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Susitna-Watana Hydroelectric Project Document
ARLIS Uniform Cover Page
Title:
Appendix 3, Comment response table of informal consultation, July-
November 2012
SuWa 79
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 79
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:
131 p.
Related work(s):
Comments to:
Alaska Energy Authority. Proposed study plan (SuWa 82)
Appendix 3 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 3
Comment Response Table of Informal Consultation,
July - November 2012
December 2012
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 December 2012
Appendix Arrangement: The comments and responses in this appendix are arranged by
resource area, following the order of the RSP sections.
RSP Study Title and RSP Section Number Key
RSP Study Title (Resource Area) RSP Section Number
General Comment No Particular Section of
RSP
Geology and Soils 4.5
Baseline Water Quality Study 5.5
Water Quality Modeling Study 5.6
Mercury Assessment and Potential for Bioaccumulation Study 5.7
Geomorphology Study 6.5
Fluvial Geomorphology Modeling below Watana Dam Study 6.6
Groundwater Study 7.5
Ice Processes in the Susitna River 7.6
Glacier and Runoff Changes Study 7.7
Instream Flow Study 8.5
Riparian Instream Flow Study 8.6
Fish and Aquatic Resources General to Section 9 of
RSP
Study of Fish Distribution and Abundance in the Upper Susitna River 9.5
Study of Fish Distribution and Abundance in the Middle and Lower Susitna
River 9.6
Salmon Escapement Study 9.7
River Productivity Study 9.8
Characterization and Mapping of Aquatic Habitats 9.9
The Future Watana Reservoir Fish Community and Risk of Entrainment 9.10
Study of Fish Passage Feasibility at Watana Dam 9.11
Study of Fish Passage Barriers in the Middle and Upper Susitna River and
Susitna Tributaries 9.12
Aquatic Resources Study within the Access Alignment, Transmission
Alignment, and Construction Area 9.13
Genetic Baseline Study for Selected Fish Species 9.14
Analysis of Fish Harvest in and Downstream of the Susitna-Watana
Hydroelectric Project Area 9.15
Eulachon Run Timing, Distribution, and Spawning in the Susitna River 9.16
Cook Inlet Beluga Whale Study 9.17
Wildlife Resources General to Section 10 of
RSP
Moose Distribution, Abundance, Movements, Productivity, and Survival 10.5
Caribou Distribution, Abundance, Movements, Productivity, and Survival 10.6
Dall’s Sheep Distribution and Abundance 10.7
Distribution, Abundance, and Habitat Use by Large Carnivores 10.8
Wolverine Distribution, Abundance, and Habitat Occupancy 10.9
Terrestrial Furbearer Abundance and Habitat Use 10.10
Aquatic Furbearer Abundance and Habitat Use 10.11
Small Mammal Species Composition and Habitat Use 10.12
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 December 2012
RSP Study Title (Resource Area) RSP Section Number
Bat Distribution and Habitat Use 10.13
Surveys of Eagles and Other Raptors 10.14
Waterbird Migration, Breeding, and Habitat Use Study 10.15
Landbird and Shorebird Migration, Breeding, and Habitat Use Study 10.16
Population Ecology of Willow Ptarmigan in Game Management Unit 13 10.17
Wood Frog Occupancy and Habitat Use 10.18
Evaluation of Wildlife Habitat Use 10.19
Wildlife Harvest Analysis 10.20
Vegetation and Wildlife Habitat Mapping Study in the Upper and Middle
Susitna Basin 11.5
Riparian Vegetation Study Downstream of the Proposed Sustina-Watana
Dam 11.6
Wetland Mapping Study 11.7
Rare Plant Study 11.8
Invasive Plant Study 11.9
Recreation Resources Study 12.5
Aesthetic Resources Study 12.6
River Recreation Flow and Access Study 12.7
Cultural Resources Study 13.5
Paleontological Resources Study 13.6
Subsistence Resources Study 14.5
Regional Economic Evaluation Study 15.5
Social Conditions and Public Goods Study 15.6
Transportation Resources Study 15.7
Health Impact Assessment Study 15.8
Air Quality Study 15.9
Probably Maximum Flood Study 16.5
Site-Specific Seismic Hazard Study 16.6
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 December 2012
Commenter Acronym Key
Commenter
Acronym Commenter
ADEC Alaska Department of Environmental Conservation
ADNR-ADF&G Alaska Department of Natural Resources - Department of Fish and Game
ADNR-DPOR
Alaska Department of Natural Resources – Division of Parks and Outdoor
Recreation
ADNR-OHA Alaska Department of Natural Resources - Office of History and Archaeology
ADNR-OPMP
Alaska Department of Natural Resources - Office of Project Management and
Permitting
Alaska
Ratepayers Alaska Ratepayers, Inc.
ARRI Aquatic Restoration & Research Institute
BLM United States Department of the Interior – Bureau of Land Management
DCCED-DED
Alaska Department of Commerce, Community, and Economic Development –
Division of Economic Development
EPA United States Environmental Protection Agency
FERC Federal Energy Regulatory Commission
NHC Northwest Hydraulic Consultants
NHI Natural Heritage Institute
NMFS
United States Department of Commerce – National Oceanic and Atmospheric
Administration
NPS United States Department of the Interior – National Park Service
RAC BLM Resource Advisory Council
SHPO State Historic Preservation Office
Stillwater Stillwater Ecosystem, Watershed and Riverine Sciences
USFWS United States Department of the Interior – Fish and Wildlife Service
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 1 December 2012
APPENDIX 3
Alaska Energy Authority’s Response to Comments on the Proposed Study Plan
(Consultation dated July 16 through early November, 2012)
NOTE: This table is a compilation of Technical Workgroup meeting comments and informal consultation between AEA and other
licensing participants from AEA’s filing of the Proposed Study Plan in July 2012, through its release of the interim draft Revised
Study Plan (RSP) at the end of October 2012, as well as some additional consultation in early November 2012. Based on written
comments filed with FERC following the release of the interim draft RSP through November 14, 2012, AEA made numerous changes
to the interim draft RSP when preparing the final RSP. See Appendices 1 and 2. Accordingly, many of the comments and responses
appearing in the table below have been superseded and are included primarily for purposes of documenting AEA’s consultative efforts
and the iterative process of developing the final RSP.
Comment
Format
Comment
Date
Licensing
Participant
Name
Licensing
Participant
Affiliation Comment or Study Request AEA’s Response
GENERAL/GLOBAL
Email 9/06/2012 Joseph Klein ADNR-
ADF&G
Project operations – We support the effort to provide
a means to evaluate future changes in the Susitna
River under different operation scenarios and also
recommend identifying a reference reach in a similar
Alaska river for using a BACI design monitoring
program to assess post project impacts.
As detailed in Section 8.5, AEA will be conducting
studies to assess various operational modes. AEA is
using the environmental flows proposed in the 1980s
as a starting point for assessing project operation
scenarios. AEA plans to investigate full load-following,
partial load-following based on primary use of load-
following from other existing hydro power projects like
Bradley Lake, Eklutna and Cooper Lake. AEA
recognizes that maintenance of ecosystem functions
may require an assessment of other operational
scenarios. These will be developed as resource needs
are identified through the environmental resource
assessments.
Email 9/07/2012 Betsy
McCracken
USFWS Biometric review – The Service previously requested
a biometric review of the 1980s findings. This request
is remains outstanding and should be conducted prior
to basing any study plans on 1980s studies or results.
In all cases, including the usage of the 1980s Su-
hydro data results and for the Susitna-Watana study
AEA is not conducting a biometric review of the data
collected in the 1980s for the Project. Instead, each
study plan in the RSP describes the extent to which—if
any—AEA is relying upon the1980s-era data and how
that data will be used to meet the goals and objectives
of the study plan.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 2 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
plans, estimates of precision and accuracy of study
results is required to evaluate the power of any study
plan. Details of proposed study plan sampling and
design methods need to be explicit and statistically
valid with a priori determination of levels of precision
and accuracy of model outputs.
As contemplated by FERC’s ILP regulations, AEA has
expended a significant effort to synthesize the 1980s
data. The results of the initial synthesis were
presented in the Pre-Application Document (PAD).
Over 3,000 documents were produced during the
intensive studies of the 1980s. AEA will continue to
review this information and include relevant information
in the currently proposed studies. This effort will
continue through 2013 and 2014.
Although the proposed APA project in the 1980s was
different than the anticipated RCC proposed Project
today, the historic environmental information remains
relevant, including from an historic and trends
perspective. Further, the impacts assessment should
not be discounted. Much of the assessment contained
in the 1983 application, FERC’s draft EIS, and the
1985 amended license application may be useful for
comparison of the impact assessment to be completed
for the 2015 License Application.
Email 9/07/2012 Betsy
McCracken
USFWS Studies integration – During the three days [August
15-17, 2012] of ILP study meetings, sequencing and
integration of the proposed biological resource studies
and the physical process studies was not described
and is still a significant outstanding information need.
It is necessary to describe the integration of these
inter-related studies and how that integration will
result in a comparison of the baseline biological
information and the resulting effects to biologic
resources caused by the proposed project
operations… The Service has repeatedly articulated
concerns about the lack of study sequencing,
connectivity and integration between the biological
studies and the other proposed engineering and
physical processes studies.
A detailed overview of the study plan process appears
in Section 2 of the RSP and includes a detailed study
plan schedule at Attachment 2-1, which has been
prepared at FERC’s request. In addition, for each of
the 58 studies proposed in the RSP, AEA has included
a section entitled “Relationship with Other Studies.”
This section provides a detailed narrative on how the
study uses outputs from other studies and/or provides
inputs to other studies. These interdependencies also
are illustrated graphically in each study plan. Although
this level of detail is not required by FERC’s ILP
regulations, AEA believes it important for all licensing
participants to understand the relationships within the
RSP and stay coordinated on these matters.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 3 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
A “map” or chart of how studies are proposed to be
integrated is needed. AEA sponsors and consultants,
committed to providing this by September. Biological
resource components are currently not integrated or
connected to the other studies, and appear as being
treated independently of the rest of the study
requests. Study proposals must demonstrate how
they will be integrated to provide needed resource
information.
Email 9/11/2012 Bob Henszey USFWS Studies integration – 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 PSP will rely upon
data from the Groundwater PSP, the Riparian
Instream Flow PSP should describe only the results
required from the Groundwater PSP, and then
describe how those results will be used in the Riparian
Instream Flow PSP (e.g., 5.7 Groundwater PSP
should be the only PSP that describes the
groundwater methods). This applies to other PSPs,
such as the habitat mapping studies that may be
providing data for this PSP.
AEA agrees with this comment. When preparing the
RSP, AEA decided to organize study plans by resource
area, to take advantage of common background issues
related to all studies in each resource area.
In addition, AEA prepared the RSP in a manner that
explains the interdependencies among the different
study, without overlapping the scopes of the different
plans. See above discussion related to
interdependencies.
Email 9/07/2012 Betsy
McCracken
USFWS Compensatory mitigation – Compensatory
mitigation is determined as part of a mitigation
sequence after avoidance, and minimization efforts.
The Service has inquired about potential
Each individual study plan has been designed to yield
sufficient information that will allow AEA, FERC, and
federal and state resource agencies to assess Project-
related effects of the resource. Based on the results of
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 4 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
compensatory mitigation for project impacts during
several meetings. To date, this concern has not
satisfactorily been addressed by the project sponsors
or project consultants. Because compensatory
mitigation is a requirement in order to offset
unavoidable projects impacts to fish and wildlife
resources and their habitats, it is should be
considered throughout the review process. Please
explain how you plan to quantify existing habitats, and
quantify primary, secondary and cumulative (40cfr
Part230 of the CWA) losses to those habitats under
the proposed operational flows over the temporal
scale of the license period. How will habitats change
proportionally under project operations?
these studies, AEA’s 2015 License Application will
include proposed protection, mitigation, and
enhancement measures. As appropriate, AEA in its
License Application may propose compensatory
mitigation as a means of addressing identified Project-
related effects.
Email 9/18/2012 Betsy
McCracken
USFWS Can you please provide a timeline for when resource
agencies can expect AEA to provide meeting minutes
from the August and the September ILP TWG
meetings? Also, requested is the documentation of
how AEA will address agencies identified
discrepancies and concerns related to proposed
approaches that were presented during the meetings.
We intend to have follow-up related to these
outcomes, and need to make concerted efforts toward
this goal. Resource agencies have many outstanding
and complex resource concerns yet to resolve with
AEA consultants related to the Susitna River basin
resources and their habitats; particularly under AEA's
proposed approaches within the study requests, and
would appreciate receipt of the follow-up information.
NMFS previously requested the August meeting
minutes, a few weeks ago. We are following up with
this secondary request, along with the additional
request for the September meeting materials.
Meeting summaries for the TWG meetings appear in
Appendix 4 of the RSP. For a discussion of how AEA
synthesized and responded to the comments made
during TWG meetings, as well as during more informal
consultation meetings and correspondence, from the
release of the PSP through the preparation of the
interim draft RSP, please see Section 2 of the RSP.
AEA’s responses to substantive comments received
during this period appear in this Appendix 3.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 5 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
SECTION 4 GEOLOGY AND SOILS
Geology and Soils Characterization Study (Section 4.5)
No comments.
SECTION 5 WATER QUALITY
General
Email 8/23/2012 Joseph Klein ADNR-
ADF&G
Information on availability of the Sampling and
Analysis Plan (SAP) and Quality Assurance Project
Plan (QAPP) is needed.
AEA will include in the SAP and QAPP in the RSP as
an attachment.
Baseline Water Quality Study (Section 5.5)
Email 8/23/2012 Joseph Klein ADNR-
ADF&G
5.5.4.3.2 In-Situ Water Quality Sampling The
sampling protocol currently calls for monthly in-situ
water quality monitoring for the 4 summer months. It
should be revised to include continuous (hourly or so)
water quality measurements for basic parameters (pH,
DO, conductivity, turbidity), year-round if possible
using in-situ semi-permanent sensors (e.g. sondes).
The technology is readily available and would provide
very useful baseline information to assess any post
project impacts.
Grab sampling of surface water has been proposed at
approximately every 5 river miles (39 sites). Grab
sampling of water for physical parameters allows for
better quality control, especially regarding calibration of
parameters such as DO and pH.
The use of multi-parameter probes would be
appropriate for the focus study areas where monitoring
of conditions is required to detect changes in water
quality that may affect aquatic life stages. This will be
performed in the Focus Areas selected for intensive
instream flow studies. (Section 5.5.4.5)
Email 8/23/2012 Joseph Klein ADNR-
ADF&G
Any monitors should be calibrated pre- and post-
monitoring along with multiple field measurements for
post monitoring calibration.
Agreed. The RSP’s QAPP will include this detail.
Email 8/23/2012 Joseph Klein ADNR-
ADF&G
GW Quality in Selected Habitats (Section 5.5.4.7) -
need more information on study. For example,
sampling intensity/number of site measurements per
slough or criteria for how they will be determined. Will
ground water level monitors be installed if so, what is
the sampling intensity (numbers per habitat type) and
duration of monitoring (e.g. continuous year-round/
point samples during field visits, etc.). If not, it is
This comment will be addressed more thoroughly when
the Focus Area intensive study site selection is
complete.
The RSP will include a process, criteria, and schedule
for selection of Focus Area. See RSP Section 5.5.4.5.
For each Focus Area, the sampling methodology will
be described, including sampling intensity/number of
site measurements per slough; whether ground water
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 6 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
strongly recommended groundwater monitoring be
performed concurrently with water quality monitoring
in this study.
level monitors will be installed, and sampling intensity
and duration of monitoring.
Water Quality Modeling Study (Section 5.6)
No Comments.
Mercury Assessment and Potential For Bioaccumulation Study (Section 5.7)
Letter 8/17/2012 Lori
Verbrugge
USFWS 1) Mercury modeling aspect is absent in all studies.
We need them to model mercury inputs into the
reservoir, amounts of mercury methylation, uptake
and biomagnification of methylmercury in reservoir
organisms including concentrations at each trophic
level, and transport of mercury downstream from the
reservoir, from date of initial flooding until 20 years
post-impoundment.
2) Avian piscivores - need to analyze feathers for
mercury content to determine baseline. This objective
is absent from the bird studies.
3) Actual risk assessment step is missing. We need
them to perform an ecological risk assessment for
each piscivorous species. Estimate the amount of
mercury ingested by individuals of each piscivorous
species, based upon dietary information and modeled
mercury levels in food items post-impoundment.
Compare ingested mercury amounts to toxic levels,
based on species-specific data from the scientific
literature. Note: this step is missing in the study plans
for avian species and aquatic furbearers.
Mercury modeling is being addressed in both the
Water Quality Modeling Study (Section 5.6.4.8) and the
Mercury Assessment and Potential for
Bioaccumulation Study plan (Section 5.7). Studies
have shown that the occurrence of mercury in newly
formed reservoirs is a relatively predictable
phenomenon, and that such predictions do not require
the degree of modeling requested. Avian piscivore
sampling is included in section 5.7.4.2.5.
A predictive risk analyses is included in Section
5.7.4.2.5.3. It is specific to avian piscivores and
aquatic furbearers.
Letter 8/17/2012 Lori
Verbrugge
USFWS 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
The text has been changed and clarified. See section
5.5.4.7. The text has been changed to reference
SQuiRT tables.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 7 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
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 species of fish
(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.
Letter 8/17/2012 Lori
Verbrugge
USFWS 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". a. 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.
This text has been clarified (Section 5.5.2); however,
several studies have shown that both metallic and
methylated mercury concentrations can vary
considerably between drainages and tributaries of the
same drainage. In the case of the Frenzel study,
significant differences were noted in mercury
speciation in sediment between Costello Creek and the
Deshka River, and the report attempted to explain
those differences based on tributary specific physical
conditions. It can be assumed that tributaries with
higher methylmercury concentrations in sediment and
water will also display higher methylmercury
concentrations in fish, particularly those (ex. Slimy
sculpin) that spend a majority of their time confined to
specific tributaries. The Frenzel study also reported
inorganic mercury in both Slimy sculpin and Dolly
Varden. This data has been added to the text. A
majority of mercury found in fish is methylmercury, and
the text did not mean to imply otherwise.
Letter 8/17/2012 Lori
Verbrugge
USFWS 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.)
a. This makes some sense, in order to understand the
amount of mercury in the fish that is clearly attributed
The goal is not to determine the current mercury
concentration in all species and model their
connections, rather it is to determine whether the
conditions for mercury methylation will be enhanced or
diminished by the dam (described in Section 5.7.1).
Target fish species in the vicinity of the Susitna-
Watana Reservoir will include adult Dolly Varden,
arctic grayling, long nose sucker, lake trout, whitefish
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 8 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
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.
species, burbot, and resident rainbow trout. If
possible, filets will be sampled from seven adult
individuals from each species.
Letter 8/17/2012 Lori
Verbrugge
USFWS Page 5-170, Section 5.12.4.5, "Pathway assessment
of mercury into the reservoir..."
a. 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.
The differences seem to be between the use of the
words “model” and “assessment”, and not in the
functional result.
The Water Quality Modeling Study (Section 5.6) will
generate a three-dimensional model of the proposed
reservoir. This model will allow us to evaluate the
potential for conditions conducive to mercury
methylation in the reservoir. If conditions for mercury
methylation are created, mitigation may be necessary.
Mercury impacts will be modeled in fish, piscivorous
birds, and aquatic mammals. (Section 5.7)
Letter 8/17/2012 Lori
Verbrugge
USFWS Section 5.12.6 Schedule: Two additional monitoring
activities needs to be added to this table and
scheduled.
a. Quantitative modeling of mercury inputs, rates of
methylation, and uptake by biota; and
b. Ecological risk assessment for mercury exposure to
avian and mammalian piscivores in the study area.
The planned modeling will generate predictions
regarding methylmercury concentrations in water,
sediment, and fish within the reservoir. It will also
model potential impacts to birds and aquatic mammals
(Sections 5.6 and 5.7).
Previous studies have found that increases in
methylmercury concentrations in a reservoir after filling
are not related to atmospheric deposition, geology, or
vegetation. Rather, they are due to mercury being
released from inundated fine organic soil particles
(Stokes and Wren, 1987; Abernathy 1979; Bodaly el
al., 1984, Newberry et al, 1983, Rudd, 1995, etc).
Rudd, for example, estimates that in a typical reservoir,
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 9 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
between 0.3 and 3% of the total mercury observed is
derived from precipitation.
Inorganic mercury deposition from the atmosphere is
not a significant source of mercury concentrations that
are elevated above background; however, they can be
a source of background mercury concentrations. The
goal of the study is to quantify mercury resulting from
filling the reservoir, not necessarily background
mercury.
Background mercury concentrations are better
predicted from studying mercury levels in nearby
natural lakes. Background lake studies are included as
part of the fish tissue sampling (Section 5.7.4.2.6).
Mercury levels in reservoirs typically are not source
limited, but are related to methylation rates in the
reservoir. The water quality model will predict
methylation rates in the reservoir (Section 5.6.4.8).
Letter 8/17/2012 Lori
Verbrugge
USFWS Page 5-17, paragraph 2 in total: 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.)
a. 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
The RSP has been modified (See Section 5.7.4.2.5).
Target fish species in the vicinity of the Susitna-
Watana Reservoir will be Dolly Varden, arctic grayling,
stickleback, long nose sucker, lake trout, whitefish
species, burbot, and resident rainbow trout. If
possible, filets will be sampled from seven adult
individuals from each species, given these fish will
show the highest background concentrations of
methylmercury. All fish species currently present in the
inundation zone will be sampled.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 10 December 2012
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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.
Letter 8/17/2012 Lori
Verbrugge
USFWS Page 5-17, paragraph 4: the report 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 laboratory experiments, using the same
or comparable piscivorous avian and mammalian
species.
EPA fish consumption advisories will be utilized for
human health protection. USEPA (1997) sets
reference doses for methylmercury in avian and
mammalian wildlife, and these have been referenced in
Section 5.7.4.2.5.3
Letter 8/17/2012 Lori
Verbrugge
USFWS Page 5-17, paragraph 5: the report 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".
This doesn't make sense. 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, you 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 this context,
because water levels do not relate directly to fish
This will be taken care of by mercury modeling under
EFDC. The model will predict if the conditions in the
reservoir will be conducive to mercury methylation.
Fish tissue mercury concentrations will be modeled
using methods described in Harris and Hutchison
(2008) and Hydro Quebec (2003). These modeling
methods predict future methylmercury concentrations
using existing background concentrations. Methylation
rates will be predicted using the water quality model
(Section 5.6).
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 11 December 2012
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levels.
TWG meeting 8/17/2012 Lori
Verbrugge
USFWS Explain the absence of macroinvertebrate sampling in
the PSP.
There are no plans for macroinvertebrate sampling at
this time. As with soil and vegetation, current mercury
concentrations in macroinvertebrates are poor
indicators of the potential methylmercury
concentrations in fish and wildlife, and most
methylmercury models do not utilize this data for that
reason.
Fortunately models for predicting methylmercury
concentrations in fish are well advanced and fairly
accurate (Harris and Hutchison, 2008, Hydro Quebec,
2003, etc). Methylmercury in fish tissues is generally
higher by an order of magnitude than that of their food
(Rennie et al, 2011). Therefore predictive models for
fish can be generally applied to macroinvertebrates.
In addition, impacts on other species are going to be
evaluated (Section 5.7.4.2.5.3).
Sampling of macroinvertebrates needs to be
conducted, if necessary, based on the pathway
analysis to define methylmercury generation and
bioexposure routes. Before this analysis is completed,
AEA will not know which sampling protocol to follow
because it will not know the specific community that is
at risk.
Letter 8/17/2012 Lori
Verbrugge
USFWS Page 5-17, paragraph 5: the report 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
This statement has been removed from the RSP. The
source of the mercury above background in reservoirs
is not typically the geology, or atmosphere, or woody
plant debris. If they were, mercury concentrations
would not decrease to background after only 20-30
years. Green vegetation (leaves of trees and shrubs)
and the top centimeters of humus are the primary
source of mercury in newly filled reservoirs. This was
first noted as far back as Abernathy and Cumbie
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 12 December 2012
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contributes to concentrations of this toxicant" must be
undertaken, 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 not the 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; unfortunately 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.
(1977), and is well understood science (Meister et al.
1979; Hydro Quebec, 2003, etc.).
Soil and vegetation sampling have been added to the
document, and an evaluation of potential geologic
sources in the inundation zone is planned (Section
5.7.4.2)
Current mercury concentrations in macroinvertebrates
are poor indicators of the potential methylmercury
concentrations in the future. Most methylmercury
models do not utilize this data for that reason.
Letter 8/17/2012 Lori
Verbrugge
USFWS Page 5-19, section 5.5.6 Schedule: Several needed
elements are missing, including the collection of
geomorphology, geology, vegetative type and
quantity, etc. needed to estimate 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.
Soil and vegetation sampling have been added, and a
geologic survey will be done for mineral deposits.
However, this information is not necessary for
estimating methylmercury impacts to fish. The
proposed study will provide mercury modeling for
methylmercury in water, sediment, fish, birds, and
aquatic mammals. The schedule can be found in
Section 5.7.6
Letter 8/17/2012 Lori
Verbrugge
USFWS Objectives Analysis: Two objectives contained in our
study request are not included in the AEA study plan.
These are:
1) Model mercury inputs into the reservoir,
amounts of mercury methylation, uptake and
biomagnification of methylmercury in reservoir
organisms including concentrations at each trophic
level, and transport of mercury downstream from the
reservoir, from date of initial flooding until 20 years
post-impoundment.
The study will be limited to predicting mercury impacts
to water, sediment, birds, aquatic mammals, and fish.
Methylmercury generation will be modeled in Section
5.6. AEA intends to model to a point where
methylmercury concentrations in the reservoir return to
background concentrations. This may be more or less
than 20 years. Other reservoirs have taken as little as
10 and more than 35 years to return to background
methylmercury concentrations (Hydro Quebec, 2003).
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 13 December 2012
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Letter 8/17/2012 Lori
Verbrugge
USFWS Page 5-37, paragraph 4: the report reads, "Organic
carbon content from inflow sources will be correlated
with mercury concentrations determined from the
Baseline Water Quality Study discussed in Section
5.5. Predicted water quality conditions established by
Project operations and that promote methylation of
mercury will be identified by location and intensity in
both riverine and reservoir habitats."
a. Nowhere in Section 5.5 or elsewhere does it
indicate how mercury inputs will be estimated based
on the specific vegetation, bedrock and soils in the
area to be inundated. Likewise, a specific model has
not been proposed to predict mercury inputs,
concentrations, or rates of methylation in the
reservoir. Neither the underlying data collection nor
the modeling activity necessary to quantify future
mercury levels in biota are contained within any of the
current study plans. This includes the area inundated,
and the pH, calcium concentration and water
hardness of the reservoir ... among other factors
Hydro Québec (2003) has studied these phenomena
extensively, and found the increase in fish mercury
levels after reservoir impoundment does not depend on
the mercury content of soil, rock, or vegetation, but
rather on the conditions within the reservoir after filling.
The variability in methylmercury concentrations within
reservoirs and drainages is based on the methylation
rate, not on the mercury source, which is largely
atmospheric for background mercury levels.
Samples of vegetation and soil will be analyzed for
mercury as part of this study; however, this information
does not directly input calculations for methylmercury
concentrations in fish and wildlife. It will be used as
part of evaluating potential mitigation strategies.
SECTION 6 GEOMORPHOLOGY
General
Memo 8/07/2012 Unspecified NPS Limiting downstream scope of this and other studies
to Talkeetna is unfounded. Until results of the
instream flow, ice, fluvial geomorphology, fish, and
other studies are available, cannot say how far
downstream project’s measurable effects on visual,
auditory resources will go. Vehemently disagree w/
this premature decision, which contradicts statements
elsewhere in this and other PSPs acknowledging
need to rely on the results of other studies.
The Fluvial Geomorphology Modeling Study area
downstream limit is currently identified at RM75;
however, components of the Geomorphology Study
extend to RM 0 or to RM 28. The initial determination
of the downstream limit was based on based on a
bedload sediment balance using USGS data from the
1980s. The downstream limit of the Fluvial
Geomorphology Study will be extended further
downstream if the studies indicate potential for the
Project to affect the of the channel morphology below
RM 75. Section 6.6.3.2 discusses the process, criteria
and schedule for establishing the downstream limit of
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 14 December 2012
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the Fluvial Geomorphology Modeling Study.
TWG Meeting 8/17/2012 Matt Cutlip /
Betsy
McCracken
FERC /
USFWS
D/S Limit of study – What is it, how and when will it be
determined. Would it be in the ISR if not reached in
RSP? Each study needs to identify the D/S extent and
put a mechanism in place to modify the boundaries if
needed.
The downstream limit of the Fluvial Geomorphology
Modeling is proposed at RM 75, which includes the
upper 23 miles of the lower river. Portions of the
Geomorphology Study will extend further. The reach
delineation and evaluation of historic channel change
extend to RM 0. Comparison of 1980s and current
aquatic habitat extend to RM 28. The initial extent of
the detailed study area was determined based on a
bedload sediment balance using USGS data from the
1980s. Additional discussion of the sediment balance
and the potential influence of the Project are discussed
in Section 6.5. More detailed sediment balance and
evaluation, within in a geomorphic framework, of
potential Project along with hydraulic routing to
determine downstream Project effects on stage and
discharge are being performed in 2012 and early 2103
to further evaluate the downstream modeling limits.
The results of the 1-D sediment transport modeling to
RM 75, will be evaluated to determine if the detailed
study area needs to be extend further downstream.
The process, criteria and schedule for determining the
downstream extent of the detailed study area are
presented in Section 6.6.3.2
TWG Meeting 8/17/2012 Jeff Davis ARRI Is the Eulachon Study tied to Geomorph Study? In the sense that the geomorphology of the Susitna
River helps define the habitat for the eulachon; The
Geomorphology Study is tied to the Eulachon Run,
Timing, Distribution, and Spawning in the Susitna River
study. Initial evaluation of the potential for the Project
to affect the geomorphology of the lower river has
indicated it is unlikely that Project effects will extend
into the lower river downstream of Sunshine (RM 84).
To be conservative, the downstream limit for the Fluvial
Geomorphology Modeling Study has been initially set
at RM 75. If, as the studies progress, additional
analysis and information suggest the Project may
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 15 December 2012
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impact the morphology D/S of RM 75, the study limit
will be extended D/S. Section 6.6.3.2 discusses the
process, criteria and schedule for establishing the
downstream limit of the Fluvial Geomorphology
Modeling Study.
Email 8/23/2012 Joseph Klein ADNR-
ADF&G
For the eulachon and boating studies, similar
information is needed on what is the study area.
The currently identified downstream study limit for the
Fluvial Geomorphology Modeling Study is RM 75.
Initial evaluation of the potential for the Project to affect
the geomorphology of the lower river has indicated it is
unlikely that Project effects will extend into the lower
river downstream of Sunshine (RM 84). To be
conservative, the downstream limit for the Fluvial
Geomorphology Modeling Study has been initially set
at RM 75. Therefore, in terms of the potential for
boating to be affected by changes in the
geomorphology as a result of Project operations and
construction will not extend below RM 84. This would
be the D/S limit of interaction of the boating Study with
the Geomorphology Study. Based on the initial
assessment Project effects on geomorphology would
not extend downstream into the habitat for eulachon. If,
as the studies progress, additional analysis and
information suggest the Project may impact the
morphology D/S of RM 75, the study limit will be
extended D/S Section 6.6.3.2 discusses the process,
criteria and schedule for establishing the downstream
limit of the Fluvial Geomorphology Modeling Study.
Letter 9/07/2012 Betsy
McCracken
USFWS If the physical studies boundary is terminated at river
mile 75, there will be no ability to relate or integrate
biological data to those studies (e.g., geomorphology,
ISF, ice processes, flow routing). Resource agencies
management goals would effectively not be
addressed below river mile 75, if project effects are
not assessed to the mouth of the river.
In terms of the Fluvial Geomorphology Study, the
downstream study limit was set at RM 75 because
initial evaluation of available sediment transport
information indicated that the Project would not affect
the morphology of the Susitna River downstream of
Sunshine Station (RM 85). If the Project does not
affect the morphology below RM 75, there will be no
impact on the resource agencies goals from this aspect
of the physical environment. If, as the studies progress,
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 16 December 2012
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additional analysis and information suggest the Project
may impact the morphology D/S of RM 75, the study
limit will be extended D/S. Section 6.6.3.2 discusses
the process, criteria and schedule for establishing the
downstream limit of the Fluvial Geomorphology
Modeling Study. In terms of the Ice Processes Study,
the physical study extends to the mouth of the river, as
described in Section 7.6, Study Area.
Email 9/07/2012 Betsy
McCracken
USFWS Instream Flow, Habitat Utilization, Geomorphology
PSPs do not fully address USFWS’ resource mgmt.
concerns. During 3 days of ILP study meetings,
sequencing and integration of proposed biological
resource studies and physical processes was not
described; significant outstanding info needed.
To address USFWS resource management concerns,
AEA has expanded the discussion and figures in
Section 6.5.6 and 6.6.6 to show the integration and
interdependency of the Geomorphology Study and
Fluvial Geomorphology Modeling studies with
biological resource and other physical process studies.
Email 9/07/2012 Betsy
McCracken
USFWS Necessary to describe the integration of inter-related
studies, how that integration will result in a
comparison of baseline biological info, resulting
effects to biological resources caused by project
operations.
AEA has revised Section 6.5.6 and 6.6.6 to provide
more detail on how the integration of inter-related
studies will address baseline biological information and
allow for an assessment of potential project effects.
E-mail 9/07/2012 Betsy
McCracken
USFWS USFWS has repeatedly articulated concerns about
lack of study sequencing, connectivity, integration
between biological studies, other proposed
engineering and physical processes studies. Need for
collection of adequate temporal and spatial baseline
biological, fish habitat data to provide direct input to
some of proposed physical modeling efforts. Many
USFWS concerns are related to temporal mismatch of
biological data collection w/ forward momentum of
physical modeling efforts.
To address USFWS resource management concerns,
AEA has expanded the discussion and figures in
Section 6.5.6 and 6.6.6 to show the integration and
interdependency of the Geomorphology Study and
Fluvial Geomorphology Modeling Studies with
biological resource, other physical process studies and
the engineering studies (Operations Modeling and
Soils & Geology).
Email 9/07/2012 Betsy
McCracken
USFWS Do not believe current Instream Flow, Habitat
Utilization, Geomorphology PSPs will yield sufficient
info to allow USFWS to adequately assess proposed
SuWa Project impacts to US fish, wildlife resources,
and to develop adequate PMEs.
The Geomorphology Studies are integrated with the
Instream Flow and Habitat Utilization studies as well as
numerous other studies. The Geomorphology Study
has been specifically designed to provide the Instream
Flow studies with information on potential Project
effects to the Geomorphology of the Susitna River that
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 17 December 2012
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would result in changes to the physical habitat. Section
6.6.4.1.2.1 provides examples of the issues that the
Fluvial Geomorphology Modeling Study was designed
to address.
E-mail 9/07/2012 Betsy
McCracken
USFWS Study results must be quantifiable to: assess
potential losses to aquatic resources, habitats; review
SuWa Project under relevant fish, wildlife resource
conservation authorities; inform fishway prescription
authority (Sec. 18 FPA); eventually develop
recommended protection, mitigation, enhancement
measures.
The Study Plans for the Geomorphology Study
(Section 6.5) and Fluvial Geomorphology Study
(Section 6.6) have been developed to provide the
biological resources and other physical process studies
with evaluation of potential changes in the
geomorphology of the Susitna River that can be used
to support determination of habitat indices under with
Project conditions. For instance, the 1-D and 2-D bed
evolution models will identify if the substrate size
changes below the dam or if downcutting results in less
connectivity to off-channel habitats. The 2-D modeling
at focus areas can identify the potential change in the
rate of sedimentation and floodplain building which will
provide information for the IFS Riparian study to
quantify potential changes to riparian plant
communities. of potential changes in channel and
floodplain morphology to support their assessments of
potential habitat losses.
Geomorphology Study (Section 6.5)
TWG Meeting 8/17/2012 Jeff Davis ARRI Will the studies be able to identify how sediment
passed out of Middle effects the Lower Reach?
Yes. The sediment dynamics between the middle river
and the lower river will be evaluated in Section 6.5.4.3
as part of the sediment balance calculations as well as
in the 1-D modeling effort in Section 6.6. The latter
effort will include modeling to at least RM 75. The
former effort looks at the sediment balance to Susitna
Station (RM 28).
TWG Meeting 8/17/2012 Jay Stallman Stillwater /
FERC
It would be useful to further define the stratification
system on a local and reach scale.
The first two levels of the stratification system are the
river segment and geomorphic reach. These are
described in Section 6.5.4.1. The remaining 3 levels
are described in the Fish Studies. The stratification
system includes river segment, geomorphic reach,
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 18 December 2012
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macroscale habitat (main channel and off-channel
habitats), mesoscale habitat, and microscale habitat
levels. Additional information on the geomorphic reach
characterization system has also been provided in
Section 6.5.4.1 including an initial reach delineation
and identification of geomorphic reach types.
TWG Meeting 8/17/2012 Eric Rothwell NMFS Add proposed sediment measurement stations to map
to identify locations where USGS is collecting 2012
Data
Figure 6.5-5 has been added to RSP showing the
Susitna River above Tsusena Creek, the Susitna River
at Gold Creek/ above Talkeetna, the Susitna River at
Sunshine and the Chulitna River near Talkeetna
gages.
TWG Meeting 8/17/2012 Jay Stallman Stillwater /
FERC
Will bank erosion be evaluated? Yes. Bank erosion will be evaluated using the
historical aerial photo analysis and by comparison of
the 1980s cross-sections with cross-sections surveyed
in 2012 at the same locations (See Sections 6.5.4.4).
The volume of sediment from bank erosion will be
included in the sediment balance describe in Section
6.5.4.3.2.2.
TWG Meeting 8/17/2012 Jay Stallman Stillwater /
FERC
Will sediment budget look at sizes? Yes. The sediment budget will consider sediment in at
least three size ranges, fines or wash load (silts and
clays), sand, and coarse sediments (gravel and
cobble). The balance will also consider in terms of bed
material load and suspended load. The RSP includes
additional details and clarification of the sediment
budget calculations including a distinction of the initial
sediment budget developed to support the initial
determination of the downstream study limit and a
more detailed sediment budget to assist in developing
the sediment supply for the fluvial morphology
modeling effort. The details of the sediment balance
have been revised and are presented in Section
6.5.4.3.
TWG Meeting 8/17/2012 Jeff Davis ARRI Explain the use of effective discharge in the
geomorphology study
Effective discharge discussion in Section 6.5.4.3.2.4
was expanded to further describe its use in the overall
assessment of potential channel change as a result of
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 19 December 2012
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Project alterations to sediment transport capacity and
discharge. Effective discharge is one means of
identifying the potential for increase or decrease in
channel dimensions as a result of alteration of flow and
sediment transport capacity.
TWG Meeting 8/17/2012 Jeff Davis ARRI Tributaries dump a good amount of sediment during
storm events. Are they being accounted for in the
Study?
Yes. Tributaries are included in the detailed sediment
transport balance described in Section 6.5.4.3.2.2 and
as a source of sediment supply in the 1-D and 2-D
modeling efforts. The discussion of determination of
tributary sediment supply is described in Section
6.6.6.4.1.2.6.
TWG Meeting 8/17/2012 Jeff Davis ARRI Is the scale of the LWD study such that the influence
of LWD on aquatic habitat in the sloughs be
determined (4th of 4 parts)?
Yes, the scale will be sufficient to assess the influence
of LWD on aquatic habitat in the sloughs. The
following wording is included in the LWD study
component described in Section 6.5.4.9: “Observations
and discussion of how large woody debris is currently
functioning in the Susitna River, including a discussion
of interactions with riparian and aquatic/fish habitat,
geomorphic processes (sediment transport/channel
forming processes), ice processes, and flows.”
TWG Meeting 8/17/2012 Eric Rothwell NMFS Will the reservoir erosion study look at the potential
different dam designs (heights)?
Yes. The reservoir Geomorphology Study component
(Section 6.54.8) will consider the reservoir inundation
zone and a band 100 feet above the high water and
covers all potential reservoir heights being considered.
Fluvial Geomorphology Modeling below Watana Dam Study (Section 6.6)
TWG Meeting 8/16/2012 Jay Stallman Stillwater /
FERC
Will the geomorphology effort model different
operational scenarios and come up with new channel
patterns?
Yes. Both the 1-D and 2-D sediment transport models
will be run to evaluate operational scenarios. Section
6.6.4.2 provides a description of time frame for each
model. The 1-D model will provide a 50 year simulation
of the overall aggradation/ degradation response of the
system, including general changes in bed material
composition, under both baseline (existing) and project
conditions. Due to computational limitations, the 2-D
model cannot reasonably be run for a 50-year period;
however, runs will be made for individual (i.e.,
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 20 December 2012
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seasonal) hydrographs for both baseline and project
conditions, and the results will be used to assess how
changes in flow and sediment regime under project
conditions will affect bed evolution. Although specific,
long-term changes in bed topography and channel
patterns cannot be made, the trajectory of these
changes can be inferred from a combination of the
short-term 2-D results and the long-term 1-D results.
TWG Meeting 8/17/2012 Jeff Davis ARRI Can the model look at spawning habitat modification
for chum (referring to the specific chum spawning
area identified for the Whiskers Slough Site in the
1980s)?
Yes. The 2-D sediment transport model is capable of
simulating the physical processes at the resolution
necessary to identify changes in hydraulic conditions
and bed material (substrate) in areas such as the chum
spawning site identified in the 1980s study at the
Whiskers Slough site. To model these areas, a finer
mesh will be used. Specific areas to provide a finer
mesh size to investigate specific aspects of local
hydraulics, bed material and sedimentation processes
will be evaluated and determined for each of the focus
areas through coordination with the Fish and Aquatics
Instream Flow Study, Riparian Instream Flow Study,
Groundwater Study, Ice Processes Study and Fish
Study and in collaboration with the relicensing
participants. Discussion of varying the mesh site to
focus in on specific areas of interest such as spawning
areas and off-channel habitats has been added to
Section 6.6.4.1.2.3
TWG Meeting 8/17/2012 Matt Cutlip FERC During the general discussion on site selection, it was
indicated that AEA will need to justify use of 6 sites (or
whatever number)
The process, schedule and criteria for selection of the
focus areas are provided in Section 8.5.4.2 of the Fish
and Aquatics Instream Flow Study. Section 6.6.4.1.2.4
describes the role of the Geomorphology Study in the
selection process. The site selection process is a
collaborative effort between the Fish and Aquatics
Instream Flow Study, Riparian Instream Flow Study,
Groundwater Study, Fish Study and Ice Processes in
the Susitna River Study and coordinated with the
relicensing participants. It is noted that the fluvial
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 21 December 2012
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geomorphic analysis presented in Section 6.5 and the
1-D sediment transport modeling presented in Section
6.6 will be performed for the entire detailed study area
(currently proposed as RM 184 to RM 75 excluding
Devils Canyon).
TWG Meeting 8/17/2012 Jay Stallman Stillwater /
FERC
Need more detail on specific geomorphic data to be
collected at the sites.
AEA has modified to Section 6.6 to describe the field
data collection program that will be conducted in 2013.
Section 6.6.4.1.2.8 has been added to present the field
data collection effort. The field data collection effort
described in this section covers the collection of data
for both the Geomorphology Study (Section 6.5) and
the Fluvial Geomorphology Modeling below Watana
Dam Study (Section 6.6). Major activities at focus
areas will include bed material sampling, bathymetric
and cross-sectional data collection, mapping of
geomorphic features, and characterization of physical
process at each focus area. Additional data will be
collected outside the focus areas such as cross-
sections to supplement the 2012 data available for the
1-D model, additional bed material samples for the 1-D
model, and identification and/or verification of controls
and other geomorphic features identified from aerial
photographs and available mapping. Data will be
collected in conjunction with field efforts being
performed by the Instream Flow Fish, Instream Flow
Riparian, Groundwater, and Ice Processes Study.
TWG Meeting 8/17/2012 Jay Stallman Stillwater/
FERC
USFWS and NMFS request pebble counts in their
Study Plans. We need to have more detail as to
where and when we will do pebble counts
The requested detail on bed material sampling has
been included in the description of data collection
added to Section 6.6.4.1.2.8. Bed material samples will
be collected at both the Focus Areas as well as at
other locations in the study area.
TWG Meeting 8/17/2012 Henszey/
Davis / Steele
USFWS/
ARRI / ADNR
OPMP
General discussion on the mesh size for the 2-D
model with questions concerning: what will the size
be? Will field results influence it? When will size be
selected?
The 2-D sediment transport model selected for the
focus areas will have a variable mesh size. This will
allow a finer mesh to be applied to areas in which the
scale of the feature being modeled (for example side or
upland sloughs) requires a finer mesh size than other
Revised Study Plan
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FERC Project No. 14241 Page 22 December 2012
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areas of the model. Larger mesh sizes can be used in
the main channel to allow for more efficient execution
of the model. However, even within the main channel,
a finer mesh can be applied to provide higher
resolution in areas such as spawning sites. More detail
on the use and selection of the 2-D model mesh size is
provided in Section 6.6.4.1.2.3.
TWG Meeting 8/17/2012 Eric Rothwell NMFS Will additional cross-section be selected at areas that
aren't hydraulic controls and added to the 1-D model?
This question was brought up since the hydraulic
routing model data collection likely concentrated on
hydraulic controls, but these may not be the best
features for describing sediment transport processes.
Yes. AEA will collect additional cross-sections to
supplement the cross-sectional data collected in 2012
to support the hydraulic routing model development.
Cross-section sites will be chosen in conjunction with
the Fish and Aquatics Instream Flow Study, Riparian
Instream Flow Study, Groundwater Study and Ice
Processes in the Susitna River Study. These additional
cross-sections are discussed as part of the fieldwork
described in Section 6.6.4.1.2.8
TWG Meeting 8/17/2012 Jay Stallman Stillwater /
FERC
How will the 2-D model be calibrated? Yes. AEA has included additional discussion of the
calibration of the 2-D fluvial geomorphology model in
Section 6.6.4.1.2.5. This includes discussion of the
calibration of hydraulics (velocity, depth and flow
distribution) and sediment transport conditions.
Email 8/23/2012 Joseph Klein ADNR-
ADF&G
Will 2-D modeling include side channels and sloughs
within study area?
The decision to apply 2-D modeling will be evaluated at
focus area in coordination with the IFS-Fish, IFS-
Riparian and groundwater studies. 2-D modeling of
side channel and sloughs will be utilized at the focus
areas as appropriate when complex hydraulic
conditions exist that are more accurately and
effectively analyzed with 2-D hydraulic and sediment
transport modeling. Section 6.6 describes the
application of 2-D modeling of fluvial geomorphology.
Email 9/11/2012 Bob Henszey USFWS RISF-5 Characterize the Role of Sediment Deposition
in the Formation of Soils: The proposed soil sampling
techniques are included in Section 6.6.4.3.1.5, but
based on these techniques it is unclear how the
USFWS requested objective to characterize the role
The Fluvial Geomorphology Modeling below Watana
Dam Study will assist the Instream Flow Riparian
Study in determining the potential effect of the Project
on the rate of sediment deposition in the floodplain.
This will include modeling of the sedimentation process
Revised Study Plan
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FERC Project No. 14241 Page 23 December 2012
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of sediment deposition in the formation of floodplain
and riparian soils, and how sediment deposition
affects the rate and trajectory of plant community
succession. 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.
at the focus areas for both existing conditions and for
various operational scenarios. Information developed
from the Riparian Instream Flow Study on existing
rates of floodplain deposition will be adjusted based on
comparison of the frequency of inundation and
alteration of sediment delivery under with Project
scenarios. This will provide an assessment of the
change in the rate of floodplain building under Project
conditions. This aspect of the Fluvial Geomorphology
Modeling below Watana Dam Study is discussed in
Section 6.6.4.1.2.8.
SECTION 7 HYDROLOGY-RELATED RESOURCES
General
No comments.
Groundwater Study (Section 7.5)
Email 8/23/2012 Joseph Klein ADNR-
ADF&G
What are the monitoring well placement sampling
approach (e.g. equal spacing along linear transects,
etc.) and location (e.g. for instream flow, in all habitat
types?) for the various resource studies (i.e. instream
flow, riparian instream flow, water quality). Also, a
description of sampling intensity would be helpful (i.e.
for instream flow purposes, will the objective be to
characterize entire gw/sw interaction throughout entire
intensive study site [Focus Area] or only at select
microhabitats).
AEA has included more detail in the Groundwater RSP
Sections 7.5.4.5 and section 7.5.4.6 pertaining to well
place sampling approach and location. In general, the
placement of wells in transects will be determined by
local hydrologic boundary conditions. Wells are
generally placed close to a boundary (stream, slough,
main channel) and then at increasing distance away
from the boundary to help measure the pressure
response from rising and falling stage levels in surface-
water features (internal/external modeling boundaries).
Additionally, some wells will be placed in key areas
related to riparian habitat, key instream flow study
needs, or to help identify hydrologic conditions near
groundwater model or study area boundaries. Within
each Candidate Focus Area (CFA), there will be
area(s) where groundwater analysis will be focused. In
some of the CFAs, this may cover a majority of the
CFA area, in others it may only be a portion. The
groundwater analysis areas will encompass the
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
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internal focus areas for riparian and instream to help
provide the groundwater portion of the hydrologic
framework being used for analysis by the various
studies.
Email 8/23/2012 Joseph Klein ADNR-
ADF&G
What is the duration for monitoring (I believe at the
meeting it would be from installation until winter 2013-
14?)
The duration of monitoring will vary for different
hydrology data collection programs. The current
network of gaging stations started in summer of 2012
will continue operations through the winter of 2012/13
into 2013 and 2014. Technical evaluations will be
made in the summer of 2014 as to which gaging
stations need to be operated during the winter of
2014/15. Groundwater monitoring programs will begin
at a small scale in winter 2012/13 and the increase
during summer of 2013. The monitoring of groundwater
wells will continue into 2014,. At that time, a subset of
the groundwater wells may be monitored for the winter
of 2014/15.
Email 8/23/2012 Joseph Klein ADNR-
ADF&G
How often will monitoring wells be calibrated for
various parameters to be sampled pre- post- and
during field monitoring?
Monitoring wells will be surveyed with a combination of
RTK survey methods and optical level loop methods.
This will be done at least two times a year, or more
frequent if well movements are recorded. Pressure
transducer measurement will be verified with manual
measurement at least month during summer months,
and 3-4 times during winter periods. Both calibration
(for determining offsets) and verification water levels
will be collected. Conductivity and temperature sensors
will have calibration checks performed before field
installations and field calibration checks monthly during
summer months. Calibration checks during winter
months will be performed at least once during the mid-
winter period when safe access and weather
conditions allow, and before spring break-up and fall
freeze-up. This process will be further described in the
Groundwater Study Plan in section 7.5.4.5 and section
7.5.4.6.
Revised Study Plan
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FERC Project No. 14241 Page 25 December 2012
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Email 9/07/2012 Betsy
McCracken
USFWS The integration of the groundwater study efforts with
the biological studies is not clear. Specifically, how
will the groundwater study be made relevant to the
scale of fish habitat and fish habitat site selection in
the Susitna River? The objectives of the groundwater
study should include relevance to the hierarchially
nested habitats, including macro-, meso-, and micro-
habitats that are influential to fish habitat selection.
The groundwater study sampling design should be
relevant to fish habitat and site selection. A specific
objective needs to be measuring the hydraulic
gradient/head (upwelling or downwelling) under the
existing hydrograph and under the proposed project
hydrograph release flow schedule.
In the RSP, AEA has clarified how fisheries studies
have been incorporated into the instream flow and
groundwater aquatic studies. The groundwater
aquatics study is coordinating with both Instream Flow
and Fisheries studies on the selection of Focus Areas
(FAs). The Groundwater Study will be measuring the
both horizontal and vertical head gradients through
combinations of nested wells installed at different
depths and shallow wells installed in surface-water
habitat areas to measure the gradients between
surface-water sources and underlying groundwater
conditions. Details on the measurement of fluxes can
be found in the RSP in section 7.4.5.6. These
gradients will be compared with simulated gradients
from groundwater/surface-water models under the field
conditions measured in 2013 and 2014 and compared
with project operation scenarios.
Email 9/11/2012 Bob Henszey USFWS Section 6.6.4.5 (Groundwater): The suggested four to
six intensive study reaches 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
pseudoreplication discussion above). However,
hydrology is likely the most dominant physical factor
required for maintaining floodplain plant communities
across the various process-domains, and baring some
other dominant physical factor (e.g., soil parent
material, weather, etc.) it may be possible to use data
from the individual intensive study-site transects to
build response curves (see Henszey et al. 2004
{ne.water.usgs.gov/platte/reports/wetlands_24-3.pdf},
Figure 7 for an indication of the number of data points
required to build a response curve).
The purpose of the Focus Areas (FAs) is to develop
intensive enough data collection and analysis
programs to define the groundwater/surface-water
interactions and hydrologic cycle processes in a variety
of environments so the process understanding can be
used at the larger scale to evaluate potential Project
affects and methods for alternating Project operations
to reach desired management goals. The CFAs will be
used in conjunction with hydrologic analysis to help
inform the Project and agencies on the hydrologic
interactions and range of natural variability in the
system. Response curves for the CFA’s will be
evaluated as part of the Riparian Groundwater Study
(see RSP 8.6.4.5).
Email 9/11/2012 Bob Henszey USFWS One-and-a-half growing seasons (July 2013 to
September 2014) will likely provide insufficient
groundwater hydrology data to fit individual species
The study schedule for riparian growing seasons is
sufficient. The model simulation tools will be used to
re-analyze past hydrologic conditions (such as recent
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 26 December 2012
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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. Precipitation may also dramatically affect
transient but critical groundwater levels (a few days to
a week or more of elevated water levels), which would
be difficult to evaluate with limited data. How will
these potential problems be addressed?
years or 80s information) to gain additional data for
the development of responsive curves. Data from
Long-Term Ecological Research (LTER) sites such as
the Bonanza Creek Experimental Forest (BCEF) will be
compared with the evaluations in the Susitna riparian
study areas to help expand the process understanding
of riparian responses to groundwater/surface-water
interactions.
Precipitation data will be measured at each of the
riparian focus areas. Shielded summer precipitation
gages will be installed in early spring 2013 in time for
the 2013 summer season. The information will be
compared with the recent update to the statewide
precipitation evaluation and new index maps.
Additionally, precipitation information collected by the
Glacier Runoff Study will be incorporated into the
precipitation analysis for the riparian focus areas.
Email 9/11/2012 Bob Henszey USFWS In addition to the Work Products described in Section
6.6.4.5.2, the products should provide water-level
summary statistics for each location (e.g., point, plot,
or transect) 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
{ne.water.usgs.gov/platte/reports/wetlands_24-3.pdf},
Table 1).
The Groundwater Study will provide the time series for
measured and simulated groundwater levels to help
provide the summary statistics needed for developing
plant-response curves. This is further described in the
Riparian Instream Flow Study Plan in Section 8.6.4.5
(previously in Section 6.6.4.5.2).
Email 9/11/2012 Bob Henszey USFWS Section 6.6.4.7 (Succession Models and Flow
Response Guilds) appears to potentially address the
USFWS's Objective 6 request; however, two critical
referenced papers (Merritt et al. 2010 and Pearlstine
et al. 1985) were not included in the Literature Cited.
These references were not provided until 8/28/2012,
and the USFWS has had insufficient time to review
these papers in detail. The concept of the PSP
Additional detail has been added to the Riparian
Instream Flow RSP Section 8.6.4.7 to demonstrate that
USFWS Objective 6 will be met by the proposed
methods. A description of the hydrologic gradient
analyses is provided in Section 7.5: Groundwater.
AEA has revised the Groundwater RSP at Section
7.5.4.5] to provide more detail to show how quantifiable
hydrologic gradient will be constructed. The
Revised Study Plan
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FERC Project No. 14241 Page 27 December 2012
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response guilds is similar to the USFWS's request to
develop plant community response curves, but the
PSP methods are insufficient to evaluate if our
requested Objective 6 will be met. The USFWS
requested evaluating specific water-level summary
statistics (see above discussion for groundwater) with
a rigorous curve-fitting technique similar to Henszey et
al. (2004). The methods should provide sufficient
detail to show how quantifiable (not qualitative)
hydrologic (surface-water and groundwater) gradients
will be constructed to show the optimum and range of
favorable water levels required for maintaining
floodplain species/communities.
groundwater and surface water field measurements for
continuous monitored stations will be 15 minutes or
less. Model simulations will also 15 minutes or less,
based on analysis of modeling results. This information
will produce time series data sets, from which water
level summary statistics can be calculated for a range
of analysis objectives, such as running averages in
hourly and daily increments.
Ice Processes In the Susitna River Study (Section 7.6)
Email 9/12/2012 Eric Rothwell NMFS I have a concern with winter flow routing and ice
processes, and how they will inform site
selection. Site selection for analyzing winter instream
flow effects to fish and their habitat will depend on an
understanding of operational effects downstream (to
flow timing and quantity, hydraulics, and water
quality). Also the extension of the studies
downstream will depend on these results. The winter
hydraulic flow routing model will rely on ice process
modeling to determine the downstream extent and
magnitude of operational flow effects. The ice
process modeling will need several years of data, in
addition to the ice thickness measurements and
discharge measurements at each of the cross-
sections for the winter routing model. I see a lack of
time to collect data for the models (winter flow routing
and ice process) calibrate the models and then
selection sites and methods to conduct ISF studies to
assess project effects on fish during winter operations
under the currently proposed study period.
See Ice Study Interdependencies (Figure 7.6-1 and
7.6-2) and Schedule (Table 7.6-1) for a description of
how ice processes model input and output are
scheduled.
Final winter flow routing/ice model results for project
conditions will not be available prior to selection of
focus areas. The selection of candidate focus area
sites will use prior information (80s and other), current
2012 studies and professional judgment to select sites
that would be affected by changes to winter flow.
Preliminary results from a steady-flow HEC-RAS model
with ice cover can be used to estimate the potential for
stage changes in the lower river. For instance, if the
HEC-RAS model indicates that winter discharges will
be higher than the natural range of variability in the
Lower River, marginal habitats that would be
susceptible to under-ice inundation may be selected.
The proposed model development and simulation
goals will continue to inform the study teams during the
2013-14 study period so that information can be used
to help refine studies, as technical and scientific
Revised Study Plan
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FERC Project No. 14241 Page 28 December 2012
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analysis warrants. This adaptive approach will help the
concurrent studies each run in parallel, helping
address both the concerns of study timeframes and
adaptive approaches to modifying study designs as
additional knowledge is gained.
Email 9/12/2012 Eric Rothwell NMFS • What can be determined from each of the
study components, a description of
deliverables (not results) this will help us
understand if our requests have been met.
• How will uncertainty be determined for each
of the study components? (ice processes ->
hydraulic flow routing -> winter fish and
habitat effects)
AEA has included in the Ice Processes in the Susitna
River RSP Section 7.6.4 description of study
components and deliverables (including field data
collected and model output). 7.6.4.4 describes how
the ice processes model uncertainty will be assessed
by comparing the results of the existing conditions
model to known conditions, and by evaluating the error
associated with model input and generalization of
physical processes by model equations.
TWG Meeting 10/23/2012 Gary Van Der
Vinne
NHC • Will there be enough data to calibrate a 1-D
model after one season of data collection?
Will the 1-D existing condition model be
updated after 2013 if new information is
collected?
The 1-D model will be calibrated with data from 2012
and ice thickness, elevation, and meteorological data
from the 1980s. AEA will update the RSP to extend
the calibration of the 1-D model past 2013 if conditions
warranting and updated calibration are encountered.
TWG Meeting 10/23/2012 Gary Van Der
Vinne
NHC • Was there sufficient climate variability in the
1980s observations to encompass the range
of expected conditions?
Section 7.6 of the RSP has been updated to expand on
the range of climate conditions encountered in the
1980s. Cold, warm, and average conditions are well
represented, but warmer conditions have occurred
since the 1980s, and would be expected to occur in the
future.
TWG Meeting 10/23/2012 Felix
Kristanovich
ENVIRON • Will climate change be considered in the Ice
Processes modeling?
Climate change will not be considered in the ice
processes modeling. However, the post-project
conditions to be modeled will include unusually warm
conditions, unusually cold conditions, and average
conditions. The unusually warm conditions model
should encompass the range of temperatures expected
due to climate change.
Glacier and Runoff Changes Study (Section 7.7)
No comments.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 29 December 2012
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SECTION 8 INSTREAM FLOW STUDY: FISH, AQUATICS, AND RIPARIAN
General
No comments.
Fish and Aquatics Instream Flow Study (Section 8.5)
Email 8/01/2012 Betsy
McCracken
USFWS Relative to the proposed Instream Flow (ISF),
Groundwater and Habitat Utilization study plans,
would you please provide a summary of recent
fieldwork conducted or currently in the works from this
summer (2012) season?
A summary of the 2012 field efforts will be provided in
the Section 8.5.4. Instream flow related fieldwork
conducted during the summer of 2012 includes 1)
measurement of nearly 100 main channel transects to
use in the mainstem summer flow routing model, 2)
aerial photography and videography that will be used in
habitat delineations and 3) pilot HSC/HSI data
collection.
Email 8/02/2012 Joseph Klein ADNR-
ADF&G
Following up with the suggestion below, additional
information that would be helpful with development of
the study design would be a summary of the relative
proportions of channel types. It would be great if the
information was combined with relative densities of
documented fish use. I see that some of this
information is included in the proposed study plan and
so I’m not clear on when this information will be
available.
The relative proportions of channel types were
identified during early 1980s study efforts along with
estimates of fish use by habitat type. This information
will be supplemented by remote sensing studies
conducted during September-October 2012 to identify
the distribution of habitat types under existing
conditions (RSP Section 9.9). The 2012 remote
sensing habitat data will be available by 1st Quarter
2013. Study efforts to be conducted during 2013 and
2014 will document fish use by habitat type under
existing conditions and will be presented in the ISR
and USR (RSP Section 9.6). Information on the
proportion of channel types and associated fish use will
be used to identify the need for modifications to Focus
Areas and weight habitat modeling results in 3rd
Quarter 2014 (Section 8.5.4).
Email 8/02/2012 Joseph Klein ADNR-
ADF&G
As you know, this information is one of the initial steps
for identifying sampling strategies (representative
reach vs. macro habitat), habitat selections as well as
modeling selections (transects, weighting protocols,
hydraulic and habitat simulation programs,
aggregation protocols, etc.). Two key issues that I am
Regarding issue one, habitat modeling selection will be
based on applying one or more methods most
applicable for addressing the flow related questions
within a given habitat type. Table 6.5.2 of the PSP
provided an initial listing of candidate methods that are
being considered for application and will be updated in
Revised Study Plan
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FERC Project No. 14241 Page 30 December 2012
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not clear on are 1) how will the decision be made on
which habitat specific model(s) will be used, and 2)
how and when will other related riverine studies be
integrated (e.g., water temperature, ground water, fish
passage, sediment transport, channel maintenance,
and ice processes)?
the Section 8.5.4. The selection of specific habitat
models will be made following a careful review of the
approaches used during the 1980s studies, and a
review of contemporary methods available for
addressing the objectives of the Fish and Aquatics
Instream Flow Study, AEA will seek to reach TWG
consensus on habitat model selection during the 2nd
Quarter 2013 (Section 8.5.4). Regarding issue two,
the integration of studies was conceptually described in
Figure 6.5-3 in the PSP and provided in Section 8.5.4.
In practice, this will occur as part of both field data
collection activities (completed in 2013 and 2014) that
will be completed at the Focus Areas in which cross-
discipline studies will be conducted and coordinated,
as well as during the data analysis and modeling
exercises that will link discipline specific models with
the flow routing and operations models. Results of
these models will be used in a Decision Support
System framework to assess different operational
scenarios.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 31 December 2012
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Email 8/23/2012 Joseph Klein ADNR-
ADF&G
Varial zone modeling, may need more defined time
steps during analysis phase (possibly down to 15-
minute increments) depending on the rate of flow
change over time.
Time-step increments, used to calculate stage
changes, will be identified during calibration of the
Mainstem (Open-water) Flow Routing Model in 4th
Quarter 2012 (see Section 8.5.4.3). Depending on the
initial calibration results, time steps as short as 3-
minutes may be needed to match predicted to
measured stage changes. In 2014, the calibrated flow
routing model will be used to evaluate the effects of
Project operations using 1-hour time-steps unless the
Technical Workgroup (TWG) determines that shorter
time steps are needed to evaluate specific fisheries
resources.
Email 8/23/2012 Joseph Klein ADNR-
ADF&G
For the eulachon and boating studies, similar
information is needed on what is the study area, what
sampling strategy will be used, how many and what
range of calibration-discharge sets if appropriate, and
how HSI curves will be developed.
As needed to support the evaluation of Project effects
on eulachon, modeling of eulachon habitat will be
conducted under the Fish and Aquatics Instream Flow
Study; as needed, HSC/HSI criteria will be collected
consistent with sampling methods described in Sec
8.5.4.5. Additional details of the recreation boating
study are provided in RSP Section12.
Email 8/23/2012 Joseph Klein ADNR-
ADF&G
What equipment will be used and how will they be
calibrated?
Water velocities will primarily be measured using either
Acoustic Doppler Current Profiler (ADCP) equipment or
Price AA current meters. Calibration of the ADCP
equipment will follow the ADCP Quality Assurance
Plan dated May 2012. Calibration of the Price AA
meters will employ a spin test whenever the meter is
assembled in the field. Once assembled, Price AA
meter operation will be tested by performing a spin
test. The cups should spin freely for a minimum of 3.5
minutes for the AA meter. The results will be recorded
on a calibration data sheet kept in the meter housing.
In some instances, other water velocity equipment may
be used, such as Marsh McBirney meters when frazil
ice is encountered.
Email 8/23/2012 Joseph Klein ADNR-
ADF&G
How do you envision the "collaborative process" will
work? When will major decisions be made (e.g., site
and transect selections) and how often do you
AEA will seek to reach TWG consensus on major
decisions. A schedule of major decisions is provided in
Section 8.5.6.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 32 December 2012
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envision the work group will get together?
Email 8/23/2012 Joseph Klein ADNR-
ADF&G
Will a DSS-type program be available to review study
results and if so, information is needed on it.
A Decision Support System-type program will be
available as described in Section 8.5.4.8.
Email 8/23/2012 Joseph Klein ADNR-
ADF&G
How will the data be aggregated to evaluate single
flow recommendation?
Habitat data will be used to evaluate potential impacts
of Project operation flow regimes by aggregating such
data by river segment unless geomorphic reach-
specific differences indicate a finer level of aggregation
is appropriate. The data analysis and aggregation
process is described in Section 8.5.4; additional details
will be developed in coordination with the TWG after
reviewing initial study results in 2014.
Email 8/23/2012 Joseph Klein ADNR-
ADF&G
HSI data are needed for identified target species for
each defined habitat type, over 2 years.
As described in Section 8.5.4.5, HSI data will be
collected in defined habitat types over 2 years.
HSC/HSI data collection efforts were initiated as a pilot
program in 2012 and will continue in 2013 and 2014.
These data will contribute to the site-specific database
of HSC/HSI data collected in the early 1980s.
Email 8/23/2012 Joseph Klein ADNR-
ADF&G
Per the description of study sites for fish passage/off-
channel connectivity (§6.5.4.5.5), what criteria will be
used to identify "a representative number" of different
habitat types?
Fish passage/off-channel connectivity will be evaluated
at sites selected using a hierarchical, framework of
habitat classification. The stratified sampling approach
will include several levels based on channel attributes
including river segment, geomorphic reach (RSP
Section 6.5), mainstem habitat type (RSP Section 9.9)
and potential fish barriers identified through Study of
Fish Distribution and Abundance in the Middle and
Lower Susitna River (RSP Section 9.6). Additional
details of process, criteria and schedule of fish
passage/off-channel connectivity are described in RSP
Section 9.12.
Email 8/23/2012 Joseph Klein ADNR-
ADF&G
What criteria will be used to select and weight
transect-derived models?
As discussed at the September 14, 2012 TWG
meeting, and described in Section 8.5.4.6, criteria to
select habitat models will include:
• All major habitat types sampled within each
geomorphic reach
• At least one Focus Area per geomorphic
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reach
• Replicate sampling strategy for major habitat
types
• Include biologically important salmon
spawning/rearing sites in main channel and
off-channel habitats
• Tributary deltas included as habitat unit
• Incorporate multiple study elements
Results of sites that are modeled using either 1-D (i.e.,
transect) or 2-D techniques will be extrapolated to non-
modeled sites based on the proportion of habitat area
they represent within the geomorphic reach. If
biological studies indicate that specific habitat types
are highly important to a species, the weighting of
modeling results from those habitat types will be given
priority as determined in coordination with the TWG in
3rd Quarter 2014.
Email 8/23/2012 Joseph Klein ADNR-
ADF&G
For PHABSIM, will transects be independent,
dependent or a combination and accordingly, what
WSE models and composite suitability index will be
used?
Habitat modeling is expected to represent a
combination of dependent and independent
techniques. The selection of PHABSIM modeling
techniques will be determined in 2nd Quarter 2013, in
collaboration with the TWG (Section 8.5.4.6). Model
selection will be based on the hydraulic characteristics
of each site and the information needed to address
Project effects. For instance, the use of 2-D modeling
techniques will involve dependent water surface
modeling techniques. The mainstem flow routing
model, used to calculate site boundary conditions, will
represent a combination of dependent and
independent transect calculations.
Email 8/23/2012 Joseph Klein ADNR-
ADF&G
What criteria will be used to identify cover types and
substrate sizes?
Cover types will be selected to represent the primary
habitat.
Substrates will be classified using a Wentworth grain
scale modified to reflect English units of measurement
(Section 8.5.4.5).
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Email 8/23/2012 Joseph Klein ADNR-
ADF&G
Will 2-D modeling include side channels and sloughs
within study area?
Yes. See Section 8.5.4.2.1.1.
Email 8/23/2012 Joseph Klein ADNR-
ADF&G
How many and at what range will discharge-
calibration sets be collected for each sampling
method?
A minimum of three stage: discharge calibration sets
will be collected for each sampling method (Section
8.5.4.6). The Mainstem (Open-water) Flow Routing
Model, used to calculate site boundary conditions, will
be developed using hydraulic data collected at flows of
approximately 8,000 cfs, 16,000 cfs and 28,000 cfs.
Email 8/23/2012 Joseph Klein ADNR-
ADF&G
What is the sampling strategy (e.g., representative
reach, mesohabitat typing) for the defined habitat
types?
As described in Section 8.5.4.2, a stratified sampling
strategy, incorporating replicate samples of major
habitat types will be based on a hierarchical,
framework of habitat classification. Sampling of
representative habitat types will be supplemented by
sampling of sites considered to be of high biological
importance.
Email 9/07/2012 Betsy
McCracken
USFWS Habitat site selection criteria: Criteria that influence
habitat selection and suitability need to be identified
using statistically powerful and robust methods and
current models of fish distribution including
bioenergetics and not exclusively physical habitat
models (Lovtang 2005). The Service remains
opposed to the proposal to repeat the 1980s
approaches to fisheries studies. The 1980s studies
do not determine the habitat criteria influencing fish
habitat site-selection, they simply report utilization
functions for water depth and velocity, or depth and
substrate. They also lack a fundamental baseline
assessment of all available fish habitat and instead
focus on study of habitats that had high fish use
density. The habitats that were apparently suitable
but unoccupied or underutilized by fish need to be
assessed, and the entire range of habitat availability
and habitat use data need to be assessed prior to
habitat study site selection.
Draft criteria for the selection of study sites were
presented during the 9/14/12 TWG meeting,
discussed during the 10/02/12 TWG meeting, and are
described further in Section 8.5.4.2. Advantages and
disadvantages of various stratification and site
selection methods have been presented. AEA is
committed to the development and implementation of
a technically sound and defensible site selection
process that is founded on the best available science
and information. As noted in Section 8.5.4.2 of the
RSP, the proposed approach includes elements of all
three of the most commonly used stratification and
site selection methods applied in instream flow studies
– representative sites, critical sites, and randomly
selected sites. AEA maintains that the entire range of
habitat availability and habitat use data does not need
to be assessed prior to habitat model site selection.
Habitat use information can be valuable to ensure that
important but scarce habitat types are represented in
the site selection process. AEA has proposed Focus
Areas that contain examples of the major habitat types
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and contains areas of high habitat use based on
surveys conducted in the 1980s. The proposed site
selection process also allows for Focus Areas to be
added or modified in 2014 based on the results of
data collection efforts in 2012 and 2013. Information
on habitat use can also be used during the data
analysis and interpretation process to assign
weighting factors by habitat type, but this occurs after
site selection and habitat modeling. The proposed
Fish and Aquatics Instream Flow Study plan is not a
repeat of the habitat modeling studies completed in
the 1980s. Rather, the proposed studies build upon
the data collected during the 1980s studies. AEA
considers the information provided in the 1980s
studies to be a valuable and informative resource that
can be used to help guide and develop its study plans
and has accordingly utilized this resource and more
contemporary information in developing the RSP.
Email 9/07/2012 Betsy
McCracken
USFWS More comprehensive data collected on nearby glacial
rivers may be used to demonstrate that habitat
selection by salmon in side-sloughs can be
independent of water depth and velocity and should
be compiled.
Information on salmon micro-habitat selection in
nearby glacial rivers will be presented to the TWG as
part of the HSC/HSI development process in 4th
Quarter 2013 and 1st Quarter 2014 (Section 8.5.4.5).
The proposed Fish and Aquatics Iinstream Flow Study
plan acknowledges that salmon habitat selection and
use involves more factors than just depth and velocity.
The RSP reflects an integrated study approach
involving groundwater, water quality, geomorphology
and ice processes.
Email 9/07/2012 Betsy
McCracken
USFWS Model selection: We need to first determine what
criteria are important to fish habitat site/suitability and
selection before we can choose an appropriate flow-
habitat model. ADFG Marine Mammals biologist, Dr.
Bob Small also reiterated this very same point
regarding model selection for the beluga whale
studies. Again, the Service notes our concern about
the limited focus of the 1980s studies and using
Methods and model selection were presented during
the October 2, 2012 TWG meeting and are discussed
in more detail in Section 8.5.4.6. The
methods/models represent those best suited for
evaluating specific habitat types (e.g. main channel,
side channel, side slough, upland slough) and are not
limited to the standard application of PHABSIM.
Specialized methods for evaluating specific processes
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PHABSIM. Our concerns stated in earlier
correspondence to AEA remain unaddressed and are
reiterated here for emphasis.
(e.g., effective spawning/incubation, varial zone
modeling) and habitat features (e.g. groundwater
upwelling, turbidity) are also proposed and will be
discussed at TWG meetings in 1st Quarter 2013 and
re-visited in 1st Quarter 2014.
Email 9/07/2012 Betsy
McCracken
USFWS Instream Flow, Habitat Utilization, Geomorphology
PSPs do not fully address USFWS’ resource mgmt.
concerns. During 3 days of ILP study meetings,
sequencing and integration of proposed biological
resource studies and physical processes was not
described; significant outstanding info needed.
Additional information was provided during workshops
held on August 15-17, September 14, October 2-4,
October 23-25 and during a site tour on October 3-4.
In addition, additional detail on sequencing and
integration of instream flow and physical processes-
related studies and other resource studies is provided
in the Section 8.5.4.8.
Email 9/07/2012 Betsy
McCracken
USFWS Need to describe the integration of these inter-related
studies, how integration will result in a comparison of
baseline biological info, resulting effects to biological
resources caused by project operations.
Section 8.5.4.8 describes the integration of these inter-
related studies, the comparison of alternate operational
scenarios to existing conditions, and analysis of Project
effects on biological resources.
Email 9/07/2012 Betsy
McCracken
USFWS Study results must be quantifiable to: assess
potential losses to aquatic resources, habitats; review
Susitna-Watana Hydroelectric Project under relevant
fish, wildlife resource conservation authorities; inform
fishway prescription authority (FPA Section 18);
eventually develop recommended protection,
mitigation, and enhancement (PMEs).
The proposed study will produce quantifiable results,
as requested by USFWS.
Email 9/07/2012 Betsy
McCracken
USFWS USFWS does not believe current Instream Flow,
Habitat Utilization, Geomorphology PSPs will yield
sufficient info to allow USFWS to adequately assess
proposed Susitna-Watana Hydroelectric Project
impacts to US fish and wildlife resources, and to
develop adequate PMEs.
In response to this comment and other feedback, the
RSP includes additional study detail which was
developed through multiple TWG meetings. These
RSPs will result in the collection of sufficient
information to assess the likely impacts of the
proposed Susitna-Watana Hydroelectric Project on fish
and wildlife resources, and to develop appropriate
PME measures.
Email 9/07/2012 Betsy
McCracken
USFWS USFWS has repeatedly articulated concerns about
lack of study sequencing, connectivity, integration
between biological studies, other proposed
engineering and physical processes studies. Need for
Additional detail on study sequencing and integration
between biological studies and habitat modeling
studies is described in Sections 8.5.4.7 and 8.5.4.8.
Study of Fish Distribution and Abundance in the Middle
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collection of adequate temporal and spatial baseline
biological, fish habitat data to provide direct input to
some of proposed physical modeling efforts. Many
USFWS concerns are related to temporal mismatch of
biological data collection w/ forward momentum of
physical modeling efforts.
and Lower Susitna River (RSP Section 9.6), and
HSC/HSI data (Section 8.5.4.5) will be collected on a
seasonal basis at representative habitat types
identified through the stratified sampling program. The
biological data will be used to ensure biologically
important habitat types are not underrepresented in the
habitat modeling efforts.
Email 9/07/2012 Mike Buntjer USFWS Early Life History and Juvenile Fish Distribution and
Abundance in the Susitna River (USFWS Study
Request; Enclosure 13)
6. Collect and provide the Instream Flow study with
habitat suitability criteria (HSC) data to support
analysis of potential project impacts.
Mention of HSC is in Study 6.5, but the study request
objective is not addressed in the upper, middle, or
lower reaches for juvenile anadromous, resident fish,
and non-salmonid anadromous fish studies. It is
unclear how HSC information will be collected,
particularly in winter for post-emergent fish up to 60
mm when fish will be most vulnerable to load-following
operations. I see no empirical baseline information
being collected to evaluate potential project effects or
for inclusion in habitat modeling efforts. There is
generic reference to developing HSC model in Study
6.5 for these species and life stages, but unclear
about the source of that information.
Data on the early life history of juvenile fish are being
collected as part of the Study of Fish Distribution and
Abundance in the Middle and Lower Susitna River
(RSP Section 9.6) and represents a collaborative effort
of Fisheries, Instream Flow, Groundwater, Ice and
Water Quality. Pilot winter studies will be conducted in
early 2013 to guide more extensive study efforts
planned for winter 2013-2014 and late winter 2014.
Some HSC data have already been collected as part of
2012 field studies and the results of those study efforts
and proposals to collect site-specific HSC/HSI data in
2013 and 2014 are described in the RSP. In response
to this comment and other feedback, Section 8.5.4.5
provides more details regarding methods (locations,
survey methods, frequency of sampling, etc.) of
HSC/HSI data collection.
Email 9/07/2012 Mike Buntjer USFWS Early Life History and Juvenile Fish Distribution and
Abundance in the Susitna River (USFWS Study
Request; Enclosure 13)
8. Evaluate the potential for stranding of juvenile fish
and stranding mortality by season under proposed
operational conditions.
This Study Request objective is not addressed.
Stranding is mentioned in Chapter 6, but the study
approach is not discussed
Stranding and trapping will be evaluated using the
varial zone model described in Section 8.5.4.6.
Stranding and trapping surveys will be conducted in
the Susitna River following natural stage reductions on
an opportunistic basis during 2013 and 2014. Site-
specific data on the size and species of stranded and
trapped fish (see Section 8.5.4.5) will be used to
validate criteria developed from studies conducted at
existing hydroelectric projects exhibiting load-following
operations.
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Email 9/07/2012 Mike Buntjer USFWS Early Life History and Juvenile Fish Distribution and
Abundance in the Susitna River (USFWS Study
Request; Enclosure 13)
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 is not addressed
anywhere.
This Study Request objective is addressed in RSP
Section 9.6. Plans for completing a pilot winter
sampling program at two Focus Areas in 2012 -2013
were presented during the October 2 2012 TWG
meeting. In summary, intergravel temperature
recorders are scheduled to be installed at several
locations within each site. Recorders will be installed
as vertical arrays with thermistors located at different
depths to capture variable groundwater flow. At two
locations, continuous recording dissolved oxygen
meters will be installed in the gravel as a means to
monitor intergravel dissolved oxygen under winter
conditions. Fish sampling will be completed at
selected locations within these areas. Pressure
transducers will be installed at different habitat types
and within the main channel to determine water
surface elevation relationships. The results of these
pilot studies will be used to guide studies of the
intergravel environment to be conducted during the
winter of 2013-2014.
Email 9/07/2012 Mike Buntjer USFWS Adult Salmon Distribution, Abundance, Habitat
Utilization and Escapement in the Susitna River
(USFWS Study Request: Enclosure 15)
9. Determine the availability and accessibility
of spawning habitats by adult salmon to mainstem and
tributary locations based upon flow regime.
Unclear if, how, or where this Study Request objective
is being addressed.
Not listed as an objective in this study; section
6.5.4.3.1 (page 6-19) describes assessing access to
rearing and spawning habitats via output from flow
routing models. Also, objective 13 (shown below) in
fish passage study (section 7.12); page 7-98):
RSP Sections 9.5 and 9.6 describes the methods that
will be applied including selection of passage criteria,
methods and modeling techniques, and the selection of
study sites. This work will be integrated into the Fish
and Aquatics Instream Flow Study program (Section
8.5) and will include collection of data by habitat type.
Email 9/07/2012 Mike Buntjer USFWS Adult Salmon Distribution, Abundance, Habitat
Utilization and Escapement in the Susitna River
(USFWS Study Request: Enclosure 15)
RSP Section 9.12 describes the methods that will be
applied including selection of passage criteria,
methods and modeling techniques, and the selection of
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13. Evaluate the potential creation of fish passage
barriers within existing habitats (tributaries, sloughs,
side channels, off-channel habitats) related to future
flow conditions, water surface elevations, and
sediment transport.
study sites. This work will be integrated into the Fish
and Aquatics Instream Flow Study program (Section
8.5) and includes data collection by habitat type within
Focus Areas and at potential passage barriers
identified by biotelemetry studies (RSP Section 9.6)
Email 9/07/2012 Mike Buntjer USFWS Adult Salmon Distribution, Abundance, Habitat
Utilization and Escapement in the Susitna River
(USFWS Study Request: Enclosure 15)
10. 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.
Do not see this study request objective addressed or
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 see determining distribution and
potential abundance of redds. Also, see mention of
evaluating potential dewatering or scouring of redds in
Chapter 6, but no empirical baseline information to
assess daily load-following operations.
Studies to evaluate potential Project effects on
salmonid spawning will integrate groundwater,
geomorphology, ice processes and water quality (see
Section 8.5.4.8). The effects of daily load-following
operations will be addressed as part of the varial zone
modeling and effective spawning analyses that were
discussed during the October 2, 2012 TWG meeting
and described in Section 8.5.4.6.
Email 9/12/2012 Eric Rothwell NMFS General – All PSPs: What can be determined from
each of the study components, a description of
deliverables (not results) this will help us understand if
our requests have been met.
Thank you for this suggestion. Specific deliverables
will be identified under specific subheadings in Section
8.5.4.
Email 9/12/2012 Eric Rothwell NMFS General – All PSPs: How will uncertainty be
determined for each of the study components? (ice
processes -> hydraulic flow routing -> winter fish and
habitat effects)
Determination of uncertainty and procedures to
address uncertainty will be described in the respective
RSP sections for each of the study components. For
example, with respect to the Mainstem (Open-water)
Flow Routing Model, calibration details will allow
uncertainty to be calculated by comparing simulated
versus observed conditions at different locations in the
stream (Section 8.5.4.3).
Email 9/12/2012 Eric Rothwell NMFS General – All PSPs: How will incomplete study The studies are designed to be adaptive so that
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components, data, or results be dealt with - situations
where an extension of the study period is necessary.
information learned during 2013 will be used to refine
methods, approaches and study locations applied in
2014. In the event that there are incomplete study
components, data, or results, AEA, in consultation with
the TWG, will assess the significance of such and
respond accordingly.
Email 9/12/2012 Eric Rothwell NMFS Site Selection Process: The data from the 1980s
provides some useful information about utilization of
off-channel habitats that should inform our studies but
the information is limited in that it does not fully
capture mainstem utilization or overwintering. So,
with new fish utilization and distribution information
site selection should include some flexibility to include
sites where life histories are not assessed under the
currently proposed sites. This seems to be suggested
in the site selection process schedule if it includes fish
distribution/habitat utilization information, November
2013 evaluate summer 2013 data and modify/add
sites as needed in collaboration with TWG
Yes, as described in the RSP Section 9.6, data on fish
distribution, and utilization by habitat type will be
collected seasonally in both main channel and off-
channel habitats. Fish distribution and abundance
data, intergravel monitoring and winter fish behavior
observations, and channel and hydraulic data, will also
be collected at Focus Areas in 2013. In collaboration
with the TWG, these data will be used to modify/add
Focus Areas in March 2014 to allow additional data
collection in 2014.
Email 9/12/2012 Eric Rothwell NMFS Site Selection Process: If possible an addendum to
the PSP or definitely in the RSP a description of the
initial site selection (by the hierarchical framework)
and refinement (by habitat mapping results and fish
studies) methods should be presented, not just the
selected sites. This depends on the fish studies being
sufficient to describe the full distribution of fish and
their habitat use.
The hierarchical framework of habitat classification
used to support instream flow study site selection and
refinement will be presented in RSP Section 9.9. The
process and criteria used to identify proposed Focus
Areas, and a list of the areas will be identified in
Section 8.5.4.2.
Email 9/12/2012 Eric Rothwell NMFS Site Selection Process: The 1980s sampling focused
on the off-channel habitats (side sloughs/channel,
upland sloughs, and confluences with tributaries).
This information should be used to inform selections
but must also be put into context that we really don't
know very much about mainstem utilization and
overwintering, and so need to be flexible (potential
with extended study years) when a better
understanding is gained through the 2013 and 2014
Although limited by available technology, nearly four
years of surveys conducted in the early 1980s provide
background information on fish and habitat distribution.
Assumptions developed in the 1980s regarding main
channel utilization and overwintering will be tested
through the use of new methods such as dual
frequency identification sonar (DIDSON)
(http://www.didson.com). The study site selection and
review process (Section 8.5.4.2) provides the
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fish studies. opportunity and flexibility to modify/add sites as new
information becomes available.
Email 9/12/2012 Eric Rothwell NMFS Site Selection Process: The slides on each of the
species, I had a general comment that they should be
put into perspective. That the 1980s data does not
represent a complete understanding so comments like
no mainstem spawning should be qualified. There
likely is a riverine component to sockeye (and other
species) that do spawn in the river but that just wasn't
captured in the 1980s due to the methodologies
available. We do not currently know the full spawning
distribution.
The draft slides referenced in this comment presented
the summary results of multiple years of study
conducted in the early 1980s along with source
citations. When distributed at the September 14, 2012
TWG meeting, qualifiers were added to the slides to
identify the information as 1980s observations.
Studies to identify the current spawning distribution,
using recent advancements in survey techniques (e.g.,
DIDSON), are proposed in RSP Sections 9.5 and 9.6.
Email 9/12/2012 Eric Rothwell NMFS Site Selection Process: The ice process modeling will
need several years of data, in addition to the ice
thickness measurements and discharge
measurements at each of the cross-sections for the
winter routing model. I see a lack of time to collect
data for the models (winter flow routing and ice
process) calibrate the models and then selection sites
and methods to conduct ISF studies to assess project
effects on fish during winter operations under the
currently proposed study period.
Ice process modeling results (RSP Section 7.6) will be
available prior to the 2014 summer instream flow
sampling period allowing sufficient time to add or
modify instream flow Focus Areas as needed to
evaluate Project effects during winter operations.
Email 9/18/2012 Joe Klein ADNR-
ADF&G
I am concerned, however, that at the pace we are
going we are going to run out of time before we have
the opportunity to thoroughly discuss key elements
(e.g., target species, HSC development, methods per
habitat types, transect selection criteria and number,
desired outputs). I am grateful for the time extension
granted by FERC and encourage you and your staff to
take advantage of this opportunity to put forth a
concerted effort to hold more meetings (either in
person or via teleconference) and address the study
topics mentioned.
The current schedule provides sufficient time to
address key elements and AEA is committed to
working collaboratively with the NMFS and others on
finalizing the RSP. Additional TWG meetings were
held on Oct 2, 4 and 24 to discuss site selection,
habitat modeling methods, and other details of the
instream flow study. Thorough discussion of various
details of the instream flow study will continue during
monthly TWG meetings scheduled through December
2013.
Email 9/18/2012 Joe Klein ADNR-
ADF&G
Please include a definition list for each study plan of
key terms. We are not overly concerned about
Thank you for the suggestion. A list of key study terms
will be provided as a table in each technical section of
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consistency between groups since different specialties
often have their own terminology, however a list would
help understand these differences/similarities.
the RSP.
Email 9/18/2012 Joe Klein ADNR-
ADF&G
After reading my notes, details about the sampling
approaches discussed are not clear to me. For
example, how many intensive sites are planned? I
believe the fish studies mentioned the previous day
that they were looking at 8-10 sites – would these be
the same? For both instream flow and riparian
studies? What is the sampling approach for other
habitats in addition to identified critical sites?
Proposed Focus Areas for the Middle Susitna River
were identified and described during the September
14, 2012 TWG meeting. A description of proposed
Focus Areas is provided in Section 8.5.4.2.These
Focus Areas may be modified in collaboration with the
TWG in early spring 2013 after the habitat mapping
results (RSP Section 9.9) are available. These Focus
Areas will include sampling for Fish and Aquatics
Instream Flow, Riparian-Instream Flow, Groundwater,
Geomorphology, Water Quality and Ice Processes in
the Susitna River Studies.
Email 9/18/2012 Joe Klein ADNR-
ADF&G
We support and agree with the approach proposed for
using 2-D modeling for sampling the intensive sites.
Complex Focus Areas, such as Whiskers Slough and
Slough 8a will be modeled using 2-D techniques.
Transect-based techniques may be appropriate to
model less complex Focus Areas, such as Slough 6a.
The selection of modeling techniques are described in
Section 8.5.4.6 and confirmed in collaboration with the
TWG in late 1st Quarter 2014.
Email 9/18/2012 Joe Klein ADNR-
ADF&G
Likewise, we support and agree with the approach
proposed for assessing surface water/ground water
interactions.
Comment noted.
Agency
consultation
meeting
9/27/2012 Joe Klein ADNR-
ADF&G
Requests that any historic data used for stranding /
trapping be referenced.
Citations for historic stranding and trapping studies or
data referenced in the Fish and Aquatics Instream
Flow Study are provided in Section 8.5.8.
Agency
consultation
meeting
9/27/2012 Joe Klein ADNR-
ADF&G
Requests all low gradient areas, including islands and
gravel bars, be modeled in the middle river.
Low gradient areas (i.e., <4% gradient), including
islands and gravel bars, will be mapped and modeled
within Focus Areas (Section 8.6.4.6). Low gradient
areas will modeled as part of the digital terrain models
developed from a combination of Focus Area-specific
bathymetry and remote sensing data. Extrapolation of
the analysis of low gradient Focus Areas to other areas
will rely on digital terrain models developed through
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 43 December 2012
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remote sensing.
TWG meeting 10/1/2012 Eric Rothwell NMFS Requests 2-D modeling at Whiskers Slough and
Slough 8A Focus Areas (if these Focus Areas are
chosen).
2-D modeling is proposed at Whiskers Sough and
Slough 8A Focus Areas (Section 8.5.4.6).
Riparian Instream Flow Study (Section 8.6)
Email 9/11/2012 Bob Henszey USFWS Section 6.6.4.7 (Succession Models and Flow
Response Guilds) appears to potentially address the
USFWS's Objective 6 request; however, two critical
referenced papers (Merritt et al. 2010 and Pearlstine
et al. 1985) were not included in the Literature Cited.
These references were not provided until 8/28/2012,
and the USFWS has had insufficient time to review
these papers in detail. The concept of the PSP
response guilds is similar to the USFWS's request to
develop plant community response curves, but the
PSP methods are insufficient to evaluate if our
requested Objective 6 will be met. The USFWS
requested evaluating specific water-level summary
statistics (see above discussion for groundwater) with
a rigorous curve-fitting technique similar to Henszey et
al. (2004). The methods should provide sufficient
detail to show how quantifiable (not qualitative)
hydrologic (surface-water and groundwater) gradients
will be constructed to show the optimum and range of
favorable water levels required for maintaining
floodplain species/communities.
Additional detail has been added to Section 8.6.4.7 to
demonstrate that USFWS Objective 6 will be met by
the proposed methods. In response to this comment
and other feedback, a description of the hydrologic
gradient analyses is provided in RSP Section 7.5:
Groundwater. This description provides detail to show
how quantifiable hydrologic (surface-water and
groundwater) gradients will be constructed to show the
optimum and range of favorable water levels required
for maintaining floodplain species/communities.
Email 9/11/2012 Bob Henszey USFWS Study Goals and Objectives: The USFWS requested
a specific goal that included 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 to quantify the
frequency and rate of sediment deposition required to
promote soil development, and to quantify the effect of
river ice on the establishment and persistence of
Section 8.6.3 (Study Methods) provides: “Objectives of
the modeling approach are to: “(1) measure and model
riparian vegetation physical process relationships
under the natural flow, sediment and ice regimes, (2)
model potential impacts to riparian vegetation resulting
from proposed Project operational changes to natural
flow, sediment and ice regimes.”
In addition, Section 8.6.3.2 provides: “Metrics and
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 44 December 2012
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riparian plant communities. Section 6.6.1.1 of the
PSP has no stated goal, and only a general approach
is provided. An "overarching goal" is provided in the
Section 6.6.4 Study Methods, but this goal is also very
general. While goals can be very general in nature,
the specifics in our goal set the stage for a rigorous
study plan to evaluate potential project-related effects
on floodplain plant communities.
indices will be developed for quantitatively describing
the relationship between floodplain plant communities
and the varying groundwater and surface water
hydroregime. Probabilistic response curves will be
developed for select plant species and all riparian plant
community types using techniques described in Rains
et al. (2004) and Henszey et al. (2004).”
Goals and specific objectives are further clarified in
Section 8.6.3.6.
Email 9/11/2012 Bob Henszey USFWS Study Goals and Objectives: The USFWS requested
six objectives to help meet our goal. Three of the
PSP objectives are similar to our requests {1)
Synthesize 1980s data, 2) Study sites, and 6) Seed
dispersal}, but they lack the additional specifics stated
in our requested objectives. Two of the PSP
objectives appear to be wholly or at least partially the
objectives for other PSPs and not appropriate as
stated {3) Map riparian vegetation, and 10) Impacts to
shallow groundwater well users}. What the PSP
objectives lack, however, are our specific requests for
river ice, sediment deposition, and water-level regime
(USFWS Objectives 4, 5, and 6). These missing
objectives may be studied under AEA’s PSP
objectives, but the USFWS prefers they be considered
as standalone objectives, and possibly integrated into
a single modeling objective after they have been
studied individually. The USFWS is particularly
interested in our Objective 6 to characterize the water-
level regime required to maintain floodplain and
riparian plant communities. Much of the discussion so
far has focused on floodplain plant succession, but
little or no discussion so far has involved maintenance
flows. Succession is important, but without
maintenance flows whole floodplain plant communities
may collapse or the direction of succession changed
The RSP includes each of the USFWS requested six
objectives, and these objectives have been specifically
identified in the text of each appropriate RSP study
plan section.
USFWS Objective 6 to characterize the water-level
regime required to maintain floodplain and riparian
plant communities (maintenance flows) is an objective
of the Groundwater / Surface Water Interaction
Modeling Study and is clearly stated as such in Section
8.6.3.6. In addition, collection of vegetation data will
be shared between the Riparian Study (Section 11.6)
and Riparian Instream Flow Study (Section 8.6). Pre-
development vegetation types will be mapped in the
Riparian Study, and then will be used to map the
predicted changes in vegetation based on changes in
flow, groundwater/surface water interactions, ice, etc.,
derived from modeling conducted in the Riparian
Instream Flow Study.
Impacts to shallow groundwater well users was added
to the groundwater / surface water study overall
objectives during PSP development. The shallow
groundwater impact analysis has been moved to the
Groundwater Study (Section 7.5).
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 45 December 2012
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to an unnatural target (e.g., non-floodplain plant
communities).
River ice, sediment transport and deposition, and
water-level regime analyses will be studied individually
and then integrated into the overall riparian vegetation
physical processes modeling approach including
Section 8.6.3.4 “Characterize the role of river ice in the
establishment and recruitment of dominant floodplain
vegetation. Develop predictive model of potential
Project operational impacts to ice processes and
dominant floodplain vegetation establishment and
recruitment.” Section 8.6.3.5 “Characterize the role of
erosion and sediment deposition in the formation of
floodplain surfaces, soils and vegetation. Develop a
predictive model of Project operations changes to
erosion and sediment deposition pattern and
associated floodplain vegetation.”
Email 9/11/2012 Bob Henszey USFWS Study Area: The USFWS agrees with the PSP study
area and four river segments, with the following
additional comments. The width of the active valley
should also include the distance from the River that
the River influences groundwater, as well as define
the return interval for both groundwater and flooding
(e.g., 100-year event under current or climate-change
induced conditions). Much discussion has centered
on the downstream influence of the Project. The PSP
study area Lower Reach would extend to RM 0. Will
this lower extent remain even if all agree that the
Project influence on surface- and ground-water
becomes indistinguishable from normal environmental
variation?
The Project Study Area includes the active floodplain,
the valley area flooded under current climatic
conditions. By definition the active floodplain is that
valley region currently flooded. The 100-year flood has
legal significance when it comes to establishing
floodplain insurance rates, but we have not seen any
studies that link it to physical processes.
When flows exceed bankfull (recurrence interval = 1.5
years), the river will start to interact with the floodplain.
As flows increase beyond bankfull, the river will interact
with more of the floodplain surface area. A recent
point of reference is the September 2012 flood (peak =
79,000 cfs at Gold Creek). This flood had a recurrence
interval of almost 25 years.
Rather than trying to pick a recurrence interval for a
valley flood condition, we will use the HEC-RAS model
to determine the flood magnitude that floods the
geomorphically delineated valley floor.
The lateral floodplain geographic extent will be mapped
out using LiDAR shaded relief map to identify slope
breaks between adjacent hill slope and valley bottom
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 46 December 2012
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alluvial surfaces, the “active floodplain.” Surface water /
groundwater influences will be sampled and modeled
in the groundwater / surface water interaction study.
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.
Email 9/11/2012 Bob Henszey USFWS Study Methods: The methods need to follow the order
of the objectives and use section headings that refer
to the intent of the objectives
Agreed. The RSP will have individual study element
objectives and methods with section headings.
Email 9/11/2012 Bob Henszey USFWS Study Methods: Few methods are referenced, and
some references that are cited are not included in the
literature cited.
All methods will be referenced and missing references
will be included in the RSP.
Email 9/11/2012 Bob Henszey USFWS Study Methods: The relationship with other PSPs
often seems confusing. It would be more helpful to
state what results will be required from PSP "x" to
evaluate a Riparian ISF objective, and potentially what
results from a Riparian ISF objective will be required
by PSP "y." It is not necessary to repeat coordination
for every objective, only state the inputs required and
the outputs provided by an objective. This applies
across PSPs and among a PSPs objectives.
In response to this Comment and other feedback, flow
diagram will be included in the RSP showing the input /
output relationships between the various PSPs and
Riparian IFS. The RSP narrative will reflect and
explain the flow diagram input / output structure.
Email 9/11/2012 Bob Henszey USFWS RIFS-1 Synthesize Historical Data: In addition to
other North American hydro-projects, this review
should also include a review of relatively undisturbed
riverine systems.
Scientific literature available concerning relatively
undisturbed riverine floodplain systems will be
incorporated into the historical data synthesis.
Email 9/11/2012 Bob Henszey USFWS RIFS-2 Select and Design Study Sites: The number
of study sites should provide sufficient replication to
address the needs of the objectives, and should
include sites where Project operation is expected to
cause early channel bed degradation or
aggradation. The casual reference to
pseudoreplication in one of the other objectives needs
Focus Areas have been proposed in the Middle River
between the Project site, RM 184, and Devils Canyon,
the river segment likely to exhibit early channel bed
degradation in response to Project operations.
Aggradational areas will be determined through the
sediment transport and fluvial geomorphological
studies. The issue of pseudoreplication and number of
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 47 December 2012
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to be addressed at the study-site level. 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" study sites are really only one
replicate for each process-domain. For more on
pseudoreplication see:
Hurlbert, Stuart H. 1984. Pseudoreplication and the
Design of Ecological Field Experiments. Ecological
Monographs 54:187–211.
http://dx.doi.org/10.237/1942661
sample sites is addressed in the hierarchical riparian
process domain sampling design. The Focus Areas
will be representative of specific riparian process
domains and their channel / floodplain characteristics
(ice process domains, channel plan form, channel
slope, channel confinement). The Focus Area physical
processes will be modeled and floodplain vegetation-
flow response relationships determined. The sampling
design will be further described in Section 8.6.3.2.
The Riparian Botanical Survey is designed to provide
Project Area wide representative sample replicates of
floodplain vegetation, soils and alluvial terrain
relationships. Furthermore, surface water flood regime
for the Project Area will be modeled providing flow
regime plant community relationship analysis replicates
throughout the Project Area, in addition to the Focus
Area sites.
Email 9/11/2012 Bob Henszey USFWS RISF-3 Characterize Seed Dispersal and Frequency
of Establishment: Not sure where this objective is
addressed in the PSP. It appears to be scattered
across several sections in the methods. If the
methods have been described by other similar
projects, then cite their methods if appropriate and
include enough details to help others understand the
methods that will be used. How will the Susitna River
bimodal peak flows be addressed? On a float trip
down the Susitna 27-29 July 2012, there were newly
emerging dicot seedlings on the sandbars. How will
the fate of these "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?
RISF 3 is addressed specifically in Section 8.6.3.3;
methods proposed will be further documented with
citations in this section.
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 Section 7.5.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 48 December 2012
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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.
Email 9/11/2012 Bob Henszey USFWS RISF-3 Characterize Seed Dispersal and Frequency
of Establishment In Section 6.6.4.3.1.4: Is
"abundance" density or some other metric? What is
"elevation" referenced to: 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. MODFLOW is a groundwater model, and many
not be sensitive enough to quantify hydroperiod
relationships for seedlings. What other metrics will be
used to quantify/separate surface water, groundwater,
soil moisture, precipitation, and other potential
hydrological process that support seedling
establishment and recruitment?
Abundance will be measured as percent cover (herbs,
shrubs) or stem density (trees, saplings). Abundance
measurement methodological details and citations will
be supplied in Section 8.6.3.7.
“Elevation” references to plot elevations. Plot
elevations will be surveyed and tied into a project wide
standard datum.
Agreed, vegetation plot sample size and shape
methods citations will be provided in Section 8.6.3.7.
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.
Further details of MODFLOW groundwater level
modeling precision will be described in the RSP.
Detailed groundwater / surface water modeling metrics
necessary to assess seedling establishment and
recruitment conditions will be provided in the RSP.
Metrics will include: meteorological 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.
Email 9/11/2012 Bob Henszey USFWS RISF-3 Characterize Seed Dispersal and Frequency Natural seed dispersal hydro and sediment regime
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 49 December 2012
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of Establishment; How will the results from this
objective be used to predict potential Project-related
changes in seedling establishment and recruitment
into the population?
relationships will be measured in the field. 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), Section 8.6.3.5 and Section 8.6.3.7.
Email 9/11/2012 Bob Henszey USFWS RISF-4 Characterize the Role of Ice in the
Establishment, Survival and Recruitment of Riparian
Species: The discussion on ice processes (Section
6.6.4.4.1) seems unfocused, and essentially provides
no discernible methods: "Final details of the
geomorphology and ice processes modeling will be
developed as the 2012 studies are obtained." The
goal of this study should be to characterize the role of
river ice in the establishment (colonization), survival
(first 3 years) and recruitment into the future
reproductive population of dominant riparian species
(e.g., balsam poplar, willows). Have others
investigated the role of ice on riparian plant
communities? If so, can their methods be used
here? How will the magnitude, frequency, and
longitudinal distribution of ice events affecting
dominant riparian species/communities be evaluated?
The ice processes (Section 8.6.3.4) has been revised
to clarify the methodology in light of 2012 summer
fieldwork and further development of the ice process
study plan.
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, however a
recent publication by Engstrom et al., Effects of River
Ice on riparian vegetation. (Freshwater Biology 2011,
56: 1095-1105) begins to address this question. A
similar study approach and methods will be developed
and presented in the RSP. 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. A geospatial analysis of the modeled, and
empirically mapped locations, of ice floodplain
interactions will be conducted. A study approach to
characterizing role of river ice process in
establishment, survival and future plant community
development is presented in Section 8.6.3.4.
Revised Study Plan
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Tree ice-scars, first identified in summer 2012
fieldwork, will be used to map ice floodplain interaction
zones along the river. Ice process modeling will also
be used to identify the vertical and lateral extent of ice
floodplain vegetation interaction zones (Section
8.6.4.3).
Email 9/11/2012 Bob Henszey USFWS RISF-5 Characterize the Role of Sediment Deposition
in the Formation of Soils: The proposed soil sampling
techniques are included in Section 6.6.4.3.1.5, but
based on these techniques it is unclear how the
USFWS requested objective 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. 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. Sampling
to only a depth of 50 cm, and describing cumulative
thickness of all organic horizons and loess (windblown
material?) without stratigraphy will likely be insufficient
to meet this objective. Soil texture by feel should
follow standard techniques (e.g., Thien 1979,
http://soils.usda.gov/education/resources/lessons/text
ure/).
The characterization of the 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. Probabilistic models will
be developed characterizing the relationship between
plant community successional stage, soil type and
sediment depositional history.
The fluvial geomorphology 2-D sediment transport
models will be used to predict the effects of Project
operations on sediment transport and depositional
patterns. Changes in sediment depositional patterns,
soil development and effects on plant community
recruitment and development will be modeled. Further
methodological details will be provided in the RSP.
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 Modeling below Watana Dam Study to
predict the effects of Project operation on floodplain
plant communities.]
Standard NRCS (2002) soil sampling protocols are
Revised Study Plan
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being used, including measuring stratigraphy and soil
texture. Yes, NRCS (2002) field manual is based upon
Thien (1979). Soil stratigraphy will be described and
measured.
Sediment transport and deposition are being modeled
in the Fluvial Geomorphology Modeling below Watana
Dam Study. The integration of the Fluvial
Geomorphology Modeling below Watana Dam Study
and the Riparian IFS will be further described in the
RSP.
Email 9/11/2012 Bob Henszey USFWS RISF-6 Characterize Water-Level Regime Required to
Maintain Floodplain and Riparian Plant
Communities: 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 USFWS
requested objective will be met. Suggest this
objective be discussed near the beginning of future
meetings to allow sufficient time for discussion.
Yes, this subject was covered in greater detail in the
October 1, 2012 Riparian TWG meeting. The Study
Plan has been revised to provide specific details on
methodology and additional literature citations. See
Groundwater Study RSP Section 7.5 for further details.
Email 9/11/2012 Bob Henszey USFWS 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.
The USFWS's Objectives RISF-3 to RISF-5 target
critical stages in plant community succession, while
RISF-6 targets critical instream flows required for
maintaining plant communities as succession
progresses (i.e., both succession and maintenance
are important).
The methods for groundwater belong in the
Groundwater PSP, and not in this PSP for reasons
discussed above. This PSP should request the
required hydrologic information from PSP 5.7 and
Groundwater methods will be moved from the Riparian
PSP to the Groundwater RSP (RSP Section 7.5).
Revised Study Plan
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begin the discussion from that point.
SECTION 9 FISH AND AQUATIC RESOURCES
General
Email 9/07/2012 Betsy
McCracken
USFWS Resource valuation of non-salmon anadromous and
resident fish resources. During the meeting, AEA
consultants stated that a resource valuation would not
be provided, as requested in the Service’s study
request for non-salmon anadromous, resident and
invasive fish study. We request that an explanation be
provided that describes the rationale for this
determination and urge reconsideration of our study
request.
AEA is not providing a resource valuation because
FERC does not require a monetary value be placed on
fish and wildlife resources potentially affected by a
proposed project.
Email 9/07/2012 Betsy
McCracken
USFWS Trophic ecology- The Service requested information
on trophic ecology in the non-salmon anadromous,
resident and invasive species study request. The
trophic ecology component needs to be clearly spelled
out in a study plan identifying any aspects that will and
will not be addressed explained and with appropriate
rationale.
AEA has revised the River Productivity Study plan (see
Section 9.8.4.5.2) to incorporate sampling at multiple
trophic levels including: organic matter, periphyton,
macroinvertebrates and fish. In addition AEA has
incorporated trophic model(s) that will allow AEA to
describe the trophic ecology of the river with respect to
supporting fisheries resources. The model(s) will also
allow for evaluation of potential project effect at
multiple trophic levels.
Email 9/07/2012 Michael
Buntjer
USFWS In Study Request = 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.
A hyphoreic study plan has been added to the ISF
program that will address intergravel temperatures.
See RSP Section 8.5.2.1.6 for Instream Flow.
Email 9/07/2012 Michael
Buntjer
USFWS In Study Request = Evaluate the potential for
stranding of juvenile fish and stranding mortality by
season under proposed operational conditions.
An early life history study object has been added to the
Study of Fish Distribution and Abundance in the Middle
and Lower Susitna River. See Section 9.6.4.3.3. This
new objective includes several subobjectives one of
which is to evaluate baseline conditions for stranding of
juvenile fish. This stranding study also will be
incorporated into the ISF Program Varial Zone model
and will be used to evaluate future potential risk for
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stranding under proposed project operational
conditions. This stranding study will be used to assess
the risk of stranding mortality to fry under varying flow
conditions.
Email 9/07/2012 Michael
Buntjer
USFWS In Study Request = Collect and provide the Instream
Flow study with habitat suitability criteria (HSC) data
to support analysis of potential project impacts.
Comment = Mention of HSC is in Study 6.5, but the
study request objective is not addressed in the upper,
middle, or lower reaches for juvenile anadromous,
resident fish, and non-salmonid anadromous fish
studies. It is unclear how HSC information will be
collected, particularly in winter for post-emergent fish
up to 60 mm when fish will be most vulnerable to load-
following operations. I see no empirical baseline
information being collected to evaluate potential
project effects or for inclusion in habitat modeling
efforts.
HSC methods are described in the ISF Program HSC
Study Plan. See RSP Section 8.5.2.1.5.
These data are also being collected by Fish
Distribution and Abundance Field Teams in locations
where target species and life stages are found. Teams
will follow the ISF study plan methods.
In addition, AEA has revised the Study of Fish
Distribution and Abundance in the Middle and Lower
Susitna River (See Section 9.6.4.3.3) to provide more
detail regarding focused sampling for fry less than
60mm. This sampling will provide empirical baseline
data that will be used to inform habitat modeling
efforts.
E-mail 9/07/2012 Betsy
McCracken
USFWS Instream Flow, Habitat Utilization, Geomorphology
PSPs do not fully address USFWS’ resource mgmt.
concerns. During 3 days of ILP study meetings,
sequencing and integration of proposed biological
resource studies and physical processes was not
described; significant outstanding info needed.
AEA has revised the study plans to describe the
integration of proposed biological resource studies and
physical processes. See RSP Sections 9, and 8.
Interdependencies Flow Charts have been added to all
study plans to show the flow and integration of data
across studies. See RSP Sections 9 and 8.
E-mail 9/07/2012 Betsy
McCracken
USFWS Need to describe the integration of these inter-related
studies, how integration will result in a comparison of
baseline biological info, resulting effects to biological
resources caused by project operations.
Interdependencies Flow Charts have been added to all
study plans to show the flow and integration of data
across biological resources. This baseline information
will be available to support effects analysis but it is
premature to identify specific analyses that will be
applied before baseline data are available.
E-mail 9/07/2012 Betsy
McCracken
USFWS Study results must be quantifiable to: assess
potential losses to aquatic resources, habitats; review
SuWa Project under relevant fish, wildlife resource
In the RSP, AEA has included additional detail that will
clarify how data will be collected in support of future
quantifiable assessments.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 54 December 2012
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conservation authorities; inform fishway prescription
authority (Sec. 18 FPA); eventually develop
recommended protection, mitigation, enhancement.
E-mail 9/07/2012 Betsy
McCracken
USFWS USFWS has repeatedly articulated concerns about
lack of study sequencing, connectivity, integration
between biological studies, other proposed
engineering and physical processes studies. Need for
collection of adequate temporal and spatial baseline
biological, fish habitat data to provide direct input to
some of proposed physical modeling efforts. Many
USFWS concerns are related to temporal mismatch of
biological data collection w/ forward momentum of
physical modeling efforts.
Interdependencies Flow Charts have been added to all
study plans to show the flow and integration of data
across studies and resource programs. This detail
includes temporal and spatial biological data on fish
and aquatic habitat. The biological data collection is
being coordinated closely with the physical modeling,
for example the collection of data from multiple
resources in Focus Areas. The biological data on fish
distribution and abundance and habitat
characterization will be used to inform the ISF model.
Study of Fish Distribution and Abundance in Upper Susitna River (Section 9.5) and
Study of Fish Distribution and Abundance in Middle and Lower Susitna River (Section 9.6)
TWG meeting 8/15/2012 Joe Klein ADNR-
ADF&G
Request methods for shocking to include block nets. Block nets have been added to methodology in RSP.
See RSP Section 9.5.4.4.2, 9.6.4.4.2
TWG meeting 8/15/2012 Various USFWS Study site selection should follow a stratified random
design.
A stratified random design is being proposed. AEA
has included additional detail and documentation in the
RSP regarding the sampling effort by strata. See RSP
Section 9.5, and 9.6. In addition, strata have been
modified per review of the 2012 video in the middle
and lower river. This modification is presented in both
Habitat Characterization and Fish Distribution and
Abundance Revised Study Plans. See RSP Section
9.5.4.1, and 9.6.4.1.
E-mail 8/23/2012 Joe Klein ADNR-
ADF&G
Minnow trapping under ice should be used during the
winter, in all habitat types.
Winter access in the Upper River will be evaluated in a
pilot study conducted this winter (2012-2013).
Depending on the results of the pilot study AEA will
add minnow trapping under ice in multiple locations to
Middle River sampling methodology in the RSP. See
RSP Section 9.6.4.3.1.
E-mail 8/23/2012 Joe Klein ADNR-
ADF&G
Evaluate the feasibility of under ice videography. Winter access in the Upper River will be evaluated in a
pilot study conducted this winter (2012-2013).
Depending on the results of the pilot study AEA will
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 55 December 2012
Comment
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add video under ice in multiple locations to Middle
River sampling methodology in the RSP. See RSP
Section 9.6.4.3.1.
E-mail 8/23/2012 Joe Klein ADNR-
ADF&G
Request use of trot lines in winter. Winter access in the Upper River will be evaluated in a
pilot study conducted this winter. Depending on the
results of the pilot study AEA will add the use of trot
lines for winter sampling in the Middle River to the RSP
for the Middle and Lower River. See RSP Section
9.6.4.3.1, 9.6.4.4.4.
Email 9/07/2012 Betsy
McCracken
USFWS A first step is to assess the seasonal distributions of
target species and life stages and the physical habitat
criteria that influence habitat selection and suitability.
As a first step, target species have to be identified,
agreed upon, and their life history and habitat use
similarities to other, unstudied species (i.e., non-target
species) need to be determined and described. In the
study requests of the Service and other agencies, we
recommended studying the baselines of all affected
fish species and life stages, including all five species
of anadromous salmon and all resident fish.
AEA will be studying seasonal distribution and life
stages of all target species as described in detail in
Objective 1 of the Fish Distribution and Abundance
Study Plan. Target species lists were presented,
discussed and agreed upon in TWG meetings in May.
Since that time specific additions have been requested
by ADF&G and USFWS and these requests have been
added to that study plan. See RSP Section 9.6.4.3.
In addition, AEA is proposing a habitat based sampling
design for Fish Distribution and Abundance. Part of
the value in this approach is that all fish species and
life stages present at sampling locations will be
targeted. Multiple methods will be used at each
location to capture all species and life stages present,
including all five species of anadromous salmon and
resident fishes. See RSP Section 9.6.4.1.
Email 9/07/2012 Betsy
McCracken
USFWS Fish distribution data are needed to describe the
baseline data to support and compliment other
proposed study objectives, including those related to
fish habitat selection and utilization. A first step to
acquiring adequate fish distribution is to assess the
full lateral and longitudinal profile of seasonal fish
distribution, life stage periodicity, and suitable used
and unused habitats that are influential in fish habitat
site selection.
Fish distribution data will be collected as part of
Objective 1 of the Fish Distribution and Abundance
Study Plan. Data will be collected in representative
habitats and across all seasons in the middle and
lower river. Data will be collected in the open water
period in the upper river. See RSP Section 9.5.4.3.1,
9.6.4.3.1.
AEA is proposing a habitat based sampling design for
Fish Distribution and Abundance. This approach
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 56 December 2012
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includes seasonal sampllng throughout that lateral and
longitudinal habitats identified in the Susitna River.
Part of the value in this approach is that AEA is not just
going where AEA thinks fish will ,or will not, be based
on 1980s data, instead AEA is proposing stratified
random design to document fish presence. Multiple
methods will be used at each location to attempt
capture all species and life stages present. With this
approach we would expect to document habitat that
are and are not used by fish. See RSP Section 9.5.4.1,
9.6.4.1.
Email 9/07/2012 Michael
Buntjer
USFWS PSP = Collect tissue samples to support the Genetic
Baseline Study for Selected Fish Species (Section
7.14); (7.5 upper reach)
Comment = No mention of analyzing samples;
analysis mentioned in Genetic Baseline Study, but
link/integration to analyzing samples collected in this
study is not discussed. Will samples be analyzed?
Explain.
Yes. AEA has included additional detail in the RSP for
Genetic Baseline Study for Selected Fish Species that
includes descriptions of both laboratory analysis of
samples and analysis of genetic structure of Chinook
salmon populations. See RSP Section 9.14.4.3.
Email 9/07/2012 Michael
Buntjer
USFWS PSP = Document the timing of downstream
movement and catch for fish species via outmigrant
traps; (7.5 upper reach)
Comment = Unclear if the timing of downstream
movement and catch for the upper river includes or
excludes addressing outmigration and winter sampling
AEA has included additional detail in the Study of Fish
Distribution and Abundance for the Upper Susitna
River RSP regarding the location and timing of
outmigrant trapping and winter sampling. See RSP
Section 9.5.4.3.2, 9.5.4.3.2.
Initial written
comments to
PSP
9/07/2012 USFWS staff USFWS The list of habitat types to be sampled in the middle
and lower reaches appears longer than habitats
proposed for the upper reach
AEA has included additional detail in the RSP to clarify
that the lists of habitat types for the Middle/Lower and
Upper reaches are similar, but the actual habitat types
will be defined by the habitats present in the mainstem
and tributaries of interest. See RSP Section 9.5.4.1,
9.6.4.1, and 9.9.
Email 9/07/2012 Michael
Buntjer
USFWS Only winter sampling I see proposed in the upper
reach includes using DIDSON and video cameras in
10 “selected” sloughs and side channels; how
were/will sites be selected?; What other habitat types
AEA has added additional detail in the Study of Fish
Distribution and Abundance in the Middle and Lower
Susitna River by including an objective for winter
sampling and describing the techniques, locations and
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 57 December 2012
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are available and why are they not being sampled? Is
this sufficient to get at winter distribution and
abundance for all life stages?; will not likely be able to
identify juvenile species using these techniques
(therefore, no distribution and abundance information
and habitat use by species, particularly for early life
stages (<60 mm); other winter sampling (using
gillnets, minnow traps, and trot lines) is listed in the
schedule section (and not in methods), but it is not
described.
timing of proposed sampling. See RSP Section
9.6.4.3.1, 9.6.4.3.2, 9.6.4.3.3, 9.6.4.3.4.
In addition, a study objective focused on Early Life
history of Anadromous Salmon has been added to
focus sampling on this species and life stages. See
RSP Section 9.6.4.3.3.
Email 9/07/2012 Michael
Buntjer
USFWS Comment = Study Request objectives 7-9 are not
addressed in 7.5 or 7.6; there is no mention of egg
incubation (rates or success), hatching (rates or
success), stranding (ramping rates) or emergence
(dates and times) sampling anywhere; no mention of
baseline intragravel temperature or water quality
monitoring of spawning and pre-emergent juvenile fish
habitats; no mention of characterizing baseline water
quality conditions at spawning or rearing habitats.
Only mention is in Study Goals (6.5.1.2, page 6-10);
Objective 8. Conduct a variety of post-processing
comparative analyses derived from the output metrics
under aquatic habitat models. Approach appears to
evaluate using only physical habitat models and
without empirical sampling post-spawning through
emergence and for juveniles up to PIT tagging size
(i.e., 60 mm).
Study Request Objectives 7-9 are now addressed
more specifically. AEA has added a study objective
focused on Early Life history of Anadromous Salmon
has been added to the Study of Fish Distribution and
Abundance in the Middle and Lower Susitna River
RSP. See RSP Section 9.6.4.3.3. This study objective
includes efforts to evaluate emergence, early
movements, and stranding of fry/parr. In addition a
hyporheic study will address water quality in spawning
areas. See RSP Section 8.5.2.1.6.
E-mail 9/07/2012 Mike Buntjer USFWS There does not appear to be any studies to collect
baseline biological or physical spawning habitat
information between the time eggs are deposited in
redds and the time of fry emergence
The Intergravel Study will collect data on the physical
characteristics of spawning habitat.
See RSP Section 8.5.2.1.6, 9.6.4.3.3.
Initial written
comments to
PSP
9/07/2012 USFWS staff USFWS Unclear if Biotelemtry objective includes or excludes
PIT tagging juvenile anadromous salmon.
AEA has added additional detail in the RSP to clarify
that that juvenile salmon will be included in PIT tagging
efforts. See RSP Section 9.5.4.3.2, 9.5.4.4.10,
9.6.4.3.2, 9.6.4.4.12.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 58 December 2012
Comment
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Initial written
comments to
PSP
9/07/2012 USFWS staff USFWS The Middle/Lower River study objective ‘characterize
the age structure, growth, and condition of juvenile
anadromous and resident fish by season’ is not in the
Upper River PSP.
Is this study objective limited to juveniles or should it
say “all” resident fish?
AEA has added the objective to characterize the age
structure, growth, and condition of juvenile
anadromous and all resident fish by season to the
Upper River RSP. See RSP Section 9.5.1.1.
Comments on
Agency
consultation
meeting notes
9/13/2012 Michael
Buntjer
USFWS Michael’s comment reads: “Seems to me this is at the
margins of the ice cover season. Jan-Mar would
seem to provide safer ice conditions for accessing
sites? …would like more discussion.”
Winter access in the Middle River will be evaluated in a
pilot study conducted this winter (2012-2013).
Depending on the results of the pilot study AEA will
add additional sampling events and locations to the
Study of Fish Distribution and Abundance in the Middle
and Lower Susitna River RSP. See RSP Section
9.6.4.3.1, 9.6.4.3.2, 9.6.4.3.3.
Comments on
Agency
consultation
meeting notes
9/13/2012 Michael
Buntjer
USFWS Is “population estimate” a necessary objective? Could
do more frequent sampling for CPUE instead of
population estimate sampling.
AEA has eliminated population estimation from the
Study of Fish Distribution and Abundance in the Middle
and Lower Susitna River RSP. See RSP Section
9.6.4.3.1.
Agency
consultation
meeting
9/13/2012 Betsy
McCracken
USFWS Unclear whether juvenile salmon would be included in
Objective #2
AEA has added additional detail in the RSP to clarify
that juvenile salmon are included in Objective #2. In
addition, AEA has added additional early life history
objectives. See RSP Section 9.5.1.1, 9.6.1.1.
Agency
consultation
meeting
9/13/2012 Jeff Davis ARRI Request that sampling be tied to species and life
stage specific objectives
AEA’s approach to fish sampling is habitat-based not
driven by where we would expect to find individual
species and life stages of fish. Sampling will be
stratified by geomorphic reaches and mainstem habitat
categories. Random samping within the habitat strata
will ensure that sampling is representative of all
habitats present in the system and therefore will be
effective at capturing all species and life stage are
present within these habitats.. In addition, monthly
sampling in those representative sites will be
implemented to determine what species and life stages
are using those habitats seasonally. See RSP Section
9.5.4.3, 9.6.4.3.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 59 December 2012
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Agency
consultation
meeting
9/13/2012 Stormy
Haught,
Monte Miller
ADNR-
ADF&G
Concerns with using PIT tags: 1) half vs full duplex
tags, 2.) size of fish tagged, 3) human ingestion of
tags
PIT tag systems have been evaluated. AEA is
considering use of Texas Instruments half-duplex tags
due to the flexibility of system and the ability to tailor it
to local conditions at a reasonable cost. See RSP
Section 9.5.4.4.10, 9.6.4.4.12
Agency
consultation
meeting
9/13/2012 ADF&G staff ADNR-
ADF&G
Request grayling to be added to list of species to be
radio tagged
Grayling has been added to target species list.
See RSP Section 9.5.1.1, 9.6.1.1.
Agency
consultation
meeting
9/13/2012 Betsy
McCracken
USFWS USFWS recommended Beechie as opposed to USFS
which was developed for small SE streams and
relative to forest practices
The methods for habitat characterization were
discussed and approved in an agency meeting in May
2012. The USFS method is a standardized approach
that is widely used in many rivers, including larger
waters. In addition, to using that protocol for habitat
characterization, AEA has revised the Habitat
Characterization study plan to include the delineation
and characterization of “edge habitat” in mainstem
reaches. See RSP Section 9.9, 9.5.1.1, 9.6.1.1.
Agency
consultation
meeting
9/13/2012 ADF&G staff ADNR-
ADF&G
Request for details of surgical methods, battery life
and specifications which determine battery life.
Additional detail has been added to the study plan on
tagging and tags. However, detail on tag specifications
and battery life will be available post RSP in an study
implementation plan. See RSP Section 9.5.4.4.10,
9.6.4.4.12
Agency
consultation
meeting
9/13/2012 Monte Miller ADNR-
ADF&G
Request a table in RSP which includes: proposed
tagged species, type of tagging, number of
individuals, and any discrepancies.
A table with detail on target species and sample sizes
has been added to the Fish Distribution and
Abundance Study plans. See RSP Section 9.5 Table
9.5-2, 9.6 Table 9.6-2.
Agency
consultation
meeting
9/13/2012 Mike Buntjer USFWS Request data on movement (and timing) of newly
emergent fish from spawning to rearing areas or
movement of juvenile fish <60 mm in winter.
Specifically:
1. How will the Project effect changes in
temperature and survival? (There will be an
Intergravel study in the ISF program).
2. How will flow fluctuations affect early life
history? (The ISF physical habitat model will
An objective on early life history of anadromous
salmon has been added to the Study of Fish
Distribution and Abundance in the Middle and Lower
Susitna River RSP study plan. This objective includes
subobjective to address timing, movements, and
diurnal behavior of anadromous salmonids in the
Middle/Lower River. See RSP Section 9.6.4.3.3
In addition there has been an intergravel study
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 60 December 2012
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address this)
3. When are fish active- day vs. night?
4. Timing of movements with respect to flows
to understand Project flow effects
component added to the Riparian Instream Flow Study
Program to help collect baseline information that will be
used to evaluate project effects on incubating embryos.
See RSP Section 8.5.2.1.6.
Phone
conversation
9/19/2012 Matt Evenson ADNR-
ADF&G
Burbot sampling methodologies. Suggested burbot
be captured with hoop traps for radio tagging; trot
lines are lethal to burbot.
AEA has added hoop traps to capture methods in the
RSP. See RSP Section 9.5.4.4.8, 9.6.4.4.8.
Email 9/07/2012 Michael
Buntjer
USFWS PSP = Collect tissue samples from juvenile salmon
and opportunistically from all resident and non-salmon
anadromous fish to support the Genetic Baseline
Study (Section 7.14). (7.6 middle and lower reach)
Because PSP is not structured similarly to our study
requests, why is this study objective limited to juvenile
salmon? This may be okay, because genetic
sampling included in Salmon Escapement Study,
though no mention in study of analyzing samples or
overall links between studies. Without providing
linkages between studies, there is a lot of searching
required to find if, where, and how information is being
collected.
Genetic sampling in the Fish distribution and
Abundance studies (RSP Sections 9.5 and 9.6) is
complimentary to Adult Escapement study (RSP
Section 9.7). As such the Fish Distribution and
Abundance study plans do not address collecting
samples from adult salmon; that is included in the
Genetic Baseline Study for Selected Fish Species plan.
This is addressed by the study interdepencies flow
chart described in RSP Section 9.14.7.
Email 9/07/2012 Michael
Buntjer
USFWS PSP = Characterize the age structure, growth, and
condition of juvenile anadromous and
resident fish by season; (7.6 middle and lower reach)
Comment = Is there a difference between Document
(as requested) and Characterize (as proposed)?
Explain
Is this study objective limited to juveniles or should it
say “all” resident fish.
This objective is not included in upper reach; should
at least characterize age structure for all resident and
anadromous fish by season
AEA has revised the terminology in the RSP to use the
term “document” instead of the term “characterize”.
This objective will be applied to all fish species
collected and has been added to study plan for Upper
River. See RSP Section 9.5.4.1, 9.6.4.1
Email 9/07/2012 Michael
Buntjer
USFWS PSP = Document the timing of downstream
movement and catch for all fish species using
The use of outmigrant traps is intended to address
downstream movements of fish species that have
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 61 December 2012
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outmigrant traps; (7.6 middle and lower reach)
Comment = Unclear if this includes or excludes
addressing outmigration
known out-migrations. The placement of the traps will
reflect locations where the likelihood of intercepting
target species is high. This is described in the RSP.
See RSP Section 9.5.4.3.2, 9.6.4.3.2.
Email 9/07/2012 Michael
Buntjer
USFWS PSP = 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;
(7.6 middle and lower reach)
Comment =
Also, mentions installing up to 10 antenna arrays; is
that sufficient to determine movement of juveniles in
and out of habitats by reach? When, where, and how
will sites be selected? What is rationale and
assumptions for selecting habitat types and sites?
AEA has added additional detail in the RSP on radio
telemetry of target species and array design. See RSP
Section 9.5.4.4.10, 9.6.4.4.12
Agency
consultation
meeting
9/13/2012 Jeff Davis ARRI Sampling frequency: suggested bi-weekly sampling
during the critical periods for early life stages of
salmon
Biweekly sampling has been added to the study plan
for the objective related to early life history of salmon.
See RSP Section 9.5.4.2, 9.6.4.2
TWG meeting 9/14/2012 Jeff Davis USFWS Jeff Davis asked what classification scale critical sites
(addressing specific life stages of fish) will be based
on.
As described in the RSP fish sampling will occur at
several habitat categories including the mainstem
habitat, mesohabitat and edge habitat levels. These
levels vary with the size and complexity of the river
system. It is possible that one life stage of a species,
including critical life stages will be sampled at all or
some of these three different levels in different part of
the river This should not be unexpected as fish move
between habitats both within and across seasons and
sampling will occur on a seasonal or monthly basis.
See RSP Section 9.5.4.1, 9.6.4.1.
Phone 9/18/2012 Randy Brown USFWS Existing cisco whitefish data. Recent studies by Will consider dropping cisco from list of focal species in
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 62 December 2012
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conversation Brown 2008-2011 (unpub) have ID’ed relative
abundance, distribution, age camp, and spawning
timing; suggest dropping cisco from list of species
study
Agency
consultation
meeting
9/27/2012 Michael
Buntjer
USFWS Requests the periodicity data sources be referenced. Sources for periodicity tables used in Project studies
will be given proper citations. See RSP Section 9.5.4.3,
9.6.4.3.
Agency
consultation
meeting
9/27/2012 Michael
Buntjer
USFWS Requests clarification on the sampling approach in the
lower river due to the more broad habitat classification
applied.
The Habitat Characterization Plan has been revised
and includes clarifying information on the habitat
mapping approach for the Lower River and the
limitations of delineating at a scale finer than mainstem
habitats. See RSP Section 9.6.4.1.
Salmon Escapement Study (Section 9.7)
Email 8/23/2012 Joseph Klein ADNR-
ADF&G
Identify locations of adult fish weir locations described
on tributary streams (7.7.4.1.5, page 7-39). Consider
placement of adult fish weir upstream of the proposed
dam on prominent Chinook salmon streams.
AEA has added additional detail in the RSP identifying
the likely weir locations. See RSP Section 9.7.4.4.2.
In light of 2012 results on Chinook salmon above
Devils Canyon, AEA is concerned that an adult fish
weir could delay or deter the upstream migration. The
current tagging and escapement study design will
adequately address the distribution and habitat use of
adult Chinook salmon above the dam with less risk for
alteing fish behavior.
Email 9/07/2012 Michael
Buntjer
USFWS = Need to define “generate count” and how
generated. If it is an index of abundance, then need
to identify the standardized unit of effort. Also, not
sure why escapement estimate is not being
determined? This study references escapement
estimates from the 1980s, but not here. Explain.
Counts will be visual observations of individual salmon
in clear-water areas within the study area. These
counts will be obtained from helicopter, ground, and/or
on-water surveys of tributaries and mainstem habitats
of the middle and upper river. The primary use for
these counts is not an index of abundance but is
instead to quantify mark rates among different areas.
Mark rate is the fraction of the fish that are tagged.
Mark rate derivation takes into account survey
conditions and observer efficiency.
Escapement estimate are not being determined
because escapement levels are not critical to
conducting an assessing the proposed project’s
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 63 December 2012
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impacts. Some quantification of abundance above the
tagging sites and in particular habitats will be possible,
but not total escapement to river sections (e.g., middle
and/or upper river).
The Salmon Study Plan has additional text to address
counting and estimates of abundance.
Email 9/07/2012 Michael
Buntjer
USFWS In Study Request = Determine the availability and
accessibility of spawning habitats by adult salmon to
mainstem and tributary locations based upon flow
regime.
Comment = Unclear if, how, or where this Study
Request objective is being addressed.
Not listed as an objective in this study; section
6.5.4.3.1 (page 6-19) describes assessing access to
rearing and spawning habitats via output from flow
routing models. Also, objective 13 (shown below) in
fish passage study (section 7.12); page 7-98):
13. Evaluate the potential creation of fish passage
barriers within existing habitats (tributaries, sloughs,
side channels, off-channel habitats) related to future
flow conditions, water surface elevations, and
sediment transport.
AEA describes how this study request objective is
being address in both the Fish Barriers and ISF study
plans. RSP Sections 9.12 and 8.5.
In addition text has been added to better describe the
interdependencies of the Fish Barriers and ISF study
plans with respect to access to rearing and spawning
habitats, including mainstem sloughs, side channels,
off-channel habitats and tributaries. RSP Sections
9.12.1.1 and 8.5.4.61.7.
Email 9/07/2012 Michael
Buntjer
USFWS In Study Request = 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.
Comment = Do not see this study request objective
addressed or 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 see
determining distribution and potential abundance of
Detail has been added to the Riparian Instream Flow
study plan to address these concerns. See RSP
Sections 8.5.4.6.1.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 64 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
redds. Also, see mention of evaluating potential
dewatering or scouring of redds in Chapter 6, but no
empirical baseline information to assess daily load-
following operations.
Email 9/07/2012 Betsy
McCracken
USFWS Request that tissue samples be obtained from radio-
tagged Chinook salmon
AEA has added additional detail to the RSP by
including descriptions of how tissue samples will be
taken from radio-tagged salmon in 2013/14. AEA
notes that AEA’s ability to do so is subject to ADF&G
Fish Research Permit conditions.
Email 9/07/2012 Betsy
McCracken
USFWS Clarify what you mean by “generate counts” of adult
Chinook salmon. Are escapement estimates being
made?
The RSP study plan defines “generate count” (Section
9.7.4.4.2). Counts will be visual observations of
individual salmon in clear-water areas within the study
area. These counts will be obtained from helicopter,
ground, and/or on-water surveys of tributaries and
mainstem habitats of the middle and upper river. The
primary use for these counts is not an index of
abundance but is instead to quantify mark rates among
different areas. Mark rate is the fraction of the fish that
are tagged. Mark rate derivation takes into account
survey conditions and observer efficiency.
Escapement estimates of the middle and upper river
are not proposed as explicit objective. Escapement
levels are not critical to conducting an impact analysis.
Some quantification of abundance above the tagging
sites and in particular habitats will be possible, but not
total escapement to river sections (e.g., middle and/or
upper river).
Email 9/07/2012 Betsy
McCracken
USFWS No mention of analyzing non-Chinook tissue for
genetics.
Only Chinook analyses are proposed as part of
Genetic Baseline Study for Selected Fish Species (See
RSP 9.14.4 for additional responses to this comment).
Email 9/07/2012 Betsy
McCracken
USFWS It is unclear where issue of availability of habitat
affected by altering flows is addressed.
This is address by instream flow model and using data
from several studies in the RSP, including the salmon
escapement (distribution and habitat use by spawning
salmon). See RSP Section 8.5.4.3.1.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 65 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
Agency
consultation
meeting
9/25/2012 Jack Erickson
and James
Hasbrouck
ADNR-
ADF&G
Series of suggested edits/clarifications to PSP.
Clarified that coho salmon escapement does not need
to be “system-wide” but instead only Susitna River
above Yentna River
AEA has added additional detail in the RSP tto clarify
that coho escapement only applies to Susitna above
Yentna confluence. See RSP Section 9.7.4.4.2.4.
River Productivity Study (Section 9.8)
TWG meeting 8/15/2012 Mike Buntjer USFWS Discussion regarding Objective 4 (Section 7.8.4.4),
inquired about the rationale for not having surrogate
sites in Alaska.
During the River Productivity Subgroup meeting it was
discussed that surrogate systems likely do not exist in
Alaska; there are no regulated glacial rivers with
reservoirs of similar size and potential operations.
Thus is was determined that adding a literature review
of glacial rivers affected by water regulation to
Objective 1 of the River Productivity Study was an
acceptable alternative. This was agreed to by the
Subgroup participants including representatives from
AEA, USFWS, NMFS, and ADF&G. See RSP Section
9.8.4.1.
TWG meeting 8/15/2012 Jeff Davis ARRI Discussion regarding Objective 4 (Section 7.8.4.4),
expressed concerns about literature-based
assessment
This subject was further discussed in the 9/27/12
Agency consultation meeting. Literature review of
glacial rivers affected by river regulation will be
included in Objective 1, synthesis of literature
reviewed, in the RSP, Section 9.8.4.1..
TWG meeting 8/15/2012 Jeff Davis ARRI Suggests that study plan should be measuring
primary and secondary productivity by conducting
stream respiration / metabolism studies.
This subject was further discussed in the 9/27/12
Agency consultation meeting.
AEA has revised the River Productivity Study plan to
include a more rigorous approach to measuring
primary and secondary productivity that includes
collecting data on organic matter, periphyton and
algea, emerging aquatic invertebrates as an estimate
of carbon production, benthic macroinvertebrates, and
drift. These data will be used to describe existing
communities of primary and secondary producers as
well as will feed into two independent trophic models:
one to describe the bioenergetics and a second to
describe origin of food sources under current
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 66 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
conditions (RSP Section 9.8.4.5). AEA thinks this is as
rigorous approach and is associated with less
uncertainty as compared to a stream metabolism
approach.
In addition, stream respiration and stream metabolism
studies are do not correlate well to the communities
(macroinvertebrates, fish) that potentially would be
affected by Project operations. As such this type of
approach would limit our ability to predict project
effects on those communities, outside of a net change
in amount of GPP or ER. , through sampling drift,
benthos, and fish diet) best relates changes in the
ecosystem to fish.
TWG meeting 8/15/2012 Joe Klein ADNR-
ADF&G
Discussion regarding Objective 4 (Section 7.8.4.4),
expressed concerns about literature-based
assessment
This subject was further discussed in the 9/27/12
Agency consultation meeting. Literature review of
glacial rivers affected by river regulation will be
included in Objective 1, synthesis of literature
reviewed, in the RSP, Section 9.8.4.1.
TWG meeting 8/15/2012 Jeff Davis,
Joe Klein
ARRI, ADNR-
ADF&G
Requested sampling in deep water Current federal protocols (specifically Angradi et al.
2006, as well as those cited in the RSP Section
9.8.4.2) recommend shoreline littoral sampling, as they
are usually considered to be where much of the
macroinvertebrate productivity takes place.
Furthermore, shoreline areas are the locations that will
be most affected by the Project. Sampling deeper
benthic habitats farther out in the channel is
challenging and benthic organisms are usually lower in
abundance in these habitats (Angradi et al. 2006).
Email 8/23/2012 Joseph Klein ADNR-
ADF&G
7.8.4.4 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. We recommend
supplementing or substituting this section using a
reference reach in a similar Alaska river using a BACI
design monitoring program in order to assess post
During the River Productivity Subgroup meeting it was
discussed that surrogate systems likely do not exist in
Alaska so that adding a review of potential project
effect to Objective 1 of the River Productivity Study
was an acceptable alternative. This was agreed to by
the Subgroup participants including representatives
from AEA, USFWS, NMFS, and ADF&G. AEA has
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 67 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
project impacts. included in the RSP a feasibility study to identify the
suitability of the Talkeetna River as a reference reach.
RSP Section 9.8.4.4.
AEA will consider the use of a BACI design when
developing a monitoring plan for post-project impacts
to river productivity. Prior to developin a monitoring
plan it is important first to obtain results from baseline
studies and have finalized Project operation
procedures.. See RSP Section 9.8.4.4.
Email 9/07/2012 Betsy
McCracken
USFWS Marine derived nutrients are mentioned in Section
7.5.2 in association with the River Productivity Study,
but are not mentioned elsewhere in the PSP.
AEA has added additional detail to the RSP describing
how marine derived nutrients will be addressed with a
stable isotope analysis as part of the trophic analysis.
See RSP Section 9.8.4.5.2.
Email 9/07/2012 Betsy
McCracken
USFWS Trophic ecology needs to be clearly spelled out in a
study plan identifying any aspects that will and will not
be addressed explained and with appropriate
rationale.
This subject was further discussed in the 9/27/12
Agency consultation meeting. AEA has added
additional detail to RSP by describing a more rigorous
approach in defining trophic relationships. Options
discussed included bioenergetics, stable isotope
analysis, and adult insect emergence traps. See RSP
Section 9.8.4.5.2.
Email 9/06/2012 Joseph Klein ADNR-
ADF&G
Recommends identifying a reference reach in a
similar Alaska river for using a BACI design
monitoring program to assess post project impacts.
RSP will address reference sites in Objective 4
(Section 9.8.4.4), with a feasibility study on the
Talkeetna River in 2013, conducting sampling efforts
on multiple sites to assess community similarities with
middle Susitna River sites.
Email 9/07/2012 Michael
Buntjer
USFWS Study Request = Develop a white paper on the
impacts of hydropower development and operations
(including temperature and turbidity) on benthic
macroinvertebrate and algal communities in cold
climates.
PSP = Synthesize existing literature on the impacts of
hydropower development and operations (including
temperature and turbidity) on benthic
“Developing a whitepaper” and “synthesizing existing
literature” may be considered synonymous. However,
stating “develop a white paper” may hold different
meaning or expectations for different parties, and
would require a definition of what a whitepaper is.
Therefore, the PSP refers to the action of synthesizing
existing literature, in descriptive terms, to clarify the
proposed task. RSP Section 9.8.4.1.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 68 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
macroinvertebrate and algal communities;
Comment = Any difference in developing a white
paper versus synthesizing existing literature?
Email 9/07/2012 Michael
Buntjer
USFWS Study Request = Characterize the pre-project benthic
macroinvertebrate and algal communities with regard
to species composition and abundance in the lower,
middle and upper Susitna River.
PSP = Characterize the pre-Project benthic
macroinvertebrate and algal communities with
regard to species composition and abundance in the
middle and upper Susitna River;
Comment = Omission of lower reach is an apparent
typo.
AEA has considered the inclusion of sampling for
macroinvertebrates and algae in the Lower Susitna
River and has determined that, at this time, sampling in
the Lower River is not warranted. Given the dramatic
change is discharge, turbidity and temperature in the
Susitna River associated with the inflows from the
Talkeetna and the Chulitna River we do not anticipate
Project related affects that will be translated to primary
and secondary producers. Our approach for river
productivity is to establish a rigorous sampling program
for the locations with the greatest potential for change,
the river upstream and directly downstream of the
proposed Project dam site.
Email 9/07/2012 Michael
Buntjer
USFWS Study Request = 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.
PSP = Estimate drift of benthic macroinvertebrates in
selected habitats within the middle and upper Susitna
River to assess food availability to juvenile and
resident fishes;
Comment = Omission of lower reach is an apparent
typo.
AEA has considered the inclusion of sampling for
macroinvertebrates and algae in the Lower Susitna
River and has determined that, at this time, sampling in
the Lower River is not warranted. Given the dramatic
change is discharge, turbidity and temperature in the
Susitna River associated with the inflows from the
Talkeetna and the Chulitna River we do not anticipate
Project related affects that will be translated to primary
and secondary producers. Our approach for river
productivity is to establish a rigorous sampling program
for the locations with the greatest potential for change,
the river upstream and directly downstream of the
proposed Project dam site.
Email 9/07/2012 Michael
Buntjer
USFWS Study Request = Conduct a trophic analysis to
describe potential changes in the primary and
secondary productivity of the riverine community
following post-project construction and operation
PSP = Conduct a review on the feasibility of a trophic
This subject was further discussed in the 9/27/12
Agency consultation meeting.
AEA has added additional detail n the RSP describing
a more rigorous empirical approach to define trophic
relationships. See RSP Section 9.8.4.5.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 69 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
analysis to describe potential changes in the primary
and secondary productivity of the riverine community
following Project construction and operation;
Comment = Shouldn’t this read: Conduct a trophic
analysis, if feasible, to describe…? Also, why would it
not be feasible? Explain.
Email 9/07/2012 Michael
Buntjer
USFWS Study Request = Characterize the benthic
macroinvertebrate compositions in the diets of
representative fish species in relationship to their
source (benthic or drift component).
PSP = Characterize the macroinvertebrate
compositions in the diets of representative fish
species in relationship to their source (benthic or drift
component);
Comment = I assume this should include term
“benthic”. If not, explain difference.
Analysis of fish diets of target species will include both
benthic and terrestrial invertebrates. RSP will mention
the terrestrial component in this objective, as well as
the drift objective, Sections 9.8.4.3 and 9.8.4.7.
Email 9/07/2012 Michael
Buntjer
USFWS Study Request = Evaluate the feasibility of reference
sites on the Talkeetna and Chulitna Rivers to monitor
baseline productivity, pre- and post-construction.
(deleted in PSP; and not addressed)
PSP = AEA replaced this objective (with #4 below),
but based on discussion at August 15, 2012, TWG
meeting it was suggested to do both or keep the
original Study Request objective. We recommend
and support that suggestion.
Comment = 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. (added in PSP)
This subject was further discussed in the 9/27/12
Agency consultation meeting. Literature review of
glacial rivers affected by river regulation will be
included in Objective 1, synthesis of literature
reviewed, in the RSP. See RSP Section 9.8.4.1.
RSP will address reference sites in Objective 4
(Section 9.8.4.4), with a feasibility study on the
Talkeetna River in 2013, conducting sampling efforts
on multiple sites to assess community similarities with
middle Susitna River sites.
Email 9/07/2012 Michael
Buntjer
USFWS Study Request = 9. Estimate benthic
macroinvertebrate colonization rates in the middle and
AEA has added additional detail in the RSP including
an analysis of fish food sources including freshwater
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 70 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
lower reaches to monitor baseline conditions and
evaluate future changes to productivity in the Susitna
River
PSP = 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.
Comment = Note: Page 7-12 of PSP states that
marine derived nutrients are included in River
Productivity Study, but there is no mention of it in
Chapter 7; i.e., is not addressed.
and marine derived nutrients as part of the trophic
analysis. See RSP Section 9.8.4.5.2.
Initial written
comments to
PSP
9/27/2012 Jeff Davis ARRI Regarding Section 7.8.4.2.1, request for additional
details of site-specific sample locations and sampling
methodology
The RSP will include additional details regarding
sampling methodology, which will be based on
accepted federal agency standardized methods, such
as the USGS NAQWA protocols, which sample in
“richest-targeted habitat”, typically riffle-like habitat and
woody snags. See RSP Section 9.8.4.2.1. Sampling
locations will follow this standardized sampling
approach and availability within sampling focus areas;
details will be addressed in the implementation plan.
Initial written
comments to
PSP
9/27/2012 Jeff Davis ARRI Regarding Section 7.8.4.2.1, number of sample sites
per macrohabitat classification.
PSP contains details on sampling areas and number of
sites within those areas in Table 7.8-1, along with
Figures 7.8-1 through 7.8-3. AEA has included in RSP
clarification that sampling focus areas contain 1
mainstem site and 2 off-channel sites that are
associated with that mainstem site. See RSP Section
9.8.4.2.1.
Initial written
comments to
PSP
9/27/2012 Jeff Davis ARRI Regarding Section 7.8.4.2.1, inquired if macrophyte
beds should be included as habitat to be sampled for
benthic macroinvertebrates
No documentation of macrophyte beds as a major
habitat area in the Susitna. No plans to further stratify
for this habitat type.
Initial written
comments to
PSP
9/27/2012 Jeff Davis ARRI Questions on methodology of sample snags for
macroinvertebrates (in Section 7.8.4.2.1)
PSP refers readers to Moulton et al. 2002 for USGS
protocols on snag sampling. RSP Section 9.8.4.2.1.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 71 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
Initial written
comments to
PSP
9/27/2012 Jeff Davis ARRI Objective 3, Section 7.8.4.3, invertebrate drift
sampling methods and timing.
RSP will clarify that drift sampling will occur in spring,
summer, and fall, and that 12 of the 18 sites to be
sampled will be in a focus area in the Middle Reach,
which include mainstem sites paired with1-2
associated off-channel sites. RSP Section 9.8.4.1, and
9.8.4.3.
Initial written
comments to
PSP
9/27/2012 Jeff Davis ARRI Objective 5, Section 7.8.4.5, trophic analysis. AEA has revised the RSP to include a more rigorous
approach in defining trophic relationships and
addressing estimates of river productivity. See RSP
Section 9.8.4.5.
Initial written
comments to
PSP
9/27/2012 Jeff Davis ARRI Regarding Objective 6, Section7.8.4.6, HSC criteria
development. Concerned that level of sampling is
insufficient.
AEA has added additional detail in the RSP regarding
the HSC/HSI criteria development process. See RSP
Section 9.8.4.6. In the RSP, the suitability information
is literature-based, with validation by site-specific field
observations, and finalization by expert panel.
Initial written
comments to
PSP
9/27/2012 Jeff Davis ARRI Regarding Objective 7, Section7.8.4.7, questioned
what the objective is for fish diet analysis.
Fish diet analysis will provide information on what
target fish species are consuming in relation to their
overall abundance in community and their prevalence
in drift. See RSP Section 9.8.4.7.
Initial written
comments to
PSP
9/27/2012 Jeff Davis ARRI Regarding Objective 7, Section7.8.4.7requested
additional details about sampling efforts (locations and
frequency).
AEA has added additional detail in the RSP regarding
the implementation plan. RSP describes how the
efforts will be coordinated with relevant fish study for
timing and locations at focus areas. See RSP Section
9.8.4.7.
Initial written
comments to
PSP
9/27/2012 Jeff Davis ARRI Regarding Objective 7, Section7.8.4.7, asked if
weights and cohort info should be collected.
Detail has been added to the RSP including taxa
weights (See RSP sections 9.8.4.2.1, 9.8.4.3, 9.8.4.5,
and 9.8.4.7.). In addition with the inclusion of the
bioenergetics and isotopic analyses AEA approach will
focuses on trophic relationships not production
estimates and thus, does not include cohort analysis.
RSP Section 9.8.4.5.
Initial written
comments to
PSP
9/27/2012 Jeff Davis ARRI Regarding Objective 7, Section7.8.4.7, asked if
terrestrial invertebrates and riparian vegetation cover
information should be collected.
Terrestrial invertebrates will be analyzed in drift
samples and fish diet analysis (RSP sections 9.8.4.3
and 9.8.4.7). Additional information on riparian
vegetation will be available from the Riparian
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 72 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
Vegetation Study Downstream of the Proposed
Watana Dam or Riparian Instream Flow studies. The
interdependencies of the Riparian Vegetation Study
Downstream of the Proposed Watana Dam and the
River Productivity Study will be clarified as baseline
data are collected and we learn what proportion of the
drift and fish diet is derived from terrestrial, specifically
riparian, resources.
Initial written
comments to
PSP
9/27/2012 Jeff Davis ARRI Regarding Objective 4, Section7.8.4.4, asked how
and who will determine if additional reference data
collection at other sites is “feasible”.
RSP will address reference sites in Objective 4
(Section 9.8.4.4) with a feasibility study of potential
sites in the Talkeetna River in 2013 which will include
sampling efforts on multiple sites to assess community
similarities with middle Susitna River sites.
Initial written
comments to
PSP
9/27/2012 Jeff Davis ARRI Regarding Objective 8, Section7.8.4.8, requested
more detail on organic matter sampling methods.
AEA has added additional detail in the RSP regarding
the methods of collecting and analyzing organic matter
will be provided in the RSP. See RSP Section 9.8.4.8.
Initial written
comments to
PSP
9/27/2012 Jeff Davis ARRI Regarding Objective 8, Section7.8.4.8, asked if
organic matter processing, flow transport, and
floodplain interactions will be investigated.
AEA is not proposing to such investigations because
such investigations would be focused on river
processes, and less on the trophic community analysis
that is the focus of this study. Results of such
investigations would not be easily related/ correlated to
the organisms of interest, i.e. macroinvertebrates and
fish, and, therefore, would be difficult to use those
results to predict project effects on those communities.
In addition, each of these would require a specialized
and extensive study involving development with or by
other study plans.
Initial written
comments to
PSP
9/27/2012 Jeff Davis ARRI Regarding Objective 9, Section7.8.4.9, request for
additional details on the sample design, materials, and
deployment.
Decisions on specific artificial substrates to be used
will depend on location of the site, flows the devices
will be subjected to, accessibility to the site, vandalism
risks, and comparability to other studies in Alaska.
This decision will be made after consideration of all
focus areas and site-specific information required to
select sampling stations for the study. See RSP
Section 9.8.4.9.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 73 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
Agency
consultation
meeting
9/27/2012 Various
agencies
Various
agencies
Discussion regarding Objective 4 (Section 7.8.4.4),
concerning surrogate sites and a literature-based
assessment.
Literature review of glacial rivers affected by river
regulation will be included in Objective 1, synthesis of
literature reviewed, in the RSP. See RSP Section
9.8.4.1.
Agency
consultation
meeting
9/27/2012 Various
agencies
Various
agencies
Discussion regarding reference sites in a similar
Alaska river for using a BACI type design monitoring
program to assess post project impacts.
RSP will address reference sites in Objective 4
(Section 9.8.4.4) with a feasibility study of potential
sites in the Talkeetna River in 2013 which will include
sampling efforts on multiple sites to assess community
similarities with middle Susitna River sites.
Agency
consultation
meeting
9/27/2012 Various
agencies
Various
agencies
Discussion regarding the BACI design for use in
monitoring program to assess post project impacts.
A BACI type design can be attempted, but there are
concerns about the power of analysis due to the level
of sampling efforts (study plan is only 2 years).
Possible that only large differences will be detectable.
Multivariate analyses could be attempted. Additional
details would be included in an implementation plan.
Agency
consultation
meeting
9/27/2012 Various
agencies
Various
agencies
Discussion regarding Objective 5, Section 7.8.4.5,
trophic analysis and formal productivity measures
RSP will include a more rigorous approach in defining
trophic relationships and addressing estimates of river
productivity. RSP Section 9.8.4.5.
Agency
consultation
meeting
9/27/2012 Various
agencies
Various
agencies
Question about recent flooding and the possible
negative effect it would have upon sampling next year
Sampling requires multiple years in order to account
for the annual variability; high, low, and average years
all need to be sampled. Study plan has the limitation
of 2 years of data.
Agency
consultation
meeting
9/27/2012 Various
agencies
Various
agencies
Regarding Objective 5, Section7.8.4.5, discussion
about options for trophic analysis, productivity
measures
Several approaches were discussed, including
bioenergetics, stable isotope analysis, and adult
emergence sampling. Regarding bioenergetics, target
species may include all 3 salmon species fry/juveniles,
and possibly stickleback. RSP Section 9.8.4.5.
Agency
consultation
meeting
9/27/2012 Various
agencies
Various
agencies
Discussion regarding Objective 4 (Section 7.8.4.4),
surrogate sites in Alaska vs. literature-based.
There are no glacial rivers with hydropower operations
of the proposed size and operation in Alaska.
Literature review of glacial rivers affected by river
regulation will be included in Objective 1, synthesis of
literature reviewed, in the RSP, Section 9.8.4.1.
Agency
consultation
9/27/2012 Jeff Davis ARRI Suggests that study plan should be measuring
primary and secondary productivity by conducting
RSP will include a more rigorous approach in defining
trophic relationships between algae, benthos, and fish
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 74 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
meeting stream respiration / metabolism studies. (RSP Section 9.8.4.5.). Surrogate for productivity
would be adult insect emergence sampling, measuring
carbon production emerging from river (RSP Section
9.8.4.2.1). This measure has been successful in other
Alaskan systems, and ties in benthic
macroinvertebrates and fish. Chlorophyll-a and AFDM
measures are commonly used in federal protocols as
surrogates for primary productivity, as well. Stream
respiration and stream metabolism studies are not
easily related/ correlated to the organisms of interest,
i.e. macroinvertebrates and fish, and, therefore, would
be difficult to predict project effects on those
communities outside of a net change in amount of GPP
or ER. Measuring the fish prey base (as proposed
through sampling drift, benthos, and fish diet) will
effectively relate changes in the ecosystem to fish. See
RSP Sections 9.8.4.2, 9.8.4.3, 9.8.4.5, and 9.8.4.7.
Characterization and Mapping of Aquatic Habitats (Section 9.9)
TWG Meeting 8/15/2012 Eric Rothwell NMFS Eric asked how the sampling structure detail would be
determined and where all the data would be collected
for habitat typing.
The RSP will include the requested detail. See RSP
Section 9.9.2, 9.9.5, 9.9.5.3 and 9.9.5.4.
TWG Meeting 8/15/2012 Jeff Davis Alaska
Ratepayers
Jeff Davis asked why Tongass National Forest
method was selected. Jeff asked what level of
classification would be used for the video work. Jeff
asked if Tier III would be applied in the tributaries.
Jeff stated that more detail on methods was needed.
The methods for habitat characterization were
discussed and approved in an agency meeting in May
2011. The USFS method is a standardized approach
that is widely used to characterize habitats in many
rivers, including larger waters. In addition, to using that
protocol for habitat characterization we will be revising
the Habitat Characterization study to include the
delineation and characterization of “edge habitat” in
mainstem reaches. See RSP Section 9.9.2, 9.9.5.1,
9.9.5.2, and 9.9.5.3.
TWG Meeting 8/15/2012 Joe Klein ADNR-
ADF&G
Stated that Tier III was satisfactory but more detail on
methods was needed.
AEA has added additional detail in the RSP on remote
and field surveys See RSP Section 9.9.2, 9.9.5,
9.9.5.3 and 9.9.5.4.
TWG Meeting 8/15/2012 Betsy FWS Stated she has concerns about Tier III and said more The RSP will include hierarchical nesting and
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 75 December 2012
Comment
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McCracken detail is needed in the plan. She asked if some form of
hierarchical habitat mapping would be done.
expansion of habitat type categories. (See RSP
Section 9.9.2, 9.9.5, 9.9.5.3 and 9.9.5.4)
email 9/07/2012 Betsy
McCracken
USFWS The hierarchally nested aquatic habitats framework is
needed to structure fish distribution surveys, the
instream flow study and other physical process
studies. Without it, the fish surveys will be too
narrowly constrained and the instream flow studies
will not represent all habitats that may be affected by
the proposed project. The Service recommends the
following habitat hierarchy for the Susitna River be
used for habitat mapping purposes and integration of
studies: see email for “Large River Floodplain Habitat
Hierarchy” recommendation
AEA has considered the USFWS request and has
developed a hierarchically nested aquatic habitat
classification system that Is presented in the Habitat
Characterization study plan. See RSP Section 9.9.1,
9.9.2, 9.9.5, 9.9.5.3 and 9.9.5.4.
Fish distribution sampling and instream flow transects
will be structured based on the hierarchical habitat
framework. This is further described in RSP Sections
9.6.4.3.1 and 8.5.4.6.1.
TWG meeting 9/14/2012 Jeff Davis
Betsy
McCracken
ARRI
NMFS
Asked if the non-physical habitat characteristics at the
micro level (such as temperature, DO and food
source) being considered in site selection.
The habitat characterization study does not incorporate
data collection of temperature, dissolved oxygen and
food source.
The data collection at the Focus Areas covers multiple
resources and will include the collection of mesohabitat
data, fish presence and relative abundance, water
quality, etc. These data will be integrated to describe
these habitats in more detail.
TWG meeting 9/14/2012 Jeff Davis ARRI Jeff is concerned that while sampling in turbid waters
it may not be able to differentiate whether individuals
are not present or simply not collected due to method
limitations.
AEA approach includes non-visual capture methods,
such as minnow trapping and seining, that have proven
to be effective when fish sampling in turbid
environments.
TWG meeting 9/14/2012 Jeff Davis ARRI Requests an outline for habitat classification and
integration of studies.
The Habitat Classification system is outlined in the
RSP. In addition the interdependencies section
addresses how this study support and integrates with
other studies. See RSP section 9.9.7.
TWG meeting 10/04/2012 Eric Rothwell NMFS Eric is unclear how the changes of habitat types with
different flows at a particular location will be
addressed when mapping habitat.
It is standard practice to map aquatic habitats at low to
moderate stream flows, in part to help determine the
most limiting condition for aquatic species. AEA
approach to mapping is consistent with those
standards to a large extent. Thus, AEA in not
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 76 December 2012
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proposing to map habitat changes with flows. Flow-
habitat relationships will be developed under the ISF
Program.
The Future Watana Reservoir Fish Community and Risk of Entrainment Study (Section 9.10)
TWG Meeting 8/15/2012 Jeff Davis ARRI Has shelf ice and its potential impact on fish in the
littoral zone been considered?
AEA reviewed this issue at the Willowstone Reservoir.
Shelf ice is not anticipated to be an issue in the
Susitna-Watana reservoir due to the changes in
surface water elevation
TWG Meeting 8/15/2012 Jeff Davis ARRI Smolt movement through still water habitats This issue will be addressed as part of the Study of
Fish Passage Feasibility at Watana Dam. See RSP
Section 9.11.
TWG Meeting 8/15/2012 Jeff Davis ARRI Sediment deposition and settling rate downstream of
dam
This issue will be addressed as part of the Fluvial
Geomorphology Modeling below Watana Dam Study.
See RSP Section 6.6.
Study of Fish Passage Feasibility at Watana Dam (Section 9.11)
Email 9/07/2012 Betsy
McCracken
USFWS Fish Passage/fishway prescription- The Service is
concerned with the lack of transparent discussion
about the potential for fish passage alternatives at the
proposed Susitna-Watana dam. If fish passage is
required, how will that be accomplished? If it is not
feasible, what is your alternative proposal? Where is
your project assessment of the fish passage
feasibility? What are the design criteria being
considered/evaluated?
AEA is conducting a Study of Fish Passage Feasibility
at Watana Dam. The RSP will contain a revised study
plan that describes the process to be followed. See
RSP Section 9.11.4.3.
Study of Fish Passage Barriers in Middle and Upper Susitna River and Susitna Tributaries (Section 9.12)
TWG Meeting 8/15/2012 Jan
Konigsberg
Natural
Heritage
Institute
Barrier studies in Lower River AEA is not proposing a barrier study in Lower River at
this time because it is anticipated that the potential
Project-induced effects to hydrology and
geomorphology will be sufficiently attenuated to
preclude the creation of barriers at tributary mouths.
TWG Meeting 8/15/2012 Jeff Davis ARRI Target species and life stages As stated in the RSP (see Sections 9.12.4.1 and
9.6.4.3), target species and life stages will be identified
after review of the existing data on fish distribution in
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 77 December 2012
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the Middle River and in consultation with Licensing
Participants during the TWG process. No modification
to study plan.
TWG Meeting 8/15/2012 Joe Klein ADNR-
ADF&G
Species and life stage timing As stated in the RSP (See Section 9.12.4.10), passage
analyses will include life stage timing. No modification
to study plan.
Email 8/23/2012 Joe Klein ADNR-
ADF&G
What criteria will be used to identify "a representative
number" of different habitat types?
Criteria will be determined as part of the IFS study site
selection process. Study Plan revised to address this
comment. See RSP Section 8.5.
Aquatic Resources Study within the Access Alignment, Transmission Alignment, and Construction Area (Section 9.13)
Letter 8/31/2012 Joe Klein ADNR-
ADF&G
Fish surveys should be conducted at proposed
crossing locations by electrofishing a distance equal
to 40 wetted stream widths, with a minimum survey
length of 50 meters. If initial surveys do not detect fish
presence at specific crossing locations, at least one
additional fish survey should be conducted during a
different season.
Section 9.13.4.2.2 of the Study Plan identifies
electrofishing as the primary sampling method and
indicates that sampling will be conducted at a distance
of up to 40 wetted channel widths and that a
subsequent survey will occur during a different season
for locations where fish are not observed during initial
sampling. Section 9.13 of the Study Plan was revised
to identify a minimum survey length of 50 meters.
Letter 8/31/2012 Joe Klein ADNR-
ADF&G
If the Denali access route is chosen, replacing or
improving existing stream crossings along the Denali
Highway would be a necessary component of
upgrading the highway to accommodate Project
traffic. The ADF&G will require a comprehensive
survey of stream crossings so that existing stream
crossings inadequate for fish passage can be repaired
or replaced with culverts or bridges designed for fish
passage (ADF&G 2012).
Section 9.13.2 of the Study Plan has been revised to
indicate that upgrades to the existing Denali Highway
would be necessary to accommodate Project traffic,
and that reviewing these crossing would be completed
outside of the this current assessment, when required.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 78 December 2012
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Genetic Baseline Study for Selected Fish Species (Section 9.14)
Email 9/07/2012 Betsy
McCracken
USFWS Fish genetics- During the August 15-17 meetings,
AEA stated that genetic samples from the Chinook
above the proposed dam site would not be collected.
The stated rationale was due to the desire to minimize
the handling of the fish after subsequent tagging of
fish. Genetic samples of Chinook at locations above
the proposed Susitna-Watana dam site are crucial to
informing the Service’s management goals specific to
recommending licensing conditions under the Federal
Power Act, and to conservation recommendations
under the Fish and Wildlife Coordination Act, and the
Anadromous Fish Act. As such, we consider our
request for collection of genetic samples from Chinook
salmon, and other fish species to be necessary for our
resource evaluation of the Susitna-Watana
hydropower project.
Because of this information need, if AEA does not
plan to collect the information, AEA should document
how this study request is being addressed.
AEA supported ADF&G in 2012 by using its radio
telemetry surveys to locate Chinook salmon for tissue
sampling and samples were collected (Kosina Creek).
This effort will continue in 2013 and 2014. Juvenile
salmon collected by AEA contractors in areas above
Devils Canyon were also sampled for tissue and these
were provided to ADF&G.
In addition, AEA will be taking tissue samples from its
radio-tagged fish in 2013-14, which will directly
contribute to the genetic characterization of fish in the
areas above Devils Canyon and the proposed dam
site. As part of spawning ground surveys of the middle
and upper river, AEA contractors will collect tissue from
spawning adult Chinook salmon in 2013-14, as was
done in 2012. Samples from middle river tributaries
will contribute to addressing the question of genetic
relatedness of those fish and fish that migrate above
Devils Canyon.
Email 9/07/2012 Betsy
McCracken
USFWS Fish genetic samples should be current and include
samples of the Chinook migrating above the proposed
dam location. Because gene frequencies change over
time, all genetic samples should be within the most
recent ten years to allow for valid comparison. Genetic
analysis should analyze the existing extent of genetic
differentiation within and between fish using distinctly
different habitats. We request genetic analysis of
Chinook above the proposed dam site relative to
those at other upper, middle and lower river and
tributary sample locations.
Genetic sampling is included in the RSP for Chinook
above and below the proposed dam site. See RSP
Section 9.14.3.
Email 9/07/2012 Betsy
McCracken
USFWS Request that tissue samples be obtained from radio-
tagged Chinook salmon
AEA will revise the RSP to include tissue sampling of
some radio-tagged salmon in 2013/14.
Email 9/07/2012 Betsy
McCracken
USFWS When comparing uniqueness among stocks, use
samples less than 10 yrs old.
AEA concurs.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 79 December 2012
Comment
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Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
Email 9/07/2012 Betsy
McCracken
USFWS Will tissue samples from species other than Chinook
salmon be analyzed as part of the study? Explain.
No, there is not a plan to analyze these other tissue
samples. These samples will be used as a repository
for other researchers and for subsequent research
needs identified for the Project based on the outcome
of other proposed research. Analyzing all these
samples without explicit questions/needs/impacts
identified is beyond AEA’s scope and mandate.
Analysis of Fish Harvest in and Downstream of the Susitna-Watana Hydroelectric Project Area (Section 9.15)
TWG meeting 8/15/2012 Joe Klein ADNR-
ADF&G
Commercial fisheries data Analysis will incorporate caveats of data including
fishery closures. See RSP Section 9.5.1.1.
TWG meeting 8/15/2012 Jeff Davis ARRI Additional fish harvest surveys. No new fish harvest surveys will be completed. Such
surveys are not necessary to analyze proposed Project
effects.
Eulachon Run, Timing, Distribution, and Spawning in the Susitna River (Section 9.16)
TWG meeting 6/12/2012 Betsy
McCracken
USFWS A comment was received to quantify marine-derived
nutrients input into the system by estimating biomass
of anadromous lamprey, eulachon, and Bering cisco
The Eulachon Run, Timing, Distribution, and Spawning
in the Susitna River study will estimate biomass of
eulachon in the lower river during 2014 and if possible
2013 (Section 9.16.4.3 Objective 3: Evaluate the
feasibility of estimating density of eulachon at
spawning sites). In addition, marine-derived nutrients
will be addressed by the River Productivity Study. See
RSP Section 9.8.
Cook Inlet Beluga Whale Study (Section 9.17)
Agency
consultation
meeting
9/19/2012 Mandy Migura NMFS The study area should only include the Susitna River
delta and not all of Type 1 critical habitat
Study area was limited to Susitna River Delta. See
RSP Section 9.17.3.
Agency
consultation
meeting
9/19/2012 Mandy Migura NMFS Aerial surveys should be conducted more regularly
and should include times when not only prey
resources are available (May and June) but also
during times when calves are present (July and
August)
The aerial survey schedule was revised to include
more surveys which will document times when prey are
abundant and when calves may be present. In
addition, surveys will be scheduled to include different
tidal cycles. See RSP Section 9.17.4.1.
Agency
consultation
9/19/2012 Mandy Migura NMFS Clarification needed for Impact Analysis Impact Analysis will be completed following the 2013
and 2014 field seasons. Modeling efforts were
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 80 December 2012
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meeting increased to facilitate future impact analysis. See RSP
Section 9.17.4.3.
Agency
consultation
meeting
9/19/2012 Mandy Migura NMFS Clarification needed regarding how group size, group
composition and behavior will be documented.
Revised Study Plan included clarification. Aerial
surveys will be used for group counts and group
behavior while the video camera portion of the study
will assist with group composition (i.e. calves) and
individual behavior. AEA also clarified that these
surveys will be conducted to gather data on distribution
and relative group sizes – there will be no attempt at
producing an abundance estimate from this data. See
RSP Section 9.17.4.
Agency
consultation
meeting
9/19/2012 Bob Small ADNR-
ADF&G
Passive acoustic monitoring should be considered as
a method for monitoring beluga presence, particularly
for winter months when aerial and video surveys are
not occurring.
AEA discussed using acoustics as a method for this
study. However, given that acoustic recorders would
need to be placed further away from the mudflats and
in deeper water in winter due to ice scour, this data
would not be relevant to the Project-related impact
analysis. Therefore, modeling efforts and impact
analyses will assume that belugas utilize the Susitna
River delta year-round. See RSP Section 9.17.4.3.
SECTION 10 WILDLIFE RESOURCES
General
No comments.
Moose Distribution, Abundance, Movements, Productivity, and Survival (Section 10.5)
TWG meeting 8/09/2012 Sarah Bullock BLM The moose study plan does not need to validate the
carrying-capacity model developed for the Susitna
Hydro Project in the 1980s because the proposed
browse removal study would use a different method
and model.
No corresponding change to the Moose Distribution,
Abundance, Movements, Productivity, and Survival
study plan is needed because the study plan did not
propose to validate the 1980s carrying-capacity model.
Instead, a newer technique was proposed to evaluate
the proportional removal of browse biomass by moose.
Phone
conversation
and email
9/24/2012 Mark Burch ADNR-
ADF&G
The moose study plan needs to be revised to reflect
the fact that the GeoSpatial Population Estimator
(GSPE) quadrat surveys will be combined into a
single-year effort (currently planned for 2012), in
The Moose Distribution, Abundance, Movements,
Productivity, and Survival study plan (Section
10.5.4.2) has been revised to clarify that the GSPE
survey will be conducted in a single year instead of
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 81 December 2012
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which case it would not need to be included in the
2013–2014 study plan. If the survey effort cannot be
conducted in 2012 because of unsuitable survey
conditions, then the GSPE survey would be retained
in the study plan for 2013.
over two years. The GSPE survey was planned for
November 2012 but suitable conditions did not occur
because of insufficient snow cover. As such, the
survey has been retained in the study plan and will be
attempted again in November 2013. If suitable
conditions do not occur at that time, then it will be
conducted in March 2014.
Caribou Distribution, Abundance, Movements, Productivity, and Survival (Section 10.6)
TWG meeting 8/09/2012 Sarah Bullock BLM The caribou study plan needs to assess whether the
Nelchina caribou herd or the Delta caribou herd
crosses the proposed reservoir inundation zone.
The Caribou Distribution, Abundance, Movements,
Productivity, and Survival study plan (Section 10.6.2
and 10.6.4) has been revised to clarify that, although
the Nelchina herd is known to cross the proposed
reservoir inundation zone, the Delta herd may do so as
well, even though it has a more northerly distribution.
The radio telemetry to be conducted for the study will
elucidate the movement patterns of both herds in the
study area.
TWG meeting 8/09/2012 Kim King ADNR-
ADF&G
Due to the number of caribou collars being tracked
and the large area to be covered, the frequency of
radio-tracking flights has had to be reduced from the
weekly flights proposed to once every two weeks.
The Caribou Distribution, Abundance, Movements,
Productivity, and Survival study plan (Section 10.6.4)
has been revised to make this change.
Phone
conversation
and email
9/24/2012 Mark Burch ADNR-
ADF&G
One of the caribou study plan objectives needs to be
revised to reflect the likelihood that sample sizes will
not be large enough for reliable estimation of calf
survival.
The third Caribou Distribution, Abundance,
Movements, Productivity, and Survival study objective
(Section 10.6.1, regarding survival estimation), has
been revised accordingly by deleting ‘calf.’
Dall’s Sheep Distribution and Abundance (Section 10.7)
Agency
consultation
meeting
9/13/2012 Mark Burch,
Kimberly King,
Earl Becker
ADNR-
ADF&G
A watershed approach was recommended to define
the Dall’s sheep survey area instead of applying a
buffer around the Project area.
ADF&G was consulted subsequently in revising the
Dall’s Sheep Distribution and Abundance study plan
and requested that the study area (Section 10.7.3) be
revised as suitable sheep habitat in Game
Management Unit 13E (a watershed-based
management subunit), east of the Parks Highway. The
study plan has been revised to describe the study area
as the portion of GMU 13E located east of the Parks
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 82 December 2012
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Highway and south of the Denali Highway.
Phone
conversation
9/24/2012 Mark Burch ADNR-
ADF&G
ADF&G is potentially interested in conducting the
proposed aerial survey of Dall’s sheep in the study
area. Other tasks being considered by ADF&G are the
possibility of genetic sampling to evaluate the degree
of isolation of sheep inhabiting the Watana Creek Hills
(north of the proposed reservoir inundation zone), as
well as the extent of the aerial survey area needed on
the south side of the Susitna River.
No changes in the study plan were made at the time in
response to this comment. Instead, further consultation
is ongoing with ADF&G regarding the study plan
approach (see next entry below, for 10/05/2012).
Phone
conversation
10/05/2012 Mark Burch ADNR-
ADF&G
ADF&G is interested in conducting aerial surveys of
Dall’s sheep in Game management Unit 13E (east of
the Parks Highway and north of the Denali Highway)
and possibly in deploying radio-collars to evaluate the
extent of movements and potential geographic
isolation by sheep using mineral licks north of the
reservoir inundation zone.
After further consultation with ADF&G, the RSP has
been revised to clarify that radio-collaring and genetic
analysis to investigate potential isolation of sheep will
not be included in the study plan. ADF&G will conduct
a single aerial survey each summer (Section 10.7.4).
E-mail 10/12/2012 Mark Burch ADNR-
ADF&G
The Dall’s Sheep study calls for delineating seasonal
home ranges, but summer range should be adequate.
The Jay Creek mineral lick is above the area of
inundation, so there is no reason to believe the
current data are not adequate.
The RSP (Sections 10.7.1 and 10.7.4) has been
revised to clarify that the aerial surveys will be used to
delineate summer range only. Examination of the Jay
Creek and Watana creek mineral licks has been
retained in the study plan, however.
E-mail 10/31/2012 Mark Burch ADNR-
ADF&G
The study boundary will be drawn at the 13E subunit
boundary and not extend into the mountains within the
13A subunit.
The RSP (Section 10.7.3 and Figure 10.7-1) has been
updated to depict the revised study area as being the
GMU Subunit 13E boundary east of the Parks Highway
and south of the Denali Highway.
Distribution, Abundance, and Habitat Use by Large Carnivores (Section 10.8)
Agency
consultation
meeting
9/13/2012 Various ADNR-
ADF&G
ADF&G agrees that fish spawning areas downstream
that could be impacted by altered river flow and are
important to bears need to be identified. It was
recommended that DNA and stable-isotope data be
collected from hair samples to enumerate the
minimum number of bears and characterize their diet
in drainages used for spawning in the middle reach of
the Susitna River. Hair traps that capture one
The Distribution, Abundance, and Habitat Use by
Large Carnivores study plan (Section 10.8.4.1)
proposes to investigate bear numbers and diets along
spawning streams downstream from the dam by
obtaining hair samples for DNA analysis and stable-
isotope analysis. ADF&G suggested that Lavern Beier
(ADF&G DWC, Juneau) be consulted about the
feasibility of using single-sample hair traps that obtain
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 83 December 2012
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Affiliation Comment or Study Request AEA’s Response
individual’s hair and then close should be considered
instead of wire snags that may sample multiple
individuals.
samples from single animals, rather than wire snags
that sample hairs from multiple animals. That type of
trap has been proposed for use in the RSP (Section
10.8.4.1.2).
Phone
conversation
9/24/2012 Mark Burch ADNR-
ADF&G
ADF&G is pursuing the feasibility of conducting spatial
modeling of bear density using existing survey data
(discussed at the 9/13/2012 meeting) with David Miller
of the University of Rhode Island. ADF&G also is
considering potential involvement in the DNA and
stable-isotope sampling proposed for bears using
anadromous fish spawning streams downstream from
the dam in the middle reach of the Susitna River
drainage.
The Distribution, Abundance, and Habitat Use by
Large Carnivores study plan (Sections 10.8.3 and
10.8.4.1.1) has been revised to include the proposed
spatial modeling of bear density in the study area,
which would use the results of several line-transect
surveys conducted by ADF&G since 2001. The study
plan (Section 10.8.4.1.2) has been revised to state that
ADF&G biologists will be consulted regarding the
sampling design and analysis of hair samples from
bears in the downstream study area.
Wolverine Distribution, Abundance, and Habitat Occupancy (Section 10.9)
TWG meeting 8/09/2012 Mark Burch ADNR-
ADF&G
The wolverine study plan describes sampling blocks
25 square miles in size, but they should be 25 square
kilometers instead. The proposed study area should
be consolidated (“squared up”) to reduce potential
problems caused by wolverines moving into and out of
the sampling blocks during the survey. A single
survey will not be sufficient to obtain habitat-use
information, so that objective should be dropped.
The error in sample-block size on the study area map
(Figure 10.9-1) has been corrected. The study area
(Section 10.9.3) was revised through further
consultation at the follow-up meeting with ADF&G on
9/13/2012 and the study area map (Figure 10.9-1) has
been revised accordingly. The objective regarding
habitat use was dropped from an interim version of the
study plan (Section 10.9.1), but the objective was
reinstated after occupancy modeling was added to the
plan methods (Section 10.9.4) at the request of
ADF&G at the TWG meeting on October 16, 2012.
Agency
consultation
meeting
9/13/2012 Earl Becker,
Howard
Golden, Todd
Rinaldi
ADNR-
ADF&G
The sampling blocks for the wolverine survey should
be 25 square kilometers in size, not 25 square miles.
The study area should be “squared up” to avoid
problems caused by animals leaving and then
reentering the study area. Sample smaller blocks to
get finer scale resolution. Stratify and select survey
quadrates according to the likelihood of seeing
wolverines.
The Wolverine Distribution, Abundance, and Habitat
Occupancy study plan has been revised to correct the
study area map error (Figure 10.9-1) regarding the size
of sampling blocks and to describe the stratification of
the study area (Section 10.9.3 and 10.9.4). The study
area (Figure 10.9-1) has been reconfigured to
consolidate the sampling blocks, thereby reducing
potential errors caused by animals moving into and out
of the study area.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 84 December 2012
Comment
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Date
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Name
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Affiliation Comment or Study Request AEA’s Response
Agency
consultation
meeting
9/13/2012 Howard
Golden, Earl
Becker, Todd
Rinaldi
ADNR-
ADF&G
Aerial surveys of wolverine tracks should be
conducted 12–36 hours after a snowfall that covers
previous tracks. Surveys should be conducted in
February and March because of increasing day length
and generally better weather than earlier in winter.
Reconnaissance flights should be conducted to
determine when and where snow has fallen in the
study area.
Additional details of the proposed survey method have
been added to Section 10.9.4 of the Wolverine
Distribution, Abundance, and Habitat Occupancy study
plan, describing the optimal timing of the survey as
being in February or March 2013, 12–36 hours after a
fresh snowfall, and preceded by a reconnaissance
survey, if necessary, to assess the adequacy of snow
cover throughout the study area.
Agency
consultation
meeting
9/13/2012 Todd Rinaldi,
Howard
Golden
ADNR-
ADF&G
Assessing habitat associations should be removed
from the wolverine study objectives because a single
Sample-Unit Probability Estimator (SUPE) survey will
not provide suitable habitat-use data. The most
effective way to obtain habitat associations for
wolverines is by using GPS telemetry.
This objective was deleted from Section 10.9.1.1 of an
interim version of the Wolverine Distribution,
Abundance, and Habitat Occupancy study plan, but
has been reinstated in Section 10.9.1 after occupancy
modeling was added to the plan methods (Section
10.9.4) at the request of ADF&G at the TWG meeting
on October 16, 2012.
Phone
conversation
9/24/2012 Mark Burch ADNR-
ADF&G
ADF&G is potentially interested in participating in the
proposed wolverine survey effort, using the SUPE
method. AEA contractors could potentially provide
additional observers if ADF&G needs help.
The study plan proposed to use the SUPE method, so
no changes were made to the study plan at the time;
see entries under 10/05/2012 below.
Phone
conversation
10/05/2012 Mark Burch ADNR-
ADF&G
ADF&G is interested in conducting the SUPE survey
of wolverines.
After consultation with ADF&G biologists, the
Wolverine Distribution, Abundance, and Habitat
Occupancy study plan was revised (Section 10.9.4) to
incorporate their input on the SUPE survey and
occupancy modeling.
Terrestrial Furbearer Abundance and Habitat Use (Section 10.10)
Agency
consultation
meeting
9/13/2012 Earl Becker ADNR-
ADF&G
The use of standard mark–recapture techniques to
develop population estimates of terrestrial furbearers
is problematic due to concerns about closure
assumptions and differential probability of capture.
Instead, cluster-grid sampling and a spatially explicit
capture–recapture (SECR) model should be used to
estimate population density because it accounts for
spatial variability.
The Terrestrial Furbearer Abundance and Habitat Use
study plan (Sections 10.10.1.1 and 10.10.4) has been
revised to incorporate the recommended changes in
sampling design and analyses. Specifically, more
details have been added describing the proposed
sampling design and the accompanying statistical
analyses (including population closure and capture
heterogeneity) to incorporate the spatially explicit
capture–recapture approach recommended by
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 85 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
ADF&G.
Aquatic Furbearer Abundance and Habitat Use (Section 10.11)
TWG meeting 8/09/2012 Mark Burch ADNR-
ADF&G
The proposed survey methods for aquatic furbearers
should be examined in more detail, particularly for
mink, and the use of another possible survey method
(floating trackbeds) should be considered.
Survey methods for mink were discussed in detail at
the follow-up meeting on selected mammals (including
aquatic furbearers) on 9/13/2012; see corresponding
entries below from that date.
TWG meeting 8/09/2012 Mark Burch ADNR-
ADF&G
River otters potentially could be studied by surveying
latrine sites and sampling DNA in scats to get an
indication of the number of otters using the study
area. Hair snares employing roughened wire cables
and DNA analysis potentially could be used also to
estimate the baseline population without collecting
animals.
Survey methods for river otters were discussed in
detail at the follow-up meeting on selected mammals
(including aquatic furbearers) on 9/13/2012 (see
corresponding entries below from that date).
TWG meeting 8/09/2012 Mark Burch ADNR-
ADF&G
ADF&G supports the USFWS study request interest in
assessing the risk of mercury bioaccumulation to
aquatic furbearers as a result of filling the proposed
reservoir.
Comment noted. In addition to enumerating minimum
numbers of animals using the study area, the Aquatic
Furbearer Abundance and Habitat Use study plan
(Section 10.11.4.3) has been revised to include
sampling of hair for laboratory analysis of mercury, in
addition to the literature review of the food habits and
diets of river otters and mink, to inform the mercury risk
assessment study.
TWG meeting 8/09/2012 Mark Burch ADNR-
ADF&G
Spring flooding creates suitable habitat for aquatic
furbearers. If furbearers lose habitat because of
reduced spring flows during Project operation,
furbearers could be affected. The impact of reducing
spring flows on aquatic furbearer populations needs to
be studied.
Comment is acknowledged and understood. The
results of the geomorphology, instream flow, and
riparian habitat studies will provide the necessary
information to evaluate potential effects on aquatic
furbearer habitats downstream. The study plan
(Section 10.11.7) has been revised to state that, in the
impact assessment for the FERC License Application
in 2015, the potential effects of flow alterations
downstream will be assessed for aquatic furbearers
when results become available from those other
studies.
Agency
consultation
9/13/2012 Howard
Golden
ADNR-
ADF&G
Riverbank surveys to locate beaver lodges and
caches are difficult because of the tree canopy.
The Aquatic Furbearer Abundance and Habitat Use
study plan, which proposes to use aerial surveys of
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 86 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
meeting Helicopter surveys in the fall (after leaf-fall and before
freeze-up) are the best way to detect fresh beaver
caches. All fresh caches should be noted along with
all lodges.
beaver food caches before freeze-up in fall, has been
clarified further (Section 10.11.4.1) to state that the
optimal timing of these surveys is after leaf fall.
Agency
consultation
meeting
9/13/2012 Howard
Golden
ADNR-
ADF&G
With regard to aquatic carnivores, focus on river otters
and not mink because mink are difficult to study.
Recognizing that mink will be difficult to enumerate
and appear to be uncommon or rare in the study area,
intensive survey methods using floating trackbeds do
not appear to be warranted. Consult Dr. Merav Ben-
David at the University of Wyoming for further ideas
regarding aquatic furbearer survey methods.
The Aquatic Furbearer Abundance and Habitat Use
study plan has been revised (Section 10.11.4) to
deemphasize mink as a focal species, although some
mink may be captured in the Terrestrial Furbearer
Abundance and Habitat Use study and an effort will be
made to record mink tracks during winter track surveys
of river otters by helicopter. Dr. Ben-David was
consulted for her ideas on survey methods for aquatic
carnivores (see Appendix 4).
Agency
consultation
meeting
9/13/2012 Howard
Golden
ADNR-
ADF&G
Obtain relative abundance of river otters by surveying
tracks along streams from the air in winter, flying the
survey area after fresh snowfall and using GPS to
mark tracks (noting single versus multiple tracks).
The survey should be flown two or three times during
each winter (probably requiring 2–3 days for each
survey).
The Aquatic Furbearer Abundance and Habitat Use
study plan (Section 10.11.4.2) has been revised
accordingly to incorporate winter track surveys of river
otters along streams in the study area within 2–3 days
after fresh snowfalls, recording locations using a GPS
receiver and the number of tracks present, if possible.
(Mink tracks also will be noted to the extent possible.)
Phone
conversation
9/24/2012 Mark Burch ADNR-
ADF&G
ADF&G is willing to assist in obtaining hair samples
for preconstruction characterization of mercury levels
in aquatic furbearers, although the small number of
trappers, and the small number of piscivorous
furbearers likely harvested, in the reservoir inundation
zone and stream drainages immediately downstream
from the proposed dam site likely will be problematic
for obtaining samples. Hair snags might be a better
way to obtain samples.
The Aquatic Furbearer Abundance and Habitat Use
study plan (Section 10.11.4.3) has been revised
accordingly to include this alternative method of
obtaining hair samples from river otter and mink.
Small Mammal Species Composition and Habitat Use (Section 10.12)
Phone
conversation
11/29/2012 Sarah Bullock BLM BLM approves of AEA’s proposal to conduct the small
mammal study as a desktop analysis of existing
information, rather than using additional field
sampling.
AEA appreciates BLM’s input on the Small Mammal
Species Composition and Habitat Use study plan and
has revised the RSP (Section 10.12) to reflect this
change, which was proposed at the TWG meeting on
October 16, 2012.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 87 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
Bat Distribution and Habitat Use (Section 10.13)
Agency
consultation
meeting
9/13/2012 David Tessler ADNR-
ADF&G
Anabat ultrasonic detectors, as proposed in the study
plan, are suitable for acoustic detection work. The bat
survey should focus on the Project infrastructure area
and reservoir inundation zone (not necessary in the
access and transmission corridors) where there are
suitable geologic features (caves, crevices) and
human structures for use as roosts. The bat study
should assess habitat suitability, although acoustic
sampling is not likely to provide enough data to
evaluate bat habitat associations. Hence, an
inventory of existing human structures and geological
features in the study area should be conducted to
identify potential locations of bat roosts and
hibernacula.
The Bat Distribution and Habitat Use study plan
(Section 10.13.4.1) has been modified to emphasize
further that geological and human structures will be a
focus of field surveys for bats, as well as acoustic
sampling in forest and wetland habitats judged to be
suitable for foraging by bats.
Agency
consultation
meeting
9/13/2012 David Tessler ADNR-
ADF&G
Acoustic surveys for bats should be done throughout
the reservoir inundation zone during the first year. In
the second year, the acoustic survey should focus on
areas where detections occurred during the first year’s
surveys. The daily sampling period for ultrasound
detectors should be adjusted according to night length
throughout the sampling season.
Language has been added (Section 10.13.6) to clarify
the intent of the Bat Distribution and Habitat Use study
plan as a 2-year effort, with the effort in 2014
depending on the results from the first year (2013) of
work. The study plan (Section 10.13.4.1) has been
revised to clarify the length of the study season as
extending from May to October and to describe the
seasonal adjustment of acoustic sampling periods to
night length.
Survey of Eagles and Other Raptors (Section 10.14)
Agency
consultation
meeting
9/06/2012 Various USFWS Winter surveys for owls are not necessary, provided
that the wildlife habitat evaluation assumes they are
present in suitable habitats.
The Survey of Eagles and Other Raptors study plan
(Section 10.14.4.1) has been modified accordingly to
remove winter surveys for owls.
Waterbird Migration, Breeding, and Habitat Use (Section 10.15)
TWG meeting 8/09/2012 Catherine
Berg
USFWS The spacing of transects for breeding-pair surveys in
the proposed waterbird study plan is 800 meters, but
USFWS standard methodology uses 400-meter
spacing.
The distance in question refers to transect strip-width
rather than transect spacing. The study plan for
Waterbird Migration, Breeding, and Habitat Use
(Section 10.15.4.2.1) has been revised to eliminate
breeding-pair transect surveys (in favor of a lake-to-
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 88 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
lake survey pattern) in all but the easternmost portion
of the study area (lowlands east of the reservoir
inundation zone), as discussed at the study plan
follow-up meeting on waterbirds on 10/04/2012. In the
transect block established in the easternmost portion of
the study area, as depicted on the revised study area
map (Figure 10.15-1), transect strip-width will be 400
meters.
Agency
consultation
meeting
10/04/2012 Maureen de
Zeeuw, Bob
Platte
USFWS USFWS requested that minimum waterbody size,
spatial extent, and number of waterbodies to be
surveyed should be identified in the study plan.
The study plan (Sections 10.15.3 and 10.15.4) has
been revised accordingly to specify these details.
Agency
consultation
meeting
10/04/2012 Maureen de
Zeeuw, Bob
Platte; Mark
Burch, Mike
Petrula
USFWS,
ADNR-
ADF&G
USFWS and ADF&G requested that the streams to be
surveyed for Harlequin Ducks should be specified in
the study plan, along with the extent of the streams to
be surveyed (i.e., how far outside the proposed 3-mile
study area buffer).
The study plan (Sections 10.15.3 and 10.15.4.3) has
been revised to clarify that all suitable streams in the
study area will be surveyed for Harlequin Ducks and
that these surveys will extend outside the 3-mile buffer
as far as is necessary to cover suitable habitat.
Agency
consultation
meeting
10/04/2012 Maureen de
Zeeuw, Bob
Platte
USFWS USFWS requested that spring migration surveys
should start by the last week of April, to avoid missing
birds in a year of early break-up and melt.
The timing of the spring migration surveys (Section
10.15.4.1.1) has been revised accordingly.
Agency
consultation
meeting
10/04/2012 Maureen de
Zeeuw, Bob
Platte
USFWS USFWS suggested that breeding-pair surveys be
timed to match seasonal conditions and melting lake
ice in each year, based on available weather and
break-up data.
The study plan (Section 10.15.4.2.1) has been revised
to state that the timing of breeding surveys will be
adjusted each year, if necessary, based on results of
ice break-up monitoring and results from spring
migration surveys. Breeding-pair transects will be
conducted only in the transect-survey block in the
lowlands in the easternmost portion of the study area,
whereas lake-to-lake surveys will be conducted in the
remainder of the study area.
Agency
consultation
meeting
10/04/2012 Mike Petrula ADNR-
ADF&G
ADF&G suggested that the distinction between spring
migration and breeding surveys be dropped, so that
migration surveys would transition directly into
breeding surveys (late April to mid-June). The same
survey method (complete waterbody search in lake-to-
lake pattern) should be used for both, and surveys
should be done every 5 days instead of every 7–10
The study plan (Sections 10.15.3, 10.15.4; Figure
10.15-1) has been revised to incorporate these
suggested changes, including lake-to-lake surveys in
most of the study area instead of breeding-pair
transect surveys, which will be restricted to a survey
block in the easternmost portion of the study area.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 89 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
days, as proposed in the PSP.
Agency
consultation
meeting
10/04/2012 Mike Petrula ADNR-
ADF&G
ADF&G suggested that productivity (brood) surveys
be conducted by helicopter, rather than on foot, and
that at least two brood surveys be conducted,
beginning in mid-July, with a possible third survey
based on the results of the second survey.
The study plan (Section 10.15.4.2.3) has been revised
accordingly to replace the single foot survey with
multiple helicopter surveys.
Agency
consultation
meeting
10/04/2012 Maureen de
Zeeuw, Bob
Platte
USFWS USFWS wants to understand the volume and
composition of birds migrating through the Project
area, for assessment of collision risk at power
transmission lines and attraction of landbirds to
lighting on Project infrastructure.
The RSP has been revised by adding Section
10.15.4.1.2 to incorporate radar and visual surveys of
bird migration in the vicinity of the dam site in 2013,
with continuation in 2014 depending on the findings of
the 2013 surveys.
Landbird and Shorebird Migration, Breeding, and Habitat Use Study (Section 10.16)
TWG meeting 8/09/2012 Maureen de
Zeeuw
USFWS Landbird and shorebird densities need to be
determined in the Project area. USFWS does not think
that measures of relative abundance are adequate to
understand the number of breeding birds potentially
affected by the Project.
The study plan (Section 10.16.4.1.1) has been revised
to incorporate density estimation from point-count
surveys, employing distance sampling and removal
sampling, as suggested by USFWS at the study plan
follow-up meeting on 9/06/2012.
TWG meeting 8/09/2012 Maureen de
Zeeuw
USFWS The landbird and shorebird study plan needs to
include a method to study the potential for the
potential attraction of landbirds to facility lighting and
the risk of subsequent collisions.
Radar monitoring of nocturnal migration by landbirds in
the vicinity of the proposed dam, as was discussed at
the study plan follow-up meetings on 9/06/2012
(landbirds/shorebirds) and 10/04/2012 (waterbirds) has
been added to the RSP (Sections 10.15.4.1.2 and
10.16.4.4).
TWG meeting 8/09/2012 Maureen de
Zeeuw
USFWS Most of the population of the Pribilof subspecies of
Rock Sandpiper (Calidris ptilocnemis ptilocnemis)
overwinters in upper Cook Inlet, where they feed
heavily on Macoma balthica, a clam that occurs in
intertidal sediments. The potential effects of Project
operations on these clams need to be assessed to
understand how Rock Sandpipers may be affected by
the Project.
The potential for impacts on Macoma will be assessed
in 2015 for the FERC License Application, based on
the predicted or modeled physical effects of Susitna
River flow alterations on intertidal mudflats in upper
Cook Inlet, using the results of other studies of
geomorphology, hydrology, sedimentation, and
temperature under the Geomorphology and Aquatic
Resources programs.
Agency
consultation
meeting
9/06/2012 Maureen de
Zeeuw
USFWS Habitat characterization of point-count locations
should not be conducted at the same time as auditory
surveys for landbirds and shorebirds.
Habitat variables at point-count locations will not be
characterized at the same time as auditory surveys.
The study plan (Section 10.16.4.1) has been revised to
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 90 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
clarify that habitat characterization of point-count
locations will be derived from the wildlife habitat map
geodatabase by using field GPS coordinates.
Agency
consultation
meeting
9/06/2012 Maureen de
Zeeuw, Steve
Matsuoka
USFWS Landbird and shorebird surveys should focus on the
species of concern listed in Table 2 of the Wildlife
Data-Gap Analysis For The Proposed Susitna–
Watana Hydroelectric Project, dated August 2011.
All species heard or seen will be recorded during field
surveys. The wildlife habitat evaluation study plan
(Section 10.19.4.1) identifies the species listed in Table
2 of the wildlife data-gap analysis report (with a couple
of minor corrections, as discussed with Steve
Matsuoka of USFWS) as focal species for detailed
habitat evaluation.
Agency
consultation
meeting
9/06/2012 Maureen de
Zeeuw
USFWS A survey from a boat should be conducted to search
for swallow breeding colonies along the Susitna River
within the reservoir inundation zone.
The study plan (Section 10.16.4.2) has been revised to
add a survey of colonial-breeding swallows, which are
undersampled by standard point-count surveys.
Agency
consultation
meeting
9/06/2012 Steve
Matsuoka
USFWS Surveying within a 2-mile buffer around the project
area should adequately sample landbirds and
shorebirds by focusing on the habitats most likely to
be affected (rather than expending sampling effort in
more mountainous areas where impacts are less likely
to occur).
The study area description in the Landbird and
Shorebird Migration, Breeding, and Habitat Use Study
plan (Section 10.16.3) has been revised to state that
point counts will target the area within a 2-mile buffer
around the Project area footprint, access/transmission
alignments, and reservoir inundation zone. A new
study area map (Figure 10.16-1) has been created
accordingly.
Agency
consultation
meeting
9/06/2012 Various USFWS Additional point-count surveys outside of the Project
study area (e.g., in Denali National Park or the Copper
River Basin), are not needed for the
landbird/shorebird study if suitable detection functions
from the literature are used for density estimation of
rare species.
No changes to the study plan are needed (see next
entry below for relevant study plan revisions regarding
detection functions).
Agency
consultation
meeting
9/06/2012 Steve
Matsuoka
USFWS Alaska Landbird Monitoring System (ALMS) protocols
should be used for the landbird and shorebird study.
Double-observer methods are not needed for the
landbird and shorebird study, and the ALMS methods
with distance analyses and removal analyses should
be adequate for landbird and shorebird surveys.
Existing detection functions, derived from other
landbird and shorebird point-count studies in Alaska,
ALMS protocols were proposed in the original study
plan, but additional details have been added (Section
10.16.4.1.1) to describe the analytical approach to
density estimation of landbirds and shorebirds by using
distance analyses, removal analyses, and detection
functions.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 91 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
should be used in cases where Project field data are
too limited to derive adequate detection functions
(e.g., rare or uncommon species).
Agency
consultation
meeting
9/06/2012 Maureen de
Zeeuw
USFWS Mist-netting could potentially be used to determine if
the reservoir inundation zone is used as migration
stopover habitat for landbirds or shorebirds. A radar
study could potentially be conducted to quantify the
volume of nocturnal bird migration through the Project
area, focusing on the dam site to address the potential
for attraction of night-migrating landbirds to lights on
the proposed infrastructure around the dam.
Because of the site-specific nature of the information
obtained from mist-netting and the risk of injury to
captured birds, mist-netting is not proposed in the
Landbird and Shorebird Migration, Breeding, and
Habitat Use Study plan. Consultation on this study
plan is continuing between USFWS and AEA.
Agency
consultation
meeting
9/06/2012 Maureen de
Zeeuw, Steve
Matsuoka
USFWS The PSP does not include enough field survey effort
to adequately sample the number of birds of different
species using the study area and to estimate landbird
and shorebird densities. Additional survey effort is
needed to sample all species throughout the early
portion of the breeding season between mid-May and
mid-June.
The field sampling effort for point-counts in the
Landbird and Shorebird Migration, Breeding, and
Habitat Use Study study plan (Section 10.16.4.1.2) has
been extended accordingly to cover the period from
mid-May to mid-June.
E-mail 09/12/2012 Steve
Matsuoka, Jim
Johnson, Rick
Lanctot
USFWS On the priority species list, a few species on the list
appear on the Bird of Conservation Concern (BCC)
2008 list, but are not checked off under the BCC
column. Some examples include Short-eared Owl and
Surfbird.
The list of species of conservation concern (Table
10.19-1 in Section 10.19, Evaluation of Wildlife Habitat
Use) was reviewed again and updated to include
species listed in the 2008 BCC list from USFWS,
including Short-eared Owl, which is listed for regions
other than Alaska during the non-breeding period.
Although Surfbird was not found in the USFWS 2008
BCC list, it is included in the table because it appears
in the Alaska Shorebird Group’s 2008 list.
E-mail 09/12/2012 Steve
Matsuoka, Jim
Johnson, Rick
Lanctot
USFWS Two shorebirds that are on the BCC list that could be
added are Hudsonian Godwit and Short-billed
Dowitcher. These probably occur in low densities, but
should be included on the species priority list.
Hudsonian Godwit and Short-billed Dowitcher were not
included in the original list because they were not
recorded in the study area during 2 years of field
surveys done in the early 1980s by Kessel’s University
of Alaska Museum crews. However, these species
have been added to the species priority list (Section
10.19, Table 10.19-1).
Agency 9/13/2012 David Tessler ADNR-Dave Tessler noted that, based on subsequent Clarifying details have been added to the Landbird and
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 92 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
consultation
meeting
ADF&G discussions he had with Maureen de Zeeuw of
USFWS, his concerns had largely been addressed
during the previous meeting on the
landbirds/shorebirds study (September 6, 2012),
which he was unable to attend. He emphasized that
observers used for point-count surveys should
undergo distance estimation training and testing
before field surveys are conducted. Although he sees
some validity in using double observers, the USFWS
recommendation of employing distance and removal
analyses based on standard Alaska Landbird
Monitoring System (ALMS) field methods would be
adequate. He agreed with the USFWS
recommendation of conducting point counts over a
longer period of time than was stated in the PSP.
Shorebird Migration, Breeding, and Habitat Use Study
plan (Section 10.16.4.1) with regard to observer
training and testing and the length of the field sampling
period.
Population Ecology of Willow Ptarmigan in Game Management Unit 13 (Section 10.17)
No comments.
Wood Frog Occupancy and Habitat Use (Section 10.18)
Agency
consultation
meeting
9/13/2012 David Tessler ADNR-
ADF&G
Examine data on fish presence in waterbodies to
determine where frogs may occur, because frogs tend
to not occur in waterbodies with fish (which prey on
adults and eggs). Frog surveys should concentrate
on isolated waterbodies and wetlands not connected
to stream systems.
This recommendation has been added to the revised
frog study plan (Section 10.18.4.1), using Project-
specific fish survey data, where available.
Agency
consultation
meeting
9/13/2012 David Tessler ADNR-
ADF&G
USGS’s amphibian monitoring protocol recommends
that a second visit be conducted to improve
occupancy estimates. Consider two visits in May
because the peak calling period can be difficult to
identify.
The frog study plan (Section 10.18.4.1) has been
revised to incorporate a second sampling visit to a
subset of waterbodies in the study area to improve
detectability and occupancy estimates.
Agency
consultation
meeting
9/13/2012 David Tessler ADNR-
ADF&G
Field sampling for chytrid fungus can be conducted
readily by collecting swab samples from captured
frogs. Meg Perdue or Mari Reeves at USFWS can
suggest labs that can analyze frog swabs for chytrid
fungus.
Further details regarding field sampling and lab
analysis of chytrid fungus samples have been added to
the frog study plan (Section 10.18.4.2).
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 93 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
Evaluation of Wildlife Habitat Use (Section 10.19)
TWG meeting 8/09/2012 Catherine
Berg
USFWS The Wildlife Habitat Evaluation Study should identify
the species for which habitat will be mapped.
The Evaluation of Wildlife Habitat Use study plan
(Section 10.19.4.1) has been revised to include a
preliminary list of species of concern (Table 10.19-1)
for which habitat use will be evaluated.
Agency
consultation
meeting
9/06/2012 Maureen de
Zeeuw
USFWS The rationale and assumptions used in the habitat
evaluation study should be clearly documented.
The Evaluation of Wildlife Habitat Use study plan
(Section 10.19.4.1) has been revised to provide more
detailed description of the proposed analytical
approach.
Agency
consultation
meeting
9/13/2012 David Tessler ADNR-
ADF&G
The Project should “crosswalk” habitat mapping and
evaluation data with the Alaska Gap Analysis Project
(GAP) mapping. Contact Keith Boggs and Tracy
Gotthardt at the Alaska Natural Heritage Program to
discuss how the data might be compared between the
Project and Alaska GAP.
The Evaluation of Wildlife Habitat Use study plan
(Section 10.19.4.1) has been revised to clarify that the
study report will incorporate the suggested crosswalk
of habitat types between the two projects. The results
of the suggested consultation will be reflected in the
revised study plan.
Wildlife Harvest Analysis (Section 10.20)
No comments.
SECTION 11 BOTANICAL RESOURCES
General
No comments.
Vegetation and Wildlife Habitat Mapping Study in the Upper and Middle Susitna Basin (Section 11.5)
TWG meeting 8/09/2012 Various USFWS,
ADNR-
ADF&G,
FERC
The general consensus was that the large (5-mile
buffer) size of the mapping area was more than
sufficient to account for the indirect wildlife habitat
alteration effects likely to occur from Project
development.
In Section 11.5.3 in the RSP, the study area for the
mapping of vegetation and wildlife habitats has been
reduced to a 4-mile buffer, which remains twice the
size of the buffer (2 miles) used in the Wetland
Mapping Study.
TWG meeting 8/09/2012 Bob Henszey USFWS The USFWS requested a comparative analysis of the
changes in vegetation between the 1980s and
present, if such a comparison would not involve a
large amount of extra work.
The draft RSP does not propose this comparative
analysis. AEA does not believe that such a
comparison can be readily prepared, because a
different version of the Alaska Vegetation Classification
was used in the 1980s. In addition, the purpose of the
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 94 December 2012
Comment
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Comment
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Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
vegetation mapping proposed in the draft RSP is to
obtain current baseline information on vegetation;
possible changes in vegetation coverage since the
1980s would not yield any information related to project
effects.
Agency
consultation
meeting
9/06/2012 Maureen de
Zeeuw
USFWS The USFWS (Maureen de Zeeuw) requested that for
the habitat mapping study, Kessel’s bird habitat
classification system for Alaska (Kessel 1979) be
compared to the Level IV vegetation types of Viereck
et al. (1992). The concern is that the habitat
classification used for the Project should appropriately
represent the habitats used by landbirds and
shorebirds, and not be limited to plant species
composition. The USGS prepared a report comparing
the two classification systems; USFWS indicated they
would provide the report.
It was confirmed that the proposed methodology
(Viereck et al. 1992 Level IV vegetation types, plus
ABR’s landscape feature additions), addresses habitat
parameters beyond plant species composition (e.g.,
vegetation structure, landscape position, disturbance
level, etc). The habitat mapping approach is further
described in Section 11.5.4.2 of the draft RSP. The
USFWS has not located the USGS report that
compares the Viereck and Kessel classifications, but in
the absence of that material, AEA prepared a
“crosswalk” between the two classification systems and
has the following comments. First, some aspects of the
Kessel classification system will be integrated into the
mapping of habitats for the Project (e.g., cliff faces for
nesting birds will be extracted from barren vegetation
types using DEM data). Second, the low, moderate,
and tall shrub classes used in the Kessel system
cannot be consistently delineated from aerial imagery.
Those fine-scale classes work well for on-the-ground
vegetation classifications, but cannot be reliably
identified from aerial imagery. The Project will use a
habitat map derived from aerial imagery to
quantitatively estimate habitat loss and alteration
effects. Lastly, AEA notes that recent Alaskan landbird
data indicate that the clean separations in habitat use
by landbird species in low, moderate, and tall shrub
types, which Kessel refers to in her paper, are not
common. Rather, many species often show a wide
range in use of shrub types with an emphasis,
perhaps, in tall or low shrub habitats depending on the
species. AEA will use that complete range of habitat
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 95 December 2012
Comment
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Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
use (from low to tall shrub types) in the estimates of
Project-induced habitat effects noted above.
Riparian Vegetation Study Downstream of the Proposed Watana Dam (Section 11.6)
TWG meeting 8/09/2012 Various USFWS,
ADNR-
ADF&G
The lateral boundary of the riparian study area needs
to be determined. In the PSP, the 100-year floodplain
limit was proposed. There were agency concerns,
however, about how the flood limit would be
determined.
Comment addressed in Section 11.6.3 in the RSP.
Preliminarily, riverine physiographic boundaries will be
used to define the lateral extent of the study area.
Riverine physiography (areas directly influenced by
semi-regular to irregular overbank flooding [~5–25 year
intervals] including off-channel waterbodies) will be
mapped from recent aerial imagery. The riverine
physiography map will be sent out for review and
agency input (late October/early November 2012)
before the final riparian study area boundary is defined
and described in the RSP.
TWG meeting 8/09/2012 Various ADNR-
ADF&G,
ARRI, BLM,
OPMP, NHI,
USFWS
The length of the Riparian Vegetation Study area
downstream needs to be determined.
Comment addressed in Section 11.6.3 in the RSP. The
downstream extent of the study area will be defined as
the point at which the effects of altered flow regimes
expected in the Susitna River would not be significant
(i.e., where expected flow changes would be
overridden by input from other rivers, are within the
range of natural variability, and/or overridden by the
effects of Cook Inlet tides). The potential Project-
induced changes to flow will be attenuated
downstream of the confluence of the Susitna and
Chulitna rivers near Talkeetna. The length of the study
area below the confluence will be defined following
analysis of data from the 2012 Fish and Aquatics
Instream Flow Study, Ice Processes in the Susitna
River Study and further refinement of the range of
potential Project operations.
Wetland Mapping Study (Section 11.7)
Agency
consultation
meeting
9/18/2012 Various USACE, EPA,
USFWS,
ADEC
The general consensus was that the water quality
wetland function would not need to include
subfunctions like sediment retention and
nutrient/toxicant removal, although an exception was
The water quality function listed in Section 11.7.4.3 in
the RSP notes that these wetland functions will be
evaluated individually.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 96 December 2012
Comment
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Comment
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Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
noted by the USACE wherein they would need, as
part of the evaluation of the wetlands permit
application, to assess these possible functions for
wetlands that would be adjacent to proposed gravel
pads and roads.
Agency
consultation
meeting
9/18/2012 Various USACE, EPA,
USFWS,
ADEC
Fish habitat should be assessed as a subfunction of
the abundance-and-diversity-of-wetland-fauna
function. Data collected by the fish studies should be
incorporated into the wetlands functional assessment
to determine whether wetland polygons are
performing a fish habitat function.
Section 11.7.4.3 in the RSP notes that fish occurrence
information for lacustrine waterbodies (from the Fish
and Aquatics Resources Studies, Section 9 in the
RSP) will be applied in the evaluation of the
abundance-and-diversity-of-wetland-fauna wetland
function. The wetland functional analysis will include a
spatially explicit component in which particular
waterbodies will be noted as providing a fish habitat
function (pending adequate data from the fish studies).
Agency
consultation
meeting
9/18/2012 Various USACE, EPA,
USFWS,
ADEC
Wildlife abundance and diversity should be assessed
as a subfunction of the abundance-and-diversity-of-
wetland-fauna function.
Section 11.7.4.3 in the RSP notes that wildlife
occurrence information will be applied in the evaluation
of the abundance-and-diversity-of-wetland-fauna
wetland function.
Agency
consultation
meeting
9/18/2012 Various USACE, EPA,
USFWS,
ADEC
Wildlife habitat work should be incorporated into the
wetlands functional assessment to determine whether
wetland polygons are performing a wildlife diversity
and abundance function.
Section 11.7.4.3 in the RSP notes that wildlife habitat-
use information (similar to that used in the Evaluation
of Wildlife Habitat Use study, Section 10.19 in the
RSP) will be assessed for the mapped wetland types.
The wetland functional analysis will include a spatially
explicit component, if necessary, in which wetland
types in different sections of the Project area will be
noted as providing a wildlife habitat function for various
wildlife species.
Agency
consultation
meeting
9/18/2012 Various USACE, EPA,
USFWS,
ADEC
The consumptive uses wetland function should be
evaluated for both actual uses (e.g., known hunting,
berry picking areas) and potential uses (e.g., suitable
wetland habitats for consumptive uses if access was
increased).
In Section 11.7.4.3 of the RSP, the consumptive uses
function is described to indicate that actual and
potential uses will be assessed (pending adequate
data from the recreation and subsistence studies). The
wetland functional analysis will include a spatially
explicit component, pending adequate data (as above),
in which particular wetland types in different sections in
the Project area will be noted as providing actual or
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 97 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
potential consumptive uses.
Agency
consultation
meeting
9/18/2012 Various USACE, EPA,
USFWS,
ADEC
The effects of permafrost on wetland functions should
be addressed, especially in light of the known
degradation in permafrost associated with climate
change.
Section 11.7.4.3 in the RSP notes that the existence of
permafrost in wetlands in the Project area will be
addressed in the wetland classification by categorizing
wetlands as associated with permafrost or not. In this
way, the functional capacities of permafrost and non-
permafrost wetlands will be addressed.
Rare Plant Study (Section 11.8)
No comments.
Invasive Plant Study (Section 11.9)
No comments.
SECTION 12 RECREATION AND AESTHETIC RESOURCES
General
Memo 8/07/2012 Unspecified NPS Request AEA develop a schedule ensuring
coordination between interdependent resource studies
associated w/ Susitna-Watana Project. Recreation
and Aesthetic studies are dependent on results of
other biophysical resource studies (hydrology,
instream flow, fluvial geomorphology, ice processes,
fisheries, game studies).
Interdisciplinary coordination discussed in each
resource study culminating in standard
interdependencies charts presented in the schedule
section of each study plan. Interdependencies for
Recreation Resources and Aesthetic Resources
studies discussed in Sections 12.5,6,7. Recreation and
Aesthetic Resources interdependences diagrams
present in Figures 12.5-2 and12.6-2.
Memo 8/07/2012 Unspecified NPS Critical Path Method, or comparable project mgmt.
mechanism, should be key element of Susitna-
Watana Project, especially w/ 58 studies, many
occurring concurrently.
Each study area provides the key elements that area
necessary inputs as well as outputs within the context
of each particular study area. AEA maintains a
schedule of each study including key predecessors
and successors for studies as well as other activities in
the planning and design of the Project.
Memo 8/07/2012 Unspecified NPS Transparent process needed for tracking critical
milestones and progress of PSPs, w/
interdependencies IDed in each study plan.
See responses above.
Memo 8/07/2012 Unspecified NPS Summary of overall Critical Path schedule should be
included as separate plan, and be made available on
Study plan schedules with interdependencies to other
disciplines are presented in the RSP within each study
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 98 December 2012
Comment
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Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
Susitna-Watana Project website for stakeholders to
access.
section as, well as an overall schedule in Section 1.
AEA’s overall schedule is continuously updated as
planning and progress advances and changes based
on weather, contracting, and other key variables. Key
schedule milestones and activities are regularly posted
on the Project Website
Memo 8/07/2012 Unspecified NPS 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’ final opportunity to comment on
ILP studies. NPS is being asked to take AEA’s word
that if results of 2012 studies indicate a need to
modify ILP studies, such modifications will be made
voluntarily.
The results of 2012 work as well as all other previous
analysis and information gathering for the Project have
been used by the study team to develop the study
plans. The study plans are based on the most current
information AEA has to develop study methodologies
that fit within the baseline conditions understood and
articulated within the study plan as needed.
Recreation Resources Study (Section 12.5)
Memo 8/07/2012 Unspecified NPS 10.1. Intro – Recreation study focuses on recreational
uses, demand rather than recreational opportunities,
experiences. Need to be qualitative, not just
quantitative, b/c experiences are likely to change post-
project. NPS is relying on recreation surveys to tease-
out qualitative information (quality of experience,
preferences, etc.). Without seeing survey instruments
and protocol, NPS does not have assurance that
studies will be able to characterize these.
Agree that having the study be more explicit about how
quality of experience and how the opportunity
assessment will be carried out is appropriate, even if
the qualitative methods are more loosely defined. The
study plan has been updated throughout to mention
where possible how the various study components can
get at the quality and recreation supply/opportunity
considerations. Section 12.5.4 describes the draft
survey protocol. Attachment 12-3 is the draft intercept
survey instrument.
Memo 8/07/2012 Unspecified NPS 10.5.1. Gen. Description of Proposed Study – Add
following to “specific goals of the study”: Incorporate
the results of the 2012 studies.
Agreed and the additional goal has been added to
Section 12.5.1.
Memo 8/07/2012 Unspecified NPS 10.5.2. Existing Info & Need for Additional Info –
Claim that existing info was compiled in Recreation
Data Gap Analysis and included in PAD is incorrect.
PAD was filed 12/2011; NPS did not receive 2011
Gap Analysis until 3/2012, after much pleading. To
NPS’ knowledge, 2011 publication date for this
The draft Socioeconomic, Recreation, Air Quality and
Transportation Data Gap Analysis report was
completed by HDR on August 25, 2011. That resource
information in that report was used in developing the
PAD, however it was inadvertently left off the Project
Website until early 2012.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 99 December 2012
Comment
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Affiliation Comment or Study Request AEA’s Response
document is inaccurate since it was not made public
until 2012.
Memo 8/07/2012 Unspecified NPS 10.5.2. Existing Info & Need for Additional Info –
Agencies, stakeholders will not have results from the
“2012 data gathering efforts” until they are reported on
11/5/2012. NPS will not be able to incorporate
comments on results by the 10/15/2012 due date for
PSP comments.
The Study Plan comment period has been extended to
November 14, 2012 however the published report for
2012 studies will not be ready for publication by that
time. 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.
Memo 8/07/2012 Unspecified NPS 10.5.4. Study Methods – With respect to
interdependent analyses, and reliance of recreation
and aesthetics studies on results from other
disciplines, there is no detail in PSP explaining how
timing will work. Schedule table at end of each PSP
w/ study seasons and deliverables does not mention
this. NPS needs details of how sequence will work.
AEA cannot just say it will happen when it does not
appear that results of other studies will be available
before delivery date for this one.
Agree. Section 12.5.4, 12.6.4, and 12.7.4 have been
updated to describe interdependencies and Figures
12.5-2, 12.6-2, 12.7-2 provide a graphical
representation of the interdependencies.
Memo 8/07/2012 Unspecified NPS 10.5.4. Study Methods, Regional Recreation Analysis
– Study plan should note, early-on, distinction w/
subsistence hunting and fishing v. sport activities.
Agreed. Study Plan, section 12.5 makes this
distinction.
Memo 8/07/2012 Unspecified NPS 10.5.4. Study Methods, Regional Recreation Analysis
– PSP states “Existing resource management plans
relevant to the recreational resources of the study
area will be reviewed and compiled.” Isn’t this being
done in 2012?
Management plans were collected and revised during
the 2012 study period. Additional analysis is necessary
throughout 2013 and 2014 as the analyses develop.
Text has been clarified in Section 12.5.4.
Memo 8/07/2012 Unspecified NPS 10.5.4. Study Methods, Regional Recreation Analysis
– 2012 info will be used to develop RSP. Will NPS
see this prior to the 10/15/2012 due date for agency
and public PSP comments? If not, how will agencies
and public ensure that 2012 data are applied
correctly? Timing problem points to larger problem of
trying to finalize study plans for a project before
reconnaissance level work is compete. This also
The Study Plan comment period has been extended to
November 14, 2012; however, the published report for
2012 studies will not be ready for publication by that
time. 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
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 100 December 2012
Comment
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Affiliation Comment or Study Request AEA’s Response
applies to Aesthetics and Instream Recreation PSPs. baseline information which by itself does not
necessarily alter the study methods proposed.
However, in many cases the 2012 work has informed
the logistical and methodological considerations of the
2013-14 study The PAD, Data Gap report, and
analysis of management plans and other existing
published information related to recreation in addition
to firsthand information gathering in 2012, all together
comprise the body of information used to identify the
data needs and develop the study plan methods to get
at those data needs. .
Memo 8/07/2012 Unspecified NPS 10.5.4. Study Methods, Regional Recreation Analysis
– AEA needs to analyze effects of Susitna-Watana
Project operations, not just “features.” Nowhere in
PSP is it explicitly acknowledged that Susitna-Watana
Project may have effects on things like fish
abundance (affecting sport fishing opportunities),
moose, caribou, waterfowl, upland game bird
populations due to migration barriers and alteration of
habitat, due to altered fluvial morphology and riparian
vegetation.
Agreed and the study plan has been updated in
several places to clarify that the analysis is directed at
providing the relevant information to form the basis to
be able to understand how the Project construction
operation may affect the resource.
Memo 8/07/2012 Unspecified NPS 10.5.4. Study Methods, Recreation Carrying Capacity
– Physical carrying capacity is just one of 4 elements
of “carrying capacity” (physical, ecological, social,
spatial). Area’s physical capacity may / may not be
most limiting, especially if Susitna-Watana Project
results in greater access, which could cause use to
exceed area’s social carrying capacity. This is one
reason why it is important to study experiential aspect
of pre- and post-project recreational use. On rivers in
particular, social capacity is almost always more
sensitive than other aspects of capacity, w/ concerns
about group size, encounter rates; competition for
space at put-ins, take-outs, campsites; crowding at
fishing holes, play boating features, etc.
Agreed. The discussion of carrying capacity has been
expanded in Section 12.5.4 to clarify the various
components being addressed. The recreation user
intercept survey and regional resident household mail
survey will gather some helpful information regarding
the social aspect of the carrying capacity.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 101 December 2012
Comment
Format
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Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
Memo 8/07/2012 Unspecified NPS 10.5.4. Study Methods, ID & Analysis of Salient Data
from Existing Survey Research – Existing survey
research appears biased towards “industrial tourism.”
Analysis needs to capture use by independent tourists
(e.g. people driving up AK Hwy. and on to Denali
Hwy.), and local (unguided AK resident) users, many
of whom are able to access area without relying on air
taxis or het boat charters.
Existing survey research, and AVSP VI specifically, is
a statistically rigorous research project that measures
all types of Alaska visitors and is not biased toward
large-scale packaged tourism. As explained in Section
12.5.4, the survey methods are intended and expected
to capture information about all types of users.
Memo 8/07/2012 Unspecified NPS 10.5.4. Study Methods, ID & Analysis of Salient Data
from Existing Survey Research – PSP states that
AVSP Survey, which will be used in the study plan, is
a statewide research program commissioned by the
AK Dept. of Commerce, Community & Economic
Development, that included 6,747 visitors to AK in
Summer 2011 and 1,361 visitors in the Fall/Winter
2011/2012. Survey excludes spring season.
The study team believes this is a robust study that is
appropriate to use in combination with other data
sources. The AVSP VI survey is conducted year round.
The “spring” season is not excluded; rather March and
April are included in the fall/winter season reports,
while May is included in the summer season report
Section 12.5.4 has been expanded to discuss further
detail about data sources and their applicability for the
AEA proposed studies.
Memo 8/07/2012 Unspecified NPS 10.5.4. Study Methods, Telephone Surveys of
Railbelt Residents – Phone survey has very little
value. Given the sample size, very few subjects are
likely to be familiar with the Susitna-Watana Project
area, and SCORP questions are too general to yield
useful info about specific kinds of recreational
opportunities in the area. Instead, USNPS suggest
resources be focused on “executive interviews” – use
snowball sampling method to find actual users of this
area and others like it.
The survey study plan has been modified accordingly
in Section 12.5.4. The study plan has been revised to
include a mail survey in addition to intercept surveys
and executive interviews. The SCORP is an important
source of information for regional recreation
characteristics and it is a formal document prepared
explicitly for the purposes of helping recreation
providers plan to meet future recreation needs. The
SCORP should help the recreation planning effort for
the Project and in the region, particularly with regards
to identifying regional recreation supply and demand
characteristics.
Memo 8/07/2012 Unspecified NPS 10.5.4. Study Methods, Telephone Surveys of
Railbelt Residents – Expecting cooperation from
vendors and outfitters, who are being asked to take
the time, effort to hand over private info on “actual
users” be difficult. This underscores need to review
survey instruments, protocols ASAP.
Agree. Information from private businesses needs to
be handled with great sensitivity and at times with
confidentiality to inform the demand assessment.
Methods discussion has been expanded in 12.5.4
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 102 December 2012
Comment
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Name
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Affiliation Comment or Study Request AEA’s Response
Memo 8/07/2012 Unspecified NPS 10.5.4. Study Methods, Telephone Surveys of
Railbelt Residents – Even though the project is
unique, such survey templates are fairly standard and
should already have been developed and
disseminated to agencies, stakeholders.
Agree. Examples of other surveys used in FERC
relicensing applications provides some insight,
however, the study area as defined is unique to some
other projects in that it is an original licensing, and
present information about current uses is limited.
Survey research will need to be customized to meet
the unique and disperse recreational use of the study
area.
Memo 8/07/2012 Unspecified NPS 10.5.4. Study Methods, Intercept Surveys &
Structured Observation Visitor Counts – Where is the
detail on this and other methods? USNPS needs to
be developing instruments now, or at least deciding
when they will be developed (prior to NPS’ last
chance to comment in mid-Oct. 2012).
Methods have been expanded in 12.5.4. Draft survey
instruments are shown in Attachment 12-3, 12-4, and
12-5. A technical advisory group function has been
added in the Study Plan, to meet quarterly, to provide
input on survey instruments and other study functions.
Memo 8/07/2012 Unspecified NPS 10.5.6. Schedule – Only one December (2013) will be
sampled. No “wiggle room” should weather, other
conditions render the limited sample seasons
inadequate to represent actual project area
conditions.
The studies are designed to understand recreation
trends in addition to a 2013 snapshot. The studies in
2013 and 2014 are also intended to collect data from
recent years, in addition to identifying recreation trends
and uses, and quality of experience in past seasons.
The survey sample plans for the recreational users
intercept survey allow for flexibility if “make up” days
are needed due to inclement weather or other issues
(such as road closures, etc.) This is reflected in Table
12.5-1, and discussed in Section 12.5.4.
Memo 8/07/2012 Unspecified NPS 10.5.6. Schedule – No mention of when results of
other studies – ice, morphology, fish and game
populations, etc. – will be in-hand, and how results will
be incorporated in the Recreation Study report.
Interdisciplinary interdependency is being charted out
by with AEA and its contractors/study leads. The
Interdisciplinary coordination for Recreation and
Aesthetic Resources studies is discussed in Section
12.5,6,7 and graphically illustrated in Figures 12.5-2,
12.6-2, 12.6-3.
Memo 9/20/2012 Cassie
Thomas
NPS A. Study of Recreation Resources Survey
Methodology – Changes in flows, sediment transport,
ice formation could likely result in significant changes
in post-construction recreational opportunities
downstream of Talkeetna. Baseline boating , fishing,
Sections 12.5.3, 12.6.3, 12.7.3 have been revised to
indicate that study area may be changed during study
implementation if analysis of specific findings from
other study disciplines indicates recreation resource
effects extend beyond currently anticipated study
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 103 December 2012
Comment
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Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
winter use of Susitna River corridor from Talkeetna to
its mouth needs to be assessed to determine project’s
impacts on recreation and aesthetics. FERC will
need this info to balance power and non-power uses
of Susitna River in its licensing decision; NPS will also
need info to develop appropriate Section 10(a)
recommended terms and conditions for the license.
Only if studies of the river’s post-project flows,
morphology, ice processes, fish habitat, etc.,
determine that there will be negligible effect on
relevant biophysical conditions in river corridor
downstream of Talkeetna should recreational and
aesthetics study areas be restricted to the river
corridor upstream of the confluence w/ Talkeetna and
Chulitna rivers.
boundaries.
At this time, AEA elects to terminate the river
recreation and flow study at river mile 83 where the
George Parks Highway Bridge crosses the Susitna
River. This termination point was selected based on
the influence of the Chulitna and Talkeetna rivers on
the channel shape and structure of the Susitan
downstream of their confluence coupled with proximity
of egress for non-motorized watercraft on the Susitna
River. If results from other resource disciplines, i.e., ice
processes, hydrology, and geomorphology, indicate
that the Project will affect river flows in a way that
changes the way recreationist currently use the lower
Susitna River, the Project impact analysis will extend
further downstream.
Memo 9/20/2012 Cassie
Thomas
NPS C.1. Access Points – Study efficiency could benefit if
resources were re-programmed away from certain
areas along Richardson and Glenn hwys. (e.g.
Chickaloon, Sourdough, Paxson Lake). Would
presumably help keep study costs in line, while
including summer and winter access points
downstream of Talkeetna. If goal of intercepting
Chickaloon area residents is to sample subsistence
activities, this effort is more appropriate under
Subsistence survey.
Intercept locations have been revised to re-allocate
effort and this is discussed in Section 12.5.4.
Memo 9/20/2012 Cassie
Thomas
NPS C.1. Access Points – Description of access points
along Parks Hwy. leaves impression that Talkeetna is
on the Parks. Might be better to say that it runs past
Talkeetna Spur Rd.
Agreed, Section 12.5.4 has been updated accordingly.
Memo 9/20/2012 Cassie
Thomas
NPS C.1. Access Points – Fixed Wing Aircraft: Will effort
be made to intercept private aircraft at Talkeetna
Airport? If not, why not, in light of planned intercepts
at Willow Airport and float plane dock?
Talkeetna Airport is included in the intercept survey
plans, see Section 12.5.4
Memo 9/20/2012 Cassie NPS 3. Survey Content – Boundary Project surveys As discussed in TWG meetings 9/20 & 10/03, it is
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 104 December 2012
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Thomas provide useful template for Susitna-Watana Project,
but crucial difference between these two projects must
be keep in mind ... Better questions to capture
baseline recreational resource conditions in Susitna-
Watana study area would focus more on recreational
experiences currently sought by area visitors, in terms
of attributes like remoteness, solitude, self-reliance,
low encounter rates, absence of “combat fishing”
atmosphere, etc. Instead of asking about the
adequacy of existing facilities and services – none of
which are provided by AEA – better questions for
capturing pre- and post-project differences would
assess demand for potential new facilities (such as
reservoir-based fishing, serviced campgrounds,
maintained trails, a hut system, etc.).
understood the the Boundary Project, is different that
the setting for the Susitna-Watana Hydroelectric
Project but the basic premise of the survey plan has
some applicability. The survey plans for this Project
have been customized to gather factors relevant to
recreationists in the Susitna River region. The quality
of experience aspect is discussed in Section 12.5.4
and outlined on the draft survey instrument in
Attachment 12-3. The capacity analysis discussion,
which includes pre and post conditions, is provided in
Section12.5.4.
Memo 9/20/2012 Cassie
Thomas
NPS 3. Survey Content – Need to determine whether
some current area visitors might go elsewhere if
Susitna-Watana Project significantly changed
recreational character of the area.
The intercept and mail surveys will help address
displacement. Executive interview research will also be
used.
Memo 9/20/2012 Cassie
Thomas
NPS 3. Survey Content – Party size is important
recreational use parameter in its own right (e.g., helps
characterize visitor experience); this info should be
collected early in intercept survey.
Based on experience, group size questions are best
situated close to questions regarding spending. Final
placement of all questions will be determined during
pre-testing of the survey instruments. A question
regarding party size is included in the draft intercept
survey instrument (Attachment 12-3).
Memo 9/20/2012 Cassie
Thomas
NPS 3. Survey Content – Basic structure of the intercept
survey will likely work as online survey, but some
elements need revision; e.g.,NPS suggests the “don’t
know” and “refused” options be deleted from each
question.
Agreed. Section 15.5.4 has been updated to more
clearly explain the differences in some questions are
based on the mode of delivery.
Memo 9/20/2012 Cassie
Thomas
NPS D. Mail & Online Survey – By surveying only
registered voters, sample will be somewhat skewed in
terms of demographics. Younger visitors are less
likely to be registered in AK, as are military members
and their dependents. Snowbirds may also be
Use of the voter registration database is a valid sample
universe for the Regional Resident Household Mail
Survey. The voter registration database is readily
available, screens for those over age 18, and also
contains a mailing address in addition to a physical
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 105 December 2012
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Affiliation Comment or Study Request AEA’s Response
registered in another state, even if they own property
in / near the study area. Is it possible to use power
utility customer lists to generate a random sample?
DMV records may also yield a less biased sample
population.
address of those registered to vote. While it is
understood that not all regional residents are
registered to vote, this database represents a wider
diversity of names and addresses than commercially
purchased mailing lists (such as utility customers).
Memo 9/20/2012 Cassie
Thomas
NPS D. Mail & Online Survey – Contingency plan: Does
AEA have plan for gathering recreation and aesthetics
resource info if study area is affected by floods, other
unusual or extreme weather, wildfires, earthquakes,
road or railroad closures, etc., during critical survey
periods? Or if Susitna River is subject to additional
emergency Chinook sport fishing closures? These
factors can have drastic effect on number of
recreational users who want to / are able to access
the study area. Study plans should include a detailed
strategy for altering survey methods and / or
extending study period in event the study area is
affected by these forces beyond AEA’s control.
The studies are designed to understand recreation
trends in addition to a 2013 snapshot. The studies in
2013 and 2014 are also intended to collect data from
recent years. There are a variety of source sources of
information that can help define the baseline conditions
and trends related to recreation. This is not a new or
unique situation for any study, analysis endeavor or
Project. In addition to trying to reach back and identify
recreation trends and uses, and quality of experience
in past seasons, AEA has 2014 to possibly perform
further investigations related to recreation.
Memo 9/20/2012 Cassie
Thomas
NPS D. Mail & Online Survey – AEA proposes to reduce
intercept survey frequency (fortnightly instead of
weekly) to save money, if sufficient sample size can
otherwise be ensured. AEA should also consider
reprogramming its survey efforts as season
progresses to respond to unforeseen weather,
access, regulatory conditions.
Contingency for sample days disrupted by weather,
access (road closures), etc. has been built into the
survey sampling plan. The intercept survey timing
description has been expanded in 12.5.4.
Memo 9/20/2012 Cassie
Thomas
NPS E. Executive Interviews – Project description: Would
be helpful to provide more info for interview subjects
about Susitna-Watana Project’s possible effects on
recreation, aesthetics. Many non-specialists have no
context for Susitna-Watana study area, and project’s
footprint will be more than just a high dam and large
reservoir.
AEA plans public outreach and to distribute fact sheets
about the Project, as well as answering questions
about Project features asked by interviewees. The draft
executive interview protocols include a description of
the project and study area to inform interviewees prior
to the semi-structured questioning. The wording
describing the project will be similar to that found on
AEA’s website for consistency (See Attachment 12-4).
Memo 9/20/2012 Cassie
Thomas
NPS E. Executive Interviews – Before project’s final
operations are determined (e.g., habitat maintenance,
The reference regarding the Project being planned to
help meet renewable energy goals has been removed.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 106 December 2012
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sediment flushing, ramping flows, which subtract from
volume of water available to make power), and before
total project costs are known, it is inappropriate to tell
survey subjects that the project will “meet nearly 50%
of the Railbelt’s electrical demand.”
See Attachment 12-4.
Memo 9/20/2012 Cassie
Thomas
NPS E. Executive Interviews – Goal of executive
interviews is to gather more info about baseline
conditions and potential project effects, not to “sell”
project to recreationists.
Agreed. Interviews should strive for clarity and avoid
bias. see – Attachment 12-4.
Memo 9/20/2012 Cassie
Thomas
NPS E. Executive Interviews – Add brief description of new
road, new power line, changes in natural flows
downstream of Susitna-Watana Dam, potential
changes in snow and ice cover, etc., to executive
survey intro.
The purpose of the executive interview research as
defined in the study plan is to gather baseline
recreation use data, not opinions about potential
impacts. Adding descriptions of potential infrastructure
and other impacts that have not been properly studied
and determined could bias the process in collecting
baseline information. See Attachment 12-4.
Memo 9/20/2012 Cassie
Thomas
NPS E. Executive Interviews – Would be useful to learn
more about kinds of recreational experiences
executive survey subjects seek in Susitna-Watana
Project area.
The kind of experiences being sought will be included
in the Executive Interviews research and where
possible, be identified in the in the Intercept/Mail/Web
surveys. See Attachments 12-3.
Memo 9/20/2012 Cassie
Thomas
NPS E. Executive Interviews – “Day use areas” could be
added to examples of new facilities in Q.7.
This change has been included in the Executive
Interview draft protocol. See Attachment 12-4.
Memo 9/20/2012 Cassie
Thomas
NPS E. Executive Interviews – Survey subjects: Based on
9/20/2012 meeting, appears that members of paddling
clubs and highly skilled kayakers who have run Devils
Canyon will be surveyed – good.
Comment noted.
Memo 9/20/2012 Cassie
Thomas
NPS Northern Economics Survey Request – NPS
disagrees w/ assumption that Susitna-Watana Project
will lead to “increases in visitation.” Some kinds of
baseline project area uses will likely decrease post-
project; e.g., hunting in area inundated by project
reservoir, floating the upper Susitna River
downstream from Denali Hwy., potentially activities
dependent on existing amount of fish habitat and
existing extent and duration of stable winter ice cover.
It is assumed that some types of location
specific/resource users might be displaced and the net
effect may increase or decrease recreation use
depending on the activity. The Demand Assessment
will determine this effect.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 107 December 2012
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Memo 9/20/2012 Cassie
Thomas
NPS Northern Economics Survey Request – Recreational
activities likely to be affected by Susitna-Watana
Project include kayaking and ATV use.
Agreed. These activities are included in the survey
research.
Memo 9/20/2012 Cassie
Thomas
NPS Intercept Survey – NPS recognizes need to keep
length of survey short so subjects will agree to
complete it. Some questions seem more appropriate
to a relicensing situation, where adequacy of existing
licensee-provided facilities and mgmt. is under review.
In Susitna-Watana’s case, primary need is more info
about baseline recreational use in area that could be
affected by the project. Such use can be further
characterized by attributes, such as experiences
sought and opportunities provided to the public.
The importance of understanding quality of experience
is described in Section 12.5.4; and built into the draft
survey instrument in Attachment 12-3. The designs of
the surveys need to take into careful consideration that
excessive length or detail may deter response and
affect successful fielding. There is also a mail survey
effort – which will allow for another avenue to gather
information about recreation attributes. .
Memo 9/20/2012 Cassie
Thomas
NPS Intercept Survey, Q.3. – Why are subjects not being
asked if they drove the Parks Hwy.?
This question will be adjusted according to location of
the intercept survey. Attachment 12-3 is a sample for
one area.
Memo 9/20/2012 Cassie
Thomas
NPS Intercept Survey, Q.13. & 14. Quality of Experience
and Crowdedness and Q.19. Experiences Sought –
Re-order these questions. Put what is now Q.19.
before Q.13.
Final placement of questions will be determined during
pre-testing of the survey.
Memo 9/20/2012 Cassie
Thomas
NPS Intercept Survey, Q.13. & 14. Quality of Experience
and Crowdedness and Q.19. Experiences Sought –
Re-word Q.13. and Q.14. to find out if project area
lacks facilities or mgmt. that would enhance
recreational experiences, if provided. Given low
density, high dispersion of recreational use in Susitna-
Watana Project area, linear quality and crowdedness
assessments are unlikely to yield info useful to project
design and mgmt. decisions.
Draft questions regarding quality of experience and
carrying capacity are included in the draft intercept
survey (Attachment 12-3) in an effort to gather some
data to assist project design and management
decisions, even in the environment where use is
dispersed.
Memo 9/20/2012 Cassie
Thomas
NPS Intercept Survey, Q.15., 16., 17. – These questions
seem more appropriate for assessing how well
existing recreation management plan is working at an
existing hydro project, than for assessing probability of
displacement from areas that will be utilized or
affected by Susitna-Watana Project. While there may
The survey questions are not intended to be based on
AEA being a recreation provider, rather the intent is to
understand how users in the area value the recreation
experience and its attributes regardless of who is
managing the use.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 108 December 2012
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be existing conflicts between visitors to Susitna-
Watana Project area, they are not necessarily AEA’s
responsibility to fix. Presumably AEA will want to
exert – or be required to exert – more active mgmt. of
project lands and waters post-construction, reducing
conflicts due to littering, vandalism, gunfire too close
to roads, trails and campsites, etc.
Memo 9/20/2012 Cassie
Thomas
NPS Intercept Survey, Q.15., 16., 17. – Until USNPS
knows more about kinds of new recreational facilities
Susitna-Watana Project may provide; how project
operations will affect boating, fishing, etc.,
downstream; and the mgmt. and access policies for
the dam, road, transmission corridor right of way,
reservoir, it will not be possible to design survey
questions that will yield meaningful feedback on public
preferences for such facilities and policies. Additional
survey regarding such preferences will be needed
after more is known about location of new road and
transmission corridor, reservoir operations, boatability
of the river downstream of the dam, etc.
Understanding preferences is useful early in the
Project to inform the planning of possible recreation
facilities.
Memo 9/20/2012 Cassie
Thomas
NPS Intercept Survey, Q.20(f). & (g). – Ask subjects about
adequacy of trails, trailheads.
Questions regarding trailheads and adequacy of trails
are included in the current draft of the intercept survey
See Attachment 12-3.
Memo 9/20/2012 Cassie
Thomas
NPS Intercept Survey, Q.20(f). & (g). – Table should ask
about need for Info. and Edu. resources: kiosks,
signage, trail information, points of interest, geologic,
historic and / or cultural information.
Questions regarding signage, etc. are included in the
draft intercept survey. See Attachment 12.3.
Memo 9/20/2012 Cassie
Thomas
NPS Intercept Survey, Q.20(f). & (g). – Ask subjects about
mgmt.: level of maintenance, staff presence, etc.
Questions regarding facility management were
considered, but due to considerations for survey length
are not in the current draft of the intercept survey. This
line of question will be considered in the design of the
mail survey.
Memo 9/20/2012 Cassie
Thomas
NPS Intercept Survey, Q.21. & 22. – Reverse order of
these questions to ascertain which areas are most
important to visitors before assessing whether
The final placement of will be determined during pre-
testing of the survey instruments. .
Revised Study Plan
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FERC Project No. 14241 Page 109 December 2012
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anything interfered w/ their aesthetic enjoyment. Note
that USNPS Aesthetic Resources study plan request
included natural sounds, not just scenic values.
Memo 9/20/2012 Cassie
Thomas
NPS Intercept Survey, Q.23. – Question should be closer to
start of survey. It provides context for many more
specific questions that follow. Could be combined
with Q.10. to help keep survey from being too long.
The final placement of will be determined during pre-
testing of the survey instruments. .
Memo 9/20/2012 Cassie
Thomas
NPS Intercept Survey, Q.24. – Determine party size earlier
in survey. It is an important recreational attribute; it’s
important to capture this info before subjects
potentially abandon the interview.
The final placement of questions will be determined
during pre-testing of the survey instruments.
Memo 9/20/2012 Cassie
Thomas
NPS Incidental Observation Survey – Possible to get
update on effectiveness of this survey prior to release
of the 2012 study report?
There has been limited response as noted in TWG
meeting of 10/03/12. However, it appears the
instrument’s design is effective. Follow-up with
selected contractors will be conducted to gather
additional information regarding their recreational use
observations while in the study area. No design
changes are expected to the Incidental Observation
Survey. This form is shown in Attachment 12-1.
Aesthetic Resources Study (Section 12.6)
Memo 8/07/2012 Unspecified NPS 10.6.2. Existing Info & Need for Additional Info –
Despite what PSP states, there was no aesthetics
inventory (as would be understood by that term in
2011-12 as opposed to 1984, in the PAD).
Agreed, Section. 12.6.2 updated.
Memo 8/07/2012 Unspecified NPS 10.6.2. Existing Info & Need for Additional Info –
Despite what PSP states, there was no gap analysis.
Agreed, Section 12.6.2 updated.
Memo 8/07/2012 Unspecified NPS 10.6.2. Existing Info & Need for Additional Info – PSP
states “Through the prior processes, the FERC
scoping process and incorporation of work group and
other licensing participant recommendations, study
methods for 2013-2014 were developed.” This is
incorrect, they are still being developed. This is
strange language to include in a proposed study plan.
USNPS has had little time, opportunity to see
Agreed, Section 12.6.2 updated.
Revised Study Plan
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FERC Project No. 14241 Page 110 December 2012
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products and engage consultants so far; it is
extremely premature to claim this as fait accompli.
Memo 8/07/2012 Unspecified NPS 10.6.3. Study Area – Limiting downstream scope of
this and other studies to Talkeetna is unfounded.
Until results of the instream flow, ice, fluvial
geomorphology, fish, and other studies are available,
cannot say how far downstream project’s measurable
effects on visual, auditory resources will go.
Vehemently disagree w/ this premature decision,
which contradicts statements elsewhere in this and
other PSPs acknowledging need to rely on the results
of other studies.
Sections 12.5.3, 12.6.3, 12.7.3 have been edited to
indicate that an extension of the study area to areas
downstream of Talkeetna will occur based on the
results of impact assessment modeling completed by
the Ice Processes in the Susitna River Study.
Memo 8/07/2012 Unspecified NPS 10.6.4. Study Methods, Estab. Key Observation
Points (KOPs) – Does NPS, other resource agencies
and stakeholders, get a say on KOPs? When? This
is supposed to be “The Plan”, not a plan to plan.
It is expected that final target analysis locations will be
selected and mapped with continued interdisciplinary,
Agency and licensing participant coordination during
study implementation as noted in Section 12.6.3.
Memo 8/07/2012 Unspecified NPS 10.6.4. Study Methods, Visual Distance Zones – No
mention of assessing aesthetics of varying flows. This
is a high volume glacial river flowing at up to 25 mph –
the sight, sound of flows, color of water, mixing at
clear water tributaries are major components of river-
related recreation. Need to do this at KOPs along the
river, in all seasons, using videography (sound).
Analysis locations (KOPs) will be placed in specific
locations designed to assess aesthetic attributes of the
river corridor across all seasons. Additional
coordination will occur with the Ice Processes in the
Susitna River Study/ Geomorphology Study /Riparian
Vegetation Study Downstream of the Proposed
Watana Dam to make use of videography collected at
standard transect locations.
Memo 8/07/2012 Unspecified NPS 10.6.4. Study Methods, Visual Distance Zones –
Need to add to sound analysis.
A description of the soundscape analysis, including
measurements of baseline, post project, and project-
induced soundscapes in included in Section 12.6.4.
Memo 8/07/2012 Unspecified NPS 10.6.4. Study Methods, Seasonal Surveys of Ambient
Sound Levels – When does NPS decide where the 4
LT and 16 ST locations will be?
This is part of the study implementation as outlined in
the study plan, see Table 12.6-3. Quarterly technical
advisory meetings will be held to collaborate with
agencies, as noted in Section 12.6.3.
It is expected that final soundscape measurement
Revised Study Plan
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FERC Project No. 14241 Page 111 December 2012
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locations will be selected and mapped with continued
interdisciplinary, Agency and licensing participant
coordination during study implementation as noted in
Section 12.6.3.
Memo 8/07/2012 Unspecified NPS 10.6.4. Study Methods, Seasonal Surveys of Ambient
Sound Levels – What if NPS thinks there should be
more?
Final soundscape measurement locations will be
selected and mapped with continued interdisciplinary,
Agency and licensing participant coordination during
study implementation as noted in Section 12.6.3.
Memo 8/07/2012 Unspecified NPS 10.6.4. Study Methods, Seasonal Surveys of Ambient
Sound Levels – Need to agree about this prior to
10/15/2012. NPS would like to have enough advance
detail to involve NPS Soundscapes staff in reviewing
this methodology.
Section 12.6.3 describes the process for selecting final
soundscape measurement locations.
Memo 8/07/2012 Unspecified NPS 10.6.6. Schedule – Schedule is very short; no work is
conducted in any December.
AEA is not planning field surveys in December and
January as it typically is a period of extreme cold and
lack of daylight. Discussed in 12.5.4. Field studies will
commence in February 2013.
Memo 8/07/2012 Unspecified NPS 10.6.6. Schedule – Initial study report is scheduled for
12/13/2012 – will this allow integration of results of
other biophysical studies?
Integration with other resources will occur
systematically, and in an ongoing manner in 4Q 2012,
and for the duration of the 2013/2014 studies.
River Recreation Flow and Access Study (Section 12.7)
Agency
consultation
meeting
7/25/2012 Cassie
Thomas
NPS Collaboration regarding study methods, requested
concentration on quality of experience rather than
exclusively on quantification of use.
The River Recreation Flow and Access Study will focus
on incorporating inputs from all sub-disciplines (i.e.,
use & demand, facilities and trails, flow-based
recreation, aesthetics, and soundscape) to collectively
describe experiential attributes (social, physical and
managerial ) under baseline and post-project
conditions.(Sections 12.5 – 12.7).
Email 8/01/2012 Cassie
Thomas
NPS Contribution of detailed information about Susitna
River reaches and access; reports of incidental
observations.
Followed up in section 12.7; shown in Figure 12.7-1.
Follow-up information on Incidental Observation form
given at 10/03/12 TWG meeting.
Memo 8/07/2012 Unspecified NPS Consider changing title of study to “Flow Dependent
Recreation,” reflecting broader affected activities
The study plan name has changed to River Recreation
Flow and Access Study.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 112 December 2012
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beyond boating and fishing.
Memo 8/07/2012 Unspecified NPS Study’s title, some initial statements about scope are
contradictory. Study goal is not merely to contribute
data concerning recreational boating and access – it
is to look at all forms of flow-dependent recreation.
Includes activities like fishing that are affected by
flows, regardless of whether recreationalists are doing
it in a boat or from shore.
Agreed, study plan has been revised throughout
Section 12.7.These studies are highly integrated, as
mentioned throughout Sections 12.5 – 12.7.
Memo 8/07/2012 Unspecified NPS Aesthetics can be flow-dependent (stillwater in res. v.
free-flowing stream; lost sight, sound of whitewater at
high flows in DC; morphological, vegetation changes
downstream due to changed flow regime). No
mention of this in Recreation or Aesthetics PSPs.
Flow-dependent aesthetic attributes will be assessed
at KOPs established up-and downstream of the
proposed dam, and will include an evaluation of scenic
quality metrics pertinent to flow and soundscape
measurements. Scenic quality metrics will focus on
assessing the degree of within channel heterogeneity
(i.e, pool, riffle, rapids) expected at various flow levels
and across seasons. Flow dependent aesthetic
attributes will also be evaluated through executive
interviews conducted as part of the River Recreation
Flow and Access Study.
Memo 8/07/2012 Unspecified NPS No mention of whether impacts on recreation access
and experiences due to changed ice, snow cover
resulting from changed flow regime will be assessed
under this PSP. This should be included.
The winter recreation study will include establishing
baseline data on winter recreation activities within the
Study Area, including those dependent on ice-
dependent recreation for locations upstream of the
Parks Highway Bridge. The impact analysis will be
based on information obtained pertinent resource
disciplines, e.g., hydrology (RSP Section 7), ice
processes (RSP Section 7.6), HEC-RAS (RSP Section
8.5.4.3), and geomorphology (RSP Section 6).
At this time, the River Recreation Flow and Access
Study extends to river mile 83 where the George Parks
Highway Bridge crosses the Susitna River. This
termination point was selected based on the influence
of the Chulitna and Talkeetna rivers on the channel
shape and structure of the Susitna downstream of their
Revised Study Plan
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FERC Project No. 14241 Page 113 December 2012
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confluence coupled with proximity of egress for non-
motorized watercraft on the Susitna River.
In the fall of 2013, Recreation Resources Study leads
will examine the preliminary results from other
resource disciplines, e.g., hydrology (RSP Section 7),
ice processes (RSP Section 7.6), HEC-RAS (RSP
Section 8.5.4.3), and geomorphology (RSP Section 6),
to assess the downstream longitudinal extent of the
project on physical stream processes. If the results
from these resource disciplines indicate that the
Project will affect river flows and ice formation in a way
that changes the way recreationists currently use the
lower Susitna River now, the Project impact analysis
may extend further downstream of the confluence with
the Talkeetna and Chulitna Rivers. Recreation
resource leads will determine if the downstream
geographic scope for the River Recreation Flow and
Access Study described in section 12.7.3 needs to be
adjusted for the 2014 field season.
Memo 8/07/2012 Unspecified NPS 10.7.1. Gen. Description of Proposed Study, Study
Goals & Objectives – PSP includes “developing flow
preference curves for each major river reach by type
of use and equipment” as a study goal and objective.
Unlikely that a preference curve can be developed for
winter activities that require stable river ice. It will
either be present or absent. What method will be
used to assess this effect?
An investigation of river ice dependent winter
recreation is included in Section 12.7 of the RSP. The
Study will investigate winter recreation activities
occurring within the bounds of the Susitna River
channel that are dependent on river ice formation. The
purpose of the 2013 ice-dependent recreation portion
of the winter recreation program is to determine
existing ice-dependent recreation, the purpose (i.e.,
transportation or recreation) and the conditions under
which these activities occur. The ice dependent
recreation activities are likely to include snowshoeing,
skiing, dog sledding, trapping and snowmobiling as
well as use of river ice for winter transportation
corridor. Additional activities observed during the field
investigations will be documented as well. A list of
winter recreation and competitive events dependent on
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 114 December 2012
Comment
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Affiliation Comment or Study Request AEA’s Response
river ice formation will also be compiled and analyzed.
The river ice dependent winter recreation study will
document winter recreation activity on the Susitna
River ice using a combination of field observations,
executive interviews and analysis of recreation and
competitive events. The executive interviews and
analysis of events will include data beyond the current
2-year field data collection period. Use patterns will be
analyzed to determine spatial and temporal use
preferences as well as frequency of use by month.
The 2013 study area will be divided into the three river
reaches identified for the River Recreation Flow and
Access Study (RSP Section 12.7) starting at the Denali
Highway Bridge (RM 290) and terminating at the
George Parks Highway Bridge at Sunshine (RM 83).
The 2013 work will be completed in coordination with
the Ice Processes in the Susitna River Study (RSP
Section 7.6). In the summer of 2013, results from the
Ice Processes in the Susitna River Study will be
examined to determine the extent to which impacts to
ice-dependent recreation are expected as a result of
the proposed project.
Memo 8/07/2012 Unspecified NPS 10.7.3. Study Area – Do not understand the
statement: “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 of the instream
flow, flow routing, ice processes, etc. studies are in
hand? What if NPS, others disagree w/ AEA’s
geographic scope decision? Needs to be nailed down
by 10/15/2012.
This statement has been deleted from Section 12.7.3.
Memo 8/07/2012 Unspecified NPS 10.7.3. Study Area – Unfounded for AEA to arbitrarily
stop Recreation River Flow Study at Talkeetna River.
At this time, the River Recreation Flow and Access
Study extends to river mile 83 where the George Parks
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 115 December 2012
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Affiliation Comment or Study Request AEA’s Response
Highway Bridge crosses the Susitna River. This
termination point was selected based on the influence
of the Chulitna and Talkeetna rivers on the channel
shape and structure of the Susitna downstream of their
confluence coupled with proximity of egress for non-
motorized watercraft on the Susitna River.
In the fall of 2013, Recreation Resource Study leads
will examine the preliminary results from other
resource disciplines, e.g., hydrology (RSP Section 7),
ice processes (RSP Section 7.6), HEC-RAS (RSP
Section 8.5.4.3), and geomorphology (RSP Section 6),
to assess the downstream longitudinal extent of the
project on physical stream processes. If the results
from these resource disciplines indicate that the
Project will affect river flows in a way that changes the
way recreationists currently use the lower Susitna
River now, the Project impact analysis may extend
further downstream of the confluence with the
Talkeetna and Chulitna Rivers. Recreation resource
leads will determine if the downstream geographic
scope for the River Recreation Flow and Access Study
described in section 12.7.3 needs to be adjusted for
the 2014 field season.
Memo 8/07/2012 Unspecified NPS 10.7.3. Study Area – Contradicts prior commitments
to rely on results of other studies to inform impacts on
recreation. Those studies will not be completed for
several years.
Study plan does not indicate “final” results rather they
will be interim results as with many disciplines. See
Section 12.7.3.
Memo 8/07/2012 Unspecified NPS 10.7.4. Study Methods – Underscores why NPS
needs to see proposed survey instruments, protocol,
etc., to determine if Recreation Survey adequately
addresses these issues.
Drafts have been provided. Attachments 12-4, 5.
Memo 8/07/2012 Unspecified NPS 10.7.6. Schedule – No info about when / how Level 1
– 3 analyses fit in w/ this schedule.
Level 1 and 2 investigations were completed as part of
the 2012 field studies. Level 3 investigation is now
described in the RSP section 12.7.4. The study
schedule is presented in section 12.7.6.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 116 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
Memo 8/07/2012 Unspecified NPS 10.7.6. Schedule – Much of this study plan appears
to have been cut-and-paste from the USNPS / OSU
guide, without explanation of how methods will be
applied to this particular project.
Section 12.7.6 has been revised overall. The study
methods have been revised in response to agency
comments and field observations during the 2012 field
investigations. The revised study plan is directly
applicable to the study area and proposed project.
Memo 8/07/2012 Unspecified NPS 10.7.6. Schedule – Need specifics and agreement on
who makes mid-point decisions to proceed (e.g., from
Level 1 to 2, or 2 to 3, based on what criteria).
Level 1 and 2 investigations were completed as part of
the 2012 field studies. Level 3 investigation is now
described in the RSP section 12.7.4. The study
schedule is presented in section 12.7.6.
Memo 8/07/2012 Unspecified NPS 10.7.6. Schedule – Only 1 winter and 1 summer of
study, and no Novembers or Decembers. This does
not indicate a sincere concern for impacts on winter
recreation. Arguably, AK’s winter recreation season is
longer than its summer season. It is certainly
important to users, purveyors of equipment, local
economy.
Section 10.7.6 now reflects field visits/surveys in all 4
seasons. Still no intercepts in Dec – Jan because of
safety of surveyors in recreation study, 12.5.4. River
Recreation Flow and Access Study data collection will
be available to river recreationalists 24/7 to record
trips.
Memo 8/07/2012 Unspecified NPS 10.7.6. Schedule – 1 yr. of study is not an adequate
sample size to support conclusions about important
flow-dependent activities like sport fishing, float
hunting. Note emergency Chinook closure this year –
how can AEA study the most sought-after fish species
in SC AK if harvest is prohibited during the only year
of the study? Likewise, upland game hunting season
is dependent on variable weather, etc. One season is
not enough to document baseline opportunities and
experiences when they are dependent on highly
variable interannual conditions.
Historical data will also be integrated into the analysis.
Most studies are front-loaded to 2013 data capture,
with a safeguard to capture unusual 2013
circumstances in 2014. This is reflected in Table 12.7-
2. Furthermore, the River Recreation Flow and Access
Study will utilize an internet survey and executive
interviews. Both tools will allow for capture of historic
information (20-30 years) from users regarding
individual trips on the river.
TWG meeting 8/08/2012 Harry
Williamson,
Cassie
Thomas
NPS Request for more information about a) inter-
relationships of recreation, aesthetics, river flow
surveys, b) request to see survey instruments, c)
methodology for sound studies, d) KOP selection
Follow-up meetings were held 9/20/12 and 10/03/12 to
concentrate on survey instruments – sound
methodology is outlined in the study plan, and AEA will
collaborate on soundscape analysis in 2013-14. Initial
KOP analysis discussed at a 10-3-12 meeting. The
resulting modifications to the Study Plan are shown in
sections 12.5, 12.6. Draft survey instruments are
shown in Attachments 12-3, 12-4, 12-5..
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 117 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
TWG meeting 8/08/2012 Ken Wilcox FERC Request for list of potential locations of KOP’s,
intercept survey locations, and more description of
river reaches/access.
Follow-up meetings were held 9-20-12 and 10/03/2012
and these were presented. The resulting modifications
to the Study Plan are shown in Sections 12.5, 12.6,
12.7, and Figures 12.5-3, 12.6-1, 12.7-1.
Email 8/14/2012 Harry
Williamson
NPS Collaborative review of Boundary Project survey;
survey contents
Follow-up meetings were held 9-20-12 and 10/03/2012
and these were presented. The resulting modifications
to the Study Plan are shown in section 12.5.4.
Phone
conversation
8/21/2012 Rebecca
Schwanke
ADNR-
ADF&G
Coordination to determine extent of data sources
regarding hunting & fishing.
The Recreation Resources Study will coordinate with
both Wildlife Resources and Fisheries and Aquatic
Resources to establish baseline data on fisheries and
wildlife harvest data. The Fish and Aquatics
Resources Studies will provide fish harvest data
characterizing baseline harvest levels and harvest
locations for commercial, sport, personal use, and
subsistence fisheries for Susitna-origin-resident and
anadromous fish (3Q 2013). These data will be used
to understand the geographic distribution and
abundance of and fisheries-based recreation
opportunities within the Study Area. The results of the
impact analysis will be incorporated to understand
potential changes in fisheries-based recreation
opportunities that may result from changes in fisheries
abundance and distribution (1Q 2015). The Wildlife
Resources Study will provide baseline wildlife harvest
data (1Q 2014, 3Q 2014), and will be used to
characterize existing conditions and anticipated
impacts to impacts to game species abundance,
hunting opportunities, and hunter distribution.
TWG meeting 9/20/2012 Cory Larson BLM Contribution of detailed trails information, provided
input about study area regarding trails.
Integrated into Section 12.5.4 Study Plan Trails
Section.
Phone
conversation
9/20/2012 Harry
Williamson
NPS Review of survey instruments/methods developed to
date.
Suggestions integrated into Study Plan, Section 12.5.4.
TWG meeting 9/20/2012 Cassie
Thomas
NPS a)Prefers analysis go downstream of
Talkeetna.b)Intercept Surveys – Prefers that
concentration be south of Talkeetna, rather than the
a)12.5.3, 12.6.3, 12.7.3 have been edited to reflect that
the study area may be changed if info from other
disciplines inform changes.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 118 December 2012
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Affiliation Comment or Study Request AEA’s Response
Richardson Highway.
b) suggestions for intercept sites.
c)Suggestions for incidental observation form
(currently deployed in 2012) to have wider use.
d)Suggested AEA develop communications protocol
so the USNPS could provide consultation outside of
formal comment periods.
e)Interested in additional TWG meeting to discuss
recreation, aesthetics, and recreation river flow.
f)Interested in reviewing Recreation River Flow survey
instrument.
b) Section 12.5-4 – Intercept sites have been adjusted
accordingly.
c) Under development.
d) AEA took this under advisement – not addressed in
Section 12.
e)Held 10/03/2012
f) Contained in SP as Attachment 12-4, 5.
TWG meeting 9/20/2012 Scott Miller NMFS a)Prefers analysis go downstream of Talkeetna.
b)ndicated ADF&G Statewide Angler/log book surveys
are biased.
c)Suggestions as to Intercept survey sites.
a)12.5.3, 12.6.3, 12.7.3 have been edited to reflect that
the study area may be changed if info from other
disciplines inform changes.
b) ADF&G data will be incorporated as one source of
data for historical sport fishing; mentioned in 12.5.4.
c) Under 2012 development.
TWG meeting 9/20/2012 Harry,
Williamson
NPS Question about timing/availability of survey database,
review.
Summary results available 1Q 2014, as shown in Table
12.5-1. Raw data availability undetermined.
TWG meeting 10/03/2012 Joe Geifer ADNR-
ADF&G
Question about timing/availability of survey database,
review.
Summary results available 1Q 2014, as shown in Table
12.5-1. Raw data availability undetermined.
TWG meeting 10/03/2012 Cassie
Thomas,
Harry
Williamson
NPS Request for clarification about “Target Analysis
Locations”; night sky conditions, focus groups, river
reaches, extent of river reach study area, web
surveys, and contingency plans. Suggestions for
executive interview respondents.
Study Plan developments in these topic areas are
included in Sections 12.5 – 12-7.
TWG meeting 10/03/2012 Joe Geifer ADNR-
ADF&G
Concern about timing of review of the RSP, and
request for response to comments previously
contributed.
Study Plan comment period has been extended. Not
addressed specifically in Section 12. AEA explained
the timing of the release of RSP drafts and the agency
comment period.
TWG meeting 10/03/2012 Dave Griffin ADNR-DPOR Question about compensation for affected recreation
uses. Contribution of recreation data.
AEA explained this is an upper state-level
consideration.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 119 December 2012
Comment
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Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
SECTION 13 CULTURAL AND PALEONTOLOGICAL RESOURCES
General
No comments.
Cultural Resources Study (Section 13.5)
TWG meetings 8/08/2012 &
9/07/2012
Lisa Wade &
Angela Wade
Chickaloon
Native Village
Request made for consideration of culturally modified
trees (CMTs)
Section 13.5.4.3 has been added to the RSP to define
CMTs (e.g. scar, plank removal, bark removal, burn)
and methods for field discovery.
TWG meeting 8/08/2012 Frank
Winchell
FERC Would Alaska Native representatives be able to
participate or monitor field studies?
The draft RSP has been updated to include an
internship program to incorporate one or more Native
interns in field and monitoring efforts to help inform
licensing participants and develop shared perspectives
on cultural resource inventory and evaluation.
TWG meeting 8/08/2012 Frank
Winchell
FERC Request made for more refined definition of indirect
APE
Section 13.5.3 of the draft RSP has been updated to
describe the indirect APE which includes Project-
induced dispersed recreation, and other areas adjacent
to Project facilities including potential visual impact
areas. The indirect APE is depicted in Figure 13.5-2.
TWG meeting 8/08/2012 Frank
Winchell
FERC Request made for better definition of areas surveyed
in 1980s and their intensity
Section 13.5.2 of the draft RSP describes the 1980s
era survey data. .Figures 13.5-3 and 13.5-4 have been
added to the draft RSP to identify survey coverage and
intensity of these prior surveys. Sections 13.5.4.1 and
13.5.4.2 of the draft RSP have been updated to
describe how these data are used in the development
of the probabilistic model and sampling strategies.
TWG meeting 9/07/2012 Richard
VanderHoek
ADNR-AOHA/
SHPO
Will reservoir direct effects APE include a margin
around the normal high water pool elevation of 2,050
to account for landslides and permafrost areas
affected by the reservoir filling (and to accommodate
possible future reservoir recreation facilities along the
shoreline like possible boat-in campgrounds found at
other reservoirs)?
Figure 13.5.2 defining the direct APE for study area
accommodates potential landslide zone and potential
shoreline recreation by using the 2,075-foot elevation
boundary. The direct APE may be modified based on
the results of mass wasting and erosion studies.
TWG meeting 9/07/2012 John Jangala
& Dara Glass
BLM
CIRI
The plans need to consider any 14(h)(1) ANCSA
selections in the study area and identify the current
The Cultural Resources Study team has identified one
14(h)(1) site within the study area. The 14(h)(1) sites
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 120 December 2012
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Affiliation Comment or Study Request AEA’s Response
status of those (including information on BIA surveys
of those areas)
had been excluded from the scope for the prior Data
Gap Analysis; but arrangements have been made to
acquire data from BIA and incorporate into the 2013-14
survey inventory prior to finalization of the RSP.
TWG meeting 9/07/2012 Frank
Winchell and
others
FERC Need discussion of how the locational model
developed in 2012 will be used in the study
methodology.
Section 13.5.4.2, supplemented by Tables 13.5-1 and
13.5-2, has been added to the RSP to explain details
of the site location model.
TWG meeting 9/07/2012 Fran Seager-
Boss
Matanuska-
Susitna
Borough
Request made for inclusion of Matsu Borough
archaeologists in field program
Agreement was reached to incorporate Matsu Borough
archaeologists, as available, in the 2013-14 field effort
and the draft RSP has been updated in Section 13.5.4
to reflect this.
TWG meeting 9/07/2012 Frank
Winchell
& others
FERC Recommends describing how ethnogeography work
will be analyzed or focused to areas that might be
affected by the Project since the language area map
encompasses such a large area.
Figure 13.5-1 has been added to the RSP to show
Native language boundaries, with explanatory text in
Section 13.5.2.2.
TWG meeting 9/07/2012 Frank
Winchell &
others
FERC Request made for map of Native land ownership in
study area
Figure 13.5.2 has been added to the RSP to show
Native land ownership in the study area.
TWG meeting 9/24/2012 Dara Glass &
Becky Long
CIRI &
Coalition for
Susitna Dam
Alternatives
Adding trails that extend to the reservoir was
considered appropriate for indirect effects analysis
area but need to be clear of what sources are used to
map the trails, or even segments of trails and indicate
any designation or official status of trail, or whether
the appear to be user-made trails. Note that the
mapping of trails is to now way indicate that use of
these trails is authorized.
Map legends have been updated to indicate that the
mapping of the trails does not mean they are open or
designated for public use.
TWG meeting 9/24/2012 John Jangala BLM Add Raptor Trail to indirect effects APE map as it
does lead toward Watana Creek (which would be
Watana Arm of the reservoir)
Figure 13.5.2 showing the indirect APE has been
revised to include the Raptor Trail.
TWG meeting 9/24/2012 Dara Glass CIRI Recommend adding ANSCA Corporation boundaries
to a map in cultural resources study plan to show
current use areas in relation to historic language
areas in particular.
Figure 13.1.1 has been added to the RSP to show
Native land ownership in the study area.
TWG meeting 9/24/2012 Rich SHPO/ Provide additional details of survey methods, both Qualitative and quantitative details of the proposed
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 121 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
VanderHoek &
various
ADNR-AOHA
&
various
qualitative and quantitative where possible. survey methods have been added to the RSP in
Sections 15.5.4.1, 15.5.4.2, and 15.5.4.3.
TWG meeting 9/24/2012 Richard
VanderHoek
SHPO/
ADNR-AOHA
Request for clarity in applying trail information to both
reconstruction of historic use versus defining potential
impacts.
Agreement to develop data on three types of trails:
BLM layer, field observation layer, and historic foot trail
layer, as stated in Section 13.5.4.6 of the RSP.
Paleontological Resources Study (Section 13.6)
No comments.
SECTION 14 SUBSISTENCE RESOURCES
Subsistence Resources Study (Section 14.5)
TWG meeting 8/08/2012 David Turner FERC Provide a survey instrument for the household
surveys
Study plan has been updated to include survey
instrument. The draft household harvest survey
instrument is provided in Attachment 14.2 and key
respondent interview protocol in Attachment 14.3.
Letter 9/14/2012 Lisa Wade Chickaloon
Village
Traditional
Council,
Health and
Social
Services Dept
Comments were in reference to the HIA specifically
but noted:
“traditional knowledge should be gathered through
qualitative discussions with Tribal communities to
contribute to the completion of the HIA.”
“can’t stress enough the importance of traditional
knowledge ..”
Traditional Knowledge (TK) interviews will be
conducted in Chickaloon during the first half of 2013,
interview questions regarding health will be developed
in consultation with the HIA team and incorporated into
the TK interview guide for use in all TK interviews.
Section 14.5.4.5 and Table 14.5-3 present TK interview
methods and communities slated to be interviewed
including Chickaloon. Results will be shared with HIA
study team as soon as they are available so that
traditional knowledge can be incorporated into the HIA
study process and analysis. Additionally, the
Subsistence Resources Study team will identify key
respondents for the HIA team for follow-up TK
interviews specific to health.
Federal
Advisory
Board Meeting
10/15/2012 Gloria
Stickwan
Southcentral
Alaska
Subsistence
Regional
Advisory
All eight villages in the Ahtna region hunt in that area,
the study should incorporate these villages
The study plan has been updated to include
Chistochina, Mendeltna, Mentasta Lake, Nabesna and
Slana as study communities (Section 14.5.4.1 and
Table 14.5.9). ADFG and the National Park Service
are conducting subsistence surveys in Ahtna
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 122 December 2012
Comment
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Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
Council (RAC) communities not included in the Susitna studies,
analysis of the results of the NPS/ADFG surveys will
be conducted as part of activities identified in Section
14.5.4.1 and 14.5.4.6.
SECTION 15 SOCIOECONOMIC AND TRANSPORTATION RESOURCES
General
Letter 8/01/2012 John (Jack)
DiMarchi
Citizen Significant number of private landowners (approx.
200) congregated along AK Railroad corridor between
Gold Creek and Hurricane, AK. FERC appears to
recognize community of people who own land along
railroad to south of Gold Creek (exp: Chase
community), but does not appreciate large number of
landowners north of Gold Creek; likely b/c we are not
formally organized like Chase community is.
Social and economic effects on residents in the study
area will be addressed in the Social Conditions and
Public Goods and Services Study. Section 15.6.3 of
the RSP has been revised so that a “railroad
community” located north of Chase is among the
communities considered to be in relatively close
proximity to the proposed Project road and
transmission line alternatives. The other communities
are Cantwell, Trapper Creek, Chase, and Talkeetna.
Letter 8/01/2012 John (Jack)
DiMarchi
Citizen Under Environmental Justice language in NEPA, we
should be recognized as a community; as lead
permitting agency, FERC should open direct dialogue
w/ this community to insure:
1 – Accurate info is delivered directly to community
members;
2 – Public meetings are held at locations that facilitate
community members to participate in NEPA process;
3 – Community’s points of views (for or against
Susitna-Watana Hydroelectric Project components) be
given weight during development of project
alternatives portion of EIS process.
The socioeconomic study will address populations and
incomes and may identify whether there are any
minority or low-income populations as defined under
Executive Order 12898 on Environmental Justice.
AEA’s goal during these licensing studies is to provide
accurate information to all interested parties, to hold
meetings and provide opportunities at a variety of
locations to facilitate public participation in the process
from all interested parties.
Memo 8/07/2012 Unspecified NPS Metrics, analyses regarding socioeconomic costs and
benefits of the Susitna-Watana Hydroelectric Project
should extend beyond estimated value of increased
recreation and tourism. Full accounting of all Susitna-
Watana Hydroelectric Project-related impacts on the
social environment must include an estimate of these
values.
The socioeconomic studies are designed to account for
a broad range of social and economic costs and
benefits. In addition to the regional economic model
analysis, social costs and benefits will be addressed.
The assessment will be quantitative when possible but
some social issues will need to be addressed
qualitatively.
Where the dollar cost of measures can be reasonably
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 123 December 2012
Comment
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Name
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Affiliation Comment or Study Request AEA’s Response
ascertained, we will do so. However, for non-power
resources such as aquatic habitat, fish and wildlife,
recreation, and cultural and aesthetic values, to name
just a few, the public interest cannot be evaluated
adequately only by dollars and cents.
Memo 8/07/2012 Unspecified NPS With respect to Benefits Transfer methodology, this
method is most reliable when reference, study sites,
projects are very similar, and when the economic
impact valuation study at reference site was
performed at the highest standard. Given the dearth
of large, original hydropower projects licensed on free-
flowing rivers in remote locations in recent decades,
NPS believes it will be challenging to ID appropriate
reference project for Susitna-Watana Hydroelectric
Project. There will be numerous assumptions,
approximations associated w/ application of the
benefits transfer method to the Susitna-Watana
Hydroelectric Project. In contrast to lack of
appropriate reference sites for benefits transfer
analysis, however, the value of ecosystem services –
including services associated with the Susitna River –
is currently being studied in the Mat-Su Borough.
As described in Section 15.6.4.1 of the draft RSP, the
benefits transfer approach will be used to supplement
or compare unit values (e.g., value per-day of sport
fishing) for recreational goods and services obtained
from primary valuation methods. It will not be used as
the sole method of estimating the value of changes in
recreation activity in the Project area.
Memo 8/07/2012 Unspecified NPS NPS would like to participate in reviewing proposed
survey methodology, ideally before ability to comment
on the ILP study plans expires.
Meetings on the survey methodology were held on
9/20/2012 and 10/03/2012. Additional information on
the proposed survey methodology is included in the
draft RSP, in the attachment of the Regional Economic
Evaluation Study
Regional Economic Evaluation Study (Section 15.5)
Memo 8/07/2012 Unspecified NPS Page 263 – Indicates that PSP for Socioeconomics
relies largely on results generated through Recreation
and Aesthetics Resources studies. Having not seen
survey instruments, protocol, NPS does not know how
socioeconomic data will be gleaned from those
surveys.
Study teams met with NPS and others on 9/20/2012
and 10/03/2012 to discuss survey instruments and
protocols. Additional information on the proposed
survey methodology is included in the revised study
plan in Section 15.5.4 and the attachment to the
Regional Economic Evaluation Study plan as well as in
the Recreation and Aesthetic Resources RSPs
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 124 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
(Section 12).
TWG meeting 8/08/2012 Various Variety of
Agencies,
Tribal Entities,
and Interested
Individuals
Review of study plans submitted in July 2012. 1) NPS
and other requested more information on the type of
people to be interviewed for the socioeconomic
studies and the type of questions to be asked. 2) NPS
and others requested draft study instruments for
review.
1) Information on the type of people/groups to be
interviewed and typical questions to be asked have
been incorporated into the attachment of the Regional
Economic Evaluation Study lan.
2) Draft survey instruments are still in development.
Example survey instruments are included in the
attachment to the Regional Economic Evaluation Study
plan.
Social Conditions and Public Goods and Services Study (Section 15.6)
TWG meeting 9/20/2012 Cassie
Thomas
NPS It is important to include different planning scenarios
and future management regimes.
It is anticipated that the With Project and the Without
Project alternatives will have different scenarios and
likely different management regimes for at least some
resources. Interviews will be held with agency and
other personnel to develop the appropriate scenarios
and potential management regimes.
Email 11/5/2012 Wanetta
Ayers
DCCED-DED In addition to data and information supplied by the
Division on new opportunities that might come about
as a result of the project, several comments were
identified including: Study plans for other large
hydroelectric projects should be reviewed to ensure
that all topics are addressed; impacts should be
discussed in terms of their short-term and long-term
effects as well as direct and indirect effects; further
attention should be given to lost opportunity and
economic values; and better conceptualization and
organization of the socioeconomic impacts was
recommended.
Citations for three socioeconomic study plans that
were reviewed for this work were added to each study
plan.
Language was added to the Socioeconomic Conditions
and Public Goods and Services study plan to indicate
that short-term and long-term effects will be discussed
in the analysis, and indicating that direct and indirect
effects will also be identified and discussed in the
analysis.
The Without Project alternative will provide the basis
for the value of existing and anticipated activities and
services, including environmental and ecosystem
goods and services that would be lost with construction
and operation of the Project. As noted in the study
plan, the difference between the With Project and
Without Project alternatives will enable us to assess
the effects, both positive and negative.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 125 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
The purpose of a study plan is to identify the methods,
data and data sources to be used in preparing the
FERC documents. The study plan guidance does not
require that all of the impacts be identified but we do
note that the organizational structure recommended
will be useful in preparing the Socioeconomic
Conditions and Public Goods and Services report.
Transportation Resources Study (Section 15.7)
Letter 8/01/2012 John (Jack)
DiMarchi
Citizen DOT transportation access study: South Road and
Hurricane alternatives – Landowners along railroad
corridor, particularly between Gold Creek and
Hurricane, stand to be disproportionately affected by 2
access roads under consideration. Although these
landowners are not formally organized, they do
represent a “community” that may be affected
disproportionately (especially by proposed access
roads from Hurricane and/or Gold Creek), compared
to population at-large.
There are three access road corridors under
consideration but at this point AEA is only proposing
that one access road be developed. It is our plan to
evaluate effects on residents and land owners in the
areas that could be directly or indirectly affected by
development of a Project access road.
The methodology for the Transportation Resources
Study (Section 15.7.4.3) acknowledges that we will
need to interview licensing participant organizations
and knowledgeable individuals about current
transportation use as part of the data collection
process. This will facilitate the evaluation of potential
impacts of the Project on existing transportation
resources and uses.
TWG meeting 8/08/2012 Various Variety of
Agencies,
Alaska Native
Entities, and
Interested
Individuals
Review of study plans submitted in July 2012. NPS
emphasized the need to get information on the use of
the river as a transportation corridor.
The Transportation Resources Study plan (Section
15.7.4.3) addresses how information on river use for
transportation will be obtained. Existing published
information by various land management agencies,
access information gathered as part of other survey
efforts (such as Recreation and Aesthetic Resources
and Subsistence Resources), and interviews with
knowledgeable people as discussed above – will all be
used to document river use for transportation.
TWG meeting 9/20/2012 Becky Long Coalition for
Susitna Dam
Alternatives
How will you get information on river transportation
uses?
The Transportation Resources Study plan (Section
15.7.4.3) addresses how information on river use for
transportation will be obtained as discussed above.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 126 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
Health Impact Assessment Study (Section 15.8)
TWG meeting 8/08/2012 Variety of
Agencies,
Tribal Entities,
and Interested
Individuals
Review of study plans submitted in July 2012.
Chickaloon Tribe asked if HIA would be a Rapid HIA
or a Comprehensive HIA (CHIA) and how information
on subsistence use would be gathered.
The HIA Study Plan (Section 15.8.1.1) clarifies that the
HIA will be comprehensive and addresses how
information will be gathered.
Letter 9/14/2012 Lisa Wade,
Director
Chickaloon
Village Health
& Social
Services
Stress importance of engaging community as early as
possible, and keeping CHIA process as transparent
as possible, throughout the process. Includes
engaging community to contribute to, guide potential
impact analysis, data gaps, developing and proposing
mitigation strategies.
The HIA study (see Section 15.8.3) will rely on
community input and best practices for HIA to develop
a set of clear criteria which will help identify potentially
affected communities (PACs) in a systematic way and
facilitate the development of zones of impact for the
Project. Local communities may provide additional
criteria for consideration through written comments or
consultation.
Letter 9/14/2012 Lisa Wade,
Director
Chickaloon
Village Health
& Social
Services
Area regarding Tribal engagement process to allow
for provision and recognition of traditional knowledge
as complementary to existing baseline health and
other scientific info, needs to be strengthened. Tribal
people hold history, knowledge of area; must be some
mechanism made for acknowledging how this info will
contribute to legitimacy of HIA Study Plan and data
collection. Will ultimately strengthen this CHIA.
The HECs are fully described in the “Technical
Guidance for HIA in AK”, but there may be community
level health concerns that are expressed holistically
and do not fit this analytic structure. Section 15.8.4. 1
outlines how the study will coordinate with other social
sciences study areas including the Traditional
Knowledge interviews being done under the
Subsistence Resources Study.
Letter 9/14/2012 Lisa Wade,
Director
Chickaloon
Village Health
& Social
Services
13.8.1.1. Study Goals & Objectives – Recommend
revising “The goals and objectives of the HIA include
the following” section to add engagement piece. Add
bullet point reading: “Engage the community in a
transparent process of identifying community health
concerns for evaluation.”
The HIA study plan, in Section 15.8.1.1 of the draft
RSP, acknowledges that through scoping meetings
and community engagement planning, AEA will seek to
identify public issues and concerns about how
community health might be affected during
construction and operation of the Project.
Letter 9/14/2012 Lisa Wade,
Director
Chickaloon
Village Health
& Social
Services
13.8.1.1. Study Goals & Objectives – In recognition of
federally recognized Tribal governments in potentially
affected areas, revise bullet point #2 to read: “Collect
baseline health data at the state, borough or census
area, tribal, and potentially affected community, as
possible.”
Section 15.8.1.1 of the draft RSP has been revised to
read: “Collect baseline health data at the state level,
borough or census area level, tribal level, and at the
level of the potentially affected community.”
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 127 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
Letter 9/14/2012 Lisa Wade,
Director
Chickaloon
Village Health
& Social
Services
13.8.1.1. Study Goals & Objectives – Question bullet
point #3. Once data gaps are IDed, how will this
trigger additional studies? Or, will there be weighting
of data gaps to determine which are priorities for
further review? Can this be addressed in this section?
Section 15.8.1.1 of the draft RSP has been updated to
describe how AEA will attempt to identify gaps and
determine the most efficient method to fill those gaps,
through community consultation and coordination with
other field studies such as subsistence, social and
demographic studies.
Letter 9/14/2012 Lisa Wade,
Director
Chickaloon
Village Health
& Social
Services
13.8.1.1. Study Goals & Objectives – Revise bullet
point #4 to read: “Evaluate the baseline data against
the Project description to determine the magnitude of
potential impacts, both positive and negative.”
Section 15.8.1.1 of the draft RSP explains that the HIA
will use methods and guidelines in the Alaska
Department of Health and Human Services (DHSS)
“Technical Guidance for HIA in Alaska” July 2011.
Letter 9/14/2012 Lisa Wade,
Director
Chickaloon
Village Health
& Social
Services
13.8.1.1. Study Goals & Objectives – Strongly believe
a projective component for potential impacts and
applied mitigation strategies should be attempted in
CHIA.
As noted in Section 15.8.4.3 of the draft RSP, the
information developed in this study may be used to
prepare a Health Management Plan (HMP) which may
include:
Traditional Knowledge, perspectives, and activities that
may represent uniquely tribal approaches to human
wellness.
Letter 9/14/2012 Lisa Wade,
Director
Chickaloon
Village Health
& Social
Services
13.8.2. Existing Info & Need for Add’l. Info – Feel
strongly that traditional knowledge should be gathered
through qualitative discussions within Tribal
communities to contribute to completion of HIA. Info
should be given same weighting as other scientific
info gathered.
Section 15.8.3 of the draft RSP has been updated to
describe that the study will rely on community input
and best practices for HIA to develop a set of clear
criteria which will help identify PACs in a systematic
way and facilitate the development of zones of impact
for the project.
Letter 9/14/2012 Lisa Wade,
Director
Chickaloon
Village Health
& Social
Services
13.8.2. Existing Info & Need for Add’l. Info – Data
gaps should not just be noted, but should attempt to
be adequately addressed in further studies to be
determined by community.
Section 15.8.1.1 of the draft RSP describes how we
will identify gaps and determine the most efficient
method to fill those gaps, through community
consultation and coordination with other field studies
such as subsistence, social and demographic studies.
Letter 9/14/2012 Lisa Wade,
Director
Chickaloon
Village Health
& Social
Services
13.8.3. Study Area – Tribal communities should have
opportunities to: weigh-in on impact areas; in defining
study area; in defining key subsistence resources
rather than simply relying on ADF&G or USFWS as
only viable source of info for CHIA.
Section 15.8.3 of the draft RSP has been updated to
describe that local communities may provide additional
criteria or considerations through written comments or
consultations.
Letter 9/14/2012 Lisa Wade,
Director
Chickaloon
Village Health
13.8.4.1. – Community should have opportunity to ID
the “Issues Summary.”
Section 15.8.4 of the draft RSP has been updated to
confirm that AEA intends to coordinate through
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 128 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
& Social
Services
community engagement other social study areas, and
through AEA licensing participant engagement
programs to ensure there will be enough information to
meet Health Impact Assessment Study needs.
Letter 9/14/2012 Lisa Wade,
Director
Chickaloon
Village Health
& Social
Services
13.8.4.1. – Comprehensive discussion pertaining to
Social Determinants of Health (SDH) should occur to
ID disparities affecting various community groups, and
potential to project future impacts, both positive and
negative.
Section 15.8.4.3 of the draft RSP outlines how AEA will
undertake detailed consideration of impacts to Alaska
Natives through the presentation of tribal health data
and inclusion of the results of tribal health
consultations in the HIA.
Letter 9/14/2012 Lisa Wade,
Director
Chickaloon
Village Health
& Social
Services
13.8.4.1. – Many local indigenous cultures pass down
info orally. Traditional knowledge regarding past,
present concerns related to similar development
projects should be acknowledged as valid in
addressing “Casual links between the proposed
project and the anticipated health impacts.” There
must be consideration in CHIA for undocumented, yet
authentic experiences conveyed orally.
Section 15.8.4.3 of the RSP outlines how AEA will
undertake detailed consideration of impacts to Alaska
Natives through the presentation of tribal health data
and inclusion of the results of tribal health
consultations in the HIA. The Traditional Knowledge
interviews in the Subsistence Resource Study will also
likely help AEA identify more information that could be
of use in the HIA.
Letter 9/14/2012 Lisa Wade,
Director
Chickaloon
Village Health
& Social
Services
13.8.4.2. Phase 2: Baseline Data Collection –
Clearer definition for study of subsistence issues and
“reasonably close proximity” needed. Project will
likely impact salmon and displace moose habitat
significantly; therefore, definition will need to be
discussed w/ scientific experts, local Tribal experts.
Section 15.8.4.2 of the draft RSP notes that the HIA
Team will coordinate with communities and the
Subsistence Resources Study team to address how
subsistence issues interact with the proposed project
locations, size, linear features, and potentially affected
communities.
Letter 9/14/2012 Lisa Wade,
Director
Chickaloon
Village Health
& Social
Services
13.8.4.3. Phase 3: Impact Assessment – Suggest
adding / revising following bullet point to include “An
in-depth review of available state, regional, tribal, and
local health data.”
Section 15.8.4.3 of the draft RSP has been updated to
include accommodation for an in-depth review of
available state, regional, tribal, and local health data.
Letter 9/14/2012 Lisa Wade,
Director
Chickaloon
Village Health
& Social
Services
13.8.4.3. Phase 3: Impact Assessment – Suggest
special emphasis be performed for impacts to tribal
peoples; especially in relation to social determinants
of health and subsistence impacts.
Section 15.8.4.3 of the draft RSP describes how AEA
will access information from existing State disease-
control programs and strategies to address information
regarding background and conditions regarding social
determinants (e.g. HIV/AIDS, hypertension, diabetes,
substance abuse, etc.).
Letter 9/14/2012 Lisa Wade,
Director
Chickaloon
Village Health
13.8.4.3. Phase 3: Impact Assessment – Holistic
approach to looking at health will help w/ development
The Traditional Knowledge interviews and studies
outlined in the Subsistence Resources Study plan
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 129 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
& Social
Services
of more effective Health Mgmt. Plan; however, if CHIA
finds no place for Traditional Knowledge, a HMP could
be one more document which compartmentalizes
health in a way that is not helpful or applicable to local
Tribal peoples.
(Section 14.5) describe how Traditional Knowledge
information will be gathered and analyzed. Section
15.8.4.3 of the draft RSP describes how Traditional
Knowledge, perspectives, and activities that may
represent uniquely tribal approaches to human
wellness will be assessed.
Letter 9/14/2012 Lisa Wade,
Director
Chickaloon
Village Health
& Social
Services
13.8.5. Consistency w/ Generally Accepted Scientific
Practices – Stress importance of traditional
knowledge, and how CHIA should make a place for
this type of evidence-based knowledge.
Section 15.8.4.3 of the RSP describes how traditional
knowledge (gathered both in HIA and Subsistence
Resources studies), provides information and
perspectives that may represent uniquely tribal
approaches to human wellness.
Letter 9/14/2012 Lisa Wade,
Director
Chickaloon
Village Health
& Social
Services
13.8.6. Schedule – Not enough time allocated on
front end to help w/ development of Project Overview
and Issues Summary. Section is integral to getting
community buy-in on the CHIA. If work is not done on
the front end, it will not have credibility on the back
end. Not enough to do this during Baseline Data
Collection process. CHIA calls for more of a
community-based participatory research approach.
The community, whenever possible, should be
included to have ownership over contributing to the
document.
Section 15.8.4.2 of the RSP has been updated to
describe that in addition to community engagement
discussions, the HIA team will visit relevant
communities during the field studies phase of the
baseline data collection to document community food
sources and make observations on critical community
services, such as water, sanitation, and health care
facilities.
Letter 9/14/2012 Lisa Wade,
Director
Chickaloon
Village Health
& Social
Services
This only constitutes commentary on sections 13.8.
Have made several recommendations that will
strengthen CHIA process. Have similar concerns
pertaining to other parts of Section 13. Would like
additional time to review these sections, as they all
have direct impact on Tribal citizens.
Comments noted and AEA expects to continue to
engage Chickaloon Village and other interested parties
during the final study plan process and during
implementation of studies and eventual development of
AEA’s License Application for the Susitna-Watana
Hydroelectric Project.
Air Quality Study (Section 15.9)
Email 10/30/2012 Herman Wong EPA It was not specifically stated that the project proponent
would model the construction emissions. The
emissions should be modeled.
Construction emissions would be estimated based on
the equipment used for construction and construction
traffic as discussed in Section 15.9.4.2. Construction
emissions are expected to be temporary and not result
in a substantial increase in emissions, therefore,
modeling is not proposed for this task.
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 130 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
Email 10/30/2012 Herman Wong EPA There was no mention of any type of combustion
sources during operation of the hydro plant. It should
be verified.
It is assumed that there will not be major combustion
sources during operation.
Email 10/30/2012 Herman Wong EPA There is uncertainty if background air quality
monitoring should be performed. Someone should
decide particularly if EPA signs off on the plan.
AEA does not believe there is a need to conduct
background air quality monitoring at the site as there
are no major emission sources in the area. The
existing conditions will be assessed as discussed in
Section 15.9.4.1.
Email 10/30/2012 Herman Wong EPA It was not clear if the project proponents intends to
model for air quality benefits (i.e., emissions from
nearby units that the hydro plant would replace).
Analysis of potential air quality benefits from emission
reductions at other power plants is included in the
study as discussed in Section 15.9.4.4. Modeling
using EPA dispersion model is not proposed for this
task.
SECTION 16 PROJECT SAFETY
General
TWG Meeting 8/08/2012 Kim Nguyen FERC Contact Doug Johnson in Portland Regional Office to
inquire about comments on PMF and Seismic Study
Plans
Completed with call/meeting on August 29, 2012
between AEA, MWH and FERC PRO.
Meeting 8/20/2012 FERC Staff FERC FERC would like AEA to form Board of Consultants FERC has approved Board of Consultant team.
Probable Maximum Flood Study (Section 16.5)
Meeting 8/20/2012 FERC staff FERC PMF study plan should be reviewed by Board of
Consultants (BoC) – at least 2 members.
Meeting planned for November to go over reports; BoC
can start reviewing July PSP as soon as they have
contracts in place.
Meeting 8/20/2012 FERC staff FERC FERC noted the NOAA Atlas 14, Volume 7, Version
2.0, Alaska (2012) had become available this year
and should be considered in the revised study plan.
This new publication is for rainfall frequency only and
contains no information on the PMP. Also, the rainfall
frequency values are for point data (10 sq. mi.) and
there are no areal reduction factors in the new
publication, which means that the data cannot be
directly applied to the 5,180 sq. mi. Susitna-Watana
watershed.
Site-Specific Seismic Hazard Study (Section 16.6)
Meeting 8/20/2012 FERC staff FERC Seismic study plan should be reviewed by Board of Meeting planned for November to go over reports; BoC
Revised Study Plan
Susitna-Watana Hydroelectric Project Appendix 3 Alaska Energy Authority
FERC Project No. 14241 Page 131 December 2012
Comment
Format
Comment
Date
Licensing Participant
Name
Licensing Participant
Affiliation Comment or Study Request AEA’s Response
Consultants (BoC) – at least 2 members. can start reviewing July PSP as soon as they have
contracts in place.
Meeting 8/20/2012 FERC staff FERC A seismologist needs to review the study plan. MWH is having Norm Abrahamson review the Site-
Specific Seismic Hazard Study plan and provide
comments.
Meeting 8/20/2012 FERC staff FERC Incorporate and make use of “Recommendations for
Probabilistic Seismic Hazard Analysis: Guidance on
Uncertainty and Use of Experts” by Senior Seismic
Hazard Analysis Committee (SSHAC) in 1997.
Defined and incorporated in revised study plan.