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Susitna-Watana Hydroelectric Project Document
ARLIS Uniform Cover Page
Title:
Scoping document 2, Susitna-Watana Hydroelectric Project, FERC project
no. P-14241-000
SuWa 85
Author(s) – Personal:
Author(s) – Corporate:
Federal Energy Regulatory Commission
AEA-identified category, if specified:
Federal Energy Regulatory Commission (FERC) Documents
AEA-identified series, if specified:
Series (ARLIS-assigned report number):
Susitna-Watana Hydroelectric Project document number 85
Existing numbers on document:
Published by:
Washington, D.C. : Federal Energy Regulatory Commission,
Office of Energy Projects, Division of Hydropower Licensing,
[2012]
Date published:
July 2012
Published for:
Date or date range of report:
Volume and/or Part numbers:
Final or Draft status, as indicated:
Document type:
Pagination:
2, iii, 70 p.
Related work(s):
Scoping document 1, Susitna-Watana Hydroelectric Project,
FERC project no. P-14241-000 (SuWa 84)
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/
FEDERAL ENERGY REGULATORY COMMISSION
WASHINGTON, D.C. 20426
July 16, 2012
OFFICE OF ENERGY PROJECTS
Project No. 14241-000 – Alaska
Susitna-Watana Hydroelectric Project
Alaska Energy Authority
Subject: Scoping Document 2 for the Susitna-Watana Hydroelectric Project
To the Parties Addressed:
The Federal Energy Regulatory Commission (Commission) is conducting National
Environmental Policy Act (NEPA) scoping for Alaska Energy Authority’s (AEA)
proposed Susitna-Watana Hydroelectric Project FERC No. 14241-000. AEA filed its Pre-
Application Document (PAD) on December 29, 2011 and will use the Commission’s
Integrated Licensing Process (ILP) to develop its license application and prepare the
environmental record needed by the Commission and other federal agencies reviewing the
project. The proposed project would be located in the Matanuska-Susitna Borough on the
Susitna River at river mile 184 above the river mouth, approximately halfway between
Anchorage and Fairbanks, Alaska. The small, unincorporated Native village of Cantwell,
in the Denali Borough, is located about 45 air miles west of the proposed project dam,
while Anchorage is approximately 180 air miles generally south of the project area. The
project would occupy federal lands currently administered by the U.S. Bureau of Land
Management (BLM) but selected for potential acquisition by the State of Alaska under
the Alaska Statehood Act, state lands administered by the Alaska Department of Natural
Resources, and private lands owned by Alaska Native Corporations and others.
Pursuant to the National Environmental Policy Act (NEPA) of 1969, as amended,
Commission staff intends to prepare an environmental impact statement (EIS), which
would be used by the Commission to determine whether, and under what conditions, to
issue a license for the project. This scoping process will be used to support the
preparation of the EIS, ensure that all pertinent issues are identified and analyzed, and
ensure that the environmental document is thorough and balanced. We intend for this
scoping effort to also satisfy the NEPA scoping requirements of the following federal
agencies that have requested to be cooperating agencies under both NEPA and the
Council of Environmental Quality Regulations: the U.S. Department of Agriculture,
Rural Utilities Service; the Environmental Protection Agency (EPA); and the U.S Army
Corps of Engineers (Corps).
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In our February 28, 2012, Scoping Document 1 (SD1), we disclosed our
preliminary view of the scope of environmental issues associated with the Susitna-Watana
Project. Based on verbal comments that we received at the scoping meetings which were
held on March 26, 27, 28, and 29, 2012, near the proposed project, and written comments
we received throughout the scoping process, we prepared the enclosed Scoping
Document 2 (SD2). We appreciate the participation of government agencies, non-
government organizations, Alaska Native Tribes, and the general public in the scoping
process. The enclosed SD2 serves as a guide to the issues and alternatives to be
addressed in the EIS. Key changes from SD1 to SD2 are identified in bold and italicized
type.
SD2 is being distributed to the Commission’s official mailing list (see section 9.0
of the attached SD2). SD2 is also available from our Public Reference Room by calling
(202) 502-8371 and can be accessed online at:
http://elibrary.ferc.gov/idmws/search/fercgensearch.asp.
If you have any questions about SD2, the scoping process, or how Commission
staff will develop the EIS for this project, please contact David Turner at (202) 502-6091
or david.turner@ferc.gov. Additional information about the Commission’s licensing
process may be obtained from our website,http://www.ferc.gov.
Enclosure: Scoping Document 2
cc:Mailing List
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SCOPING DOCUMENT 2
SUSITNA-WATANA HYDROELECTRIC PROJECT
FERC PROJECT NO. P-14241-000
Federal Energy Regulatory Commission
Office of Energy Projects
Division of Hydropower Licensing
Washington, D.C.
July 2012
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TABLE OF CONTENTS
1.0 INTRODUCTION......................................................................................................1
2.0 SCOPING....................................................................................................................3
2.1 PURPOSES OF SCOPING...............................................................................................3
2.2 SCOPING COMMENTS .................................................................................................4
3.0 PROPOSED ACTION AND ALTERNATIVES...................................................37
3.1 NO-ACTION ALTERNATIVE.....................................................................................37
3.2 AEA’S PROPOSED ACTION ....................................................................................37
3.2.1 Project Facilities..............................................................................................37
3.2.2 Project Operation ............................................................................................38
3.2.3 Proposed Environmental Measures.................................................................39
3.3 ALTERNATIVES TO PROPOSED ACTION ..................................................................41
4.0 SCOPE OF CUMULATIVE EFFECTS AND SITE-SPECIFIC RESOURCE
ISSUES..............................................................................................................................41
4.1 CUMULATIVE EFFECTS...........................................................................................41
4.1.1 Resources that could be Cumulatively Affected.............................................41
4.1.2 Geographic Scope ...........................................................................................41
4.1.3 Temporal Scope ..............................................................................................42
4.2 PROJECT-SPECIFIC RESOURCE ISSUES....................................................................43
4.2.1 Geologic and Soils Resources.........................................................................43
4.2.2 Water Resources..............................................................................................44
4.2.3 Fisheries and Aquatic Resources ....................................................................44
4.2.4 Terrestrial Resources.......................................................................................46
4.2.5 Threatened and Endangered Species...............................................................47
4.2.6 Recreation Resources and Land Use...............................................................47
4.2.7 Aesthetics........................................................................................................48
4.2.8 Cultural Resources..........................................................................................48
4.2.9 Socioeconomic Resources...............................................................................49
4.2.10 Air Quality ...................................................................................................49
4.2.11 Developmental Resources............................................................................50
5.0 PROPOSED STUDIES..........................................................................................50
6.0 EIS PREPARATION SCHEDULE.........................................................................52
7.0 PROPOSED EIS OUTLINE....................................................................................53
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8.0 CONSISTENCY WITH COMPREHENSIVE PLANS.........................................55
9.0 MAILING LIST.........................................................................................................56
LIST OF APPENDICES
APPENDIXA PROCESS PLAN AND SCHEDULE ...................................................63
APPENDIXB ENTITIES THAT FILED WRITTEN COMMENTS.........................65
LIST OF FIGURES
FIGURE 1. SUSITNA-WATANA PROJECT AREA .................................................................2
LIST OF TABLES
TABLE 1. AEA’S INITIAL STUDY PROPOSALS FOR THE SUSITNA-WATANA
HYDROELECTRIC PROJECT .......................................................................................50
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1.0 INTRODUCTION
The Federal Energy Regulatory Commission (Commission or FERC), under the
authority of the Federal Power Act (FPA),1 may issue licenses for a term of up to 50 years
for the construction, operation, and maintenance of non-federal hydroelectric projects.
The Alaska Energy Authority (AEA) filed its Notice of Intent (NOI) and Pre-Application
Document (PAD) for the Susitna-Watana Hydroelectric Project P-14241-000, on
December 29, 2011, and will use the Commission’s Integrated Licensing Process (ILP) to
develop its license application.
The proposed project is located in the Matanuska-Susitna Borough on the Susitna
River at river mile 184 above the river mouth, approximately halfway between Anchorage
and Fairbanks, Alaska (Figure 1). The small, unincorporated Native village of Cantwell,
in the Denali Borough, is located about 45 air miles west of the proposed project dam,
while Anchorage is approximately 180 air miles generally south of the project area. The
project would occupy federal lands currently administered by the U.S. Bureau of Land
Management (BLM) but selected by the State of Alaska under the Alaska Statehood Act,
state lands administered by the Alaska Department of Natural Resources, and private
lands owned by Alaska Native Corporations and others.
The proposed project would consist of a 700- to 800-foot-high by about 2,700
foot-long, concrete gravity or rock-filled dam that would create an approximately
39-mile-long reservoir with a surface area of 20,000 acres and 2,400,000 acre-feet of
usable storage capacity. Optimization studies are ongoing, but the capacity of the project
is expected to be between 600 and 800 megawatts (MW) depending on results of future
updates to the Railbelt Integrated Resource Plan. An approximately 40- to 50-mile-long
road and transmission line corridor would be constructed along one of three alternative
routes (i.e., Chulitna, Gold Creek, or Denali). The project would be operated in a load-
following mode such that firm power is maximized during the critical winter months of
November through April to meet the Railbelt utility load requirements. The estimated
annual generation would be 2,500,000 gigawatt-hours (GWh). A detailed description of
the project is provided in section 3.0.
1 16 U.S.C. §§ 791(a)-825(r)(2006).
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Figure 1. Susitna-Watana Project Area
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The National Environmental Policy Act of 1969 (NEPA),2 the Commission’s
regulations, and other applicable laws require that we independently evaluate the
environmental effects of the proposed project and reasonable alternatives. Based on the
Commission staff's analysis of the issues, staff will prepare an environmental impact
statement (EIS) that describes and evaluates the probable effects, including an assessment
of the cumulative effects, if any, of the proposed action and alternatives. The EIS
preparation will be supported by this scoping process to ensure identification and analysis
of all pertinent issues.
The following federal agencies asked to be cooperating agencies under NEPA:
U.S. Department of Agriculture, Rural Utilities Service; Environmental Protection
Agency (EPA); and U.S. Army Corps of Engineers (Corps). Each agency will sign a
Memorandum of Understanding (MOU) with the Commission that defines how the
agencies will work together during the process. This enables all of the federal agencies
that need to authorize some part of the proposed project or to provide certain expertise to
work together under a single process.
2.0 SCOPING
Scoping Document 2 (SD2) is intended to advise all participants of the proposed
scope of the EIS based on the written and verbal comments received during the scoping
period. This document contains a brief description of: (1) the scoping process and
schedule for the development of the EIS; (2) the proposed action(s) and reasonable
alternatives identified to date; (3) preliminary identification of environmental issues and
proposed studies; (4) a proposed EIS outline; and (5) a preliminary list of comprehensive
plans that are applicable to the proposed project.
2.1 Purposes of Scoping
Scoping is the process used to identify issues, concerns, and opportunities for
enhancement or mitigation associated with a proposed action. According to NEPA, the
process should be conducted early in the planning stage of the project.
The purposes of the scoping process are as follows:
invite participation of federal, state and local resource agencies, Indian tribes,
non-governmental organizations (NGOs), and the public to identify significant
environmental and socioeconomic issues related to the proposed project;
2 42 U.S.C. §§ 4321-4335 (2006).
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determine the resource issues, depth of analysis, and significance of issues to
be addressed in the EIS;
identify how the project would or would not contribute to cumulative effects in
the project area;
identify reasonable alternatives to the proposed action that should be evaluated
in the EIS;
solicit, from participants, available information on the resources at issue,
including existing information and study needs; and
determine the resource areas and potential issues that do not require detailed
analysis during review of the project.
2.2 Scoping Comments
We issued Scoping Document 1 (SD1) on February 28, 2012, to enable resource
agencies, Alaska Native Tribes, and other interested parties to more effectively participate
in and contribute to the scoping process. In SD1, we requested clarification of
preliminary issues concerning the project and identification of any new issues that need to
be addressed in the EIS. We revised SD1 following the scoping meetings and after
reviewing comments filed during the scoping comment period. Scoping Document 2
(SD2) presents our current view of issues and alternatives to be considered in the EIS.
Additions to SD1 issues are shown in bold and italic type in this SD2.
We conducted seven scoping meetings for the Susitna-Watana Project on March
26, 27, 28, and 29, 2012, in Anchorage,3 Wasilla, Sunshine, Glenallen, Cantwell, and
Fairbanks, Alaska. Announcement of the scoping meetings was published in local
newspapers and in the Federal Register. Based on completed registration forms,
67 individuals attended the March 26 evening meeting in Anchorage, 51 individuals
attended the March 27 morning meeting in Anchorage, 32 individuals attended the
March 27 evening meeting in Wasilla, 102 individuals attended the March 28 evening
meeting in Sunshine, 23 individuals attended the March 28 evening meeting in Glenallen,
23 individuals attended the March 29 evening meeting in Cantwell, and 58 individuals
3 Two meetings were held in Anchorage. The first was on March 26, 2012 from
6:30 p.m. to 8:13 p.m., and the second was on March 27, 2012 from 9:00 a.m. to
1:40 p.m.
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attended the March 29 evening meeting in Fairbanks. A court reporter recorded the
scoping meetings.
In addition to the comments received at the scoping meetings, the Commission
received 169 comment letters from the general public, non-governmental organizations,
and state and federal agencies (Appendix B). Many individuals provided either oral or
written scoping comments, or both. All comments received are part of the Commission’s
official record for the project. Information in the official file is available for inspection
and reproduction at the Commission's Public Reference Room, located at 888 First Street,
N.E., Room 2A, Washington, DC 20426, or by calling (202) 502-8371. Information also
may be accessed through the Commission’s eLibrary system using the “Documents &
Filings” link on the Commission’s web page at http://www.ferc.gov. Call (202) 502-6652
for assistance.
A large number of the comments expressed strong concerns about or opposition to
the project, often referring to project effects on the natural beauty and wild character of
the river corridor; fish, wildlife and the river ecosystem; recreation and tourism; fishing
and hunting (including subsistence); public safety; the uses of Native Corporation lands;
and local population levels (e.g., Cantwell) and demands on public services. Some of the
comments received were highly supportive of the project and pointed to the need for
energy development in the Railbelt, and the benefits to local economies, including
potentially lower-cost electricity and the creation of new job opportunities. All of these
concerns fall within the scope of issues identified in SD1 and will be addressed as part of
the environmental analysis of the proposed project. Thus, they are not addressed further
in SD2. However, several issues were raised that were not specified in SD1 and we have
modified SD2 accordingly. We summarize below those comments where we did not
make the requested change or to address concerns raised about the licensing process
generally.
Comments and responses to these comments are discussed below by resource or
subject area.
LICENSING PROCESS
Comment: Many commenters (including those from the U.S. Department of
Commerce’s National Marine Fisheries Service, the U.S. Department of Interior’s Fish
and Wildlife Service, and the National Wildlife Federation) state that the ILP is not the
appropriate process to develop the license application for a large original project. Most
commenters stated that the ILP was developed for relicensing projects and not for
licensing large, original projects. Others assert that this is the first large hydroelectric
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dam proposed in the United States in a generation, and the first to use the ILP. Several
commenters believe that the ILP is not a good fit for a large, new, controversial project
because it forces the agencies, the public, and AEA to work too quickly, and that the
schedule is deadline-driven and overly restrictive, especially since numerous aspects of
the project are still undefined (e.g., dam height, transmission-line route, proposed
operations, etc.). Several commenters also state that agency concerns regarding the use of
the ILP for this project have not been addressed, and the only response from FERC and
AEA is that the ILP is the default licensing process and therefore AEA is allowed to use
the ILP to develop its license application.
Response: The Commission has three licensing processes available to
applicants. The traditional licensing process can be used where it is likely that the
application will have relatively few issues, little controversy, and can be expeditiously
processed. The alternative licensing process is available where an applicant chooses to
use it and there is support for its use. In this instance, AEA chose to use the ILP, which is
the default licensing process. Contrary to the commenters’ assertions that the ILP was not
designed to be used for original projects, in the Commission’s final rule adopting the ILP
as Part 5 of its regulations, the Commission specifically considered whether the ILP
should apply as the prefiling process for original license applications and found that it
should.4 Therefore, the ILP will be used to develop the license application.
It is not uncommon for various components of the project design to evolve during
application development, particularly in response to measures to avoid or minimize
adverse effects on environmental resources uncovered during studies. Where an
applicant’s project is not well defined or multiple alternatives are being considered, the
applicant is subject to potentially greater study needs. These factors would be common to
all licensing processes.
Comment: Multiple commenters state that the project appears to have a
pre-determined outcome, is on a fast-track for approval, and that FERC rarely, if ever,
denies hydropower licenses.
Response: The application process is designed to develop the record needed by
the Commission to provide a sound evidentiary basis on which the Commission staff and
other participants in the process can make recommendations, including whether it is in the
public interest to issue a license for the project. After weighing the information
4 Hydroelectric Licensing Under the Federal Power Act, Order No. 2002, FERC
Stats. & Regs. ¶ 31,150, at P 352 (2003).
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developed in the proceeding, the Commission has denied issuing a license for original
projects in several instances.5
Comment: Several commenters expressed concern about inadequate noticing of
the public scoping meetings. Several felt that the scoping meetings should have been
noticed using the local radio or any of the Railbelt media (e.g., pamphlets at rail stops,
facebook, etc.). One commenter questioned whether FERC is legally bound to publish
notice of public meetings. Another commenter stated that they were not given adequate
time in the public notification process.
Response: In accordance with the Commission’s regulations and longstanding
practices, we issued public notice of the scoping meeting in the Federal Register, in a
daily or weekly newspaper in the county or counties in which the project or any part
thereof is located, and by mail to entities on the Commission’s mailing list.6 Our
February 24, 2012 notice of the scoping meetings provided entities 60 days to file
comments (April 27, 2012). At the request of several agencies and with the support of
AEA, the due date was extended to May 31, 2012, providing an additional 34 days to
provide comments. Further, AEA’s pre-application document included estimated dates
for scoping, providing additional notification of likely dates when scoping would be
taking place. This should have provided entities with enough time to review and
comment on the project as proposed by AEA.
Comment: One citizen questions why there is not a citizens' advisory board
established for the project, and notes that FERC has used citizen advisory groups on other
licensing processes. She requests that we do so here.
Response: The ILP allows all interested entities to participate in the licensing
process, including various groups of citizens that may have formed to express a common
position or concern about a project. However, the Commission has not established a
“citizens advisory board” in other hydroelectric licensing proceedings. Perhaps, the
commenter is confusing the FERC licensing requirements with the efforts of AEA and the
Regulatory Commission of Alaska to use advisory groups to look at the railbelt energy
needs and the abilities of the Susitna Project to meet those needs.
5 These include Shelley Project No. 5090, Barberville Project No. 11213, Oxbow
Bend No. 6329, Grave Creek Project No. 7334, Upper Squaw Creek No. 7301, and Lake
Redding Project No. 2828.
6 18 C.F.R. § 5.8(e) (2012).
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Comment: One commenter recommends that the Commission use a commonly
accessible Decision Support System (a computer-based information system) to integrate
stakeholder interests.
Response: While such systems can be useful for compiling and keeping track of
myriad comments, it is not necessary, particularly where, as is the case here, most of the
comments are similar.
Comment: Multiple commenters request that FERC consider the value of a free-
flowing river as a factor in deciding whether to issue a license for the project, and note
that it is not possible to mitigate for the destruction of a natural and complex river
ecosystem.
Response: The no-action alternative, will serve as the basis for comparison of the
effects of all reasonable alternatives on the resources of the Susitna River, which in this
case is an unregulated river system. Future power demand and supply, alternative sources
of power, the public interest in preserving reaches of wild rivers and wilderness areas, the
preservation of anadromous fish for commercial and recreational purposes, and the
protection of wildlife are examples of the factors that will be considered in the public
interest finding of whether to license the project or not, and if so, under what conditions.
Comment: The Natural Heritage Institute, supported by various other NGOs (e.g.,
National Wildlife Federation, Coalition of Susitna Dam Alternatives (Coalition), Alaska
Survival, etc.,) argue that the Federal Power Act requires that FERC’s licensing decision
be in the public interest, having given equal consideration to power and non-power
values. The Natural Heritage Institute further argues that the domain of public interest to
be analyzed by FERC for the Susitna-Watana Project should consider Alaska’s Railbelt
region, the entire State of Alaska, and the entire United States. The Natural Heritage
Institute argues that equal consideration implies an equivalent level of information and
knowledge of the non-power values as for the value of power and other economic
benefits ascribed to the power production of the proposed project
The National Heritage Institute, the Coalition, Chickalon Village, and others also
state that the NEPA process must put a value on the ecosystem services of the Susitna
Basin, which it defines as the conditions and processes through which the natural
ecosystems and their species sustain and fulfill human life.
Response: Section 4(e) of the Federal Power Act requires the Commission to give
“equal consideration” to the purposes of energy conservation, the protection, mitigation
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of damages to, and enhancement of, fish and wildlife (including related spawning
grounds and habitat), the protection of recreational opportunities, and the preservation of
environmental quality.” “Equal consideration” is not the same as “equal treatment.
Nothing in the statute requires the Commission to place a dollar value on non-power
benefits, even if the Commission assigns a dollar value to the licensee's economic costs.
We do not dispute that the existence of a free-flowing, wild Susitna River that
supports salmon and other resources would have intrinsic value to Alaskans and others
nationally. We further recognize that various methods have been developed that attempt
to express existence values in dollars. However, in the context of public interest
balancing for long-term authorizations, it is not appropriate to rely too heavily on the
accuracy of current dollar estimates of non-power resource values, calculated using any
number of reasonably disputable assumptions and methods. This is particularly true if we
were to try to determine and weigh national values against the energy needs of Alaskans,
as the Natural Heritage Institute would have us do. Moreover, the public interest
balancing of environmental and economic impacts cannot be done with mathematical
precision, nor do we think our statutory obligation to weigh and balance all public interest
considerations is served by trying to reduce it to a mere mathematical exercise. Where
the dollar cost of measures can be reasonably 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. The methods for evaluating effects on ecosystem
services have not been determined and will be a subject of the study plan process.
STUDIES
Comment: Many commenters urged the Commission to take the time needed to
gather the data necessary to evaluate project effects on the various environmental
resources. Multiple commenters, including several agencies (e.g., National Marine
Fisheries Service, U.S. Fish and Wildlife Service) state that two years of environmental
studies is inadequate. Rather, they assert that six to eight years, the lifespan of a Chinook
salmon, is the minimum timeframe for conducting studies. Other commenters believe
that the licensing process should be shortened to no more than 4 years due to the historic
database of information from the 1980’s studies.
Response: Under the ILP, the Director of the Office of Energy Projects will
approve a study plan, which will consist of a compilation of various studies that must be
completed before the Commission will issue its notice that the application is ready for
environmental analysis and is proceeding with preparation of the EIS. The time needed to
complete the various studies will be study-specific, and will consider the availability of
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existing information. We expect a license applicant to file a complete license application.
Unlike a relicense of an existing project, as long as the applicant is making substantive
progress in developing the license application, there is latitude as to when an applicant
must file its license application.
Comment: One commenter requested that the public be allowed to participate in
the 2012 study plan process since the 2012 studies are not part of the formal FERC ILP
process.
Response: AEA voluntarily began developing studies that it would implement in
2012 before the Commission formally approves the project study plan. These 2012 study
planning efforts are not required by the ILP and the Commission cannot require AEA to
conduct these study planning processes in a particular manner. Nonetheless, AEA has
approached these study efforts in a collaborative manner and Commission staff and
several members of the general public have participated in many of the meetings.
Comment: The Coalition objects to AEA’s statement that it can conduct
environmental studies after the license application is filed, noting that this approach may
not be legal and would indicate that the project is being fast-tracked.
Response: See above response on the temporal scope of studies and development
of Commission-approved study plan.
Comment: Several commenters state that studies should be done by independent
agencies that do not have a vested interest in the project.
Response: The Commission can require an applicant to gather information to
support its application. However, the Commission cannot require an applicant to hire a
particular entity or require another agency to conduct a study.
Comment: The Knik Tribal Council states that it cannot support a project of this
magnitude without first having the opportunity to participate directly in determining the
extent of the project’s impact upon the tribe, and its lands and the resources on which it
depends. The Knik Tribal Council asks that it be directly involved in establishing the
scope of proposed studies and how the tribe can participate, both in gathering and
collecting the data and in developing the conclusions and findings on the implications to
the tribe.
Response: As noted above, the ILP provides a venue for all parties to be
consulted during the development of the license application, including identifying the
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information needed to address the effects of the project on Knik Tribal resources.
However, as also noted above, we can not require AEA to hire a particular entity or tribal
representative to gather the information.
Comment: The United Cook Inlet Drift Association would like to be included in
emails, focus groups, and discussions regarding the project, as well as contacted and
consulted by any party conducting fisheries studies or research.
Response: The ILP provides a venue for all entities to be consulted in the
preparation of the license application, starting now with the request for comments and
studies. AEA has also established a web page and email notification system for entities
interested in the project, which should facilitate the United Cook Inlet Drift Association’s
participation in the pre-filing process. Further, as explained in Section 6.0, we
recommend that all entities interested in this project register online on the Commission’s
web page to be notified of all filings and issuances by the Commission for this project.
PROJECT ALTERNATIVES AND NEED FOR POWER
Comment: Many commenters note that the state’s goal of generating 50 percent
of its energy needs is a laudable goal, but it is not a mandatory standard, and should not
be relied on as a basis for support for a project that raises significant environmental
concerns.
Response: The EIS will evaluate the regional need for power using the most
recent projections, which are currently those forecasted in the Alaska Railbelt Regional
Integrated Resource Plan. The scope of the need for power analysis encompasses such
factors as whether there is a regional need for power, displacement of non-renewable
fossil fuels, and diversification of generation mix.
Comment: Multiple commenters request that AEA conduct a comprehensive,
comparative cost-benefit analysis that will inform the public which energy source or
combination of sources will provide the required energy over the next 50 years and at
what cost. Several commenters stated that the State of Alaska has not fully considered
the financial effects or the best use of funds. They further state that FERC is in the
unique position of being able to advise the state on its need for creating a comprehensive
energy plan by requiring appropriate study and analysis of the State’s energy needs. A
full analysis of real costs must be detailed in the EIS, including state-funded subsidies and
their effect on energy rates.
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Response: The basic purpose of the Commission's economic analysis is to
provide a general estimate of the potential power benefits and costs of a project, and
reasonable alternatives to project power. This helps support an informed decision
concerning the scope of the public interest with respect to a proposed license. The EIS
will compare the current cost of project power to likely alternatives with no forecasts
concerning potential future inflation, escalation, or deflation beyond the license issuance
date. However, it is beyond the scope of the EIS to develop a comprehensive energy plan
for the State of Alaska.
The Commission’s regulations require AEA to provide a detailed statement of
project costs and financing with its application. This statement must include, in relevant
part: (1) the estimated annual value of project power based on a showing of the contract
price for the sale of power or the estimated average annual cost of obtaining an equivalent
amount of power from the least cost alternative source of power; (2) a description of other
electric energy alternatives, such as coal and nuclear-fueled power plants and other
conventional and hydroelectric plants; (3) an evaluation of the consequences of denial of
the license application and a brief perspective of the future use of the site if the proposed
project were not constructed; and (4) a description of the sources and extent of financing
and annual revenues available to the applicant to meet the identified costs. This
information will form much of the basis of the costs in the EIS.7 To the extent state or
federal subsidies would be relied on to finance the project, they should be identified in the
statement. However, this is often unknown at the time of filing and dependant on final
costs of construction.
We cannot factor into our public interest determination effects on retail rates when
financing for the project has not been obtained. Moreover, it is the responsibility of the
Regulatory Commission of Alaska (RCA) to ensure that the retail rates are just and
reasonable and we have no reason to think the RCA will not fulfill its responsibilities in
this regard.
Comment: Many commenters note that the project would only serve to meet
50 percent of the Railbelt’s energy needs and even less of its heating needs (by some
estimates 25 percent). Multiple commenters state that the Susitna dam would not
eliminate the need for natural gas in the Railbelt area; rather, it would reduce the use of
natural gas by only 25 percent. Consequently, natural gas alternatives and coal
alternatives should be pursued instead of the hydroelectric project. FERC must evaluate
the fact that the dam would not solve the Railbelt energy problems. FERC must also
7 See 18 C.F.R. § 4.41(e)(5)-(8) (2012).
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consider that the dam would likely encourage industries to locate to the area, thereby
increasing future power demand.
Response: As noted above, the EIS will evaluate the regional need for power.
Predicting energy needs for development that may result from the power produced by the
project would be too speculative to be of value to the decision making process and
beyond the scope of the EIS.
Comment: The Copper County Alliance noted that while the project would help
meet some of the Railbelt’s energy needs and provide some cost stability for the Railbelt
communities, it will not serve to meet the energy needs of the more rural, off-Railbelt
communities whose energy costs are already much higher than the Railbelt communities.
The Copper County Alliance recommends that the EIS take a broad look at alternatives,
especially small local projects that bring sustainable, affordable energy and jobs to rural
communities. They also recommend that the EIS look at the lost opportunity cost of
meeting these small community needs.
Response: As stated, the EIS will evaluate the regional need for power.
Determining how the state might use its funds to develop energy alternatives for rural
communities is speculative, outside of the Commission’s authority, and beyond the scope
of the EIS.8
Comment: Multiple commenters state that the project would not provide any
benefits for home heating, which is a primary need for the region, and therefore would
provide an extremely low return for the huge investment required for the project.
Reponse: We base our electrical energy projections on the regional need for
power. We will not speculate whether home owners will opt to use electricity versus
other energy sources for home heating.
We also note that project economics are only one of the public interest
considerations, and a finding of negative economic benefits does not preclude issuance of
a license. In analyzing public interest factors, the Commission takes into account the fact
8 We note, however, that AEA, through its authorities, is also considering how to
provide for rural communities’ energy needs. For example, through its Rural Power
Systems Upgrade Program, AEA is conducting an inventory of rural power system needs
throughout the state to prioritize system upgrades (See AEA’s Rural Power Systems
Upgrade Program at:
http://www.akenergyauthority.org/FactSheets/AEA_ProgramFS_RPSU.pdf.).
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that hydroelectric projects offer unique electric utility system operational benefits. These
benefits include their value as a source of power available to assist in quickly placing
fossil fuel-based generating stations back on line following a major utility system or
regional blackout, system-power-factor correction through condensing operations, and
almost instantaneous load-following response to dampen voltage instability on the
transmission system during highly dynamic peak load periods. The Commission also
takes into account the fact that proposed projects may provide substantial benefits not
directly related to utility operations that would be lost if a license were denied on solely
economic grounds. These may include creation of recreational benefits, flood control,
and local economic development. Moreover, the analysis makes no assumption that a
project which appears to cost more than currently available alternatives will always be so
situated.9
Comment:Multiple commenters state that, instead of spending $4.5 billion to
build the dam, AEA should look to energy efficiency and conservation, natural gas, tidal,
geothermal, wind, solar, and energy storage projects. The commenters contend that Cook
Inlet has enormous natural gas supplies and the state should subsidize gas development in
the Railbelt area instead of pursuing the Susitna-Watana Project.
Response: Conservation efforts appear to be part of the AEA’s ongoing plans10
and were considered in developing its Integrated Railbelt analysis. The EIS will evaluate
all reasonable alternatives to the proposed project that are reasonably foreseeable. In our
analysis of the proposed project and any alternatives, we will include any conservation
measures that we conclude could be achievable.
Comment: EPA states that the EIS should identify specific criteria that would be
used to: (1) develop a range of reasonable alternatives, (2) eliminate alternatives
considered, and (3) select the agency preferred alternative. The criteria should be based
on factors such as conservation of important aquatic and terrestrial habitats, maintaining
wildlife connectivity and fish passage, economics, public need, and pubic safety. The
9 See Duke Power Co., 72 FERC ¶ 61,030 (1995); Mead Corp., 72 FERC ¶ 61,027,
order on reh'g, 76 FERC ¶ 61,352 (1995).
10 See AEA’s Alternative Energy and Energy Efficiency Programs at:
http://www.akenergyauthority.org/FactSheets/AEA_ProgramFS_AEEEPrograms.pdf.
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alternatives criteria should also incorporate substantive issues identified during scoping
and agency and tribal consultation.
Response: As noted above, the Commission will consider all reasonable
alternatives. The Federal Power Act requires that the Commission give “equal
consideration” to the purposes of energy conservation, the protection, mitigation of
damages to, and enhancement of, fish and wildlife (including related spawning grounds
and habitat), the protection of recreational opportunities, and the preservation of
environmental quality. Consequently, the EIS will consider the above factors and will
explain any alternatives considered but eliminated from detailed analysis. However, it is
not necessary and, we believe, not prudent, to define specific criteria for defining
alternatives. Doing so could be either overly restrictive or so broad that it would not be
beneficial to the decision making process.
Comment: EPA expects that the range of alternatives considered in the EIS will
be at least as broad as those developed in the EIS for the original Susitna Project because
many of the alternatives evaluated in the previous EIS likely remain practicable today.
EPA, the Coalition, and others recommend that FERC evaluate other dam designs as well
as alternative energy projects to meet the future need identified by AEA. NMFS and
others recommend that the EIS consider the addition of a small re-regulating dam and
base load operations to reduce the effects of flow fluctuations from load-following
operations on downstream resources. Trout Unlimited also recommends that the EIS
analyze a range of alternative dam configurations and operations including alternative
flow conditions, fish passage provisions, run-of-river operation, ramping rate restrictions,
and the addition of a re-regulating reservoir. The Coalition states that the full range of
potential dam heights (i.e., 700-880 feet) and alternative energy sources should be
evaluated as alternatives to the proposed action in the EIS.
Response: The EIS will evaluate all reasonable, foreseeable alternatives to the
proposed project. Furthermore, our regulations require AEA to consider and conduct an
analysis of all environmental measures recommended by a resource agency, Indian tribe,
or member of the public, and explain its reasons for not adopting an environmental
measure based on project-specific information.11 At this time, we have no basis for
dismissing consideration of the re-regulating dam or base load operations as reasonable
alternatives to the proposed project design and would expect AEA to gather sufficient
information to address these measures in its application. Accordingly, the EIS will
evaluate all project alternatives, including proposed and recommended environmental
measures that are reasonable in the circumstances of the case.
11 See 18 C.F.R. § 5.18(b)(5) (2012).
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Comment: Several commenters would like a study of other transmission line
routes from the project to the Copper Valley, Delta Junction, and Glennallen. The Cook
Inlet Region, Inc. (CIRI) recommends the project include two separate, non-northerly,
transmission corridors to ensure safety and reliability.
Response: The EIS will evaluate the environmental effects and costs of the three
transmission line routes proposed by AEA. Adjustments to transmission line routes often
rise during the development of an application and the EIS will consider any other
reasonable alternative routes to serve as the project’s primary transmission line in these
circumstances. However, it is a long standing policy of the Commission not to require a
specific allocation of power from licensed projects to specific entities in the absence of a
statutory directive to do so. Thus the EIS will not consider alternative transmission line
routes that may be recommended by other entities to serve that end.
Comment: Multiple commenters question the appropriateness of using roller
compacted concrete (RCC) to construct a dam in an extremely cold environment in
northern latitudes. Additionally, they question whether RCC has ever been successfully
used in similar climates with a similarly sized dam.
Response: It is important whether placing conventional concrete or roller
compacted concrete that proper construction procedures are followed to address the affect
of extreme temperatures. The Commission’s regulations require that AEA file a
supporting design report that demonstrates that its proposed structures are safe and
adequate to fulfill their stated functions.12
Comment: One commenter requests consideration of the source of the aggregate
and limestone needed for dam construction. Another asked whether extraction activities
associated with the project would result in massive holes and a disturbed environment.
Response: AEA’s application must describe its sources for aggregate and
limestone. The EIS will assess the effects of developing and processing these materials if
they occur on-site and not from an existing, permitted source.
Comment: EPA states that, to support the purpose and need statement, the EIS
should discuss the proposed project in the context of the larger energy market, including
12 See 18 C.F.R. § 4.41(g)(3) (2012).
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identification of existing utilities and sources, and clearly describe how the need for the
proposed action has been determined.
Response: Consistent with the NEPA regulations,13 the purpose and need
statement in the EIS will briefly specify the underlying purpose and need to which the
Commission is responding in proposing alternatives to the proposed action, which is the
licensing of a proposed hydroelectric project. Refer to the responses above for further
discussion of the need for power and development of alternatives.
Comment: CIRI states that the Commission should examine the extent to which
future state energy needs may be met by alternatives to the project. CIRI asserts that
ratepayers benefit when utilities pursue multiple resource supply options, including long-
term power purchase agreements with least-cost independent power producers. Thus, the
Commission’s NEPA analysis should engage in a very hard look at the extent to which
this project will commercially exclude or preclude independent power producers from
competing in the same market because the project is subsidized by the state.
Response: As noted above, the EIS will evaluate the regional need for power.
However, it is beyond the scope of the EIS to develop a state energy plan.
CUMULATIVE EFFECTS
Comment: The Coalition and one other commenter state that the following
actions should be included in the cumulative effects analysis for cultural, subsistence,
recreational, aesthetic, and wildlife resources: (1) military flight expansion in the Fox 3
MOA as described in the Joint Pacific Alaska Range Complex EIS; (2) mineral
exploration and potential production by the Pure Nickel’s Man Alaska Project on
240 square miles of state lands called the Denali Block and on U.S. Bureau of Land
Management lands; (3) scenic air tours and landings on two glaciers located north of the
project area near Mt. Deborah; and (4) project effects on the Nelchina Public Use Area,
currently managed under the 2012 Susitna Matanuska Area Plan.
Response: The direct and indirect effects of the project on the Nelchina Public
Use Area will be assessed in the resource specific sections of the EIS and will also be
considered in the cumulative effects analysis.
13 40 C.F.R. § 1502.13 (2012).
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Comment: NMFS recommends that glacial wasting and climate change be added
to the cumulative effects analysis because it is reasonably foreseeable that resources could
be cumulatively affected by hydropower operations and changes in timing and availability
of water. Many comments were received from the public and NGOs also stating that
climate change is undeniably occurring in northern latitudes and must be considered in
the assessment of the project and incorporated in all prefiling study plans. In addition,
many commenters state that the effects of climate change on glacial melt, snow pack,
precipitation, and sediment load should be studied because it is necessary to understand
how the cumulative effects of the dam and climate change will affect flows and sediment
transport and fish and wildlife resources throughout the Susitna River.
Response: We are not aware of any way to accurately predict the effects of
climate change on changes in glacial wasting and on the timing and availability of water
in the Susitna River Basin, on a basin-specific scale given the current state of the science.
It is common practice for the Commission to evaluate a range of flow release alternatives
that take into consideration both high and low water years and to condition any license
that may be issued to adaptively manage for these variations in water years.
Comment: Trout Unlimited states that project-related developments (roads,
transmission lines, airport) will significantly increase the likelihood of additional future
development in the project area. These factors should be considered as part of the
cumulative effects analysis.
Response: The EIS will consider population growth and access-related effects of
the proposed project facilities where such effects can be reasonably foreseen. Trout
Unlimited does not specify any specific developmental actions that are reasonably
foreseeable and dependant on future project road, transmission line, or airport
construction in the project area. In the event that Trout Unlimited or others become
aware of any reasonably foreseeable actions that are contingent on construction of project
facilities, we would consider the need to expand our cumulative effects analysis at that
time.
Comment: CIRI asserts that regardless of FERC’s limited jurisdiction over
transmission issues beyond the point of the project’s interconnection to the grid, the
Commission must evaluate the need for reasonably foreseeable future transmission lines
and upgrades necessitated by the project as “cumulative impacts” in its NEPA analysis.
Response: As part of any hydroelectric project, the primary transmission line for
that project ends at the point of interconnection to the grid or the distribution system.
Also, any future transmission lines and upgrades to this primary line must end at the point
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of interconnection to the grid. Therefore, our NEPA analysis does not need to include
cumulative impacts by the project’s transmission line beyond the point of interconnection.
Comment: CIRI asserts that the Commission’s cumulative effects analysis must
look beyond the 30- to 50-year time frame posed in the scoping document because
construction of the dam and its effects would extend beyond the initial license term.
Response: While it is true that if the Commission finds it in the public interest to
authorize the construction and operation of the project, the project may have a life-span
greater than the term of the license, which is statutorily limited to 50 years. However, the
projected effects beyond that time frame become too speculative to be of value in the
decision whether to license the project.
GEOLOGY, SEISMICITY, AND DAM FAILURE
Comment: Multiple commenters expressed concern with the proposed location of
the dam relative to major earthquake faults, notably the Broad Pass Fault and the Denali
Fault, and that a 7.9 earthquake has occurred on the Denali Fault. Several members of the
public questioned how the Commission and AEA could consider developing a project in
an active fault area. Commenters would like AEA to study seismic activities in the faults
within the project area.
Response: The EIS will examine site geologic conditions and seismology.
Additionally, the Commission’s regulations require that AEA file a supporting design
report that demonstrates that proposed structures are safe and adequate to fulfill their
stated functions.14 A comprehensive review will be undertaken of all loading conditions,
including seismic loadings, by an independent consultant hired by the applicant and will
be overseen by the Commission's Division of Dam Safety and Inspections. The review
will insure the proposed dam is designed to safely pass all credible loading conditions,
including ground motions up to the Maximum Credible Earthquake. In addition to the
Commission’s review of project’s design, an independent Board of Consultants will be
required to perform a peer review. As has been conducted on other dams of similar
magnitude, the Board of Consultants will be composed of world renowned experts in dam
design and construction and they will review the dam design as well as the plans and
specifications for construction of the dam. The Commission will not allow AEA to start
construction until we are satisfied the dam meets our Engineering Guidelines, including
the seismic guidelines, which can be found on the Commission’s web page at:
14 See 18 C.F.R. §4.41(g)(3) (2012).
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http://www.ferc.gov/industries/hydropower/safety/guidelines/eng-guide/chap13-draft.asp
Comment: Many members of the public also expressed concern about their safety
following a dam failure and the resulting flood. Several requested a map and analysis
outlining the areas that would be flooded, and to what depth, as well as projected fatalities
and economic damage in a variety of scenarios, including total dam failure. One also
requested a plan for a warning system in the event of a dam failure.
Response: Public safety at licensed projects is of the upmost importance to the
Commission. As noted above, the Commission’s regulations require AEA to develop
sufficient information to support the design of the project. AEA will be required to
design the dam to withstand normal, seismic, and flood loading conditions with adequate
factors of safety.
Because of its size, this dam will likely be considered as having a high hazard
potential in the event of a failure. Accordingly, AEA will be required to develop an
Emergency Action Plan in accordance with our guidelines, which can be found on the
Commission’s web page at:
http://www.ferc.gov/industries/hydropower/safety/guidelines/eng-guide/chap6.asp
The Emergency Action Plan will include inundation maps showing the expected
downstream areas that could be impacted from a dam failure and discuss procedures for
notifying emergency agencies and ensuring the downstream public is adequately warned.
The inundation maps are based on a dam break analysis which is typically performed after
a license is issued, once the final size and site conditions of the proposed dam are known.
The analysis will be conducted in coordination with, and reviewed by, the Commission's
Division of Dam Safety and Inspections and the Board of Consultants referenced above.
Emergency Action Plans must be filed with the Commission no later than 60 days prior to
the initial filling of the project reservoir.
Comment: Multiple commenters requested an analysis of what the increased risk
of the dam will cost downstream residents in terms of higher home insurance premiums,
and perhaps the necessity to buy flood insurance, including an evaluation of those that
were not previously in a floodplain, but may be after construction of the dam.
Response: An analysis of how the project may affect insurance premiums is
beyond the scope of the EIS because a variety of factors determine insurance premiums,
including the amount and type of coverage being purchased, what deductibles are desired,
location and flood zone, design and age of individual structures, elevation of structures,
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and individual issuance company risk assessments. We will examine how project
operations influence downstream river elevations. Further, the development of the
emergency action plan may further influence individual risk factors considered by the
Federal Emergency Management Agency, but this information will be dependant on final
design of the project.
Comment: One commenter questions who would pay for damages to residential
and community properties in the event of a dam failure, and how many residents would be
affected by a failure, especially considering the increase in population over the 100 year
lifespan of the project.
Response: Section 10(c) of the FPA states that each licensee shall be liable for all
damages to the property of others by the construction, maintenance, or operation of the
project works constructed under the license.15 As discussed above, AEA’s license
application must include dam design drawings and supporting design reports. Once the
license application is filed, Commission staff will perform a safety assessment and review
of the dam design before any license would be issued. Furthermore, also as noted above,
the Emergency Action Plan would need to consider potential downstream impacts as part
of the dam break analysis.
Comment: Dr. Jeff Benowitz would like the Commission to consider using
“thermochronology” to map active and non-active faults along the Susitna River corridor.
Response: The EIS will identify and discuss seismic conditions at the project.
The appropriate method for identifying and mapping active faults will be determined
through the ILP study plan development process and will consider various factors
including existing information, whether the proposed methods are consistent with
generally accepted practices in the scientific community, and cost.16
WATER RESOURCES
Comment: The Coalition says that the public has not seen the Alaska
Deptartment of Environmental Conservation’s (Alaska DEC’s) waiver of its authority to
issue Clean Water Act section 401 water quality certifications for hydropower projects in
Alaska. The Coalition questions whether FERC could issue a license for a hydropower
15 16 U.S.C. § 803 (2006).
16 See 18 C.F.R. § 5.19(b) (2012).
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project without a water quality certification from Alaska DEC. Moreover, the Coalition
questions whether water quality impacts and protection and mitigation measures would be
adequately addressed by FERC without Alaska DEC’s water quality certification.
Response: Under section 401(a)(1) of the Clean Water Act, the Commission may
not issue a license authorizing the construction or operation of a hydroelectric project
unless the state water quality certifying agency either has issued water quality
certification for the project or has waived certification. On August 10, 1999, Alaska DEC
filed a letter with the Secretary of the Commission indicating that it would waive its right
to issue water quality certifications under section 401 of the Clean Water Act for FERC
licenses for hydroelectric projects. The letter can be found on the Commission’s eLibrary
web page by conducting an advanced search on the date 08/10/1999 and entering “section
401” into the text search.
The Commission would need to evaluate the effects of the project on water quality
resources of affected waters as required by NEPA. Consideration of the effects of project
construction and operation on numerous water quality variables is already included in the
SD2.
Comment: The Center for Water Advocacy states that the absence of water rights
in the Statutory and Regulatory Requirements section of the EIS outline provided in the
scoping document suggests that the EIS will not include an analysis of the project’s
effects on federal and other water rights. This is contrary to the fact that project
operations will affect instream flows and, therefore, will potentially impact downstream
surface and ground water rights including those needed to protect native Alaskan health
and subsistence uses.
Response: The Center for Water Advocacy does not identify which statutes and
regulations should be included in the outline for the EIS. Section 27 of the FPA states
that nothing in Part I of the FPA “shall be construed as affecting or intending to affect or
in any way to interfere with the laws of the respective States relating to the control,
appropriation, use, or distribution of water used in irrigation or for municipal or other
uses, or any vested right acquired therein.”17 Should a license be issued to AEA,
Standard Article 5, which is included in all licenses, requires licensees to acquire all
rights necessary for operation and maintenance of a project within five years of the
license issuance. This includes necessary water rights. The project’s effects on instream
flows, groundwater, and subsistence users have already been identified as potential issues
in SD1.
17 16 U.S.C. § 821 (2006).
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FISHERIES RESOURCES
Comment: Many commenters would like studies of the project’s potential
impacts on salmon, steelhead, dolly varden, grayling, trout, and other fish in the Susitna
River above and below the dam.
Response: The Commission will make a determination on the scope of
environmental studies for affected fisheries resources during the ILP study planning
process.
Comment: The Coalition and Chickaloon Village state that the proposed project
may be in conflict with Alaska’s Sustainable Salmon Fisheries Policy as set forth in the
Alaska Administrative Code (5 AAC 39.222). Moreover, the Coalition contends that the
EIS must show how the project will comply with Alaska’s state laws and policies for
fisheries sustainability.
Response: The Federal Power Act does not require that the project comply with
every state and local law and policy for fisheries and environmental resource protection.
Rather, it requires that, in addition to power and developmental purposes for which
licenses are issued, the Commission give equal consideration to the purposes of energy
conservation; the protection of, mitigation of damage to, and enhancement of fish and
wildlife; the protection of recreational opportunities; and the preservation of other aspects
of environmental quality. The EIS will evaluate the project’s effects on environmental
resource issues identified in SD2, including anadromous fish populations of the Susitna
River Basin, and the Commission will determine the appropriate level of environmental
protection in any license issued for the project after consideration of all available
information in the project record.
Comment: The Coalition states that the EIS must list and consider the Cook Inlet
Regional Salmon Enhancement Planning Phase II Plan: 2006-2015, as implemented by
the Cook Inlet Regional Planning Team January 2007.
Response: The Commission is required to determine whether a project is
consistent with filed, qualifying comprehensive plans. The Cook Inlet Regional Salmon
Enhancement Planning Phase II Plan: 2006-2015, is not an approved comprehensive plan
filed under section 10(a)(2)(A) of the FPA. To be considered a comprehensive plan
under 10(a)(2)(A) of the FPA, the plan must be filed with the Commission with a request
that it be considered a comprehensive plan. If a document does not qualify as a
comprehensive plan, we will consider the document, as we consider all relevant studies
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and recommendations, in the public interest analysis pursuant to section 10(a)(1) of the
FPA.
Comment: EPA recommends analyzing ecological connectivity in the EIS.
Response: SD2 already includes a comprehensive list of environmental resources
that will be evaluated in the EIS, including an analysis of applicable fish and wildlife
species’ life histories, migrations, and habitats. Where appropriate, the EIS will evaluate
the potential project effects on disruptions to the specific life history needs, migrations,
and habitats of all affected fish and wildlife communities in the project area.
Comment: Trout Unlimited recommends that the EIS not only consider project
effects on water quantity and quality and effects on spawning and rearing habitats, but
also include a comprehensive evaluation of alternatives for restoring affected habitats in
the reaches above and below the project site.
Response: We do not evaluate the appropriateness of mitigation or restoration
measures at this time. An analysis of the need for, costs, and benefits of any
recommended environmental measures would be included in the NEPA document after
the specific recommendations (e.g., implementation of restoration measures) have been
filed with the Commission in response to the notice identifying AEA’s application as
Ready for Environmental Assessment (REA notice).
TERRESTRIAL RESOURCES
Comment: Because the proposed action involves a discharge of dredge or fill
material into waters of the U.S. and would require authorization from the Corps, the EPA
recommends that practicability as defined in the 404(b)(1) Guidelines (40 C.F.R. § 230)
be used as a screening criteria for all project components under all action alternatives that
may require a 404 permit.
Response: The Corps has requested to be a cooperating agency for the
preparation of the EIS. We intend for the EIS to serve our purposes as well as those of
the Corps. Consequently, we anticipate that the Corps will prepare any analysis needed to
be consistent with its authorization requirements.
Comment: The Knikatnu, Inc. would like the federal government and the state of
Alaska to bring forward one or more versions of the 49 different wildlife management
program models currently in use on private and/or reservation lands throughout the
nation, to be implemented on lands impacted by or subject to this project.
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Response: Based on consultation meetings with the Knikatnu on March 26, 2012,
we understand the Knikatnu Inc.’s comment to mean that as mitigation for project effects
on moose, it would like the state of Alaska and the Commission to consider providing
more active wildlife habitat management methods to any lands affected by the project or
proposed for mitigation as a means to increase moose populations—a species important to
the subsistence use of the Knikatnu and other Alaskan Natives. We do not evaluate the
appropriateness of mitigation or restoration measures at this time. An analysis of the
need, costs, and benefits of any recommended environmental measures would be included
in the EIS after the specific recommendations (e.g., implementation of restoration
measures) have been filed with the Commission in response to the REA notice.
Comment: The Denali Citizens Council recommends that the EIS consider
project effects on Denali National Park and Preserve wildlife.
Response: The Denali Citizens Council do not identify which species they are
concerned about. The EIS will assess project effects on those wildlife species that have
the potential to use the habitats affected by project construction and operation (e.g.,
occupied by the project facilities or affected by project operations). The Denali National
Park and Preserve is located about 45 miles east of the proposed project. Consequently,
only those species of wildlife that use both the park and areas affected by the project
would be assessed in the EIS. These would most likely be species with large home ranges
(e.g., wolves) or wide-ranging migration corridors (e.g., caribou).
Comment: Multiple commenters request an evaluation of the project’s effects on
the spread of invasive plants and noxious weeds and note that herbicides should not be
used and will not be tolerated by the public to control weed spread.
Response: The EIS will assess the potential for the project to introduce and
spread noxious weeds. We do not evaluate the appropriateness of mitigation measures at
this time. An analysis of the need, costs, and benefits of any recommended
environmental measures would be included in the EIS after the specific recommendations
(e.g., implementation of restoration measures) have been filed with the Commission in
response to the REA notice.
Comment: NMFS asserts that a mercury risk assessment is needed to determine
whether the proposed project may pose a significant risk to health and survival of
piscivorous wildlife in the reservoir area and downstream of the dam.
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Response: The Commission will make a determination on the scope of
environmental studies for affected wildlife resources during the ILP study planning
process.
RECREATION
Comment: The BLM commented on the need to evaluate the effects of a large
workforce on all recreation resources in the area, not just game resources as stated in
SD1. An individual commented that improved access and hydrologic changes in the
Devil’s Canyon area may result in more recreationists using the resource, which may
affect the recreational experience in general.
Response: SD2 has been revised to clarify that the EIS will assess the effects that
a large workforce and more recreationists in the project area may have on recreational
resources and experiences.
Comment: The EPA commented that the Commission should evaluate the
management of outdoor recreation vehicles (ORV) and snow machine use in order to
protect resources, including policing and enforcement. The BLM expressed similar
concerns with increased access to off-highway vehicles in areas such as transmission line
corridors and draw down areas of the reservoir.
Response: Existing and potential ORV and snow machine use will be addressed
in the environmental analysis, including potential measures to address adverse effects on
natural resources. However, the Commission cannot bestow on its licensees any authority
for enforcing laws.
Comment: Many commenters would like studies of impacts of the project on
recreation and land use including kayaking, rafting, canoeing, berry picking, and
subsistence hunting. The BLM commented that while the demand for future recreation in
the project area is unknown, there would likely be a need for scenic waysides, boater put-
in and take-out facilities (both river and reservoir), camping and picnicking facilities,
restrooms and access roads. The BLM also noted that improved winter access could
substantially change winter recreational use in the area. The Alaska DNR commented
that the upper Susitna River provides “an extensive remote rafting experience, with the
potential to access the Talkeetna River” through a series of portages and lake crossings.
They suggest that boating studies should extend upriver to the Denali Highway Bridge
and those effects on river use and existing portage opportunities need to be addressed.
An individual commented that recreation studies should also consider potential effects on
recreational cabins that are present in the project area and have been for generations.
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Response:The Commission will make a determination on the scope of
environmental studies for recreational resources during the ILP study planning process.
We modified SD2 to more clearly indicate that the EIS will consider how the project may
affect boating opportunities, including kayaking, rafting, and canoeing, and winter
recreation.
Comment: American Whitewater notes that the project will affect a segment of
the Susitna River currently listed as eligible for addition to the National Wild and Scenic
Rivers System, but that the Wild and Scenic suitability analysis has not been completed
and must be completed as part of the NEPA process. BLM similarly states that BLM
believes that the Recreation and Aesthetic Resource studies proposed by AEA, if
amended to incorporate recommendations from the National Park Service, will be
sufficient to complete the suitability analysis of the Susitna and Brushkana Creek—
Brushkana segments by either the BLM or FERC.
Response: To clarify, the Commission does not implement the Wild and Scenic
Rivers Act and does not make suitability determinations under the Act. We may
participate at least indirectly through the NEPA process, including the review of project
effects on recreation and aesthetic resources. The BLM would be responsible for making
suitability determinations..
AESTHETICS
Comment: Ahtna, Incorporated asked how noise from flights associated with the
project might affect subsistence activities.
Response: Project noise was included in SD1 as a potential effect on aesthetic
resources. The noise issue has been added to the cultural resources section of SD2.
LAND USE
Comment: Doyon, Limited stated that the project significantly affects Alaska
Native Claims Settlement Act (ANCSA) corporation lands. Doyon Limited also
expressed concern with the use of eminent domain and how that might affect lands owned
by Native corporations. Similarly, CIRI states that the EIS should consider how CIRI and
the village corporations would be affected by the inundation of lands that CIRI owns or
controls on behalf of itself and various Alaska Native village corporations; the purchase,
lease, or taking of these lands for materials, roads, and transmission rights-of-way; and
the unauthorized recreational and other uses that are likely to occur as an indirect or
cumulative effect of the project’s construction, operation, and maintenance.
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Similarly, Chickaloon Village Traditional Council noted that, in light of ongoing
court proceedings and land selections under ANCSA, future ownership of some lands in
the project area is unknown, which complicates land access and project development.
Ahtna recommends using land status data from BLM instead of DNR (from AEA) since
native corporations are getting final ANCSA conveyances.
Response: The EIS will consider the direct and indirect effects of project
construction and operation on existing land uses (e.g., trespass, subsistence, etc.). If a
license is issued to AEA to construct the project, AEA will have to acquire the necessary
rights to construct the project within 5 years of license issuance. How AEA may acquire
those rights to such lands is not subject to environmental review as part of NEPA.
Comment: Several Alaska native tribes and their associated corporations (e.g.,
Doyon Ltd, CIRI, and others) expressed concern about the increased public and
construction workforce access to and across native-owned lands provided by the access
roads and transmission line corridors. They expressed concern that such access would
result in the potential for illegal trespass, hunting, and building of structures on native-
owned lands, as well as potential vandalism, break-ins, or wildfires.
Response: The EIS will consider the potential for increased access. However, the
Commission has no authority to enforce trespass laws and cannot through its license
provide applicants with any such authority. However, we will consider potential
measures that AEA may implement to avoid or minimize such adverse effects.
Comment: Alaska Department of Natural Resources (Alaska DNR) comments
that public access in rural areas is provided by public easements and rights-of-way, RS
2477 trails, ANCSA 17b easements, navigable waters, and other means that exist outside
of the formal road network. Alaska DNR states that these access routes should be
identified where they exist in the project area and impacts on them should be minimized
and mitigated during planning, construction, operation, and maintenance of the project.
Response: We revised SD2 to more clearly indicate that the EIS will consider
how project construction and operation may affect these public access areas. The
Commission will make a determination on the scope of environmental studies for
recreational resources during the ILP study planning process.
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CULTURAL RESOURCES
Comment: The Center for Water Advocacy (Center) states that the scoping
document fails to include the need to consult with Native Alaskan Tribal Governments as
a measure to protect and enhance environmental resources of the project area. The Center
also states that such consultation is required by the Federal Trust Doctrine to protect the
interests of tribes in a manner above and beyond those of the general public. In addition,
the Center states that the EIS must discuss how FERC will work with Alaskan Native
tribal governments to ensure that the agency engages in proper consultation with affected
Native Alaskan Tribes and otherwise complies with its trust duty to protect subsistence
and other Native Alaskan interests in relation to the project.
The Ahtna and other native groups noted that they would like to be consulted
throughout the development of the project.
Response: The intent of the scoping document is to advise all participants as to
the proposed scope of the EIS and seek additional information pertinent to our analysis.
Commission staff has actively engaged Native Alaskan tribal governments in such
consultations since January 2012, involving approximately 45 Alaska Native villages,
tribes, and local and regional corporations. Such consultations with Alaska Native groups
are still taking place with Commission staff and will continue throughout the licensing
process. The EIS will consider the information obtained through these consultations and
will assess project effects on subsistence and other Native Alaskan interests.
Comment: The Talkeetna Airmen’s Association commented that their Village Air
Strip is listed on the National Register of Historic Places.
Response: Any cultural resources considered eligible or listed on the National
Register of Historic Places that may be affected by the project will be considered in the
EIS.
Comment: BLM recommends additional review of geologic maps and previously
described paleontological resources for the area; field inspections by a qualified
paleontologist/geologist in high probability areas or geologic formations likely to be
affected by dam construction or rendered inaccessible in the future by inundation; and
compliance with the Paleontological Resources Protection Act of 2009.
Response: SD2 has been revised to include paleontological resources. The
Commission will make a determination on the scope of environmental studies for affected
paleontological resources during the ILP study planning process.
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Comment: CIRI recommends that the EIS address potential effects on properties
of traditional religious and cultural importance to Indian tribes that may be determined to
be eligible for inclusion on the National Register of Historic Places, as well as those
which have already been determined to be eligible.
Response: Any cultural resources considered eligible or listed on the National
Register of Historic Places that may be affected by the project will be considered in the
EIS.
Comment: CIRI states that the Area of Potential Effects may be different for
different kinds of effects on historic properties and different types of historic properties
that may be eligible for inclusion on the National Register of Historic Places. Effects
may extend beyond the proposed project boundary and may include effects of recreation,
tourism, and other project-induced access to the project vicinity on properties listed on or
eligible for listing on the National Register of Historic Places.
Response: The Commission will make a determination on the scope of
environmental studies for cultural resources during the ILP study planning process. We
agree that the APE and the EIS need to consider both direct and indirect effects on
cultural resources. Indirect effects, such as noise and visual aspects of the project, may
extend beyond the proposed project boundary
Comment: BLM recommends that Table 1 of SD1 be revised to identify and
update information related to traditional cultural properties. BLM recommends that
anticipated concerns by federally recognized Tribes and Regional Alaska Native
Corporations regarding confidentiality over proprietary cultural information be addressed
to the maximum extent possible by FERC and AEA and its contractors through the use of
Confidentiality Agreements, including provisions to keep that information from public
venues of discussion.
Response: Table 1 has been updated to reflect AEA’s most current list of
proposed studies. A restricted distribution list could be established. Thus, any
confidential information gathered as part of AEA’s studies or provided in consultation
with the affected tribes could be filed with the Commission as non-public information and
would be distributed to only those particular stakeholders who have a right to see such
information, pursuant to section 106 of the National Historic Preservation Act.
Confidentiality agreements among the involved parties could also be developed if desired.
SUBSISTENCE
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Comment: Knikatnu, Inc. states that Knikatnu lands were conveyed under a
federal law which mandated they be selected for the subsistence needs of Knikatnu
shareholders. They described some of the economic challenges and subsistence issues
faced by rural communities in Alaska and asked that these issues be considered during the
review of the project proposal. Because the Ahtna Natives have a documented history of
hunting, fishing, and gathering on the lands at the project site, Ahtna, Incorporated would
like a study on the impact of the dam on caribou migration and calving, all fish species’
spawning, edible fowl, and edible and medicinal plants.
Response: While there is considerable overlap with our proposed analysis of
project effects on fish, wildlife and vegetation, we revised SD2 to clarify that our analysis
of how the project may affect subsistence activities includes hunting, fishing, berry
picking, gathering of edible and medicinal plants, and harvesting of forest products for
shelter and firewood. The Commission will make a determination on the scope of
environmental studies for subsistence activities during the ILP study planning process.
SOCIOECONOMICS
Comment: Many commenters note that their businesses and communities are
based on tourism and visitors that travel to the area to see the abundant wildlife and
spectacular scenery, and to experience a natural setting. The Talkeetna Community
Council states that the scoping document fails to address the Northern Susitna Valley’s
robust wilderness-based tourism industry. They also believe that dam construction and
operation would change the landscape and adversely affect the free-flowing river system,
salmon, and wildlife. They assert that the resulting loss in wildlife and wilderness would
have significant negative effects on the economies of local businesses. Salmon was also
highlighted as a major, regional economic resource that could be adversely affected by the
project.
Response: SD2 has been revised to clarify that the EIS will examine project
effects on natural resources-based tourism in the area.
Comment: NMFS states that the Commission’s socioeconomic analysis is limited
to local issues. NMFS believes the socioeconomic analysis should be expanded to
include an economic valuation study at a national level.
Response: The socioeconomic analysis will examine project effects on local
communities as this is where most of the effects are likely to occur. The analysis will also
evaluate impacts on a regional level where appropriate. See also our earlier response to
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the Natural Heritage Institute’s comment regarding evaluating the intrinsic values of a
free-flowing Susitna River.
Comment:The Center for Water Advocacy states that the economic analysis
conducted in the EIS must address whether building the dam will rely heavily on State of
Alaska funds and whether taking money from the treasury will affect the state’s ability to
provide other services and programs funded through the treasury (i.e., police, fire
prevention and education).
Response: The analysis will consider the effect on costs to government services
that are related to the project. However, an analysis of tradeoffs for the state of Alaska
associated with funding the Susitna-Watana Project over other projects or programs
would be too speculative and beyond the scope of the EIS.
Comment: Several commenters request to be notified of contracts and sub-
contract opportunities during licensing and construction of the project, and believe that all
work should be done by people who live and work in the area most affected
Response: The analysis will consider the number and likely origin of workers that
will be needed for the construction and operation of the Susitna Dam. However, the
Commission has no authority to require a license applicant or a licensee to hire specific
workers.
Comment: The Coalition states that FERC must include license conditions for
socioeconomic and cultural resources, in addition to conditions for protecting
environmental resources. For example, the Coalition states that an economic boom from
dam construction would require additional societal services such as police, emergency
technicians, school expansion, and housing. The Coalition states that the licensing
process must consider the effect of these services on the local communities that would be
required to fund the expanded services through property taxes.
Response: The EIS will assess effects of project construction and operation on
local and regional government services and on cultural resources and will identify
measures needed to avoid or mitigate these effects.
Comment: The Denali Citizens Council states that the EIS should focus on likely
land use and economic impacts in the southern Denali Borough. For example, what will
be the likely changes in population in Cantwell and surrounding area during construction
and operation? How much new housing will be required? What local government
expenditures will be required during construction and operation related to education,
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emergency services, and land use planning? Another commenter asked what will happen
to the large construction workforce once the project is completed?
Response: The EIS will assess effects of project construction and operation on
local and regional government services and populations and will identify measures
needed to avoid or mitigate these effects.
Comment: The Talkeetna Airmen’s Association would like to ensure that specific
efforts are made to establish and ensure air traffic patterns and procedures are put in place
for the incremental use of helicopters by the project. The Association states that noise
abatement procedures must be established. Lynden Inc. would like a year-round road
access and aircraft landing strip to be provided to ensure access during construction and
operation.
Response: Effects of dam construction on air transportation and noise will be
addressed in the EIS. We do not evaluate the appropriateness of mitigation measures at
this time. An analysis of the need, costs, and benefits of any recommended
environmental measures would be included in the EIS after the specific recommendations
(e.g., implementation of restoration measures) have been filed with the Commission in
response to the REA notice.
Comment: EPA recommends that the FERC undertake a screening process to
determine which aspects of human health (including, but not limited to public,
environmental, mental, social, and cultural health) could be affected by the project. As an
example, EPA notes that income from new jobs can have positive health impacts by
increasing socioeconomic status or increasing access to health care. However, this
income has also been associated with decreased access to health care by changing
someone's eligibility for public assistance programs. EPA further explains that income
from new jobs has also been associated with increased rates of alcohol and drug use, and
domestic violence and child abuse due to increased discretionary income, rapid social and
community change (particularly in rural areas) and disrupted family structure due to
unusual work schedules. As another example, adding lanes to a roadway increases
vehicle traffic volume and speed, which could result in increased motor vehicle crashes
and increased severity of those crashes. Increased vehicle volume also affects air quality
in neighborhoods adjacent to the road, potentially exacerbating the rate and severity of
respiratory disease in vulnerable populations.
Response: Impacts to socioeconomic and other resources will consider several
aspects that may also have human health and safety implications. This includes changes
in traffic patterns and volume, noise and dust levels, changes in housing demands, change
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in demands on public services (mental and health services) and other changes in social
conditions. Because of a plethora of confounding factors beyond the control of the
project and affected by the project, analyzing the indirect health implications of the above
impacts is beyond the scope of the EIS or would be so broad as not to be informative to
the decision making process. However, AEA has indicated that it intends to evaluate
human health implications of the project as required by state regulations.
AIR QUALITY
Comment: Many commenters would like studies for impacts of the project on air
quality in the project area during construction.
Response: AEA has proposed an air quality study, filed May 18, 2012, which will
assess the current conditions of the area against applicable state and national air quality
standards for both short-term (construction) and long-term (operational) impacts. The
Commission will make a determination on the scope of environmental studies during the
ILP study planning process.
Comment: Multiple commenters request an evaluation and quantification of
methane and carbon dioxide gas emissions as a result of inundating vegetation and
thawing permafrost during reservoir filling and operation. Many others request an
evaluation of the carbon footprint of constructing the project, including an evaluation of all
aspects of construction (e.g., road construction, materials movement, dam construction,
vegetation clearing and removal, construction workers and environmental study workers
transportation, and concrete and steel manufacturing) and an evaluation of the number of
years the project would have to operate to off-set the amount of carbon produced during
construction.
Response: We revised SD2 to clarify that the EIS will examine the effects of air
emissions from the various sources associated with the construction and from operation of
the project, including carbon dioxide gas emissions from filling the reservoir. We will
also assess the offset of emissions from reasonable foreseeable alternative energy sources.
Comment: The EPA commented that pollution from outdoor recreation vehicle
(ORV) and snow machine use should be considered if the project results in additional
access to new areas.
Response: It is too speculative to quantify the net effect of increasing access on
the regional air quality. For example, there would be no way to assess the increase in the
project area from an offset by a reduction in nearby areas.
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DEVELOPMENTAL ANALYSIS
Comment: Many commenters state that climate change is causing glaciers to
shrink, including those feeding the Susitna River. Consequently, the EIS should look at
how the potential for mass glacial wasting may reduce the hydropower resource over time
and increase the rate of glacial sediment deposition in the reservoir, both of which would
significantly affect project generation, operational flexibility and maintenance, and the life
and viability of the project.
Response: As we have stated earlier, we are not aware of any way to accurately
predict the effects of climate change on changes in glacial wasting and on the timing and
availability of water in the Susitna River Basin, on a basin-specific scale given the current
state of the science. Nonetheless, we will evaluate a range of hydrological conditions as
part of our environmental analysis of the projects. In addition, we have requested that
AEA reexamine the effects of surging glaciers on sediment accumulation rates in the
project reservoir based on historical data and AEA’s proposed monitoring. The
Commission will make a determination on the scope of such studies during the ILP study
planning process.
Comment: Multiple commenters state that there is need for a cost/benefit analysis
with an honest, comprehensive, and realistic analysis of the costs versus the benefits of
the project and various energy alternatives, and a reasonable estimate of the cost of
project power. Further, multiple commenters question where the money to construct the
project will come from and who will profit from the project, noting that the bond structure
used to finance the Bradley Lake Project would not likely be available for the Susitna
Project.
Response: In evaluating the economics of hydropower projects, the EIS will
include a comparison of the project cost to an estimate of the cost of obtaining the same
amount of energy and capacity using a likely alternative source of power for the region
(cost of alternative power). Funding for any project is at the discretion and risk of the
applicant.
Comment: Commenters would like to see a dam removal and restoration plan,
including costs for implementing such a plan, addressed in the EIS.
Response: At this point, we see no basis for evaluating a decommissioning
alternative or dam removal and restoration plan in the EIS. The current project under
consideration involves construction and operation of the project as proposed by AEA, as
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well as the alternative locations, designs, and energy sources AEA considered in arriving
at the selection of the proposed site. Any future proposals to decommission the project
would be evaluated only after a license has been issued and an application has been filed
to surrender the license.
Comment: Multiple commenters are concerned with the estimated costs of the
project and note that cost overruns in large dam construction are very common, pointing
to the Healy Clean Coal plant and Willow-Healy transmission intertie as examples of
energy projects that cost millions to hundreds of millions more than their initial cost
estimates.
Response: The exact cost of the project must be provided in the final license
application.
COMPREHENSIVE PLANS
Comment: Multiple commenters state that FERC must consider whether the
project is consistent with the Chase Comprehensive Plan, Talkeetna Comprehensive Plan,
and the Y Community Council Area Comprehensive Plan, all of which were omitted from
the list of comprehensive plans in SD1. Other plans mentioned by commenters include
the Alaska DNR’s Susitna Area Plan, Southeast Susitna Area Plan, Susitna-Matanuska
Area Plan, and Susitna Basin Recreation Rivers Management Plan
Response: The Alaska’s Susitna Area Plan and Susitna Basin Recreation Rivers
Management Plan are approved comprehensive plans filed under section 10(a)(2)(A) of
the Federal Power Act. None of the remaining plans identified above are approved
comprehensive plans filed under section 10(a)(2)(A) of the FPA. To be considered a
comprehensive plan under 10(a)(2)(A) of the FPA, the plan must be filed with the
Commission by a state or federal agency with a request that it be considered a
comprehensive plan. The Commission is required to determine whether a project is
consistent with filed, qualifying plans. That analysis will be included in the EIS.
Although a city or county would not qualify to submit such plans for Commission
approval, we will consider these documents, if filed, as we consider all relevant studies
and recommendations, in our public interest analysis pursuant to section 10(a)(1) of the
Federal Power Act.
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3.0 PROPOSED ACTION AND ALTERNATIVES
In accordance with NEPA, the environmental analysis will consider the following
alternatives, at a minimum: (1) the no-action alternative; (2) AEA’s proposed action; and
(3) alternatives to the proposed action that may be identified.
3.1 No-action Alternative
The no-action alternative is license denial. Under the no-action alternative, the
project would not be built and environmental resources in the project area would not be
affected.
3.2 AEA’s Proposed Action
3.2.1 Project Facilities
The proposed project would be located at river mile 184, which is roughly 90 river
miles northeast of the community of Talkeetna. The proposed project would consist of
the following: (1) a 700- to 800-foot-high, approximately 2,700-foot-long, earth
embankment, roller compacted concrete or concrete faced rockfill dam; (2) a 39-mile-
long reservoir with a surface area of 20,000 acres and 2,400,000 acre-feet of usable
storage capacity at a normal water surface elevation of 2,000 feet mean sea level;18 (3) a
powerhouse with a minimum of three generating units and a total installed capacity of
600 to 800 MW; (4) a 40- to 50-mile-long road and 230-kilovolt (kV) transmission line
corridor that would be constructed along one of three alternative routes (i.e., Chulitna,
Gold Creek, or Denali); and (5) appurtenant facilities. The estimated annual generation
would be 2,500,000 GWh.
Access to the project would be via a new road and by air. The access roads and
transmission facilities would be located in the same corridor to the extent practicable.
Three corridors are currently being evaluated: Chulitna, Gold Creek, and Denali
Highway. The Chulitna and Gold Creek Corridors would accommodate east-west
running transmission lines and a road running roughly parallel to the Susitna River on the
north and south sides of the river respectively. A transmission line and a road from the
project in this configuration would extend between 45 and 50 miles and connect to the
18 Generation optimization studies may lead to AEA proposing to operate the
project at a normal maximum reservoir elevation of 2,100 feet which would cause the
reservoir to be proportionately longer and have a greater surface area.
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Anchorage-Fairbanks Intertie Transmission line and the Alaska Railroad near the
Chulitna or Gold Creek rail stops.19 If the Denali Corridor is selected as the preferred
access route, a 44-mile-long road would be constructed from the project north to the
existing Denali Highway.20 The Denali Corridor would also accommodate transmission
and road facilities. The transmission line would continue east along the existing Denali
Highway to connect to the Anchorage-Fairbanks Intertie Transmission lines near
Cantwell. If the Denali corridor were used for road access, railhead facilities would likely
be developed near the Cantwell rail stop. An approximately 8,000-foot long airstrip, with
helicopter pad, would also be permanently constructed at the project site to accommodate
the transport of construction personnel as well as supplies.
A temporary, fenced construction camp capable of housing and supporting a peak
construction workforce of 1,000 would be constructed at the project site. The camp is
currently proposed to be constructed on the north bank of the Susitna River near
Deadman’s Creek. Deadman’s Creek would provide potable water and fire protection for
the camp and work areas, with a backup system of groundwater wells. Water supply for
the camp would be treated to meet U.S. Environmental Protection Agency and state water
quality requirements. A wastewater collection and treatment system would be
constructed to serve the camp. Following construction, the camp would be removed
except for those facilities needed to support smaller permanent residential and operation
and maintenance facilities.
3.2.2 Project Operation
The proposed project will operate in a load-following mode to maximize firm
energy during the critical winter months of November through April. To meet this
objective, the reservoir would be drafted on a daily and seasonal basis. The reservoir
would be drafted annually by an average of about 120 ft. Maximum annual drawdown
could be up to 150 foot occurring once in 50 years. In most years, the reservoir would
reach its lowest levels by mid-May, and would refill by mid-August.
Downstream flows at the project site are expected to vary on a seasonal, weekly,
19 For both the Chulitna and Gold Creek Corridors alternatives, the new access
roads would end at the railroad and would not connect to an existing public road.
20 The new road would start at milepost 113.7 on the Denali Highway. If needed
to accommodate increased construction traffic, AEA would improve about 20 miles of the
Denali Highway near Cantwell.
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and daily basis as dictated by minimum instream flow requirements (which have yet to be
determined) and load requirements of the railbelt utilities. During the peak winter
months, load following would result in discharges over a 24-hour period typically ranging
from a low of 3,000 cubic feet per second (cfs) to a high of 10,000 cfs, and average about
6,700 cfs. During the late summer when the reservoir is full, discharges through the
powerhouse may be as high as 14,500 cubic feet per second (at maximum plant output
based on a 600 MW project) to prevent or minimize spill and maximize energy
generation.
Minimum instream flow releases to maintain aquatic habitats downstream have not
been determined yet. These flows would be made through either the powerhouse or low
level outlet works. With the project in place, regulated peak summer flows downstream
of Watana dam at Gold Creek would be reduced and winter flows would be increased in
comparison to the natural flow regime.
3.2.3 Proposed Environmental Measures
AEA plans to develop measures to protect and enhance environmental resources
affected by construction and operation of the project through the planned licensing studies
and through agency and stakeholder collaboration. AEA has thus far identified the
following measures to protect and enhance environmental resources of the project area:
Geologic and Soil Resources
Develop a Sediment and Erosion Control Plan to prevent or minimize adverse
effects on water quality of project waters.
Water Resources
Develop a Spill Prevention, Control, and Countermeasures Plan to minimize
the potential for chemical spills during project construction.
Construct the project with selective withdrawal facilities and operate the
project to meet water temperature targets in the Susitna River downstream of
the project.
Aquatic Resources
None proposed at this time.
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Terrestrial Resources
Minimize the project footprint and vegetation impacts.
Dispose of excavated materials within the impoundment area.
Discourage or restrict off-road vehicle use in the project area to minimize trail
propagation and erosion.
Develop a restoration plan with revegetation measures to restore construction
areas.
Avoid wetlands to the maximum extent possible, and rehabilitate temporary
impacts on wetlands to the maximum extent possible
Rare, Threatened, and Endangered Species
There are no federally listed threatened or endangered species or critical
habitats that occur in the project area. The Cook Inlet beluga whale is an
endangered species with designated critical habitat in Upper Cook Inlet, which
is located 184 river miles downstream of the proposed dam site. No specific
measures are proposed for this species at this time.
Aesthetic Resources
Develop a comprehensive Site Restoration and Aesthetics Plan to minimize
adverse effects on the landscape.
Recreation Resources
Develop a Recreation Plan, which will include proposals for new recreation
facilities and measures to manage recreation use and resources of the project
area. Proposed recreation facilities are likely to include: roads and parking
areas, scenic overlooks, directional and informational signage, boat launches,
picnic areas, campgrounds, hiking trails, fishing piers, interpretive exhibits and
programming, and a visitor center.
Cultural Resources
Develop subsistence resource protection, mitigation and enhancement measures
in consultation with the appropriate agencies, Alaska Native entities, and other
interested parties.
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Develop a Historic Properties Management Plan (HPMP) to protect significant
cultural resources during project construction and operation.
3.3 Alternatives to Proposed Action
Commission staff will consider and assess all alternative recommendations for
location or other changes to the proposed project, as well as protection, mitigation, and
enhancement measures identified by the Commission, other agencies, Alaska Native
entities, NGOs, and the public.
4.0 SCOPE OF CUMULATIVE EFFECTS AND SITE-SPECIFIC
RESOURCE ISSUES
4.1 Cumulative Effects
According to the Council on Environmental Quality's regulations for implementing
NEPA (50 C.F.R. 1508.7), a cumulative effect is the effect on the environment that
results from the incremental effect of the action when added to other past, present, and
reasonably foreseeable future actions, regardless of what agency (federal or non-federal)
or person undertakes such other actions. Cumulative effects can result from individually
minor but collectively significant actions taking place over a period of time, including
hydropower and other land and water development activities.
4.1.1 Resources That Could Be Cumulatively Affected
Based on information in the PAD, preliminary staff analysis, and comments
received, we have identified the following as resources that could be cumulatively
affected by the proposed construction and operation of the project: anadromous
salmonids, wildlife (particularly caribou and moose migration and calving areas),
aesthetic and recreation activities, subsistence and hunting activities, tourism, and civil
and commercial aviation access.
4.1.2 Geographic Scope
Our geographic scope of analysis for cumulatively affected resources is defined
by the physical limits or boundaries of: (1) the proposed action's effect on the
resources, and (2) contributing effects from other hydropower and non-hydropower
activities within the Susitna River Basin. Because the proposed action would affect the
resources differently, the geographic scope for each resource may vary.
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At this time, we have tentatively identified the Susitna River, its tributaries, and
upper Cook Inlet as our geographic scope of analysis for cumulatively affected
anadromous salmonids. Activities within this geographic area that may cumulatively
affect these resources include: (1) oil and natural gas exploration and extraction; (2)
Chuitna coal project; (3) Port Mackenzie rail expansion; (4) fish harvest (commercial,
sport, personal use, and subsistence); (5) proposed coal mines in the Mat-Su Valley;
and (6) introduction and proliferation of non-native fish species.21
At this time, we have tentatively identified the Susitna River basin as our
geographic scope of analysis for wildlife (particularly caribou and moose migration
and calving areas), aesthetic and recreation activities, subsistence and hunting
activities, tourism, and civil and commercial aviation access. Activities within this
geographic area that may cumulatively affect these resources include: (1) military
flight expansion in the Fox 3 MOA as described in the Joint Pacific Alaska Range
Complex EIS; (2) mineral exploration and potential production associated with the
Tangle Lakes/MAN Project; and (3) scenic air tours and landings on two glaciers
located north of the project area near Mt. Deborah.22
4.1.3 Temporal Scope
The temporal scope of our cumulative effects analysis in the EIS will include a
discussion of past, present, and future actions and their effects on each resource that
could be cumulatively affected. Based on the potential term of a license, the temporal
scope will look 30-50 years into the future, concentrating on the effect to the resources
from reasonably foreseeable future actions. The historical discussion will, by necessity,
be limited to the amount of available information for each resource. The quality and
quantity of information, however, diminishes as we analyze resources further away in
time from the present.
Those issues identified by an asterisk (*) in section 4.2 below will be analyzed for
both cumulative and site-specific effects.
21 While we have identified these projects to be considered in the cumulative
effects analysis, we will reevaluate these actions as well as other new actions that may be
proposed, at the time we begin to prepare the EIS to ensure that they are reasonable
foreseeable projects.
22 Id.
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4.2 Project-Specific Resource Issues
In this section, we present a preliminary list of environmental issues to be
addressed in the EIS. We identified these issues, which are listed by resource area, by
reviewing the PAD and the Commission’s record for the project. This list is not intended
to be exhaustive or final, but contains those issues raised to date that could have
substantial effects. After the scoping process is completed, we will review this list and
determine the appropriate level of analysis needed to address each issue in the EIS.
4.2.1 Geologic and Soils Resources
Effects of project construction activities on soil erosion and sedimentation
(e.g., dam and hydropower generation facilities, transmission lines, access
roads, airstrip, construction camp, borrow areas, disposal areas, staging areas,
etc).
Effects of project construction and operation on sediment deposition in the
reservoir, including the rate of sediment deposition and the effect of sediment
deposition on the useful life of the reservoir.
Effects of project operations on soil movement, shoreline erosion, tributary
mouth migration, and shoreline stability within the reservoir inundation zone.
Effects of project operations on sediment transport, streambed material particle
size distribution, and stream morphology in the middle and lower reaches of the
Susitna River.23
Potential seismic effects on the proposed dam and other project facilities,
including the potential for soil failure, (e.g., landslides, liquefaction,
settlement, lateral spreading) and seiches or oscillations of lake surfaces, and
any related effects on public safety and property downstream.
Effects of project construction and operation on access to proven or probable
mineral deposits.
23 The project area for the Susitna River includes the upper, middle, and lower
reaches. The upper reach includes the mainstem Susitna River upstream of the proposed
dam site at river mile (RM) 184. The middle reach includes the mainstem Susitna River
from the dam site downstream to the three rivers confluence area at RM 98. The lower
reach includes the mainstem Susitna River from RM 98 downstream to RM 0 at the
confluence with Cook Inlet.
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4.2.2 Water Resources
Effects of project operation (e.g., minimum instream flow releases; flood,
pulse, and base flow conditions; peaking operations, etc.) on the existing flow
regime of the middle and lower reaches of the Susitna River, including the
timing, magnitude, and duration of flows.
Effects of project operation on ice processes within the reservoir and the
middle and lower reaches of the Susitna River.
Effects of project construction activities (e.g., excavation, dredging, blasting,
etc.)on water quality in the Susitna River and affected tributaries, including:
temperature, turbidity, total dissolved solids, suspended solids, dissolved
oxygen, pH, chemical/nutrient characteristics, and metals (e.g., aluminum,
cadmium, copper, manganese, mercury, and zinc).
Effects of reservoir filling and project operations on water quality (within the
reservoir and the middle and lower reaches of the Susitna River, including:
temperature, turbidity, total dissolved solids, suspended solids, dissolved
oxygen, pH, metals, and chemical/nutrient characteristics.
Effects of the project on water quality impaired waters that are listed on the
Clean Water Action section 303(d) list, and identification of any potential
measures to avoid further degradation of impaired waters.
Effects of the project on source water/drinking water protection areas, and
identification of any potential measures to protect source water areas.
Effects of spillway operations on total dissolved gas concentrations in the
middle reach of the Susitna River.
Effects of reservoir inundation on the potential for mercury methylation and
subsequent bioaccumulation of mercury in fish and wildlife.
Effects of project construction and operation on water evaporation rates due
to creation of a large reservoir.
4.2.3 Fisheries and Aquatic Resources
Reservoir
Effects of reservoir operations (e.g., daily and seasonal fluctuations) on
resident fish migration and habitat in the reservoir and in reservoir tributaries.
Effects of reservoir inundation and permanent change from riverine to reservoir
habitat on aquatic habitat; primary production; and fish and macroinvertebrate
distribution, species composition, and abundance.
Effects of project operations on reservoir fish entrainment and mortality.
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Susitna River
Effects of project operation (e.g., daily and seasonal flow fluctuations, water
temperature, etc.) on primary production and macroinvertebrate species
distribution, composition, and abundance in the middle and lower reach of the
Susitna River.
Effects of modification of the existing flow regime on off-channel habitat (i.e.,
side channels and sloughs) connectivity with the mainstem Susitna River
throughout the middle and lower reaches, and corresponding effects on fish
access to off-channel habitats.
Effects of changes in streambed material composition and stream morphology
on aquatic habitat in the middle and lower reaches of the Susitna River (e.g.,
changes to streambed material particle size distribution, stream morphology,
riparian vegetation characteristics, and distribution and characteristics of off-
channel habitats).
Effects of project operation on fish access to tributary habitats in the upper,
middle, and lower reaches of the Susitna River.
Effects of project construction and operation on the recruitment and deposition
of large woody debris within the middle and lower reaches of the Susitna
River.
Effects of project construction and operation on resident and anadromous fish
migrations, including anadromous salmonid access to the upper reach through
Devils Canyon, and any potential measures to minimize adverse effects (e.g.,
fish passage).*
Effects of modifications to the existing flow regime on physical aquatic habitat
availability for spawning and rearing resident and anadromous fish species in
mainstem and off-channel habitats throughout the middle and lower reaches of
the Susitna River.
Effects of modifications to the existing flow regime, sediment transport, ice
processes, channel morphology, water quality, etc. on anadromous fish
spawning, rearing, and migration habitats (i.e., mainstem and off-channel) in
the middle and lower reaches of the Susitna River.
Effects of project construction and operation on anadromous fish
distribution, abundance, and habitat utilization in the upper, middle, and
lower reaches of the Susitna River.*
Effects of project operation (e.g., winter peaking, water temperatures, etc.) on
anadromous fish spawning success, fry emergence timing and success,
juvenile fish growth and survival, and outmigration timing and success in the
upper, middle, and lower reaches of the Susitna River.*
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Effects of modifications to the existing flow regime, sediment transport, ice
processes, channel morphology, water quality, etc., on resident fish species
distribution, composition, and abundance in the middle and lower reaches of
the Susitna River.
Effects of modifications to water temperatures on the distribution of fish
communities, including the invasive northern pike.
Effects of project construction, operation, and maintenance activities on the
potential for introduction of invasive aquatic macroinvertebrates and fish
species.
4.2.4 Terrestrial Resources
Effects of habitat loss and fragmentation from project construction and
operation on the availability, use, and productivity of wildlife habitats,
including key habitat features such as den sites and mineral licks.*24
Effects of the project features (i.e., reservoir, access roads, camp site, etc.),
fluctuating reservoir levels, ice conditions, and new patterns of human
activities on wildlife movement, including any physical and behavioral
blockage and alteration of wildlife movement patterns and access to important
habitats (e.g., moose wintering range, caribou foraging and calving areas,
etc.).*
Effects of project-related fluctuating water levels and ice conditions in the
reservoir and downstream river reaches on wildlife mortality rates, with an
emphasis on big game species.*
Effects of improved access on levels of human presence and disturbances,
hunting and trapping, vehicular use, and noise, on wildlife distribution, habitat
use, and abundance in the project area.*
Effects of vegetation removal, altered hydrologic regimes, and construction and
operation activities on bald and golden eagle roosting, nesting, rearing, and
foraging habitats and forage availability.*
24 A major focus of the analysis will be on big game species (moose, caribou,
Dall’s sheep, black and brown bears), game birds (ptarmigan, grouse, etc.), wolf,
furbearers (beaver, marten, river otter, lynx, and red fox), and small game (snowshoe
hare, ptarmigan, and grouse) due to their ecological, management, recreational, and
subsistence values; however, other wildlife (e.g., small mammals, shorebirds, shorebirds,
seabirds, amphibians, etc.) will be examined as well.
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Effects of vegetation removal and disturbance associated construction and
operation activities on nesting, rearing, and foraging habitats of migratory “bird
species of concern.”*25
Effects of the project transmission lines on avian collision and electrocution.
Effects of inundation and water level fluctuations, construction activities,
changes in solar radiation and temperature moderation, and erosion and dust
deposition on the distribution and composition of vegetation and wetland
communities within and adjacent to the proposed reservoir, transmission line
and access roads, and other project features.
Effects of project construction and operation activities on the introduction and
spread of new or existing invasive plants on vegetation communities and
wildlife habitats.
Effects of altered hydrologic regimes on wetlands, wetland functions, riparian
vegetation, and riparian succession patterns in the middle and lower reaches of
the Susitna River.
Effects of project construction and operation on rare plant populations.
4.2.5 Threatened and Endangered Species
Effects on the Endangered Cook Inlet beluga whale from any changes in
habitat and prey base at the Susitna River mouth.
4.2.6 Recreation Resources and Land Use
Effects of altered hydrologic regimes and ice cover on timing and extent of
river access and navigation within and downstream of the reservoir.
Effects of altered hydrologic regimes and ice cover on floodplain vegetation,
and subsequent effects on recreational access.
Effects of project construction and altered hydrologic regimens on fishing
opportunities, including availability of fish, fishing access, and quality of
experience.*
25 As stipulated in the March 30, 2011 Memorandum of Understanding between
the Commission and Interior, migratory bird species of concern in this case will include:
(1) species listed by the U.S. Fish and Wildlife Service (FWS) as birds of conservation
concern, (2) priority migratory species identified in various bird conservation plans such
Alaska’s Comprehensive Wildlife Conservation Plan, (3) species or populations of
waterfowl of high or moderately continental importance, and (4) game birds of
management concern.
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Effects of project construction and altered hydrologic regimens on potential
whitewater and other boating opportunities (e.g., kayaking, rafting, canoeing),
including access and quality of experience.*
Effects of the project construction (i.e., reservoir and access roads and
presence of the construction workforce) and operation on hunting and
trapping opportunities and on non-consumptive uses (e.g.,bird-watching,
hiking, camping, boating, berry picking, recreational races and events,etc.) in
the vicinity and downstream of the project reservoir, including availability of
the resource, access, quality of experience, and displacement of users.*
Effects of project construction and operation activities (e.g. noise, dust, access,
etc.,) on recreation.*
Effects of changes in land use, ownership, and winter road plowing and
maintenance on public access and recreation, including any associated
increase in off-road vehicle recreation (e.g., all-terrain vehicle or snow
machine) and potential for illegal trespass, vandalism, and wildfires.
Effect of the presence of more people recreating on the recreational
experience.*
Effects of project construction on the eligibility of Brushkana Creek and the
Susitna River for possible future designation as a wild and scenic river.
Consistency of the project with any applicable land use and management plans.
4.2.7 Aesthetics
Effects of project construction and operation activities (e.g. equipment noise,
blasting, dust, lighting, variable reservoir water levels,etc.,) and the presence
and contrast of project features (dam, transmission lines, quarries, staging
areas,construction camp and permanent village) on aesthetic resources.*
Effects of the project on the natural character of the river (e.g., color and
appearance of the flowing water) and adjoining lands (e.g., public facilities,
altered channels, banks, islands, vegetation).*
4.2.8 Cultural Resources
Effects of project construction (e.g., soil disturbing activities); inundation and
reservoir fluctuations; disturbance, looting, or vandalism from improved site
access; and changes in the surrounding historic landscape on cultural resource
sites, including those determined eligible for listing on the National Register of
Historic Places (NRHP).
Effects of the presence of project facilities and construction, operation, and
maintenance activities (including noise)and increased human use on
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traditional spiritual areas and other traditional uses (Traditional Cultural
Properties) within the Area of Project Effect (APE).
Effects of project construction (e.g., inundation and disturbance) on
paleontological resources.
4.2.9 Socioeconomic Resources
Effects of project construction and operation on local and regional
employment, income, housing, and cost of living.*
Effects of project construction and operation on commercial opportunities
related to fishing and hunting, recreation, tourism, forestry, and mining in
the Susitna River basin.This includes changes in visitation, expenditures,
jobs and income.*
Effects of changes to the natural character of the river and adjoining lands
on quality of life and tourism and other industries (e.g., photography,
filmmaking) that may be highly dependent on natural landscapes.
Effects on salmon as a regional economic resource.*
Effects of construction traffic and the construction work force on local
government facilities and services (e.g., health and human services, law
enforcement, emergency services, education, etc) and housing.
Effects of project construction and construction traffic on local and regional
transportation systems (both passenger and freight), including highway, rail and
air transport.
Effects of altered flows and ice conditions on river-dependent transportation
along or across the Susitna River (e.g., boating, snowmobiling, snowshoeing,
dog-sledding, and access to recreational cabins and home sites).
Effects of changes in fish and wildlife populations and their normal locations
and distribution patterns due to project construction and operation on the
availability and use of subsistence resources.
Effects of use and occupancy of project lands on access to subsistence
resources and traditional subsistence activities including hunting, fishing,
berry picking, and gathering of medicinal plants and forest products.
Disproportionate effects of project construction and operation on minority
and low-income populations.
4.2.10 Air Quality
Effects of air emissions (carbon monoxide, volatile organic compounds,
nitrogen dioxide, sulfur dioxide, ozone, particulate matter, etc.) from
concrete batching, construction equipment, earth moving activities,
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construction worker commutes, material deliveries, earth hauling, and
operation and maintenance on air quality in the region.
Effects of air emissions from project operation, including methane and
carbon dioxide gas emissions as a result of inundating vegetation and
thawing permafrost during reservoir filling and operation, on air quality in
the region.
Effects of air emissions from outdoor recreation vehicle and snowmachines
from any potential increase in access and use in the project area.
4.2.11 Developmental Resources
Effects of the proposed project and alternatives, including anyprotection,
mitigation, and enhancement measures on the economics of the project.
5.0 PROPOSED STUDIES
AEA has proposed to develop studies to address the resource issues summarized in
Table 1. Table 1 has been updated to reflect the most current list of proposed studies
that would be conducted in 2013 and 2014 as filed with the Commission on May 18,
2012.AEA is actively working with resource groups to develop these studies and others
that may be recommended by the groups. AEA is also voluntarily working with resource
groups to gather data in 2012 before the Commission’s formal approval of the study plan
to help refine study needs. A formal study plan will be developed based on the
Commission’s identification of issues identified in this SD1 and, as necessary, an SD2.
Table 1. AEA’s initial study proposals for the Susitna-Watana Hydroelectric
Project (Source: Susitna-Watana Hydroelectric Project PAD).
RESOURCE AREA STUDY
Social Resources Cultural Resources
Aesthetic and Recreation Resources
Socioeconomics: Social Conditions and
Public Goods and Services
Socioeconomics: Regional Economic
Evaluation
Socioeconomics: Transportation Resources
Analysis
Subsistence Baseline Documentation
Air Quality Air Quality
Water Resources Water Quality Modeling
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Baseline Water Quality
Ice Processes on the Susitna River
Fish and Aquatic Resources Aquatic Resurces Study with the Access
Alignment, Construction Area and
Transmission Alignment Study
Cook Inlet Beluga Whale and Prey Study
Characterizatin of Potentially Affected Aquatic
Habitats in the Susitna River
Analysis of Fish and Harvest Rates in and
Downstream of the Project Area
Freshwater Fish Distribution and Abundance
in the Middle and Lower Susitna River
Water Quality Modeling
Geomorphology
Groundwater-related Aquatic Habitat
Baseline Water Quality
Instream Flow Study
Riparian Instream Flow
River Productivity
Ice Processes on the Susitna River
Fluvial Geomorphology Modeling below
Watana Dam
Fish Passage Barriers in the Upper Susitna
and Select Middle Susitna Tributaries
The Future Watana Reservoir Fish
Community and Risk of Entrainment Study
Fish Distribution and Abundance in the Upper
Susitna River, 2013-14
Salmon Escapement in the Susitna River
Wildlife Resources Waterbird Migration, Breeding and Habitat
Use
Wolf and Wolverine Distribution and
Abundance
Wildlife Harvest Analysis
Brown Bear and Black Bear Distribution,
Abundance, and Habitat Use
Breeding Survey of Landbirds and Shorebirds
Caribou Distribution, Abundance, Movements,
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and Productivity
Moose Distribution, Abundance, Movements,
Productivity and Survival
Dall’s Sheep Distribution, Abundance and
Habitat Use
Population Ecology of Willow Ptarmigan in
Game Management Unit 1
Surveys of Eagles and Other Raptors
Terrestrial Furbearer Abundance and Habitat
Use
Wood Frog Distribution and Habitat Use
Little Brown Bat Distribution and Habitat Use
Small Mammal Species Composition and
Habitat Use
Aquatic Furbearer Abundance and Habitat
Use
Botanical Resources Invasive Plant Study
Wildlife Habitat Evaluation
Vegetation and Wildlife Habitat Mapping
Wetland Mapping and Functional Assessment
Rare Plant Study
6.0 EIS PREPARATION SCHEDULE
We intend to prepare a draft and final EIS (we show our preliminary Outline in
section 7). The draft EIS will be sent to all persons and entities on the Commission's
service and mailing lists for the Susitna-Watana Hydroelectric Project. The EIS will
include recommendations for construction and operating procedures, as well as
environmental protection, mitigation, and enhancement measures that should be part of
any license issued by the Commission. All recipients will then have 60 days to review the
draft EIS and file written comments with the Commission. All comments on the draft EIS
filed with the Commission will be considered in preparation of the final EIS. A schedule
for preparing the EIS will be issued once the application is filed.
A copy of AEA’s process plan, which has a complete list of pre-filing licensing
milestones for the project is attached as Appendix A to this SD2.
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7.0 PROPOSED EIS OUTLINE
The preliminary outline for the EIS is as follows:
COVER SHEET
FOREWORD
TABLE OF CONTENTS
LIST OF FIGURES
LIST OF TABLES
LIST OF APPENDICES
ACRONYMS AND ABBREVIATIONS
EXECUTIVE SUMMARY
1.0 INTRODUCTION
1.1.Application
1.2.Purpose of Action, Need for Power
1.3.Statutory and Regulatory Requirements
1.3.1. Federal Power Act
1.3.1.1.Section 18 Fishway Prescriptions
1.3.1.2.Section 4(e) Conditions
1.3.1.3.Section 10(j) Conditions
1.3.2. Clean Water Act
1.3.3. Coastal Zone Management Act
1.3.4. Endangered Species Act
1.3.5. National Historic Preservation Act
1.3.6. Magnuson-Stevens Fishery Conservation and Management Act
1.3.7. Wild and Scenic Rivers Act
1.3.8. Other Regulatory Requirements
1.4.Public Review and Comment
1.4.1. Scoping
1.4.2. Interventions
1.4.3. Comments on the Application
1.4.4. Comments on the Draft EIS
2.0 PROPOSED ACTION AND ALTERNATIVES
2.1.No-action Alternative
2.2.Applicant’s Proposed Action
2.2.1. Proposed Project Facilities
2.2.2. Proposed Project Operation
2.2.3. Proposed Environmental Measures
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2.2.4. Modifications to Applicant’s Proposal-Mandatory Conditions
2.3.Staff Alternative
2.4.Staff Alternative with Mandatory Conditions
2.5.Other Alternatives (as appropriate)
2.6.Alternatives Considered but Eliminated from Detailed Analysis
3.0 ENVIRONMENTAL ANALYSIS
3.1.General Description of the River Basin
3.2.Scope of Cumulative Effects Analysis
3.2.1. Geographic Scope
3.2.2. Temporal Scope
3.3.Proposed Action and Action Alternatives
3.3.1. Geologic and Soil Resources
3.3.2. Water Resources
3.3.3. Aquatic Resources
3.3.4. Terrestrial Resources
3.3.5. Threatened and Endangered Species
3.3.6. Recreation and Land Use
3.3.7. Cultural Resources
3.3.8. Aesthetic Resources
3.3.9. Socioeconomics
3.3.10.Air Quality
3.4.No-Action Alternative
4.0 DEVELOPMENTAL ANALYSIS
4.1.Power and Economic Benefits of the Project
4.2.Comparison of Alternatives
4.3.Cost of Environmental Measures
5.0 CONCLUSIONS AND RECOMMENDATIONS
5.1.Comparison of Alternatives
5.2.Comprehensive Development and Recommended Alternative
5.3.Unavoidable Adverse Effects
5.4.Recommendations of Fish and Wildlife Agencies
5.5.Consistency with Comprehensive Plans
6.0 LITERATURE CITED
7.0 LIST OF PREPARERS
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8.0 LIST OF RECIPIENTS
APPENDICES
A.License Conditions Recommended by Staff
B.Response to Comments on Draft EIS
8.0 CONSISTENCY WITH COMPREHENSIVE PLANS
Section 10(a)(2) of the FPA, 16 U.S.C. section 803(a)(2)(A), requires the
Commission to consider the extent to which a project is consistent with federal and state
comprehensive plans for improving, developing, or conserving a waterway or waterways
affected by a project. The staff has preliminarily identified and reviewed the plans listed
below that may be relevant to the Susitna-Watana Project. Agencies are requested to
review this list and inform the Commission staff of any changes. If there are other
comprehensive plans that should be considered for this list that are not on file with the
Commission, or if there are more recent versions of the plans already listed, they can be
filed for consideration with the Commission according to 18 CFR 2.19 of the
Commission’s regulations. Please follow the instructions for filing a plan at
http://www.ferc.gov/industries/hydropower/gen-info/licensing/complan.pdf.
The following is a list of comprehensive plans currently on file with the
Commission that may be relevant to the project.
Alaska Department of Fish and Game. Susitna Flats State Game Refuge, March 1988.
Juneau, Alaska.
Alaska Department of Fish and Game. Matanuska-Susitna Borough. 1985. Susitna Basin
area plan. Juneau, Alaska. June 1985. 440 pp.
Alaska Department of Fish and Game. Matanuska-Susitna Borough. 1991. Susitna Basin
recreation rivers management plan. Anchorage, Alaska. August 1991. 181 pp.
Alaska Department of Fish and Game. 1998. Catalog of waters important for spawning,
rearing or migration of anadromous fishes. November 1998. Juneau, Alaska. Six
volumes.
Alaska Department of Fish and Game. 1998. Atlas to the catalog of waters important for
spawning, rearing or migration of anadromous fishes. November 1998. Juneau,
Alaska. Six volumes.
Alaska Department of Natural Resources. Alaska's Outdoor Legacy: Statewide
Comprehensive Outdoor Recreation Plan (SCORP): 2009-2014. Anchorage,
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Alaska.
Bureau of Land Management. 1981. South central Alaska water resources study:
Anticipating water and related land resource needs. Anchorage, Alaska. October
1, 1981. 97 pp.
U.S. Fish and Wildlife Service. Undated. Fisheries USA: the recreational fisheries
policy of the U.S. Fish and Wildlife Service. Washington, D.C.
9.0 MAILING LIST
The list below is the Commission’s official mailing list for the Susitna-Watana
Hydroelectric Project (FERC No. 14241). If you want to receive future mailings for the
Susitna-Watana Project and are not included in the list below, please send your request by
email to efiling@ferc.gov or by mail to:
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E., Room 1A
Washington, DC 20426.
All written and emailed requests to be added to the mailing list must clearly
identify the following on the first page: Susitna-Watana Hydroelectric Project No.
14241-000. You may use the same method if requesting removal from the mailing lists
below.
Register online at http://www.ferc.gov/docs-filing/esubscription.asp to be notified
via email of new filings and issuances related to these or other pending projects. For
assistance, please contact FERC Online Support at FERCOnlineSupport@ferc.gov or toll
free at 1-866-208-3676, or for TTY, (202) 502-8659.
FERC’s Mailing List for the Susitna-Watana Project No. 14241
Becky Long
Box 320
Talkeetna, AK 99676
Rachel Day
P.O. Box 921
Talkeetna, AK 99676
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Robert Gerlach
13666 E 2nd St
P.O. Box 23
Talkeetna, AK 99676
John Strasenburgh
15406 E. Barge Dr.
P.O. Box 766
Talkeetna, AK 99676
Kevin Foster
Mile 230.7 Alaska Railroad
Talkeetna, AK 99676
James Ferguson
P.O. Box 15391
Fritz Creek, AK 99603-6391
Denis Ransy
P.O. Box 344
Talkeetna, AK 99676
Beth Pike
P.O. Box 968
Talkeetna, AK 99676
Frank Yadon
14152 E. Gliska Street
Talkeetna, AK 99676
William FitzGerald
15537 Cummings Road
Talkeetna, AK 99676
Robert Gerlach
13666 E 2nd St
P.O. Box 23
Talkeetna, AK 99676
Paul Roderick, President
Talkeetna Air Taxi
23125 Comsat Rd
Talkeetna, AK 99676
Ruth D. Wood
15406 E. Barge Dr.
Talkeetna, AK 99676
William Post
P.O. Box 271
Talkeetna, AK 99676
Michael Wood
P.O. Box 773
Talkeetna, AK 99676
Joseph Klauder
P.O. Box 396
Talkeetna, AK 99676
Constance Twigg
P.O. Box 266
Talkeetna, AK 99676
Sheryl Salasky
P.O. Box 196
Talkeetna, AK 99676
Robert Coleman, President
Susitna Community Co
HC 89 Box 8575
Talkeetna, AK 99676
Sharon Corsaro
Corsaro Creative Coaching
P.O. Box 255
Hermosa Beach, CA 90254
Louisa Yanes
Alaska Center for the Environment
807 G Street
Anchorage, AK 99501
Lissa Hughes
Northern Alaska Environmental Center
830 College Road
Fairbanks, AK 99701
David Theriault, Legislative Director
Alaska Conservation Alliance
810 N St., Ste. 203
Anchorage, AK 99501
Wayne M Dyok, Project Manager Alaska
Energy Authority
813 West Northern Lights Blvd.
Anchorage, AK 99503
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Brett Swift
American Rivers, Inc., Et Al.
320 SW Stark Street Suite 412
Portland, OR 97204
Sara Fisher-Goad, Project Manager
Alaska Energy Authority
813 West Northern Lights Blvd.
Anchorage, AK 99503
Michael Swiger, Member
Alaska Energy Authority
1050 Thomas Jefferson Street, NW
7th Floor
Washington, DC 20007
Thomas O'Keefe
PNW Stewardship Director
American Whitewater
3537 NE 87th St
Seattle, WA 98115
Harold Shepherd
Center for Tribal Water Advocacy
P.O. Box 331
Moab, UT 84532-0331
Peg Foster, Secretary
Chase Community Council
P.O. Box 205
Talkeetna, AK 99676
Shawn Stankowitz, President
Trapper Creek Community Council
P.O. Box 13021
Trapper Creek, AK 99683
Bob Shavelson
Cook Inlet Keeper
P.O. Box 3269
Homer, AK 99603-3269
Cliff Earnes
Copper Country Alliance
HC 60 Box 306T
Copper Center, AK 99573
Charlie Loeb, President
Denali Citizens Council
PO Box 78
Denali Park, AK 99755
Jeremy Millen, Executive Director
Friends of Mat-Su
308 East Dahlia St
Palmer, AK 99645
Pat Lavin
National Wildlife Federation
750 W. 2nd Ave., Suite 200
Anchorage, AK 99501
Susan Walker, Marine Resources Specialist
NOAA National Marine Fisheries Service,
Alaska Region
P.O. Box 21668
Juneau, AK 99802-1668
Eric Rothwell, Hydrologist
Pat Lavin
National Wildlife Federation
750 W. 2nd Ave., suite 200
Anchorage, AK 99501
Thomas Meyer, General Counsel
NOAA National Marine Fisheries Service,
Alaska Region
P.O. Box 21109
Juneau, AK 99801
Mary B. Goode, Admin. Assistant
NOAA National Marine Fisheries Service,
Alaska Region
PO Box 21668
Juneau, AK 99802-1668
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U.S. Fish & Wildlife Service
Regional Office
1011 East Tudor MS 331
Anchorage, AK 99503
Office of Solicitor
U.S. Department of Interior
4230 University Dr, Ste. 300
Anchorage, AK 99508
Coalition for Susitna Dam Alternatives
1 Main Street
Talkeetna, AK 99676
Joshua Sonkiss
1024 21st Avenue
Fairbanks, AK 99701
Sharon Montagnino, Chairperson
Talkeetna Community Council, Inc.
P.O. Box 608
Talkeetna, AK 99676
Ellen Wolf
Talkeetna Defense Fund
P.O. Box 371
Talkeetna, AK 99676
Brad Powell, Forest Supervisor
USDA Forest Service
Tongass National Forest Federal Building
Ketchikan, AK 99901
Karen Kelly, Executive Director
Northern Alaska Environmental Center
830 College Road
Fairbanks, AK 99701
Kathryn Miller
Trout Unlimited
227 SW Pine Street, Suite 200
Portland, OR 97204
Ken Lord, Attorney-Advisor
U.S. Department of Interior
4230 University Dr., Suite 300
Anchorage, AK 99508
Kirby Gilbert, Water Resources Planner
Alaska Energy Authority
MWH Americas Inc.
2353 130th Ave N.E., Suite 200
Bellevue, WA 98005
Office of Environmental Policy and
Compliance (USDOI)
Regional Environmental Office
3601 C St, #1100
Anchorage, AK 9950-5947
Governor of Alaska
Office of the Governor of Alaska
RE: FERC Projects
Office of the Governor of Alaska
P.O. Box 110001
Juneau, AK 99811-0001
Monte D Miller
ADFG Statewide Hydropower Coordinator
Alaska Department of Fish and Game
Division of Sport Fish/RTS
333 Raspberry Rd.
Anchorage, AK 99518-1565
John Burke, General Manager
SSRAA
14 Borch Street
Ketchikan, AK 99901
Sharon Montagnino, Chairperson
Talkeetna Community Council, Inc.
P.O. Box 608
Talkeetna, AK 99676
Regulatory Division Chief
U.S. Army Corps of Engineers CEPOA-RD
Post Office Box 6898
JBER, Alaska 99506-6898
Frances E Mann, Branch Chief
Conservation Planning
U.S. Fish & Wildlife Service
605 W. 4th Ave., Room G-61
Anchorage, AK 99501
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NOAA National Marine Fisheries Service,
Alaska Region
222 West Seventh Ave
5th Floor
Anchorage, AK 99513
Corinne Smith
Mat-Su Basin Program Director
The Nature Conservancy of Alaska
715 L Street Suite 100
Anchorage, AK 99501
Teresa Trulock, Lands Forester
USDA Forest Service
P.O. Box 19001
Thorne Bay, AK 99919-0001
Pete Stephan, President
Montana Creek Native Association
3300 C Street
Anchorage, AK 99503
Penny Carty, President
Village of Salamatof
P.O. Box 2682
Kenai, AK 99611
Charles G. Anderson, Chairman
Cook Inlet Region, Inc.
2525 C. St., Suite 500
Anchorage, AK 99503
Edith Baller, President and Chairperson
Chickaloon-Moose Creek Native
Association
P.O. Box 875046
Wasilla, AK 99674
Anne Thomas, President
Chitina Native Corporation
P.O. Box 3
Chitina, AK 99566
Orie G. Williams, Chair
Doyon, Ltd.
1 Doyon Place, Suite 300
Fairbanks, AK 99701
Kathy Morgan, Chairman of the Board
Toghotthele Corporation
P.O. Box 249
Nenana, AK 99760
Emil J. McCord, Chairman
Tyonek Native Corporation
1689 C Street, Suite 219
Anchorage, AK 99501
Fred S. Elvsaas, Chairman of the Board
Seldovia Native Association, Inc.
P.O. Box Drawer L
Seldovia, AK 99663
President
Kenai Natives Association, Inc
215 Fidalgo Street, Suite 101
Kenai, AK 99611
Michael E. Curry, Chairman and President
Eklutna, Inc.
16515 Centerfield Drive, Suite 201
Eagle River, AK 99577
Gary Oskolkoff, President/CEO
Ninilchik Natives Association, Inc.
15730 Sterling Hwy.
P.O. Box 39130
Ninilchik, AK 99639-0130
Robert Brean, President
Tanacross, Inc.
22808 Green Garden Road
Chugiak, AK 99576
Michelle Anderson, President/CEO
Ahtna, Inc.
P.O. Box 649
Glennallen, AK 99588
Tom Harris, CEO
Knikatnu, Inc.
P.O. Box 872130
Wasilla, AK 99687
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Jerry Isaacs, President
Tanana Chiefs Conference
122 1st Avenue, Suite 600
Fairbanks, AK 99701
Wilson Justin, Administrator
Cheesh-Na Tribal Council
PO Box 241
Chistochina, AK 99586`
Veronica Nicoles, President
Native Village of Cantwell
P.O. Box 94
Cantwell, AK 99729
Jaylene Peterson-Nyren, Executive Director
Kenaitze Indian Tribe
P.O. Box 988
Kenai, AK 99611
JoAnn Polston, President
Healy Lake Village
P.O. Box 74090
Fairbanks, AK 99706
Roy Ewan, President
Gulkana Village Council
Gulkana Village
P.O. Box 254
Gakona, AK 99586- 0254
Darin Gene, President
Gakona Village Council
Native Village of Gakona
P.O. Box 102
Gakona, AK 99585
Ron Mahle, President
Chitina Traditional Village Indian Council
P.O. Box 31
Chitina, AK 99566
Donald Charlie, First Chief
Nenana Native Association
P.O. Box 369
Nenana, AK 99760
C. Nora David, 1st Chief
Mentasta Traditional Council
P.O. Box 6019
Mentasta, AK 99780
Doug Wayne, Chairman
Chickaloon Traditional Village Council
Chickaloon Native Village
P.O. Box 1105
Chickaloon, AK 99674
Frank Standifer, President
Native Village of Tyonek
P.O. Box 82009
Tyonek, AK 99682-0009
Lorraine Titus, President
Northway Village
P.O. Box 516
Northway, AK 99764
Debra Call, President
Knik Tribal Council
Box 871565
Wasilla, AK 99567
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Kathrin McConkey , President
Native Village of Kluti-Kaah
P.O Box 68
Copper Center, AK 99573
Donald Adams, President
Native Village of Tetlin
P.O. Box TTL
Tetlin, Ak 99779
Roy Denny, President
Tanacross Village Council
P.O. Box 76009
Tanacross, AK 99776
John Goodlaw, President
Tazlina Village Council
Native Village of Tazlina
P.O. Box 87
Glennallen, AK 99588
Crystal Collier, President
Seldovia Village Tribe
Drawer L
Seldovia, AK 99663
Richard “Greg” Encelewski, President
Ninilchik Traditional Council
P.O. Box 39070
Ninilchik, AK 99639
William J. Miller, President
Village of Dot Lake
P.O. Box 2279
Dot Lake, AK 99737
Lee Stephan, President
Eklutna Native Village
26339 Eklutna Village Road
Chugiak, AK 99567
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APPENDIX A
PROCESS PLAN AND SCHEDULE
The timeline assumes two years of study and the filing of a license application by
September 11, 2015, as proposed by AEA, but this is subject to change based on the
outcome of the study development process. Shaded milestones are unnecessary if there
are no study disputes filed by any agency with mandatory conditioning authority. The
timeline has been adjusted to account for weekends and holidays, but if a due date falls
on a weekend or holiday, the due date is the following business day. We will issue a
post-filing schedule once the application is filed.
Responsible
Party
Pre-Filing Milestone Date FERC
Regulation
AEA Issue Public Notice for NOI/PAD 12/29/11 5.3(d)(2)
AEA File NOI/PAD with FERC 12/29/11 5.5, 5.6
FERC Tribal Meetings 1/30/12 5.7
FERC Issue Notice of Commencement of
Proceeding and Scoping Document 1
2/27/12 5.8
FERC Scoping Meetings 3/26-29/12 5.8(b)(viii)
All stakeholders PAD/SD1 Comments and Study
Requests Due
5/31/12 5.9
FERC Issue Scoping Document 2 (if needed)7/16/12 5.1
AEA File Proposed Study Plan (PSP)7/16/12 5.11(a)
All stakeholders Proposed Study Plan Meeting 8/15/12 5.11(e)
All stakeholders Proposed Study Plan Comments Due 10/15/12 5.12
AEA File Revised Study Plan 11/14/12 5.13(a)
All stakeholders Revised Study Plan Comments Due 11/29/12 5.13(b)
FERC Director's Study Plan Determination 12/14/12 5.13(c)
Mandatory
Conditioning
Agencies only
Any Study Disputes Due 1/3/2013 5.14(a)
Dispute Panel Third Dispute Panel Member Selected 1/18/2013 5.14(d)
Dispute Panel Dispute Resolution Panel Convenes 1/23/2013 5.14(d)(3)
AEA Applicant Comments on Study Disputes
Due 1/28/2013
5.14(j)
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Dispute Panel Dispute Resolution Panel Technical
Conference 2/04/2013
5.14(j)
Dispute Panel Dispute Resolution Panel Findings
Issued 2/22/2013
5.14(k)
FERC Director's Study Dispute Determination 3/14/2013 5.14(l)
AEA First Study Season 2013 5.15(a)
AEA Initial Study Report 12/16/13 5.15(c)(1)
All stakeholders Initial Study Report Meeting 1/6/13 5.15(c)(2)
AEA Initial Study Report Meeting Summary 1/21/13 5.15(c)(3)
All stakeholders Any Disputes/Requests to Amend Study
Plan Due
2/20/14 5.15(c)(4)
All stakeholders Responses to Disputes/Amendment
Requests Due
3/23/14 5.15(c)(5)
FERC Director's Determination on
Disputes/Amendments
4/23/14 5.15(c)(6)
AEA Second Study Season 2014 5.15(a)
AEA Updated Study Report due 1/15/14 5.15(f)
All stakeholders Updated Study Report Meeting 1/5/15 5.15(f)
AEA Updated Study Report Meeting
Summary
1/20/15 5.15(f)
All stakeholders Any Disputes/Requests to Amend Study
Plan Due
2/19/15 5.15(f)
All stakeholders Responses to Disputes/Amendment
Requests Due
3/22/15 5.15(f)
FERC Director's Determination on
Disputes/Amendments
4/21/15 5.15(f)
AEA File Preliminary Licensing Proposal 4/14/15 5.16(a)
All stakeholders Preliminary Licensing Proposal
Comments Due
7/13/15 5.16(e)
AEA File Final License Application26 9/11/15 5.17
26 The timeline from the filing of the application forward assumes that a complete
application is filed with the Commission and no additional information is required to
process the application.
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APPENDIX B
ENTITIES THAT FILED WRITTEN SCOPING COMMENTS
In addition to the comments received at the scoping meetings, the following
entities filed written comments on SD1:
Entity Date Filed
Knikatnu, Inc.March 27, 2012
Wayne Mushrush March 28, 2012
Laborers’ International Union of North America – Local 341 March 28, 2012
Cathy Giessel March 28, 2012
Athna, Inc.March 28, 2012 and
May 16, 2012
Cathy Teich
March 28 & 30, 2012,
May 15, 21, and 25,
2012
Greg Campbell April 2, 2012
Anne Kahn April 2, 2012
Ivan Chikigak-Steadman April 2, 2012
Susan Olsen April 3, 2012
Paul B. Theodore, Knik Chief April 4, 2012
Richard G. Wilson April 4, 2012
David Rohwer April 5, 2012
Alaska Ratepayers, Inc.April 5, 2012
Jerry Gallegher April 5, 2012
Linda Rutledge March 28, 2012 and
April 6, 2012
Unnamed April 6, 2012
United Cook Inlet Drift Association April 9, 2012
Lynden Inc.April 12, 2012
Shannon Cartwright April 14, 2012
Beth Pike April 15, 2012
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Bob Doyle April 16, 2012
Anne Kilkenny April 17, 2012
Gary L. Fandrei April 18, 2012
Carly Wier April 20, 2012
Harden Mebone April 23, 2012
Steve Denton April 23, 2012
Michael Raffaeli April 23, 2012
Carlise Doria April 26, 2012
Douglas McIntosh April 26, 2012
Charlie Bussell April 27, 2012
Steve Estes April 27, 2012
Laura Caillet April 27, 2012
Doyon Limited May 1, 2012
William Nye May 7. 2012
Robert H. Weaver May 7, 2012
Karin Landsberg May 7, 2012
Richard Herron May 7, 2012
Jeff Lebegue May 7, 2012
Savuth Chhin May 7, 2012
Janie Kirk May 7, 2012
Robert Thompson May 7, 2012
Frank Abegg May 7, 2012
Chickaloon Village Traditional Council May 8, 2012
Kevin Foster May 9, 2012
U.S. Geological Survey May 9, 2012
Katherin Erickson May 14, 2012
Roger Perry May 14, 2012
Will Elliott May 14, 2012
Lance Roberts May 14, 2012
Audobon Bakewell May 14, 2012
Galen Johnston May 14, 2012
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Denis Ransy May 14, 2012
Katie Writer March 28, 2012 and
May 15, 2012
Trenton Rieley-Gibbons May 16, 2012
Jeralyn Hath May 16, 2012
Jonathan F. Durr May 16, 2012
Charles and Linda Rutledge May 17, 2012
Judith Fisher May 21, 2012
John Polonowski May 21, 2012
Randi Gryting May 21, 2012
Robin Song May 21, 2012
John Strasenburgh May 21, 2012
Deborah Teich May 21, 2012
Sarah Radonich May 22, 2012
Jeff Benowitz May 22, 2012
Talkeetna Airmen’s Association May 22, 2012
Robert Gerlach May 22, 2012
Sarah Birdsall May 23, 2012
William Barstow May 23, 2012
Sean Bujold May 24, 2012
Mike Sheehan May 24, 2012
National Park Service, Alaska Region May 25, 2012
Chris Noonan May 25, 2012
Coalition for Susitna Dam Alternatives & Alaska Survival May 25, 2012
Dan Dunn May 25, 2012
Charles Renick May 29, 2012
Becky Long May 29, 2012
Clyde W. Lovel, Jr.May 29, 2012
Jennifer Peters May 29 & 30, 2012
Sandra White-Loomis May 29, 2012
Matt Clabaugh May 29, 2012
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Shawn Murray May 29, 2012
James Trussell May 29, 2012
Tony Crocetto May 29, 2012
Marybeth Holleman May 29, 2012
Cari (Carolyn) Sayre May 29, 2012
Coley Gentzel May 29, 2012
Shelley Plumb May 29, 2012
Jeff Yarman May 30, 2012
Shelley Campbell May 30, 2012
Joe Page May 30, 2012
Alaska Departments of Natural Resources, Environmental
Conservation, and Fish and Game May 30, 2012
Barbara A. Mercer May 30, 2012
James Trump May 31, 2012
David H. Holmquist May 31, 2012
Kathy Trump May 31, 2012
Francis Marvin Milam May 31, 2012
National Wildlife Federation May 31, 2012
Ed Yadon May 31, 3012
John Schandelmeier May 31, 2012
Felicia Riede May 31, 2012
Stefanie Tatalias May 31, 2012
Copper Country Alliance May 31, 2012
Natural Resources Defense Council May 31, 2012
Murray Nash May 31, 2012
Cedar Cussins May 31, 2012
Heather Collins May 31, 2012
Deborah A. Brocke May 31, 2012
Matt Kaso May 31, 2012
Robert Gordy Vernon May 31, 2012
Sheryl Salasky May 31, 2012
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National Marine Fisheries Services May 31, 2012
Sean Fitzgerald May 31, 2012
Center for Water Advocacy May 31, 2012
The Nature Conservancy May 31, 2012
Alaska Department of Natural Resources Division of Mining
and Land May 31, 2012
Trout Unlimited May 31, 2012
U.S. Fish and Wildlife Service May 31, 2012
Daniel Rauchenstein May 31, 2012
Elaine Martin May 31, 2012
American Whitewater May 31, 2012
U.S. Bureau of Land Management May 31, 2012
RicardoErnst June 1, 2012
Kathleen Fleming June 1, 2012
William J FitzGerald June 1, 2012
U.S. Army Corps of Engineers June 1, 2012
Noelle Carbone June 1, 2012
Kinross Fort Knox June 1, 2012
Cari Sayre June 1, 2012
Mark B Butler June 1, 2012
Kathy Ungrodt Ernst June 1, 2012
Whitney Wolff June 1, 2012
Talkeetna Community Council June 1, 2012
Knik Tribal Council June 1, 2012
Alaska Center For The Environment June 1, 2012
Chickaloon Native Village June 1, 2012
Chase Community Council June 1, 2012
Talkeetna Defense Fund June 1, 2012
Michael Wood June 1, 2012
Charlie Loeb June 1, 2012
David Theriault June 1, 2012
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Kathleen P Harms June 1, 2012
Vince Pokryfki June 1, 2012
Susan Deyoe June 1, 2012
Colby Coombs June 1, 2012
Laura Wright June 1, 2012
Mia Costello June 1, 2012
Lon McCullough June 1, 2012
Elisabeth Moorehead June 1, 2012
Niall McInerney June 1, 2012
Harry Brod June 1, 2012
Eleanor Fitzgerald June 1, 2012
U.S. Environmental Protection Agency June 1, 2012
Alexa FitzGerald June 1, 2012
Diane Calamar Okonek June 1, 2012
Doug Smith June 1, 2012
Shannon Salomaki June 4, 2012
Knik Tribal Council June 5, 2012
Representative Kyle Johansen June 7, 2012
Representative Mia Costello June 12, 2012
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