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Susitna-Watana Hydroelectric Project Document
ARLIS Uniform Cover Page
Title:
SuWa 229
Proposal to eliminate the Chulitna Corridor from further study
Author(s) – Personal:
Author(s) – Corporate:
Alaska Energy Authority
AEA-identified category, if specified:
September 17, 2014 technical memorandum filings
AEA-identified series, if specified:
Series (ARLIS-assigned report number): Existing numbers on document:
Susitna-Watana Hydroelectric Project document number 229
Published by: Date published:
[Anchorage, Alaska : Alaska Energy Authority, 2014] September 2014
Published for: Date or date range of report:
Volume and/or Part numbers:
Final or Draft status, as indicated:
Attachment A
Document type: Pagination:
2 p.
Related work(s): Pages added/changed by ARLIS:
Cover letter to this report: Susitna-Watana Hydroelectric
Project, FERC Project no. 14241-000; Initial filing of September
2014 technical memoranda. (SuWa 228)
Attachments B-J (SuWa 230-238)
Added cover letter
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/
September 17, 2014
Ms. Kimberly D. Bose
Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C. 20426
Re:Susitna-Watana Hydroelectric Project, Project No. 14241-000
Initial Filing of September 2014 Technical Memoranda
Dear Secretary Bose:
By letter dated January 28, 2014, the Federal Energy Regulatory Commission
(Commission or FERC) extended the procedural schedule for the preparation and review
of the Initial Study Report (ISR) for the proposed Susitna-Watana Hydroelectric Project,
FERC Project No. 14241 (Project).1 In particular, the Commission’s January 28 letter
established a deadline of June 3, 2014 for the Alaska Energy Authority (AEA) to file the
ISR, and provided a 120-day period for licensing participants to review the ISR prior to
the ISR meetings, which are scheduled to begin the week of October 13.2 The purpose of
this filing is to provide several technical memoranda to Commission Staff and licensing
participants prior to the ISR meetings.
As required by the Commission’s January 28 letter, AEA filed the ISR with the
Commission on June 3. Among other things, the ISR detailed AEA’s planned work
during the 2014 field season.3 As AEA was preparing this 2014 work plan, it recognized
that data gathered during the 2014 field season, together with other study work conducted
prior to the October 2014 ISR meetings,could assist Commission Staff, AEA, and other
licensing participants in developing the Project’s licensing study program for 2015. For
this reason, the ISR provided for AEA to prepare certain technical memoranda and other
information based on 2014 work.
AEA recognizes that Commission Staff and licensing participants need a
reasonable amount of time prior to the ISR meetings to review this additional
information. AEA and licensing participants consulted with Commission Staff on this
1 Letter from Jeff Wright, Federal Energy Regulatory Commission, to Wayne Dyok, Alaska Energy
Authority, Project No. 14241-000 (issued Jan. 28, 2014)[hereinafter, “January 28 letter”].
2 The full schedule for the ISR meetings appears in Section 1.5 of the ISR, as well as on AEA’s
licensing website, http://www.susitna-watanahydro.org/meetings/.
3 E.g., Initial Study Report §1.3 & Table 3, Project No. 14241-000 (filed June 3, 2014) [hereinafter,
“ISR”].
2
matter, and Staff directed that any additional information should be filed with the
Commission and made available to licensing participants no later than 15 days prior to
the ISR meetings, consistent with the typically applicable deadline under the
Commission’s Integrated Licensing Process regulations.4
With this letter, AEA is filing and distributing the first set of technical
memoranda and other information generated during the 2014 study season, as described
below. As part of its continued implementation of the study plan, AEA expects to file
certain additional technical memoranda prior to October 1, 2014, in accordance with
Commission Staff direction.
This first set of technical memoranda and other information consists of the
following:
Attachment A: Proposal to Eliminate the Chulitna Corridor from Further
Study. As explained in the ISR, throughout the licensing process AEA has
continually evaluated its proposal for Project development based on
environmental review, technical feasibility, practical considerations, and other
factors. As part of this iterative process, AEA notified the Commission and
licensing participants in the ISR that it was evaluating whether to continue
study of the Chulitna Corridor.5 Attachment A details AEA’s conclusion that
development of the Chulitna Corridor is not a reasonable alternative, and
therefore AEA proposes to eliminate the corridor from further study. AEA
seeks any comments or information on this proposal from federal and state
resource agencies and other participants in the licensing process.
Attachment B: Ice Processes in the Susitna River Study (Study 7.6),Detailed
Ice Observations October 2013 –May 2014 Technical Memorandum. The
ISR indicated that AEA would provide a summary of the 2014 break-up
observations.6 This technical memorandum describes all field activities and
observations between October 16, 2013 and May 15, 2014 for the Ice
Processes in the Susitna River Study (Study 7.6).
Attachment C: Study of Fish Distribution and Abundance in the Upper
Susitna River (Study 9.5), Proposed 2015 Modifications to Fish Distribution
and Abundance Study Plan Implementation Technical Memorandum. Based
on AEA’s experience in implementing the study plan for the Study of Fish
Distribution and Abundance in the Upper Susitna River (Study 9.5)during
2014, this technical memorandum proposes to continue certain modifications
to the implementation of this study during 2015.
4 See 18 C.F.R. §5.15(c)(2).
5 See ISR, ISR Overview §1.4.
6 See id., Ice Processes in the Susitna River Study,Study Plan 7.6, Part C §7.2.
3
Attachment D: Study of Fish Distribution and Abundance in the Middle and
Lower Susitna River Study (Study 9.6), 2013-2014 Winter Fish Study
Technical Memorandum. At the time the ISR was filed, AEA was still in the
process of conducting data entry, quality control, and analysis of winter
sampling for this study. AEA reported in the ISR that it would develop plans
for completing this study in a technical memorandum to be filed with the
Commission.7 This technical memorandum fulfills this commitment and sets
forth AEA’s proposal for winter efforts, including proposed methodologies
and modifications.
Attachment E: Characterization and Mapping of Aquatic Habitats (Study
9.9), 2013 and 2014 Aquatic Habitat Mapping Field Season Completion
Progress Technical Memorandum. In the ISR, AEA reported that its 2014
activities for the Characterization and Mapping of Aquatic Habitats Study
(Study 9.9) would consist of various ground-truthing surveys and collection of
habitat information for the 12 lakes within the potential reservoir inundation
zone.8 This technical memorandum reports on these activities.
Attachment F: Eulachon Run Timing, Distribution, and Spawning in the
Susitna River (Study 9.16), 2015 Proposed Eulachon Spawning Habitat Study
Modifications Technical Memorandum.After reviewing the 2013 and 2014
results from the Cook Inlet Beluga Whale Study (Study 9.17) and discussing
the results with the National Marine Fisheries Service, AEA has determined
that additional data are needed regarding eulachon spawning habitats. This
technical memorandum describes a proposed modification to the Study of
Eulachon Run Timing, Distribution and Spawning in the Susitna River (Study
9.16)to include an assessment of eulachon spawning habitats.
Attachment G: Fish and Aquatics Instream Flow Study (Study 8.5),
Evaluation of Relationships between Fish Abundance and Specific
Microhabitat Variables Technical Memorandum. Consistent with the
Commission’s study plan determination,9 this technical memorandum
provides a detailed evaluation of the comparison of fish abundance measures
with specific microhabitat variable measurements where sampling overlaps.
This memorandum is used to determine whether a relationship between a
specific microhabitat variable and fish abundance is evident.
Attachment H: Fish and Aquatics Instream Flow Study (Study 8.5), 2013-
2014 Instream Flow Winter Studies Technical Memorandum.In the ISR,
AEA reported that it would distribute its finding concerning the 2013-2014
7 See id., Study of Fish Distribution and Abundance in the Middle and Lower Susitna River Study,
Study Plan 9.6, Part C §7.1.2.5.
8 See id., Characterization and Mapping of Aquatic Habitats, Study Plan 9.9, Part C § 7.1.
9 See Study Plan Determination on 14 Remaining Studies for the Susitna-Watana Hydroelectric Project,
Appendix B at B-84 to B-86, Project No. 14241-000 (issued Apr. 1, 2013).
4
winter activities in 2014.10 This technical memorandum describes the
methods applied, and data and information collected, as part of the Instream
Flow Study 2013-2014 winter studies.
Attachment I: Geomorphology Study (Study 6.5), Susitna River Historical
Cross Section Comparison (1980s to Current) Technical Memorandum. As
specified in Revised Study Plan Section 6.5.4.1.2.3, this technical
memorandum describes changes within the main and side channels of the
Susitna River by comparing historical survey data from the 1980s with survey
data from the current Project.
Attachment J: Geomorphology Study (Study 6.5), 2014 Update of Sediment-
Transport Relationships and a Revised Sediment Balance for the Middle and
Lower Susitna River Segments Technical Memorandum. The purpose of this
technical memorandum is to update the sediment load rating curves and
preliminary estimates of the overall sediment balance in the Middle and
Lower River segments under pre-Project conditions that were initially
provided in “Development of Sediment-Transport Relationships and an Initial
Sediment Balance for the Middle and Lower Susitna River Segments,” (Tetra
Tech, Inc. 2013a). This update is based on additional data collected by the
U.S. Geological Survey in 2012 and 2013.
AEA appreciates the opportunity to provide this additional information to the
Commission and licensing participants, which it believes will be helpful in determining
the appropriate development of the 2015 study plan as set forth in the ISR. If you have
questions concerning this submission please contact me at wdyok@aidea.org or (907)
771-3955.
Sincerely,
Wayne Dyok
Project Manager
Alaska Energy Authority
Attachments
cc: Distribution List (w/o Attachments)
10 See ISR, Fish and Aquatics Instream Flow Study, Study Plan 8.5, Part C §7.5.2.
Susitna-Watana Hydroelectric Project
(FERC No. 14241)
Proposal to Eliminate the Chulitna Corridor
from Further Study
Prepared by
Alaska Energy Authority
September 2014
PROPOSAL TO ELIMINATE THE CHULITNA CORRIDOR
FROM FURTHER STUDY
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 1 Draft: September 2014
PROPOSAL TO ELIMINATE THE CHULITNA CORRIDOR
FROM FURTHER STUDY
The Alaska Energy Authority (AEA) is in the pre-application phase of a federal licensing process
before the Federal Energy Regulatory Commission (FERC) for the licensing of the Susitna-
Watana Hydro Project (Project). As part of this licensing process, AEA originally proposed and
has been evaluating three access and transmission corridors: the Gold Creek Corridor, which
would run south of the Susitna River and extend to the Gold Creek area; the Denali Corridor,
which would run due north for a distance of about 44 miles to the Denali Highway, with a
transmission line continuing east to connect near the community of Cantwell; and the Chulitna
Corridor, which would run north of the Susitna River and extend to the Chulitna rail siding area.
Throughout this licensing process, AEA has continued to evaluate and refine its Project proposal
and explore various options for its licensing and development. In its June 2014 Initial Study
Report (ISR), AEA explained that this continuing effort has led AEA to pursue the study of an
additional alternative north-south corridor alignment for transmission and access from the dam
site to the Denali Highway and the existing transmission line (Denali East Option). AEA also
explained that, in addition to the inclusion of the Denali East Option, it was investigating the
possibility of eliminating the Chulitna Corridor from further study.
As part of its continued evaluation of the Project, and based in part upon information obtained
through the licensing process, AEA is proposing to eliminate the Chulitna Corridor from further
detailed study. This AEA proposal is based primarily on a desire by AEA to avoid the need to
cross Indian River and Portage Creek subwatersheds. Adoption of the Chulitna Corridor would
require crossing Indian River and Portage Creek and paralleling Portage Creek for about 8 miles.
Both streams contain important anadromous salmon spawning and rearing habitat (as described
in Initial Study Report 9.13 (Salmon Escapement; http://www.susitna-watanahydro.org/wp-
content/uploads/2014/05/09.07_ESCAPE_ISR_PartA.pdf) and Initial Study Report 9.06 (Fish
Distribution and Abundance in the Middle Lower Susitna River; http://www.susitna-
watanahydro.org/wp-content/uploads/2014/05/09.06_FDAML_ISR_PartA_1_of_5.pdf)).In
addition, the Chulitna corridor would require the road and transmission line routes to be located
at higher elevations along more avalanche prone slopes than the other corridors and thus would
not provide as reliable access and transmission operations as the other corridors.
Based upon AEA’s proposal to eliminate the Chulitna Corridor from further consideration, AEA
is proposing additional modifications to the FERC approved Study Plan as part of the ISR
process under FERC’s Integrated Licensing Process. Specifically, AEA is proposing to modify
the study areas for Studies 4.5, 6.5, 9.13, 10.5, 10.8, 10.10, 10.11, 10.12, 10.14 –10.17, 10.19,
11,5, 11.7 –11.9, 12.5, 12.6, 13.5, 13.6, and 15.7 –15.9 from that described in the Revised
Study Plan. AEA is proposing to eliminate the Chulitna Corridor from the study area for those
PROPOSAL TO ELIMINATE THE CHULITNA CORRIDOR
FROM FURTHER STUDY
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 2 Draft: September 2014
studies. Furthermore, AEA proposes to not conduct any additional study activities within the
Chulitna Corridor for those studies.
AEA is making this proposal at this time in order to provide licensing participants and the
general public with the opportunity to comment on this proposal during the October ISR
meetings or during the ISR comment period.
AEA will continue to evaluate the remaining alternate corridors, and will propose preferred
access and transmission routes in the FERC license application. The ultimate proposal of
preferred routes will be made based upon a thorough evaluation of all relevant environmental
and engineering considerations, including, but not limited to: land ownership, potential
environmental (including socioeconomic and cultural) impacts, cost, and technical and
engineering feasibility. License participants and the public will have future opportunities to
comment on the alternative corridor routes after AEA proposes a preferred access and
transmission routes.