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Susitna-Watana Hydroelectric Project Document
ARLIS Uniform Cover Page
Title:
SuWa 288
[FERC eSubscription to Docket 14241, Susitna-Watana Hydroelectric
Project]
Author(s) – Personal:
Author(s) – Corporate:
United States. Federal Energy Regulatory Commission (in addition to various parties and
individuals)
AEA-identified category, if specified:
AEA-identified series, if specified:
Series (ARLIS-assigned report number): Existing numbers on document:
Susitna-Watana Hydroelectric Project document number 288 Each document is individually
numbered.
Published by: Date published:
[2014]- First document is dated April 29,
2014.
Published for: Date or date range of report:
Volume and/or Part numbers:
Final or Draft status, as indicated:
Document type: Pagination:
Correspondence, legal, etc. multiple documents
Related work(s): Pages added/changed by ARLIS:
Notes:
Distributed through registration obtained on the FERC Online website. Each document is emailed
to subscribers. The subscription began with a document dated April 29, 2014.
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/
20121231-3016
FEDERAL ENERGY REGULATORY COMMISSION
WASHINGTON, DC 20426
December 31, 2012
OFFICE OF ENERGY PROJECTS
Project No. 14241-000—Alaska
Susitna-Watana Hydroelectric Project
Alaska Energy Authority
Wayne Dyok
Susitna-Watana Project Manager
Alaska Energy Authority
813 West Northern Lights Boulevard
Anchorage, AK 99503
Reference: Revised Study Plan Determination Schedule
Dear Mr. Dyok:
On December 14, 2012, Alaska Energy Authority (AEA) filed its revised study
plan for the Susitna-Watana Project No. 14241 as required by the Federal Energy
Regulatory Commission’s (Commission’s) regulations for the Integrated Licensing
Process. The revised study plan includes 58 individual studies that AEA proposes to
implement to study environmental resources that may be affected by the project.
Commission staff have reviewed the revised study plan and conclude that, of the
58 studies, 45 contain sufficient detail such that the Commission’s study plan
determination (SPD) on those studies can be completed by February 1, 2013, as set forth
in the September 17, 2012, “Notice of Extension of Time To File Comments On AEA’s
Proposed Study Plan.” However, the remaining 13 studies, which are related to water
resources, instream flows, and fish and aquatic resources, contain insufficient detail.
Therefore, I am modifying the SPD schedule for those studies, pursuant to section
5.29(f)(2) of the Commission’s regulations.
In the 13 studies, AEA only provides conceptual details on sampling methods,
techniques, analytical approaches, and study site selection (e.g., focus areas). AEA
proposes to refine and finalize these details by March 15, 2013, after selecting focus areas
and after reviewing the results of open-water flow routing model and initial habitat
mapping efforts that will be completed in December 2012.
20121231-3016 FERC PDF (Unofficial) 12/31/2012
2
These study details are integral to determining whether the studies would gather
the needed information to process AEA’s license application. Consequently, these study
details must be finalized prior to the Commission issuing its SPD. Therefore, in order to
allow AEA sufficient time to develop these details, AEA must file by March 15, 2013,
the following additional information: (1) the implementation plans described in section
9.5.4 of study 9.5, Study of Fish Distribution and Abundance in the Upper Susitna River;
section 9.6.4 of study 9.6, Study of Fish Distribution and Abundance in the Middle and
Lower Susitna River; and section 9.8.4 of study 9.8, River Productivity Study; and (2) the
final site selection for focus areas for all studies to be implemented in the middle and
lower Susitna River (study 5.5, 5.6, 5.7, 6.5, 6.6, 7.5, 7.6, 8.5, 8.6, 9.6, 9.8, and 9.9).
Furthermore, because the results of the open-water flow routing model and initial habitat
mapping will be important in developing the above details, these study results must be
filed with the Commission by January 21, 2013, and a meeting must be held with
interested stakeholders by February 15, 2013, to discuss the study results, the proposed
implementation plans, and the selected focus areas.
By copy of this letter, interested stakeholders are notified of the modification to
the process schedule described in Attachment A, and that comments on the 45 other study
plans included in AEA’s December 14, 2012, revised study plan, are still due by January
18, 2013. The Commission’s study plan determination for these 45 studies is scheduled
to be issued by February 1, 2013. Agencies with mandatory conditioning authority
pursuant to sections 4(e) and 18 of the Federal Power Act or under section 401 of the
Clean Water Act may file a notice of study dispute on the Commission’s determination
on any of these 45 studies relating to their mandatory conditioning authority within 20
days of the study plan determination. The initial and updated study reports for all studies
are still due February 3, 2014, and February 2, 2015, respectively.
If you have any questions, please contact David Turner at (202) 502-6091.
Sincerely,
Jeff Wright
Director
Office of Energy Projects
Enclosure:Attachment A—Revised Study Plan Determination Schedule for
December 14, 2012, revised study plan studies 5.5, 5.6, 5.7, 6.5, 6.6, 7.5,
7.6, 8.5, 8.6, 9.5, 9.6, 9.8, and 9.9.
cc:Mailing List
Public Files
20121231-3016 FERC PDF (Unofficial) 12/31/2012
3
ATTACHMENT A
REVISED STUDY PLAN DETERMINATION SCHEDULE FOR
DECEMBER 14, 2012, REVISED STUDY PLAN STUDIES 5.5, 5.6, 5.7, 6.5, 6.6,
7.5, 7.6, 8.5, 8.6, 9.5, 9.6, 9.8, and 9.9.
A study plan determination will be issued for the following studies in accordance
with the schedule below: (1) Baseline Water Quality (study 5.5), (2) Water Quality
Modeling Study (study 5.6), (3) Mercury Assessment and Potential for Bioaccumulation
Study (study 5.7), (4) Geomorphology Study (study 6.5), (5) Fluvial Geomorphology
Modeling Below Watana Dam Study (study 6.6), (6) Groundwater Study (study 7.5), (7)
Ice Processes in the Susitna River Study (study 7.6), (8) Fish and Aquatics Instream Flow
Study (study 8.5), (9) Riparian Instream Flow Study (study 8.6), (10) Study of Fish
Distribution and Abundance in the Upper Susitna River (study 9.5), (11) Study of Fish
Distribution and Abundance in the Middle and Lower Susitna River (study 9.6), (12)
River Productivity Study (study 9.8), and (13) Characterization and Mapping of Aquatic
Habitats (study 9.9).
Shaded milestones are unnecessary if there are no study disputes filed by any agency with
mandatory conditioning authority. If a due date falls on a weekend or holiday, the due
date is the following business day.
Responsible
Party
Pre-Filing Milestone Date FERC
Regulation
AEA AEA files results of open-water flow
routing model and habitat mapping.
January 21, 2013 N/A
AEA AEA holds meeting to discuss the study
results, proposed implementation plans,
and selected focus area sampling sites in
the middle and lower Susitna River.
February 15,
2013
N/A
AEA AEA files studies 9.5 and 9.6, Fish
Distribution and Abundance
Implementation Plan; study 9.8, River
Productivity Implementation Plan; and
description of final site selection for any
focus areas in the middle and lower
Susitna River as described in study 8.5
March 15, 2013 5.13(a)
waived
20121231-3016 FERC PDF (Unofficial) 12/31/2012
4
(including studies 5.5, 5.6, 5.7, 6.5,
6.6, 7.5, 7.6, 8.5, 8.6, 9.6, 9.8, and 9.9).
All Stakeholders Revised Study Plan Comments Due for
studies 5.5, 5.6, 5.7, 6.5, 6.6, 7.5, 7.6,
8.5, 8.6, 9.5, 9.6, 9.8, and 9.9.
April 14, 2013 5.13(b)
waived
FERC Director’s Study Plan Determination for
studies 5.5, 5.6, 5.7, 6.5, 6.6, 7.5, 7.6,
8.5, 8.6, 9.5, 9.6, 9.8, and 9.9.
May 14, 2013 5.13(c)
waived
Mandatory
Conditioning
Agencies only
Any Study Disputes Due for studies 5.5,
5.6, 5.7, 6.5, 6.6, 7.5, 7.6, 8.5, 8.6, 9.5,
9.6, 9.8, and 9.9.
June 3, 2013 5.14(a)
Dispute Panel Third Dispute Panel Member Selected June 18, 2013 5.14(d)
Dispute Panel Dispute Resolution Panel Convenes June 23, 2013 5.14(d)(3)
AEA Applicant Comments on Study Disputes
Due June 28, 2013
5.14(i)
Dispute Panel Dispute Resolution Panel Technical
Conference July 3, 2013
5.14(j)
Dispute Panel Dispute Resolution Panel Findings Issued July 23, 2013 5.14(k)
FERC Director's Study Dispute Determination August 12, 2013 5.14(l)
20121231-3016 FERC PDF (Unofficial) 12/31/2012
20140507-0008
The following letter was received from FERC on May 7.
Ascension number 20140513-0201 has the same letter, but is clearer.
Apiil 29,2014
Subject:
Reference:
..Deir Mr.Johnson:
Mr.Douglas L.Jo&~~on,P.E.;.".Pr
FEDERAL ENERGY::RB1GULATORY COMMISSION -'::,:,':,':-io
805 S.W.Brea)d)way,Suite 550
Portland,Ore1gon)97205:
Board of Consul~~t Meetl'YIII ~4
.Susitna-Wa~)a Hj4me1ec~c ProJect
P-14241-Ag,.'/A
Letty to Willi~H-.Allerton,,P.E.Gled):¹v~~bcr l6,2012:
'4
)
5""-"::Iitl
)'))
r
The BOC a}pfAsl &~at.lf the pllss+ed site),lIlvcsklgaflon:pro~'c~RI ares tlllt thee are':nio shears
bcsng oondus-;M and pleated)are zeiIson)able and appa'upiiate for detaR i~&ng @ejectfleas&Qty
aud to !wive as a basis for furuaer design evalu~wo)n and ~~s~ation,
1)
e SSSHA stgdies Iver '1inerl~~ents plioba1billstics 'and 'defRiIiinisgc sel~ic &~abri analyses and
are detailed enough)to provide pLels~iriar deign ground omti iolksr fbi pR~cgt.Senaigyjty
analyses show t&sst Baither analysis of reg1iona1 crustal »&ce~ents will not si~sficantly1ssY1eact.the
design @ound n|otions ii the p ei rdo)ra)nge)of sient6cant ~N~resyo)ate.Howler,fifrfher analyzs
of site area &ssLe~~cets and angled drill holes are necessaiy'o jgsess pot1entlal fo)r.fiLult rupture
under.the dNRYs as a result of pi:~a)iy,recon)~~~,"or sym)p)ithetic Selt displaccERR
The BQC agr Slat the PMF infiow hydiogmph prcecnted in the dry PMp ~op rep~Rents
generally appsopR)-ia)te assmYIptions)and modeling,methodologies'and:4e study is sLLfRciently
)~I
1~3~&~gj~UyWlcI I M A~%or~,+~~9eSOS TN7.V).SON VollheeyeastIOnlg Mern%}~p%y.yyq.~~
20140507-0008 FERC PDF (Unofficial) 05/07/2014
Mr.Jo&~~on,P.H.
Page 2 of 2
complete to be used in feasibility d.esign.
The proposed and pl~nod Site Investigation Program for the project cntails a phased series of
field jnvestigations that respond to several of the BOC co~ments and cone=.res.The primary
focus of the progr~*-.is to characterize and confi=~the geologiclgeotec&~Heal conditions in the
d~~site area The main objectives include;1)investigation and verification of the &acture and
she~~zones and geologic features,2)evaluation of the potential for offset displac:ents in the
foundation due to earthquake motions;3)de»~cation of the erozen ground and groundwater
conditions (adits)and 4)evaluation of the abutment stability.The BOC considers the present
detailed and phased site investigation appropriate for developing the data for supportmg the
feasibility and design of the da~.
Attached are the BOC Final Report 54,the BOC Fin&Report@4 mth ABA responses aud the
BOC Corn~cat Log for meetIn~lP,8.3 with BOC co~~eats.
I
Thank you for your assistance and plea~+let me know if there is anythmg else you need
i l.
Bryan Carey,-P.E.
Egp&eegkag Manager
Mr.Wayne,Dyok,P.B.,Alaska &clergy Authority,Susitna-%stan'roject Manager
Attached DlsiiibutlOn L18t
The attachIInents aie being made publicly available by diplo~&&g than to the
"Dom~ents"page of A/A's lice~~~~g website,
http:llwivw.susitnawitanahvdro.oriattvoeldoc~ents.
Attac&~,ants:BOC Final Report N,4
BGC Final Report g4 with AHA Resyonses
BOC Co~~eat Log for MeeLingi 1,.2 8'c 3 with BGC Co~~ants
20140507-0008 FERC PDF (Unofficial) 05/07/2014
20140513-0201
~ENERGY AlJTHORITY
April 29,2014
Mr.Douglas L.Johnson,P.E.
FEDERAL ENERGY REGULATORY COMMISSION
Regional Engineer,Portland Regional Office
Division of Dam Safety and Inspections
805 S.W.Broadwa,Suite 550
Portland,Oregon 97205
Subject:Board of Consultant Meeting ¹4
Susitna-Watana Hydroelectric Project P-14241-AK
FEDERAL ENERGY
REGULATORY COMMISSION
MAY 6 2014
PORTLAND
REGIONAL OFFICE
Reference:AEA Letter to William H.Allerton,P.E.filed November 16,2012
Dear Mr.Johnson:
The fourth Susitna-Watana Hydroelectric Project Independent Board of Consultants (BOC)
meeting was held April 24,2014 in Bellevue,Washington at the office of MWH Global Inc.
The purpose of the meeting was to update and solicit advice from the BOC and advisors on
the status of the Probable Maximum Precipitation (PMP)and Probable Maximum Flood
(PMF)studies,the Site Specific Seismic Hazards Analysis studies,and the 2014 geotechnical
investigation program plans.The progress of the RCC dam configuration feasibility and
design studies was presented and discussed.A summary of the Boards comments follows.
The BOC agrees that if the planned site investigation program confirms that there are no shears,
linear features or faults found that can negatively affect the performance of the dam,the
configuration of the dam would be acceptable as a basis for further design evaluation,analysis
and license application.The Site Specific Seismic Hazard Analysis (SSSHA)studies that are
being conducted and presented are reasonable and appropriate for determining project feasibility
and to serve as a basis for further design evaluation and optimization.
The SSSHA studies cover lineament,probabilistic,and deterministic seismic hazard analyses and
are detailed enough to provide preliminary design ground motions for the prcjee.Sensitivity
analyses show that further analysis of regional crustal lineaments will not significantly impact the
design ground motions in the period range of significant dam response.However,further analysis
of site area lineaments and angled drill holes are necessary to assess potential for fault rupture
under the dam as a result of primary,secondary,or sympathetic fault displacement.
The BOC agrees that the PMF inflow hydrograph presented in the drafi PMF report represents
generally appropriate assumptions and modeling methodologies and the study is sufficiently
813 West Northern Ughts goo lerard Anchorage,Alaska yymk T 807 771 3000 Tog gree lAlaska Only)888 300 8334 7 407 771.3044
20140513-0201 FERC PDF (Unofficial) 05/05/2014
Mr.Johnson,P.E.
Page 2 of 2
complete to be used in feasibility design.
The proposed and planned Site Investigation Program for the project entails a phased series of
field investigations that respond to several of the BOC comments and concerns.The primary
focus of the program is to characterize and confirm the geologic/geotechnical conditions in the
dam site area.The main objectives include;1)investigation and verification of the fracture and
shear zones and geologic features,2)evaluation of the potential for offset displacements in the
foundation due to earthquake motions;3)delineation of the frozen ground and groundwater
conditions (edits)and 4)evaluation of the abutment stability.The BOC considers the present
detailed and phased site investigation appropriate for developing the data for supporting the
feasibility and design of the dam.
Attached are the BOC Final Report ¹4,the BOC Final Report ¹4with AEA responses,and the
BOC Comment Log for meetings 1,2,8'ith BOC comments.
Thank you for your assistance and please let me know if there is anything else you need.
Sincerely,
Bryan Carey,P.E.
Engineering Manager
Mr.Wayne Dyok,P.E.,Alaska Energy Authority,Susitna-Watana Project Manager
Attached Distribution List
The attachments are being made publicly available by uploading them to the
"Documents"page of AEA's licensing website,
httn://www.susitnawatanahvdro.ore/tvoe/documents.
Attachments:BOC Final Report ¹4
BOC Final Report ¹4with AEA Responses
BOC Comment Log for Meetings 1,2 8:3 with BOC Comments
20140513-0201 FERC PDF (Unofficial) 05/05/2014
Al Jh:~~ENERSV AUTHOINY
Joseph Ehasz
URS Ccrpcnmca
1632 San Pablo Drive
San Marcus,CA 92078
916.8353200
Joseck.ehsszCdurs.corn
Yusof Ghanaat
3 Altsrinds Road
Suite 203
Grinds,CA 94563
925.2533555
vxhanaxtmOucstStrccturcs.corn
Alfied J.Hendron,Jr.
P.O.Box 125
4 College Park Court
Savoy,IL 61874
217.493.9701
Mahccclkcarth link.net
Brian Forbes
GPO Box 668
Brisbane 4001,Austndis
s61.79316.3601
brian.forbes(Rshd.corn
George Taylor
5478 SW Philomath Blvd
Corvallis,OR 97333
5412073448
tavlorab(kccmcast.act
Ellen Faulkner
3433 Oakwood Xllls Pkwy
Eau Claire,Wl 54701
715.834.3161
FsulkncrEtRAvresAssocistes.corn
April 4,2014
Mr.Bryan Carey
Engineering Manager
Alaska Energy Authority
813 West Northern Lights
Anchorage,Alaska 99503
Sahject:Susitua-Watmm Dam Project (Project ¹P-1424&NO)
Jndependent Board of Consultants and Advhmtu
Meeting Nsx 4-Aprg 2 -4,2014 -Begevne,WA
Dear Mr.Carey:
JNFrurfucfruN
The Fourth Meeting of the Independent Bend of Consultants (BOC)was held in Bellevue,Washington
during April 2,3 and 4,2014 at the offices of MWH.Wifliam Lettis of Lettis Consultants
International was added to the Project as the seismic geology expert and advisor to the BOC.The
purpose of the meeting was to updass thc BOC on the status of thc PMP and PMF studies,the Site
Specific Seismic Hazards Analysis studies,as well as the 2014 gcotechnical investigation progcam plans.
Tbe Pcotpsuu of the RCC dam conflgurattou feasibility and design studies was pnxented and discussed in
detail.The following Rcport nuponds to the AEA Questions posed to the Baud as well as presents
additional considerations mgarding seismic geology,fault ruptmu hazards and Stand motions for the
Materials were distributed to the Board in advance for their review.The meeting was conducted in
general accordance with the attached agenda as Attachment A.The list of attendees that attended the
meetings is attached as Attachment B.
The AEA Susitna BOC Comment Log that was dislributed to the Board was discussed briefly at the
Meeting.The BOC reviewed the Comment Log in dehdl and will submit comments to AEA.
Page t of 11
20140513-0201 FERC PDF (Unofficial) 05/05/2014
Al i~I&A~ENERGY AUTHORflY
AEA Oiregtfons and ROC Resnonses
AE4 Question li Does the BDC agree thot the configuration of the dam is acceptable as a basis
)br further design evaluation and optimization (ond license application ),with the proviso that the
dynamic analysis be revised with foundation mass etc ond (results of)Site Specific Seismic
Hazard Analysis studies,(and)site investigation (lbr the conftguratfon)7
ftOC Response to Qaesfion Ir The BOC agrees that if the msult of the planned site investigation
program is positive,i.e.,that there are no shears,linear featwes or gtults found that can
negatively affect the perfonnance of the dam,the conflguratioa of the dam would be acceplabte
as a basis for further feasibility/dmign evaluation,analysis and license application.The BOC
feels that confirmation of these site conditions are paramount to the feasibility and therefore
encourages early completion of the planned foundation investigation.The Site Specific Seismic
Hazard Analysis (SSSHA)studies that are being conducted and ~are reasonable and
appropriate for determining project feasibility and to serve as a basis flir further design evaluation
and optimization.
The various dynamic analyses need to be further investigated for the Openuing Basis Earthquake
(OBE)to show that operation can continue without intenuption afler an OBE event.Analysis for
the MCE should be conducted as a limit case and evaluated for overall stability to ensum that the
dam is stable during and afler thc MCE without sudden and uncontmlled release of the reservoir.
Some possible damage and small displacement is acceptable for the MCE case as long as the
water retention capability of the dam is mahrtainoL With respect to follow up dynamic analyses,
the BOC suggests the following:
l.It is important that dynamic analysis with massed foundation uses appropriate foundation
modulus consistent with mck properties at the dam site.A low foundation modulus may
be assigned to a narrow strip of elements along the footprint of thc dam to account for
rock fmctures and joints that may exist in shallow deplhs,but a higher deformation
modulus of the mck should be used in the rest of the foundation.
2.Appropriate tnmsmitting or ncn-reflecthqt boundary conditions should be applied to the
bottom and sides of the foundation model io elimhuue reflection of mismic waves at the
boundaries of the modeL
3.Transmitting boundaries (dampers)with no onstrrdm do not permit acceleration time
histories as the seismic input.The ground-surface acceleration time histories therefom
should first be deconvolved and then converted tn stress time histories and applied to
bottom and sides of the model.It is important that the deconvolution and convemion to
atreaa time histories are verified io ensure that they produce similar ground surface
acceleration when applied to a foundation block without the dam in place.
Page 1 of 11
20140513-0201 FERC PDF (Unofficial) 05/05/2014
P Al AC~L~ENERGY AUTHORITY
A%4 Question 2:Does the BOC agree that the Site Spedjtc Seismic Hazard Analysis (SSSHA )studies
performed to date are acceptable with the proviso that further crusbsl lineament analysis and angled
drill holes across the valley under the dam foundation (2014-15iield program)be completed before
jinni seismic criterio can be verijled?
BOC jtesponse to Question 2:
The SSSHA studies accomplished So date cover lineament,probabilistic,and deterministic seismic
hazard analyses and are detailed enough to provide preliminary desiga ground motions for the project.
Sensitivity analyses show that further analysis of regional crusud lineaments will not significantly
impact the design ground motions in the period mngs of significant dam response.However,further
analysis of site area lineaments and angled drill holes are necessaty to assess ptential for fault
ruptum under the dam as a insult oF primary,~,or sympathetic fault displacement,as
discussed in mom ddail under the "Additional Considerations"section below.On this basis,the BOC
believes that the main purpose of fiuther lineament analysis at the dam site including anghid drill
holes should focus on asscssmcnt of polential fault displacement aud not necessarily on the vibratory
ground motion associated with the I'neamentx From the BOC perspctive the pmbabilistic and
deterministic ground motions mu acceptable and can be linalized giving considemtion to the
following:
l.Based on preliminary measmuments,Voe at the dam site could be as high as 2,000 m/s,
which is significantly higher than the current value considered (1,080 m/s).The BOC
recommends that ground motions be ~for Vas consistent with thc ruck properties at
the dam,and if ~be adjusted Air the effect of Kappa (effect of upper crust damping).
2.The BOC is generally satisfied with the deterministic estimates of Mmax (i.e.Magnitudes,
7.5,7.8,and 8.0)and the assochucd level of ground motions (i.e.,84 54 for M7.5 and 69
for M7.8 and M8.0)for the iutraslab events.However,the BOC considers that the magnitude
of 7.5 is a more defeasible MCE fcr the dimensions and historical activity of the McKinley
Block beneath the site;and recommends that a Mmax of 7.5 at the closest hypoccntral
dislnnce and 84 percentile debnninistic ground motion (pga of 0.76g)be adopted for
feasibility/design (see "Additional Considerations").
3.An ANSYS dynamic analysis of Layout-4 indicates a fundamental period of vibration of
about 0.55 seconds with sliding and permanent displacements under the MCE ground motion
(innuslab M7.5 at 84 pcrcctmle,equivalent to a mtuin period of 5,000 years).The nonlinear
response oFihe dam is therefore expcexcd to be sensitive to long-period and Iong~a
gtuund motion,typical of interface events.As such,the BOC recommends that in additian to
the intraslab ground motiim,the dam also be analyzed for the intcrgtce deterministic ground
motion scaled to the 5000-year UHS at the fimdammtal period of the dam (0.55 sec).
Aftd Qnesthrn 31 Does the itOC agree that the drq jl pjdPIPbfp studies —prior to cornjdeting the
report —are acceprablefor fjnajl'zing ihs feasibility design aud thar (fthere acr no changes in
conclusion during the finalization of the report thor ihs conclusions can be used for the jlnal
design oftlie spillway?
Page g of 11
20140513-0201 FERC PDF (Unofficial) 05/05/2014
AI ii@2'~~ENERGY AUIIIOR(N
ROC Respacsse (a Ques((acc 9r
Probable Maximum Precinitation (PMP)
Applied Weather Associates (A WA)has made subtle but very significant changes to their
modeling approach,many of them based on suggestions fiom the BOC.It is the BOC's opinion
that the cunent configuration of the model,and the msults obuuned,represent an accmzte,
consistent,and defensible estimate of PMP as it would affect the spillway design.
While there are some details which have been idcntificd for modification in the PMP mports,
these cue mostly minor clsrifications and gnmunsr suggestions.The PMP process itself,snd the
resultant rainfall estimates,am excellent.
The most significant change in modeling procedure is in the storm transposition process.AWA is
using a pocedure which normalizes piecipitaticm using a companson with extreme precipitation
coverage (such as 100-year grids from NOAA Atlas 14).Then this normalized grid is transposed
to the target ~ed and multiplied by the extreme coverage values at tbe tsrgcz The result is a
process very similar to the socalled "isoeecenttd"method,which is known to work well in areas
with complex tensin.We believe that the storm tmnsposition approach cuimntly used by A WA is
the most consistent and defensible method available.The BOC recommends that the report be
edited for consisieacy and clarification prior to final submittal.
Probsbla Maximum Flood (PMR
The BOC agrees that the PMF infiow ydrogrspb ~in the draft PMF report eeptzsenh
gcnemlly appropriate assumptions and modeling methodologies snd the study is sufflcientiy
complete to be used in feasibility design.The BOC commends the thoughtfulness snd level of
detail shown in the work to date,considering the unusual challenges posed by two factors in
particular:the sparseness of historical hydrometeomlogical data snd the dominance of snowmelt
in many historical and hypothetical floods.
However,Tbe BOC recommends that additional analyses and investigations be completed befom
adopting a final design inflow hydrograph,as follows:
1.The constant loss rate of 0.02 inch per hour applied to develop the PMF was lass than the
calibrated loss fimction (that is,it resulted in mote computed runoff)and was chosen to
provide sn additional level of co ervatism.Thc BOC conauz with this decision because the
original loss function calibration for snowmelt-impacted events is somewhat unreliable,
requiring an innaase in the precipitation inputs relative to the values provided by Applied
Weather Associates (AWA)for the calibration events.When greater-than-observed ndnfiill
has so be added to the model in order to achieve the observed runoff volume,the other inputs
aflacting volume become very questionable.In fact,the csiibrafions wctu not able to
conclusively prove that the loss rate wss any greater than zen.In tbe presentcmon to the
BOC on April 3,MWH's hydrologist noted that they had begun the process of applying the
adopted PMF loss rate to the calibcztion events with generally acceptable results.The BOC
strongly supports this step-along with the elimination of any arbitrary adjustments to the
AWA-provided rainfall dais —for the sake of consistency.The BOC would view a less
parfiact fit to the calibration events to bc an acceptable sacrifice in ceder to avoid adjusting the
rainfall data.
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P hl ~Wk..~ENERGY AUTHORITY
2.If the model continues to underestimate snowmelt-impacted cvcnts,consider tbe possibility
that the energy budget loss method is not adequately considering the relcasc of free water
fiam a compacted snowpack.One ~ackhcssing this condition is the1966 Bureau of
Reclamation Engineering Mcmograph No.35.
3.The near-record fiood of June 2013 raises the possibility of a "sunmn-snow"PMF.In light
of the fact that the PMP iainfldl is mlatively small and is associated with temperatmus
substantially lower than thc temperatures that may occur in late spriny'early sununer with no
cloud cover,the BOC suggests investigating the snowmelt~ly event in at least enough
depth to confirm it cannot contml the PMF.This investigation would involve two elements:
o Apply the HEC-1 model to the June 201 3 event to confirm that it can mplicate this type
of flood;
o Consider whether a probable maximum snowpack combined with unusually high
temperatures,with no rain,could produce a controlling PMF.An efflcient approach
might be to make multiple model runs to determine what temperure/wind
combinations would be nccded to produce a PMF "conterulcr"and then consult with
AWA to evaluate whether such a combination of circumstances is plausible.
4.The sensitivity analysis leading to the adopuxl PMF model used a June
precipitation/snowmelt combination.However,in the "base case"model runs,the August
PMP with no snowmelt contmflcd thc PMF.The final study should either addmss making
similar conservative loss rate adjustments to the August case,or explain why the adopted
changes apply to rain-on-snow flood but nat to summer floods.
5.In the PMF report,Table 9.1-3,run M6 (The October PMP,or $0 percent of the all season
PMP,on an October snowptck accumulation)is listed as resulting in a peak inflow of 24,000
cfs.Hawever,in mid-October 1986 the Gobi Creek gage recorded a daily flow of 36,000 cfs.
The BOC ayces that this case will not contml the PMF.Still,to retain confidence in the
model assumptions the discrepancy between the compuaxl extmme floo and the observed
fload needs to be msolvccL
AEA Queeshrn 4r Given the configuration presented does the BOC consider that the planned site
investigation is appropriate far the provision of data for feasibility/fdasign of the dam7
BOC Response fo Quesabn eh The propomd and planned Site Investigation Program for the
pmjcct was ~at the meeting.This prognun entails a phased series of field investigations,
conducted over the next thme years that mspond ta several of the BOC comments and concerns.
The primary focus of the pmyam is to characterize and oonfirm the geologic/geotccimical
conditians in the dam site area.The main objectives include;1)investigation and verification of
the fractmc and shear zones and geologic features,2)evaluation of the potential far offset
displacements in the foundation due to earthquake motions;3)delineation of the flozen ground
and gmundwater conditions (edits)and 4)evaluation of the abutment stability.Given the above
plan and objectives,which can be accomplished by the detaihd mapping end exploratory edits
and borings planned;the BOC considers the present dehdled and phased site investigation
appmpriate for developing the data for supporting the feasibility and desiga of the dam.
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hl jkCBWl~ENERGY AUTHORITY
The BOC agrees that the Site Specific Seismic Hanud Analysis (SSSHA)studies performed to date are
acceptable for further design evaluation and optimization with the proviso that the proprsmd site-specific
studies be performed in the 2014-15 field seasons to evaluate the potential for fimlt rupture at the dam
site.
Potential seismic hazard at thc site includes two components:(I)Strong ground motion (development of
design ground motion criteria),and 2)Fault rupture (documenting the absence of potential for fault
displacement through the dam foundation).Fault displacement includes both tectonic Sault displacement
(primary,secondary or sympathetic)and non-tectonic displacement (e.g.,sachung,etc.),
Considerable work has been performed to date to develop pmbabilistic and deterministic gmund motion
estimates for ihe dam.As described below,the BOC considers that this work is sufficieat to move
forward with fiuther design and optimization studies,and the license application,pending completion of
the final SSSHA studies.
Conversely,given site access limitations,only limited assessment has been performed of the potential for
fault displacement at the dam site.Given the imporuum of this pctenthd hazard Io selection of the RCC
dam design and location,the BOC concurs with the pri ritization given to this assessmeat in tbe proposed
work srxtpc for 20 14 field activities,including detailed field mapping,angle bcruholes,and dating of
identiTicd shear zones.We reiterate ow BOC comment following Meeting ¹2(Comment 10)"It is
recommended that the energy ofthe geologists aud the jhndmg be jocnsed on the mapping,d'riling,and
adiai at the dem site area in a maJor ejjort to dejine the geometry ofthe shears in arder to locate tire dane
such that any a+sets oacrtrrmg along these features during an earttuptabe do not need to be considered.
This activity must be given the highest priority ~to the lineament studies at signtjicant dlstimces
jrom the possible dam site".
Fault Runture Hazard.
In performing the upcoming 2014 site studies,the BOC recommends that particular attention be given to
the following:
1.The Lineament Study provides an excellent basis for further evaluation of geologic featurtu that
may intersect the dam site area,and provides explicit criteria for "including"or "excluding"
lineaments for further study.Cununtly,all of the criteria mu related to the identification of
ptential seismic sources for ground motion analysis.The BOC recommends that onc or more
criteria be added rclatcd to thc assessment of lineaments for potential fault rupture.For example,
all lineaments that project toward the dam site within a 3 to 5 Km radius,reganllcss of length,
should be evaluated for potential fault rupture.
2.During the upcoming 2014 field season,the BOC strongly recommends that explicit attention be
gives to the evaluation of the Susitna lineament as a potential fault tructuiu,and the potential
relationship of this lineament to the NW-SE tteadmg shears mapped through the dam foundation
(e.g.,as poiuntial Reidel shears).This potential association must be ruled out either by direct
observations such as cross cutting relationships or by indirect arguments such as expected sense
of slip in the current tectonic stress/strain regime.
3.In addition to mapping observed lineaments in the dam site area,tbe BOC recommends that 6
large scale lineament and detailed geologic map of the site area (approximately I or 2 kilometer
radius around the dam)be prepared documenting the "absenoe"of lineaments or geologic
features that may be associated with tectonic or non-tectonic activity (e.g.,sachung thatures or
esse 6 ct ll
20140513-0201 FERC PDF (Unofficial) 05/05/2014
P gl~ENERGY AUTHORRY
other deep-seated sympathetic structums)snd explicitly stating in the report that these feanues
afe absent at the site.
4.Considerable "legacy"data exist for the site,including the Woodward Clyde lineament and
trenching study.For example,trenches an the Susitna lineament and Talkeetna lineament are
used to conclude that these features are not active faults.TIie BOC recanmends that the site
rupert include a section or commentary mNuding the use of this ~g knowledge for
current evaluation of these features.
1.Seismic Source ModeL The seismic source madel developed for the site is well documented
and is appropriate for use in both deterministic and pmbabilistic analysis of ground motion at
the site.Sensitivity analyses have identified those parameters of the model that ste
significant to hanud for further evaluation,including the Mmax distribution on the Intraslab
sauna and selection/weighting of appropriate GMPE models.Sensitivity analyuui show that
crustal faults in the site region do nat contribute significantly to hazanL Thus,the BOC
mcommcnds that little further effort be given to ciuusctmizing the potential activity of
Lineaments in the site mgion.As needed,any Regional Lineaments "identified for fiuther
study"in the Lineament Report may be addressed by assigning a pmbability of being
seismogfmic (P(s)),a slip rate based on the threshokl of detection,snd an Mmax based on
lineament length.Sensitivity analyses have showa that incoiponmng these 1incamcnts ss
seismic sources will not contribute to Nnund motion hazard at fite site.
2.Mmax of the Intraslab Source.Fcr thc deterministic analysis,the BOC supports the use of
an Mmax of 7.5 at the closest hypocentnd distance and 84ya deterministic tpnund mation,
or an Mmax of 7.8 to 8.0 at a hypocentral distance uniformly disuibuted on the rupture plane
and 84 Yo deterministic ground motion as nxxnnmended in Tedmicai Memorandum 14-04-
TM.Alternately,the latter is equivalent to the use of the closest hypcentrsl distance and
69 qa ground motion as shown in 1444 TM.The BOC recommends that additional
discussion be provided in 14414 TM regarding the hypocennal distribution used in the
analysis both in depth (width)snd length of ptential Intrsslab Fault Planes.The BOC
recommends that the project team evaluate the fitult ruptum dimensions associated with
recorded magnitude 8 lntmslab earthquakes in the global data base for comparison to the
dimensions of the McKinley Block beneath the sita Such an evaluatioa can be used to assess
whether the lntmslab source at the site can support similar large magnitude events,whether a
lower Mmax (e.g.,7.5)is defensible for the MCE deterministic evaluation,and to inform the
weighting given to the magnitude dislribution for the PSHA.
3.Ground Motian Pnxliction Equation (GMPE)Model.The BOC recommends that a final
decision be made on the selection of the GMPE model for the Intraslab source.Currently,
the Deterministic and Prnbabilistic assessmmts um differen GMPE models.For
consistency,a final assessmcnt of the GMPE madel should be used in thc SSSHA studies for
development of final seismic design criteria
page 1 of tt
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P AI i~A~EgERGY AUTHORITY
Cowclrlfrwf.ffertfsrfrgr
1he BOC appreciates that this phase of the Feasibility Study need not get into the final design delails;
however,it also feels that there are significant basic conditions that infiuence the configuration and
performance of the dam.These gtctors csn and may well affect the feasibility and esthmed cost of the
Project.Whether the present Feasibility Report addresses or tries to address all of the potential conditions
of the dam and its cnvituns is up to both the Owner and the Engineer.However,there are serious
conditions and considerations that must bc addressed.The following are several considerations
identified,by the BOC,that need to be mcognized and attended to:
1.The presence cr absence of fault or shear fbatures in the foundations that may affect both the static
and dynamic eefornumce of the RCC dam.The BOC suongly suggests that these issues be resolved
in a timely manner,preferably in the 20 14 detailed surface mapping and inclined cross-river borings
planned during this first stage of the investigation.
2.The xistence of pmafrtxu within the foundation rock formations and how it has affected or will
affect the foundation characteristics (i.e.ice jacking,rock block movements,long tenn foundation
permeability etc.).The BOC stmngly suggests that these issues be resolved in a timely manner,
prefembly in the first stage of the investiyuion (2014-15),from thc proposed exploratory edits.
3.Knowing that the dam will be subject to sliding duriag aa MCE event,consideration should be given
to shaping of the foundation of each monolith to provide an upstream inclination for additional shear
lesistallce.
4.It is imporlant that upper abutment blocks (thrust blocks)provide adeqmue support Rr thc arch thrust
to capture or limit movements.This may be accomplished by appropriat orientation of the tluust
blocks aad possibly increasing their cress sections.
5.With the completion of the PMF and estimate of the design Nound motion,the BOC reiterates its
Comment 12.4 from Boanl Meeting 2 that special attention should be given to potential of increasing
the number of spillway gates thereby reducing the height of piem,which would be mom efficien in
transferring the arch thrust into the adjacent blocks and impmving cmss-valley perfonnance of the
piers.This issue is also of concern to FERC as a result of e present incident at Wanapum project
spillway.
6.Thermal considerations mgarding placement of RCC directly on the cold foundations and hrinkage.
7.The transverse joint spacing that is appopriate for thc cold climate and the thernal shock stresses
generated by the cold water when the reservoir is impounded.
g.Considerations regarding longitudinal cracking fmm concrete shrinkage and foundation mstraint
R Consideration of foundation grouting within the extnmely cold &undstion mcks and Noundwater.
10.The complications of sequencing of the seasonal placements and the thermal efibcts on the internal
stress development
Page g of it
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P plAC%~~ENERBY AUTHORITY
The BOC recognizes the etforts of AEA,and MWH to provide and present information for our review
during the meetings and anangements.The hospitality and accommodations pnwided by MWH are
greatly appreciated.
The BOC Report was mad during a Conference Call on Friday April 4 at l:00PM fiom MWHs oRices.
Sincmuly.
Joseph Ehasz ~Brian Forbes Yusof Ghanaat Alfred J.Hendron,Jr.
Ellen Faulkner George Taylor William R.Lettis
Attachments:
Attachment A-Meeting Agenda
Attachment B —Attendance Sheets
Psy.9 of 11
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Al~EhERGY AUTHORITY
ATTACHMENT A
MEEYING AGENDA
Page gO of il
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SUSITNA-WATANA HYDRO
Susitna-Watana Board of Consultants Meeting ¹4
MWH Office,2853 180~Ave.NE ¹200,Bellevue,WA
Agenda
April 2-4,2014
8:15AM-5:ODPM
Wednesdav.Aur)l 2
iPUBUC ACCESS)
1.Welcome and Introductions
~Safety Topic
2.Prior Meetings Comment Response Review
S.2018 eeotechnkal I vestlgation Program
~2013 Site Investigation Update
~Seismic Hazard and Lineament Studies Update
8:15AM
B:45AM
9:45AM
CONCURRENTSESSIONS
(PUBUC ACCESS)
4A.PMP Breakout Session
~PMP Study Update
~PMF Study Update
START EXECUllVE SESSION-CEll
(CEB)
4'am Configuration
~Deterministic Analysis of Intraslab
~Dam Configuration
~FE Analysis Update
Adjourn
1:15PM
1:15PM
20140513-0201 FERC PDF (Unofficial) 05/05/2014
SUSITNA-WATANA HYDRO
Susitna-Watana Board of Consultants Nleetini ¹4
MWH Office,285$1$0e Ave.NE F00,Bellewe,WA
Thiirsdav.ADril S"
CONCURRENT SESSIONS
lPUBUC ACCESS)
SA.PMP Breaiux»Session (continued)
~PMP Study Update
~PMF Study Update
RESUME EXECUTIVE SESSION-CER
lCER)
SL Dam Configuration (continued)
~Deterministic Analysis of Intraslab
~~m Configuration
~FE Analysis
END EXECUTIVE SESSION /CONCURRENT SESSIONS
(PUBUC ACCESS)
6.Geotachnical Investilnlon Program
7.PMP/PMF Overview
Adloum
gi1SAM
8:16AM
1040AM
20140513-0201 FERC PDF (Unofficial) 05/05/2014
SUSITNA-WATANA HYDRO
Susitna-Watana Board of Consultants Meeting ¹4
MWH Ofhce,2353 130~Ave.NE ¹200,Bellevue,WA
Fridav.ADril4 .
START NON-PUBUC SESSION
B.Board of Consultants Deliberations
END NON-PUBUC SESSION
(PUBUC ACCESS)
9.Board of Consultants Conclusions and Recommendations
10.Establish Date for Next Board Meeting Adjourn
Adjourn
8:15AM
lTBD)
20140513-0201 FERC PDF (Unofficial) 05/05/2014
hl ~PA~ENERGY AUIHORITY
ATTACHMENT B
MEETING ATTENDANCE SHEETS
Page 11of 11
20140513-0201 FERC PDF (Unofficial) 05/05/2014
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20140513-0201 FERC PDF (Unofficial) 05/05/2014
BOC Final Report ¹4with AEA Responses
AEA Ouestions,BOC Responses and AEA Comments
l.AEA Question 1:Does the BOC agree that the configuration of the dam is acceptable as a
basis for further design evaluation and optimization (and license application),with the
proviso that the dynamic analysis be revised with foundation mass etc.and (results oj)Site
Specific Seismic Hazard Analysis studies,(and)site investigation (for the configuration)?
BOC Response to Question 1:The BOC agrees that if the result of the planned site
investigation program is positive,i.e.,that there are no shears,linear features or faults found
that can negatively affect the performance of the dam,the configuration of the dam would be
acceptable as a basis for further design evaluation,analysis and license application.The
BOC feels that confirmation of these site conditions are paramount to the feasibility and
therefore encourages early completion of the planned foundation investigation.The Site
Specific Seismic Hazard Analysis (SSSHA)studies that are being conducted and presented
are reasonable and appropriate for determining project feasibility and to serve as a basis for
further design evaluation and optimization.
The various dynamic analyses need to be further investigated for the Operating Basis
Earthquake (OBE)to show that operation can continue without interruption after an OBE
event.Analysis for the MCE should be conducted as a limit case and evaluated for overall
stability to ensure that the dam is stable during and after the MCE without sudden and
uncontrolled release of the reservoir.Some possible damage and small displacement is
acceptable for the MCE case as long as the water retention capability of the dam is
maintained.
AEA Comment:
There has always been the intention to perform a dynamic structural analysis of the
dam for both the OBE and the MCK.However,using the level of OBE suggested by
the various guidelines in use in the US indicates an event that can "reasonably be
expected to occur within the service life of the project,that is,with a 50-percent probability
of exceedence during the service life".This would be about a 144-yr occurrence which
is less than 0.25g.AEA will discuss and may choose an OBE that is higher.In any
event,the behavior of the structure under the MCE will essentially govern the
feasibility design of the dam,so AEA has chosen to focus on that criteria for the time
being.The analyses will be performed for that seismic criteria and when the final
configuration has been derived,it will be subject to the chosen OBK -and is expected to
perform satisfactorily.
With respect to follow up dynamic analyses,the BOC suggests the following:
~It is important that dynamic analysis with massed foundation uses appropriate
foundation modulus consistent with rock properties at the dam site.A low foundation
modulus may be assigned to a narrow strip of elements along the footprint of the dam
to account for rock fractures and joints that may exist in shallow depths,but a higher
deformation modulus of the rock should be used in the rest of the foundation.
20140513-0201 FERC PDF (Unofficial) 05/05/2014
AEA Comment:
Noted.
~Appropriate transmitting or non-reflecting boundary conditions should be applied to
the bottom and sides of the foundation model to eliminate reflection of seismic waves
at the boundaries of the model.
AEA Comment:
Intend to include.
~Transmitting boundaries (dampers)with no constraint do not permit acceleration time
histories as the seismic input.The ground-surface acceleration time histories
therefore should first be deconvolved and then converted to stress time histories and
applied to bottom and sides of the model.It is important that the deconvolution and
conversion to stress time histories are verified to ensure that they produce similar
ground surface acceleration when applied to a foundation block with the dam in
place.
AEA Comment:
Intend to do this.However,there is,we believe a typographical error.In the last line it
says "block with the dam in place"this seems wrong and that it should be "block
without dam in place".
2.AEA Question Z:Does the BOC agree that the Site Specific Seismic Hazard Analysis
(SSSHA)studies performed to date are acceptable with the proviso that further crustal
lineament analysis and angled drill holes across the valley under the dam foundation (2014-
15field program)be completed before final seismic criteria can be verified for final design?
BOC Response to Question Z:
The SSSHA studies accomplished to date cover lineament,probabilistic,and deterministic
seismic hazard analyses and are detailed enough to provide preliminary design ground
motions for the project.Sensitivity analyses show that further analysis of regional crustal
lineaments will not significantly impact the design ground motions in the period range of
significant dam response.However,further analysis of site area lineaments and angled drill
holes are necessary to assess potential for fault rupture under the dam as a result of primary,
secondary,or sympathetic fault displacement,as discussed in more detail under "Additional
Considerations"section below.On this basis,the BOC believes that the main purpose of
further lineament analysis at the dam site including angled drill holes should focus on
assessment of potential fault displacement and not necessarily on the vibratory ground
motion associated with the lineaments.From the BOC perspective the probabilistic and
deterministic ground motions are acceptable and can be finalized giving consideration to the
following:
~Based on preliminary measurements,V,30 at the dam site could be as high as 2,000 m/s,
which is significantly higher than the current value considered (1,080 m/s).The BOC
Page 2 of 10
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recommends that ground motions be estimated for V,30 consistent with the rock
properties at the dam,and if necessary be adjusted for the effect of Kappa (effect of
upper crust damping).
AEA Comment:
Noted.In the absence of any actual site testing,we intend to run the analysis using a
Vs30 that is conservative with respect to ground motions.
~The BOC is generally satisfied with the deterministic estimates of Mmax (i.e.,7.5,7.8,
and 8.0)and the associated level of ground motions (i.e.,84'"%for 7.5 and 69'"%for
M7.8 and M8.0)for the intraslab events.However,the BOC considers that the
magnitude of 7.5 is a more defensible MCE for the dimensions and historical activity of
the McKinley Block beneath the site;and recommends that a Mmax of 7.5 at the closest
hypocentral distance and 84'"percentile deterministic ground motion (pga of 0.76g)be
adopted for the feasibility/design (see "Additional Considerations").
AEA Comment:
Noted.
~An ANSYS dynamic analysis of Layout-4 indicates a fundamental period of vibration of
about 0.55 seconds with sliding and permanent displacements under the MCE ground
motion (intraslab M7.5 at 84'"percentile,equivalent to a return period of 5,000 years).
The nonlinear response of the dam is therefore expected to be sensitive to long-period
and long-duration ground motion,typical of interface events.As such,the BOC
recommends that in addition to the intraslab ground motion,the dam also be analyzed for
the interface deterministic ground motion scaled to the 5000-year UHS at the
fundamental period of the dam (0.55 sec).
AEA Comment:
Noted.
3.AEA Question 3:Does the BOC agree that the draft PMP/PMF studies —prior to
completing the report —are acceptable for finalizing the feasibility design and that if there
are no changes in conclusion during the finalization of the report that the conclusions can be
used for the final design of the spillway?
BOC Response to Question 3:
3.1 Probable Maximum Precipitation (PMP)
Applied Weather Associates (AWA)has made subtle but very significant changes to their
modeling approach,many of them based on suggestions from the BOC.It is the BOC's
opinion that the current configuration of the model,and the results obtained,represent an
accurate,consistent,and defensible estimate of PMP as it would affect the spillway design.
Page 3 of 10
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While there are some details which have been identified for modification in the PMP reports,
these are mostly minor clarifications and grammar suggestions.The PMP process itself,and
the resultant rainfall estimates,are excellent.
The most significant change in modeling procedure is in the storm transposition process.
AWA is using a procedure which normalizes precipitation using a comparison with an
extreme precipitation coverage (such as 100-year grids from NOAA Atlas 14).Then this
normalized grid is transposed to the target watershed and multiplied by the extreme coverage
values at the target.The result is a process very similar to the so-called "isopercental"
method,which is known to work well in areas with complex terrain.We believe that the
storm transposition approach currently used by AWA is the most consistent and defensible
method available.
The BOC recommends that report be edited for consistency and clarification prior to final
submittal.
AEA Comment:
Noted.Final editing and review of the PMP report will be performed.
3.2 Probable Maximum Flood (PMF)
The BOC agrees that the PMF inflow hydrograph presented in the draft PMF report
represents generally appropriate assumptions and modeling methodologies and the study is
sufficiently complete to be used in feasibility design.The BOC commends the
thoughtfulness and level of detail shown in the work to date,considering the unusual
challenges posed by two factors in particular:the sparseness of historical
hydrometeorological data and the dominance of snowmelt in many historical and
hypothetical floods.
However,The BOC recommends that additional analyses and investigations be completed
before adopting a final design inflow hydrograph,as follows:
~The constant loss rate of 0.02 inch per hour applied to develop the PMF was less than the
calibrated loss function (that is,it resulted in more computed runoff)and was chosen to
provide an additional level of conservatism.The BOC concurs with this decision because
the original loss function calibration for snowmelt-impacted events is somewhat unreliable,
requiring an increase in the precipitation inputs relative to the values provided by Applied
Weather Associates (AWA)for the calibration events.When greater-than-observed rainfall
has to be added to the model in order to achieve the observed runoff volume,the other
inputs affecting volume become very questionable.In fact,the calibrations were not able to
conclusively prove that the loss rate was any greater than zero.In the presentation to the
BOC on April 3,MWH's hydrologist noted that they had begun the process of applying the
adopted PMF loss rate to the calibration events with generally acceptable results.The BOC
strongly supports this step —along with the elimination of any arbitrary adjustments to the
AWA-provided rainfall data —for the sake of consistency and credibility.The BOC would
view a less perfect fit to the calibration events to be an acceptable sacrifice in order to avoid
adjusting the rainfall data.
Page 4 of 10
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AEA Comment:
It is expected that the analysis of a constant loss rate of 0.02 inch per hour for the
spring calibration and verification floods will be added to the PMF report in either a
new or a revised report section.
~If the model continues to underestimate snowmelt-impacted events,consider the possibility
that the energy budget loss method is not adequately considering the release of free water
from a compacted snowpack.One reference addressing this condition is the1966 Bureau of
Reclamation Engineering Monograph No.35.
AEA Comment:
It is anticipated that the energy budget snowmelt method (as recommended in FERC
guidelines)will prove adequate for simulation of historic snowmelt events.It is noted
that USBR Monograph No.35 states that it is intended for use in in inflow design flood
studies in which a design rain occurs on a fresh snowpack.
~The near-record flood of June 2013 raises the possibility of a "sun-on-snow"PMF.In light
of the fact that the PMP rainfall is relatively small and is associated with temperatures
substantially lower than the temperatures that may occur in late spring/early summer with
no cloud cover,the BOC suggests investigating the snowmelt-only event in at least enough
depth to confirm it cannot control the PMF.This investigation would involve two elements:
o Apply the HEC-1 model to the June 2013 event to confirm that it can replicate this
type of flood;
o Consider whether a probable maximum snowpack combined with unusually high
temperatures,with no rain,could produce a controlling PMF.An efficient approach
might be to make multiple model runs to determine what temperature/wind
combinations would be needed to produce a PMF "contender"and then consult with
AWA to evaluate whether such a combination of circumstances is plausible.
AEA Comment:
Noted.The sun-on-snow PMF will be investigated in sufficient detail to determine
whether it could constitute the controlling case for the PMF,including simulation of the
actual June 2013 flood event.
~The sensitivity analysis leading to the adopted PMF model used a June
precipitation/snowmelt combination.However,in the "base case"model runs,the August
PMP with no snowmelt controlled the PMF.The final study should either address making
similar conservative loss rate adjustments to the August case,or explain why the adopted
changes apply to rain-on-snow floods but not to summer floods.
AEA Comment:
Noted.
Page 5 of 10
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~In the PMF report,Table 9.1-3,run M6 (The October PMP,or 80 percent of the all season
PMP,on an October snowpack accumulation)is listed as resulting in a peak inflow of
24,000 cfs.However,in mid-October 1986 the Gold Creek gage recorded a daily flow of
36,000 cfs.The BOC agrees that this case will not control the PMF.Still,to retain
confidence in the model assumptions the discrepancy between the computed extreme flood
and the observed flood needs to be resolved.
AEA Comment:
This case will be revised to present a more plausible October PMF,probably by
investigating an October 1 PMF condition to replace the October 15 condition.
4.AEA Question 4:Given the configuration presented does the BOC consider that the
planned site investigation is appropriate for the provision of data for feasibilityfdesign of the
dam?
BOC Response to Question 4:The proposed and planned Site Investigation Program for the
project was presented at the meeting.This program entails a phased series of field
investigations,conducted over the next three years that respond to several of the BOC
comments and concerns.The primary focus of the program is to characterize and confirm
the geologic/geotechnical conditions in the dam site area.The main objectives include;1)
investigation and verification of the fracture and shear zones and geologic features,2)
evaluation of the potential for offset displacements in the foundation due to earthquake
motions;3)delineation of the frozen ground and groundwater conditions (adits)and 4)
evaluation of the abutment stability.Given the above plan and objectives,which can be
accomplished by the detailed mapping and exploratory adits and borings planned;the BOC
considers the present detailed and phased site investigation appropriate for developing the
data for supporting the feasibility and design of the dam.
AEA Comment:
Noted.
ADDITIONAL CONSIDERATIONS:
The BOC agrees that the Site Specific Seismic Hazard Analysis (SSSHA)studies performed to date
are acceptable for further design evaluation and optimization with the proviso that the proposed site-
specific studies be performed in the 2014-15 field seasons to evaluate the potential for fault rupture
at the dam site.
Potential seismic hazard at the site includes two components:(1)Strong ground motion
(development of design ground motion criteria),and 2)Fault rupture (documenting the absence of
potential for fault displacement through the dam foundation).Fault displacement includes both
tectonic fault displacement (primary,secondary or sympathetic)and non-tectonic displacement (e.g.,
sachung,etc.).
Considerable work has been performed to date to develop probabilistic and deterministic ground
motion estimates for the dam.As described below,the BOC considers that this work is sufficient to
move forward with further design and optimization studies,and the license application,pending
Page 6of10
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completion of the final SSSHA studies.
Conversely,given site access limitations,only limited assessment has been performed of the
potential for fault displacement at the dam site.Given the importance of this potential hazard to
selection of the RCC dam design and location,the BOC concurs with the prioritization given to this
assessment in the proposed work scope for 2014 field activities,including detailed field mapping,
angle boreholes,and dating of identified shear zones.We reiterate our BOC comment following
Meeting ¹2(Comment 10)"It is recommended that the energy of the geologists and the funding be
focused on the mapping,drilling,and adits at the dam site area in a major effort to define the
geometry of the shears in order to locate the dam such that any offsets occurring along these
features during an earthquake do not need to be considered.This activity must be given the highest
priority compared to the lineament studies at significant distance s from the possible dam site".
Fault Rupture Hazard.In performing the upcoming 2014 site studies,the BOC recommends that
particular attention be given to the following:
1.The Lineament Study provides an excellent basis for further evaluation of geologic features
that may intersect the dam site area,and provides explicit criteria for "including"or
"excluding"lineaments for further study.Currently,all of the criteria are related to the
identification of potential seismic sources for ground motion analysis.The BOC
recommends that one or more criteria be added related to the assessment of lineaments for
potential fault rupture.For example,all lineaments that project toward the dam site,
regardless of length,should be evaluated for potential fault rupture.
2.During the upcoming 2014 field season,the BOC strongly recommends that explicit
attention be given to the evaluation of the Susitna lineament as a potential fault structure,and
the potential relationship of this lineament to the NW-SE trending shears mapped through
the dam foundation (e.g.,as potential Reidel shears).This potential association must be
ruled out either by direct observations such as cross cutting relationships or by indirect
arguments such as expected sense of slip in the current tectonic stress/strain regime.
3.In addition to mapping observed lineaments in the dam site area,the BOC recommends that
a large scale lineament and detailed geologic map of the site area (approximately 1 or 2
kilometer radius)be prepared documenting the "absence"of lineaments or geologic features
that may be associated with tectonic or non-tectonic activity (e.g.,sachung features or other
deep-seated sympathetic structures)and explicitly stating in the report that these features are
absent at the site.
4.Considerable "legacy"data exist for the site,including the Woodward Clyde lineament and
trenching study.For example,trenches on the Susitna lineament and Talkeetna lineament are
used to conclude that these features are not active faults.The BOC recommends that the site
report include a section or commentary regarding the use of this pre-existing knowledge for
current evaluation of these features.
Ground Motion Hazard.
(1)Seismic Source Model.The seismic source model developed for the site is well documented
and is appropriate for use on both deterministic and probabilistic analysis of ground motion
at the site.Sensitivity analyses have identified those parameters of the model that are
significant to hazard for further evaluation,including the Mm„distribution on the Intraslab
source and selection/weighting of appropriate GMPE models.Sensitivity analyses show that
crustal faults in the site region do not contribute significantly to hazard.Thus,the BOC
recommends that little further effort be given to characterizing the potential activity of
Page 7 of 10
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Lineaments in the site region.As needed,any external lineaments "identified for further
study"in the Lineament Report may be addressed by assigning a probability of being
seismogenic (P(s)),a slip rate based on the threshold of detection,and an Mmax based on
lineament length.Sensitivity analyses have shown that incorporating these lineaments as
seismic sources will not contribute to ground motion hazard at the site.
AEA Comment:
Noted.
(2)Mme of the Intraslab Source.For the deterministic analysis,the BOC supports the use of an
Mme of 7.5 at the closest hypocentral distance and 84'"%deterministic ground motion,or an
M~„of 7.8 to 8.0 at a hypocentral distance uniformly distributed on the rupture plane and
84'"%deterministic ground motion as recommended in Technical Memorandum 14-04-TM.
Alternately,the latter is equivalent to the use of the closest hypocentral distance and 69'"%
ground motion as shown in 14-04 TM.The BOC recommends that additional discussion be
provided in 14-04 TM regarding the hypocentral distribution used in the analysis both in
depth (width)and length of potential Intraslab Fault Planes.The BOC recommends that the
project team evaluate the fault rupture dimensions associated with recorded magnitude 8
Intraslab earthquakes in the global data base for comparison to the dimensions of the
McKinley Block beneath the site.Such an evaluation can be used to assess whether the
Intraslab source at the site can support similar large magnitude events,whether a lower
Mmax (e.g.,7.5)is defensible for the MCE deterministic evaluation,and to inform the
weighting given to the magnitude distribution for the PSHA.
AEA Comment:
Noted.For the moment we will continue to use both M7.5 (84'"%tile)and M8.0 (69'"
%tile)or the higher of the two.
(3)Ground Motion Prediction Equation (GMPE)Model.The BOC recommends that a final
decision be made on the selection of the GMPE model for the Intraslab source.Currently,
the Deterministic and Probabilistic assessments use different GMPE models.For
consistency,a final assessment of the GMPE model should be used in the SSSHA for
development of final seismic criteria.
AEA Comment:
The deterministic and probabilistic assessment use the same GMPE.There is an error
in the Technical Memorandum 14-04-TM that would lead the reader to believe
otherwise.This error will be corrected.The computations includedin the Technical
Memorandum 14-04-TM are for comparison purposes only and utilize one GMPK
criteria.
Concluding Remarks
The BOC appreciates that this phase of the Feasibility Study need not get into the final design
details;however,it also feels that there are significant basic conditions that infiuence the
configuration and performance of the dam.These factors can and may well affect the feasibility and
Page 8of10
20140513-0201 FERC PDF (Unofficial) 05/05/2014
estimated cost of the Project.Whether the present Feasibility Report addresses or tries to address all
of the potential conditions of the dam and its environs is up to both the Owner and the Engineer.
However,these are serious conditions and considerations that must be addressed.The following are
several considerations identified,that need to be recognized and attended to:
~The presence or absence of fault or shear features in the foundations that may affect both the
static and dynamic performance of the RCC dam.The BOC strongly suggests that these issues
be resolved in a timely manner,preferably in the 2014 detailed surface mapping and inclined
cross-river borings planned during first stage of the investigation.
AEA Comment:
Noted.
~The existence of permafrost within the foundation rock formations and how it has affected or
will affect the foundation characteristics (i.e.ice jacking,rock block movements,long term
foundation permeability etc.).The BOC strongly suggests that these issues be resolved in a
timely manner,preferably in the first stage of the investigation (2014-15),from the proposed
exploratory adits.
AEA Comment:
Noted.
~Knowing that the dam will be subject to sliding during an MCE event,consideration should be
given to shaping of the foundation of each monolith to provide an upstream inclination for
additional shear resistance.
AEA Comment:
Noted.
~It is important that upper abutment blocks (thrust blocks)provide adequate support for the arch
thrust to capture or limit movements.This may be accomplished by appropriate orientation of
the thrust blocks and possibly increasing their cross sections.
AEA Comment:
Noted.
~With the completion of the PMF and estimate of the design ground motion,the BOC reiterates
its Comment 12.4 from Board Meeting 2 that special attention should be given to potential of
increasing the number of spillway gates thereby reducing the height of piers,which would be
more efficient in transferring the arch thrust into the adjacent blocks and improving cross-valley
performance of the piers.This issue is also of concern to FERC as a result of a present incident
at Wanapum project spillway.
Page 9of10
20140513-0201 FERC PDF (Unofficial) 05/05/2014
AEA Comment:
Number of gates will be increased to four.
~Thermal considerations regarding placement of RCC directly on the cold foundations and
shrinkage.
AEA Comment:
Noted.A thermal analysis is planned.
~The transverse joint spacing that is appropriate for the cold climate and the thermal shock
stresses generated by the cold water when the reservoir is impounded.
AEA Comment:
Noted.
~Considerations regarding longitudinal cracking from concrete shrinkage and foundation restraint
~Consideration of foundation grouting within the extremely cold foundation rocks and
groundwater.
~The complications of sequencing of the seasonal placements and the thermal effects on the
internal stress development.
AEA Comment:
The thermal model will address.
Page 10 of 10
20140513-0201 FERC PDF (Unofficial) 05/05/2014
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20140929-5059
September 26, 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
Second Set of 2014 Technical Memoranda for Initial Study Plan Meetings
Dear Secretary Bose:
As the Alaska Energy Authority (AEA) explained in its September 17, 2014 filing
with the Federal Energy Regulatory Commission (Commission or FERC) for the
proposed Susitna-Watana Hydroelectric Project, FERC Project No. 14241 (Project), the
June 3, 2014 Initial Study Report (ISR) provided for AEA to prepare certain technical
memoranda and other information based on 2014 work. In accordance with Commission
Staff direction, on September 17, 2014, AEA filed and distributed the first set of
technical memoranda and other information generated during the 2014 study season.
With this letter, AEA is filing and distributing the second set of technical
memoranda generated during the 2014 study season, as described below. As part of its
continued implementation of the study plan, AEA expects to file a third set of technical
memoranda prior to October 1, 2014.
This second set of technical memoranda includes:
• Attachment A: Geomorphology Study (Study 6.5) - Updated Mapping of
Aquatic Macrohabitat Types in the Middle Susitna River Segment from 1980s
and Current Aerials Technical Memorandum. This technical memorandum
updates the Middle Susitna River Segment portion of the aquatic macrohabitat
mapping results previously provided in the technical memorandum titled
Mapping of Aquatic Macrohabitat Types at Selected Sites in the Middle and
Lower Susitna River Segments from 1980s and 2012 Aerials (Tetra Tech
2013a).
• Attachment B: Geomorphology Study (Study 6.5) - Mapping of Geomorphic
Features and Turnover within the Middle and Lower Susitna River Segments
from 1950s, 1980s, and Current Aerials Technical Memorandum. This
technical memorandum updates the geomorphic mapping and assessment of
channel change that were initially provided in Mapping of Geomorphic
2
Features and Assessment of Channel Change in the Middle and Lower Susitna
River Segments from 1980s and 2012 Aerials (Tetra Tech 2013a). The initial
technical memorandum provided the results from tasks identified in Revised
Study Plan Study 6.5 Section 6.5.4.4. This update extends the previous 30
year analysis between the 1980s and 2012 by an additional 30 years with
aerial photography from the 1950s, and also provides a short term analysis of
geomorphic changes by comparing 2012 with 2013 aerial photography.
• Attachment C: Fluvial Geomorphology Modeling below Watana Dam Study
(Study 6.6) - Decision Point on Fluvial Geomorphology Modeling of the
Susitna River below PRM 29.9 Technical Memorandum. This technical
memorandum describes the decision of whether to extend the downstream
limit of the 1-D bed evolution model below Susitna Station at PRM 29.9.
• Attachment D: Fluvial Geomorphology Modeling Below Watana Dam (Study
6.6) - Winter Sampling of Main Channel Bed Material Technical
Memorandum. The overall purpose of this technical memorandum is to
quantify main channel bed material gradations at selected sites in the Upper,
Middle, and Lower Susitna River Segments. The data obtained from this
study serves as input for the 1-D and 2-D bed evolution modeling efforts
being conducted under the Fluvial Geomorphology Modeling Study (Study
6.6).
• Attachment E: Cook Inlet Beluga Whale Study (Study 9.17) - 2014 Cook Inlet
Beluga Whale Prey Study Implementation Technical Memorandum. This
technical memorandum summarizes activities implementing the Cook Inlet
Beluga Whale Study (Study 9.17) conducted in 2014 that tested methods to
document Cook Inlet Beluga Whale prey and prey habitat in the Susitna River
delta.
• Attachment F: River Productivity Study (Study 9.8) - 2013 Initial River
Productivity Results Technical Memorandum. This technical memorandum
provides a preliminary review and summary of 2013 river productivity sample
results based on laboratory data received after the ISR submittal in June 2014.
• Attachment G: River Productivity Study (Study 9.8) - 2014 Field Season River
Productivity Progress Report Technical Memorandum. This technical
memorandum presents an update on activities conducted during the Spring
field sampling event in June 2014, which was focused on data collection to
support the needs of the trophic modeling and stable isotope analysis
objectives of the River Productivity Study.
3
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)
FERC PDF
20140929-5059
Susitna-Watana Hydroelectric Project, FERC Project no. 14241-000; Second Set of
2014 Technical Memoranda for Initial Study Plan Meetings
This cover letter accompanied seven reports:
• Attachment A: Geomorphology Study (Study 6.5) - Updated Mapping of
Aquatic Macrohabitat Types in the Middle Susitna River Segment from 1980s
and Current Aerials Technical Memorandum.
• Attachment B: Geomorphology Study (Study 6.5) - Mapping of Geomorphic
Features and Turnover within the Middle and Lower Susitna River Segments
from 1950s, 1980s, and Current Aerials Technical Memorandum
• Attachment C: Fluvial Geomorphology Modeling below Watana Dam Study
(Study 6.6) - Decision Point on Fluvial Geomorphology Modeling of the
Susitna River below PRM 29.9 Technical Memorandum.
• Attachment D: Fluvial Geomorphology Modeling Below Watana Dam (Study
6.6) - Winter Sampling of Main Channel Bed Material Technical
Memorandum.
• Attachment E: Cook Inlet Beluga Whale Study (Study 9.17) - 2014 Cook Inlet
Beluga Whale Prey Study Implementation Technical Memorandum.
• Attachment F: River Productivity Study (Study 9.8) - 2013 Initial River
Productivity Results Technical Memorandum.
• Attachment G: River Productivity Study (Study 9.8) - 2014 Field Season River
Productivity Progress Report Technical Memorandum.
The cover letter and seven attachments are catalogued as a set of documents in the
library catalog and are numbered SuWa 239 – SuWa 246. They are available in print
format at ARLIS and are available online at:
http://www.arlis.org/docs/vol1/Susitna2/2/SuWa239.html
20140930-5303
September 30, 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
Third Set of 2014 Technical Memoranda for Initial Study Plan Meetings
Dear Secretary Bose:
As the Alaska Energy Authority (AEA) explained in its September 17, 2014 filing
with the Federal Energy Regulatory Commission (Commission or FERC) for the
proposed Susitna-Watana Hydroelectric Project, FERC Project No. 14241 (Project), the
June 3, 2014 Initial Study Report (ISR) provided for AEA to prepare certain technical
memoranda and other information based on 2014 work. In accordance with Commission
Staff direction, on September 17 and September 26, AEA filed and distributed the first
and second sets of technical memoranda and other information generated during the 2014
study season.
With this letter, AEA is filing and distributing the third set of technical
memoranda generated during the 2014 study season, as described below.
This third set of technical memoranda includes:
• Attachment A: Baseline Water Quality Study (Study 5.5) and Water Quality
Modeling Study (Study 5.6), Water Quality and Lower River Modeling
Technical Memorandum. This technical memorandum evaluates water quality
data collected during 2013 and 2014 for adequacy in representation of current
riverine conditions. This Technical Memorandum further includes an
assessment of whether to extend the Water Quality Modeling Study’s riverine
model below PRM 29.9.
• Attachment B: Mercury Assessment and Potential for Bioaccumulation Study
(Study 5.7), Evaluation of Continued Mercury Monitoring Beyond 2014
Technical Memorandum. This technical memorandum evaluates the need for
continued monitoring of mercury data beyond 2014 and whether the existing
data collection efforts are sufficient to satisfy objectives for characterizing
baseline mercury conditions in the Susitna River and tributaries (Revised
Study Plan (RSP) Section 5.7.1).
20140930-5303 FERC PDF (Unofficial) 9/30/2014 3:56:08 PM
2
• Attachment C: Groundwater Study (Study 7.5), Preliminary Groundwater and
Surface-Water Relationships in Lateral Aquatic Habitats within Focus Areas
FA-128 (Slough 8A) and FA-138 (Gold Creek) in the Middle Susitna River
Technical Memorandum. This technical memorandum provides an overview
of the types of data and information that are being collected to support the
Task 6 activities of the Groundwater Study, and describes the methods and
techniques that are being applied in analyzing the data leading to development
of response functions to be used for evaluating Project operational
effects. The TM centers on the analysis for FA-128 (Slough 8A) and to a
lesser extent FA-138 (Gold Creek) and represents an expansion of the
presentation materials provided during the Proof of Concept meetings held on
April 15-17, 2014.
• Attachment D: Groundwater Study (Study 7.5), Groundwater and Surface-
Water Relationships in Support of Riparian Vegetation Modeling Technical
Memorandum. This technical memorandum provides an overview of the
types of data and information that are being collected to support the Task 5
activities within the Groundwater Study, and describes the methods and
techniques that are being applied in analyzing the data leading to development
of response functions for evaluating Project operational effects. The TM
provides analysis objectives for FA-115 (Slough 6A) as a primary example of
upland versus riverine dominated groundwater conditions. Additional
examples are shown for FA-128 (Slough 8A) and FA-138 (Gold Creek).
• Attachment E: Salmon Escapement Study (Study 9.7), 2014 Implementation
and Preliminary Results Technical Memorandum. This technical
memorandum describes 2014 implementation (including methods and
variances) of and preliminary results from the Salmon Escapement Study.
• Attachment F: Cook Inlet Beluga Whale Study Plan (Study 9.17), 2015
Implementation Plan Technical Memorandum. This implementation plan
describes the methods for study activities proposed for 2015 that would
implement the Cook Inlet Beluga Whale Study (instead of those described in
RSP Section 9.17.1).
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.
20140930-5303 FERC PDF (Unofficial) 9/30/2014 3:56:08 PM
3
Sincerely,
Wayne Dyok
Project Manager
Alaska Energy Authority
Attachments
cc: Distribution List (w/o Attachments)
20140930-5303 FERC PDF (Unofficial) 9/30/2014 3:56:08 PM
FERC PDF
20140930-5303
Susitna-Watana Hydroelectric Project, FERC Project no. 14241-000; Third Set of 2014
Technical Memoranda for Initial Study Plan Meetings
This cover letter accompanied six reports:
• Attachment A: Baseline Water Quality Study (Study 5.5) and Water Quality
Modeling Study (Study 5.6), Water Quality and Lower River Modeling
Technical Memorandum.
• Attachment B: Mercury Assessment and Potential for Bioaccumulation Study
(Study 5.7), Evaluation of Continued Mercury Monitoring Beyond 2014
Technical Memorandum.
• Attachment C: Groundwater Study (Study 7.5), Preliminary Groundwater and
Surface-Water Relationships in Lateral Aquatic Habitats within Focus Areas
FA-128 (Slough 8A) and FA-138 (Gold Creek) in the Middle Susitna River
Technical Memorandum.
• Attachment D: Groundwater Study (Study 7.5), Groundwater and Surface-
Water Relationships in Support of Riparian Vegetation Modeling Technical
Memorandum.
• Attachment E: Salmon Escapement Study (Study 9.7), 2014 Implementation
and Preliminary Results Technical Memorandum.
• Attachment F: Cook Inlet Beluga Whale Study Plan (Study 9.17), 2015
Implementation Plan Technical Memorandum.
The cover letter and six attachments are catalogued as a set of documents in the library
catalog and are numbered SuWa 247 – SuWa 253. They are available in print format at
ARLIS and are available online at:
http://www.arlis.org/docs/vol1/Susitna2/2/SuWa247.html
20141003-3041
FEDERAL ENERGY REGULATORY COMMISSION
WASHINGTON, DC 20426
October 3, 2014
OFFICE OF ENERGY PROJECTS
Project No. 14241-000—Alaska
Susitna-Watana Hydroelectric Project
Alaska Energy Authority
Wayne Dyok
Project Manager
Alaska Energy Authority
813 West Northern Lights Boulevard
Anchorage, AK 99503
Reference: Response to Filing of Technical Memoranda and Modification of ILP
Process Plan and Schedule
Dear Mr. Dyok:
This letter contains our response to the filing of Alaska Energy Authority’s (AEA)
30 “technical memoranda” on September 17, 29, and 30, 2014 for the Susitna-Watana
Hydroelectric Project No. 14241, and modifies the Integrated Licensing Process (ILP)
plan and schedule to provide additional time for ILP participants to review the technical
memoranda.
Background
On January 6, 2014, AEA filed a request for an extension of time to file the Initial
Study Report (ISR) under the ILP for the project from February 3, 2014, to June 3, 2014,
and to postpone most second-season studies scheduled for 2014 until 2015. Specifically,
AEA stated that in 2014, it would: only complete studies with a winter component
already scheduled for early 2014 or those studies that did not require sustained logistical
support; continue ongoing study components such as monitoring and wildlife tracking at
sites where equipment had already been installed; develop and calibrate analytical models
for the project; and continue an analysis of data gathered in 2012 and 2013 in comparison
with data collected in the 1980’s. Several licensing participants filed comments on the
proposed extension of time request and revised schedule, stating, among other things, that
the revised schedule would create a hardship for many of the licensing participants
because it would shift review and comment on the ISR to the busy summer season when
many of the participants would be engaged in field studies or operating tourism-based
20141003-3041 FERC PDF (Unofficial) 10/03/2014
2
businesses. The commenters recommended postponing the ISR meeting by at least 120
days beyond the June 18, 2014 date proposed by AEA.
By letter order issued on January 28, 2014, Commission staff granted AEA’s
request to extend the ISR due date to June 3, 2014, and to postpone most second-season
studies until 2015. Commission staff also granted the commenter’s requests to extend the
deadline for holding the meeting by at least 120 days by establishing a meeting date of
October 16, 2014. The letter order included a revised process plan and schedule
commensurate with the approved extensions of time.
On June 3, 2014, AEA filed its ISR, which contains a description of AEA’s
progress in implementing the 58 studies required by the ILP study plan, an explanation of
instances where the study method used varied from that required by the study plan, and
AEA’s proposed modifications to the study plan. In the ISR filing, AEA also states that
it had double the budget that it anticipated it would have when it made its extension of
time request in January 2014, and therefore, included an updated and more extensive
scope of work for summer 2014 studies.
On September 17, 29, and 30, 2014, AEA filed a total of 30 technical memoranda
into the project record for consideration in the upcoming Director’s determination on
modifications to the study plan. The 30 technical memoranda include: (1) proposed
study plan modifications; (2) the results of studies conducted during 2013 and 2014 that
were not available at the time AEA filed the ISR in June 2014; (3) the results of second
season studies that had been postponed until 2015 by Commission staff’s January 28,
2014 letter order, but AEA decided to conduct one year ahead of schedule in 2014; and
(5) the results of studies not required by the approved study plan to occur in 2014, but
AEA decided to conduct in 2014 to maintain continuity of study results between 2013
and 2015. In the filings, AEA states that it wishes to discuss the information presented in
the technical memoranda at the ISR meetings scheduled for October 15-17 and October
21-23, 2014, and that the information provided in the technical memoranda will help to
inform the decision on the need for modifications to the study plan.
On September 22, 2014, the National Marine Fisheries Service (NMFS) responded
to the September 17, 2014 technical memoranda requesting that AEA adhere to the
approved ILP schedule by only discussing the June 3, 2014 ISR at the October 2014 ISR
meetings. NMFS did not make any recommendations as to how the 30 technical
memoranda should be addressed.
Discussion
The Commission’s ILP regulations state that the purpose of the ISR meeting is for
the potential license applicant and ILP participants to discuss the study results and any
proposals for study plan modifications in light of the progress on the study plan and data
20141003-3041 FERC PDF (Unofficial) 10/03/2014
3
collected.1 The information presented in the technical memoranda supplement study data
presented in the ISR; therefore, consistent with the stated purposes of the ISR meeting,
presentation and discussion of the technical memoranda at an ISR meeting would help to
inform the ILP participants on needed study plan modifications.
However, the filing of technical memoranda is neither a milestone under the ILP
regulations nor under the approved ILP plan and schedule for the project. When the
project’s ILP plan and schedule were last revised, at AEA’s request, in January 2014,
there were no expectations on the part of ILP participants, including Commission staff,
that technical memoranda would be filed and discussed at the October 2014 ISR meeting.
The volume of additional information included in the 30 technical memoranda is not
inconsequential in that it comprises over 1,800 pages, and when added to the several
thousands of pages of material already provided in the ISR, would be difficult to present
and discuss in the time allotted for the October 2014 ISR meetings. Therefore, this letter
modifies the ILP process plan and schedule for the project to require AEA to hold a
second set of ISR meetings in January 2015 to provide ILP participants with sufficient
time to review the new material and provide sufficient time to discuss the new material at
an ISR meeting. Subsequent ILP milestones are modified, accordingly in Attachment A.
We note that the new due date for the Director’s determination on study plan
modifications is April 22, 2015.
In the interest of efficiency and to provide ILP participants with sufficient time to
review the technical memoranda, we recommend that at the October 2014 meetings, AEA
focus its presentations predominantly on the data provided in the June 3, 2014 ISR, and,
where feasible, hold any discussion on data presented in the 30 technical memoranda
until the January 2015 meetings.
If you have any questions, please contact Nicholas Jayjack at (202) 502-6073.
Sincerely,
Jeff Wright
Director
Office of Energy Projects
1 See 18 C.F.R. §5.15(c)(2) (2014).
20141003-3041 FERC PDF (Unofficial) 10/03/2014
4
Enclosure:Attachment A—Revised Process Plan and Schedule
cc:Mailing List
Public Files
20141003-3041 FERC PDF (Unofficial) 10/03/2014
5
ATTACHMENT A
REVISED SUSITNA PROJECT PROCESS PLAN AND SCHEDULE
If a due date falls on a weekend, holiday, or other day on which the Commission is
not open for business, the due date is the following business day.
Responsible
Party
Pre-Filing Milestone Date
AEA File Initial Study Report June 3, 2014
AEA Hold First Initial Study Report Meetings October 16, 2014
AEA Hold Second Initial Study Report Meetings January 7, 2015
AEA File Initial Study Report Meeting Summary
(October 2014 and January 2015 Meetings,
combined)
January 22, 2015
All
Stakeholders
File disagreements with Meeting Summary and
recommendations for modified or new studies
February 21, 2015
All
Stakeholders
File responses to meeting summary disagreements
and recommendations for modified or new studies
March 23, 2015
FERC Issue Director Determination on meeting
summary disagreements and recommendations for
modified or new studies
April 22, 2015
AEA Second Study Season 2015
AEA File Updated Study Report February 1, 2016
AEA Hold Updated Study Report Meeting February 16, 2016
AEA File Updated Study Report Meeting Summary March 2, 2016
All
Stakeholders
File disagreements with Meeting Summary and
recommendations for modified or new studies
April 1, 2016
20141003-3041 FERC PDF (Unofficial) 10/03/2014
6
Responsible
Party
Pre-Filing Milestone Date
All
Stakeholders
File responses to meeting summary disagreements
and recommendations for modified or new studies
May 1, 2016
FERC Issue Director Determination on meeting
summary disagreements and recommendations for
modified or new studies
May 31, 2016
AEA Third Study Season (if required)2016
AEA File Preliminary Licensing Proposal or Draft
License Application
July 5, 2016
All
Stakeholders
File comments on Preliminary Licensing Proposal
or Draft License Application
October 3, 2016
AEA File License Application December 1, 2016
20141003-3041 FERC PDF (Unofficial) 10/03/2014
20141007-5131
October 7, 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 Study Report Meetings
The Alaska Energy Authority (AEA) is in receipt of the letter from Mr. Jeff
Wright, Director, Federal Energy Regulatory Commission (Commission), Office of
Energy Projects, dated October 3, 2014, regarding the 2014 study results and changes to
the Integrated Licensing Process (ILP) plan and schedule (October 3 Letter). AEA
appreciates the Commission’s direction on integration of the 2014 study results into the
licensing process, and has no objection to a second set of Initial Study Report (ISR)
meetings in January 2015 to discuss the results of studies conducted in 2014.
Although we will focus our October presentations on material submitted in the
June 2014 ISR filing, there are two types of instances in which 2014 study results have
been included in AEA’s ISR presentations. The first is where the results of 2014 studies
bear directly on the discussion of future study plans or proposed modifications; in these
cases, limiting discussions to 2013 data would provide an incomplete or distorted picture.
The second is where Commission-approved studies begun in 2013 were completed in
2014. Thus, while AEA’s presentations will predominantly involve 2013 data, it is not
feasible to defer all discussions of 2014 data. In addition, State resource agencies have
conveyed to AEA that they expect to discuss 2014 study results in the October ISR
meetings. Licensing participants will be not be required to comment on, or ask questions
about, the 2014 study results at the October ISR meetings. However, AEA expects that
the entities who have consistently requested additional data and information would
welcome the opportunity to be presented this additional information collected during the
study implementation process.
The 2014 study results and their applicability will be fully discussed in the
January 2015 ISR meetings as directed by the Commission.1 AEA notes that moving the
Director’s determination on requests for modified or new studies from January to April
2015 could affect AEA’s ability to implement certain biological studies in 2015. AEA
1 In addition to the technical memoranda filed with the Commission in September as noted by the
Commission’s October 3 Letter,there are data from the 2014 field season that AEA and its contractors are
still in the process of reviewing. Once the data have been QA/QC’d, they will be posted to the Project
website per AEA’s past practice. These data will be available to licensing participants well in advance of
the January ISR meetings.
20141007-5131 FERC PDF (Unofficial) 10/7/2014 2:57:22 PM
2
may seek to revisit this if there are critical path studies that could be affected by that
timing.
AEA would like to take this opportunity to address some other suggestions and
requests regarding the ISR meetings that it has received from licensing participants.
First, it has been requested that AEA avoid long presentations summarizing studies, and
leave the majority of time for licensing participants to offer their analysis and proposals
for modification. AEA plans to limit its presentations to a few minutes, depending on the
study, and to focus the presentations on explaining any study variances and AEA’s
proposed modifications to future study implementation. AEA will leave ample meeting
time to discuss licensing participants’ proposals.
Second, it has been requested that AEA provide specific meeting agendas at least
two weeks in advance of the meetings. AEA has been posting the meeting agendas and
the study plan presentations on its Project website two weeks in advance of each meeting
day. See http://www.susitna-watanahydro.org/meetings/.
Third, licensing participants have requested that the meetings be recorded and that
transcripts be provided to licensing participants. AEA will have a court reporter at the
meetings and the transcripts will be posted to the Project website and filed in the
Commission’s docket following the meetings. Thus, although the Commission’s revised
schedule does not call for AEA’s meeting summary of the October ISR meetings to be
provided until after the January 2015 ISR meetings, the actual record of the October ISR
meetings will be available to licensing participants and the Commission much sooner.
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
cc: Distribution List
20141007-5131 FERC PDF (Unofficial) 10/7/2014 2:57:22 PM
20141008-5071
October 7, 2014
James W. Balsiger
Administrator, Alaska Region
National Marine Fisheries Service
P.O. Box 21668
Juneau, Alaska 99802-1668
Re: Susitna-Watana Hydroelectric Project, FERC Project No. 14241-000
Dear Mr. Balsiger:
The Alaska Energy Authority (AEA) is in receipt of a letter from the National
Marine Fisheries Service (NMFS) dated September 22, 2014,1 in which you provide
comments on portions of the Initial Study Report (June 3, 2014) (ISR) for the proposed
Susitna-Watana Hydroelectric Project, Federal Energy Regulatory Commission (FERC)
Project No. 14241 (Project). Your letter raises a number of what it refers to as “issues
with the data,” including alleged questionable data collection methods, absence of
quantitative analysis, and inappropriate scale of data collection, among others. You
opine that these supposed anomalies mean that “it is not plausible that the data for
predictive modeling be used to describe baseline conditions or to predict potential
impacts,” and that “these issues must be resolved prior to conducting additional field
studies.” In other words, you believe we are at a standstill.
Frankly, for NMFS to take the position that the massive amount of scientific data
AEA has collected and summarized in the ISR is unreliable is untenable, bordering on the
absurd. As documented in the ISR, AEA was largely successful in implementing the
FERC-approved study plan in 2013. This effort included, among many other studies, a
large-scale field effort for fishery studies with a suite of 10 studies covering more than
200 sampling sites across more than 200 miles of river, with sampling occurring during
not only the open water period but also during winter and spring periods. Your letter,
however, focuses on the limited exceptions in which AEA’s data collection varied from
FERC-approved study plan methods during the 2013 field season. These variances, as
we all know, occurred mostly due to private land access issues, and conditions in the field
such as the late ice breakup in the spring of 2013. The ISR includes a detailed
description of proposed modifications to the study plan to account for these variances.
1 Letter from James W. Balsiger, National Marine Fisheries Service, to Wayne Dyok, Alaska Energy Authority,
Project No. 14241-000 (filed with Federal Energy Regulatory Commission on September 23, 2014).
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
2
Noticeably absent from your letter is any critique or analysis of AEA’s proposed
modifications, or any alternative method that would help achieve study plan objectives in
light of the variances.
AEA also takes exception to any suggestion that it has not implemented the
FERC-approved study plan in a professional manner. The fisheries field work was led by
nationally renowned experts in their respective fields, representing five independent
contractors, all with significant hydropower licensing and Alaska experience. The field
technicians employed by these contractors are highly qualified, and many have advanced
degrees from the University of Alaska-Fairbanks and University of Alaska-Anchorage.
In contrast, NMFS’s generalized comments either ignore the data and analysis presented
in the ISR, or reflect a fundamental lack of understanding of the methodologies being
relied upon by the FERC-approved study plan, which NMFS helped develop.
For example, NMFS asserts that AEA has misidentified or was unable to identify
juvenile fish species in its field sampling efforts. As you should know, all field
identifications of juvenile salmon are subject to error due to the inherent variations in
each species’ distinguishing characteristics at those life stages. Your letter claims we
have an unacceptable level of error because the juveniles we identified as Chinook
salmon in our samples were too large, and too many were found in sloughs or with
beaver ponds. We instructed our crews to make field calls based on the physical
characteristics used for distinguishing coho and Chinook salmon, not on their size or
where they were found. There are several possible explanations for why larger juveniles
might be found in the sloughs, including displacement during the 2012 fall flood, or
during 2013 spring flooding at breakup, or as a result of ice processes. Simply to dismiss
the possibility that these fish were Chinook because of where they were found would
have been unscientific. You also cite an unusually large number of unidentified juveniles
in our sampling. Our field crews followed instructions per AEA’s Quality
Assurance/Quality Control (QA/QC) measures that, when unable to make a call in the
few seconds that is safe to hold a juvenile fish out of water, they should subsample in a
location by photographing juveniles and collecting genetic samples and voucher
specimens. The senior scientists from our study team and Alaska Department of Fish and
Game staff review these photographs, genetic samples, and vouchers to verify field
identification. Some unidentified salmon calls remain at some sites, but these are not
material to the objectives of relevant studies (Studies 9.5 and 9.6).
Under the FERC-approved study plan (Studies 8.5, 9.5, and 9.6), the purpose of
this particular data collection effort is to determine the distribution of fish species within
different aquatic habitats. This information will be used as inputs to habitat models.
Whether a specific juvenile salmon is correctly identified as coho versus Chinook salmon
will have no bearing whatsoever on the outcome of the habitat modeling because these
models will consider all life stages of all five of the Pacific salmon species present in the
Susitna basin. With respect to coho and Chinook salmon, the habitat suitability criteria
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
3
for the rearing life stages of these species substantially overlap, ensuring that the model
will adequately characterize the most protective habitat for both species.
Your letter also contains a number of outright errors and instances in which you
ignore available information. Among these, your letter states that there was an “absence
of pink salmon in any samples.” However, pink salmon counts are reported in several
tables in the ISR. Your letter also states that AEA did not include estimates of relative
abundance, yet relative abundance is presented in the ISR in text and detailed tables of
“catch per unit effort.” Your letter states that fish passage criteria have not been
developed—they have been developed, and reviewed with licensing participants
including NMFS at the March 19, 2014 fish barriers technical meeting.
Attached to this letter is a comment-response table that addresses in detail each of
the comments in your September 22 letter. I think you will agree, on careful review of
our responses, that the 2013 study program provides a solid foundation of data upon
which we can continue to build.
AEA remains committed to implementing the comprehensive suite of studies
proposed in the FERC-approved study plan and encourages NMFS to work with us in
good faith in studying the feasibility of and potential effects associated with an
undertaking that is critically important to Alaskans. If you have questions or comments
concerning this matter, please feel free to contact me directly at (907) 771-3955.
Sincerely,
Wayne Dyok
Project Manager
Alaska Energy Authority
Attachment
Cc: Distribution List
Samuel D. Rauch III
Jeff Wright
Ann Miles
Vince Yearick
Dr. Jennifer Hill
Nick Jayjack
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 1 October 2014
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
OCTOBER 7, 2014
Comment
Page
Para
Comment
Number Comment Response
Page 4 1
Para 5
1 1) Habitat classification has not been
completed;
This comment ignores the data and analysis presented in the ISR. Remote habitat classification was
completed in 2013, as presented in Study 9.9 ISR Sections 5.1 and 5.2, and Study 6.5 ISR Section 5.4
and Part 2 of 3 Figures. Land access restrictions resulted in a delay to complete the field surveys to
ground-truth remote classification. The variance regarding delay in the ground-truthing study
component was addressed in Study 9.9 ISR Section 4.2.4.
The schedule for completion of the ground-truthing surveys was presented in 9.9 ISR Section 7.2.
All field work was completed in 2014 as described in the 2013 and 2014 Aquatic Habitat Mapping
Field Season Completion Progress Technical Memorandum that was filed with FERC on September
17, 2014.
Page 4
Para 6
2 2) Fish passage criteria have not been
developed;
AEA disagrees. With respect to Study 9.12 Fish Passage Barriers, AEA proposed leaping, depth, and
velocity criteria. AEA reviewed this criterion with the Licensing Participants during Interdisciplinary
Fish Barriers Technical Meeting on March 19, 2014.
Page 4
Para 7
3 3) Fish sampling study plans were not
followed; sampling units were
inappropriately subsampled;
This comment ignores the data and analysis presented in the ISR. The Fish Distribution and
Abundance Study Plan Determination and Final Implementation Plan (filed April 1, 2013) were
implemented by AEA field crew. However, as noted and explained in Study 9.5 ISR Section 4.4.4,
there were variances to the plan methods that occurred during implementation, including sub-
sampling GRTS panels and transects sites in the Upper River, as a result of conditions in the field.
NMFS does not acknowledge the reason for the variances or AEA’s proposed modifications to
account for them, nor does it explain why subsampling was inappropriate in the circumstances. AEA
conducted additional analysis of the data collected in the Upper River and proposed modifications in
Study 9.5 ISR Section 7.1.2 to ensure that the data will meet all Study 9.5 objectives. This
information also was presented in a Fish Technical Meeting on March 20, 2014 and input from
stakeholders including NMFS was solicited. The modifications, as proposed in Study 9.5 ISR
Section 7.2, were implemented in 2014 to collect data supplemental to the 2013 field effort. The
results of the 2014 surveys were summarized in the Proposed 2015 Modifications to Fish Distribution
and Abundance Study Plan Implementation Technical Memorandum filed with FERC on September
1 Page and Paragraph Numbering:
• Partial sentences at the top of a page are considered Sentence 1.
• Partial paragraphs at the top of a page are considered Paragraph 1.
• Paragraphs are numbered by their position on a page, not within a Section.
• Paragraphs are blocks of text separated by hard returns; each heading, bullet, and item in a numbered list is considered one paragraph.
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 2 October 2014
Comment
Page
Para
Comment
Number Comment Response
17, 2014.
Page 4
Para 8
4 4) Fish sampling locations did not
incorporate FERC recommendations;
This comment ignores the data and analysis presented in the ISR. Fish sampling locations followed
the FERC recommendations where feasible. As explained in Studies 9.5 and 9.6, there were some
variances due to field conditions and land access limitations. These variances did not affect the
quality or the integrity of the data collected, or the ability to meet study plan objectives.
Page 4
Para 9
5 5) Because the fish sampling did not follow
the sampling plan, this resulted in an
inability to estimate relative fish abundance;
AEA disagrees that variances from the sampling plan identified in Comments 3 and 4 resulted in an
inability to obtain accurate estimates. See answers to Comments 3 and 4. Estimates of relative
abundance are reported in Study 9.5 ISR Sections 5.1.2, 9.5, and Appendix E (Upper River Fish
Observations and Relative Abundance 2013) as well as Study 9.6 ISR Section 5.1.2 and Appendix E
(Relative Abundance Tables).
Page 4
Para 10
6 6) Fish seem to have been identified
incorrectly;
Please see below for responses to specific comments concerning fish identification.
Page 4
Para 11
7 7) Data were collected and reported at
inappropriate mesohabitat scales;
This comment ignores the data and analysis presented in the ISR. Fish Distribution and Abundance
(FDA) data were collected and reported at meso- and macro-habitat scales consistent with the study
plan (Study 9.5 ISR Section 4.4.2 and Study 9.6 ISR Section 4.4.2). Based on USFWS comments,
Comment 7 appears to be specific to the Barrier Study (Study 9.12) and the HSI/HSC component of
the IFS Study (Study 8.5). The Fish Barriers and IFS studies are collaborating, regarding target
species, passage criteria, and sampling locations. This will ensure that the model outputs from IFS
are useful for analysis of passage barriers.
Page 4
Para 12
8 8) Sampling sites among studies were not
co-located;
This is incorrect; the sampling sites were co-located. This comment ignores the data and analysis
presented in the ISR. AEA’s selection of sampling sites was consistent with the River Productivity
Implementation Plan. As presented in the River Productivity Implementation Plan Section 2.1: “All
stations established within the Middle River Segment will be located at Focus Areas established by
the Instream Flow Study (AEA 2012, Section 8.5.4.2.1.2), in an attempt to correlate
macroinvertebrate data with additional environmental data (flow, substrates, temperature, water
quality, riparian habitat, etc.) collected by other studies (e.g., AEA 2012, Section 5.5, Baseline Water
Quality), for uses in statistical analyses, and HSC/HSI development. Furthermore sites for Fish
Distribution and Abundance, Habitat Suitability Criteria, and River Productivity were all co-located
within Middle River Focus Areas. In 2013, private land access restrictions prevented fish sampling
in some desired locations, yet River Productivity sampling was able to be conducted because the sites
for that study were located in mainstem and within ordinary high water. Maps depicting the co-
locations of sampling sites among these three studies will be presented in the October 15, 2014 ISR
meeting.
Page 4
Para 13
9 9) Tagging goals were not met; This comment ignores the data and analysis presented in the ISR. Tagging goals were generally, but
not precisely, met for every location and species in the Escapement Study in 2013 (9.7 Section 4.1.4).
These few discrepancies do not affect the quality or the integrity of the data collected. In the Lower
River, the targets were 700 Chinook salmon, 600 coho salmon, and 200 pink salmon. Actual tagging
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 3 October 2014
Comment
Page
Para
Comment
Number Comment Response
numbers were 698 Chinook salmon, 596 coho salmon, and 197 pink salmon. At the Yentna, 690
Chinook salmon were tagged as compared to the 700 fish target. In the Middle River, tagging targets
were met for all salmon species except sockeye; 139 sockeye were tagged out of the 200 fish target.
For resident species tagging target in Studies 9.5 and 9.6, the study plan indicated that “the goal is to
implant 30 radio transmitters per target species” and the winter movement objective specified “up to
30” fish as the target for burbot, humpback whitefish and round whitefish. In 2013, progress was
made toward these goals as indicated in Study 9.6 ISR Section 4.5.2 and Study 9.6 ISR Section 4.5.2.
Further progress toward the tagging goals was made in 2014 and will be presented at the ISR meeting
on October 15, 2014.
Page 4
Para 14
10 10) Fish targets for HSC sampling were not
met;
This comment ignores the data and analysis presented in the ISR and reflects a fundamental lack of
understanding of the methodologies being relied upon by the FERC-approved study plan. The
targets pertain to the total number of HSC data points collected over the entire licensing study period,
not one field season. Absolute target numbers were not established for HSC data collection (see RSP
8.5.4.5.1.1.5) for the first year of study, or the licensing study period in general. The FERC-approved
Study Plan noted that: “If possible, a minimum of 100 habitat use observations will be collected for
each target species life stage. However, the actual number of measurements will be based on a
statistical analysis that considers variability and uncertainty. While information will be collected on
all species and life stages encountered, the locations, timing, and methods of sampling efforts may
target key species and life stages identified in consultation with the TWG.” This was discussed
during several TWG meetings where it was emphasized that the approach AEA is taking in
developing HSC curves will include several components, including collection of new site specific
data, which is AEA’s and agencies preferred approach, as well as other approaches for species or life
stages infrequently encountered. AEA listed those in RSP 8.5.4.5.1.1 and included use of existing
site specific data collected during the 1980s studies, use of site specific data from other similar
Alaska systems, as well as professional opinion.
A summary of HSC collection efforts to date is provided below. As noted, there are a number of
species for which the numbers of observations have exceeded 100, including those for Chinook
salmon juvenile, Chum fry and spawning, Coho fry, Sockeye fry and spawning, Arctic Grayling fry,
and whitefish fry. These species and life stage mixes reflect the majority of the target species and life
stages that are central to the habitat-flow modeling for evaluating Project effects.
Species Lifestage 2013 2014
Through July
Project
Total
1980s
Total
Chinook Fry 54 164 218
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 4 October 2014
Comment
Page
Para
Comment
Number Comment Response
Juvenile 38 25 63
Chum Fry 14 258 272
Spawning 348 348 333
Coho Fry 99 181 280
Juvenile 56 28 84
Pink Fry 0 39 39
Spawning 59 0 59 NR
Sockeye Fry 79 299 378
Spawning 181 181 81
Arctic Grayling Fry 113 7 120
Juvenile 43 9 52
Adult 4 4 8 140
Burbot Juvenile 2 4 6
Adult 17 3 20 18
Dolly Varden Fry 20 20
Adult 1 1 2 2
Longnose Sucker Fry 41 46 87
Juvenile 52 27 79
Adult 70 3 73 157
Rainbow Trout Juvenile 5 2 7
Adult 6 1 7 143
Whitefish Fry 39 73 112
Juvenile 39 15 54
Adult 29 4 33 384
Additional HSC/HSI sampling is planned for the next year of study and it is anticipated that most
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 5 October 2014
Comment
Page
Para
Comment
Number Comment Response
HSC relationships will be updated. However, for species and life stages that are rarely observed,
final HSC curves may be based on additional data, including utilization data from 2012 and the 1980s
studies on the Susitna River. Even then, there may still be some species where few or no empirical
HSC/HSI data were able to be collected. In those cases, AEA will consider other methods for
developing curves. This may include the use of literature based curves, developing envelope curves
(see, for example, Jowett et al. 1991, and GSA BBEST 2011), guilding (e.g., creating a combined
HSC/HSI curve representing multiple species and/or life stages; see, for example, Vadas, Jr. and
Orth 2001, GSA BBEST 2011), developing curves based on expert opinion/round table discussions)
and the use of Bayesian statistical methods for updating data distributions (see, for example,
Hightower 2012).
Page 4
Para 15
11 11) The mainstem upper river migrant fish
trap was not installed;
This comment ignores the data and analysis presented in the ISR. This variance was identified in
Study 9.5 ISR Section 4.1.6.2 due to lack of access to areas above the ordinary high water mark.
AEA completed this task in 2014 as described in Study 9.5 ISR Section.7 and TM for Study 9.05.
Page 4
Para 16
12 12) A fish wheel was not installed, and fish
were not tagged near the entrance to Devils
Canyon;
This comment ignores the data and analysis presented in the ISR. This variance was described in
Study 9.7 ISR Section 4.1.8.1. This change in tagging location was compensated for by increased
fishwheel effort and an increase in tagging targets at the Curry fishwheels.
Page 4
Para 17
13 13) Additional problems associated with
late installation and operation of migrant
traps were likely influenced by
environmental conditions associated with
late breakup; and
Downstream migrant traps were installed and operated as indicated in the Study 9.5 ISR Section
9.5.4.4.10 and Study 9.6 ISR Section 9.6.4.4.10: “flow conditions permitting, traps will be fished on
a cycle of 48 hours on, 72 hours off throughout the ice-free period.” As soon as break-up and flow
conditions allowed in mid-June 2013 traps were fished immediately upon installation in June through
mid-October 2013. In 2014 breakup occurred earlier and migrant traps installation occurred in mid-
May with traps operated immediately after installation (the Proposed 2015 Modifications to Fish
Distribution and Abundance Study Plan Implementation Technical Memorandum filed with FERC on
September 17, 2014).
Page 4
Para 18
14 14) Juvenile salmon distribution and
abundance in 2013 were likely affected by
the record fall floods in 2012.
AEA agrees that floods can affect juvenile salmonid abundance. While the fall 2012 floods did not
approach the magnitude of the flood of record, they potentially distributed juvenile salmonids into
lateral habitats that may not otherwise be occupied during a low water year. AEA believes that the
range of hydrologic events that occur over the multi-year study period provide opportunities to better
understand the response of aquatic resources to flow fluctuations.
Page 4
Para 20 –
Page 5
Para 1
15 The actual implementation of the abundance
sampling program did not follow the
statistical models used to select sampling
units. In particular, subareas (mesohabitats)
within selected areas were ‘randomly’
selected for subsampling, and sampling was
not consistent between sampling events
AEA disagrees. This comment reflects a fundamental lack of understanding of the methodologies
being relied upon by the FERC-approved study plan. The random selection of meso-habitat units
within GRTS selected panel sites and at transects was implemented as proposed in the Fish
Distribution and Abundance Implementation Plan filed with FERC on March 1, 2013.
The use of different gears consistent with habitat characteristics was implemented as proposed in the
Fish Distribution and Abundance Implementation Plan filed with FERC on March 1, 2013 with
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 6 October 2014
Comment
Page
Para
Comment
Number Comment Response
(different gears, different effort, different
order of gears, different total area sampled,
etc.). Sampling error in the fish distribution
and relative abundance studies needs to be
accounted for in order for these studies to
accurately estimate fish distribution and
abundance. Estimates of numbers of
Chinook salmon that migrate above Devils
Canyon need to include the assumptions,
standard error, and resulting statistical
confidence intervals associated with that
estimate. Better descriptions of (and
statistical accounting for) both sampling and
non-sampling errors need to be provided.
The data used to describe fish-habitat
association preferences and the standard
errors associated with those species and
life-stage habitat correlations need to be
validated, as this analysis proposes to
describe macrohabitat relationships for fish.
These relationships will be used to evaluate
project effects, to validate instream flow
habitat model predictions, and to
extrapolate results from focus areas to
geomorphic reaches and river segments.
Ultimately these data will be used to
develop protection and mitigation measures
and to serve as a basis for post-project
monitoring.
modification described in Study 9.5 ISR Section 4.4.4 and Study 9.6 ISR Section 4.4.4.
AEA disagrees that sampling error will impact AEA’s ability to meet objectives of fish distribution
and abundance sampling for Studies 9.5 and 9.6. The fish distribution and relative abundance
methods were implemented consistent with Studies 9.5 and 9.6 RSPs, the Fish Distribution and
Abundance Implementation Plan, and FERC’s SPD.
As described in RSP Section 9.7.4.1.5 (Objective 1) and Section 9.7.4.6 (Objective 6), AEA planned
to examine fish on selected spawning grounds (e.g., Indian River) in part to establish mark rates
(proportion of fish tagged) so that inferences could be made about the representativeness of tagging
across stocks. In addition, AEA stated that mark rates from these areas can be used to estimate the
abundance passing the tagging sites (but not the abundance at the recovery site). If sufficient
sampling can be obtained and some assumptions met, some inference can be made about relative
abundance among recovery locations using the estimates of mark rates and the number of radio-
tagged fish present. However, it was not an objective of this study to produce a mark-recapture
estimate of the number of Chinook salmon migrating above Devils Canyon (or above the proposed
dam site).
In the FERC SPD (page B-13), NMFS and the USFWS requested that AEA add the additional goal
of estimating the numbers of fish above Devils Canyon (and the proposed dam site) to the study.
FERC did not recommend this additional goal be included in the study. Instead, FERC
recommended the study be modified to require AEA to include in the 2013 ISR an evaluation of the
feasibility of putting in a weir or sonar counting station at or near the dam site during the 2014 study
season to count anadromous fish.
In ISR Section 5.6.4, AEA used two different approaches to estimate of the number of Chinook
salmon that migrated above Devils Canyon in 2013. The first approach involved expanding the peak
aerial spawner count in tributaries above Devils Canyon (29 fish) by the estimated observer
efficiency (46.3 percent, as observed in the Indian River; 26/0.463 = 63 fish). This expanded count
should be considered a minimum number since only fish counted on the July 25-27 survey were
included. Chinook salmon were also observed in tributaries above Devils Canyon on four other
surveys, so it is possible that some of these fish were not present during the July 25-27 survey. Also,
this approach assumed that the observer efficiency in tributaries above Devils Canyon was similar to
that in the Indian River (which was ‘ground-truthed’ with weir counts in 2013).
The second approach involved expanding the number of radio-tagged Chinook salmon detected
above Devils Canyon (3 fish) by the marked fraction of Chinook salmon in the Middle River (6.3
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 7 October 2014
Comment
Page
Para
Comment
Number Comment Response
percent; 3/0.063 = 48 fish). It was highly unlikely that more than three fish migrated above Devils
Canyon. This approach assumed that the mark rate of fish above Devils Canyon was the same as the
mark rate of fish sampled in the Indian River. Sensitivity analyses were included in ISR Sections
5.6.4 and 6.6 to illustrate how extreme, but unlikely, parameter values affected the expanded counts
derived from both approaches.
In summary, too few tagged and untagged fish were observed above Devils Canyon to derive a
statistically valid estimate of the number of Chinook salmon that passed Impediment 3 (or the
proposed dam site). Regardless, the study was not designed to produce such estimates. As proposed
in the RSP, AEA used available data to make inferences about the abundance of Chinook salmon
above Devils Canyon. Although lacking statistical rigor, these estimates provided insight into the
order of magnitude of Chinook salmon abundance above Devils Canyon (e.g., 50-65 fish above
Devils Canyon in 2013 was likely, but 100 or more was unlikely). These estimates also illustrate
how difficult it would be to achieve sufficient samples sizes to derive a reasonably accurate and
precise mark-recapture estimate for Chinook salmon above Devils Canyon.
Summary of passage events for large Chinook salmon (MEF ≥ 50 cm) released in the Middle
River, 2012-2014. Small Chinook salmon, and large Chinook salmon released in the Lower
River, were not included in this table.
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 8 October 2014
Comment
Page
Para
Comment
Number Comment Response
As stated in Study 9.5 ISR Section 5.1.3 and Study 9.6 ISR Section 5.1.3 data presented on habitat
associations was preliminary and based only on counts and therefore have no standard error
associated with these data. Once QAQC has been completed on the fish data, the analysis of fish-
habitat associations will be completed with additional inputs including relative abundance, species
2012 2013 2014 Total
Tags Released at Curry 352 536 590 1,478
Number of Tags Detected Above:
Gateway 313 445 491 1,249
Impediment 1 23 17 11 51
Impediment 2 20 13 8 41
Impediment 3 10 3 2 15
Proposed Dam Site 6 2 1 9
Percent of Tags Released Detected Above:
Gateway 88.9 83.0 83.2 84.5
Impediment 1 6.5 3.2 1.9 3.5
Impediment 2 5.7 2.4 1.4 2.8
Impediment 3 2.8 0.6 0.3 1.0
Proposed Dam Site 1.7 0.4 0.2 0.6
Percent of Tags Past Gateway Detected Above:
Impediment 1 7.3 3.8 2.2 4.1
Impediment 2 6.4 2.9 1.6 3.3
Impediment 3 3.2 0.7 0.4 1.2
Proposed Dam Site 1.9 0.4 0.2 0.7
Number of Tags That Approached Impediment 1 (within 1 km)34 60 32 126
Percent of Tags Released That Approached Impediment 1 9.7 11.2 5.4 8.5
Percent of Tags Past Gateway That Approached Impediment 1 10.9 13.5 6.5 10.1
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 9 October 2014
Comment
Page
Para
Comment
Number Comment Response
richness, and life stages supported. As stated in the RSP Section 9.6.4.3.1, Study 9.5 ISR Section
5.1.3, and Study 9.6 ISR Section 5.1.3 fish-habitat associations will be evaluated at the meso-habitat
level. These data will not be used to validate the instream flow model but to further characterize at
macrohabitat that are subject to flow effects at the meso-habitat level.
Page 5
Para 3
16 Data collection methods need improvement.
For example, detection and recovery of PIT
(passive Integrated Transponder) tags need
to be improved to yield useful data to meet
study goals and objectives. Location of the
detection arrays did not cover the entire
channel and was biased toward fish
migrating down channel. Also, because too
few tags were recovered, efficiency
estimates could not be made.
This comment reflects a fundamental lack of understanding of the methodologies being relied upon
by the FERC-approved study plan. As stated in RSP Sections 9.5.4.4.1.2 and 9.6.4.4.1.2, remote
telemetry techniques were “intended to provide detailed information on relatively few individual
fish.” PIT tags were used to “document relatively localized movements of fish as well as growth
information from tagged individuals.” Due to the size of the study rivers, the necessity for installing
arrays across split channels, side-channels and/or as partial coverage arrays across a portion of the
main channel is described in the Fish Distribution and Abundance Implementation Plan Section
5.6.5. Furthermore, both FA-104 and FA-128, the PIT tag arrays spanned the entire channels.
Data from PIT tag arrays provided limited but valuable information on fish movements. As indicated
in Study 9.5 ISR Section 5.2.2.2 and Study 9.6 ISR Section 5.2.2.2, antenna arrays recorded 29,047
detections of 33 fish in the Upper River and 126,351 detections of 664 fish at Middle River arrays.
These resightings provided information on local and inter-stream movements of individual for six
species in the Upper River and 11 species in the Middle River as well as site-specific growth rates for
individuals of several species (Study 9.6 ISR Section 5.5.1).
Page 5
Para 4
17 Misidentification of juvenile fish by species
induces significant error, and application of
this erroneous data would result in
inaccurate conclusions. Our review of the
Initial Study Report finds that a very high
percentage of the juvenile salmonids were
misidentified. We also question the
accuracy of all juvenile fish sampling data
because of the following details:
AEA disagrees. This comment reflects a fundamental lack of understanding of the methodologies
being relied upon by the FERC-approved study plan. NMFS concern appears to be centered on the
potential mis-identification of coho versus Chinook salmon in certain habitats that were part of fish
distribution studies. Whether those identifications are correct or not has no bearing on the outcome
of the habitat-modeling studies that will consider all of the Pacific salmon species. AEA has focused
a substantial effort into the development of resource specific models that will link with habitat-flow
based models for evaluating the effects of flow regulation below the dam on various fish species and
processes both spatially and temporally. The biological inputs to the habitat models will be provided
primarily via the HSC analysis that includes a suite of flow sensitive parameters associated with
different species and life stages. The HSC data are being collected in accordance with the study plan
and will result in a series of species specific HSC curves that will be brought into the fish-habitat
modeling. At this time the plan is to run the habitat-flow models for all of the target salmonid species
and life stages including sockeye and chum salmon adults/spawning, which are the species most
often associated with the lateral habitats that are likely to be most influenced by Project operations, as
well as coho, Chinook, and pink salmon.
Page 5
Para 5
18 large numbers of unidentified salmonid
juveniles (some of which were PIT tagged);
AEA disagrees that numbers of unidentified juvenile salmonids are significant.
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 10 October 2014
Comment
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Para
Comment
Number Comment Response
In Study 9.6 ISR Table 5.1-2: 865 undifferentiated Pacific salmon Juveniles in MR, five percent of
all juvenile salmon, ~ half from Slough 6A. 436 fish identified after photo review and classified to
species. Resulting in a total of 429 undifferentiated Pacific salmon remaining in database, 2.5
percent of total.
In Study 9.46 ISR Table 5.1-3: 78 undifferentiated Pacific salmon juveniles in LR, two percent of
total.
AEA is in the process of reviewing photos from the Lower River, which should reduce the number of
unidentified juvenile salmonids.
In 2013, 11 undifferentiated pacific salmon were PIT-tagged (67 reported in ISR but photo review
resulted in identification of 56 of the 67); four of these 11 tagged unidentified pacific salmon met
length criteria to be two-year-olds. Ten of these 11 fish have photos that are under review. In total
1,872 Chinook salmon and 2,793 Coho salmon were PIT-tagged in 2013 and Winter 2014.
Page 5
Para 6
19 anomalous length distributions and habitat
associations (e.g., juvenile Chinook 150
mm fork-length;
Summary of large juvenile Chinook and coho salmon. Based on growth modeling, juvenile Chinook
and coho >100mm in May and June were presumed to be two-year-old fish and >120mm from July-
April were presumed to be two-years of age. These data are not consistent with data from the 1980s
and are undergoing additional analysis.
Location PRM Habitat Chinook
salmon
Coho
salmon
Pacific
salmon,
undifferenti
ated
Total
DMT-Talkeetna
Station 106.9 MS Susitna River 72 8 3 83
Indian River
DMT 142.1 Tributary 70 4 74
FA-141-Slough
17 142.3
Upland Slough
Beaver Complex 70 16 1 87
Montana Creek
DMT 80.8 Tributary 37 4 41
FA-104-Slough
3A 105.7
Upland Slough
Beaver Complex 15 25 1 41
FA-104-SS 105 Side Slough 14 2 16
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 11 October 2014
Comment
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Para
Comment
Number Comment Response
PRM-63.5-US 62.5
Upland Slough
Beaver Complex 9 11 20
FA-115-Slough
6A 116.2
Upland Slough
Beaver Complex 6 31 37
Genetics samples were collected from 37 of these large Chinook and four large coho salmon, 2013.
An additional 29 samples were collected from Chinook salmon >100 mm collected July 2013-April
2014. Analysis of these samples is currently underway. A total of approximately 600 Chinook
salmon tissue samples have been delivered to ADF&G for analysis and can be used to determine
overall Chinook salmon identification error rate if needed.
Approximately 24 voucher specimens have been collected for Chinook (10) and coho salmon (14).
These fish will be used for meristic counts to determine species ID. Our ADF&G permit limited us
to 10 per species but was recently modified to up to 20 Chinook and coho salmon.
31 photos of these large Chinook salmon are also available for review. Review is complete for R2
photos but need to review photos from HDR and Golder. Results of photo review will be used in
combination with genetics and meristic data to evaluate accuracy of field identification.
Page 5
Para 7
20 the large abundance of juvenile Chinook
in beaver ponds;
Habitats where Chinook salmon were collected in 2013 and winter 2014. Larger Chinook salmon are
defined in Comment Number 19. 681 juvenile Chinook salmon were collected from upland slough
beaver complexes compared to 3,414 coho salmon. Approximately 14 percent of Chinook salmon
were associated with upland slough beaver complexes. The highest habitat supporting collection was
tributaries, over 21 percent of total collections. Of larger Chinook salmon, roughly a third, 100 out of
313, were associated with upland slough beaver complexes.
Macro Habitat
Chinook salmon Coho salmon
Pacific salmon,
undifferentiated Total
All
Sizes
Larger
fish
All
Sizes
Larger
fish All Sizes
Larger
fish
Additional Open
Water
1 32 1 33
Backwater 31 1 107 3 141
Clear Water Plume 69 2 144 14 227
Main Channel 1,038 74 1,210 23 79 3 2,327
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 12 October 2014
Comment
Page
Para
Comment
Number Comment Response
Side Channel 176 12 291 1 42 509
Para Side Channel
Complex
11 1 3 14
Side Slough 177 3 554 147 878
Side Slough Beaver
Complex 76 1 221 11 25 322
Tributary 1,875 43 1,411 6 53 3,339
Tributary Mouth 615 70 2,123 7 28 2,766
Upland Slough 108 6 378 19 1 487
Upland Slough
Beaver Complex
681 100 3,414 65 131 1 4,226
Grand Total 4,858 313 9,885 133 526 4 15,269
Page 5
Para 8
21 the absence of pink: salmon in any
samples; and
This is incorrect. Pink salmon were caught during winter sampling and ELH. Winter data are
provided in Study 9.6 ISR Appendix C Tables C2.2-5 and c2.2-5 and Figure C A1-17. ELH data are
provided in Study 9.6 ISR Tables 5.3-1, 5.3-2, and 5.3-3.
Page 5
Para 9
22 the disappearance of sockeye salmon
from Indian River between the February
draft Initial Study Report and the June draft
Initial Study Report).
This is incorrect. AEA reviewed ISRs for Studies 9.5, 9.6, 9.7, and 8.5 and the numbers of reported
sockeye salmon did not differ between the Draft and Final ISR.
Page 5
Para 10
23 Considering the length distributions and
habitat associations reported, we have
reservations also about the identification of
these juvenile fish and conclude that many
juvenile salmonids identified as Chinook
salmon were coho salmon.
AEA disagrees. See Comment Response Number 20. Consistent with QAQC protocol’s AEA is
verifying fish identifications. In addition, 681 out of the 757 total Chinook salmon in habitats with
beaver influence came from three sloughs: Slough 6A, Slough 17, and Slough 3B (Whiskers). The
photo review, meristic, and genetic sampling are ongoing for these sites and will provide an estimate
of error associated with field identifications. Based on the recent photo review for Slough 6A we are
confident that Chinook and coho salmon do co-occur at this site; however, we also anticipate
additional corrections to field identifications due to the phenotypic variations evident in juvenile
salmon at this location. We have over 500 photos of Chinook and coho salmon that can be used for
photo-based QAQC in addition to more than 550 genetic samples of Chinook and coho salmon for
verification of field identification.
Page 5
Para 11 –
Page 6
24 There is an absence of quantitative analysis
of habitat sampling, fish distribution and
relative abundance, and early life history
AEA disagrees with these assertions. This comment reflects a fundamental lack of understanding of
the methodologies being relied upon by the FERC-approved study plan. As shown in the ISR
sufficient data has been collected to indicate that progress has been made towards meeting study
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 13 October 2014
Comment
Page
Para
Comment
Number Comment Response
Para 1 data collected to date. Deviations from the
Revised Study Plan (RSP) and FERC staff
recommendations make developing
estimates from these data difficult or even
impossible. These data are the basis of the
fish and habitat sampling design and must
be collected appropriately for the study to
yield useful information. Without better
integration of historical data into assessment
of current results (e.g., the data from studies
collected in 2012, which used different
methodology and locations), these data
should not be used to assess habitat
associations for salmon by species and life
stage. Much of the data on species
distribution, relative abundance, and habitat
associations appears anomalous in
comparison to available science on these
species and their life stages as known
through data previously collected and past
studies conducted in the Susitna River and
environs.
objectives in spite of variances. Furthermore, AEA has proposed modification where needed to
improve data collection efforts based on a quantitative analysis of the data in the ISR. In all cases the
study modifications implemented in 2014 have been shown to be successful at improving rigor of the
data set as presented in Fish Distribution and Abundance Technical Memorandum filed with FERC
on September 17, 2014.
Page 6
Para 2
25 One of the main objectives of radio-tagging
was locating spawning locations. The
proposed activity of circling over a tag that
remained in the same location for a period
of time was not done (mainly for salmon).
For non-salmon species, it was proposed to
tag some species after their spawning
season and monitor the tag in the following
year to locate spawning locations. It
remains to be seen if this actually worked.
If not, the objective of locating spawning
locations was not met.
This comment reflects a fundamental lack of understanding of the methodologies being relied upon
by the FERC-approved study plan. AEA met the study plan objective within Study 9.7. Aerial
telemetry survey methods are stated in RSP 9.7 Section 9.7.4.2.2:
“When tagged fish are within 2 km of their last seen location, the helicopter will circle at a lower
altitude to pinpoint the fish location to mainstem, side channel, or slough habitats. As well, when
aggregations of two or more tagged fish are found stationary (i.e., within 2 km on one or more
surveys) and/or when visual observations of spawning fish are made from the helicopter, ground and
boat-based surveys will pinpoint spawning locations to within 5-10 meters,” and Study 9.7 ISR
Section 4.2.2.
“When aggregations of two or more tagged fish were found stationary (i.e., within 2 km on one or
more surveys), spawning locations were more intensively tracked to achieve relatively high
resolution geographic positions.”
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 14 October 2014
Comment
Page
Para
Comment
Number Comment Response
Aerial survey protocol with respect to identifying the position of a radio-tag adapted to the local
physical environment, weather conditions, timing relative to the migration, helicopter pilots, and
abundance of radio-tags, but always maintained the stated goal of achieving each position to within
300 meters. Obtaining an accurate fix on a tag did not necessarily require circling or changing
altitude although those maneuvers were used; sometimes it involved hovering, changing orientation
of the antenna, or simply making an additional pass at a particular location. Therefore, the adaptive
protocol provided higher accuracy of positions than the original protocol.
The aerial protocol was adapted to conditions during the salmon season with respect to monitoring
non-salmon frequencies (RSP 9.6, Section 4.5.3.3). More specifically, “Resident tag frequencies
were programmed into a receiver and scanned automatically. No manual tracking, directed
searching, or identification of habitat type was conducted during the period when adult salmon were
being tracked.” (ISR 9.6, Section 4.5.3.3). This was done to accommodate the high number of
frequencies that needed to be scanned for salmon and resident fish (i.e., it was impossible for two
crew to actively monitor six to eight receivers), and “may make habitat use inferences less accurate if
habitat delineations were much smaller than the resolution of the tag positions.” The adapted
approach was not necessary during surveys above Devils Canyon nor during the period when only
resident tags were being tracked.
The 2013 data on spawning and holding locations for radio tagged salmon were reported in Study 9.7
ISR Section 5.5.3.
AEA notes that as part of the radio tagging surveys in the Middle River, there was cross-
communication between the radio tagging teams and HSC study teams. In instances where stationary
adult fish were observed, ground or boat based surveys were conducted and measurements of depth
and velocity made at a number of locations to define the areas as potential spawning locations.
Furthermore, telemetry tagging targets are stated in IP 9.5/9.6 Section 5.8.1 and Study 9.6 ISR
Section 4.5.2.1.
“Tags will be surgically implanted (see Appendix 5) in 60 fish of sufficient body size (i.e., ≥200
grams) of each target species. For each species, 30 tags will be allocated to the Upper River, and 30
tags will be allocated to the combined Middle/Lower River. To the extent possible given the
constraints of field sampling conditions, …”
FERC recommended (SPD at B-135) tagging 10 of a 30 tag species allocation prior to and during
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 15 October 2014
Comment
Page
Para
Comment
Number Comment Response
spawning periods for Arctic grayling, burbot, Dolly Varden, humpback whitefish, rainbow trout, and
round whitefish. As Study 9.6 ISR Section 4.5.3.2, AEA’s implementation varied from this
recommendation. However, tagging the identified species during the specified periods was
conducted based on the surgeon’s discretion. For 2013 and 2014, tagging resulted in the FERC
recommendation being achieved for Arctic grayling and rainbow trout in the Middle-Lower River,
and Arctic grayling and burbot in the Upper River (Table 1). Further, the available tags-at-large in
spawning periods subsequent to tagging also achieved the FERC recommendation for burbot and
round whitefish in the Middle-Lower River (Table 2). The species yet to achieve the
recommendation are Dolly Varden and humpback whitefish in the Middle-Lower River, and round
whitefish in the Upper River. Note that the FERC recommendation will not be met for Dolly Varden,
humpback whitefish, and rainbow trout in the Upper River because there have been none of sufficient
size caught (i.e., too low abundance). Activities in 2015 will target achievement of feasible targets
by applying tags in June. Therefore, the approach being used is achieving the tagging targets
designed to allow locating spawning locations.
Page 6
Para 4
26 We do not believe that data has been
collected among individual related studies
at an appropriate scale to allow fish/habitat
associations to be made and extrapolated.
A related concern is that fish and habitat
data have not been collected at a
biologically relevant scale.
This comment reflects a fundamental lack of understanding of the methodologies being relied upon
by the FERC-approved study plan. The scale at which fish data were to be collected was described in
the RSP Sections 8.5.4.5.1.1.3, 9.5.4.4.3, 9.5.4.4.2, 9.6.4.4.3, and 9.6.4.4.2 and in the results of data
collected at these scales are presented in Studies 8.5 ISR Section 4.5.1.3, 9.5 ISR Sections 4.4.3 and
4.4.2, and 9.6 ISR Section 4.4.3 and 4.4.2. These studies followed the Study Plan for scale at which
data were to be collected and no variance was implemented with respect to scale for data on
fish/habitat associations. Furthermore, as fish distribution and abundance data collected at the
mesohabitat level were nested within macrohabitats (Study 9.6 ISR 4.4.3) and again within
Geomorphic Reaches which will facilitate use of the data by other studies.
As a point of clarification, AEA is not developing fish/habitat associations so they can be
extrapolated. Rather, AEA is developing HSC curve sets that will be used in the habitat-flow models
for defining how Project operations may influence fish habitats (target species and life stages) within
different habitat types. AEA has identified several approaches for extrapolating the results of this
type of analysis to other areas of the Middle River but has not selected a specific approach pending
further stakeholder review.
Page 6
Para 5
27 To assess project-caused impacts to
fisheries resources (for example), the
sampling effort must be at a scale relevant
to Susitna River fish species and life stages
and must adequately quantify baseline
conditions for accurate extrapolation. In
some instances, the spatial scale of data
See AEA’s response to Comment 26 regarding scale.
Fish sampling followed the sampling plan. In RSP Section 9.6.4.1 it stated that “winter sites will be
selected based on information gathered during 2012-2013 pilot studies . . . attempts will be made to
sample all Focus Areas.” The winter pilot study was conducted in Winter 2013 at two Focus Areas
as described in the Study 9.6 RSP Section 9.6.4.5. AEA made recommendations based upon the
winter pilot study for sampling sites, as stated in Study 9.6 ISR Appendix C Section 6.1.1, and the
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 16 October 2014
Comment
Page
Para
Comment
Number Comment Response
collection implemented varies
inappropriately within and among studies,
resulting in a mismatch between the data
collected and the purpose of its collection.
Additionally, the temporal scale of data
collection needs improvement. The Initial
Study Report indicates that winter fish
sampling did not occur in all focus areas as
proposed. Early spring sampling occurred
only in three focus areas due to record late
breakup. Initial sampling following
breakup and installation of migrant traps did
not occur until the middle of June (after
juvenile outmigration had begun), and
spring sampling for fish distribution and
abundance was not conducted.
Improvements need to be made to capture
the full seasonality of fish life history
strategies which vary considerably within a
single season. (Fish move around, and the
extent of that movement must be captured
through sampling. A single-day of
sampling is insufficient to understand the
habitat associations of many different and
mobile species and life-stages of fish.)
2014 Winter Study was expanded to three Focus Areas and opportunistic sampling at accessible sites
outside of the Focus Areas. Results of the first year of the winter study for fish are presented in the
Study 9.5 Winter Study Technical Memorandum filed with FERC on September 17, 2014.
In 2013 Early Life History sampling began two weeks after winter sampling was stopped and
continued bi-weekly through June with the exception that no sampling was conducted for two weeks
during the dynamic break up in mid-May 2013 (Study 9.6 ISR Section 4.6). As stated in Study 9.6
ISR Section 4.6.2 ELH sampling included six Focus Areas identified to have both spawning and
rearing habitat as well as additional sites in the Upper (Study 9.5 ISR 4.6.2), Middle, and Lower
River (Study 9.6 ISR 4.6.5). Sample sites for these various fish study components were visited
multiple times during the Winter Study (1-3 times), Early Life History Study (3 times), and Fish
Distribution and Abundance Study (3 times). Some sites were visited during all three seasonal study
components and ended up being sampled more than eight times in 2013.
Downstream migrant traps were installed and operated as indicated in the Study 9.5 ISR Section
9.5.4.4.10 and Study 9.6 ISRs Section 9.6.4.4.10: “flow conditions permitting, traps will be fished on
a cycle of 48 hours on, 72 hours off throughout the ice-free period.” As soon as break-up and flow
conditions allowed in mid-June 2013 traps were installed fished immediately upon installation in
June through mid-October 2013. In 2014 breakup occurred earlier and migrant traps installation
occurred in mid-May with traps operated immediately after installation (the Proposed 2015
Modifications to Fish Distribution and Abundance Study Plan Implementation Technical
Memorandum filed with FERC on September 17, 2014).
ELH sampling was conducted in 2013 during May and June in the Upper (Study 9.5 ISR Section
4.6.2, Middle and Lower (Study 9.6 ISR Section 4.62) River segments.
For clarification, the spring break-up of 2013 did not reach the magnitude or the late timing of the
breakup of record. AEA believes that the range of hydrologic events that occur over the multi-year
study period provide opportunities to better understand the response of aquatic resources to spring
break up and flow fluctuations associated with Project operations. While the harsh and dangerous
field conditions associated with the spring breakup of 2013 inhibited AEA’s ability to install migrant
traps, data collected in spring 2013 will be combined with other data collected to evaluate the
response of juvenile fish to Project operations over a range of environmental conditions.
Furthermore, data on fish movement were documented with downstream migrant traps and
biotelemetry as indicated in Study 9.5 ISR Sections 4.5.1 and 4.5.2, and Study 9.6 ISR Sections 4.5.1
and 4.5.2. Results for biotelemetry included a total of more than 150,000 repeat detections of tags for
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 17 October 2014
Comment
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Number Comment Response
more than 1,000 tagged fish (Study 9.5 ISR Sections 5.2.1 and 5.2.2, and Study 9.6 ISR Sections
5.2.1 and 5.2.2).
Page 6
Para 6
28 The error inherent in the inappropriate scale
of data collection would be compounded by
the proposal to extrapolate study results
throughout the river; this would perpetuate
and increase sampling errors across the
entire length and width of the river and its
habitats. Resource agencies are particularly
concerned about this proposal to “scale up,”
and requested rationale for its
implementation (Riverine Modeling
Integration Meeting, November 2013). The
ability to “scale up” is only valid when the
initial sampling has been conducted
accurately and at a scale relevant to
resource concerns, which is not the case
with studies conducted thus far.
See above Response to Comment 26 on extrapolation. Additionally, AEA provided several options
for scaling up/extrapolating results of the habitat-flow models being developed during the April 15-
17, 2014 Riverine Modelers Meeting (see http://www.susitna-watanahydro.org/wp-
content/uploads/2014/04/2014_04_17TT_Riverine_SpatialExtrapolation.pdf ). AEA intends to seek
the input of the Licensing Participants prior to selecting the specific option for scaling.
Page 6
Para 8 –
Page 7
Para 1
29 Review of the Initial Study Report reveals
that sampling sites for the various study
disciplines have not been consistently and
thoroughly co-located, as laid out in the
RSP as modified by FERC staff
recommendations, to provide an assessment
of baseline conditions of habitats relative to
fish use and preference. For example,
invertebrate sampling locations (River
Productivity 9.8) were not co-located with
fish sampling locations. Rather than
addressing this issue, or NMFS’s previous
concerns about the number of middle river
sampling locations, AEA is proposing a
study modification to sample in tributaries
above the dam inundation zone. At some
locations, sampling of variables such as
depth and velocity was appropriately co-
located, but other variables that should also
AEA disagrees with the assertion that it did not follow the FERC-approved study plan with respect to
co-location of sampling sites.
Regarding Sentence 1: As an initial matter, the RSPs never specified the co-location of sample sites
across study disciplines. It did specify the location of 10 specific Focus Areas that would be
evaluated relative to the different resource disciplines (RSP 8.5.4.2.1.2).
AEA disagrees with NMFS comments regarding the locations of the groundwater measurements. The
Focus Areas represent areas of intensive study across resource disciplines (see approved Study Plan,
Section 8.5.4.2.1.2). Detailed two-dimensional hydraulic models are being developed for each of the
Focus Areas and will support analysis by other resource disciplines being conducted within those
areas. The Focus Areas represent a variety of habitat types with varying complexity that factored
directly into determining the types and level of detail of resource specific studies. Thus, where
groundwater influence was important relative to habitat features that included riparian communities,
then detailed groundwater studies and riparian investigations occurred. For those where groundwater
exchange was not as important, e.g., those associated with tributaries (Focus Area 141 – Indian River,
Focus Area 151 – Portage Creek) than groundwater studies were scaled back or not included as part
of the overall study of that Focus Area.
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 18 October 2014
Comment
Page
Para
Comment
Number Comment Response
be co-located such as groundwater
exchange were not. NMFS recommends
that at Focus Areas data collection for the
full suite of interdependent variables should
be co-located.
Page 7
Para 2
30 The cumulative effects of deficiently
implemented sampling methods, failure to
co-locate sampling sites, lack of integrative
links, and discrepancies in data collection
scales are magnified because these data are
proposed for inputs to models. Model
calibration, validation and decision making
processes will then be used to assess
potential impacts to resources.
AEA disagrees. This comment reflects a fundamental lack of understanding of the methodologies
being relied upon by the FERC-approved study plan. As describe in the ISR, AEA anticipates that
the data generated will provide the necessary inputs for the models within the FERC-approved study
plan.
Page 7
Para 3
31 NMFS recommends that the data issues be
resolved as soon as possible. Accurate data
is required to calibrate and validate
proposed models; and quality data from
individual studies is necessary to integrate
models without amplifying errors
unknowingly. Given these concerns about
the data, it is not plausible to use the data
for the predictive modeling that is proposed
to describe baseline conditions or to predict
potential project impacts.
AEA disagrees with NMFS assertion that the models cannot be used to predict potential project
impacts. Those models were fundamentally designed to be able to evaluate Project effects related to
flow regulation and the data that have been and will continue to be collected to support their
development have been rigorously collected and checked in accordance with a stringent set of
QA/QC protocols.
Page 7
Para 4
32 These issues of data integrity and data
collection are based in part on studies being
conducted with significant differences from
the FERC-modified RSP. These issues
must be resolved prior to conducting
additional field studies. NMFS cannot
develop appropriate recommendations for
study modifications or make new study
requests for the second year of study given
the current issues with the studies and the
data.
AEA disagrees that there are significant differences in how the studies have been implemented versus
the FERC-approved study plans. AEA acknowledges that there have been some slight variances in
the plans but has specified those in the ISR and noted that none of the variances will substantively
affect the completion of the respective studies.
Page 7 33 During the Riverine Modeling Integration AEA disagrees. The time frames of 0, 25, and 50 years were selected because they represent time
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 19 October 2014
Comment
Page
Para
Comment
Number Comment Response
Para 7 Meeting (November 2013), 25- and 50-year
scenarios for predicting project impacts to
the physical river channel and habitats were
proposed. While those timelines are
consistent with the study plan and may
present a manageable timeframe for the
modeling work (B. Fullerton, POC meeting,
November 2013), they may not answer
questions related to assessing impacts on
important biological resources in a
biologically meaningful timeframe. Models
need to be sensitive enough to detect
changes that are biologically meaningful to
the species and habitats likely to be affected
by project operations. As currently
planned, this is not the case.
intervals that span the potential length of the FERC license, and as well are reasonable increments
from which to gauge and compare changes in channel morphology (RSP 6.6, Section 6.6.4.2.2.1) that
may translate into changes in fish habitat. Having time intervals at shorter increments of
geomorphological modeling would be less likely to elicit substantive changes in channel
morphologies and would therefore be less likely to elicit changes in the results of the habitat-flow
modeling.
However, the greatest potential effects of Project operations on fish and fish habitats are on the actual
regulation of flows that would occur over much shorter time intervals (annual, seasonal, weekly,
daily, hourly) and for which the habitat-flow models are being developed to evaluate. As described
in RSP 8.5, Section 8.5.7.4.1.1, the “[t]emporal analysis will involve the integration of hydrology,
Project operations, the Mainstem Open-water Flow Routing Model, and the various habitat-flow
response models to project spatially explicit habitat changes over time. Several analytical tools will
be utilized for evaluating Project effects on a temporal basis. This will include development and
completion of habitat-time series that represent habitat amounts resulting from flow conditions
occurring over different time steps (e.g., daily, weekly, monthly), as well as separate analysis that
address effects of rapidly changing flows (e.g., hourly) on habitat availability and suitability. The
Mainstem Open-water Flow Routing Model and habitat models will be used to process output from
the Project operations model. This will be done for different operating scenarios, hydrologic time
periods (e.g., ice free periods: spring, summer, fall; ice-covered period: winter [will rely on Ice
Processes Model – Section 7.6]), Water Year types (wet, dry, normal), and biologically sensitive
periods (e.g., migration, spawning, incubation, rearing) and will allow for the quantification of
Project operation effects on the following:
• Habitat areas (for each habitat type – main channel, side channel, slough, etc.) by
species and life stage; this will also allow for an evaluation of the effects of breaching
flows on these respective habitat areas and biologically sensitive periods (e.g.,
breaching flows in side channels during egg incubation period resulting in temperature
change).
• Varial zone area (i.e., the area that may become periodically dewatered due to Project
operations, subjecting fish to potential stranding and trapping and resulting in reduced
potential invertebrate production).
• Effective spawning areas for fish species of interest (i.e., spawning sites that remain
wetted through egg incubation and hatching).
• Other riverine processes”
These shorter time intervals (hourly, daily, weekly, monthly) represent those that are the most
biologically meaningful in the sense that they would have the most direct and immediate effect on
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 20 October 2014
Comment
Page
Para
Comment
Number Comment Response
fish and fish habitats. If warranted, it will also be possible to evaluate effects over longer time steps
that encompass Project operations over several different water years.
Page 7
Para 8 –
Page 8
Para 1
34 NMFS has identified a need to develop and
incorporate biological input and output
parameters and evaluate these under an
appropriate range of operational scenarios
(e.g., base load, ecological flows, load-
following, run-of-river). The temporal
scales (i.e., 25-and 50-year scales) that are
needed must have biological relevance. For
example, 5-, 10-, and 15-year operational
scenarios should be considered to
demonstrate the model’s ability to detect
generational impacts to fish populations and
habitat persistence (e.g., Susitna River
Chinook salmon, 5-7 years; or 2-4 years for
eulachon). NMFS is concerned that the
present model cannot answer the biological
questions it proposes to answer.
See AEA’s response to Comment 33.
Page 8
Para 2
35 Some study plan data collection efforts do
not provide the information needed for the
integrated modeling efforts. For example,
during the November 2013 Riverine
Modelling Integration meeting, it was
revealed that the Water Quality Modeling
study would require data on the spatial
distribution of groundwater discharge to
surface water bodies. Analytical or
numerical groundwater flow simulation
would be one way to satisfy this input
requirement. However, the Groundwater
Study in the Initial Study Report does not
explicitly state that analytical or numerical
groundwater flow simulations would be
undertaken in support of the other physical
process models.
AEA disagrees. This comment reflects a fundamental lack of understanding of the methodologies
being relied upon by the FERC-approved study plan. The data collection effort will provide the
information needed for integrated modeling efforts.
AEA notes that there have been two, three day Riverine Modelers meetings designed to provide
Licensing Participants with updates on model development and integration and to solicit feedback
and suggestions on model refinements. The first of these was held from November 13-15, 2013, the
second April 15-17, 2014. During both meetings, each of the resource modelers explained first the
specific models they were working on and the model dependencies on other models or data sources,
as well as the model outputs to other models. Review of the November meeting notes
(http://www.susitna-watanahydro.org/wp-content/uploads/2014/02/2013.11.13Modelers_Notes.pdf)
indicates questions did occur related to the Water Quality model that pertained to the integration of
groundwater. These comments were addressed by noting that data from targeted grab samples as
well as data from groundwater wells would be used, as well as data from other locations. Additional
information was provided on the groundwater study during the April Proof of Concept meetings
(http://www.susitna-watanahydro.org/wp-
content/uploads/2014/04/2014_04_15TT_Riverine_Presentation-Groundwater.pdf), and more
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 21 October 2014
Comment
Page
Para
Comment
Number Comment Response
recently in two Technical Memoranda (GWS and R2 2014a, http://www.susitna-
watanahydro.org/wp-
content/uploads/2014/09/07.5_GW_GWS_T6_TM_Aquatic_Hydro_Final_Draft_20140925.pdf;
GWS and R2 2014b, http://www.susitna-watanahydro.org/wp-
content/uploads/2014/09/07.5_GW_GWS_T5_TM_Riparian_Final_Draft_20140926.pdf ) which
describe some of the analysis leading to development of preliminary groundwater/surface water
relationships in selected Focus Areas.
Page 8
Para 3
36 Model integration is at this point largely an
ad hoc exercise. A stand-alone model
integration study is required to allow
stakeholders to develop confidence in the
models, understand inputs and outputs, and
have the conceptual linkages demonstrated
via an interactive riverine working model.
Many questions remain about the predictive
capabilities of the models, particularly
under integration and model assumptions.
Sensitivity and uncertainty analyses need to
be conducted to contribute to understanding
of model limitations. The full extent of
mismatch of purported integration of
models is currently unknown, even to the
project proponent, much less to
stakeholders reviewing study results.
AEA disagrees. This comment reflects a fundamental lack of understanding of the methodologies
being relied upon by the FERC-approved study plan. The model integration is not an ad-hoc
exercise. The two Riverine Modelers Meetings held in November 2013 and April 2014 respectively
were specifically held in response to stakeholder concerns about model integration. Review of the
presentations from both of these meetings which are available on AEA’s website
(http://www.susitna-watanahydro.org/meetings/past-meetings/) clearly demonstrate the linkages
between the models and how individual model outputs will be used in evaluating Project effects for
each resource discipline, with an emphasis on effects on fish habitats. The meeting notes for the two
meetings provide a clear record of the major topics discussed and stakeholder questions pertaining to
model integration. Indeed, one of the comments provided at the end of the April meeting by a USGS
representative suggested that the modeling and model integration efforts were moving in the right
direction – “…. thought it was a great meeting and that the studies are making good progress. Feels
that there has been tremendous amount of focus on where the problem areas are and are a lot further
along than in November 2013.” Since then, the resource modelers have continued working in a
collaborative fashion on each of the respective models.
Page 8
Para 5
37 Decision Support Systems (DSS) are critical
for evaluating potential impacts of the
project. We believe that their development
should be expedited to the extent possible
without excluding input from stakeholders.
AEA agrees that DSS are important for evaluating Project effects and presented several options for
this during the November modelers meetings (http://www.susitna-watanahydro.org/wp-
content/uploads/2013/11/SuWa-DSS-presentation-20131115_DRAFT.pdf). As was noted in the
Study Plan (RSP Section 8.5.4.8.1), the development of the DSS including selection of indicator
variables will be done in a collaborative process with stakeholder input.
Page 8
Para 6 –
Page 9
Para 1
38 The RSP (Instream Flow Study 8.5 RSP)
includes the use of conceptual ecological
models as the DSS to assess the project’s
impacts on a free flowing river and its
resources. Also, the Fish Passage study
includes use of a DSS to assess the
feasibility and effectiveness of different fish
passage options. It is our understanding
AEA does not consider the DSS to be a conceptual ecological model but rather a platform to reduce
the complexity of information and focus attention on tradeoffs involved with decisions regarding
project operations. Likewise, AEA notes that the Fish Passage Study does not include a DSS type
evaluation, but rather utilization of an analytical tool to weigh various passage options. The
development of both of these will be done in a collaborative framework. As to the schedule of the
DSS, the major elements of this are scheduled for 2015, and will require stakeholder inputs at various
intervals.
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 22 October 2014
Comment
Page
Para
Comment
Number Comment Response
that AEA intends to develop the conceptual
ecological model DSS using manual
matrices by early 2015 (FERC 2013) and to
use a modified existing DSS for fish
passage (currently past due). Considering
the potential of these DSSs to support
critical assessments of impacts from the
project, development of the DSS should be
a collaborative process with mutual
development of, and agreement about
fundamental objectives, assumptions,
critical inputs, weighting methods, and
other parts of the models. Formulation of
the fundamental objectives for the DSS may
reveal important, time-sensitive data gaps
that require modifications to existing studies
or perhaps development of new studies. An
example for the fish passage DSS is
reservoir ice studies: we expect to be used
to design tributary collectors for
outmigrating juvenile fish but don’t know if
the model will provide that information. An
example for the conceptual ecological
model is the groundwater studies which we
expect will allow estimation of project
impacts to areas of upwelling, but project
effects to upwelling are not one of the goals
of that study. Therefore, we request that the
schedule for DSS development be
accelerated so potential data needs not
currently covered in the existing study plans
can be identified and added to the study
plan.
Page 10
Para 1
39 Enclosure 2: NMFS Comments on the
2014 Fish Genetics Implementation Plan
These comments were reviewed and incorporated in the Final 2014 Genetics Implementation Plan
filed with the Study 9.14 ISR on June 3, 2014. A comment-response table was filed with the Study
9.14 ISR Part B Section 8. These comments are not addressed here again.
Page 14 40 Enclosure 3: NMFS Initial Comments to AEA filed the 2015 Implementation Technical Memorandum on September 10, 2014. AEA expects
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 23 October 2014
Comment
Page
Para
Comment
Number Comment Response
Para 3 –
Page 17,
Para 1
AEA regarding the 2014 Pilot Study for
Cook Inlet Beluga Whales and Eulachon:
Beginning in early May 2014, NMFS staff
were contacted and asked to meet with AEA
and their contractors (hereinafter referred to
collectively as AEA) to discuss AEA’s
plans to modify the [RSP as modified by
FERC’s determination] for the Cook Inlet
Beluga Whale Study (Study 9.17). AEA
informed NMFS staff of their intent to
conduct a boat-based pilot study involving
both a Cook Inlet beluga whale research
effort and a eulachon research effort.
Despite the very short notice from the
intended start date of the research activities,
NMFS agreed to provide some initial
comments and preliminary
recommendations to AEA. These initial
comments were primarily provided to help
reduce the high harassment and harm
potential this pilot project could have on the
endangered Cook Inlet beluga whales, and
to help AEA avoid violating both the
Marine Mammal Protection Act and the
Endangered Species Act. These comments
were not an endorsement of the pilot study,
nor an acknowledgement that the pilot study
would constitute the second year of the
required FERC-approved study plans.
These comments were sent to AEA by
email on May 14, 2014, and are reproduced
in Enclosure 3. As a result of these NMFS
comments, AEA did make modifications to
the pilot study in an effort to reduce the
harassment potential to Cook Inlet beluga
whales. NMFS has had multiple meetings
that through implementation of this plan along with the continued implementation of the Eulachon
Study (Study 9.16), AEA will meet all Study Plan objectives.
From May through August, AEA held a series of four meetings (May 7, May 22, August 7, and
August 26, 2014) with NMFS personnel to discuss alternative methods for collecting data on Cook
Inlet beluga whales (CIBW) and their prey. The intent of these meetings was to openly discuss and
collaborate on the development of alternative study methods that could be used by AEA to better
understand potential impacts of the project on CIBWs while minimizing any potential impacts of
conducting the research itself. During the first meeting in May 2014, AEA described preliminary
plans to test the feasibility of using boat-based surveys to document relationships between beluga
whales and their prey in Cook Inlet at the mouth of the Susitna River. Upon review of a written
description of the proposed methods, NMFS provided, via email, the comments also contained in this
letter from NMFS to FERC. Although AEA felt there was very little risk of harassment and no
chance of harm to CIBW’s from the proposed boat-based survey methods, NMFS concerns were
incorporated into revised pilot-study methods (discussed with NMFS during the May 22, 2014
meeting) that focused solely on beluga whale prey and included provisions to specifically avoid
beluga whales. Nine surveys were conducted in June and July, 2014 as described in the 2014 Cook
Inlet Beluga Whale Prey Study Implementation Technical Memorandum filed with FERC on
September 26, 2014 (LGL 2014a). The surveys in 2014 were successful in detecting fish and marine
mammals; however, it was decided that the boat-based surveys should not be carried out in 2015
because of concerns regarding the potential disturbance of CIBW. Documenting habitats where
CIBW and their prey are closely associated may require approaching beluga whales at closer
distances than deemed appropriate as well as limitations to the survey method caused by weather (see
further details in the 2014 Cook Inlet Beluga Whale Prey Study Implementation Technical
Memorandum filed with FERC on September 26, 2014 (LGL 2014a), and the Cook Inlet Beluga
Whale Study 2015 Implementation Plan Technical Memorandum filed with FERC on September 30,
2014).
AEA has provided NMFS with several documents throughout the process of discussing CIBW study
methods. A description of AEA’s plans to conduct limited field work in 2014 and, based on the
results, submit a Cook Inlet Beluga Whale Study 2015 Implementation Plan in September 2014 was
included in Study 9.17 ISR Section 7.1 and Attachment 1 (LGL and R2 2014). The two meetings
with NMFS in August were primarily intended to discuss the methods that would be included in the
Cook Inlet Beluga Whale Study 2015 Implementation Plan. Prior to the August 7, 2014 meeting,
AEA shared with NMFS an outline and rationale for proposed methods to be included in the Cook
Inlet Beluga Whale Study 2015 Implementation Plan. Preliminary results from the 2014 field work
were discussed with NMFS at the beginning of that meeting and that occupied a majority of the time
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 24 October 2014
Comment
Page
Para
Comment
Number Comment Response
with AEA to discuss the progress and status
of the 2014 pilot study since early May.
During several meetings, AEA has provided
inconsistent information regarding their
plans for 2015 Cook Inlet beluga studies.
At this time, it is unclear which aspects of
the FERC-approved study plans for Cook
Inlet beluga whales AEA intends to
implement in 2015, if any. Additionally,
AEA has a pattern of providing information
to NMFS immediately prior to a meeting
(e.g., one hour in advance) or after the
meeting, but has an expectation that NMFS
will provide official comments during the
meeting. This process has substantially
limited the ability of NMFS to provide
meaningful comments to AEA. Finally,
while the focus of Study 9.17 is on Cook
Inlet beluga whales, NMFS reiterates that
the Marine Mammal Protection Act pertains
to all marine mammals, regardless of any
additional protections under the Endangered
Species Act. Thus, harassment of any
marine mammal resulting from AEA’s
activities is prohibited.
allotted for the meeting. AEA used the remaining meeting time to describe to NMFS the intent and
content of the 2015 study outline. Because there was insufficient time to fully discuss the outline and
content of the Cook Inlet Beluga Whale Study 2015 Implementation Plan, a follow-up meeting with
NMFS was scheduled for August 26, 2014. Prior to the August 26, 2014 meeting, AEA provided the
identical meeting materials and outline to NMFS as was provided ahead of the August 7, 2014
meeting. The rationale and content of the outline and methods to be included in the Cook Inlet
Beluga Whale Study 2015 Implementation Plan were more fully discussed during the meeting on
August 26, 2014 and the results of that discussion were incorporated into the Cook Inlet Beluga
Whale Study 2015 Implementation Plan Technical Memorandum filed with FERC on September 30,
2014 (LGL 2014b).
REFERENCES
AEA (Alaska Energy Authority). 2012. Revised Study Plan: Susitna-Watana Hydroelectric Project FERC Project No. 14241.
December 2012. Prepared for the Federal Energy Regulatory Commission by the Alaska Energy Authority, Anchorage,
Alaska. http://www.susitna-watanahydro.org/study-plan.
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 25 October 2014
Geo-Watersheds Scientific and R2 Resource Consultants, Inc. 2014a. Preliminary Groundwater and Surface-Water Relationships in
Lateral Aquatic Habitats within Focus Areas FA-128 (Slough 8A) and FA-138 (Gold Creek) in the Middle Susitna River,
Technical Memorandum, Study 7.5. Susitna-Watana Hydroelectric Project, FERC No. P-14241. Prepared for Alaska Energy
Authority, Anchorage, Alaska. September 2014. 136 pp. http://www.susitna-watanahydro.org/wp-
content/uploads/2014/09/07.5_GW_GWS_T6_TM_Aquatic_Hydro_Final_Draft_20140925.pdf.
Geo-Watersheds Scientific and R2 Resource Consultants, Inc. 2014b. Groundwater and Surface-Water Relationships in Support of
Riparian Vegetation Modeling, Technical Memorandum, Study 7.5. Susitna-Watana Hydroelectric Project, FERC No. P-
14241. Prepared for Alaska Energy Authority, Anchorage, Alaska. September 2014. 58 pp. http://www.susitna-
watanahydro.org/wp-content/uploads/2014/09/07.5_GW_GWS_T5_TM_Riparian_Final_Draft_20140926.pdf.
GSA BBEST (Guadalupe, San Antonio, Mission, and Aransas Rivers and Mission, Copano, Aransas, and San Antonio Bays Basin and
Bay Expert Science Team). 2011. Environmental flows recommendations report. Final submission to the Guadalupe, San
Antonio, Mission, and Aransas Rivers and Mission, Copano, Aransas, and San Antonio Bays Basin and Bay Area Stakeholder
Committee, Environmental Flows Advisory Group, and Texas Commission on Environmental Quality. March 1, 2011.
Unpublished report available online http://www.tceq.texas.gov/permitting/water_rights/eflows/guadalupe-sanantonio-bbsc.
Hightower, J.E., J.E. Harris, J.K. Raabe, P. Brownell, and C.A. Drew. 2012. A Bayesian Spawning Habitat Suitability Model for
American Shad in Southeastern United States Rivers. Journal of Fish and Wildlife Management, 2(3): 184-198.
http://scholarworks.umass.edu/fishpassage_journal_articles/2046.
Jowett, I.G., J. Richardson, B.J.F. Biggs, C.W. Hickey and J.M. Quinn. 1991. Microhabitat preferences of benthic invertebrates and
the development of generalised Deleatidium spp. habitat suitability curves, applied to four New Zealand rivers. New Zealand
Journal of Marine and Freshwater Research 25(2):187-199.
LGL (LGL Alaska Research Associates, Inc.). 2014a. 2014 Cook Inlet Beluga Whale Prey Study Implementation Technical
Memorandum, Study 9.17. Susitna-Watana Hydroelectric Project, FERC No. P14241. Prepared for Alaska Energy Authority,
Anchorage, Alaska. September 2014. 23 pp. http://www.susitna-watanahydro.org/wp-
content/uploads/2014/09/9.17_CIBW_DRAFT_TM_20140909.pdf
LGL (LGL Alaska Research Associates, Inc.). 2014b. Cook Inlet Beluga Whale Study 2015 Implementation Plan Technical
Memorandum, Study 9.17. Susitna-Watana Hydroelectric Project, FERC No. P14241. Prepared for Alaska Energy Authority,
Anchorage, Alaska. September 2014. 17 pp. http://www.susitna-watanahydro.org/wp-
content/uploads/2014/09/9.17_CIBW_DRAFT_2015_IP_20140911-1.pdf
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 26 October 2014
LGL and R2 (LGL Alaska Research Associates, Inc. and R2 Resource Consultants, Inc.). 2014. Initial Study Report, Part C:
Executive Summary and Section 7, Study 9.17. Susitna-Watana Hydroelectric Project, FERC No. P-14241. Prepared for
Alaska Energy Authority, Anchorage, Alaska. June 2014. 39 pp. http://www.susitna-watanahydro.org/wp-
content/uploads/2014/06/09.17_CIBW_ISR_PartC.pdf
Vadas, Jr., R.L., and D.J. Orth. 2001. Formulation of habitat suitability models for stream fish guilds: Do the standard methods
work? Transactions of the American Fisheries Society 130:217-235.
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 27 October 2014
Table 1. Radio-tags released in resident fish, 2013-2014.
River Section
2013 2014
Total
'13+'14
Total
FERC
period
Balance
of 30
target
Middle-Lower Ma/Ju July August Sept Total Ma/Ju July August Sept Total
Arctic grayling 11 17 1 5 34 8 0 0 0 8 42 19 -12
Burbot 2 0 5 2 9 0 0 0 5 5 14 7 16
Dolly Varden 1 6 2 0 9 0 0 0 0 0 9 2 21
Humpback whitefish 3 4 0 0 7 0 0 0 0 0 7 0 23
Lake trout 0 0 0 0 0 0 0 0 0 0 0 -30
Longnose sucker 13 8 6 1 28 0 0 0 0 0 28 -2
Northern pike 0 0 5 0 5 0 0 0 0 0 5 -25
Rainbow trout 11 17 3 13 44 0 0 0 0 0 44 11 -14
Round whitefish 11 3 0 7 21 0 0 0 0 0 21 0 9
2013 2014
Total
'13+'14
Total
FERC
period
Balance
of 30
target
Upper Ma/Ju July August Sept Total Ma/Ju July August Sept Total
Arctic grayling 0 31 1 26 58 53 0 0 0 53 111 53 -81
Burbot 0 0 0 7 7 14 0 0 19 33 40 26 -10
Dolly Varden 0 0 0 0 0 0 0 0 0 0 0 0 30
Humpback whitefish 0 0 0 0 0 0 0 0 0 0 0 0 30
Lake trout 0 0 0 0 0 0 0 0 12 12 12 -18
Longnose sucker 0 5 0 5 10 17 0 0 17 34 44 --14
Northern pike 0 0 0 0 0 0 0 0 0 0 0 -30
Rainbow trout 0 0 0 0 0 0 0 0 0 0 0 0 30
Round whitefish 0 0 0 18 18 7 0 0 16 23 41 0 -11
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
AEA’S RESPONSE TO NMFS SEPTEMBER 22, 2014 ISR COMMENT LETTER
Susitna-Watana Hydroelectric Project Alaska Energy Authority
FERC Project No. 14241 Page 28 October 2014
Table 2. Radio-tags at large by month.
Mid-or-Lower-Susitna-released resident fish at large, by study month. Tags released in a given month become "at-large" in the following month.
Species Jun '13 Jul '13 Aug '13 Sep '13 Oct '13 Nov '13 Dec '13 Jan '14 Feb '14 Mar '14 Apr '14 May '14 Jun '14 July '14 Aug'14 Sep'14
Total
FERC
period
Arctic Grayling 0 11 24 17 18 13 12 8 8 8 8 8 6 13 10 10 14
Burbot 0 2 2 4 4 3 3 2 2 2 1 1 1 1 1 6 10
Dolly Varden 0 1 5 6 4 4 3 3 3 3 3 3 3 2 1 1 6
Humpback Whitefish 0 1 4 0 0 0 0 0 0 0 0 0 0 0 0 0 4
Lake Trout 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 -
Longnose Sucker 0 8 9 7 5 4 4 1 0 0 0 0 0 0 0 0 -
Northern Pike 0 0 0 3 3 3 3 3 3 3 3 3 2 2 2 2 -
Rainbow Trout 0 11 25 14 21 21 20 20 20 20 20 17 16 16 15 15 33
Round Whitefish 0 10 13 11 13 11 11 9 9 7 7 5 3 3 2 2 15
Shaded cells are FERC periods to tag a total of 10 of 30 tags.
Upper-Susitna-released resident fish at large, by study month
Species Jun '13 Jul '13 Aug '13 Sep '13 Oct '13 Nov '13 Dec '13 Jan '14 Feb '14 Mar '14 Apr '14 May '14 Jun '14 July '14 Aug'14 Sep'14
Total
FERC
period
Arctic Grayling 0 0 24 19 40 36 27 25 23 22 21 18 15 57 47 47 33
Burbot 0 0 0 0 6 5 5 4 4 4 4 3 2 15 12 31 31
Dolly Varden 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Humpback Whitefish 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Lake Trout 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 12 -
Longnose Sucker 0 0 3 1 5 5 2 2 1 1 1 1 1 17 15 32 -
Northern Pike 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 -
Rainbow Trout 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Round Whitefish 0 0 0 0 18 15 12 9 6 5 5 4 3 10 9 25 9
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
Wayne Dyok
Susitna Project Manager
Alaska .Energy Authority
813 W. Northern Light Boulevard
Anchorage, AK 99503
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
National Marine Fisheries Service
P.O. Box 21668
Juneau, Alaska 99802-1668
September 22,2014
RE: FERC Project P-14241, Proposed Susitna-Watana Hydropower Project
Dear Mr. Dyok:
The Alaska Energy Authority (AEA) has requested that the National Marine Fisheries Service
(NMFS) comment on portions of the Initial Study Report for the proposed Susitna-Watana
Hydropower project (June 3, 2014). We also include here comments previously submitted on the
2014 Fish Genetics Implementation Plan and on the pilot 2014 Cook Inlet beluga whale and
eulachon studies (May 12 and May 14, 2014). We expect that the Alaska Energy Authority
(AEA) will address these issues at the upcoming meeting on the Initial Study Report in October
2014.
Briefly, our enclosed comments on the Initial Study Report's fish studies (9.5 Upper River Fish
Distribution and Abundance, 9.6 Lower and Middle River Fish Distribution and Abundance, and
9.7 Salmon Escapement) identify issues with the integrity of data, the ability to effectively
integrate modeled studies, and the progress and detail of the decision support systems. Model
integration is a key concern, especially for assessing baselines and project impacts on the Susitna
River.
NMFS recommends that the data issues be resolved as soon as possible. For NMFS to effectively
review this project, the studies must accurately identify fish species, develop accurate habitat
models, and use the best available science to understand anadromous fish distribution and habitat
associations. Moreover, the studies require accurate data to calibrate and validate proposed
models and to integrate these models without inadvertently amplifying errors. Given the current
issues with the data, it is not plausible that the data for predictive modeling be used to describe
baseline conditions or to predict potential impacts. Modifications, additions, and new study
requests for the second year of studies cannot be developed given the current issues with the
data; these issues must be resolved prior to conducting additional field studies.
In regards to the 2014 Studies and the Final Study Plan, NMFS requests that the AEA adhere to
the schedule the Federal Energy Regulatory Commission (FER C) established for the mt~egr.at~~-~'
ALASKA REGION -www.fakr.noaa2ov
20141008-5071 FERC PDF (Unofficial) 10/8/2014 10:58:27 AM
Licensing Process (ILP) for this project in their January 28, 2014 determination. In that
determination, FERC ordered the ABA to submit the final Initial Study Report on June 3, 2014
and to hold a meeting in October to present the results of the Initial Study Report and discuss any
proposed changes. Although the AEA has just released reports of the studies it conducted in
2014 and intends to discuss those studies at the October meeting, NMFS is not prepared to step
outside the PERC-ordered process and consider those studies at this time. The limited time
allocated would be more effectively spent addressing problems with the 2013 study
implementation and discussing study modifications or new studies.
Any studies that the AEA conducted in 2014 cannot be construed as "Year 2 ILP Studies,"
because the Initial Study Report was not yet complete at the time the studies were conducted.
Conducting the studies before completing the Initial Study Report precluded participants from
recommending any changes to the study or making new study requests based a review of a
completed Initial Study Report. As noted by FERC in an May 6, 2014 e-mail on the
Implementation Plan for the Genetic Baseline Study for Selected Fish Species in the Susitna
River, Alaska:
... to clarify, we just reviewed our Study Determination letter and confirmed that
the genetics operational plans are due by April30 of 'each year of study
implementation.' Because our January 2014 letter granted AEA' s request, in part, for
second season studies to be conducted in 2015 rather than 2014 ... it follows that
the genetics operational plan for the second study season is due by April 30, 2015, and
not by April 30, 2014.
(Nicholas Jayjack, March 6, 2014 email to Susan Walker)
Although NMFS provided courtesy reviews and comments to the ABA on 2014 studies for fish
genetics (Enclosure 2) and the Cook Inlet beluga whales/eulachon pilot study (Enclosure 3) by
mid-May of 2014, NMFS does not consider any 2014 study to be the second year of study under
the ILP process.
We consider these concerns significant and in need of resolution for NMFS to fulfill its statutory
responsibilities. In the context of this project, we construe those responsibilities as follows:
1) to identify study data gaps;
2) to make recommendations for the second year of studies (and beyond);
3) to understand the project's ability to quantify baseline and proposed project
operational impacts to fish and wildlife resources;
4) to support recommendations for the protection, mitigation, and enhancement measures
associated with the project; and
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5) to make informed decisions pursuant to our Section 18 Fishway Prescription authority
under Federal Power Act.
The ILP schedule for this project has been altered and now affords the AEA an opportunity to
make necessary changes to studies for this project prior to entering the second year of study.
This will allow for development and implementation of a more accurate, effective, and cost-
effective plan of study for this important project.
In our November 30, 2014, FERC filing we will provide detailed recommendations to address
specific concerns related to the individual Initial Study Reports of June 3, 2014. If you have
questions regarding this letter, please contact Susan Walker at (907) 586-7646 or
Susan. Walker@noaa.gov ).
Sincerely,
Enclosures (3)
cc:
e-filed under FERC docket P-14241 as distribution to all Susitna licensing participants
Sarah Goad, AIDEA
Betsy McGregor, AEA
Nicholas Jayjack, FERC
Joe Klein, ADFG
Soch Lor, USFWS
Mike Bethe, ADFG
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Enclosure 1: Details regarding Data Integrity, Model Integration/Proof-of-Concept and
Decision Support Systems.
DATA ISSUES:
Data Collection: Quality Assurance and Quality Control, and Methodologies
NMFS is concerned with the current status and implementation of aquatic studies and believes
that, unless these issues are addressed, many study objectives will not be met. Our primary
concerns are as follows:
1) Habitat classification has not been completed;
2) Fish passage criteria have not been developed;
3) Fish sampling study plans were not followed; sampling units were inappropriately
subsampled;
4) Fish sampling locations did not incorporate PERC recommendations;
5) Because the fish sampling did not follow the sampling plan, this resulted in an inability to
estimate relative fish abundance;
6) Fish seem to have been identified incorrectly;
7) Data were collected and reported at inappropriate mesohabitat scales;
8) Sampling sites among studies were not co-located;
9) Tagging goals were not met;
10) Fish targets for HSC sampling were not met;
11) The mainstem upper river migrant fish trap was not installed;
12) A fish wheel was not installed, and fish were not tagged near the entrance to Devils Canyon;
13) Additional problems associated with late installation and operation of migrant traps were
likely influenced by environmental conditions associated with late breakup; and
14) Juvenile salmon distribution and abundance in 2013 were likely affected by the record fall
floods in 2012.
We are providing some additional clarification on some of these concerns.
The actual implementation of the abundance sampling program did not follow the
statistical models used to select sampling units. In particular, subareas (mesohabitats) within
selected areas were 'randomly' selected for subsampling, and sampling was not consistent
between sampling events (different gears, different effort, different order of gears, different total
area sampled, etc). Sampling error in the fish distribution and relative abundance studies needs
to be accounted for in order for these studies to accurately estimate fish distribution and
abundance. Estimates of numbers of Chinook salmon that migrate above Devils Canyon need to
include the assumptions, standard error, and resulting statistical confidence intervals associated
with that estimate. Better descriptions of (and statistical accounting for) both sampling and non-
sampling errors need to be provided. The data used to describe fish-habitat association
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preferences and the standard errors associated with those species and life-stage habitat
correlations need to be validated, as this analysis proposes to describe macrohabitat relationships
for fish. These relationships will be used to evaluate project effects, to validate instream flow
habitat model predictions, and to extrapolate results from focus areas to geomorphic reaches and
river segments. Ultimately these data will be used to develop protection and mitigation measures
and to serve as a basis for post-project monitoring.
Data collection and analysis
Data collection methods need improvement. For example, detection and recovery of PIT
(Passive Integrated Transponder) tags need to be improved to yield useful data to meet study
goals and objectives. Location of the detection arrays did not cover the entire channel and was
biased toward fish migrating down channel. Also, because too few tags were recovered,
efficiency estimates could not be made.
Misidentification of juvenile fish by species induces significant error, and application of this
erroneous data would result in inaccurate conclusions. Our review of the Initial Study Report
fmds that a very high percentage of the juvenile salmonids were misidentified. We also question
the accuracy of all juvenile fish sampling data because of the following details:
• large numbers of unidentified salmonid juveniles (some of which were PIT
tagged);
• anomalous length distributions and habitat associations (e.g., juvenile Chinook
150 mm fork-length;
• the large abundance of juvenile Chinook in beaver ponds;
• the absence of pink salmon in any samples; and
• the disappearance of sockeye salmon from Indian River between the February
draft Initial Study Report and the June draft Initial Study Report).
Considering the length distributions and habitat associations reported, we have reservations also
about the identification of these juvenile fish and conclude that many juvenile salmonids
identified as Chinook salmon were coho salmon.
There is an absence of quantitative analysis of habitat sampling, fish distribution and relative
abundance, and early life history data collected to date. Deviations from the Revised Study Plan
(RSP) and PERC staff recommendations make developing estimates from these data difficult or
even impossible. These data are the basis of the fish and habitat sampling design and must be
collected appropriately for the study to yield useful information. Without better integration of
historical data into assessment of current results (e.g., the data from studies collected in 2012,
which used different methodology and locations), these data should not be used to assess habitat
associations for salmon by species and life stage. Much of the data on species distribution,
relative abundance, and habitat associations appears anomalous in comparison to available
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science on these species and their life stages as known through data previously collected and past
studies conducted in the Susitna River and environs.
One of the main objectives of radio-tagging was locating spawning locations. The
proposed activity of circling over a tag that remained in the same location for a period of time
was not done (mainly for salmon). For non-salmon species, it was proposed to tag some species
after their spawning season and monitor the tag in the following year to locate spawning
locations. It remains to be seen if this actually worked. If not, the objective of locating
spawning locations was not met
Scale
We do not believe that data has been collected among individual related studies at an appropriate
scale to allow fish/habitat associations to be made and extrapolated. A related concern is that
fish and habitat data have not been collected at a biologically relevant scale.
To assess project-caused impacts to fisheries resources (for example), the sampling effort must
be at a scale relevant to Susitna River fish species and life stages and must adequately quantify
baseline conditions for accurate extrapolation. In some instances, the spatial scale of data
collection implemented varies inappropriately within and among studies, resulting in a mismatch
between the data collected and the purpose of its collection. Additionally, the temporal scale of
data collection needs improvement. The Initial Study Report indicates that winter fish sampling
did not occur in all focus areas as proposed. Early spring sampling occurred only in three focus
areas due to record late breakup. Initial sampling following breakup and installation of migrant
traps did not occur until the middle of June (after juvenile outmigration had begun), and spring
sampling for fish distribution and abundance was not conducted. Improvements need to be made
to capture the full seasonality of fish life history strategies which vary considerably within a
single season. (Fish move around, and the extent of that movement must be captured through
sampling. A single-day of sampling is insufficient to understand the habitat associations of
many different and mobile species and life-stages of fish.)
The error inherent in the inappropriate scale of data collection would be compounded by the
proposal to extrapolate study results throughout the river; this would perpetuate and increase
sampling errors across the entire length and width of the river and its habitats. Resource
agencies are particularly concerned about this proposal to "scale up," and requested rationale for
its implementation (Riverine Modeling Integration Meeting, November 2013). The ability to
"scale up" is only valid when the initial sampling has been conducted accurately and at a scale
relevant to resource concerns, which is not the case with studies conducted thus far.
Co-location of sampling sites
Review of the Initial Study Report reveals that sampling sites for the various study disciplines
have not been consistently and thoroughly co-located, as laid out in the RSP as modified by
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FERC staff recommendations, to provide an assessment of baseline conditions of habitats
relative to fish use and preference. For example, invertebrate sampling locations (River
Productivity 9 .8) were not co-located with fish sampling locations. Rather than addressing this
issue, or NMFS' s previous concerns about the number of middle river sampling locations, ABA
is proposing a study modification to sample in tributaries above the dam inundation zone. At
some locations, sampling of variables such as depth and velocity was appropriately co-located,
but other variables that should also be co-located such as groundwater exchange were not.
NMFS recommends that at Focus Areas data collection for the full suite of interdependent
variables should be co-located.
The cumulative effects of deficiently implemented sampling methods, failure to co-locate
sampling sites, lack of integrative links, and discrepancies in data collection scales are magnified
because these data are proposed for inputs to models. Model calibration, validation and decision
making processes will then be used to assess potential impacts to resources.
NMFS recommends that the data issues be resolved as soon as possible. Accurate data is
required to calibrate and validate proposed models; and quality data from individual studies is
necessary to integrate models without amplifying errors unknowingly. Given these concerns
about the data, it is not plausible to use the data for the predictive modeling that is proposed to
describe baseline conditions or to predict potential project impacts.
These issues of data integrity and data collection are based in part on studies being conducted
with significant differences from the PERC-modified RSP. These issues must be resolved prior
to conducting additional field studies. NMFS cannot develop appropriate recommendations for
study modifications or make new study requests for the second year of study given the current
issues with the studies and the data.
MODEL INTEGRATION/PROOF-OF-CONCEPT:
Biological relevance
During the Riverine Modeling Integration Meeting (November 2013), 25-and 50-year scenarios
for predicting project impacts to the physical river channel and habitats were proposed. While
those timelines are consistent with the study plan and may present a manageable timeframe for
the modeling work (B. Fullerton, POC meeting, November 2013), they may not answer
questions related to assessing impacts on important biological resources in a biologically
meaningful timeframe. Models need to be sensitive enough to detect changes that are
biologically meaningful to the species and habitats likely to be affected by project operations.
As currently planned, this is not the case.
NMFS has identified a need to develop and incorporate biological input and output parameters
and evaluate these under an appropriate range of operational scenarios (e.g., base load,
ecological flows, load-following, run-of-river). The temporal scales (i.e., 25-and 50-year scales)
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that are needed must have biological relevance. For example, 5-, 10-and 15-year operational
scenarios should be considered to demonstrate the model's ability to detect generational impacts
to fish populations and habitat persistence (e.g., Susitna River Chinook salmon, 5-7 years; or 2-4
years for eulachon). NMFS is concerned that the present model cannot answer the biological
questions it proposes to answer.
Some study plan data collection efforts do not provide the information needed for the integrated
modeling efforts. For example, during the November 2013 Riverine Modelling Integration
meeting, it was revealed that the Water Quality Modeling study would require data on the spatial
distribution of groundwater discharge to surface water bodies. Analytical or numerical
groundwater flow simulation would be one way to satisfy this input requirement. However, the
Groundwater Study in the Initial Study Report does not explicitly state that analytical or
numerical groundwater flow simulations would be undertaken in support of the other physical
process models.
Model integration is at this point largely an ad hoc exercise. A stand-alone model integration
study is required to allow stakeholders to develop confidence in the models, understand inputs
and outputs, and have the conceptual linkages demonstrated via an interactive riverine working
model. Many questions remain about the predictive capabilities of the models, particularly under
integration and model assumptions. Sensitivity and uncertainty analyses need to be conducted to
contribute to understanding of model limitations. The full extent of mismatch of purported
integration of models is currently unknown, even to the project proponent, much less to
stakeholders reviewing study results.
DECISION SUPPORT SYSTEMS:
Decision Support Systems (DSS) are critical for evaluating potential impacts of the project. We
believe that their development should be expedited to the extent possible without excluding input
from stakeholders.
The RSP (Instream Flow Study 8.5 RSP) includes the use of conceptual ecological models as the
DSS to assess the project's impacts on a free flowing river and its resources. Also, the Fish
Passage study includes use of a DSS to assess the feasibility and effectiveness of different fish
passage options. It is our understanding that AEA intends to develop the conceptual ecological
model DSS using manual matrices by early 2015 (FERC 2013) and to use a modified existing
DSS for fish passage (currently past due). Considering the potential of these DSSs to support
critical assessments of impacts from the project, development of the DSS should be a
collaborative process with mutual development of, and agreement about fundamental objectives,
assumptions, critical inputs, weighting methods, and other parts of the models. Formulation of
the fundamental objectives for the DSS may reveal important, time-sensitive data gaps that
require modifications to existing studies or perhaps development of new studies. An example for
the fish passage DSS is reservoir ice studies: we expect to be used to design tributary collectors
for outmigratingjuvenile fish but don't know if the model will provide that information. An
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example for the conceptual ecological model is the groundwater studies which we expect will
allow estimation of project impacts to areas of upwelling, but project effects to upwelling are not
one of the goals of that study. Therefore, we request that the schedule for DSS development be
accelerated so potential data needs not currently covered in the existing study plans can be
identified and added to the study plan.
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Enclosure 2: NMFS Comments on the 2014 Fish Genetics Implementation Plan
SUMMARY:
NMFS Fisheries geneticists; Dr. Jeff Guyon, Supervisory Research Geneticist and the
Fisheries Genetics Program Manager at the Ted Stevens Marine Research Laboratory of
NOAA's Alaska Fisheries Science Center and Dr. Robin Waples, Senior Scientist at NOAA's
Northwest Fisheries Science Center, reviewed the "Implementation Plan for the Genetic Baseline
Study for Selected Fish Species in the Susitna River, Alaska." NMFS appreciates that AEA and
the Alaska Department of Fish & Game (ADF&G) incorporated most of the comments and
suggestions provided to AEA in our review, and included the topics discussed with ADF&G,
U.S. Fish and Wildife Service and NMFS at the technical meeting in March in the final2014
implementation plan.
COMMENTS PROVIDED TO AEA:
This report reflects a carefully thought-out approach to sampling from natural populations to
provide baseline data prior to a proposed hydroelectric project. As proposed, the project would
no doubt produce a great deal of very useful information. Comments below are intended to help
improve certain aspects of the experimental design and/or data analysis.
Hypotheses for Chinook salmon:
Page 3: NMFS agrees that departures from HWE [Hardy-Weinberg Equilibrium] could support
hypothesis lb (fish above Devils Canyon are derived from spawners above and below), but only
if the departures are in the direction of a deficit of heterozygotes, as expected under the Wahlund
effect (population mixture). However, Hypothesis 2 would not necessarily produce any such
departures if all the fish above the canyon were derived from a single lower population.
Page 3: "On the other hand, low genetic divergence between fish spawning above Devils Canyon
and fish spawning in aggregates below the canyon would indicate that a large proportion of the
fish ascending Devils Canyon are strays or colonizers, and have not established a self-sustaining
population (support for Hypothesis 2)." This conclusion cannot be supported simply from
failing to find a difference. It would be necessary to conduct a power analysis to determine how
large a difference (e.g., Fst value) could exist and not be detected as statistically
significant. Then, it would be necessary to translate the genetic data into estimates of gene flow
to evaluate what levels of connectivity are consistent with the observed data.
Sampling design:
NMFS concurs that that samples from multiple years are essential to be able to make sense of the
relative magnitude of spatial and temporal differences. Three years of samples may be
inadequate for this purpose, especially considering that Chinook and perhaps some of the other
species have generation lengths much longer than three years.
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The required sample sizes depend on the particular objective, as well as the (unknown)
differences among populations. In general the numbers proposed seem reasonable. However,
the logic for requiring larger samples for msat [microsatellite] analyses is inadequately
explained. This may be based on the idea that larger samples are required to provide precise
estimates of all the low frequency alleles involved with msats. However, that is not the
objective; the objective is to use all the data to draw biological conclusions about the species of
interest. From this perspective, each msat locus is worth several SNP [single nucleotide
polymorphism] loci in terms of information content, as a large number of empirical studies have
demonstrated.
Analyses:
Page 12-13: NMFS strongly recommends that the Pis [primary investigators] not remove
putative siblings as proposed. Siblings, in fact, contribute part of the signal in genetic analyses
that provides insights into biological processes. Purging them from the sample universe scrubs
the data of this biological signal, particularly for small populations where siblings are
common. The effects that this has on subsequent analyses cannot be easily determined, but
could be substantial. This purging makes the remaining individuals more similar to what would
be expected from populations that are infinite in size and hence have no relatives. Purging of a
particular sample might be justified, if the sample has been collected non-randomly (that is, if it
is thought to represent progeny from only a few families). However, in that case the proper
amount of purging could only be determined if one knows exactly how non-random the
collection is. But this will seldom if ever be known in practice. Furthermore, even if this was
known and relatives were removed, the result still would not be a representative collection from
the population as a whole. Therefore, the solution to non-random sampling is not purging
relatives but to going back into the field and collecting a representative sample.
Page 13: "We will exclude juvenile collections from the baseline if they show significant allele
frequency differences from adult collections or show deviations from HWE when pooled with
adult collections." We note that age structure creates mini-Wahlund effects that could cause HW
departures even in mixed-age adult samples. Likewise the same thing could happen if you
combine juveniles and adults produced by different cohorts. That does not mean that combining
them won't produce a more robust overall estimate of population allele frequencies.
NMFS does not agree with using the Bonferroni correction for HWE tests; there are too many
overall tests and thus the criterion become too conservative. Bonferroni correction controls the
probability of false positives only and the correction ordinarily comes at the cost of increasing
the probability of producing false negatives, consequently reducing the statistical power of the
HWE tests. Instead, we suggest starting with unadjusted tests and evaluating what fraction are
significant for each locus (across all pops) and for each pop (across all loci). If the resulting
proportions do not deviate much from the expected proportion (dictated by the significance level
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of the test), there is no reason to reject HWE. Loci or pops that are outliers can be singled out
for more detailed analysis, perhaps using Bonferroni or FDR [false discovery rate].
Minor comments:
Page 1: The project "will modify the flow, thermal, and sediment regimes of the Susitna River ...
. " The project will also affect migration and fish passage, among a host of other important
effects. The description of project effects should be written to comprehensively describe all
major project effects.
Page 1: "If breeding isolation (lack of migration) among populations occurs over sufficient time
and population sizes are small enough, genetic drift will result in variation in allele frequencies at
neutral loci (loci not under natural selection) among populations." Genetic drift
will always result in some differences unless there is complete panmixia.
Analyses of genetic distance: it is fine to use Fst as an index of genetic distance, but it must
include a correction for sample size (like W&C theta). Otherwise, small samples will tend to
look like outliers.
Page 6: "For mixed stock collections, sample sizes of200 fish or 100 fish per collection are
adequate to provide stock composition estimates that are within 7% or 10% of the true estimate
95% of the time, respectively (Thompson 1987)." That might have been true for the particular
study cited, but how large a sample is required will depend on the number of markers and the
magnitude of divergence among populations, so this general statement is not valid.
Page 8, the numbering is off under "Sample Collection Targets."
Page 9, under "Sample Collection Targets" item #9, we understand the issues regarding sample
numbers, but an adequate adult Chinook salmon sample set from above the proposed dam is
needed at the end of the study to make the necessary conclusions. What happens if the goal of
100 adult Chinook salmon is not realized? This should be addressed in advance.
Page 10, Section 4.2.4.1, identifies a sample target of 200 juvenile Chinook salmon from 4
systems in or above Devils Canyon, but later in the report under section 4.5 "Data Retrieval and
Quality Control" it mentions that software will be used to identify siblings and exclude all but
one individual in the baseline for every set of siblings identified. As such, given the likely small
population sizes above the proposed dam site, 200 juveniles from each system is unlikely to be
sufficient.
Page 16, Section 4.6.5, where it says "Collections will be pooled when tests indicate no
difference between collections ( P>0.01)." While we agree that it is difficult to prove there is no
difference between collections, we recommend though using a p value greater than 0.05 as more
appropriate to reject the null hypothesis.
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Appendix A Section 2.2 Regarding the radio telemetry studies, the potential impacts of the tag
on the migration pattern of the salmon, especially for a stock that has to migrate the farthest and
through a 7-mile long Class 5+ canyon must be considered and discussed. Also please address
whether the tags let you know where the fish spawned (or if they spawned) or just indicate where
they were when relocated, including noting the spatial accuracy of the tag signal recoveries.
Appendix B-page 1, for the Black River: Were the Chinook that were sampled two juveniles
which were collected in 2013? Please confirm and identify them as juveniles if that's true.
Table B5, Is there an overall HWE test for all markers for each population?
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Enclosure 3: NMFS Initial Comments to AEA regarding the 2014 Pilot Study for Cook
Inlet Beluga Whales and Eulachon
SUMMARY:
Beginning in early May 2014, NMFS staff were contacted and asked to meet with AEA and their
contractors (hereinafter referred to collectively as AEA) to discuss AEA's plans to modify the
[RSP as modified by PERC's determination) for the Cook Inlet Beluga Whale Study (Study
9.17). AEA informed NMFS staff of their intent to conduct a boat-based pilot study involving
both a Cook Inlet beluga whale research effort and a eulachon research effort. Despite the very
short notice from the intended start date of the research activities, NMFS agreed to provide some
initial comments and preliminary recommendations to AEA. These initial comments were
primarily provided to help reduce the high harassment and harm potential this pilot project could
have on the endangered Cook Inlet beluga whales, and to help AEA avoid violating both the
Marine Mammal Protection Act and the Endangered Species Act. These comments were not an
endorsement of the pilot study, nor an acknowledgement that the pilot study would constitute the
second year of the required PERC-approved study plans. These comments were sent to AEA by
email on May 14, 2014, and are reproduced in Enclosure 3. As a result of these NMFS
comments, AEA did make modifications to the pilot study in an effort to reduce the harassment
potential to Cook Inlet beluga whales. NMFS has had multiple meetings with AEA to discuss
the progress and status of the 2014 pilot study since early May. During several meetings, AEA
has provided inconsistent information regarding their plans for 2015 Cook Inlet beluga
studies. At this time, it is unclear which aspects of the PERC-approved study plans for Cook
Inlet beluga whales AEA intends to implement in 2015, if any. Additionally, AEA has a pattern
of providing information to NMFS immediately prior to a meeting (e.g., one hour in advance) or
after the meeting, but has an expectation that NMFS will provide official comments during the
meeting. This process has substantially limited the ability of NMFS to provide meaningful
comments to AEA. Finally, while the focus of Study 9.17 is on Cook Inlet beluga whales,
NMFS reiterates that the Marine Mammal Protection Act pertains to all marine mammals,
regardless of any additional protections under the Endangered Species Act. Thus, harassment of
any marine mammal resulting from AEA's activities is prohibited.
COMMENTS PROVIDED TO AEA:
These initial comments are intended to provide early guidance and preliminary recommendations
regarding this pilot study. NMFS intends to submit formal comments on this study proposal to
PERC.
NMFS received a draft copy of the AEA' s "Pilot Study of Cook Inlet Beluga Whale and Prey
Species in the Susitna River Delta" on Monday May 12, 2014. AEA and their contractors intend
to implement the pilot study beginning the week after NMFS received the draft study plan for
review, and continue through all of June. The pilot study is submitted in lieu of the PERC-
approved beluga studies (aerial surveys, video cameras, still cameras, and water surface
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elevation model) for 2014. Although NMFS agreed to try and get these preliminary comments
back to AEA prior to implementation of the pilot study, NMFS advises that these are not official
comments, and as such do not indicate NMFS's support for or rejection of the pilot
study. Furthermore, NMFS does not consider any 2014 study to be the second year of study
under the ILP process. This is because the Initial Study Report is not complete, and licensing
participants have not been able to recommend any changes to the study or make new study
requests based on a review of the completed Initial Study Report. Our initial comments
regarding the draft pilot study after an abbreviated review period are as follows:
We understand neither AEA nor its contractors will be obtaining authorizations under the federal
Marine Mammal Protection Act (MMP A) for the unintentional take by harassment of marine
mammals. Thus no harassment or take of any marine mammal under NMFS' jurisdiction is
authorized under either the MMP A or the Endangered Species Act (ESA) and AEA and/or its
contractors would be responsible for any violation of these federal laws.
The draft pilot study references LGL Alaska Research, Inc.'s ongoing boat-based surveys for
Cook Inlet belugas as good documentation of Cook Inlet belugas as a result of closer proximity
and longer encounter durations with the whales than by aerial surveys. While we agree that a
boat survey has the potential to get closer to and spend more time with a group of marine
mammals than an airplane, we do note that the referenced LGL studies have a NMFS-issued
MMPA research permit and ESA authorization to allow harassment and close approaches. The
level of information collected by these two different boat-based studies will not be
comparable. Furthermore, we note that the LGL researchers associated with the NMFS
permitted photo-identification study are not indicated as participating in this pilot study.
The pilot study has the potential to disturb or harass marine mammals due to the presence of the
boat and operation of the split-beam sonar. The pilot study does suggest the implementation of
the "Marine Mammal Viewing Guidelines and Regulations" as found on our website
(http://alaskafisheries.noaa.gov/protectedresources/mmv/guide.htm) as an effort to reduce the
potential for harassment or take. We note that many of the steps of the viewing guidelines are
stated in the "2014 Pilot Study Methods" section of the draft pilot study, but add that whales
should not be encircled or trapped between boats or boats and shore, and that the study needs to
ensure that when approaching the whales the boat stays fully clear of whales' path of travel (i.e.,
the boat doesn't approach belugas "head-on"). These guidelines are intended to reduce the
likelihood that marine mammals would be affected by this study, but do not guarantee no
harassment or take will occur. This is a directed research project targeting Cook Inlet beluga
whales, and a research permit may be necessary if the project may result in take or harassment of
this endangered species or other marine mammals.
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The pilot study is designed for repeated approaches to Cook Inlet beluga whales, albeit
theoretically no less than lOOm away. This study design increases the potential for harassment,
including behavioral modifications or displacement that may not be evident from the boat,
despite one of the pilot study's goals being to not cause any disturbance to the whales
themselves. Given the repeated approaches, and potential for belugas or other marine mammals
to not be visible below the water, implementation of the Marine Mammal Viewing Guidelines
may be insufficient for preventing harassment or take. This potential for disturbance or
harassment is of concern to NMFS, not only in general, but specifically during the first two
weeks of June when we will be conducting our aerial surveys to assess official population
abundance and distribution. Any disturbance or behavioral modification of the beluga whales
associated with the pilot study may result in a reduction of our ability to accurately conduct our
aerial surveys. The Susitna delta area is an important foraging area to the Cook Inlet belugas in
late spring/early summer, after limited food during the winter. Any disturbance to the whales
may result in reduced foraging success, and thus have population-level adverse effects.
The draft pilot study plan indicates that "if whales move away from the area where they were
initially detected, an attempt will be made to obtain a depth reading and prey information at that
location", but there is no information regarding how much time must pass without a beluga
sighting before the survey crew moves to that location to attempt to obtain depth and prey
information. There are confirmed reports that some stressed, chased, or harassed Cook Inlet
beluga whales do not swim away, but rather submerge and remain on the bottom of the seafloor,
which can be very shallow in Cook Inlet. If the observers do not wait a sufficient length of time,
the potential exists for a beluga exhibiting this behavior to be struck by the vessel or propellers
as the boat approaches the area where belugas were observed.
Given the topography and mudflats surrounding the Susitna Delta, as well as the potential that
belugas will be traveling and not staying still, it is unclear how accurately or consistently the
fine-scale surveys could be implemented. Should the belugas be traveling, it is possible the boat
may inadvertently chase the whales group while trying to accomplish the fine scale sampling
scheme as depicted in Figure 3. This could result in increased stress or harassment to the belugas
or other marine mammals (i.e., seals) in the vicinity.
The draft pilot study does not provide much detail about the acoustic component of the split-
beam sonar, but we understand some split-beam sonars have the potential for operating at
multiple frequencies. Frequencies below 200 kHz are within the hearing range of Cook Inlet
belugas, and thus noises associated with the sonar with frequencies below 200 kHz have the
potential to harass belugas and other marine mammals. Noise has been identified as one of the
highest threats to Cook Inlet belugas. Based on the information in the draft pilot study plan, it
appears there may only be a single frequency during operation, at 206 kHz. It is unclear whether
the split-beam sonar will be operated when conducting the "fine-scale sampling" triggered by
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Cook Inlet beluga sightings or if it will only be operated when no belugas are sighted, or if it will
be in constant operation.
In general, the pilot study plan is unclear about the primary goal of the study; is this a beluga
study that has a fish component or a fish study that will record beluga sightings? The study plan
states that data on prey and belugas will be "collected simultaneously", however, fish data can
only be recorded after the whales leave the area, and the split-beam sonar is unlikely to be able to
collect adequate fish data from over 100 m away (the minimum distance the boat will stay from
the belugas and other marine mammals). Overall, while it appears this pilot study attempts to
combine information regarding the distribution of beluga whales and their prey, we do have
initial concerns about the harassment potential to the belugas. Although there is information on
the data collection protocol sheets and software, there is no information regarding protocols
should the vessel be closer to lOOm of the Cook Inlet beluga whales, or if the presence of the
boat or use of the split-beam sonar results in a change of behavior, disturbance, or displacement
of the whales. These are indications of harassment and take, and are currently not authorized by
NMFS. NMFS requests to be provided a survey schedule in advance of the first survey.
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Attachment I. Data Issues
Below we discuss our preliminary concerns relating to deviations from study plans, quality
assurance and control, and statistical practices and procedures for the 2013 study year.
Deviations From Study Plans – Deviations from established sampling designs occurred in some
studies for various reasons, and in some cases resulted in reduced sample size or compromised
reliability of data. Below we provide examples.
As currently planned, some two-year studies cannot be completed because access to all
Focus Areas (FAs) was not granted until after the first study year (e.g., ISRs 8.5, 9.6, 9.7,
9.9). For example, a fish wheel was not installed and fish were not tagged near the
entrance to Devil’s Canyon (e.g., ISR 9.7).
Anomalous weather conditions prevented or delayed fieldwork on aquatic studies (e.g.,
ISR 8.5), resulted in late installation of migrant traps, which were likely influenced by
environmental conditions associated with late breakup (e.g., ISR 9.6). Moreover,
juvenile salmon distribution and abundance measured in 2013 were likely affected by the
record fall floods in 2012 (e.g., ISR 9.6).
Sampling has not been temporally adequate across all seasons. ISR 9.6 reports winter
fish sampling did not occur across all FAs as proposed; early spring sampling occurred
only in three FAs; initial sampling following breakup and installation of migrant traps did
not occur until the middle of June, and therefore, spring sampling for fish distribution and
abundance was not conducted (e.g., ISRs 7.5, 8.5, 8.6). The extent to which fishes move
must be described through sampling; multiple sampling days across all seasons are
required to capture the full seasonality of a fish’s life-history strategy, which varies
considerably within a single season. A single-day of sampling is insufficient to
understand the habitat associations of different fish species with differing mobility and
life-stages.
Sample site selections for integrated studies were inconsistently co-located. For example,
invertebrate sampling locations (ISR 9.8) were not co-located with fish sampling
locations (ISR 9.6). Failure to co-locate sampling sites risks the magnification of data
discrepancies, and because the data will be used as inputs for predictive models, may
jeopardize the validity of the models.
Detection arrays did not cover the entire channel and tagging efforts did not allow for
detection of fish migrating upstream, therefore the data were biased and efficiency
estimates cannot be calculated. Detection rate and recovery of passive integrated
transponder (PIT) tags is insufficient to yield useful data to meet study goals and
objectives (ISR 9.6).
Fish targets for fish Habitat Suitability Curve (HSC) sampling were not met (e.g., ISR
8.5), therefore, power to assess fish habitat-preferences and relationships is reduced.
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Data collected on fish habitat for the Fish Passage Barrier Study (ISR 9.12) and the
HSI/HSC component of the fish and aquatic Instream Flow Study (ISR 8.5) were
gathered at incompatible spatial scales to meet the study objectives.
Quality Assurance and Control Concerns - Below we preliminarily provide some discrete
examples where the Service has data quality concerns. Poor data quality has a rippling effect
throughout this assessment process because extrapolating inaccurate results throughout the river
would amplify errors across the river and associated habitat.
Water quality samples were qualified as either estimated or rejected by the analytical
laboratory due to quality-related failures (ISR 5.5). Issues included failure to deliver
samples to the laboratories within the method-specified temperature range; failure to
meet procedure specified holding times; contaminated or missing field, trip, and method
blanks; and Chain of Custody and bottle labeling discrepancies. AEA proposed to apply
a correction factor to the 2013 data to render it useable, but provided no details on how
that would be done.
There is evidence that juvenile salmon may have been misidentified. A comparison of
juvenile fish collections from the Susitna River in the 1980s (Alaska Department of Fish
and Game 1983 as cited by R2 Consultants in the Fish Population Summary Document),
local Alaskan rivers (Alaska Department of Fish and Game, unpublished data; Davis et
al. 2013), recent studies on the Susitna River (Kirsch et al. 2014), and nearby tributaries
(Miller et al. 2011), signal substantial differences in total fork length distribution and
habitat associations among juvenile salmon from that which is expected. Large numbers
of unidentified salmonid juveniles (some of which were PIT tagged), anomalous length
distributions and questionable habitat associations decrease our confidence in the
accuracy of species identification. For example, juvenile Chinook salmon measuring 150
mm fork-length were reported, juvenile Chinook salmon were reportedly most abundant
in beaver ponds, there was absence of pink salmon in any samples, and a disappearance
of sockeye salmon from Indian River between the February draft ISR and the June draft
ISR. We have strong reservations about the identification of these juvenile fish, and
suspect many juvenile salmons identified as Chinook salmon may be coho salmon.
Information used to describe fish/habitat preferences were gathered using professional
best judgment, literature, and limited field data, but were not confirmed with an adequate
sample from the Susitna River system (ISR 8.5). Fish/habitat data gathered from the
Susitna River is necessary to identify preferential use of the habitats. It is vital that these
data are accurate as they will be used to: 1) develop Habitat Suitability Indices (HSI) and
Habitat Suitability Criteria (HSC); 2) describe fish-macrohabitat relationships, which
may be used to evaluate project effects; 3) validate the Instream Flow Study (8.5) habitat
model predictions; and 4) extrapolate results from FAs to geomorphic reaches and river
segments. Ultimately the data will be used to develop protection and mitigation measures
and to provide a basis for post-project monitoring.
The Service is concerned about AEA’s proposal to “scale up”, and requests rationale for
its implementation (Riverine Model Integration Meeting 2013). “Scaling up” is only
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appropriate when the sampling is conducted accurately, in a random fashion throughout
the population, and at a scale relevant to resource concerns. To assess impacts from the
Project on fish resources, sampling effort must be at a scale relevant to Susitna River fish
species at various life stages in order to adequately quantify baseline conditions with the
accuracy required for accurate extrapolation. For example, incorrect fish identification
and would lead to imprecise and inaccurate extrapolation of species-specific habitat
associations.
Statistical Practices and Procedures – Based on our preliminary reviews, we note (below) failures
to report standard statistical procedures and calculations required for complete analyses.
Standard error was not reported for stated relationships between species of juvenile
salmonids at various life stages and their habitat (e.g., ISRs 9.5, 9.6). A robust
assessment of statistical results must include calculations for standard error.
Assumptions for the estimating numbers of Chinook salmon migrating above Devils
Canyon were not clearly specified and the standard error of that estimate was not reported
(e.g., ISRs 9.6, 9.7).
Sampling and non-sampling errors were not clearly stated (e.g., ISR 9.7). Sampling error
is the error resulting from sampling only a part of the population and not the whole
population. Non-sampling errors are those errors resulting from selection bias,
systematic non-representativeness of samples, and transcription or recording errors.
Sampling error is usually quantified and reported with confidence intervals or standard
errors and related to precision of the estimates. Non-sampling errors are harder to
recognize, yet very important, and more closely related to the accuracy of the estimates.
Sampling errors must be clearly accounted for in statistical analyses to assess data
reliability and interpret results.
Consistent fish sampling methods were not applied (i.e., different gear types used,
different effort was applied within and across sampling units, concurrent use of non-
compatible gear types within a sampling unit). This resulted in inability to estimate
sampling error because (e.g., ISR 9.6) inconsistent sampling methods resulted in
individual datasets that are not comparable.
No power analysis was reported (ISR 9.14), and it is unclear how sample size for both
adult and juvenile Chinook salmon was determined. Based on the number of genetic
markers sampled and the magnitude of genetic divergence measured in the population
documented thus far, a power analysis would inform determination of the number of
samples needed to provide a robust estimate of genetic diversity. Furthermore, three
years of samples may not be adequate to characterize genetic diversity among a species
with a life cycle of five to seven years; this limitation must be addressed in the study
results.
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Samples from presumed siblings were proposed for removal from the genetic analyses
(ISR 9.14). Only if the samples have been collected in a non-random way may this
method be justified. Purging related animals as proposed will bias the results.
Furthermore, ISR 9.14 proposes to exclude samples from juvenile Chinook salmon if
they show significant differences in allele frequency from adult Chinook salmon. Using
all data will produce a more robust estimate of allelic frequencies across the entire
population.
Using a Bonferroni adjustment on the tests for Hardy-Weinberg Equilibrium (ISR 9.14)
will increase the risk of a Type-2 error and reduce the statistical power of the test to
detect a difference. Furthermore, estimates of genetic distance using Fst must include a
correction for sample size otherwise small samples tend to look like outliers (ISR 9.14).
Literature Cited
ADFG. Unpublished data for Willow Creek and Deshka River tagging study.
Alaska Department of Fish and Game. 1983. Resident and Juvenile Anadromous Fish Studies
on the Susitna River Below Devil Canyon, 1982. Phase II, Volume 3 Basic Data Report.
ADFG/Su Hydro Aquatic Studies Program. Anchorage, Alaska
Davis, J.C., and G.A. Davis. 2013. Water quality in the Lower Little Susitna River: Cumulative
draft report, July 2007 through June 2012. Final Report for the Alaska Department of
Environmental Conservation. Aquatic Restoration and Research Institute, Talkeetna, AK.
Kirsch, J.M., J.D. Buckwalter, and D.J. Reed. 2014. Fish inventory and anadromous cataloging
in the Susitna River, Matanuska River, and Knik River basins, 2003 and 2011. Alaska
Department of Fish and Game, Fishery Data Series No 14-4, Anchorage.
Miller, E.M., J.C. Davis, and G.A. Davis. 2011. Monitoring juvenile salmon and resident fish in
the Matanuska-Susitna Basin. Final Report for the U.S. Fish and Wildlife Service, Mat-Su
Salmon Habitat Partnership. Aquatic Restoration and Research Institute, Talkeetna, AK.
Riverine Model Integration Meeting. 2013. AEA meeting minutes. November 2013.
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20141027-5014
1
Licensing Participant Becky Long
Initial Study Review(ISR) Public Review Comments
Sec. 10.6 ISR Parts A-C Caribou Distribution, Abundance, Movements, Productivity
1.0 Seasonal Use and Movement Documentation
RSP 10.6.1 (ISR A.2) states that one of the Study Goals and Objective is to obtain
sufficient population information on caribou to evaluate projet related effects on
important seasonal ranges such as calving areas, rutting areas, wintering areas and
movement corridors.
10.6.2 discuses the need for documentation of currently used areas, along with
information on the timing, duration and proportion of the regional population that uses
those areas. This can be used to develop any necessary protection, mitigation, and
enhancement measures. Appropriate sufficient data must be collected in order to assess
impacts for the license application.
1.1 Local Ecological Knowledge
The boots on the ground local knowledge is an important part of this documentation.
These comments speak on behalf of Susitna River Coalition members in Game
Management Units 13 and 14. These are people who have hunted the caribou of either the
Nelchina or Delta herd for 10 to over 30 years. The words they speak are what the study
industry calls now local ecological knowledge.
The current movement of the herds has changed in response to two things. The warm late
fall season and Tier 1 hunting pressure are driving these changes according to local
hypotheses.
Usually the herds have come down from the high country.by hunting time. They did not
do that this year. The hunting pressure is overwhelming. The use of ATV vehicles
penetrate further into the remote areas. The gravel pit at the Susitna River bridge on the
Denali Highway was mass motor homes, campers and ATVs testifying to large amounts
of people in the area.
According to local hunters, “The Nelchina Caribou Herd has hunting pressure like never
before.” The general area around and adjacent to both the Denali East and Denali West
has been characterized as a “war zone”.
Hunters say that the caribou herds are fractured. Where in the Tier II hunting days,
hunters would see bands of caribou. But now they often see single caribou, and they look
panicked.
2.0 Documentation of other Human Caused Disturbances in the 10.6 Study Area
The evaluation of population and density estimates, delineation of seasonal ranges, and
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movement corridors will make conclusions on post project habitat loss and detrimental
impacts to these herds. This is a major goal of 10.6. An impact assessment will be
conducted in 2015 for the FERC License Application. There must be a study focus on the
cumulative negative impacts from all the development actions in the Caribou lives.
Specific development to consider:
2.1 MMG Mineral Exploration Drilling Project
In 2012 and 2013, MMG Mineral Exploration LLC has done exploratory drilling on state
lands south of the Susitna River. They have been drilling rock core samplings.
This year, MMG.applied for a mineral drilling exploration application with the Bureau of
Land Management Glenallen Field Office on tentatively approved state land east of the
Susitna River which is within 10.6 study area. The locations are T29N R5 E sections 13,
14,20,21,23,24 and T30N R6E Sec. 29. The Environmental Assessment is found as
DOI-BLM-AK-A020-2014-0013-EA. Sec302 of the Federal Land Policy Management
Act covers this application.
This is the northern part of the traditional Nelchina herd calving area.
THE TALKEETNA MOUNTAIN CALVING GROUNDS ARE CONSIDERED THE
MOST IMPORTANT SINGLE GEOGRTAPHIC AREATO THE HERD.
MMG helicopter flights flew in that area and also south of the Susitna Bridge on the
Denali Highway towards the headwaters and the Susitna glacier. Perhaps some of these
flights were connected to AEA’s study flights.
The helicopter noise was throughout the day with the usual high noise level that
permeates the air space.
2.2 Joint Pacific Alaska Range Complex (JPARC) Fox3 and Paxon Military
Operation Areas (MOA)
The Fox 3 MOA Expansion and the Paxon MOA Addition are well-defined actions for the
JPARC Master Plan by the Air Force.
Both actions are to provide vertical and horizontal airspace structures needed to
modernize the JPARC training exercises according to the plan. This is both low and high
altitude training with elevation as low as 500 feet up to 5000 feet. The subsonic noise
levels for Fox3 can be as much as 50dB. For the Paxon, it would be 54dB. The average
number of sonic booms per training day could be 5.2. Emissions and pollution from chaff
and flare use are a consideration.
Conclusion
The above projects are coupled with the road building, dam construction, inter-tie
building, etc. that will accompany the Susitna Dam if built. This means that the
cumulative effect on the Nelchina Herd is an issue that must be part of the data for the
impact assessment. The helicopter use of the study area by AEA study staff and MMG
staff is already impacting both the herds.
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20141027-5019
1
Licensing Participant Becky Long
Initial Study Review (ISR) Public Review Comments
Sec. 15.9 Air Quality Study
1.0 ISR Part A 5.1.1 Meteorology and Climate
An important statement from this stakeholder’s literature review of Air Quality issues to
be entered into the public record. This is information from the draft Environmental
Impact Statement for the previous hydroelectric project on the Susitna River. 1
“An important feature characteristic of Alaska and the project area in particular in
terms of air quality is the so-called “extreme” meteorology. Because of the dramatic
topographical and meteorological conditions in Alaska, the potential for air pollution
is far greater than in the rest of the U.S. The winter inversions in Alaska are among
the strongest anywhere in the world. Strong inversions occur when ground surface
cools faster that the overlying air, a condition common in the arctic winter when
there is little sunlight to heat the ground surface. The long winter nights prolong
these inversion periods, and a strong potential for air pollution may last for several
weeks.”
2.0 Modification Requests
Modifications of 5.2 Project Emissions are proposed.by this stakeholder. The
modification would be a quantification of greenhouse gas emissions from reservoir
inundation, permafrost melting from project development along with climate change, and
cement production emissions.
The proposed Susitna Dam Project Manager in his 2014 presentations in meetings in the
Railbelt and to the media quotes the quantification of carbon dioxide emissions that
supposedly will be displaced by the proposed dam. This figure he got from this study.
This study has not been finished nor the data accepted by FERC. But this emission
statement is now out there being promoted as fact. This figure does not tell the whole
story about air emissions. The public has a right to know the whole picture of short and
long term emissions.
2.1 Reservoir Greenhouse Gas Emissions
Both FERC’s 2/1/13 Study Plan Determination and the applicant’s Technical Work Group
meetings state that AEA intends to assess greenhouse gas (GHG) emissions in the license
application.
According to the 2/1/13 FERC Study Plan Determination B-69:
“AEA intends to assess greenhouse gas emissions in its license application based on
1 Office of Electric Power Regulation, Federal Energy Regulatory Commission, “Draft Environmental Impact
Statement Alaska Power Authority, Susitna Hydroelectric Project,” (May 1984): G-3
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unspecified guidelines for projects in boreal regions and using existing information
from studies that show such emissions from reservoirs in boreal regions are low.
While greenhouse gas emissions initially increased under construction, within 10
years they returned to levels similar to natural water bodies (Tremblay 2009). “
Both FERC and AEA state that existing information from this study shows that methane
and carbon dioxide emission from reservoirs in boreal regions are low. GHG emissions
initially increased under construction; but within 10 years. they returned to levels similar
to natural water bodies. These statements come from 1 study which is Tremblay 2009. 2
There are 3 major pathways of reservoir emitted GHG emissions:
1.diffusion at the reservoir surface,
2.bubbles produced at the sediment-water interface which migrate through the water
column into the atmosphere,
3.diffusion in turbulent waters downstream of the generating station in a process called
degassing.
Tremblay did indeed make the above conclusions. But the study also states:
There must be further measurements in the Eastman 1 Hydroelectric reservoir in
Quebec to confirm this trend. Thus, I don’t think FERC and AEA should state the
assumption as fact.
The values presented have significant uncertainty due to the biological nature of
organic matter degradation, sampling method diversity and spatial and temporal
variation of emissions.
These caveats should be placed into the public record regarding this study which is
becoming baseline-type data for the applicant.. Thus, both FERC and AEA should not
take Tremblay conclusions as fact. Models to predict GHG emissions are being developed
by a few specialized groups which will help evaluate the uncertainty about total GHG
reservoir emissions. The science of determining reservoir emissions is still young.
An increasing plethora of media in the scientific and general populations regarding the
dam reservoir GHG emissions makes this an important issue in order to understand
climate impacts. In separate studies, researchers have seen methane jump 20 and 36 fold
during reservoir drawdowns.
2.2 Permafrost
Also there needs to be quantitative analysis of permafrost degradation in the project area.
Melting permafrost also emits the GHG emissions of methane and carbon dioxide based
on the aerobic or anerobic conditions. We know from 7.7 study Glacier and Runoff
Changes and the draft Watana Transportation Access Analysis that the majority of the
whole project area including all the access alternatives are underlain with discontinuous
permafrost.
2 Bastien, Julie and Maud Demarly, Alain Tremblay.”CO2 and CH4 diffusive and degassing emissions from 2003 to
2009 at Eastmain1 hydroelectric reservoir, Quebec, Canada,”6/21/2011.
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There is significant permafrost evident at the abutments of the dam site. This was found
in the 80s and is currently being quantified in study section 4.5 Geology and Soils. In the
10/22/14 recent ISR meeting, the 4.5 Geology and Soils study staff stated that frozen
ground could be 235 feet deep on the south side of the dam. The temperatures are very
close to 32 degrees F. Calculations for the north side are still being quantified. The data
from the 1980s studies shows permafrost conditions exist to a depth of 120 feet on the
south side and up to 60 feet on the north side.
The development in permafrost areas that causes melting and emissions needs to be
quantified as an air quality emission.
2.3 Cement Manufacturing Emissions
The applicant has not made public or does not know where the cement will be made.
Thus, the quantitative analysis of emissions if the applicant locates a Portland cement
plant in the project area will be put off until the license application This must be analyzed
in this ILP study in order to get a full picture of emissions in dam construction.
Section 3.3.1.1 of applicant’s Preliminary Application Document states that there will be
5.2 million cubic yards total volume of concrete in the dam structure. This does not
include the 35 foot diversion tunnel, a 1800 foot concrete lined tunnel and also the
spillway. This is a lot of concrete to not be talking about in this air quality study. This
cement will be manufactured somewhere with the resulting emissions.
Conclusion
The above three emission sources should be analyzed in 15.9 in order for the study to
adequately describe both the short and long term air emissions from the proposed project.
20141027-5019 FERC PDF (Unofficial) 10/25/2014 3:42:28 PM
20141202-3032
UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
Alaska Energy Authority Project No. 14241-000
NOTICE OF REVISED RESTRICTED SERVICE LIST
FOR A PROGRAMMTIC AGREEMENTS FOR MANAGING
PROPERTIES INCLUDED IN OR ELIGIBLE FOR INCLUSION IN
THE NATIONAL REGISTER OF HISTORIC PLACES
(December 2, 2014)
On February 25, 2014, the Federal Energy Regulatory Commission (Commission)
issued notice of a proposed restricted service list for the preparation of a programmatic
agreement for managing properties included in, or eligible for inclusion in, the National
Register of Historic Places at the Susitna-Watana Hydroelectric Project No. 14241. Rule
2010(d)(1) of the Commission’s Rules of Practice and Procedure, 18 CFR 2010(d)(1)
(2005), provides for the establishment of such a list for a particular phase or issue in a
proceeding to eliminate unnecessary expense or improve administrative efficiency.
Under Rule 2010(d)(4), persons on the official service list are to be given notice of any
proposal to establish a restricted service list and an opportunity to show why they should
also be included on the restricted service list.
On March, 11, 2014, Sharon Corsaro, Concerned Citizen for the Historic District
of Talkeetna, Alaska (Talkeetna Historic District), and Robert Gerlach, President of
Talkeetna Airmen’s Association filed requests to include: Sharon Corsaro, Talkeetna
Historic District; Constance Twigg, property owner in the Talkeetna Historic District;
and Robert Gerlach, Talkeetna Airmen’s Association on the proposed restricted service
list.
On March 12, 2014, Van Ness Feldman, LLP (Van Ness) on behalf of the Alaska
Energy Authority (AEA) filed a request to include Wayne Dyok, Susitna-Watana Project
Manager of AEA and Charles Sensiba of Van Ness, and council for AEA, on the
proposed restricted service list.
On May 12, 2014, AEA filed a letter opposing the additions of such persons as
Ms. Corsaro, Ms. Twigg, and Mr. Gerlach to the restricted service list because AEA
maintains that their particular interests are more broad and non-regulatory in nature and
they should not have access to sensitive cultural information that is protected by law from
20141202-3032 FERC PDF (Unofficial) 12/02/2014
Project No. 14241-000 2
public disclosure.1 In this regard, we agree with AEA to restrict such sensitive
information from individuals who are not associated with the involved agencies and
Alaska Native entities.
Under Rule 2010(d)(2), any restricted service list will contain the names of each
person on the official service list, or the person’s representative, who, in the judgment of
the decisional authority establishing the list, is an active participant with respect to the
phase or issue in the proceeding for which the list is established. As the proposed
licensee for the project, AEA, and their legal representative at Van Ness, have an
identifiable interest in issues relating to the management of historic properties at the
Susitna-Watana Hydroelectric Project No. 14241. Therefore, AEA’s representatives will
be added to the restrictive service list. In regards to the representatives associated with
the Talkeetna Historic District and Talkeetna Airmen’s Association, these additional
three individuals will also be added to the restricted service list as they too have
identifiable interest in issues relating to the management of historic properties at the
Susitna-Watana Hydroelectric Project No. 14241. These interests are: (1) the partial
ownership of the Talkeetna Village Air Strip by the Talkeetna Airmen’s Association and
the preservation and protection of this historic property; and (2) the preservation and
protection of the Talkeetna Historic District. However, these three individuals should not
receive any information deemed sensitive or confidential in nature that is associated with:
(1) data or reports involving archeological finds; or (2) Alaska Native areas, items, or
perspectives deemed to be of religious or cultural significance and considered sensitive to
one or more the involved Alaska Native entities. Finally, the Bureau of Land
Management also needs to have a representative added to the restricted service list
because they manage lands within the proposed project’s boundary and are participants
within the technical work group for cultural resources.
Accordingly, the restricted service list issued on October 12, 2006, for the Susitna-
Watana Hydroelectric Project No. 14241, is revised to add the following persons:
1 See 16 U.S.C. 470w-3(a); also see 18 CFR 5.2(c).
Wayne Dyok or Representative Charles Sensiba or Representative
Susitna-Watana Project Manager Van Ness Feldman, LLP
Alaska Energy Authority 1050 Thomas Jefferson St., NW
813 West Northern Lights Boulevard Seventh Floor
Anchorage, AK 99503 Washington, DC 20007
John Jangela or Representative Constance Twigg or Representative
Bureau of Land Management Property Owner
Glennallen Field Office Historic Townsite of Talkeetna
P.O. Box 147, Mile Post 186.5 Glenn Hwy.P.O. Box 266
Glennallen, AK 99588 Talkeetna, AK 99676
20141202-3032 FERC PDF (Unofficial) 12/02/2014
Project No. 14241-000 3
Sharon Corsaro or Representative Robert Gerlach or Representative
Concern Citizen President of the Talkeetna Airman’s
Historic District of Talkeetna Association
P.O. Box 255 P.O. Box 23
Hermosa Beach, CA 90254 Talkeetna, AK 99676
Kimberly D. Bose,
Secretary.
20141202-3032 FERC PDF (Unofficial) 12/02/2014
20141208-0047
DEPARTMENT OF THE ARMY
ALASKA DISTRICT,U.S.ARMY CORPS OF ENGINEERS
REGULATORY DIVISION
P.O.BOX 6898
JEER,ALASKA 995064898
Oy
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CEPOA-RD
(POA-2011-1107)
Ms.Kimberly D.Bose
Secretary
Federal Energy Regulatory Commission
888 First Street,N.E.
Washington,D.C.20428
28 November 2014
'1
C )
ico
Dear Secretary Bose:
This is in regard to the June 3,2014,letter from the Alaska Energy Authority that gave notice of
filing and distribution of the Initial Study Report (ISR)prepared for the Susitna-Watana Hydroelectric
Project,FERC No.14241-000.In response to the notice,we are providing comments on proposed new or
modified studies included in this report.Our review was limited to the studies central to our regulatory
authority under Section 404 of the Clean Water Act and Section 10 of the Rivers and Harbors Act of 1899.
The following are our comments on the Aquatic Resources Study within the A&mess Alignment (9.13)and
the Wetland Mapping Study (11.7).
1)We understand the wetland mapping study is currently on-going,including QAIQC of the field
data,aerial imagery interpretation and mapping of wetlands,and wetland functional assessment
analysis.To ensure the fi'nal products are suitable and appropriate for our potential future use
and consideration,we request that we be notified by the applicant at the soonest possible date
this information becomes available for review.
2)The Corps supports incorporating the interdependency studies in the wetland functional
assessment as a way of developing a sound evaluation system that reflects the project site
aquatic resources functions and values.Integration of the Vegetation and Wildlife Habitat
Mapping Study and the Ripadan Study into the Modified Magee 1988 Functional Assessment
should be useful to development of 8 robust aquatic resource evaluation method for this project.
3)We would like to be consulted on the proposed modifications to the Magee 1988 Functional
Assessment methodology,including an opportunity to review and provide input on adjustments to
the field wetland functions investigation forms and the wetland functional assessment models.
4)The Corps Special Public Notice (SPN)2010-45 is to serve as guidance for Consultant-Supplied
Jurisdictional Reports within the Alaska Dish ict.As per SPN 201 0-45,specific document format
and data submittals are necessary,including georeferenced information such as shapefiles of
wetland polygons,sampling points GPS,project footprint,contour lines,streams,aerial imagery,
among others.Incorporation of this information format into the wetland study may be of
assistance to avoid duplication of future efforts.
5)It is not apparent in Study 9.13what criteria were used in selection of the alternatives for the
access and transmission alignments,and construction areas.
20141208-0047 FERC PDF (Unofficial) 12/08/2014
Please contact me via email at Jason.R.Berkner@usace.army.mil,by mail at the address above,by
phone at (907)753-5778,or toll free from within Alaska at (800)478-2712,if you have questions.For
more information about the Regulatory program,please visit our website at
htto://www.ooa.usace.armv.mil/Missions/Reoulatorv.asox.
Sincerely
Jason Berkner
Project Manager
20141208-0047 FERC PDF (Unofficial) 12/08/2014
20141208-0048
P
J~~ENERGY AUTHORITY
"josi'8 C"C-8 p I:l5
November 26,2014
The Honorable Kimberly D.Bose
Secretary
Federal Energy Regulatory Commission
888 First Street,NE
Washington,DC 20426
Re:Susitna-Watana Hydroelectric Project,FERC Project No.14241-000;
Errata to June 3,2014 and November 14,2014 Filings
Dear Secretary Bose:
On June 3,2014,the Alaska Energy Authority (AEA)filed with the Federal
Energy Regulatory Commission (Commission or FERC)the Initial Study Report for the
proposed Susitna-Watana Hydmelectric Project,FERC Project No.14241 (Project).~
Additionally,on November 14,2014,AEA filed Initial Study Plan meetings transcripts
and additional technical memoranda.2 The purpose of this filing is to submit errata to
two documents:
~Attachment A:River Productivity Study,Srudy Plan Section 9.8,Initial Study
Report,Errata to Appendix A (June 3,20ld Final Initial Study Report).This
errata corrects references to reviews conducted by R2 Resource Consultants
and adds literature cited to the initial study report filed on June 3.
~Attachment B:Errata io Fish Disiribuiion and Abundance in the Upper and
Middle/Lower Susirrrrr River (Studies 9.5 and 9.6):Draft Chinook and Coho
Salmon Identification Protocol.This errata makes minor revisions to the
language in the introduction of the protocol filed on November 14.Included
with this attachment is a revised protocol that includes this revision.
Initial Study Report for the Susitna-Watana Hydroelectric project of Alaska Energy Authority,project
No.14241-000 (filed June 3,2014).
Filing of Initial Study Plan Meetings Transcripts and Additional Information in Response to October
2014 Initial Study plan Meetings of Alaska Energy Authority,project No.14241400 (tiled Nov.14,
2014).
813 West tsonhem ughts Boulevard Anchorage,Alaska tr0503 T 407.771.3000 Tes Free gtlaska Only)888.300.8534 F 007.771.3044
20141208-0048 FERC PDF (Unofficial) 12/08/2014
If you have any questions related to this maner or need additional information,
please do not hesitate to contact the undersigned at f907)771-3955.
project Manager
Alaska Energy Authority
cc:Distribution List
20141208-0048 FERC PDF (Unofficial) 12/08/2014