data that were gathered prior
to 1985. Without ability to review that data, it is difficult to address what needs
to be further studied.
The studies that were done in the summer of 2012 and those proposed in the
next two field seasons are not detailed.
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.
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.
4. GEOLOGY AND SOILS
This study plan will review the existing information on the Susitna-Watana Project
(Project) area regarding geology and soils and gather additional information in
order to define the geologic, geotechnical, seismic, and foundation conditions
at the sites of Project works (e.g., dam, reservoir, access road, construction
camps, and materials borrow sites).The study appears to be confined to the
immediate area of dam construction and access road only. This information will
be used to support development of the Project design, with an emphasis on
minimizing risks to dam safety. In general, the study tasks will include field
investigations, laboratory testing, review of existing studies, and engineering
analyses to characterize site conditions, limitations, and constraints. The study will
also identify impacts of Project construction and operation, such as soil erosion
along the reservoir rim, slope stability, excavation, and spoil disposal,
on environmental resources (e.g., oil, gas, and minerals). This sentence doesn’t
make sense with parenthetical phrase.
4.2. Nexus Between Project Construction / Existence / Operations
and Effects on Resources to be Studied
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pg. 11
· Sediment load contributions due to glacial melt and possible surging glacier
event The 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.
4.5. Geology and Soils Characterization Study
4.5.1. General Description of the Proposed Study
The general objectives of the study plan are to:
· identify the existing soil and geologic features at the proposed construction
site; 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 sediment into the
reservoir, especially during any seismic activity.
The field investigation activities for each season will be coordinated with
resource agencies, ANCSA Corporation landowners. A Geotechnical
Exploration Program Work Plan (Work Plan) will be developed which outlines the
field program information that will be needed for submitting applications and
obtaining land access permits from applicable agencies and ANCSA
Corporation landowners. The Work Plan will identify known impacts to geology
and soil resources. FERC regulations require “evaluation of unconsolidated
deposits, and mineral resources at the project site” 18 CFR 5.(d)(3)(ii)(A). For the
Exhibit E, AEA must provide a report on the geological and soil resources in the
proposed project area and other lands that would be directly or indirectly
affected by the proposed action and the impacts of the proposed project on
those resources.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. This study report will provide the basis of the information needed for the
Exhibit E.
4.5.2. Existing Information and Need for Additional Information
·evaluation of reservoir induced seismicity (RIS) (Harza-Ebasco 2005)There is no
reference to this study in Literature Cited;
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pg. 12
In summary, the following geotechnical investigations were performed prior to
2012 (No geotechnical investigations were preformed after 1985, except
whatever might have been done in the summer field season of 2012.):
· geologic mapping
· drilling at the dam site, construction materials source areas, and in other
geologic features (i.e., relict channel near dam site)
· instrumentation monitoring (groundwater and temperature)
· seismic refraction
· test trenches and pits (Borrow Areas E)
· trenching of lineaments and faults
4.5.4. Study Methods
The study of geology and soils resources for supporting licensing and detailed
design will include a number of components:
· Develop understanding of geologic and foundation conditions for the dam site
area and specifically for each of the project surface and underground
components of the project; This should be for the “reservoir area” rather than
“dam site.”
· Evaluate the mineral resource potential in the reservoir, dam and upland
facilities areas;
· Evaluate major geologic features, rock structure, weathering/alteration zones,
etc.;Where, how?? It should be the whole reservoir area.
· Delineate and characterize construction material sources for the dam and
appurtenant structures, access road, transmission line, and construction camp;
· Evaluate the surficial geology and potential thawing of localized permafrost on
reservoir slope stability. This should be done on the whole reservoir area.
Geologic and Geotechnical Investigation and Testing Program Development
The development of a geological and geotechnical exploration and testing
program work plan for completion of geologic field studies for final design and
ultimately for construction will be undertaken. Based on review of the existing
data including previous geologic mapping, subsurface investigations and
laboratory testing from the 1970s and 1980s, additional investigations and
testing will be to:
o Evaluate major geologic features, rock structure, weathering/alteration zones,
etc.;How? Where?
o Evaluate the effect of project features on permafrost and periglacial features
(thawing of permafrost), as well as the impact of these features on permanent
structures, work camps, temporary construction areas, road corridors,
transmission lines, etc.;(this should include the whole reservoir area)
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pg. 13
Field Geologic and Geotechnical Investigations
Geologic and geotechnical field investigations will be carried out in phases with
portions of that work contributing to the report on geology and soils in 2013 and
updates in 2014.It is real important to know WHAT was done and WHAT is
proposed. What are the specifics?The geotechnical (This should read
“geologic” rather than “geotechnical”)investigations and testing being
undertaken as part of the Project feasibility and design effort will include
geologic mapping, drilling, sampling and in situ testing, test trenches, pump
tests, test adit, laboratory testing, instrumentation monitoring, etc.Where, how
many?A geotechnical exploration and testing program is planned for the 2012
season to investigate the dam foundation and a new quarry site for concrete
aggregate material, installation and monitoring of geotechnical
instrumentation, and reconnaissance geologic mapping. Specifics?
Reservoir Slope Stability Study
An assessment will be made of reservoir rim stability based on the geologic
conditions in the reservoir area, particularly in the reservoir drawdown zone.
Geologic information from the previous study on reservoir slope stability (1982) as
well as mapping, geotechnical investigations and instrumentation monitoring
will be used to assess the stability concerns of the reservoir rim. Key factors in this
study are the planned reservoir level and anticipated range of drawdown, soil
conditions, presence of permafrost, topography and slope
conditions. Specifics?
4.5.6. Schedule
The proposed study includes a limited field investigation program in 2012 for
aerial photographic interpretation, reconnaissance geologic mapping, drilling,
lineament analysis, installation of a long-term earthquake monitoring system,
assessment of slope stability for the reservoir rim, and reservoir triggered
seismicity study. For 2013-14, comprehensive investigations (What are they?)will
focus on the dam site, reservoir area, and access road and transmission line
corridors. Initial and Updated Study Reports explaining actions taken and
information collected to date will be issued in December 2013 and 2014.Again,
generally lacking in specifics.
Conclusion to Proposed Study Plans
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pg. 14
We do not believe that the ILP study plan time frame is conducive to good
science. The fast pace and the two year timeframe produces an overreliance
on the 1980’s studies. There is no adequate analysis that this is scientifically
defensible. Our comments describe some of the goals in the studies that are not
being considered. We believe these goals protect the public’s best interests.
Respectfully submitted,
Becky Long, Richard Leo, Ellen Wolf, Whitney Wolff
Board of Directors
Coalition for Susitna Dam Alternatives
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Tony Crocetto, Talkeetna, AK.
This is the second time I am trying to submit these comments. The first time i
tried, I received a message that there was a server error. So, if you have
already received this, please disregard this one.
The Coalition For Susitna Dam Alternatives has submitted very detailed
commentary to you about why the studies being undertaken now are inadequate to
insure that there will be no adverse effects to the ecosystem and the socio-
economic systems that are in place now in the area that the dam will affect. I
will not attempt to voice these concerns in my own words. Instead, I simply
declare that I am opposed to the construction of this dam. I am not a tree-
hugger or a radical left-winger. I believe that the concerns of the people who
will be impacted by projects like these should be given paramount importance.
To ruin forever the place that one calls home, for which one has worked part of
or all of a lifetime in order to make the cost of electricity cheaper by a few
cents or more abundant for consumers of power from outside of this area is
immoral. Put yourself in the shoes of someone in this predicament. Would you
be willing to have the place that you fell in love with and worked hard to
establish as your homeland drastically altered so that it was no longer
attractive to you, maybe even dangerous to continue living there? Where the
activities that you worked hard to be able to enjoy were no longer available to
you? And how could you, in good conscience, not explore every avenue to insure
that there would be no negative impacts? The people being impacted are your
fellow citizens of Alaska. Many of them very well educated in the possible
impacts that a huge project like this will have, and who are open to proposing
alternative energy producing projects, which is what our government should be
investigating if they wish to move ahead into the 21st century, and not be left
in the dust like an obsolete dinosaur. Please think of your fellow citizens
first when considering huge projects like these. Compromise is the way to the
future.
Thank you for taking my comments.
Tony Crocetto
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David B Downey, Palmer, AK.
Build it!
Seems to be common sense to me. There is limited private lands there, a vast
area, with only fly in access or ATV. Build it while you can. Also, a lake of
that size in that area, will create a lot of recreational activity and commerce
in the future.
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Lara Gentzel, Talkeetna, AK.
Lara Gentzel
P.O. Box 951
Talkeetna, AK 99676
November 11, 2012
Federal Energy Regulatory Commission
888 First Street, N.E.
Wahington, DC 20426
Dear FERC,
I am writing this letter to express my exceedingly strong opposition to the
proposed Susitna River Dam (Susitna-Watana Project). While I am excited about
the idea of increasing our state’s use of alternative energy, I feel this
specific project will have far more negative impacts than positive.
I was born and raised in Talkeetna, AK, a beautiful and lively town built near
the convergence of the Susitna, Talkeetna and Chulitna rivers. I lived in
Washington State for roughly ten years, where I attended college and married an
avid fisherman and outdoor enthusiast. We moved back to Talkeetna to begin our
careers and purchase a home, knowing that it is a wonderful place to someday
start a family. We have seen the immense damage done throughout the Lower 48
due to damming of rivers. Now we are seeing a huge movement to remove these
outdated energy sources and attempts to repair the severe damage done to the
ecosystems and communities. By installing a large hydroelectric dam on the
Susitna River, there would be severe and immediate damage to the local wildlife,
habitat, economy and community.
I am asking FERC to deny Alaska Energy Authority’s (AEA) application to license
the Susitna River Dam for the following reasons:
First of all, and most important for Alaska as a whole, the proposed dam does
not make long-term sense in terms of energy production or energy cost. We know
that Alaska is rushing to produce “sustainable” energy, but in this rush AEA has
developed a plan that is far too expensive and will actually increase the cost
of local energy, and consume most if not all of our state’s precious financial
surplus. It will not produce enough of Alaska’s energy to justify the huge
price tag. This dam would do nothing to improve the heating expenses for homes
in Alaska, almost all of which are from fuel/oil heat sources. Research in the
field of energy shows that the most efficient and cost affective way to produce
alternative “sustainable” energy, is through smaller, diverse projects. With a
combination of wind, solar, tide, geothermal and other renewable projects,
Alaska could develop a comprehensive energy program that could produce energy
for many generations to come. It is known that a dam built on a glacial river
such as the Susuitna, has a very short life due to the build up of silt in the
reservoir. With such exceedingly high construction costs, and such a limited
productive time for the dam to produce energy, this dam is not a long-term
solution for our energy needs.
If built, the dam will not only block the path of a run of large King Salmon
returning upstream to spawn, it will also dramatically alter the water levels
and flow throughout the year, damaging the habitat and conditions for salmon
eggs and fry. In addition to altering the Susitna River, all the rivers
20121113-5013 FERC PDF (Unofficial) 11/11/2012 1:20:00 PM
downstream will also be negatively affected. Alaska is a state that depends on
salmon for both subsistence and economical reasons. My husband and I both fish
for salmon, which is a substantial food source for us throughout the year. My
husband is also a fishing guide part-time in our small community. With already
declining salmon populations, we cannot afford to drive the salmon numbers any
lower.
The dam would also create an enormous reservoir that would flood migratory lands
and habitat for caribou, moose, bears, and other wildlife. The increased flow
and water temperatures from the reservoir in the would postpone or prevent the
ice from freezing across the Susitna River in the winter, making the typical
travel in these areas dangerous/deadly for snowmachiners, dog mushers and
wildlife who use this river for transportation. Lower water levels in the
summer will again endanger salmon, but also limit the use of boats on the river
for commercial, recreational, and travel purposes. This could have a very
negative impact on our local economy which is largely dependant on tourist
activities such as fishing, sightseeing, rafting, and jet boat tours.
I also have concerns that the proposed location of the dam is too close to a
known geological fault in an area that recently suffered an earthquake that
destroyed mountainsides with a magnitude of 7. A 750-850 foot tall dam with a
42 mile reservoir behind it is asking for disaster in this area. If built, I
would fear for my family and my community if this dam were to break. We all
know that building so close to a fault line would greatly increase the
possibility of dam failure.
We live in Alaska because we love this state. I want to see Alaska and my local
community of Talkeetna thrive. I want to see us make positive steps forward to
developing less expensive renewable energy. The proposed Susitna Dam will not
help us meet any of these goals.
Please deny Alaska Energy Authority’s application to license the Susitna-Watana
Project. Thank you for your time and effort.
Sincerely,
Lara Gentzel
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Sarah Kehoe, Talkeetna, AK.
I oppose the Susitna dam and I think AEA's Proposed Study Plans are not adequate
for understanding the impacts the dam would have on a river system as
biologically rich and complex as the Susitna River.
There has never been a dam so massive, built so far north, on a river so large.
Two years of study is simply not enough.
In addition, AEA has dismissed a National Valuation Study. I believe the value
of an intact Susitna watershed should be considered on a national scale.
AEA insists on using studies that are 30 years old. We need to allow for climate
change (the climate of the Susitna Valley has changed dramatically in 30 years,
averaging 4 to 5 degrees warmer) and also make decisions after much more
sophisticated data collection and computer modeling techniques have been used.
AEA has not made any of this summer's study data available. All data must be
available to the public and be peer-reviewed.
20121113-5016 FERC PDF (Unofficial) 11/12/2012 12:37:49 PM
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20121113-5016 FERC PDF (Unofficial) 11/12/2012 12:37:49 PM
Jen Latham, Talkeetna, AK.
I oppose the Susitna dam and I think AEA's Proposed Study Plans are not adequate
for understanding the impacts the dam would have on a river system as
biologically rich and complex as the Susitna.
Two years of study is not enough. There has never been a dam so massive, built
so far north, on a river so large. Even the agencies studying the extent of the
dam's impacts and risks say that only two study years cannot return a full
understanding of what would happen if the dam is built. For instance, with the
Susitna running at much reduced summer flows, the Chulitna could push the main
stem of the Susitna toward Talkeetna. What is the likelihood of this, and what
would the impacts of increased erosion be on the town of Talkeetna? Also, what
impacts would the changes in Susitna River water flows have on the five species
of salmon? The life cycle of a Chinook salmon is five to seven years. A
comprehensive, meaningful study that confidently predicts the potential effects
of a dam of this nature on Susitna River salmon simply cannot be conducted in
two years.
Winter water flows are planned to fluctuate across the day, at times reaching
four times average flows. This would make river ice unstable, making travel
dangerous, or even impossible, for both humans (snowmachine, dogsled or ski) and
animals (moose and caribou). It would disrupt winter habitat of juvenile salmon
in the main river, for example by removing still pools where they would normally
rest, making their survival difficult at best and impossible at worst.
The fish and wildlife resources of Game Management Unit 13 will be negatively
impacted by this developed access. This means trespassing issues, increased
harvest pressure, user conflicts, increased use of Off Road Vehicles on the
tundra, and disturbance to caribou calving areas. The preferred access route
bisects the range of the Delta Subherd of the Nelchina Caribou Herd.
The establishment of access routes is an extensive carbon footprint. The
majority of the ground in each access alignment is permafrost. Development will
cause the thermal regime to warm and thaw creating an increase of greenhouse gas
emissions to the environment.
The Seattle Creek route joins the Susitna River Watershed to the Tanana/Nenana
River Watershed with the increased potential for invasive species penetration.
This is worrisome because government agencies usually want to spray herbicides
when invasive plants are discovered.
Studies from the early 80's are being used to speed the process, but the climate
of the Susitna Valley has changed dramatically in 30 years, averaging 4 to 5
degrees warmer. Many of the old studies are no longer accurate for today's
conditions. In addition, there are much more sophisticated data collection and
computer modeling techniques that were not available 30 years ago. But still AEA
is insisting that they can use those old studies to... speed the process.
A National Valuation Study has been dismissed by AEA, but the impacts of the dam
should be considered from a national level, not just Alaskan. A free-flowing
Susitna River has value to Alaskans and all Americans. Formally called a
National-Level Economic Valuation Study, this study would fully explore and
define the cost/benefit, loss/reward of the national value of a free flowing
river versus a dammed river, including costs to such factors as recreation,
20121113-5014 FERC PDF (Unofficial) 11/12/2012 2:23:00 AM
aesthetics, and culture. FERC is a national agency. The value of an intact
Susitna watershed should be considered on a national scale.
All data must be available to the public, and it must be peer reviewed. AEA has
not made any of this summer's study data available.
-
20121113-5014 FERC PDF (Unofficial) 11/12/2012 2:23:00 AM
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20121113-5014 FERC PDF (Unofficial) 11/12/2012 2:23:00 AM
November 10, 2012
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
666 First St., NE, Washington DC 20426
RE: Proposed Study Plan (PSP) for proposed Susitna Dam P-14241-000,
Applicant Alaska Energy Authority (AEA)
Ecosystems have Intrinsic Rights
Ecosystems have intrinsic rights. Residents of communities in
ecosystems have the right to act as legal guardians of a threatened
ecosystem. The Susitna Valley communities take the protection of the
natural environment seriously. Proper functioning of the ecosystem is
essential to human life. Aldo Leopold in A Sand Country Almanac states:
An action is right when it tends to preserve the integrity, stability,
and beauty of the biotic community. It is wrong when it tends
otherwise.
Accurate, peer reviewed scientific data is necessary to decide if this
project will negatively impact the natural environmental ecosystem.
Inadequate Study Time
The two-year Integrated Licensing Process (ILP) timeframe is not
legally defensible. A major dam on a major complex river system in an
area which is vulnerable to climate change means major impacts. Two
years of studies are not enough. Looking at these studies, many of them
are in reality only one year of actual field study. Many of the studies that
are connected to the larger distribution and abundance studies will be
run as “pilot studies in 2013 and then refined in the final 2014 year.
This scarcity of data will in no way characterize the full knowledge
of the 19 resident fish species. The October 8, 2012 Alaska Chinook Salmon
Knowledge Gaps and Needs report from the Alaska Department of Fish
and Game Office of the Commissioner shows the large amount of
unknown data regarding the Susitna River Chinook stocks. Annual run size
and freshwater and marine survival rates of all the stocks are unknown.
With an inadequate time frame, there is a scarcity of information
which may result in underestimating the negative project impacts and
overestimating the benefits.
20121113-5117 FERC PDF (Unofficial) 11/12/2012 3:36:50 PM
The following studies should be 5-7 years long: all fish and aquatic
Resources, Instream Flow studies, Breeding Survey of Landbirds and
Shorebirds, Ice Processes. This is to just name a few.
Over-reliance on the 1980’s Alaska Power Authority Su Hydro Studies
The proposed Study plans include data from the 1980’s as points of
reference and also as actual data upon which to base project impacts.
For instance, the Ice Processes Study consultants will be using data from
the studies for the years 1979-1985. The relevance of using this data is
questionable. We do not know the scientific validity of these studies. This is
because many of them were not completed, were for a different project
of a 2 dam configuration, and did not take into consideration any sort of
climate change projections into their calculations. A Biometric Study of
these older studies has been requested by the federal agencies. This
needs to happen.
Comments on Socioeconomic Resources Studies
An important component of these studies should be the National-
Level Economic Valuation. The Susitna Valley economy of tourism,
hunting, fishing, subsistence, and recreation is dependent on the natural
resources and is enjoyed by national and international consumers. It is an
economy based on a wild river, an undammed river. Thus, there needs to
be a national valuation of this aspect as part of the non-power uses of the
river figured into cost/benefit figures. Calculations for this kind of study are
perfectly acceptable among government agencies and NGOs. Without
this, the socioeconomic studies are narrowly defined, unrealistic and
hopelessly out of date.
Also, the social Conditions and Public Goods and Services Study
needs to include an ecosystem service component. According to the
Environmental Protection Agency, these include water filtration and
storage, air filtration, carbon storage, nutrient cycling, soil formation,
recreation, food and timber. These considerations are directly connected
to economic benefits and economic costs. Healthy watersheds reduce
capital costs to supply clean drinking water and to treat wastewater.
In the Socioeconomic Resource Studies, the following information
from the study 7/26/12 Susitna-Watana Cost of Power Analysis Discussion
Paper written by the Institute of Social and Economic Research, University
of Alaska Anchorage needs to be presented in order to give a realistic
picture to future electrical costs to retail customers.
The reference case assumptions include a capital cost of 5.0 billion
year 2008 dollars, 100% debt financing at 6%, and an on-line date of
20121113-5117 FERC PDF (Unofficial) 11/12/2012 3:36:50 PM
2024…the retail rate for Susitna power in 2024 at a Railbelt
customer’s meter would be about 40 cents a kilowatt-hour (kWh).
By comparison, if natural gas is available to electric utilities in year
2024 at a price of about $13 per million btu, and neglecting
potential carbon taxes, then the retail rate for power from a new
conventional combined cycle gas turbine going online in 2024
would be about 21 cents per kWh. If the State of Alaska were to
contribute cash to cover part of the cost of the Watana project,
required rates would be lower. For example, if the state paid 50% of
the reference case cost of $ 5billion, then a retail rate of about 23
cents per kWh would be required to cover the remaining 50%. The
required outlay by the state would be the equivalent of about
$15,000 per family of three Railbelt residents.
Climate Change
Thankfully, AEA proposes to establish by study some climate change
projections. 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.
I fully support the study request of the federal agencies “Project
Effects under Changing Climate Condition.” The impacts from a changing
climate will continue to become more evident as more extreme storms
such as the September storms in Alaska and the recent storm from
Hurricane Sandy. These will happen more often. Studies such as the
agency study request will become status quo when impacts from large
development projects such as the proposed Susitna Dam are considered.
FERC needs to recognize this and accept climate change studies.
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?
Short Comments
Engineering and design studies are being conducted now. This seems
inappropriate until applicant sees the study results of ground and
surface water movement studies at the dam site. Groundwater piping
and infiltration are causes of dam failure.
With increased Susitna River mainstem flows from the project, how will
this impact the Chulitna River? Will the Chulitna River encroach more
on Talkeetna and cause erosion?
20121113-5117 FERC PDF (Unofficial) 11/12/2012 3:36:50 PM
With so much of the sediment removed from the Susitna River by the
project, will the Susitna River become a “hungry” river and pick up
more sediment and cause significant erosion?
Currently, the Susitna River clears up around September when the
glaciers shut down. Photosynthesis occurs in the river ecosystem.
Project impacts will create a year round turbid river. These impacts
need to be studied.
If there are emergency situations in winter after the dam is completed
and water must be let out of the reservoir, will there be mid-season
break up in winter time? How will this affect public health?
There needs to be seismic studies to determine if there is a Deadman
Earthquake Fault near the dam site.
There needs to be a study that determines the carbon footprint of the
construction of the project and the greenhouse gas emissions of
methane and carbon dioxide from the reservoir and melting
permafrost.
There needs to be total transparency on all the study data that is
available to the public.
The studies need to be peer reviewed. This is a must.
Becky Long
20121113-5117 FERC PDF (Unofficial) 11/12/2012 3:36:50 PM
Document Content(s)
Becky Long Study plan doc.DOC.........................................1-4
20121113-5117 FERC PDF (Unofficial) 11/12/2012 3:36:50 PM
BrianOkonek, Talkeetna, AK.
Nov. 13, 2012
To: FERC
Ref: P-14241-000, Proposed Susitna River Dam
Dear FERC representatives,
All around the world people are finding out the detrimental affects that
dams have on rivers ecosystems. Dams are being removed (at considerable
expense) to bring life back to rivers. The Susitna River supports runs of all
five species of salmon. This fishery is important to the economy of Talkeetna
and other communities in the Susitna valley and to the commercial fisheries in
Cook Inlet. Although few salmon make it up Devil's Canyon (where the dam is
proposed) the change in river flow and water temperature below the dam could
have detrimental affects to salmon eggs and fry down river and the adult
salmon’s spawning habitat.
The 39 mile reservoir the dam will create could disrupt the migratory
route of the Nelchina caribou herd, an important source of meat for many Alaska
hunters. Alaska is renown for its scenery, wilderness and wildlife. These
resources attract thousands of tourist to the Susitna valley and Alaska every
year. I do not believe that two years is long enough to study the many
impacts that a dam will have on life in and along the length of the Susitna
River both summer and winter.
There needs to be long term, comprehensive studies done to determine
exactly how a dam will impact the Susitna River ecosystem, communities along or
near the river and the economy of the region. How will the change in river flow
rates effect salmon and other fish species both summer and winter? 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? How will the sediment
load the river carries in the summer be changed? What will change at the
confluence of the Chulitna River with the change of flow rates in the Susitna
River? What impacts will there be from roads, construction camps, power
lines, the dam, the reservoir and increased recreation and hunting access into
the wilderness where the dam is proposed? How has climate change effected the
river? How will escalating glacier melt effect the proposed reservoir? If an
earthquake damages the dam causing a flood how will this effect the river
ecosystem, the railroad and highway bridges and Talkeetna and its’ residences?
What would be the economic consequences of a failure of the dam? These are all
broad concept questions that each can be broken down into dozens of others for
information that needs to be gathered to have a clear understanding of how a dam
will effect the Susitna River and the life along it. It will take longer than
two years to gather this information. Do not hurry the process.
The tourism and fisheries of the Susitna River drainage is of
international interest. The Susitna River should be considered a resource
worthy of a National-Level Economic Valuation Study.
As studies proceed all reports need to be made available to the public and
must be peer reviewed. It is important that the data collected is reviewed and
evaluated on a timely and regular basis.
20121113-5378 FERC PDF (Unofficial) 11/13/2012 3:02:41 PM
Please ensure that the study and planning process for the proposed Susitna
River dam is accomplished with the highest degree of integrity, that all
questions are answered, that the science is sound and the process is
transparent.
Sincerely,
Brian Okonek and
Diane Calamar Okonek
20121113-5378 FERC PDF (Unofficial) 11/13/2012 3:02:41 PM
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20121113-5378 FERC PDF (Unofficial) 11/13/2012 3:02:41 PM
Sandra, Trapper Creek, AK.
Comments on FERC’s Proposed Study Times
We have lived near the Susitna River since 1973. We do not feel that a true
picture of the nature of the Susitna River can be gained in only a two-year
study. There are far too many variables. Before building a massive dam of such
magnitude as the one proposed, a longer, comprehensive study needs to take
place. Therefore, we support extending the study period.
We understand that studies from the 1980’s may be used in the decision process.
We understand these might be used for some comparisons; however, given 30 years
of change in climate, population, data gathering techniques, and the river
itself, these studies are of questionable validity for basing decisions on
current proposals. They should not be used to speed up the studies that are
being done now.
We have learned that a National Valuation Study has been ignored by AEC. We
feel this is a narrow view of the importance of the river to everyone in our
country, not only Alaskans. The Susitna River is a free-flowing river that is
visited by people from all over the United States and the world each year.
Impacts of the dam should be viewed in the most global manner possible.
Thank you for the opportunity to comment. We implore you to keep us all
informed by making the research data public and peer reviewed.
David and Sandra Porter
PO Box 13152
5494 S. Sawmill Lane
Trapper Creek, AK 99683
20121115-5005 FERC PDF (Unofficial) 11/14/2012 5:47:37 PM
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20121115-5005 FERC PDF (Unofficial) 11/14/2012 5:47:37 PM
Denis Ransy, Talkeetna, AK.
11/12/12
Kimberly D. Bose, Secretary, Federal Energy Regulatory Commission
888 First St. NE, Washington DC 20426
Comments on the Proposed Study Plan for the Proposed Susitna Dam P-14241-000
First and foremost, the two-year time period for studies is completely
inadequate for any real understanding of the Susitna River. The Integrated
Licensing Process (ILP) was chosen for the project. The ILP process was
originally for the relicensing of existing dams, not new ones. AEA’s desire to
fast track the project is the rationale.
So far comments from federal agencies have already been adversely affected
by the timeframe. NMFS and USFWS both have stated that their PAD and SD 1
comments were not adequate due to the short time constraints. This tells me that
AEA is not interested in complete scientific studies. It just wants to get all
that tiresome science stuff out of the way and start pouring concrete. And as
far as considering the old studies from the 1980’s, please spare me…that is a
pathetic joke. Present day water, air, fish, wildlife and socioeconomic factors
have all changed since then. If you want to use those outdated studies, please
proceed to your nearest time machine, and head on back there. We are living in
the present and these issues are critical to us now.
The average life span of a Chinook salmon is six years. Two years of study
is ridiculous to even consider.
What are the life spans of moose and caribou? What are the life span of
glaciers, upon which the dam would so heavily rely upon? Two years barely gets
things off the ground.
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. The sacrifice of this important part
of the run is unacceptable.
Susitna salmon are under stress now, due to increase climactic changes,
other environmental factors, and increasing fishing pressure. The great
environmental changes caused by the dam would increase the stresses many times
over.
Speaking of climate change, comprehensive long-term studies must be done
on this all-important subject. AEA acts as if it is not really happening, when
85% of the world’s scientists say that it is, and it is at least in part human-
caused. And the entire Susitna River must be included, not just from the dam
site up.
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.
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
20121113-5019 FERC PDF (Unofficial) 11/12/2012 3:22:14 PM
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.
The socioeconomic study Social Conditions and Public Goods and Services
Study must have a much wider scope. Alaskans benefit from clean water, abundant
fish and wildlife, thriving commercial and sport fishing, and tourism
industries. Tourists come to the Susitna Valley to see a natural landscape not
an industrial city and river. These values will be lost due to the project.
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.
A study is clearly required on National-Level Economic Valuation. This
River is visited by thousands of people per year from the US and foreign
countries. Its national importance is obvious and is a valuable asset to all
Americans in its natural state. It has long been discussed as a possible
National Wild and Scenic river, and is in fact on the Bureau of Land
Management’s list of potential candidates. Many national and local NGOs endorse
the need for this study. The Federal Power Act requires FERC to give equal
weight to river values other than damming. NMFS also strongly supports this
study. These factors cannot be ignored.
Submitted by
Denis Ransy
20121113-5019 FERC PDF (Unofficial) 11/12/2012 3:22:14 PM
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20121113-5019 FERC PDF (Unofficial) 11/12/2012 3:22:14 PM
Mary L. Raychel, Willow, AK.
Nov. 13, 2012
I am opposed to the Susitna-Watana Hydroelectric Project.
I feel like this is being pushed ahead without enough comprehensive studies and
too many unresolved issues.
This project will impact 3 rivers. How will it change salmon runs and fishing?
How will it effect the rivers in regard to boating and fishing and sightseeing?
Will the rivers be safe for snowmachines, trappers, etc. during the winter
months?
This will be in an earthquake prone area. Will the Town of Talkeetna and other
places along the river be more vulnerable to floods?
I feel that Alaska should invest more in gas reserves in Cook Inlet and not
waste money on this project.
20121114-5003 FERC PDF (Unofficial) 11/13/2012 6:55:55 PM
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20121114-5003 FERC PDF (Unofficial) 11/13/2012 6:55:55 PM
Cari Sayre, Talkeetna, AK.
Thank you for the opportunity to comment on the study plans submitted to FERC by
the Alaska Energy Authority regarding the Susitna Hydro Project. This proposed
project is a massive one, and one that would have massive impacts. Two years of
study is simply not sufficient to fully understand what could and would happen
if the dam were built.
We who live in the Upper Susitna Valley value our resources. We value the fish
in the river, as well as the other wildlife that depend on the river for
sustenance, as a travel corridor, as a part of their habitat. Any study of
salmon must take into account at least one full life cycle, which is five to
seven years. A comprehensive, meaningful study which accurately predicts the
potential effects of a mega-dam on the Susitna River salmon simply cannot be
conducted in two years.
We also value our winters for the ease with which we can travel to far-flung
places. The Susitna River is a highway, not only for humans on snowmachines,
dogsleds or skis, but also for animals (moose and caribou). The dam would
impact winter water flows, making travel dangerous or even impossible. It would
also disrupt the winter habitat of juvenile salmon. Again, with winters being
variable, a study of only two years seems insufficient.
I lived in Talkeetna in the 1980s when studies were being done for this dam
project. Those studies are no longer valid. The climate has changed. It is
much warmer than it was then (4-5 degrees warmer, on average). The predictions
made then are no longer accurate. In addition, there are much more
sophisticated data collection and computer modeling techniques that were not
available 30 years ago. AEA should not be allowed to use short-cuts to speed
this process along. The river deserves better.
This Susitna River is not just important to folks who live in Talkeetna.
Granted, we would suffer most if the dam were to be built (especially in the
event of catastrophic dam failure). In speaking with thousands of visitors
last summer, I heard again and again how much they value a free-flowing Susitna
River. This river has innate value. It has value as a source of recreation, of
aesthetic beauty, of cultural resources. It has economic value to our community
and also to the many tourism businesses that bring visitors to the Susitna
Valley. AEA has refused to consider a National Valuation Study, but the impacts
of the dam really would be felt on a national, if not international, level.
This issue must be explored.
AEA has been far from transparent with their study data. It is critical that
the data be held open to the public, and that it be peer-reviewed.
Thanks for listening,
Cari Sayre
20121113-5379 FERC PDF (Unofficial) 11/13/2012 3:03:27 PM
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20121113-5379 FERC PDF (Unofficial) 11/13/2012 3:03:27 PM
Douglas Smith, Talkeetna, AK.
Nov. 13, 2012
Kimberly Bose, Secretary
FERC
888 First St. NE
Washington DC 20426
Dear Ms. Bose,
I am writing to comment on the Alaska Energy Authority’s Proposed Study Plan
(PSP) for the Susitna-Watana Hydroelectric Project. This is a project that I
oppose for a variety of reasons – it’s exorbitant cost, impacts, and the
inappropriate use of the Integrated Licensing Process for a project of this
scale, something that has never been done before. As a retired science teacher
with degrees in biology and toxicology, I am now vacillating between despair and
disgust at the short study period that fulfills the requirements for the PSP
under this licensing approach.
In short, this PSP sacrifices quality and validity for expediency. The AEA
proposes to finish all its scientific studies in two years – in Alaska that
translates into two short summers of field work – which is not enough time to
even get a snapshot of what possible effects this dam could have on the northern
Susitna Valley. In less than half the life cycle of many of the salmon this
project is sure to impact, the AEA contends that it can reliably predict the
impacts of reduced summer river flows, widely-fluctuating and higher winter
river flows, siltation changes, temperature changes, migration pattern
alterations, and a host of other impacts on a rich and diverse biological
community covering hundreds of square miles. It’s not possible. For example,
researchers that I have talked to from one participating state agency don’t
think they can even accurately count the impacted moose population in the given
time frame, and moose are relatively easy to count. Like all organisms up here,
their populations move and vary considerably over time, as forest succession,
predation, and a host of other factors affect their populations. What will we
know bout moose from AEA’s two-year snapshot? Are we looking at a high in the
moose population cycle? A low? Who knows? This pinhole view of what’s going
on with moose populations (or waterfowl, caribou, trout, or five salmon species)
cannot give us reliable information on what a huge dam’s impacts will be.
Everyone knows it (and knew it when the ILP was approved). The goal is to get a
license, not understand an ecosystem. So the studies, and the charade, go on
for one more short summer of field work. In the end, we’ll end up with the
minimum quantity (and quality) of studies necessary to fulfill the meager
requirements of the all-in-one dam-promoting and dam-regulating agency.
That sound rather cynical, but actually, I’m not. I’m hopeful. Because YOU CAN
DECIDE THAT THESE STUDIES ARE IMPORTANT, AND NECESSARY, AND NOT JUST LICENSING
WINDOW-DRESSING.
Please restore our faith in the licensing process. Tell AEA that they are
required to expand the timeframe, and the scope of their studies. These
studies must be peer-reviewed, and the data should be available to the public.
Please make this study process more rigorous, valid, and transparent.
Thank you for the opportunity to comment.
20121114-5008 FERC PDF (Unofficial) 11/13/2012 10:36:45 PM
Doug Smith
P.O. Box 371
Talkeetna, AK 99676
dougseabird@yahoo.com
20121114-5008 FERC PDF (Unofficial) 11/13/2012 10:36:45 PM
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20121114-5008 FERC PDF (Unofficial) 11/13/2012 10:36:45 PM
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington DC 20426
PO Box 766
Talkeetna, AK 99676
November 12, 2012
Subject: Comments on Alaska Energy Authority Proposed Study Plan (PSP) and Draft
Revised Study Plans for the Proposed Susitna-Watana Hydroelectric Project Number
P-14241-000
To Whom It May Concern:
I am submitting these comments as a long term resident of Talkeetna and user of the
backcountry and wilderness areas of the northern Susitna Valley. I own properties and
two recreational cabins at various locations in the northern Susitna Valley, where I have
recreated extensively for over 40 years. I have used and continue to use the Susitna
River, as well as some of its tributaries for both summer and winter travel. In the
winter, I travel primarily by dogteam; in the summer by river boat or raft. I use the river
for recreation and also for access to my remote cabin. I have fished and hunted along
the Susitna River Corridor.
I gain a great deal of enjoyment from, and have an abiding appreciation for, the natural
and in-tact environment. I live in a community that relies heavily on tourism, guiding
and other outdoor based businesses, which in turn rely on the natural, unaltered wildlife
habitat, waters, and landscapes, in order to maintain its economic health.
1. The two year time frame allotted to the study plan is utterly inadequate.
The Susitna River watershed is a biologically rich and productive river system. The
Susitna River is located in a sub-arctic region .. The proposed Susitna-Watana dam would
be one of the largest dams in the United States and the only one in a sub-arctic
environment. The scale of the proposed project and the environment in which it would
be located present unique and extraordinary challenges.
The proposed dam, if built, would dramatically and permanently alter the natural
Susitna watershed on which so much depends.
Winter temperatures in the Susitna Valley are very cold, with daytime high
temperatures sometimes at 30 degrees below zero Fahrenheit, with nighttime
temperatures much colder. Ice formation and condition is a significant issue. In trying
to study the dynamics of the river, resident and anadromous fish, other organisms,
1
20121114-5020 FERC PDF (Unofficial) 11/13/2012 8:27:35 PM
nutrients, vegetation, the side streams, sloughs, water chemistry, sediment, and so on,
ice complicates everything.
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.
This just one of the countless variables and effects that must be studied. I doubt that
AEA is even close to knowing all of what it must study.
Another major complicating factor is the dramatic fluctuation in flow volumes (i.e., the
load following regimen) that would occur on a daily basis. This adds a whole new layer
of variables that need to be studied.
Study of the environmental impacts that the proposed dam would have is so
enormously complex that I can see taking two years to gather the information to design
comprehensive, scientifically sound studies. But it is simply not possible to design and
conduct such studies in a two year period. A two year time frame is not just
"inadequate," it is absurd. It is absurd to suggest that comprehensive, legitimate
studies can be conducted in two years.
Here is just one example. The ongoing health and abundance of Susitna's wild salmon
are critically important in so many ways: subsistence, commercial and recreational
fishing, guiding businesses, and most important is salmon's critical role in maintaining
the structure of the ecological community of the watershed. Salmon support wildlife
such as bears, birds, otters, and the decaying bodies of spawned-out salmon supply
nutrients that the salmon acquire from the ocean (e.g. nitrogen, carbon, phosphorus) to
the lands and forest. It takes 1-3 years for the salmon fry to grow into smelt and go to
the ocean; the adults stay in the ocean for another 4 years. It is clear that a two year
study is not sufficient.
Even agency folks object to the compressed tifne frame. I attended the Susitna-Watana
Hydroelectric Project FERC Public Outreach meeting in Talkeetna last August 29, 2011
and heard an agency person object, complaining that the ILP didn't provide sufficient
time to do the necessary studies.
There were studies conducted on the 1980s with respect to another project on the
Susitna River, but these studies provide only historical data, which is of very limited
usefulness today. The modeling then was relatively unsophisticated and the data is
both limited and dated. The previous studies were conducted nearly 30 years ago for a
different project under different circumstances and different assumptions. Those
studies are not sufficient to justify the decision to go with the fast track ILP process that
allows only two years for the studies for the current project proposal.
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There are so many unknowns and variables, so many widespread and far-reaching
effects, and so many hydrological complexitie~ and interrelationships that must be
studied. This proposed project is an extremely risky proposition with a huge downside.
It is astonishing to me that AEA, by insisting on a ILP process and only two years of
study, is willing to plunge ahead with this project lacking complete, comprehensive
information on its effects.
In summary, two years is much too short a time frame to properly study a project of
such massive scale and consequence. FERC should require a sufficient time frame be
allotted for the design and conduct of the studies. If the ILP process doesn't allow for
this, then I recommend that FERC disallow the use of the ILP and require a full blown
licensing and application process that is customary for new dams.
2. In 1986, Congress amended the Federal Power Act to require FERC to give equal
consideration to non-power values when deciding whether or not to license a
hydropower project.
In order to comply with this 1986 provision, non-power values, such as the value of an
intact natural watershed, must be considered using methods that enable comparison
with power related values. Non-power values must be identified and fairly valued and
otherwise treated in a manner that allows comparison to power related values.
The methods used to determine power and non-power values likely will not be the
same. It is straightforward to quantify the value of a mega watt of electricity. It is not so
easy to attach a value to an intact ecosystem or watershed. Nonetheless, there are
methods by which power and non-power values can be fairly derived and compared.
It makes no sense for Congress to have stipulated that non-power values be
"considered" if it did not intend that "consideration" would result in meaningful,
substantive research and evaluation that would inform the decision to approve or deny
the license. There would be no reason for this stipulation to "consider" non-power
values if Congress intended that the non-power values be simply looked at and
effectively ignored. To give meaning to the stipulation to consider non-power values,
"consideration" must include adding the appropriate studies, so that these non-power
values are fairly assessed such that they can be compared to power-related values.
Thank you for this opportunity to comment.
Sincerely,
John Strasenburgh
3
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Document Content(s)
Comments FERC study plans project no 14241 FINAL 111212.PDF...........1-3
20121114-5020 FERC PDF (Unofficial) 11/13/2012 8:27:35 PM
Cathy Teich, Talkeetna, AK.
P.O. Box 155
Talkeetna, AK 99676
November 9, 2012
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, N. E., Room 1A
Washington, DC 20426
RE: Susitna-Watana Hydroelectric Project No. 14241-000
I would like to comment on AEA’s study plan for the proposed Susitna-Watana
Hydroelectric Project No. 14241-000.
1. Two years of study is not even close to enough time to evaluate the impacts
of a dam of this size, built further north than any other dam, on such a large,
silty river, with five fault lines in the region. There are so many things to
be considered, such as:
-Impacts on 5 species of salmon and other fish due to changes in river
flow and temperature and changes in food supply due to changes
in flow and temperature.
-A 2 year study is inadequate because the life span of Chinook salmon is 5
to 7 years. Not enough information could be obtained in a 2 year period to
determine how Chinooks would be affected.
-Impacts on the Susitna River as a travel corridor for people and wildlife
due to dangers of unstable ice resulting from fluctuating flow.
-Impacts on traditional recreational activities such as snowshoeing,
skiing, snowmachining, and dog sledding due to dangers of unstable
ice resulting from fluctuating flow.
-The studies from the ’80’s are no longer appropriate, as the climate of
the upper
Susitna Valley has changed since then. Using the old studies to speed up the
process is inappropriate and would not produce reliable answers to important
questions. It is painfully obvious that AEA doesn’t want to find anything to
slow down the process. It appears that they may have been mandated to force
this particular project rather than look at any other alternative.
2. AEA dismissed a National Valuation Study. This is EXTREMELY inappropriate,
as Alaska is a NATIONAL treasure, visited by countless people from all over the
United States and all over the world. This area should receive study at the
national level (FERC is a national agency) because everyone benefits from the
jobs produced by the Susitna, recreation it provides, and food it provides. The
economics of tourism must be considered. Dams across the lower 48 are being
dismantled at huge costs. They are old technology and very expensive. There
are less expensive ways to generate power, financially and environmentally.
Putting all of your eggs in one basket is short sighted...and not very smart.
20121113-5001 FERC PDF (Unofficial) 11/9/2012 7:59:13 PM
3. AEA has not made any of the data they obtained this summer available to the
public, which is inappropriate. The public needs to see what is going on and
the data must be peer reviewed to ensure that unethical practices aren’t going
on.
4. Talkeetna had quite a flood this past August. We need to have studies done
to determine whether or not the changes in the flow of the Susitna would affect
the flow of the Chulitna and Talkeetna Rivers. Could this cause more erosion
and put the town of Talkeetna at risk? What other settlements would be at risk?
Thank you for allowing us the time to comment. I would appreciate your taking
our comments seriously and looking at these studies carefully while they are
being peer reviewed in order to determine honestly how the eco system of the
Susitna River drainage, our traditional uses, and our current economy would be
impacted.
Sincerely,
Cathy Teich
cathyt@mtaonline.net
907-733-2155
20121113-5001 FERC PDF (Unofficial) 11/9/2012 7:59:13 PM
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20121113-5001 FERC PDF (Unofficial) 11/9/2012 7:59:13 PM
Cathy Teich, Talkeetna, AK.
I was unable to access your website earlier to send copies of transportation
corridor comments that I sent to AEA. Here is a copy of that comment:
P.O. Box 155
Talkeetna, AK 99676
10-11-12
AEA
susitnawatana@aidea.org
To Whom It May Concern:
RE: Draft Watana Transportation Access Analysis
I would like for it to become a part of public record that I am opposed to all
of your proposed routes for road construction and transmission lines. I am
also opposed to all of your proposed runway/airport possibilities. There is no
“lesser of all evils” route. They are all extremely damaging.
We hunt/berry pick in that area and any of the proposed construction would
impact hunting, caribou migration, moose habitat, bear habitat, small mammal
habitat, bird habitat and nesting, migratory bird habitat and nesting, berry
picking, camping, hiking, subsistence use, the Native peoples traditional use of
the area, fishing, and tourism in a negative way.
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.
This dam threatens not only Alaskan jobs, it threatens Alaskan, U. S., and World
food supplies. There has already been disaster funding for fishermen in Cook
Inlet. The proposed dam would only make that situation worse.
This proposed dam would bankrupt Alaska. There are better ways. You should be
doing research on better ways instead of having the governor tell you what he
wants. You are SUPPOSED to be an agency that finds out the best ways for us to
go instead of rubber stamping what someone with a hidden agenda has in mind.
Please do not hesitate to call me if you have questions.
Sincerely,
Cathy Teich
907-733-2155
cathyt@mtaonline.net
20121113-5291 FERC PDF (Unofficial) 11/13/2012 1:38:53 PM
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20121113-5291 FERC PDF (Unofficial) 11/13/2012 1:38:53 PM
Ellen Wolf, Talkeetna, AK.
PO Box 371
Talkeetna, AK 99676
November 13, 2012
Honorable Kimberly D. Bose, Secretary, FERC
888 First Street, N.E.
Washington, D.C. 20426
Comments for proposed Susitna-Watana Hydroelectric Project No.14241-000 Proposed
Study Plans and Draft Revised Study Plans
Dear Secretary Bose:
Please add my voice to the many voices expressing serious concerns about AEA’s
Proposed Study Plans and Draft Revised Study Plans.
First and foremost, that the proposed dam would forever change the Susitna River
in a way that will cost us a wild and vital river ecosystem is certain. So
here, then, is the question that we must address: Do we have the right to dam
the Susitna River in order to generate what boils down to 300 megawatts of
electricity? In the year 2012, with a century’s worth of evidence about the
impacts of large dams on river systems, and with a generation’s worth of
perceptions of how vulnerable and precious what remains of our natural treasures
are, the answer is clear: THIS DAM SHOULD NOT BE BUILT.
The rest of my comments speak to the process that has been set into motion.
However, I remain confident that intelligent minds at FERC and in the state of
Alaska will recognize that the project should not be licensed or constructed.
• Two years is not enough time for many of the planned studies to be thorough
and conclusive.
• The ILP process continues to prove to be the wrong choice for considering a
newly licensed large dam on a subarctic river. The process is for relicensing
dams where impacts are already understood. This dam’s location far north of
other similar-sized U.S. dams should be reason enough choose a licensing process
that guarantees thorough study. No dams of this size have been built in the
U.S. in decades; indeed, dams such as this are being torn down in order to
reverse devastating impacts, especially to salmon. The Susitna River is home to
salmon of all five species – where is the sense in endangering these populations
when we can look to what happened in rivers like the Elwha in Washington?
• The Susitna is an important transportation corridor for humans and wildlife
in both summer and winter. The impacts of the dam on both seasons are of
serious concern. The impacts in winter are of particular concern because of the
potential dangers posed by unstable ice. Will the proposed studies be able to
confidently predict the effect of fluctuation river levels on winter ice?
• Resource Valuation is increasingly undertaken for many federal projects
because we are recognizing that the values of our natural resources go beyond
the economic. It is imperative that both state and national valuation
assessments be conducted.
Thank you for your consideration.
20121115-5006 FERC PDF (Unofficial) 11/14/2012 6:08:03 PM
Ellen Wolf
ellenmwolf@yahoo.com
20121115-5006 FERC PDF (Unofficial) 11/14/2012 6:08:03 PM
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20121115-5006 FERC PDF (Unofficial) 11/14/2012 6:08:03 PM
Ruth Wood, Talkeetna, AK.
RUTH D. WOOD
P. O. BOX 766
TALKEETNA, AK 99676
TO: Secretary Kimberly Boss, Federal Energy Regulatory Commission
RE: Comments on Alaska Energy Authority Proposed Study Plan for Susitna Dam
FERC Project #14241
Dear Ms. Boss:
These are my comments on AEA's Proposed Study Plan for the Susitna Dam, FERC
Project #14241.
I oppose the Susitna dam because I think it is an unnecessary boondoggle project
that will will permanently and irreparably damage this magnificent and vital
river - the Susitna. My opposition does not mean that I don't understand that
others have a different view, but it does make me realize that those who propose
this have to bear the burden of proof that it is a necessary project, that there
are not suitable alternatives, that natural resources will not be harmed, that
alternative uses and users will not be displaced. Because the consequences of
mistakes or misjudgements are so he standard of proof must be higher than high.
Unfortunately, I do not think AEA's approach meets those high standards, and the
Proposed Study Plans are not adequate to measure and analyze the impacts.
1. There should be no reliance on studies done in the 1980's. Temperatures in
the Susitna Valley are averaging 4 to 4 degrees warmer than they were in the
1980s. Data collection, research, and analysis (including modeling) are much
more sophisticated now. AEA wants to use the old studies in the interest of
speeding of the process. Making the
2. Two years of study is not sufficient. The Susitna is different. It is a
glacial river, in the sub-Arctic. Every summer here is different from previous
summers. Every winter here is different from previous winters. Two years is
not enough time to conduct studies and draw meaningful conclusions.
3. 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? We know the river
will freeze differently. What effect will that have on moose and caribou and
other animals? The research and analysis needed to answer these (and other)
questions cannot possibly be completed in two years.
4. Summer impacts need to be measured from the source to the mouth, and that
includes the tributaries that flow into the Susitna. What will be the impact
where the Chulitna joins the Susitna? Will the Chulitna impact Talkeetna in new
ways. What happens at the confluence of the Susitna and the Yentna in summer?
How does this impact the lower reaches, all the way to Cook Inlet. As with
winter impacts, the research and analysis needed to answer these (and other)
questions cannot possibly be completed in two years.
20121115-5008 FERC PDF (Unofficial) 11/14/2012 7:40:23 PM
5. A National Valuation Study, or National-Level Economic Valuation Study,
should be undertaken. The value of the other non-power uses, such as scenic,
recreation, or life style needs to be measured and quantified in order to do a
true cost/benefit analysis. There are methodologies to assign economic value to
these factors. Without such a study the value assigned to these other uses is
just speculation.
6. 2012 summer data would be invaluable when developing comments on additional
studies, but AEA has not made any of this summer's study data available. This
should be a public process, and AEA should be required to make data available in
an easily accessible manner. AEA's Revised PSP, for example, should have
been issued earlier than October for a November comment, and it should have been
presented in a "red line" format.
7. 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.
8. Every few months, the world gets another notice that Climate Change is real.
It makes no sense for AEA and FERC to take a position that climate change
studies are not needed. The increase in average temperatures that we've already
experienced in conjunction with further increases will effect glacial melt,
sediment transportation, water quality, and water temperature. Cumulative
conditions are relevant and they must be studied and taken into account in the
licensing process.
Thank you for considering my comments.
Sincerely,
Ruth D. Wood
20121115-5008 FERC PDF (Unofficial) 11/14/2012 7:40:23 PM
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20121115-5008 FERC PDF (Unofficial) 11/14/2012 7:40:23 PM
Katie Writer, Talkeetna, AK.
Katie Writer PO Box 440 Talkeetna, AK 99676 907/863-7669 November
10, 2012
I strongly oppose the Susitna Dam. My passion for the beauty and power of the
Susitna River Valley is shared by a majority of the people that live in
Talkeetna, Alaska and nearby communities. It is home of salmon, bear, moose,
caribou and pristine wilderness that should never be destroyed by the
construction of a Dam that Makes No Sense!
As an 8+ year Talkeetna River Sub-Division resident, I have lived thru 2 major
floods….August 18th, 2006 and more recently, September 21, 2012. During both
events, I witnessed the powerful force of water come whipping through our
neighborhood. We do not live on the bank of the Talkeetna River, yet the water
levels reached 6-8 feet of fast flowing water thru our property that engulfed
our house. We evacuated our small children in a raft on Friday morning, the day
the water’s peaked. I witnessed the town of Talkeetna get evacuated as well as
the water’s rise and flood the town. I am a pilot and had the ability to go
flying and witness the Susitna River, the Chultina River and The Talkeetna River
in their peak flood stage. It was a very frightening sight to behold and I did
not stay in the air long. Talk about scary! The destructive power of water in
the Susitna River Valley environment is enormous. If the Susitna Dam were ever
built, and there was an earthquake or rain event that the dam could not
handle…Talkeetna would be wiped off the map and human and animal life would be
sacrificed for a project that should have been never begun.
There are so many reasons to oppose the Susitna Dam. Dollars are of importance
to the state of Alaska. From the recent Presidential Election, one cannot miss
the bottom line of politics…money. $4.5 Billion to create a Dam in a subarctic
environment means two things to me. The hidden escalating costs of the future
problems of creating this Dam in an un-trodden landscape would far exceed $4.5
Billion. This Dam is a financial nightmare. If money matters and we know it
does...then let’s go with the available natural gas in the Cook Inlet. As
scientist have already explored, “the Cook Inlet gas resource could be as little
as 50% of the required investment in the hydropower dam, but will provide four
times the energy demand as Watana, enough to meet the current Railbelt energy
demand for electric power and space heating for the next 100 years.” Now that
makes Sense to me….Natural Gas is our solution, not a Dam.
This 700’ foot high dam would flood an area 39 miles long, 2 miles wide and 500’
deep in a subarctic environment where freezing temperatures begin in October and
lasts thru April(7 months of the year). Managing water flow would be a
nightmare. There are hundreds of residents and thousands of recreationalists
that utilize the Susitna River for travel, mushing, and snowmobiling. The
uneven water release proposed for the dam would make river ice unsafe for travel
for man and beast! Please, don’t jeopardize this fragile ecosystem and human
life. If you don’t issue a permit, you can rest your head at night knowing that
you made the best decision.
Just like the recent Election Day, the American people were relieved to have the
Elections over in order for President Obama to get busy with the things that
need attention, like running the country! Let’s be Smart for the planet! NO
PERMIT, NO DAM, NO more wasting money on a problematic Dam. Let’s get on with
the natural gas. It’s that simple. Sincerely, Katie Writer
20121113-5010 FERC PDF (Unofficial) 11/10/2012 1:56:02 PM
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Diane Ziegner, Talkeetna, AK.
I am opposed to this project. I feel that there has not been adequate study.
Additionally I feel that the project is too far away from the population that
will benefit the most from it. After the flooding of the Susitna River this
fall I also feel it is an unreasonable risk to the communities that are down
stream from the proposed dam. I urge you to find an alternate solution to our
energy concerns and be more forward thinking rather than resorting to this
rather "primitive" technology of damming a river. Thank you for the opportunity
to make a comment.
20121115-5010 FERC PDF (Unofficial) 11/14/2012 10:27:48 PM
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