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Susitna-Watana Hydroelectric Project Document
ARLIS Uniform Cover Page
Title:
Instream flow study: fish, aquatics, and riparian, Study plan Section 8
introduction : Final study plan SuWa 200
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Alaska Energy Authority
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Final study plan
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Series (ARLIS-assigned report number):
Susitna-Watana Hydroelectric Project document number 200
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Published by:
[Anchorage : Alaska Energy Authority, 2013]
Date published:
July 2013
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Study plan Section 8
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5 p.
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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/
Susitna-Watana Hydroelectric Project
(FERC No. 14241)
Instream Flow Study: Fish, Aquatics, and Riparian
Study Plan Section 8 Introduction
Final Study Plan
Alaska Energy Authority
July 2013
Final Study Plan Instream Flow Resources Introduction
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 8-1 July 2013
8. INSTREAM FLOW STUDY: FISH, AQUATICS, AND RIPARIAN
8.1 Introduction
Project construction and operation will affect Susitna River flows downstream of the dam; the
degree of these effects will ultimately depend on final Project design and operating
characteristics. The Project will be operated in a load-following mode. Project operations will
cause seasonal, daily, and hourly changes in Susitna River flows compared to existing
conditions. The potential alteration in flows will influence downstream resources/processes,
including fish and aquatic biota and their habitats, channel form and function including sediment
transport, water quality, groundwater/surface water interactions, ice dynamics, and riparian and
wildlife communities (AEA 2011).
The potential operational flow-induced effects of the Project will need to be carefully evaluated
as part of the licensing process. This Final Study Plan (FSP) describes the Susitna-Watana
Instream Flow Study (IFS) that will be conducted to characterize and evaluate these effects. The
plan includes a statement of objectives, a description of the technical framework that is at the
foundation of the IFS, the general methods that will be applied, and the study nexus to the
Project. This plan will be subject to revision and refinements as part of the Technical Workgroup
(TWG) review and comment process identified as part of the Integrated Licensing Process (ILP).
Pursuant to the standards, schedule, and process described below, these details will be developed
in consultation with the TWG as part of the continuing study planning process and during study
implementation.
The FSP has benefitted from formal written comments submitted to the Federal Energy
Regulatory Commission (FERC) from Proposed Study Plan (PSP) filing (July 16, 2012) through
submittal of Interim Draft RSPs (October 31, 2012), formal comment letters filed with FERC
between November 1 and 14, 2012 (see Section 8.4), comment letters on the Revised Study Plan
(RSP) filed with FERC December 2012, and the FERC Study Plan Determination. In addition,
comments and suggestions were provided during the study plan development at eight agency and
licensing participant TWG meetings that were conducted to describe various elements of the
proposed studies. These meetings were conducted in 2012 on January 1, March 2, April 5, June
13, August 16, September 14, October 2, and October 24 and included specific discussions on
study area selection, methods and models, and linkages with other resource studies. Detailed
notes were recorded during each of these meetings that highlighted action items and/or technical
issues and comments that were considered in the RSP. A one-and-one-half-day field
reconnaissance was also conducted with the agencies on October 3–4, 2012, to visit three of the
proposed study areas (termed Focus Areas (Focus Areas)—see Section 8.5.4.2.1.2) and discuss
sampling methodologies. These agency interactions, coupled with direct communications via e-
mail and telephone, and FERC study plan requests have all contributed to refinements in the
individual study plans. Even so, as noted above and depicted in the IFS schedule (see Section
8.5.6), refinements will continue to be made to the plan as more information from this and other
interdependently-linked studies is collected and evaluated.
Final Study Plan Instream Flow Resources Introduction
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 8-2 July 2013
8.2 Nexus Between Project Construction / Existence / Operations
and Effects on Resources to be Studied
As described above, the operational strategy of the Project could result in a variety of flow
responses to the river below Watana Dam. These may include seasonal, daily, and hourly
changes in river stage that would vary longitudinally along the river. Having a clear
understanding of Project effects on instream flow and riparian habitats and biological resources
present within the Susitna River corridor will be critical to environmental analysis of the Project.
8.3 Resource Management Goals and Objectives
Several natural resources agencies have jurisdiction over aquatic species and their habitats in the
Project area. These agencies will be using, in part, the results of the IFS and other fish and
aquatic studies to satisfy their respective mandates. The federal and state agencies and Alaska
Native entities mentioned below have identified their resource management goals, or provided
comments in the context of FERC licensing related to instream flow and riparian resource issues.
8.3.1 National Marine Fisheries Service
The following text is an excerpt of the May 31, 2012, National Marine Fisheries Service (NMFS)
letter and Instream Flow Study Request:
NMFS has authority to request water quality and other natural resource studies related
to the project pursuant to the: Magnuson-Stevens Fishery Conservation and Management
Act, as amended by the Sustainable Fisheries Act of 1996 (Public Law 104-267),
National Environmental Policy Act (NEPA) of 1969 (83 Stat. 852; 42 U.S.C. §4321 et
seq.), Endangered Species Act (ESA) of 1973 (87 Stat. 884, as amended; 16 U.S.C. §1531
et seq.), Bald and Golden Eagle Protection Act (BGEPA) (54 Stat. 250, as amended, 16
U.S.C. §668a-d), Migratory Bird Treaty Act (MBTA) (40 Stat. 755, as amended; 16
U.S.C. §703 et seq.), Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16
U.S.C. §661 et seq.), and Federal Power Act (16 U.S.C. § 91 et seq.).
Under Section 18 of the FPA, NMFS and the USFWS have authority to issue mandatory
fishway prescriptions for safe, timely, and effective fish passage. Under Section 10(j) of
the FPA, NMFS and USFWS are authorized to recommend license conditions necessary
to adequately and equitably protect, mitigate damages to, and enhance, fish and wildlife
(including related spawning grounds and habitat) affected by the development, operation,
and management of hydropower projects. Section 10(a)(1) of the FPA requires FERC to
condition hydropower licenses to best improve or develop a waterway or waterways for
the adequate protection, mitigation, and enhancement of fish and wildlife (including
related spawning grounds and habitat) based on NMFS and Service recommendations
and plans for affected waterways. Therefore, one of the resource management goals of
NMFS is to inform development of fishway prescriptions for this project pursuant to
Section 18 of the FPA.
A number of Federal regulations address the need to protect and preserve fish and
wildlife resources and their habitats, including preventing the “take” of certain species
(or groups of species). The following is a list of some of the most important of these
Final Study Plan Instream Flow Resources Introduction
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 8-3 July 2013
regulations which are applicable or may be applicable to the proposed license
applications:
• Federal Power Act
— FERC is required to give equal consideration to “protection,
mitigation of damage to, and enhancement of, fish and wildlife
(including spawning grounds and habitat).”
• Magnuson-Stevens Fishery Conservation Act
— Magnuson-Stevens Fishery Conservation and Management Act, as
amended by the Sustainable Fisheries Act of 1996 (Public Law
104-267), established a new requirement to describe and identify
EFH in each fishery management plan. The EFH provisions of the
MSA (§305(b)) require federal agencies to consult with NMFS on
all actions, or proposed actions, authorized, funded, or undertaken
by the agency, that may adversely affect EFH
• Fish and Wildlife Coordination Act
— Requires equal consideration and coordination of wildlife
conservation with other water resources development programs.
• National Environmental Policy Act
— Requires evaluation of project alternatives, cumulative effects.
• Endangered Species Act
— Section 7(a)(2) requires Federal agencies to ensure that their
activities are not likely to jeopardize the continued existence of
listed species or adversely modify designated critical habitat.
• Anadromous Fish Conservation Act
8.3.2 U.S. Fish and Wildlife Service
The following text is an excerpt of the May 31, 2012, U.S. Fish and Wildlife Service (USFWS)
Instream Flow Study Request:
The U.S. Fish and Wildlife Service (USFWS), U.S. Department of Interior, has authority
to request fish and wildlife resources studies related to this project pursuant to:
The National Environmental Policy Act (NEPA) of 1969 (83 Stat. 852; 42 U.S.C. 4321 et
seq.), the Endangered Species Act (ESA) of 1973 (87 Stat. 884, as amended; 16 U.S.C.
1531 et seq.), the Bald and Golden Eagle Protection Act (BGEPA) (54 Stat. 250, as
amended, 16 U.S.C. 668a-d), the Migratory Bird Treaty Act (MBTA) (40 Stat. 755, as
amended; 16 U.S.C. 703 et seq.), the Fish and Wildlife Coordination Act (48 Stat. 401, as
amended; 16 U.S.C. 661 et seq.), and the Federal Power Act (16 U.S.C. § 791 et seq.).
Under Section 18 of the Federal Power Act (FPA), the National Marine Fisheries Service
(NMFS), U.S. Department of Commerce and the USFWS have authority to issue
mandatory fishway prescriptions for safe, timely, and effective fish passage. Under
Final Study Plan Instream Flow Resources Introduction
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 8-4 July 2013
Section 10(j) of the FPA, NMFS and USFWS are authorized to recommend license
conditions necessary to adequately and equitably protect, mitigate damages to, and
enhance, fish and wildlife (including related spawning grounds and habitat) affected by
the development, operation, and management of hydropower projects. Section 10(a)(1) of
the FPA requires FERC to condition hydropower licenses to best improve or develop a
waterway or waterways for the adequate protection, mitigation, and enhancement of fish
and wildlife (including related spawning grounds and habitat) based on NMFS and
USFWS recommendations and plans for affected waterways.
Consistent with our mission and with the legal authorities described above, our resource
goal in this matter is to conserve existing fish and wildlife resources and their habitats in
the Susitna River basin. With regard to fish passage, we will recommend scientifically-
based and coordinated studies, collaborate with others, and ensure development of the
best information possible to inform potential development of fishway prescriptions for
this project pursuant to Section 18 of the Federal Power Act.
8.3.3 Alaska Department of Fish and Game
The following text is an excerpt of the May 30, 2012, ADF&G letter and Instream Flow Study
Request:
The Fish and Game Act requires the Alaska Department of Fish and Game to, among
other responsibilities, “…manage, protect, maintain, improve, and extend the fish, game
and aquatic plant resources of the state in the interest of the economy and general well-
being of the state” (AS 16.05.020).
8.3.4 Alaska Native Entities
8.3.4.1. Chickaloon Village Traditional Council
The Chickaloon Native Village provided comments on Project licensing activities in a May 31,
2012, letter to the FERC. Chickaloon Native Village is a federally recognized Alaska Native
tribe. Chickaloon Village is an Ahtna Athabascan Indian Tribe governed by the nine-member
Chickaloon Village Traditional Council. The Chickaloon Village Traditional Council strives to
increase traditional Ahtna Dene’ practices for the betterment of all residents in the area.
Preserving and restoring the region’s natural resources is one way of supporting Ahtna culture
and the regional ecosystem.
8.4 Summary of Consultation with Agencies, Alaska Native
Entities, and Other Licensing Participants Regarding Revised
Study Plan Development
Input regarding the issues to be addressed in the IFS has been provided by the TWG during
workgroup meetings commencing in late 2011. During 2012, workgroup meetings were held in
January, March, April, June, August, September, and October, during which resource issues
were identified and discussed and objectives of the instream flow studies were defined. A one-
and-one-half day field reconnaissance was also conducted in October 2012 with agency
representatives to tour three of the proposed Focus Areas and discuss riparian, groundwater, and
Final Study Plan Instream Flow Resources Introduction
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 8-5 July 2013
fish habitat sampling and modeling. In addition, agency interactions via e-mail and telephone
contributed to refinements in the IFS. Various agencies and other parties (USFWS, NMFS,
ADF&G, etc.) provided written comments specific to this study that have been considered and
will be addressed as part of this plan. Summary tables of comments and responses from formal
comment letters filed with FERC through November 14, 2012 were provided in RSP Appendix 1
filed December 14, 2012. Copies of the formal FERC-filed comment letters were included in
RSP Appendix 2. In addition, a single comprehensive summary table of comments and responses
from consultation, dated from PSP filing (July 16, 2012) through release of Interim Draft RSPs,
was provided in RSP Appendix 3. Copies of relevant informal consultation documentation were
included in RSP Appendix 4, grouped by resource area.
Consultation subsequent to the filing of the Revised Study Plan (RSP) is described within each
Final Study Plan (FSP).