HomeMy WebLinkAboutSusitna FERC Vol 10A exhibit E 1983-
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BEFORE THE
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FEDERAL ENERGY REGULATORY COMMISSION
APPLICATION FOR LICENSE FOR MAJOR PROJECT
SUSITNA HYDROELECTRIC PROJECT
VOLUME 10A
EXHIBIT E
Chapter 11
FEBRUARY 1983
~--ALASKA POWER AUTHORITY __ __,
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SUSITNA HYDROELECTRIC PROJECT
VOLUME lOA
EXHIBIT E _ CHAPTER 11
TEXT AND APPENDICES A THROUGH H
AGENCY CONSULTATION
P~ SUSITNA HYDROELECTRIC PROJECT
VOLUME lOA
fXHIBIT E CHAPTER 11
Text and Appendices A through H
AGENCY CONSULTATION
TABLE OF CONTENTS PAGE
1-ORGANIZATION OF CONSULTATION PROGRAM ........................ E-11-1
1.1 -Formal Consultation •.................................. E-11-1
1.1.1 -Regulatory Requirements .............•......... E-11-1
1.1.2-Organization .................................. E-11-2
1.1.3-Fish and Wildlife Mitigation Review Group ...•. f-11-3
1. 2 -Informal Consult at ion ................................. E-11-3
1.2.1 -Susitna Hydro Steering C{)mmittee .............. E-11-3
1.2.2 -Environmental Workshop ........................ E-11-3
2 -PHASES OF-REVIEW ............................................ E-11-5
2.1 -Consultation Prior to Preparation of Draft FERC
Application .......•...............................•... E-11-5
2.1.1 -Plan of Study ................................. E-11-5
2.1.2 -Data Collecti{)n and Project Assessment ........ E-11-5
2.1.3-Development Selection ......................... E-11-5
2.1.4-Mitigation Planning ·························~· E-11-5
2.1.5-Feasibility Assessment .•...........•..••...... E-11-6
2.1.6-Additional Studies ...............•............ E-11-6
2.2 -Draft License Review .................................. f-11-6
LIST OF TABLES i
LIST {)f FIGURES ii
-Appendix EllA -Correspondence Re 1 at ing to Organization
of Consultation Program
Appendix £118 -Corr~spondenc-e Relating to Plan of Study
Appendix EllC -Correspondence RelaUng to lJata Collection
and Project Assessment
Appendix El1D -Correspondence Relating to Deveiopment Se1ectfon
Appendix Ell£ -Correspondence R-elating to Mitigatinn Planning
Appendix EllF -Correspondence "Re1 at ing to Fe as i-b1l ity Assessment
Appendix EllG -Correspondence Reiating to Addit1onal Studies
and Pr-oject Refinement
Appendix EllH -Comments During Nov€mber 1982 Workshop
TABLE OF CONTENTS
Appendix Ell! -Correspondence Relating to Draft Review
Appendix EllJ -Comments Received from Agencies Concerning
the Draft License and the Power Authority•s
Response to These Comments
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LIST OF TABLES
Table
E.ll.l
E.11.2
E.11.3
E.11.4
E.11.5
E.11.6
E.11. 7
E.l1.8
E.11.9
Formal Agency Coordination List (original}
Original List of Reports and Groups to Which
Reports Were/Were To Be Sent
Original List of Agencies and Reports Received
Agency Coordination Expanded List
Expanded List of Reports and Groups to Which
Reports Were/Were To Be Sent
Reports, Date Sent, and Purpose
Agencies Invited and Those Which Declined To Be On
the Fish and Wildlife Mitigation Review Group
Members of the Susitna Hydroelectric Project
Steering Committee
Dates and Purpose of Steer·i ng Committee Meetings
With APA and/or its Consultants
E.ll.lO Objectives of the Susitna Hydroelectric Environmental
Workshops
E.ll.ll Agenda of the Susitna Hydroelectric Environmental
Workshop
E.11.12 List of Attendees
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LIST OF FIGURES
Figure
E.ll.l
E.11.2
Organization of Agency Consultation Program
Agency Consultation Review Process
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11 -AGENCY CONSUL TATfON
This chapter describes the various processes utilized, and committees
established by the Alaska Power Authority (Power Authority) to provide
agency input into the. studies and discussions associated with the
Susitna Hydroel ect ric Project. This agency consultation and resulting
agency input was requested and provided on both an informal and formal
basis as described below. In addition, the Power Authority conducted
an extensive public participation program. For a discussion of this
general public participation in the project, refer to Appendix D of the
Feasibility Report.
In addition to this agency consultation described, a large number of
agencies were contacted for information during the preparation of the
environmental reports. This resulted in a constant exchange of ideas
and updating on the project 1 S progress.
1 -ORGANIZATION OF CONSULTATION PROGRAM
Consultation with the regulatory agencies was conducted on both a for-
mal and informal basis as described below. Formal consultation was
conducted with the agencies as required by the regulations of the Fed-
eral Energy Regulatory Commission (FERC) and was done primarily via
correspondence. Informal consultation was done primarily via numerous
meetings and was conducted to provide an information flow between the
Alaska Power Authority, its consultants, and the agencies to insure
agency input into the project planning and decision making process.
Figure E.11.1 depicts the organization of the agency consultation pro-
gram.
1.1-Formal Consultation
1~ 1.1 -Regulatory Requirements
The FERC regulations pertaining to applications for license under
Part I of the Federal Power Act require in 18 CFR Part 4, Subpart
E, Section 4.41, that applicants for licenses consult with local,
state, and federal natural resource agencies prior to fil·ing of
their license application. Accordingly, the Alaska Power Author-
ity formulated a plan to consult with these agencies.
· The process utili zed by the Power Authority was based upon c i rcu-
lation of reports of the various aspect~ of the projects to the
agencies and a written request for agency comments. The reports
circulated were interim reports in specific study areas (fisher-
ies, wildlife, etc.) as discussed below, as well as planning de-
cision reports (access road, transmission line corridors, etc.) •
. In addition, prior to initiation of project studies, the Plan of
'Study and revisions were circulated. Results of the fish and
wildlife mitigation planning efforts were also circulated under
E·dl-1
this formal program. Finally, a draft version of Exhibit E of
the license application was provided to all agencies on November
15, 1982.
1.1.2-Organization
The organization and implementation of the Formal Agency Coordi-
nation Program has been a dynamic process modified because of
agency input. The original organization is explained below, fol-
1 owed by an exp 1 a nat ion of the revised organization. Correspon-
dence relating to that organizational process appears in Appendix
ll.A.
(a) Original Organization
(i) Agency Groups
Subject areas for coordination were selected based
upon those required by the FERC regulations. These
were water quality and use; fish, wildlife, and bo-
tanical; historical and archeological; recreation;
aesthetics; and land use. State, federal, and local
agencies having jurisdiction over ,,resources in each
of these subject areas were then placed in the appro-
priate group of agencies which would receive reports
concerning these subjects. A general category was
also added to include agency involvement with policy
decisions. Table E.11.1 lists the agencies original-
ly included in each of these groups.
(ii) Reports Circulated
A 1 i st of the reports and the groups to which they
were sent appears in Table E.ll.2. Because of over-
lapping jurisdictions (one agency present in more
than one group), several agencies received reports ~n
different subjects. Table E.ll.3 1 ists, by agency,
the reports received.
(b) Revised Organization
Initial circulation of these reports resulted in feedback
from the agencies concerning the organization of the for-mal
agency coordination program. Following several meetings be-
tween the Power Authority and the agencies, t-he -program was
revised. The revisions included:
-An expansion of the number nf groups;
-An expansion of the number of agencies within each group;
and
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- A decrease in the number of reports for which formal com-
ments were requested and, instead, simply providing re-
ports for information as backup documents to reports on
which comments were requested.
Table E.l1.4 Ti sts the revised subject groups and the agen-
cies within each group. Table E.ll.5 lists the reports to
be received by each group, and Table E.11.6 reports the date
they were circulated and their purpose '(information or
comment). This revised program exceeds the consultation
required by FERC but was implemented to insure that all
agencies received adequate informatiorr.
1.1.3-Fish and Wildlife Mitigation Review Group
Throughout the Sus itna Hydroe 1 ectri c Project studies, technical
mitigation planning has been conducted by the Power Authority and
its consultants to reduce impacts to fish and wildlife resources.
To insure agency input into this process, a Fish and Wildlife
Mitigation Review Group was established. The purpose of this
group was to review fish and wildlife mitigation options pre-
sented to them and provide comments on priority and practicality
of their options. Agencies invited to be on this committee and
those who accepted are listed in Table E.11.7.
1.2 -Informal Consultation
1. 2.1 -Sust ina Hydro Steering Committee
The Sus itna Hydroelectric Project Steering Committee was estab-
lished in 1980 as a mechanism to insure agency interaction in
project progress and decision making. The first meeting was held
in July 1980 and meetings continue to date. Originally envi-
sioned as a formal process, it was decided the committee would
function as an informal body with official agency comment ad-
dressed via the Formal Agency Coordination Program. Appendix
11.A contains correspondence relative to the establishment of the
Steering Committee. ,
The committee consists of representatives of state and federal
agencies as listed in Table E.11.8. Table E.11.9 1 ists the dates
of meetings between the Power Authority and the Steering Commit-
tee and the purpose of these meetings.
1.2.2-Environmental Workshop
To assist agencies in reviewing the draft Exhibit E a four-day
workshop was held in Anchorage from November 29 to December 2,
1·982. The objectives for the workshop agenda and a listing of
participants is included in Table E.l1.10, E.ll.ll, and E.11.12,
respectively.
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2 -PHASES OF REVIEW
The Sus itna studies have included extensive agency consultation, com-
mencing with a request for review of the Plan of Study in the spring of
1980 through to a request for review and comment on the Draft Exhibit E
on November 15, 1982. The various study phases, items reviewed, and
review schedule are shown on Figure E.11.2.
2.1 -Consultation Prior to Preparation
of Draft FERC License Application
2.1.1 -Plan of Study
The Plan of Study was circulated for review in March 1980, with
public and agency meetings being held in April 1980. The Plan of
Study was further discussed with the Steering Committee in Sep-
tember 1980. In addition, Environmental Procedure Manuals were
circulated for.review in October 1980. Comments on the Plan of
Study were subsequently received and responded to. This process
insured agency input into the design and future of the study.
Correspondence appears in Appendix 11.B.
2.1.2 -Data Coll~ction and Project Assessment
All big game and fisheries baseline data were collected by the
Alaska Department of Fish and Game (ADF&G) under a Reimburseable
Services Agreement with the Alaska Power Authority. ADF&G had a
major influence on the direction, scope, and schedule for these
studies. Annual reports for all the environmental subtasks were
distributed in April-May 1981.
In addition to annual environmental reports, comments were re-
. quested on access road reports, transmission line siting reports,
and the Sus itna Hydroelectric Project Mid-Study report. Corres-
pondence concerning these documents appears in Appendix ll.C.
2.1.3 ~ Development Selection
In March 1981, the Development Selection Report was circulated to
agencies for. review and comment. This report compared various
development scenarios.within the lower and middle Susitna Basin
as well as alternatives outside the basin. Comments received on
the Development Selection Report appear in Appendix 11.D.
2.1.4-Mitigation Planning
Mitigation Planning for the Susitna Hydroelectric Project has in-
volved the Power Authority, its consultants, and state and fed-
eral resource agencies. A Fisheries .Mitigation Core. Group,
Wildlife Mitigation Core Group (to develop technical mitigation
plans)~ and a Fish and Wi.ldlife Mitigation Review Group (to pro-
vide agency input to 'the mitigation plans) were established.
E-11-5
A Fish and Wildlife Mitigation Policy was developed, revised
three times following receipt of comments, and finalized during
the 1981-1982 period. Various mitigation option papers were also
drafted, circulated for comments, and discussed in meetings with
the agencies. Appendix 11.E contains correspondence related to
mitigation planning.
2.1.5-Feasibility Assessment
On March 15, 1982, the Susitna Feasibility Report was distributed
for review and comments. During April and May all support docu-
ments were distributed. Appendix ll.F contains a 1 ist of agen-
cies to whom the report was sent. Also included are agency com-
ments and testimony.
2.1.6-Additional Studies and Project Refinement
In response to agency concerns and in recognition that further
studies, especially in the area of fisheries, were warranted
prior to submitting a FERC license appliction, the decision was
made by the Alaska Power Authority to delay the license applica-
tion date. Studies and project refinements that received agency
review included the wildlife/habitat model, water quality and
flow modeling, access plans, and downstream flow release sched-
ule. Agency consultation took the form of Steering Committee
meetings, habitat modeling workshop, Fish and Wildlife Mitigation
Review Group meetings, and request for written comment on the re-
vised access p 1 an. Correspondence and minutes of meetings from
the above are contained in Appendix 11.G.
2.2-Draft License Review
On November 15, 1982, a Draft Exhibit E of the 1 icense appl ica-
tion was distributed to appropriate federal, state, and local
agencies for official review and comment. Agencies receiving
copies of this report are 1 isted in Table E.l1.12. To assist
agencies in reviewing the Draft Exhibit E, a four-day workshop
was held in Anchorage from November 29 to December 2, 1982. Un-
official agency comments received during this workshop are in-
cluded in Appendix ll.H. Following the 60-day review period,
comments were received from the resource agencies. These appear
in Appendix ll.I. Comments relating to any measures or facili-
ties recommended by the agencies that could mitigate potential
impacts of the project are addressed specifically at the end of
appropriate chapters with Exhibit E. If the Power Authority has
not accepted any of these recornmendat ions, the reasons are ·pre-
sented.
An entire set of comments, including all those relating tomiti-
gation, report reviews, assessment of alternatives, and the need
for the project, are inc 1 uded in a comment-response format in
Appendix 11.J. Each comment is presented followed immediately by
the Power Authority•s response.
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TABLE Eo 11 o 1 : FORMAL AGENCY COORD I NAT I ON Ll ST (ORIGINAL)
Water Quality and Use Group
Mr. John Katz
Alaska Department of Natural Resources
Pouch M
Juneau, Alaska 99811
Colonel Lee Nunn
District Engineer
Alaska District
U.S. Army Corps of Engineers
P.O. Box 7002
Anchorage, Alaska 99510
Mr. John Spencer
Regional Administrator
Region X
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
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Fish, Wildlife, and Botanical Group
Mr. Robert McVey
Director, Alaska Region
National Marine Fisheries Service
NOAA
P.O. Box 1668
Juneau, Alaska 99802
Mr. Ernest W. Mueller
Commissioner
Alaska Department of Environmental
Conservation
Pouch 0
Juneau, Alaska 99801
Mr. Keith Schreiner
Regional Director, Region 7
U.S. Fish and Wildlife Services
1011 East Tudor Road
Anchorage, Alaska 99503
cc: Mr. Alan Carson
Division of Natural Resources
Alaska Department of Natural
Resources
Pouch 7-005
Anchorage, Alaska 99510
cc: Judy Swartz
U.S. Environmental Protection
Agency
Mail Stop 443
Region X EPA
1200 Sixth Avenue
Seattle, Washington 98101
cc: Mr. Ron Morris
Director
Anchorage Field Office
National Marine Fisheries
Service
701 C Street, Box 43
Anchorage, Alaska 99513
Mr. Ronald 0. Skoog cc: Mr. Thomas Trent
State of Alaska Commissioner
State of Alaska Department of Fish and Game
Support Building
Juneau, Alaska 99801
Department of Fish and Game
2207 Shepard Road
Anchorage, .Alaska 99502
TABLE E. 11.1: (Page 2)
Historical and Archeological Group
Mr. John E. Cook
Acting Regional Director
Alaska Office
National Park Service
540 West Fifth Avenue
Anchorage, Alaska 99501
Ms. Lee McAnerney
Department of Community and Regional Affairs
Pouch B
Juneau, Alaska 99811
Mr. Robert Shaw
State Historic Preservation Officer
Alaska Department of Natural Resources
Division of Parks
619 Warehouse Avenue, Suite 210
Anchorage, Alaska 99501
Recreation Group
Mr. John E. Cook
Acting Regional Director
Alaska Office
National Park Service
540 West Fifth Avenue
Anchorage, Alaska 99501
Mr. John Katz
Alaska Department of Natural Resources
Pouch M
Juneau, Alaska 99811
Mr. Lee Wyatt
Planning Director
Matanuska-Susitna Borough
Box B
Palmer, Alaska 99645
Aesthetics and Land Use Group
Mr. Roy Huhndorf
President
Cook Inlet Region, Incorporated
P.O. Drawer 4N
Anchorage, Alaska 99509
Mr. John Katz
Alaska Department of Natural Resources
Pouch M
Juneau, Alaska 99811
cc: Mr • Larry Wright
National Park Service
1011 East Tudor Road
Suite 297
Anchorage, Alaska 9950~
cc: Mr .• Alan Carson
Division of Natural Resources
Alaska Department of Natural
Resources
Pouch 7-005
Anchorage, Alaska 99510
cc: Mr. Larry Wright
National Park Service
1011 East Tudor Road
Suite 297
Anchorage, Alaska 9950~
cc: Mr. Alan Carson
Division of Natural Resources
Alaska Department of Natural
Resources
Pouch 7-005
Anchorage, Alaska 99510
cc: Mr. Alan Carson
Division of Natural Resources
Alaska Department of Natural
Resources
Pouch 7-005
Anchorage, Alaska 99510
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TABLE E. 11.1: (Page 3).
Aesthetics and Land Use Group {cont'd)
Mr • John Rego
Bureau of Land Management
Anchorage District Office
4700 East 72nd Avenue
Anchorage, Alaska 99507
General
Ms. Wendy Wolt
Office of Coastal Management
Division of Policy Development and Planning
Pouch AP
Juneau, Alaska 99811
Report
TABLE E.11.2: ORIGINAL LIST OF REPORTS AND GROUPS TO
WHICH REPORTS WERE/WERE TO BE SENT
Plan of Study and Plan of Study Revisions
Development Selection Report
1980 Annual Environmental Summary Report
1980 Annual Reports
Fish Ecology
Big Game
Birds and Non-Game Mammals
Furbearers
Plant Ecology
Land Use
Socioeconomics
Cultural Resources
Recreation
Instream Flow Study Plan
Transmission LiRe:Corridor Screening Report
Fish and Wildlife Mitigation Policy
Feasibility Report
1981 Final Phase I Reports
FWB = Fish, Wildlife, and Botanical
ALU = Aesthetics, Land Use
HA = Historic and Archaeological
R = Recreation
WQ = Water Quality
G = General
Group
A11
A11
A11
FWB
FWB
FWB
FWB
FWB
ALU
HA
HA
R
WQ, FWB, G
A11
FWB
A11
A11
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TABLE E.l1.3: ORIGINAL LIST OF AGENCIES AND REPORTS RECEIVED
Alaska Department of
Natural Resources
Alaska Department of
Fish and Game
Alaska Department of
Environmental Conservation
Alaska Department of
Community and Regional Affairs
Plan of Study
Plan of Study Revisions
Development Selection Report
1980 Annual Environmental Summary Report
Instream Flow Study Plan
1980 Socioeconomic Annual Report
1980 Cultural Resources Annual Report
1980.Land Use Annual Report
1980 Recreation Annual Report
Transmission Line Corridor Screening Report
Fish and Wildlife Mitigation Policy
feasibility Report
Final Phase I Reports
Plan of Study and Plan of Study Revisions
Development Selection Report
1980 Annual Environmental Summary Report
Instream Flow Study Plan
1980 Fish Ecology Annual Report
1980 Big Game Annual Report
1980 Birds and Non-Game Mammals Annual Report
1980 Furbearers Report
1980 Plant Ecology Report
Transmission Line Corridor Screening Report
Fish and' Wildlife Mitigation Policy
Feasibility Report
Final Subtask Reports
Plan of Study
Plan of Study Revisions
Development Selection Report
1980 Annual Environmental Summary Report
Instream Flow Study Plan
1980 Fish Ecology Annual Report
1980 Big Game Annual Report
1980 Birds and Non-Game Mammals Annual Report
19.80 Furbearers Report
1980 Plant Ecology Report
Transmission Line Corridor SCreening Report
fish and Wildlife Mitigation Policy
feasibility Report
Final Subtask Report
Plan of Study
Plan of Study Revisions
Development Selection Report
1980 Annual Environmental Surnmar.y Report
1980 Socioeconomic Annual Report
1980 Cultural Resources'; Annual Report
Transmission Line CorriddD.·Screening Report
Feasibility Report
Final Subta~k Reports
TABLE E.11.3: (Page 2)
Division of Policy Development
and Planning Office of Coastal
Management
Mantanuska-Susitna Borough
Cook Inlet Region, Inc.
U.S. Environmental Protection
Agency
U.S. Army Corps of Engineers
National Marine Fisheries
Service
Plan of Study
Plan of Study Revisions
Development Selection Report
1980 Annual Environmental Summary Report
Instream Flow Study Report
Transmission Line Corridor Screening Report
Feasibility Report
Final Subtask Reports
Plan of Study
Plan of Study Revis-ions.
Development Selection Report
1980 Annual Environmental Summary Report
1980 Recreation Annual Report
Transmission Line Corridor Screening Report
Feasibility Report
Final Phase I Reports
Plan of Study
Plan of Study Revisions
Development Selection Report
1980 Annual Environmental Summary Report
1980 Land Use Annual Report
Transmission Line Corridor Screening Report
Feasibility Report
Final Phase I Reports
Plan of Study
Plan of Study Revisions
Development Selection Report
1980 Annual Environmental Summary Report
Instream Flow Study Plan
Transmission Line Corridor Screening Report
Feasibility Report ··
1981 Final Phase I Reports
Plan of Study
Plan of Study Revisions
Development Selection Report
1980 Annual Environmental Summary Report
Instream Flow Study Plan
Transmission Line Corridor Screening Report
Feasibility Report
1981 Final Phase I Reports
Plan of Study
Plan of Study Revisions
Development Selection Report
1980 Annual Environmental Summary Report
lnstream Flow Study Report
1980 Fish Ecology Annual Report
1980 Big Game Annual Report
1980 Birds and Non-Game Mammals Annual Report
1980 Furbearer Report
1980 Plant Ecology
Transmission Line Corridor Screening Report
Fish and Wildlife Mitigation Policy
Feasibility Report
1981 Final Phase 1 Reports
TABLE E.11.3: (Page 3)
U.S. Fish and Wildlife
Service
National Park Service
U.S. Bureau of Land
Management
Plan of Study
Plan of Study Revisions
Development Selection Report
1980 Annual Environmental Summary Report
Instream Flow Study Plan
1980 Fish Ecology Annual Report
1980 Big Game Annual Report
1980 Birds and Non-Game Mammals Annual Report
1980 Furbearer Report
1980 Plant Ecology Report
Transmission Line Corridor Screening Report
Fish and Wildlife Mitigation Policy
Feasibility Report
1981 Final Phase I Reports
Plan of Study
Plan of Study Revisions
Development Selection Report
Instream Flow Study ~lan
1980 Annual Environmental Summary Report
1980 Socioeconomic Annual Report .
1980 Cultural Resources Annual Report
1980 Recreation Annual Report
Transmission Line Corridor Screening Report
Feasibility Report
1981 Final Phase I Reports
Plan of Study
Plan of Study Revisions
Development Selection Report
Instream Flow Study Report
1980 Annual Environmental Summary Report
1980 Land Use Annual Report
Transmission Line Corridor Screening Report
Feasibility Report ·
1981 Final Phase 1 Reports
TABLE E.11.4: AGENCY COORDINATION EXPANDED LIST
Water Quality and Use Group
Mr. Max Brewer *
Office of the Director
Special Assistant for Alaska
U.S. Geological Survey
21B East Street
Anchorage, Alaska 99501
Mr. John Cook **
Acting Regional Director
Alaska Region
National Park Service
540 West Fifth Avenue
Anchorage, Alaska 99501
Mr. John Katz
Alaska Department of Natural Resources
Pouch M
Juneau, Alaska 99811
Mr. Robert 6ey *
Director, Alaska Region
National Marine Fisheries Service
NOAA
P.O. Box 1668
Juneau, Alaska 99802
Mr. Ernest W. Mueller *
Commissioner
Alaska Department of Environmental
Conservation
Pouch 0
Juneau, Alaska 99801
Colonel Lee Nunn
District Engineer
Alaska District
U.S. Army Corps of Engineers
P.O. Box 7002
Anchorage, Alaska 99510
Mr • John Rego
Bureau of Land Management
Anchorage District Office
4700 East 72nd Avenue
Anchorage, Alaska 99507
Mr. Keith Schreiner *
Regional Director, Region 7
U.S. Fish and Wildlife Service
1011 East Tudor Road
Anchorage, Alaska 99501
Mr. Ronald 0. Skoog *
Commissioner
State of Alaska Department of Fish & Game
Support Building
Juneau, Alaska 99801
cc: Mr. Larry Wright
Natignal Park Service
1011 East Tudor Road
Suite 297
Anchorage, Alaska 99503
cc: Mr. Alan Carson
Division of Natural Resources
Alaska Department of Natural
Pouch 7-005
Anchorage, Alaska 99510
cc: Mr. Ron Morris
Director
Anchorage Field Office
National Marine Fisheries
Service
701 C Street, Box 43
Anchorage, Alaska 99513
cc: Mr. Bob Martin
Alaska Department of
Environmental Conservation
437 East Street, 2nd Floor
Anchorage, Alaska 99501
cc: Mr. Lenny Carin
U.S. Fish and Wildlife Service
Western Alaska Ecological
Service
733 West 4th Avenue
Anchorage, Alaska 99501
cc: Mr. Thomas Trent
State of Alaska
Department of fish and Game
2207 Sp.enard Road
Anchorage, Alaska 99502
* Added at the suggestion of the Susitna Hydro Steering Committee.
**Added as a result of specific agency request.
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TABLE E.11.4: (Page 2)
Mr. John R. Spencer
Regional Administrator
Region X
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
cc: Ms. Judy Swartz
U.S. Environmental Protection
Agency
Mail Stop 443
Region X EPA
1200 South 6th Avenue
Seattle, Washington 98101
Fish, Wildlife, and Botanical Group
Mr. Max Brewer *
Office of the Director
Special. Assistant for Alaska
U.S. Geological Survey
218 East Street
Anchorage, Alaska 99501
Mr. John Katz
Alaska Department of Natural Resources
Pouch M
Juneau, Alaska 99811
Mr. Robert McVey
Director, Alaska Region
National Marine Fisheries Service
NOAA
P.O. Box 1668
Juneau, Alaska 99802
Mr. Ernest W. Mueller
Commissioner
Alaska Department of Environmental
Conservation
Pouch 0
Juneau, Alaska 99801
Mr • John Rego *
Bureau of Land Management
Anchorage District Office
4700 East 72nd Avenue
Anchorage, Alaska 99507
Mr. Keith Schreiner
Regional Director, Region 7
U.S. Fish and Wildlife Service
1011 East Tudor Road
Anchorage, Alaska 99503
cc: Mr. Alan Carson
Division of Natural Resources
Alaska Department of Natural
Pouch 10U5
Anchorage, Alaska 99510
cc: Mr. Ron Morris
Director
Anchorage Field Office
National Marine Fisheries
Service
701 C Street, Box 43
Anchorage, Alaska 99513
cc: Mr. Bob Martin
Alaska Department of
Environmental Conservation
437 East Street, 2nd Floor
Anchorage, Alaska 99501
cc: Mr. Robert Bowker
U.S. Fish and Wildlife Service
Western Alaska Ecological
Service
733 West 4th Avenue
Anchorage, Alaska 99501
Mr. Ronald 0. Skoog cc: Mr. Thomas Trent
Commissioner
State of Alaska Department of Fish and Game
Support Building
Juneau, Alaska 99801
State of Alaska
Department of Fish and Game
2207 Spenard Road
Anchorage, Alaska 99502
* Added at the suggestion of the Susitna Hydro Steering Committee.
TABLE E.11.4: (Page 3J
Mr. John Spencer *
Regional Administrator
cc: Ms. Judy Swartz
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
U.S. Environmental Protection
Agency
Mail Stop 44 3
Region X EPA
1200 Sixth Avenue
Seattle, Washington 98101
Historic and Archaeological Group
Mr. John Cook
Acting Regional Director
Alaska Region
National Park Service
540 West Fifth Avenue
Anchorage, Alaska 99501
Ms. Lee McAnerney
Department of Community and Regional Affairs
Pouch B
Juneau, Alaska 99811
Mr. John Rego *
Bureau of Land Management
Anchorage District Office
4700 East 72nd Avenue
Anchorage, Alaska 99507
Mr. Robert Shaw
State Historic Preservation Officer
Alaska Department of Natural Resources
Division of Parks
619 Warehouse Avenue, Suite 210
Anchorage, Alaska 99501
cc: Mr • Larry Wr·ight
National Park Service
1011 East Tudor Road
Suite 297
Anchorage, Alaska 99503
cc: Mr. Alan Carson
Division of Natural Resources
Alaska Department of Natural
Resources
Pouch 7-005
Anchorage, Alaska 99510
Mr. Ronald D. Skoog * cc: Mr. Thomas lrent
State of Alaska Commissioner
State of Alaska Department of Fish and Game
Support Building
Juneau, Alaska 99801
Mr. Lee Wyatt**
Planning Director
Matanuska-Susitna Borough
Box B
Palmer, Alaska 99645
Department of Fish and Game
2207 Spenard Road
Anchorage, Alaska 99502
Recreation Group
Mr. John Cook
Acting Regional Director
Alaska Region
National Park Service
540 West Fifth Avenue
Anchorage, Alaska 99501
cc: Mr. Larry Wright
National Park Service
1011 East Tudor Road
Suite 297
Anchorage, Alaska 99503
* A~ded at the suggestion of the Susitna Hydro Steering Committee.
**Added as a result of specific agency request.
-
-
-
TABLE E.11.4: (Page 4)
Mr. John Katz
Alaska Department of Natural Resources
Pouch M
Juneau, Alaska 99811
Mr. Robert McVey *
Director, Alaska Region
National Marine Fisheries Service
NOAA
P.O. Box 1668
Juneau, Alaska 99802
Mr. Keith Schreiner *
Regional Director, Region 7
U.S. Fish and Wildlife Service
1 011 East Tudor Road
Anchorage, Alaska 99503
cc: Mr. Alan Carson
Division of Natural Resources
Alaska Department of Natural
Resources
Pouch 7-005
Anchorage, Alaska 99510
cc: Mr. Ron Morris
Director
Anchorage Field Office
National Marine Fisheries
Service . ,
701 C Street, Box 43
Anchorage, Alaska 99513
Mr. Ronald 0. Skoog * cc: Mr. Thomas Trent
State of Alaska Commissioner
State of Alaska Department of Fish and Game
Support Building
Juneau, Alaska 99801
Mr. Lee Wyatt
Planning Director
Matanuska-Susitna Borough
Box B
Palmer, Alaska 99645
Department of Fish and Game
2207 Spenard Road
Anchorage, Alaska 99502.
Aesthetics and Land Use Group
Mr. Johri Cook **
Acting Regional Director
Alaska Region
National Park Service
540 West Fifth Avenue
Anchorage, Alaska 99501
Mr. Roy Huhndorf
President
Cook Inlet Region, Incorporated
P.O. Drawer 4N
AQchorage, Alaska 99509
Mr. John Katz
Alaska Department of Natural Resources
Pouch M
Juneau, Alaska 99811
Mr • John Rego
Bureau of Land Management
Anchorage District Office
4700 East 72nd Avenue
Anchorage, Alaska 99507
cc: Mr. Larry Wright
National Park Service
1011 East Tudor Road
Suite 297
Anchorage, Alaska 99503
cc: Mr. Alari Carson
Division of Natural Resources
Alaska Dep·artment of Natural
Resources
Pouch 7.o.005
Anchorage, Alaska 99510
* Added at the suggestion of the Susitna Hydro Steering Committee.
**Added as .the result of specific agency request.
TABLE E. 11 .4: (Page 5)
Mr. Keith Schreiner *
Regional Director, Region 7
U.S. Fish and Wildlife Service
1011 East Tudor Road
Anchorage, Alaska 99503
Mr. Ronald 0. Skoog * cc:
Commissioner
State of Alaska Department of Fish and Game
Support Building
Juneau, Alaska 99801
Mr. Lee Wyatt**
Planning Director
Matanuska-Susitna Borough
Box B
Palmer, Alaska 99645
Mr. Thomas Trent
State of Alaska
Department of Fish and Game
2207 Spenard Road
Anchorage, Alaska 99502
Socioeconomic Group*
Director of~nnlng
Fairbanks North Star Borough
520 5th Avenue
P.O. Box 1267
Fairbanks, Alaska 99701
Mr. Roy Huhndor f
President
Cook Inlet Region, Incorporated
P.O. Drawer 4N
Anchorage, Alaska 99509
Mr. John Katz
Alaska Department of Natural Resources
Pouch M
Juneau, Alaska 99811
Ms. Lee McAnerney
cc: Mr. Max Dolchak
Executive Director
Cook Inlet Native Association
670 Firewood Lane
Anchorage, Alaska 99502
cc: Mr. Alan Carson
Division of Natural Resources
Alaska Department of Natural
Resources
Pouch 7-005
Anchorage, Alaska 99510
Department of Community and Regional Affairs
Pouch B
Juneau, Alaska 99811
Mr. Michael Meehan
Director, Planning Department
Municipality of Anchorage
Pouch 6-650
Anchorage, Alaska 99502
Mr. Ronald 0. Skoog * cc:
Commissioner
State of Alaska Department of Fish and Game
Support Building
Juneau, Alaska 99801
Mr. Herb Smelcer, President
General Manager
AHTNA Corporation
Drawer G
Copper Center, Alaska 99573
Mr. Thomas Trent
State of Alaska
Department of Fish and Game
2207 Spenard Road
Anchorage, Alaska 99502
* Added at the suggestion of the Susitna Hydro Steering Committee.
**Added as a result of specific agency request.
-
--
!''""
-
TABLE E.11 .4: (Page 6)
Mr. lee Wyatt
Planning Director
Matanuska-Susitna Borough
Box B
Palmer, Alaska 99645
Geological and. Soils Group *
Mr. Max Brewer
Office of the Director
Special Assistant for Alaska
U.S. Geological Survey
218 East Street
Anchorage, Alaska 99501
Mr. John Katz
Alaska Department of Natural Resources
Pouch M
Juneau, Alaska 99811
Mr. David Haas
State-Federal Assistance Coordinator
State of Alaska
Office of the Governor
General
Division of Policy Development and Planning
Pouch AW
Juneau, Alaska 99811
Ms. Wendy Walt
Office of COastal Management
Division of Policy Development and Planning
Pouch AP
Juneau, Alaska 99811
cc: Mr. Alan Carson
Division of Natural Resources
Alaska Department of Natural
Pouch 7-005
Anchorage, Alaska 99510
* Added at the suggestion of the Susitna Hydro Steering Committee.
TABLE E.11.5: EXPANDED LIST OF REPORTS AND GROUPS TO WHICH
REPORTS WERE/WERE TO BE SENT
REPORT GROUP*
Instream Flo~ Study Plan
Draft Fishery Mitigation PIan
Draft Wildlife Mitigation Plan
Final Phase I Reports:
(a) Fish Ecology
(b) Wildlife Ecology
(c) Plant Ecology
(d) Birds and Non-Game Mammals
(e) Furbearers
(f) Land Use
(g) Socioeconomics
(h) Cultural Resources
(i) Recreation
Land Status Report
Interim Report on Seismic Studies
Final Report on Seismic Studies
Geotechnical Exploration Report on 1980 Studies
Geotechnical Exploration Report on 1981 Studies
Water Quality Report
Water Use Report
River Morphology
Sociocultural Report
Environmental Evaluation of Access Plans
Engineering Evaluation of Access Plans
*ALU
FWB
HA
WQ
R
SE
GS
G
= Aesthetics, Land Use
= Fish, Wildlife, and Botanical = Historic, Archaeological
= Water Quality
= Recreation
= Socioeconomic = Geology and Soils
= General
R, ALU
WQ, FWB, R, ALU
WQ, FWB, R, ALU
WQ, FWB, R
WQ, FWB, R
FWB, ALU
FWB, R
FWB, R, SE
ALL
FWB, R, ALU, SE, G
HA, SE
R
R, ALU, SE, GS
GS
GS
GS
GS
WQ, FWB,
WQ, FWB,
WQ, FWB,
FWB, HA,
WQ, FWB,
WQ, FWB,
R, ALU
R, ALU, SE
R, ALU, GS
R, ALU, SE
HA, R, ALU,
HA, R, ALU,
Note: These reports and groups ~ere added to those listed in Table 1.2.
Groups refer to those listed in Table 1.4.
SE, GS
SE, GS
-
'~
TABLE E.11.6: REPORTS, DATE SENT, AND. PURPOSE
PRIOR TO
DOCUMENT 03/15/82 03/15/82 04/01/82 04/15/82 04/30/82 PURPOSE*
Plan of Study X
Plan of Study -Revision 1 X
1980 Summary Environmental Report X
1980 Annual Environmental Reports:
(a) Fish Ecology X
(b) Plant Ecology X
(c) Big Game, Birds, and Non-Game X
Mammals, Furbearers
(d) Land Use X
(e) Socioeconomics X
(f) Cultural Resources X
Transmission Line Corridor Screening
~~t X
Development Selection Report X
Initial Fish and Wildlife Mitigation
Policy X
(Revised Mitigation Policy)
Instream Flow Study
Feasibility Report
Draft Fishery Mitigation Plan
Draft Wildlife Mitigation Plan
Phase I Environmental Reports:
(a) Fish Ecology -ADF&G
(b) Wildlife Ecology -ADF&G
(c) Plant Ecology
(d) Bird and Non-Game Mammals
(e) Furbearers
(f) Land Use
(g) Socioeconomics
(h) Cultural Resources
( i) Recreation ·
Land Status Report
Interim Report on Seismic Studies
Final Report on Seismic Studies
Geotechnical Exploration Report on
1980 Studies
Geotechnical Exploration Report
1981 Studies
Water Quality Report
Water Use Report
River Morphology Report
Sociocultural Report
Environmental Evaluation of
Access Plans
Access Route Selection Report
*FC : Formal Comments Requested
I : Provided for Information Only
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
FC
FC
I
I
I
I
I
I
I
FC
FC
FC
FC
FC
FC
FC
FC
I
I
I
I
I
I
I
I
FC
I
I
I
I
I
I
I
I
I
I
I
TABLE E.11.7: AGENCIES INVITED AND THOSE WHICH
DECLINED TO BE ON THE FISH AND
WILDLIFE MITIGATION REVIEW GROUP
State Agencies Status
Alaska Department of Fish and Game
Alaska Department of Natural Resources
Federal Agencies
U.S. fish and Wildlife Service
National Marine fisheries Service
U.S. Bureau of Land Management
Environmental Protection Agency
U.S. Geological Survey
U.S. Army Corps of Engineers
Agreed
Agreed
Agreed
Agreed
Agreed
Agreed
Declined
Declined
....
TABLE E.11.B: MEMBERS OF THE SUSITNA HYDROELECTRIC
PROJECT STEERING CGMMITTEE
State Agencies
Alaska Department of Fish and Game
Alaska Department of Natural Resources
Alaska Department of Commerce
Alaska Department of Environmental
Conservation
Other
Federal Agencies
U.S. Fish and Wildlife Service
U.S. Geology Survey
National Park Service
National Marine Fisheries Service
U.S. Bureau of Land Management
Environmental Protection Agency
Heritage Conservation and
Recreation Service
Arctic Environmental Information and Data Denter
Note: U.S. Army Corps of Engineers, Alaska Division of Policy Development and
Planning and Matanuska-Susitna Borough were invited but declined to sit
on the Steering Committee.
TABLE E.11.9: DATES AND PURPOSE OF STEERING COMMITTEE
MEETINGS WITH APA AND/OR ITS CONSULTANTS
DATE PURPOSE
June 12, 1980 Objective of Committee and Introduction
to Project
July 17, 1980 Federa I Energy Regulatory Commission and
State License Process, lnstream Flow
Studies
November 5, 1980 Evaluation of Alternatives to Susitna
April 13, 1981 Alternatives, Access Road Evaluation, and
Comments on Envlronmenta I Studies
October 20, 1981 Access Road Evaluation
December 2, 1981 Explanation of Agency Comments Requests
from APA
January 20, 1982 Environmental Studies and Concerns,
Fisheries Mitigation
June 14, 1982 lnstream Flow Studies, Access Road
Evaluation, Formalization of Steering
Committee role
November 4, 1982 Reorganization of Steering Committee,
Status of AEIOC Work and Discussion of
Land Use and Recreation
TABLE E.11.10: OBJECTIVES OF THESUSITNA HYDROELECTRIC
ENVIRONMENTAL WORKSHOP
SUSITNA HYDROELECTRIC PROJECT
FERC License Application Exhibit E Presentation and Discussion
Anchorage, Alaska
Hoi i day Inn
Objectives
November 29-December 2, 1982
1. Update federal, state, and local agencies regarding-significant changes in
project features s i nee the Feas I b i II ty Report was pub II shed In March 1982.
2. Use the presentations and discussions as an interactive process whereby
federal, state, and local agency review of the draft Exhibit E can be
facll itated.
3. Develop a mechanism for continued interaction as the finalized Exhibit E is
prepared for submission to FERC.
TABLE E.11.11: AGENDA OF THE SUSITNA HYDROELECTRIC PROJECT
ENVIRONMENTAL WORKSHOP
Monday, November 29 1:00 P.M.
Introduction
Project Operational Description
Watana Dam
Devil Canyon Dam
Access
Transmission
Schedule for Preparation of Exhibit E
Group Definition
Tuesday, November 30 9:00A.M.
Group 1 -Water Use and Quality and Fishery Resources
Group 2 -WI I d I i fe and Bot ani ca I Resources
Group 3 -Socioeconomic/Land Use
Group_ 4 -CuI tura I Resources
Wednesday, December 1 9:00 A.M.
Group 1 -Water Use and Quality and Fishery Resources
Group 2-Wildlife and Botanic~! Resources
Group 3 -Recreation and Aesthetics
Thursday, December 2 9:00 A.M.
Group -Water Use and Qua II ty and F r shery Resources
Group 2-Wildlife and Bot~nJcaJ Resources
-
-
Name
Michael P. Storonsky
Philip Hoover
Thomas lavender
Tony Burgess
Michael Grubb
Charlotte Thomas
Steve Fancy
Martha Raynolds
Robert Sener
Dave Tremont
Roland Shanks
Priscilla Lukens
Michele Urban
Tom Armlnskl
leonard Cor In
larry Moulton
Jean Baldridge
Keith Qulntavell
Robert Mohn
George Gleason
John Blzer •
Jack Robinson
Randy FaIrbanks
Gary lawley
George S. SmIth
E. James Dixon
B. Agnes Brown
Carole A. Ellerbee
Robert M. Erickson
Tim Smith
Richard Fleming
Bob Madison
Bob Lamke
Bob Martin
Don McKay
George Cunningham
Randy Cowart
AI Carson
Paul Janke
Gary Prokosch
Mary lu Har I e
Robin Hill
Peter Rogers
Steve Zrake
Jan Ha II
Gary Stackhouse
Brad Smith
B II I lawrence
Floyd Sharrock
Bruce Bedard
Ann Rappoport
Bob Everett
Er lc Myers
John Rego
Lee Adler
Bill Wilson
Chris Godfrey
Ted Rockwe I I
larry M. Wright
Kevin R. Young
John w. Hayden
Wayne Dyok
TABLE E.11.12: LIST OF ATTENDEES
SUSITNA HYDROELECTRIC PROJECT WORKSHOP
Hoi lday Inn, Anchorage, AK
Monday, November 29, 1982
Organization
Acres
Acres
Acres
Acres
Acres
Alaska Power Authority
LGL Alaska
LGL Alaska
LGL Alaska
Dept. Community Regional Affairs
Cook Inlet Region, Inc.
Acres
Harza/Ebasco
Alaska Power Authority
USFWS
Woodward-clyde
Woodward-c I yde
DNR -DLWM
Alaska Power Authority
Alaska Power Authority
Harza/Ebasco
Harza/Ebasco
Harza/Ebasco
Harza/Ebasco
University of AK Museum
University of AK Museum
Tyonek Native Corporation
Tyonek Native Corporation
EDAW, Inc.
DNR-Parks (History and Archaeology)
Alaska Power Authority
USGS""WRD
USGS-WRD
ADEC
ADF&G
ADF&G
ADNR-R&D
ADNR
ADNR
ANDR-Water
ANDR-Water Management
Frank Orth & Associates
Frank Orth & Associates
ADEC
USFWS
USFWS
NMFS
U.S. EPA
NPS
Alaska Power Authority
USFWS-WAES
ESSA ltd.
NAEC
BLM
AHTNA, Inc.
AEIDC
COE
USCE Reg. Fnctlon
NPS
Acres
Acres
Acres
Telephone
276-4888
n
n
n
716-853-7525
276-0001
479-2669
274-5714
274-5714
264-2206
274-8638
276-4888
277-1561
276-0001
271-4575
276-2335
276-2335
276-2653
276-0001
II
277-1561
n
" II
474-7818
" 272-4548
II
274-3036
264-2139
276-0001
271-4138
" 274-2533
267-2284
n
276-2653
276-2653
II
276-2653
II
206-455-3507
II
274-2533
263-3403
263-3475
271-5006
271-5083
271-4216
276-0001
271-4575
274-5714
276-4244
267-1273
822-3476
279-4523
552-4942
" 271-4236
716-853-7525
907-276-4888
907-276-4888
-
-
PUBLIC ,,.... -PARTICIPATION
PROGRAM
-ACTION RESPONSE
-NEWSLETTERS
r--PUBLIC MEETINGS
-WORKSHOPS
-
ALASKA
POWER
AUTHORITY
DIRECT
AGENCY CONTACT
I
FORMAL
AGENCY REVIEW
WRITTEN
CORRESPONDENCE
WITH AGENCIES
IDENTIFIED IN
FERC REGULATIONS
FISH AND WILDLIFE
MITIGATION
REVIEW GROUP
WRITTEN
CORRESPONDENCE
ON DRAFT
EXHIBIT E
ORGANIZATION OF
AGENCY CONSULTATION PROGRAM
AGENCY CONTACT
THROUGH
CONSULTANTS
_j
INFORMAL I--AGENCY REVIEW
SUSITNA HYDRO
STEERING -
COMMITTEE
ENVIRONMENTAL
WORKSHOP ;--
FIGURE E. II. I
STUDY
PHASES
MAIN
REVIEW
ITEMS
SCHEDULE
I
I
I
l
DEVELOPMENT
OF PLAN OF
STUDY
I
I ,
I
DATA COLLECTION
IMPACT PREDICTION
MITIGATION PLANNING
PROJECT PLANNING
,, I
FEASIBILITY REPORT
AND ASSOCIATED
SUPPORT
DOCUMENTS
I ,,
I
ADDITIONAL DATA COLLECTION
IMPACT PREDICTION
MITIGATION PLANNING
DRAFT FINAL
LICENSE LICENSE APPLI-
APPLICATION CATION
I
u I
I I PLAN
I OF
DEVELOPMENT
SELECTION
DOWNSTREAM
FLOW
RELEASE
FEASIBILITY I REPORT
LICENSE
APPLICATION
DECISION
REVISED
ACCESS
PLANS
DRAFT LICENSE
APPLICATION
AND WORKSHOP I . STUDY
I
I
I
I
I
I
PROCEDURE
MANUALS 1
I
I
I
I
I
, •• 0 1
,,
ACCESS
PLAN
1981
,, I
I
FISH I
AND
WILDLIFE I
MITIGATION
OPTIONS I
I
I
I
FEASIBILITY
SUPPORT
DOCUMENTS
AGENCY CONSULTATION
REVIEW PROCESS
,,
WILDLIFE
MODEL
1982
REVISED
DOWNSTREAM
FLOW
RELEASE
I
I LICENSE
APPLICATION
1983
FIGURE E.ll.2
APPENDIX EllA
CORRESPONDENCE RELATING TO
ORGANIZATION OF CONSULTATION PROGRAM
....
.....
-
--
-
APPENDIX ll.A
ORGANIZATION OF CONSULTATION PROGRAM
The Alaska Power Authority established a number of committees and interagency
groups to serve as a means of consulting with federal and state agencies.
This included the Susitna Hydro Steering Committee and the Fish and Wildlife
Mitigation Review Group. In addition~ reports concerning each of the major
subject divisions (water quality~ recreation, wildlife, etc.) were circulated
to the appropriate agencies responsible for these resources .
This appendix contains correspondence concerning the organization and estab-
lishment of the Susitna Hydro Steering Committee and correspondence relating
to the various agencies groups. The first set of letters address the Susitna
Hydro Steering Committee; the second the agency coordination program. Due to
the importance of mitigation as a
this subject is in Appendix ll.E.
individual reports is in Appendix
separate effort, correspondence concerning
Correspondence concerning comments on
11. C and G.
-
-
ALASKA Pm,IER AUTHORITY
The Honorable Lee McAnerney
Commissioner
Department of Community and
Regional Affairs
Pouch B
Juneaus Alaska 99311
Dear Corranissioner ~tcAnerney:
June 3, 1980
The Alaska Power Authority through fts consultant, Acres Aw.erican
Incorporated, is in the early stages of a 30-month feasibility study of the
proposed Susitna Hydroelectric Pro.ject. Because of the magnitude of this
study, effective interagency coordination will be best accomplished through
formation of a Susitna Hydroelectric Steering Committee. The function of
this colmlittee---YTould be to provide _coordinated exchanges of information
beb'leen the Alaska Power Authority and interested resource management agencies.
Through this exchange, the .concerns of all agencies involved~would be identified
early and hopefully prevent unnecessary delays in the progress of the feasi-
bility study. application for the Federal Energy Regulatory Commission license
to construct, and Environmental Impact Statement review.
As proposed, the Steering Committee would be composed of representatives
of resource agencies with responsibilities pertaining to the Susitna Hydro-
electric Feasibility Studies and/or the project's environmental consequences.
He therefore invite your agency's participation.
The committee would provide for 1nteragency coordination through joint
reviev1 of project related materials and development of mar~ informed and
uniform positions representing all resource interests. \Je believe this will
provide a more efficient process of infonnation exchange.
Proposed objectives for this committee are to:
1. Revie~ and comment on study approaches throughout each phase of the
planning process;
2. Insure that the biological and related environmental studies, their
timing, and technical adequacy are planned. implemented. and conducted
to provide the quantitative and qualitative data necessary to:
(a) assess the potential impacts to fish anrl wildlife resources, and
{b) provide the basis for mitigation and compensation of resource
losses which will result from the project;
Corrrniss ioner lee i-k:\ner.-·"y
June 3, 198£'1 "'·_;
Page T\>lo
3. Provide a forum for continued project revi ev: of all aspects of the
studies, for a timely exchange of information, and for recommendation of
study redirection, should the accomplishment of specific objectives be
in jeopardy;
4. ~tonitor compliance of the studies with all state and federal laws,
regulations, Executives Orders, and mandates as they apply to fish and
wildlife resources; and
5. Provide unified agency comn1ents from the committee to the Power Authority.
Should your agency elect to participate in the comnittee, we reco!11Tlend
that your representative have a technical background enabling him to comment
on the adequacy and approach of ongoing and future feasibility stud1est and
be able to speak knowledgeably on the policies and procedures of your agency
with respect to the review of the Federal Energy Regulatory Commission license
ap~licat1on for the project and the subsequent Environmental Statement (ES).
The first Susitna Hydroelectric Steering Committee m~et1ng \'1111 be held
at the Alaska Power Authority, 333 West 4th Avenue, Suite 31, Anchorage,
Alaska on June 12th at 9:00 AM. Attached 1s a sheet with a description of
the agenda for this first meeting. Your attendance is encouraged •
A ttachrnent:
as noted
•
Sincerely,
Eric P. Yould
Executive Director
-'
-
Preceding Letter Sent To:
Ms. Lee McAnerney
Department of Community and Regional
Affairs
Pouch B
Juneau, AK 99811
Mr. Harry Hulsing, Chief
U.S. Geological Survey
Water Resources Division
218 E Street
Anchorage, AK 99501
Colonel Lee Nunn
U.S. Army Corps of Engineers
P.O. Box 708
Anchorage, AK 99510
Mr. Bob Bowker
U.S. Fish and Wildlife Service
733 West 4th Avenue
Anchorage, AK 99501
l~r. John Rego
U.S. Bureau of Land Management
4700 East 72nd Avenue
Anchorage, AK 99507
Mr. Robert E. LeResche
Commission~r
Alaska Department of Natural
Resources
Pouch M
Juneau, AK 99811
Mr. Frances A. Ulmer, Director
Division of Policy Development
and Planning
Office of the Governor
Pouch AD
Juneau, AK 99811
Mr. Ronald 0. Skoog
Commissioner
Alaska Departnent of Fish and
Game
Juneau, AK 99801
AILASiiA PO\Vll~R AIJ'l'UORITY
SUSITNA HYDRO STEERING COMMITTEE
Bob Lamke
U. S. Geological Survey
Hater Resources
733 W. 4th Avenue, Suite 400
Anchorage, Alaska 99501
271-4138
John Rego
Bureau of Land Management
Anchorage District Office
4700 E. ?2nd Avenue
Anchorage, Alaska 99502
344-9661
Brad Smith
National Marine Fisheries Studies
701 "C" Street, Box 43
Anchorage, Alaska 99513
271-5006
William J. Wilson
Arctic Environmental Information &
Data Center, (U of A)
707 A Street
Anchorage, Alaska 99501
279-4523
Al Carson
State of Alaska
Department of Natural Resources
323 E. 4th Avenue
Anchorage, Alaska 99501
279-5577
Tom Tren.t
Alaska Department of Fish and Game
2207 Spenard Road
Anchorage, Alaska 99503
274-7583
Larry Wright
Heritage Conservation and
Recreation Service
lOll E. Tudor Road, Suite 297
Anchorage, Alaska 99503
276-1666
Lenny Corin
U. S. Fish and 1-Jildlife Service
733 W. 4th Avenue, Suite 101
Anchorage, Alaska 99501
271-4575
Gary Stackhouse
U. s.·Ftsh & Wildlife Service
lOll E. Tudor Road
Anchorage, Alaska 99501
276-3800
Bob t~arti n
Department of Environmental
Conservation
437 E Street
Anchorage, Alaska 99501
274-2533
Mr. Bill Lawrence
Anchorage Operations Office
Environmental Protection Agency
701 C Street
Anchorage, Alaska 99513
271-5083
Judy Schwarz
Environmental Evaluation Branch
Mail Stop 443
Region X, EPA
1200 6th Avenue
Seattle, Washington 98101
(206) 442-1285
SUS!Ti'lf\ HYDf<O STE[!{l:/C --------·----· ·--·--. -·-
T !l·\E: 9:00 Ai·1
Dfi1E: June 12, 1980
P Lt\C C: A 1 as ka Pa\·11:r ,~uthori ty
3.
'!.
333 West 4th Avenue, Suite 31
Anchorage, Alaska 99501
A discussion and out1ining of the purrose ilnd ol!j~ctivr~:. of the
Susitna"'Hydro Steering Committee.
/\ review by Acres An:erici:ln of the procedurz,l uspe<;ts of the rEf\C
license application, the ES r~view processes, and their pcrspccti~es
on the procedural mileposts for this project.
A discussion of the proposed FERC license application andES review
process by the Steering Committc:e and il!l assessment of the iHJencies
vie1·1s and mar~dates to reviev1 and co;:tment u;)on the ;Jroposcd rroject.
i\ rcviC\'1 of the S .. usitna Hydro fcilsibility tllsks by l<rcs t.r:1r~r-ican
with· discussion of FERC's possible rcquirrmc~ts for study, technical
stJ.ndards, and lal'd or envir-onmental stl:rly subjects vil:ich rnu::.t br~
cr:1pha s 1 red.
S. i\ discussion by the Steering Committee of the uoss study task or
i n t e r d i s c i p l i nary J. spec t s of the Sus it n a i !y d r o f cas i b i 1 it y ·: t u d i c s .
6. Steering Con'Jnittee discussion of a proposCd C1~jr:ndu for" thG July
meeting involving representatives of FERC.
-· \,.-... ,. -'
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. '
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'
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....
Mr. Ronald Morris
National r1arine Fishc:·y Service
701 "C" Street
Anchorag·, f1laska 99513
July 7, l9fl.O
P!iOIIC. ('lCi7) 277-76!. 1
(007) 276·27 i 5
The Alaska Pm.;er ."'.uU10rity, ,;cting c·n behillf o;· the rc:source
m;lnliJC~~ent agencies, ·.~ovld like to inform yo:J of the second ~usitn<3
Hydr·o Steering Committee meeting. 1\t the request of the vurious ogencics,
· .... e h2.ve n~ade anange::1ents for r-epresentatives of the Federal Energy
F< e 9 u 1 a to I' y Co n~m i s s i on to be pres en t a t the me e t i n g i n c r d e r to <J n s ... , r:: J'
t e c h n i c a 1 que s t ions . The s u b j e c t o f the f i r s t day o f t hi s t 1-10 day
session will consist of a discussion of the general technical aspects of
.the FERC and state licensing process whereas the second dny 1·1i 11 specificl!lly
address the Susitna fisheries and in-stream flow studies crograms. ,-.. ' .
In addition to the above topics, an election of a committee chairm2.n
will take place (please be thinking of prospective candidates for nomination),
and the guidelines for the committee's organization will be established.
i. I • ........
The first days session of. the second .Susitna Hydro Steering Committee
meeting ~ill be held at th~·AC~ Lucy Cuddy Ce~ter on July 17th at B~OO a.m.
The secorid day 1 s session ~111 tie held at the Federol Building, Room C-105
on July 18th at 8:30 a.m.~.Atti2h~d is·a sheet with a description of the
meeti.ng.~~enda. Your parti~i~~tion ~s ~ncouraged.
Sincerely,
L:_V\\d~
Eric r. Yould
Executive Director
l s t Oa v
Dote:
Time: 8:00 c..m.
Place: !ICC Lucy Cuddy Center
Da :e:
Time:
.July 18, lCJnJ
rl:lO a.m.
Place: Fcderill Guilrlina, R0 om r-10~
lc:.tDa;Topics
r, : 0 0 c1 • m . -9 : 3 0 a . 111 •
o Election of il committee chait·man
o Discussion of the committee's organization
o Anv ~ther items of concern
9:30a.m. -5:00p.m.
o General technical overview of FERC licensing process
o Discussion of general technical license requirements
for hyroelectric projects (both FERC and State)
a Discussion of Susitna specific technical license
requirements (both FERC and State)
2nJ ~ay Topics
R:30 a.m. -5:00p.m.
a Potential changes in Susitna i-:1ver hydrology due to
hydroe 1 ectr'i c development
o Details of hydrology-water quality monitoring pro~ram
a Details of the ADf&G fisheries program
o Development of fisheries impact predictions and mitig~tion
p 1 an ,
o Hodifications incoqJol-aced into the study pr·oqri\rll 1n order
to il c como d a t e the i n-s t rca m f 1 o \·1 s t u c1 i e s
a Discussion of details on in-stream flovt studies
-
....
-i
SUSITNA HYDRO STEERING COMMITTEE MEETING
July 17th & 18th, 1980
A 1 Carson
Bob Lamke
Bill Hilson
Bi 11 \·Jel ch
Pat Beckley
John Rego
Bob Bowker
Rickki Fowler
Gary Stackhouse
Lee l·/yatt
Jim Sweeney
Heinz Noonan
Dave Sturdevant
Dick Eakins
i·iu rray Wa 1 s h
Larry Kimball
PERSONS NOTIFIED OF THE MEETING
Department of Natural Resources
U.S.G.S. -W.R.D.
AEIDC-University of Alaska
Heritage Conservation & Rec.
BLM
BLM
U.S. Fish & Hildlife
tnvironmental Conservation
U.S. Fish & Wildlife Serviu
t1a t-Su Borough
Environmental Protection Agency (US)
Energy & Povter Development
Environmental Conservation
Div. of Economic Enterprise
(send twik via 277-1936~
Otfice of Coastal Management
Com.ni. & R~g. Affairs (D'iv. of Comm. Planmng)
279-5577
271-4138
279-4523
277-1666
344-9661
1344-9661
271-4575
27lf-5527
276-3800
7 45-4801
271-5083
276-0508
465-2636
465-2018
465-3540
279..:.863b
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Itt' A
rl!~. ~L Jar.1es sv .. eeney, Director
U.S. Environoental Protection
.~gency
Room E535, Federal Building
701 "C" Street
Anchorage, Alaska · 99501
Deur 1-lr. Sv1eeny:
Ju1y ')"J 1.-.u,_ 19DG
Thank you for your letter regardin(] the Susitna l!ydro Steering
Committee r:~eeting of July 17 and 18. I am sorry to hear you !,·Jere
unable to attend as it \tas a very informative m~etina. The Steering
Committee has, as a result of th~ meeting. evolved into an organization
independent of the Poto1er l\uthority and acting in a revie'IJ and advisory
capacity to the Power Authority. It is now run v;ho1 ly by the various
State and Federa1 agencies. tl.l Carson of the Alaska repart~mnt of
Natural Resources has taken the responsibility of chairman for the
co~Jittee and Ton Trent of the Alaska Department of Fish ~hd Game is
act·ing as his assistant. I \till see to it that your agency is retained
on the r,Jailing list for the committee. Unfortunately, no meeting minutes
were taken although a tape recording is avatlable at the Power Authority.
I appreciate your continued interest in the cosnittee and encourage
your participation at future meetings.
Sincerely,
Eric P. Ycul d
Executive DirGctor
-
-
. ,.ALASKA POWER AUTHORITY
Robert E. leResche, Comm1ss1oner
Alisi.a Departmen·t of Natural Resources
P.6uch'M (Mail Stop 1000)
Juneau, Alaska 99811
Dear Commissioner leResche:
January 2. 1981
··;,: •. 1:,'/our organ1zat1oo has been cooperating extensively with the Power Authority
in assess1ng:tha potential effects of hydroelectric development of the Upper Su-
sitna River'Bas1n~ ·.Several -different vehicles have been tJsed; meetings. corres~
poi\dence, ·a.~ Su"s1tna Hydroelectric Project Steering COOiTiittee activities. We .
feel that the results reflect close consultation and coordination between our or-
ganizations.
As the study has progressed, more and more items requiring consu1tation have
emerged, and the future w11l require a st111 hfgher level of 1nvolvement. This
ant1c1pated level of activity, plus the fact that the Federal Energy Regulatory
Ccmn1ss1on (FERC) and the Fish and Wildlife Coord1nation Act require documentation
of such consultations, suggests 1t 1s now appropriate to be more formal in our ex-
changes. Accordingly. we advance this suggested procedure to you for your concur-
rence and/or suggestions for modification. '·
~ .
In general, ~e propose a two step process. The first step will consist of
consultation w1th the Sus1tna Hydroelectric Project Steering Coom1ttee. ·That
body \Ifill perfonn evaluations and structure recoomendat1ons. The Power Authority
w111 consider these recoomendat1ons and fonnulate a p(>s1t1on. Upon complet1on of
these actions, the results w~ll be processed through your agency for formal con-
currence.
Th1s represents a sl1ght expans1on of the original concept under which the
Steering COOillittee was structured; the C001111ttee was to act pr1mar11y as an ad-
visory bol-, to the study team while secondarily facilitating agency 1nvolvement
1n the study effort. Member agencies were to be represented by senior staffers of
skills appropriate to the matters under cons1derat1on. This was cons1dered to be
advantageous as 1t would facilitate responsiveness by virtue of being relat1vely
independent of procedural 1111Ped1ments, while still reflecting to a substantial de-
gree the agencyviewpo1nt.
This proposal hopefully preserves those advantages within an expanded role by
permitting attainment of interagency concensus with a relatively low level of in-
put and a high degree of f1ex1bil1ty. It also penn1ts the various agencies to
tailor their participation to the specific needs. Finally, the second step of re-
ferral of Steering Comn1ttee deliberations for fonnal agency concurrence meets regu-
latory and statutory requirements.
Frar.ces A. U1mer. Director
Offfce of the Governor
Ofvbion of Policy Development and Planning
vouch AD (Hail Stop 01~4)
Juneau,.A1aska 99811
~nr Fran:
Januory 2, 1981
The Power Authority 1s stUdying and assessing the potential effects of hydro-
electric ci.eve1opmeilt of the UppPr Sus1tna River f3as1n. Accomp11shment of that
tasl<.. necessitat~s consult.a~1on and coordination •.;ith various Federal, State and 1o-
ca1 orga.nnations. 1nclud1na yours.
As. the study has progrjlllssed, more and more items requiring consultation nave
eDEt--ged. and the future wPl ~u1re a still higher level of involvement. This
am:1dpated 1·eve1 of act1v1tyt Plus the fact that tho Federal Energy Re-gulatory
Comfssion {FERC) and the Fish anti W11d1He Coordination Act requ1re documentation
of such consu1tat1oosl suggests ft h now appropriate to establiSh a fonnal p?a-
cedure for our contacts. Accordingly we advance the folimoting plan to you for
your concurrence and/or tuqgestlons for morlificat1on.
In general, we prop-ose a two nep nrocess. The first step ~~11 cons1st r:rf
consultation w1th the SusHna Hydtbei'cctt1c Project Staedng Cam11ttee. That
body w1l1 perform evaluations and stnidur~ recoomendat1ons. The Power Author1ty
will consider these rocoamendatHms and formi.llate a position. Upon completion f'lf
these act f ons 1 the results ~111 ba, prer.Msed through the nppropri ate organ1 zatf OM
for forma 1 concurrence~
I request yrrur ~•tten conr.urN!nce t11th th1s proposal, or. 1r you have other
thoughts on tha matter •. ~e are a,x jm.1s to explore them with you.
cc: 8111 Welch, U. S. HCRS
Larry Wright, 0. S. ,BCRS
J1m Thomson, U. S. HfiRs.
Sent to:
Sincerely,
.-··. \ ( I /. I ···-··--· ·-~-·' I .. t\
£r1c P. Yould '
Executive Director
Alaska Department of Community and Regional Affairs
Alaska De~artment of Co~nerce & Economic Development
Office of the Governor, Division of Policy Development and Planning
Matanuska-Susitna Borough
Environmental Protection ~gency, Region 10
Alaska District, Corps of Engineers
U. S. Geological SurVey
A tta.chme n t #2
CONCUR:
DW
R!l.M
EPY
~-
RESPONSE SUMMARY
Agency Respond? Comment
1\DC&RA Yes Abstain
ADC&ED Yes Concur .... DPOP Yes Suggest A-95 Procedures
EPA Yes Concur w/option preserved
COE Yes Does not wish to participa
USGS Yes Concur
MAT-SU No
AOF&G Yes Concur
ADEC Yes Concur
ADNR No
~MFS Yes Concur, w/option preserved
BLM Yes Concur, w/option preserved
HCRS Yes Concur
~,USFWj Yes Concur, vl/opti on preserved
-
Attachment #3
United States Department of the Interior
tN REPLY REFER TO:
Eric P. Yould
FISH AND WJLDLII·E SLRV!CI:
Western Alaska Ecological Services
733 W. 4th Avenue, Suite 101
Anchorage, Alaska 99501
(907) 271-4575
Executive Director
Alaska Power Authority
333 W. 4th, Suite 31
Anchorage, Alaska 99501
Dear Me Yould:
t l If
flECEIVEO
AU\SKA POWER AUTHOR!~ '
The U.S. Fish and Wildlife Service (FWS) has received your letter of
2 January 1981 proposing that the agencies comprising the Susitna Hydro-
electric Steering Committee provide formal concurrence to positions
developed by t~e Alaska Power Authority (APA) in response to committee
recommendations. We concur with your proposal. However, in the event
that we disagree wtth APA's position, we reserve the option of providing
a formal response indicating what is required for fi.l'S concurrence.
Sincerely,
Field Supervisor
cc: ACES
IH~I'.'\U.'f,U::\1' 01·' lciSII :\~U (~.\ :UI·: / I
OFFICE OF THE COMMISSIONER /
JAYS. HAMMOND, GOVERNOR
I
SUBPORT BUILDING
JUNEAU. ALASKA 99801
January 22, 1981 p.E,CE.IVE.O
Mr. Eric P. Yould, Executive Director
Alaska Power Authority
333 West 4th Avenue
Suite 31
Anchorage, Alaska 99501
Dear Mr. Yould:
1; 1981
·The Alaska Department of Fish and Game has considered your January 2
proposal for an agency consultation process by th~ Abska Power Authority
(APA) through the Susitna Hydro Steerin!!, Committf~e. The process for
evaluation and recommendation by stnff of this <-'gency, and the form~1l
agency concurrence action of APA's developed p0sition is acceptable to
this Department.
I suggest APA work further with the Steering Committee .to finalize the
details of the implementation of your ptopos~d coordination/consultation
process at their next meeting. The. S teerit'g Con~mit tee should be able to
do much in the future to eliminate duplication of coordination and
consultation effort, on both our parts, for the Susitna Hydroelectric
ProjeCt.
SincQ:·~
Ronald 0. Skoog
Commissioner
(907) 465-4100
cc: A. Carson
UNITED STATES
DEPARTMENT OF THE INTERIOR
GEOLOGICAL SURVEY
Water Resources Division
733 West Fourth Avenue, Suite 400
Anchorage, Alaska 99501
January 26, 1981
E ri c P. You l d
Executive Director
Alaska Power Authority '' .. 333 West Fourth Avenue, Suite 31
Anchorage, Alaska 99501
Dear Eric:
/ -· ..
We concur with the b1o-step process of interagency consultation and
coordination in studying the potential effects of the proposed hydro-
power Gevelopment of the upper Susitna River basin outlined in your
letter of January 2, 1981.
The Water 'Resources Di vision has no regula tory functions, so forma 1
concurrence with your agencies actions is not within our field of
authority. However, we can assist in advisory capacities. The Geologic
Division expertise may also be available for consultation. The Conservation
Division is the only Geological Survey division with regt.latory authority
and they have a section that handles hydropower developments.
Sincerely yours,
,,.,.
-·
-
-
Unued States Department of the Interior
BUREAU OF LAND MANAGEMENT
Anchorage District Office
4700 East 72nd Avenue
Anchorage, Alaska 99507
Hr. Eric Yould
Alaska Power Authority
333 West 4th Ave., Suite 31
Anchorage, Alaska 99504
Dear Mr. Yould:
HECL:IVED
I ~· .·.~ 2 1981
2920 {01))
JAN 3 0 1981'
This is in reply to your letter dated January 2, I9Rl, questioning the
official nature of the suggestions given during meetings with the Susitna
Hydroelectric Project Steering Committee.
All statements made at these meetings 1~ith the Steering Committee arc at a
working level and are not to be construed as fiLM's official stand or
policy.
All official Bureau policy and positions concerning the Susitna Project
will originate from this office in wdti.ng with my signature or the signa-
tur~ of an acting District Manager.
p
Richard W. Tindall
District Manager
'DEPARTMENT OF THE A~,.v1Y
REPLY TO
ATTENTION OF,
NPAEN -P L-EN
Mr. Eric P. You 1 d
Executive Director
Alaska Power Authority
ALASKA DISTRICT, CORPS OF ENGINEERS
P.O. BOX 7002
ANCHORAGE. ALASKA 99510
REGE\\/ED
F FJ3 4 1981
Ow 'R AUlr\ORITY NJ-.SKA r r.
333 West 4th Avenue Suite 31
Anchorage, Alaska 99501
Y'c..
Dear ~0"uld:
This is in res!X)nse to your letter of 2 .January 1981 concerning
consultation wifh the Corps of Engineers on your stud~of the Upper
Susitna River Basin.
FEB OG1981
As stated in our letter to you of 12 June 1980, we are unable to
participate in the Susitna Hydroelectric Project Steering Committee
because of funding and manpower constraints, and 1ve vJi1l only be able to
conduct the necessary reviews required for the issuance of permits under
our regulatory program.
I would suggest that the seeping process prescribed in the regulations of
the Council.on Environmental Quality (see 40 CFR 1501.7) be initiated.
This process, which would involve the Federal Energy Regulatory
Commission (FERC}, would help to define the scope of issues to be
addressed and to identify the sig1ificant issues to be analyzed in depth
in the Environmental Impact Statement (EIS). The Corps could p()rticipate
in the scoping process and, possibly, become a cooperating agency with
FERC in the preparation of the EIS.
If further details are desired by your staff, Mr. Harlan Moore, Chief,
Engineering Division, can be contacted at 752-5135.
LEER. NUNN
Colonel, Corps of Engineers
District EnginP.er
l~ ~~ed Slates Department of~ tlle Intenor
I-IERITAC.E CONSERVATION AND RECREATION SERVICE
. ALASKA AREA OFFICE
1011 E. Tudor, Suite 297 Anchorage, :\Iasko '19503
lN REPLV REFER TO:
A800
1201-03a RP
Mr. Eric P. Yould
Executive Director
Alaska Power Authority
333 West 4th Avenue, Suite 31
Anchorage, Alaska 99501
Dear Mr. Yould:
Tde.('l07) ?.77-1666
FEB 4 1981
RECEIVED
; c 8 6 19 81
J..LASY:A POVIER t\UTHORITY
\~e concur with vour recommendation of January 2, 1981, concerning the
expanded role of the Susistna Hydroelectic Project Steering Committee.
However, we .would remind you that we also have .1. separate coordination
and review function associated with the license application Exhibit R.
Thank you for the opportunity to consider and conunent on the proposal.
Sincerely,
/·ri 11 <I -/ /; c /~, t:.-.;
· J .. ~ne t HcCabe
Regional Director
U. S. E ~ _-· · .... 0 N M E NT A L P R 0 T E C T I C. . : < G E N C Y
REGION X
1200 SIXTH AVENUE
R E c UIAirfi. D: . w A s H I N G T 0 N 9 8 1 0 1
k' f'l
REPtYTO ,., .. r.~'-· .. p()\-\'~.-:.:.,.-;:-~J·••J
A. !TN Of: M/ s 443 ,,._·.~·".
FEB 0 5 1981
Eric P. Yould, Executive Director
Alaska Power Authority
333 West 4 Avenue, Suite 31
Anchorage, A1aska 99501
Suoject: Sus1tna Hydroelectric Project Coordination Procedures
Dear Mr. Youle1:
Tnank you for your letter proposing a two-step process tor the coordina-
tion required under the Federal Energy Regulatory Commission regu1at10ns
and the Fish and Wildlife Coordination Act. We basically concur with
your proposals. However, we may have further comments on the issues
dealt lvith in this coordination process once more intormation on each
subject is available and the comoined etfects of tne project become more
visible.
lt is our understanding that so far the Susitna Hydroelectric Project
Steering Committee has worked on the procedures manual for the 1981 f1elo
studies and is now in the process of starting up a subcommittee to deal
with possible mitigation for wildlife impacts. Other issues, 1ncluding
possible m1tigation for fisheries 1mpacts, are to be deait with later
when more information on tne resources to be affected w1ll De available.
We would like to be kept informed of both the steering comm1ttee and
subcorrunittee meet1ngs and agendas so that we can participate more
actively when items affecting tPA's areas of responsibility or expertise
wil I be considered. For now, most of our involvement will have to oe by
letter and teiepnone due to personnel and travel constra1nts. With1n our
limitations, we win try to be as responsive and nelpfui as possibie.
~PAis coordinator for this project wil I continue to be Judi Schwarz, of
my staff. She can be reached at (2u6) 442-l2H5.
We look forward to working with you in the future. It we can be of
assistance, please do not hesitate to ask.
Sincerely yours,
fls._l0i f!)dy--
Ellzabeth Corbyn, Chief
Environmental Evaluation tiranch
'''""
-
Mr. Eric P. Yould
Executive Director
Alaska Power Authority
333 Wes+ 4th Ave. Suite 31
Anchorag~, Alaska 99501
Dear Mr. Yould:
U.S. DEPARTMEiV. -.." COMMERCE
National Ocaanic l.. . .i At:mosphoric Admlnlatratlan
NationaL Ma~ine Fisheries Se~ice
P. 0. Box 1668, JuneauJ ALaska 99802
lll~CL:JVED
i [. '·) l () 1981
We have received your letter of January 2, 1981, regarding the
involvement of the National Marine Fisheries Service (NMFS) in the
planning and study of the proposed Susitna RiVer Hydroelectric Project.
We recognize the need for a "higher level of involvement" on .. the
part of our agency, not only due to certain procedural requirements
but the fact that the proposal has reached a more advanced stage of
study. To this end we have been participating as a member of the
Steering Co11111ittee since July, 1980. We feel this involvement
affords us the opportunity to evaluate project studies and provide
any input we may feel is necessary. ·
Regardless of our status with the Steering Committee, we feel formal
agency concurrence with all policy matters and deliberations should
be obtained and therefore, agree with the process you have suggested.
Sincerely~~ /..--, ~~:~~tZ!Y
DIVISION OF POLICY DEVELOPMENT AND PLANNING
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JAY S. HAMMOND, Governor
POUCH AD
JUNEAU. ALASKA 99811
PHONE: 465-3573
February 19, 1981
~1r. Eric Yould
Executive Director
Alaska Power Authority
333 West Fourth Avenue
Suite 31
Anchorage, Alaska 99501
Dear Eric:
··•g2c··,19B1 ,. [. ,• --
On January 3, you sent a letter referring to consultation and coordination
with various federal, State and local organizations in the study and assess-
ment of potentia 1 effects of hydroe 1 ect ric deve 1 opment in the Upper Sus itna
River Basin. Your letter requested my concurrence with your plan or
suggestions for its improvement.
Frankly Eric, the paragraph in your letter that describes your plan is
somewhat brief and general, making concurrence rather difficult at this time.
I agree, however, that the study being undertaken is one that should have
a very high level of involvement by interested State and federal agencies as
wel1 as potentia1ly affected local communities.
I suggest that a more detailed description of the workings of the Susitna
Hydroelectric Project Steering Committee be provided. \~hat may also be
appropriate is the use of your public participation staff to serve a state
government coordination as well as a public involvement function. The
staff could document and disseminate the proceedings of the steering
committee to a wider governmental audience. Such communication could occur
prior to formal Authority position formulation and smooth the process of
required formal concurrence with such positions.
As for meaningful involvement of State and federal agencies in your assessment,
I am enclosing a copy of Administrative Order No. 55, describing the Major
Project Review (MPR) process. This process might be appropriate for the
Steering Corrmittee. The process described can be used by any unit of State
government and is designed to ensure that a~propriate State agencies are
involved in analyses from the outset and that each assessment is highly
issue oriented. The technique can be used to involve federal agencies and
the public as well.
-
Mr. Eric Yould -2-Februaty 19, 1981
The MPR questions can be modified as needed and a schedule can be prepared
that indicates points at which cooperators are to tie in to the process. We
generally include a public review draft in the time line for an analysis.
We have also found that it is essential to the success of the MPR process for
the lead unit to be able to sufficiently detach itself from its own project
goals and objectives to administer the analysis in a neutral and objective
fashion. One solution is, of course, to have the analysis administered by a
separate agency.
Eric, I hope that at least some of these ideas are Dseful tci you. From your
letter, we are not too certain as to vJhat involvement process you had in mind.
Please let me know if we can be of any assistance.
Sincerely,
Frances /\. Ulmer
Enc1osure
S tc. "L <: of A l a s );.z -~~=~nistrative Order No.
SL!bjecL:
\];Jeer ;:he autho:::i-cy of Art. II::., Sectio::s l c.;Jd 26 o:f t~:e /.lc.sL:. Cor:sti-
'Lu"Lion, and AS 4Cl9.880, c.nc f;i·v-en L.he need ~o:-tillely, cor;sist.er:t, and
L.horough evaluation of proposed ~ajar projects or ac~ivities, I order·
that L.t. follouing revie~ process be ins'Li'LuL.ed:
l. Certain projecL.s, because of their srate~ide br regional significance
'-'ill be ciesig::1c:ted by me a.s wajor projec:.s subject ::o c. l:Cjc;:-Project
Revie'-'.
2. .t.n;' st.ate .:ogene;• to 1..."nic;1 I assig:~ :;•e le.:od rE:S?Dilsibili:y for
conducting:=. >~cjor ?reject Revie·~ooo.~ sf-~c.~l pre?c.re 2nC subwit to De
-.:'le info~c.'Lio::1 conL.c.ine.C: on the ?:-ojE:ct .!,ric.lvsis Su:::::.c:r;· Shee'L
(.!,::L.achrnent ;._) 1..."ithin 10 cays of 'L.r'E: assig;;::;eil"L.
~-3y the assigned date, Ihe lead agency shall ~'enare and sub::.it L.o
me a prelir.,in.:or-y ?c-o_iect Analvsi.s ·._··::ic~: acC:::t::.'ses :·ne e·;c:luc:Iion
fac:ors specifieci by ~e (~ttact~en: 3)
~. l~~~cii~tely upon receip~ u• thE ~reli~i~2~y ?ro~ect ~nc:}vsis, the
Division of ?olicy Deve1o?~ent an~ ?l2nning (u~D?), Offic~ of the
Go\'ernor, sh.:.ll fo:-~·c.rc i;-,fo:::-::c.L.io;-,c.l ccj:-::.es to eac;-; 2ffecLed or
-' .
interested go'":E:-!1;ll€7:Lcl c:~enc;· . .c-.· :.f~c c.ss~g:~ec C:c.Les c2.c:-1 cger~cy
shall sub~i: to DPD? its revie~ znc cc~5ent.
During t.he period of age:~cy revie~ of ~he prelimiilc.ry ?roiec'L
.~.nc.l,•sis, l.ne Public ?o;:-ui'J o:-DPJ?, in cc;:su~cr.:ion '-'lt·n -..'ne lead
agency, shall conduct one or ~~re public ~ee~~ngs in thE: affected
c.rea(s) :for 'L:'ie purpose of receiviT'g public cc::-:oE:L;ts on Ihe project
or c.cL.ions.
6. By the assigned dc.te, D?DP shc.ll sub:::it in '-"7iting, -.:o the lead
2gency, a suw,;nar;·. of the revie;.: along. ·~·it~r"J reco;::;2enca-cior.s for rhe
final Proiect Analvsis.
'· 3;•. the 2ssigne"d dc.re, the lec:c ageo:cy, J.:-,.conjuOJc'Lio:-. ·~-.:.o:.n D?DP,
shall prepzre a";'lG subr.,it to me:, in ·--z:-i-cir:g c:1G verbc:1ly, a finc.l
version of ·'Lh~ ?reject .!.ncl,·sis. Tne ?roiect A:;c:lysis s;-,all inclurie
dissen'Ling vie~s. reco~~eil~C.'Lio~s ~or further actio~ anci, ~nere
c.ppropriate specific ~onC:iL.ion~ or ~irigc:L.ion measures necessary
for state ap?roval of L.he project or c:cL.ion.
S. No designa'Led ~.:ojor project or action vill be approved prior to ~he
CO:i:pletion of the p-;-oceSS cescriDcG c'::Jove, u'iiless 2. ?ricr ·~~itt€';').
~aiver of necessity has been obtzir:ed from me.
9. tne revie~ specified ~n this cr~er ~~all be coordinated ~ith proce-
dures co:JL.ai:-reri in .!.S !;6.~5. :.:1\'i'D:-:.::-·e:-.tal ?'oceC-u:ce Coo:-dinc:L.ion
Actr and ot~er so:.aL.e revie~ proce~ses, c.s 2?plicable.
-1-
10.
ll . Tnis c:-cer sn.:oll tc:i:e e.: f e.c-c
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.....
De~cric:tion
3riei description
~ncluci~£ locEtio~
'='-=' n "7 :-r"'-;--.. •.....,...;-'"""" ~
c£ scope, nc.rure, c.nd
of project~ esti=cteC
oGjr2c::ive~
s:c.rt c.~;c
o;: ;):Cojec.
cc::-,:J~<:otion
es-.:i::c.ted cost of ?reject., stc.t.e i11terest ir; :;:roje:c::..
Src.te Action Recuesred/Recuireci
? 2 :-::-.:. : s s o u g h L I w y c. g e :-1 c y ; r e s o "J :: c e s
co~srructed; Rinerzl or other ri~hrs,
Lec.6 ~~ency responslbility
?reject ~nc.lysis.
A~e~cv ?c.r:icicatic~
c c~ :-: c. c:. s ,
o;: c.ct::..cn,
cc.::e,
:.o be
D:~e: agencies c.nd individuals c.ssisned to :he ?:o~e:::t c.na~ysis e!for:
an:: their responsibilities. ?reposed cont:c.ctua! asslsta~ce.
?reli~inc.ry Project A~c.lysis -----( Gcys c:-:: Go"'~e :-ncr I cs.s:igr-!Dent --)
Agency and ?~blic Revie~ ( cc.ys -' c:c. v-el :i.22. ~;C 'Z~~~ ?roj e ::c. J;_Lj 2 ~ --------S~.e;:-,;:-,c.ry Repent: -----------------------------( c c;· s -!"C ?.gency C:.ltd ?:Jblic Revi e:..
~i~c.l ?rojec~ Analysis ( GCY s -----------------I!" G:": Sll::~c. ""ZY ?,E:J 0 rt)
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1.
2.
Prciect Ev2lu~~~on ~~ctors
Whet ch~nges would be l I ~
income for current resident Al~sk~ns over life or the project
(construction and operetionel pheses)?
. ' c~~nces expected to
result from the project?
c.. Whc.t proportion of jobs 2re exp~c~ec ~o ~E occupied by
current Alc.skc.ns?
Does the project contribut~ to 1cn£-run econc~1c s~ebility?
Whet ~hart or long-term pr1ce
7rom the project?
roc.cibl od:s
c..:=.:,..,,...,;..c:
-lit:"\...~-·
economic 7easibility of 2 project?
to result
c.ffecL.
CcT:T:·.mitv \·!e1·1-3eino
Hhct chcnges are expected in ti:e c;"Jc.i~:_y, 2vc.ilc.bil"ity: or
dem2nd for govern~~ntc.l goods, s~rvices or fecilities?
..
iJ:'"1CE, ~uc.lity)?
3. l·.'h.:: t icc.:: l populetion changes ,_ c \ ;:: . ..: . )
.__,..,.. ... c ...... ,. -..:.c' ,;. -··c::. c ·r-. .-:.~-·r;...-~ ~;:."'/''~ ,...,r .. 1.:.-=cc...:..,,"),.... c,,c.o~;;::-;:,.,p::c.__a ,o Cc.~~-_I::'"' 'w-''" \_ '--...... "--~_,,-:: conn icts
ordin.:nc:~.s. reven~~-gener2~~~g
proposed project?
Fisce.1
1 . \·,! h 2 t e 7 f E c t \·:o u i d t h e pro j e c t n c v e :::; n t he r::: :: b =. l c. n c e o f s t c. t e
the pr-cject?
effect
or other resource vc.1uts? r::su1: in irreversibl~
2. ~ill the croject .:ffect fish 2nd wi~dlife D~JulE~ions or their
h.:bit.:t? Will these effects b2 short-term cr ldng-ter@ in nature7
W~ll the project subsistence reso~rc::s?
chc.nges in rnigr2tion p~tterns. less o~ spec1es. dislocation, or
~vc.il2bility changes expected?
4. ~ill the project affect designated or soecif~c2lly defined wilderr
historic, wc.tershed, recre2tion~1 cr ~cenic 2re2s?
1 ~hat are the 2nticip.:ted effects of :he prcject on the enviro~~en~
hea1~h or safety of
2nd qu2lity contro1?
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1.· 'loes the project invoive techn:)1o_oicc:·i, envi rc;-.:~,=-n7;:'1 , -· • 1 ---7irrc!'!Clc,,
·or economic fc.ctors which h~ve·~ hir_~h dE~r~c-c: ··~cc-~-~ · --' "·'' -· '-:::n:y or risk
2. To 1\'hC.t extent is the existino_• dc.~c-kc·se c·r_::=qu;:-7-c: " -------t.O c ns.,.,·er the
above questions?
3. Are there external factors (e.g.~ nation~l or internation~l)
which fig~re prominently in the success or fc.ilure of the prbject?.
1. Are there econornic2lly feasible and sociclly c.cceptc.ble
~ltern2tives for accomplishing the c~ject~ves of the project?
2. be the implications of
l. 1 s the proposed project or action cc~pc.tible with l 0~~ l
plz:ns or policies?
2. What permits, licenses 2nd/or government::.! (stet~, 1occ.i c.nd/or
federal) ~pprovels are necessary?
3. What is the timetable for various stc:ges of the project? How
'flexible is this schedule?
4. ~hat mitigation m!!Sur~s or stipul~tions c~n be ide~tified to
mini~ize the confllcts or prcblE~s ide~tified ab~ve?
~~&U~ @~ ~~~~~t~ I ~YS.HAMMOND.GOVERNOR
Ot:PT. 01;-I~N\'IUON :UJ<~NTt\1~ CONSI~&l\',\'I'ION /
Mr. Eric P. Yould
Executive Director
Alaska Power Authority
333 West 4th Avenue, Suite 31
Anchorage, Alaska 99501
Dear Mr. Yould:
j' ;. ') . \ ·. J-0---
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I POUCH 0 -JUNEAU !1!1811
Harch 2, 1981
Your letter of January 2, 1981 proposes to expand the function
of the Susitna Steering Committee from that af an advisory
body to the study team to one of performing evaluations and
structuring recommendations. I am happy to offer the resources
of this agency to serve in that capacity to a reasonable
extent.
It is not clear to us, however, precisely what may constitute
"items requiring consultation," as the only substantive
matters to come before the Steering Committee have been
review of the field procedures manuals regarding Task 7 of
the Plan of Study, and review of the preliminary screening
of poten~ial hydro sites. Apparently, a more direct link
with the Power Authority is anticipated, rather than simply
with the study team, since your letter indicates that Steering
Committee recommendations will be considered by the Power
Authority. We will look forward to additional information,
at an appropriate time, concerning matters that may be
brought before the Steering Committee, and the action requested
of the committee.
Bob Martin will be the representative of this agency to the
Steering Committee as of this date. Bob is the new supervisor
of ADEC's Southcentral Regional Office.· Bob will receive
whatever support he needs from Dave _§.t!J~<:l-~ant, who has been
our representative in the past al)dWho will"{:;-sntinue as
Bob's alternate. \ '\
~·
£/-t~-----~ Vj_.~/-·
cc: Deena Henkins, EQM.
Bob Martin, SCRO
_.../'"'··Ei~..§_L_rL--M {i'e 11 e r
Commissioner
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Dl VISION OF RESEARCH &DEVELOPMENT
June 5, 1981
Eric Yould
Executive Director
Alaska Power Authority
333 W. 4th Avenue, Suite 31
Anchorage, AK 99501
Dear M.r. Yould:
JAr S. HAIIIIOND, SDY£11101
323 E. 4TH A VENUE
ANCHORAGE, ALASKA 99501
279-5577 JH:CEIVED
JUN-9 1981
"A/,ASY.A POWER AUl.'iORITY
The purpose of this letter is to transmit to you a proposed revision
in your June 3. 1980 letter stating the role and objectives of the
Susitna Hydro Steering Committee. The Steering Committee members feel
the following more accurately describes the role and function of the
Comrni t tee.
"The Alaska Power Authority through its consultant, Acres American
Incorporated, is carrying out a 30-month feasibility study of the
proposed Susitna Hydroelectric Project. Because of the magnitude of
this study, effective interagency coordination will be best accom-
plished through formation of a Sus-itna Hydroelectric Steering Committee.
The function of this committee would be to provide coordinated exchanges
of information between the Alaska Power Authority and interested
resource management agencies. Through this exchange, the concerns of
all agencies involved would be identified early and hopefully prevent
unnecessary delays in the progress of these feasibility study, appli-
cation for the Federal Energy Regulatory Commission license to construct,
and Environmental Impact Statement review.
As proposed, the Steering Committee would be composed of representatives
of resource agencies with responsibilities pertaining to the Susitna
Hydroelectric Feasibility Studies and/or the project's environmental
consequences. We therefore invite your agency's participation.
The committee would provide for interagency coordination through joint
review of project related materials and development of more informed
and uniform positions representing all resource interests. We believe
this will provide a more efficient process of information exchange.
Proposed objectives for this committee are to:
1. Review and comment on study approaches throughout each phase of
the planning process;
Eric Yould 2 J£ 5, 1981
2. Provide a forum for continued project review of all aspects of
the studies, for a timely exchange of information, and for recom-
mendation of study redirection, should the accomplishment of
specific objectives be in jeopardy;
3. Comment on compliance of the studies with state and federal laws,
regulations, Executives Orders, and mandates as they apply to
fish and wildlife resources; and
4. Provide unified steering committee comments to the Power Authority.
Should your agency elect to participate in the committtee, we recommend
that your representative have a technical background enabling him to
comment on the adequacy and approach of ongoing and future feasibility
studies, and be able to speak knowledgeably on the policies and procedures
of your agency with respect to the review of the Federal Energy Regulatory
Commission license application for the project and the subsequent
Envirorunental Statement (ES)."
If you have comments or suggestions concerning these proposed revisions,
please advise.
Sincerely,
~~
Al Carson
Chairman
Susitna Hydro Steering Committee
cc: Steering Committee
r---:-
ALASKA POWER AUTII()RITY
334 WEST 5th AVENUE-ANCHORAGE, ALASKA 99501 Phone: (907) 277-7641
(907) 276-0001
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ALASKA POWER
AUTKORITY
SUSHNA
I FILE ·p5700
F""" • tl
SEQUENCE NO.
F. d/15" ..
Mr. Al carson
Alaska Depar1:1rent of
Natural Resources
Research and Develq::rrent
555 Cordova
Anchorage, Alaska 99501
Dear Al:
December 10, 1981
R£CEiVED
DEC 14 1981
ACil .. ., ....... muM mlitutrORATED
In lc;te November, 1981 you approached rre with sane concerns
relative our on-going effort to solicit formal coordination on various
aspects of the Susitna Hydroelectric Project. This led to a series of
neetings between ourselves and the Susitna Hydroelectric Project ·
Steering Carrnittee. To broadly surcmarize those events:
1. Acres Arcerican Incorp::>rated, acting for the Po.ver Authority,
has carrrenced circulation for formal coordination certain
building blocks of the studies that will form the basis for a
project licensing reccmrendation.
2. In rrost instances the agency heads (addressees of the fonnal
requests for coordination) referred the request to staff for
analysis. Alrrost without exception the staff involved also
had been serving on the Susitna Hydroelectric Project Steering
Ccmnittee. Largely due to this relationship, the individual
agency staff rrernbers elected to use the Steering Corrrnittee
structure as a vehicle to discuss their formal coordination
concerns. As a result of rnul tiple interactions between the
Steering Ccmnittee and the Fewer Authority, a number of issues
have been clarified and options for agency resJ?Onse to the
Acres request for formal coordination have been identified.
The Steering Committee has summarized its concerns as follows:
1. In sane cases, the docurrentation of field study results is not
available coincident with the request for agency comment an
aspects of the project.
2. There has been no decision made yet by the PONer J.mthority,
the State legislature and the administration as t:o whether
there will be an application to the FERC for the construction
of the project.
Mr. Al Carson
December 10, 1081
Page 2
3. SCire of the agencies are concerned about responding to bits
and pieces of the proposed project without being able to
evaluate the entire proposal.
'Ib clarify the Faler Authority intentions relative the request for
formal coordination, it is appropriate to look to basic intentions and
objectives. The present and proposed FERC regulations clearly encourage
pre-application coordination; First, to assure that the project
planning process has taken into account policies and guidelines of
local, state and federal agencies, and second, to assure that the
applicant has solicited agency ccmrents and concerns and has attempted
to address them. Specifically, the proposed PERC regulations
{anticipated to be in effect by tllre of license application, July 1, ·
1982) require a request for formal coordination fDOm agencies, provision
of up to of sixty (60) days response tine to those agencies, and
inclusion of applicant response to agency fonra.l caments in the license
application. Therefore, one major purpose ~or the request currently
circulating is to comply with FERC regulations.
The Pc:wer Authority is anxious to accarrrodate agencies and the
Steering ~~ttee in the decision process. We have demonstrated this
in the past and wish to continue that policy. OUr requests for foJ:!'Cel
coordination are very much intended to accommodate consideration of
agency comrents in the formulation of the project and in the decision
process leading to the Power Authority project licensing recommendation.
Clearly, our ability to use comrents in this fashion is very much a
function of when we receive them.
.
In response to regulatory require.rrents, and to our best judgerrent
of when agency cornrent vlill be rrost productive we perforce must persist·
in our requests for fol:JT\3.1 coordination. We hasten to add, ha..vever,
that we willingly accept interim CCl'TITent, informal carrrcnt, or any other
variant that gets the infonration to us in a tirrely fashion. Hea.nwhile,
we will attempt to make available pertinent dcx::urnentation of field
studies as early as possible so as to assist your review.
I hor.x= this sunmary assists you and your colleagues in deciding hew
to resr:ond to our requests for forrral coordination. If other facets to
this action emerge, I would welcome an opportunity to further discuss
them with you.
FOR THE EXEClli'IVE DIPECIOR ~ttl~ Dav:d D. l·~o:niak )
ProJect Eng1neer
cc: John I.avrrevmce, Acres Anerican, Buffalo
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ALASKA POWER AUTHORITY
334 WEST 5th AVENUE -ANCHORAGE, ALASKA 99501
Mr. Al Carson
State of Alaska
Department of Natural Resources
323 E. 5th Avenue
Anchorage, Al?ska 99501
Dear Al:
December 17, 1981
Phone: (907) 277-7641
(907) 276-0001
Just a quick note to advise you we will be meeting with the Cook
Inlet Acquaculture Association on January 21, 1982, 5:30 p.m. in the
Kenai Borough Building. This meeting will also be open to other special
interest group5 and the public, who will be notified via direct mailing
and newspaper notices. ~Je will be discussing the probable impact of the
Susitna Hydroelectric Project to the anadromous populations.
You might want to pass thi's information to your colleagues on the
Steering Committee. Your, as well as their, attendance would be welcome.
FOR THE EXECUTIVE DIRECTOR
DDW:mlj
cc: R. Mohn, APA
N. Blunck, APA
J. Lawr-ence, Acres.
7J;JJ . / ~vid IV Wozn~J['MUJ
Project Manag~
(
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f
I
I
JAY S. HAIIIIOIID, &DVEINOI
UEI»;\UT~IENT 01' ~.t\.TIJili\1. lli<:SOIJIU~ES
January 14, 1982
Dave Wozniak
Project Manager
DIVISION OF RESEARCH & DEVELOPMENT
Alaska Power Authority
334 West 5th Avenue
Anchorage, AK 99501
Dear Dave:
I Pouch 7-005
~
ANCHORAGE, ALASKA
276-2653
Per our earlier discussion, this memo identifies the topics the Steering
Committee members believe to be of mutual interest to Dr. Leopold and
ourselves.
I want to Pmphasize that the Steering Committee members recognize that
Dr. Leopold s role on the External Review Panel is oversight in nature.
Thus, the Steering Committee members will be leading the discussion on
the topics listed below. Our objective is to review what we believe to
be the most important Susitna Hydro-related issues in Dr. Leopold's area
of interest arid expertise.
The issues and brief descriptions follows:
l. Fish and Wildlife Studies. Discussion of scope, timing and current
status in relation to Susitna hydro feasibility decision making
schedule.
~ 99510 c-
2. Fish and.Wildlife Mitigation. Current status and summary of miti-
gation Review Group meeting of l/20/82 (I understand that Dr. Leopold
will attend 1/20 meeting).
3. Instream Flow Studies. Relationship to mitigation, downstream
impact assessments and power generation-related flow regimes.
4. Access to Proposed Dam Sites. Implications of route alternatives
and public access on caribou, moose, and waterfowl.
5. External Review Panel's
schedule, and products?
Committee to continue a
level?
Role in the Future. What are plans,
Is it useful for Dr. Leopold and Steering
dialogue? If yes, at what frequency and
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Da.ve Wozniak
Sincerely,
Al Carson, Chairman
Susitna Hydro Steering Committee
cc: Steering Committee Members
Reed Stoops
2 January 14, 1982
WILLETT
WITTE
BEARY
n .. ........:
IX'( 1 ,_ (,!
/ J\~ JJ.
/ ......,... ~-liA~
LAMB
LAWRENCE
l)>I~A
V ~ANl GH
f-f~-
f-
CARLSON
FRETZ
JEX
LOWREY
SINGH
" v I~ A
!_
11rl'~
HUST~~
BOVE
CHASE
r-,_
'--
~ ,,,(}
Mr. David Haas
Office of the Governor
November 24. 1981
P5700. 11 • 92
T.1297
4 D1vis1on of Po11cy Development and Planning
Pouch AW
Juneau, AK gga11
Dear Mr. Haas :
Cbry
Sus1tna Hydroelectric Project
Fonnal Agency Coordination
As discussed yesterday, I am enclosing a list of all people
within state and federal agencies to whom we are sending
Sus1tna Hydroelectric Project Reports. The list is keyed to
explain who gets which reports. We are attemp'tring to insure
that each agency has the opportunity to review reports dealing
with resources or issues for which it has jurisdiction.
If I can be of further help, please let me know.
Sincerely,
# John D. Lawrence
Project Manager
JDL:dtp
Enclosure
xc: Alas~a Power Authority
SUSITNA HYDROELECTRIC PROJECT
REPORTS CIRCULATED FOR FORMAL AGENCY COORDINATION
NUfoeER KEY
I"' ~·· WILLETT
I WITTE
I BERRY Plan of Study 1
-r -1980 Envi ronmenta 1 Sunmary Report 2
I
...JHAYOEN
LAMB
1980 Fish Ecology Annual Report 3
.. · LAWRENCE
. [SINCLAIR 1980 Plant Ecology Annual Report 4
IVANOEFIBURGH
'!""'r
.1 '\.
1980 Big Game Annual Report 5
CARLSON
1980 Furbearer Annual Report 6
I• FRETZ ~. JEX 1980 81 rds and Non-Game Manma 1 Annua 1 Report 7
LOWREY
SINGH
1-1980 la~d Use Annua 1 Report 8
I 1980 Socioeconomic Annual Report 9
HUSTEAD -BOVE 1980 Cultural Resources Annual Report 10
Transmission Line Coaridor Screening Report 11
t-CHASE
Development Selection Report 12
""" ~
1981 Final Subtask Report 13
Draft Feasibility Report 14
-
-
Regional Administrator
Region X
U.S. Environmental Protection Agency
1200 South Avenue
Seattlet WA 98101
Col. Lee Nunn
District Engineer
U.S. Army Corps of Engineers
Anchorage District
P.O. Box 7002
Anchorage, Alaska 99510
Mr. Keith Schreiner
Regional Directort Region 7
U.S. Fish and Wildlife Service
1011 E. Tudor Road
Anchorage, Alaska 99503
Mr. Robert McVey
Director, Alaska Region
National Marine Fisheries Service
NOAA
P.O. Box 1668
Juneau, Alaska 99802
Mr. John E. Cook
Regional Director
A 1 ask a Off ice
National Park Service
540 West Fifth Avenue
Anchorage, Alaska 99501
Mr. John Rego
Bureau of Land Management
701-C Street
Anchorage, Alaska 9950
Mr. Larry Wright
National Park Service
1011 E. Tudor Roadt Suite 297
Anchorage, Alaska 99503
Ms. Judy Schwarz
U.S. Environmental Protection Agency
Mail Stop 443
Region X EPA
1200 South 6th Avenue
Seattle, Washington 98101
Mr. Ron Morris
Director, Anchorage Field Office
National Marine Fisheries Service
701 C Street
Box 43
Anchorage, Alaska 99513
Reports sent/to be sent
1t 2t 11, 12t 13, 14
1t 2, 11, 12, 13, 14
1t 2, 3t 4t 5, 6, 7t 11,
12, 13t 14
1, 2, 3, 4t 5t 6t 7t
11, 12t 13t 14
1, 2, 9, 10, 11t 12t 13, 14
1, 2, 8, 11~ 12t 13, 14
1, 2, 11, 12, 13t 14
1, 2, 11t 12, 13t 14
1, 2t 11, 12, 13, 14
~I
-
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-
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Mr. Ronald 0. Skoog
Commissioner
State of Alaska Department of Fish and Game
Juneau, Alaska 99801
Mr. Ernest W. Mueller
Commissioner
Alaska Department of Environmental Conservation
Juneau, Alaska 99801
Mr. Lee Wyatt
Planning Director
Matanuska-Susitna Barough
Box B
Palmer, Alaska 99811
Mr. Tom Barnes
Office of Coastal Management
Division of Pol icy Development & Planning
Pouch AP
Juneau, Alaska~9811
Mr. Roy Huhndorf
Cook Inlet Region Corporation
P .0. Drawer 4N
Anchorage, Alaska 99509
Mr. Thomas Trent
State of Alaska
Department of Fish & Game
333 Raspberry Road
Anchorage, Alaska 99502
Mr. Bob Martin
Alaska Department of Environmental Conservation
437 E. Street, 2nd Floor
Anchorage, A 1 ask a 99501
Mr. Alan Carson
Alaska Department of Natural Resources
323 East 4th Avenue
Anchorage, Alaska 99501
Ms. Lee McAnerney
Commissioner
Department of Community & Regional Affairs
Pouch B
Juneau, Alaska 99811
Mr. Robert Shaw
State Historic Preservation Officer
Alaska Department of Natural Resources
·Division of Parks
619 Warehouse Avenue, Suite 210
Anchorage, Alaska 99501
Mr. John Katz
Alaska Department of Natural Resources
Pouch M
Juneau, Alaska 99811
Reports -sent/to be sent
1, 2, 3, 4, 5, 6, 7, 11,
12, 13, 14
1, 2, 3, 4, 5, 6, 7, 11,
12, 13, 14
1, 2, 11, 12, 13, 14
1, 2, 11, 12, 13, 14
1, 2, 8, 11, 12, 13, 14
1, 2, 11, 12, 13, 14
1, 2, 11, 12, 13, 14
1, 2, 11, 12, 13, 14
1, 2, 9, 11, 12, 13, 14
1, 2, 9, 10, 11, 12, 13,
14
1, 2, 8, 11, 12, 13, 14
DIVISION OF POliCY DEVELOPMENT AND PLANNING
GOVERNMENTAL COORDINATION UNfT
December 2~ 1981
Mr. John D. lawrence
Project Manager, Susitna Hydroelectric Project
Acres American Incorporated
The liberty Bank Building, Main at Court
Buffalo, New York 14202
Dear Mr. lawrence:
JAY S. HAMMOND, Governor
POUCH AW (MS · 0165)
JUNEAU, ALASKA 99811
PHONE: (907) 465-3562
RECEIVED
DEC 7 1981
This letter should clarify a telephone conversation we had on November 23, 1981
and the role of this office in reviewing subsequent materials relating to the
Susitna Hydroelectric Project.
Our office recently received copies of correspondence addressed to Tom Barnes,
formerly of the Alaska Office of Coastal Management (OCM). We conduct Alaska
Coastal Management Program {ACMP) consistency reviews for OCM as well as unified
r--A-L-As_K_A_P_ow_E_R---:::: ate responses on many major projects. Thus~ OCM notified us of this correspond-,~
AUTHORITY ce. In this regard, we'd first like to inform you that Ms. Wendy Wolf has
SUSJTNA placed Tom Barnes at OCM and will handle any future reviews of the Susitna
oposal for OCM.
'SEQu~-·-,,,..,1:" NO for future reviews, we would like to receive a mailing list of all agencies
l --'~'"';~q ·c ntacted and a copy of the particular report. We would like to do an informa-~ ~ v ·anal review of the feasibility study when it is available. We would expect
z: :-il c:i J tat an Environmental Impact Statement {EIS} would also be prepared for this
2 ~.: ~ I S. jar project and that we would conduct an ACMP consistency review of it. If
~~~~· S ; ~Y u do prepare such an EIS, we would like to coordinate the mailing of such
__ , ___ ; -d cument with you to simplify our review procedures. We would, of course, like
I i u::-·.·.': t know if there won't be an IIS.
-1 :/f}'-.-,---1-i c.--; ··---p ease advise us if you can clar1fY any of the review process and if you -~~:! ve any questions. , I~F;,-+---
\_l_,~!-" i--1 [.-(.'
!~--E~~\_j_!:_' I== ~:~:i 1
• !'1 RV l__c · Eric Yould, APA :--~-H RC j •
~~=,=j-'-=j=~l-
-~--,
-~~~---
Sincerely,
!lv~~ fv', ~~~vJ
David W. Haas
State-Federal Assistance Coordinator
F
I
J.
I
I'
~
I
"""'
[
I
r .
I
.J.
I
I r.
WILLETT
WITTE'
BERRY
LAMB t
Mr. David Haas Cta te-Federal Assistance Coord1nattr
ta of Alaska ta
ltff1 ce of the Governor
fivi s1on of Policy Development
d Planning an
,/ ,, ! ~~ f//.J: ,, .....
hAW
au. Alaska 99811
December 9, 1981
P5700. 11 • 92
T.1338
LAWRENCE'
SINCLAI_f!
H
r·~~·
/ ~
CARLSON
FRETZ
JEX
LOWREY
SINGH
,..,~//}
~aar Mr. Haas: Susitna ~droelectric Project
Formal Agency Coordination ~l..;)../t:_· ll
his
981
)
will hopefully address the issues raised in your letter of December 2,
•
We will send future correspondence to Ms. Wendy Wolf at the Alaska Office
of Coastal Management.. Thank you for notifying us of change in personnel.
---·JV(. ~) We will send you copies of all future reports issued formally for agency
review. MY letter to you of November 24, 1981 listed all recipients
HUSTEAD and the reports they will receive.
eave
) This formal agency review process we are conducting is for several
purposes. Although we have had many meetings with agency personnel, we
CHASE
1 Jt-1,}~
have been informed thefr views do not necessarily represent those of their
agencies. To insure c~ncerns of the agencies are addressed and incorporated,
where possible, into project planning and to receive agency input on the
studies, we have implemented this formal process whereby project reports
are sent to agency Commissioners and/or Directors. In addition, the
-
Federal Energy Regulatory C01m1ission requires docwnentation of agency input
into project planning and mitigation.
4) The Feasibility Report will be issued by the Alaska Power Authority (APA).
By copy of this letter, I will request you be placed on the distribution
list.
5) The Environmental Impact Statement for this project will be prepared and
issued by the·Federal lgengy"Regulatory Colllllission, on the basis ofa
license application to be submitted by APA. should a decision be made to
do so by the state. If you wish to coordinwte ma111ng of this document,
I .suggest you contact Mr. Quentin Edson. Chief of the Environmental
Division in Washington. D.C.
Mr. David Haas December 9, 1981
page 2
I hope this c1ar1f1es matters. If.Y.you have further questions, please
call.
~!jMGJJmh
cc: £. You1d, APA
Sincerely,
~
John D. Lawrence
Project Manager
F--:-·,
-WILLETT
WITTE
BERRY
_L
""'
f1"1'~ l~l
LAMB -LAWRENCE
SINCLAIR
VANDERBUn:tGH
-7~--r-'
CARLSON
FRETZ -JEX
LOWREY
SINGH
~ ¥: ~
_j_
HUSTEAD
BOVE
!""'"
f..< ..1'1. ,, .. ,-.....
ii f ftT'O"""'-L
CHASE -
f-..... -
-
Mr. Tom Trent
Alaska Department of Fish and Game
2207 Spenard Road
Anchorage, AK 99503
November 25, 1981
P5700.11.92
T .1301
Dear Hr. Trent: Susitna Hydroelectric Project
Report Review
As you diseussed with Michael Grubb on November 24, 1981.
I am enclosing the following Sus1tna Hydroelectric Reports
which were also sent to Mr. Skoog for ADF&G review and
cooment:
1. 1980 Environmenta 1 Sumnary Report
2. 1980 BiQ Game Annual Reoort
3. 1980 Fish Ecology Annuai Report
4. 1980 Plant Ecology Annual Report
5. 1980 Furbearer Annual Reoort
6. 1980 Bird and Non-Game Annual Report
As you sugge~ted we will in the future send reports both to
Mr. Skoog and directly to you.
lf.1G:dl p
xc: E. Yould/APA
R. Skoog/AOF&G
Enclosures
Sincerely,
John D. Lawrence
Project Manager
DEP.-\.GTM£zt.T OF ~AT1JII..U RESOURCES
IXVJSlO'IOF RESEARCH&~
December 9. 1981
Eric Yould, Ex~.utive Director
Alaska ~r Authority
333 West 4th Avenue. Suite 31
A."''c.horage. AA 99501
Dear Mr. Yould:
·Several state and federal agencies. in recent weeks have been asked ta ··
formally review and provide connents on several doct!l!li!'flts relating to
the proposed Susitna Hydroelectric Project.. Although the Susitna. Hydro~
electric Steering Caanittee 1s an organization that is designed to pro-
vi-de infQrma.l advice and caooent on matters pertaining. to the Susitna.
H_yi:froelectri.c Project,. roost of' the steering c~ittee members recei'lt!ii
the formal agency respanse request that 'lias S~'1t to the agency directors
and cc:a:tissioner:s by Acres. it is primarily because of that fact that the
steering c.omiitt.ee feels that it is appropriate and neo=ssary tD send
----~--.a letter to you at this time with respe..-t to the Alaska Power A.uthority•s
· AL~:~o~~;£R re-~uest for formal agency coordir.ation and review on ela><ents uf the .SUsitna
SUS11:N.A Hydroel~tric Power Project.
~--___;,~--1
:_FILE .PJJOO · As a result of concerns expressed by srsnbers af tl"'.e steerinq ~fttee. we
--=~=:::_jconvened a meeting on 0-ece:-.ber 2. 1981 of the steerin9 c~ittee with
;EQUENCE ~·-~Robert Mchn and Dave WQzniak. of the Alaska Pmfer Autti'Oi'ity L'ltt-.onding.
· , d/ !35'-. ·At this steering cOf!inittee ~tin9, we were provided with our first gH~se
of how the Alaska Power Authority intends to cc-nduct tt-~ ftrn:ial ccnsultation
-:i. and coordination required for this project.. The foma.l coorriinaticn process
;::: that is proposed in t.~ August 12:1> 1S81 Acres dOCG;r.<2nt to fric You1d. subject,.
z wsusitna Hydroelectric Project fo~~l Coordination Plan•. is conceptua11y
appropriate but incomplete and deficient. The fo11 owing are probl~ areas.
1-:7""'--1----1 in the prop<}sed fonr.al coordination p1an as described above.:
FILE
1. The fonr.a1 coordination plan as proposed by Acres. has not b~n
formally or informally discussed and reviewed ~ith the agencies
from which the Po~r Authority requires responses. This is pro·
bably the !'nost significant objection we have with the approach of
Acres. The contractor sent letters to heads of state and fe-deral
agE=;..cies requesting s~~iftc c.o.,~nts on detailed studies and
reports associated with the Susitr~ Hydroelectric P~j~t without
having a c~~lete understanding of the responsibilities and concerns
of agencies.
2. S:Y..r:e of the reports -,.;hic.h agencies wi11 be requested to form:lly
respond to wi11 not ~ pre-::e-eded by the reievant data and study
findings f:-o;~ 'Fihich the su:;;;;ary report and formal agency co;w..ents
should be based. An obvious exa..r.:p1e is the review of the 1931
draft annual re~rts is ~uired 2 r:10nths after the draft fe-as1-
bil1ty report reYiew.
, ....
-
-
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3. Ttee proposed formal coordination plan. as described in the Au9ust
12, 1981, riocrarent fma Acn!s tc APA does not accurately describe
all tt;e parties and agencies who should receive t:et"t4fn doc\B!e!lta.
The steering callilittee feels that the furcal COOS\lltation process should proceed
in a liliOI"e ccordinat-od and organized fashion in order to avoid umecessary
cr-Aseqt.JeneeS caused by the problems. "We rrave identified abclft. · .. We offer' 'the
following suggestions and ~ts:
1.. lie. rec0ii1'Gend that the APA., as soon as possible, convene a formal
r;eeting with agencies to establish the schedule, and the process for
formal c:oordin.1tion for this project. In light (}f the proposal to
have a complete draft feasibility plan available on March 15, 1982.
we urge tha.t the PeEr Authority convene th1s ~ting and get this
~~a.tter sorted out with the agencies before January 1, 1982.
Z. The formal coordination list that will be ·used for this project
needs to be reviewed and approved by ager.cy representatives to
ensure that it is ca;plete and ccmprehensive. At+...ached to this
letter please find a series of additions tD the 8/12/81 Acres
list ..
3. Review of the proposed F .. E .. R.C. regulations in volr.se 46 ~r 219
of the Federal Register dated 11/23/81 identified a list of inforae-
tion categories to be included in Exhibit E. Ca:;parinq these re-
quirements to the 9/12/81 proposed coordina~ion pian, liE find the
foll~ing agency review categories missing: .
i} Socirecc.~ic sb:dies
H) A1terr.ative assigns, locations ar.-d er.€rgy sources
i i1) 6eo log i ca 1 and soi 1 s stud1 es
We agree with the APA approach of requesting eariy fot.....;tl revi~ arrlf ~ts
on policy related dcozents that are required in order t£J put the project
proposal togetr.er. For e~le, the reqw::st for revieo~ <rf fr£ fish an.d wild-
life mitigation policy before the specific mitigation proposal for the project
is su!=mitted: to agencies for reviell an~ catr.ent.
In suma-.ary. the ~bers of the steering cr .. :-,ittei! found the proposed forna1
coordinat1on plan to be revealing ar.-d useful to better tn·~i!~rstand ho"' ag-encies
~111 have to respond in order to ineet the needs of APA. ~ are particularly
encr;~uraged to see L'iat the instrecs f1!illl sturly plan ~s p1anr.ed to be available
for reviei and C<W"""~t by agencies in Dece:ber of 1981.. Since. this is such a
critical el~nt of the Susitra Study Plan. thi~ rleserv~s attention and re-
sponse from the agencfes as soon as possible.
The steering comittee hopes that you will find the-;a.e <:.oaiEnts ar.d ~
tions useful and constructive ar.d is anxious to continue to. provide 'infon:2.l
review and ad<~ice to the Pmer Authority.
Sincerely yours,
A 1 Carson, 01a. f l"!!'W1
Susitna Hydroeleetric Steering Cculittee
AC:dh
cc: Steeriri!J Coimit'".,.ee
Reed Stoops
Quentin Edson. Director, Division of Environmental Analysis, F.E.R.C.
A.. Starker leopc ld
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....
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. 12/9/81
R~ additions to the 8/12/81 agency coordinat1on list for Susitna
Hydroelectric .Project.
water Quality and Use
Alaska DHR,. OF & G
• DEC· _
U.S .. A'tflfl. Corps of Engineers
• EPA,. NPS
• F & WS, GS
• BUI,lftfS
AEIDC
Fish, Wildlife and Botanical
. -
Alaska Of & G
-• DEC
• OMR
U.S. F & WS, &S·
" N1FS. EPA
•-Bl.H
AEIDC
Historical arid Archeological
Alaska DMR (~~PO), OF & G
• DCRA
U.S. NPS
• BLM
AEIOC
Recreation
Alaska DNR. OF & G
U.S. NPS
• F-& WS, ~~S
Mat-Su Borough
AEIDC
Aesthetics and Land Use
Alaska DNR, OF & G
U.S. BLH. F & WS~ NPS
CIRI
AEIOC
General
OPDP, OCM,. Govemor•s Office
United States Department of the Interior
RECEIVED,·
IN REPLY REFER TO:
FISH AND WILDLIFE SERVICE
lOll E. TUDOR RD.
DEC 21 1981 WAES
r --,J..:.-
1
--~ .\ . Eric Yould
ANCHORAGE, ALASKA 99503
(907) 276-3800
ACRES it. . - . . I ORATED,. . •• .... uao.~ •• ,,. htC..Unr
-· -,) I · ~ •I ~ E?Cecutive Director
; _·/~L]/_Afi.ask.a Power Authority 15 DEC T~~1
1-~;] /_~.r,!h:;.:~~ ~;=~~ 99501
. --· " I ;tnrar Mr. Yould: i~ ~: g ~Tpe u.s. Fish and Wildlife Service (FWS) has been contacted by Acres American
~-~-7---~fgarding fonual coordination of certain aspects of the feasibility study for r· -r /_-:,/ ; tile Federal Energy Regulatory Commission (FERC) license application for the
!" -~-7-~--sr1 sitna Hydroelectric Project. To date four document packets have been sub-; _:_ · -!-m tted to us for formal review. These are the 1980 Environmental Studies !--'----~_1 ------A..hnual Reports, Transmission Line Corridor Screening Report, Development
j __ >~. i S~lection Report, and the Fish and Wildlife Mitigation Policy.
i---::__·_" L_j
1 1 ! Initially, some confusion arose over these requests. In his letter of
· r--i-·r::·\j~. bvemb. er 16, 1981, Mr. John D. Lawrence (Acres) identified the sources of
-:-.--·. -·-r""""""Chnfusion, explained which documents were to be reviewed and extended the
1--.--~--;~mment period to 45 days. While we appreciate this clarification, we feel a
; ____ : -l--mhre formal and explicit plan for formal coordination of the Susitna Project
-~hst be developed. Mr. David D. Wozniak of your staff addressed the Susitna
... --·~~:__Hydroelectric Steering Committee on this subject at their meeting of
:_ --~---::; _ ____]ecember 2, 1981, and presented th7 coordination plan developed by Acres
1 Jtt.·~ . -~f?-J4letter of August 12, 1981, from John D. Lawrence to Eric Yould).
) , · . ~~ M~. Wozniak's briefing .was very beneficial to our understanding of this pro-
-----cess; however, ve feel it is important that the Alaska Po~er Authority (APA)
understand the position of the FWS on this issue. The FERC regulations
(Federal Register Vol. 46, No. 219, November 13, 1981) require a FERC license
application to document coordination with federal resource agenci_es in the,
Exhibit E. These agencies must be afforded a minimum of 60 days for review
and comment. As such we disagree with the 45-day comment period suggested by
your contractor. Additionally, there are several deficiencies within the
Acres coordination plan which concern us; the first of these being the fact
that no formal discussion as to this coordination has occurred. Thus,the
contractor arbitrarily decides which documents are of concern to a particular LJ)~~: agency, and what level of coordination will take place. Formal contact should
i~ work to insure that all agency concerns and consultations are met so as to c7tJ~ comply with the intentions of the FERC regulations. With the exception of £. l;f(/tt4} /certain_ policy statements (e.g. Mitigation), the Acres plan calls for formal ~~. (d ~ agency 1oput before necessary background reports and data are available. An JLR-y obvious example of this is found in the formal coordination plan-product list
,t}k,! .
hie
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(attached to the aforementioned letter dated August 12, 1981) where the Draft
Feasibility Report will be released for agency review two months prior to
release of the 1981 Annual Reports. It is unrealistic to assume that
m;:Aningful comment can be generated in the absence of such information.
We believe a meeting should be arranged by your office to define the objec-
tives of the required coordination and to develop a plan suitable to both the
APA and the federal resource agencies. In the interim we w~l attempt to
respond in a timely manner to all appropriate project documents, but will
withhold comment on those documents which must be supported or clarified by
the results of other studies.
Sincerely,
AdJ:!;O£~
cc: FWS/ROES, WAES
Quentin Edson, Director, Div. of Env. Analysis, FERC
NMFS, EPA, NPS, BLM, USGS, ADEC, ADF&G
Carson/ADNR
Lawrence/Acres American
,--,-,
HECEIVED
JAYS. HAM~ ~~Rf'9.fl 1
'ftU,.SKA POWER AUTHORITY ,-
DEPT. OF ENVIRONMENTAL CONSERVATION
Mr. Eric P. Yould
Executive Director
Alaska Power Authority
334 West 5th Avenue
Anchorage, AK 99501
Dear Eric:
. POUCH 0 -JUNEAU 19111
December 21, 1981
The Department of Environmental Conservation has been contacted by
Acres American requesting formal coordination and review on five
Susitna Hydroelectric Project documents. These requests were
received in October and November, 1981. There apparently is some
confusion as to what exactly was being requested. In his letter
of November 16, 1981, Mr. John D. Lawrence of Acres clarified the
situation and extended the review period to 45 days. On December 2,
1981, the Susitna Hydroelectric Steering Committee met with
Mr. Dave Wozniak of your staff. Dave presented the Acres coordina-
tion plan. This document, plus Dave Wozniak's briefing, provided
a clearer understanding of what we must do to be responsive to the
needs of APA for the Susitna project.
As noted by the steering committee's letter to you on December 9,
1981, there are several problem areas with the formal coordination
process outlined by Acres. We are particularly concerned that DEC
was not inclutled in the water quality and use group. Since DEC sets
State Water Quality Standards and regulates water quality throughout
Alaska, I feel our inclusion on the water quality review group is
necessary.
Review of the coordination plan leads me to recommend that it would
be useful for APA and the appropriate agencies to design a single
continuing process for review and comment on the Susitna Hydro-
electric Project. Since we are dealing with a State-sponsored
project, I believe it is appropriate and timely that the State
agencies and APA also determine the funding and personnel needed
for these efforts. Our contacts for this matter are Bob Martin or
Steve Zrake of our Anchorage Regional Office. They can be reached
by phone at 274-2533.
Commissioner
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
National Marine Fisheries Service
P.O. Box 1668
Juneau, Alas~ 99802 .RECEIVE;D
December 23 , 1981 DEC 3 11981
-msKA P9WSi AUTHORI1Y
-I
r
r
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·-
Mr. Eric Yould, Executive Director
Alaska Power Authority .
333·w. 4th Avenue
Anchorage, Alaska 99501
Dear Mr. Yould:
The National Marine Fisheries Service has been contacted
by ACRES American regarding formal coordination of certain aspects
of the feasibility study for the Federal Energy Regulatory Commis-
sion (FERC) ·license application of the Susitna Hydroelectric
Project. To date four (4) ·documents have been submitted to us
for formal revie~ These are the 1980 Annual Reports, Transmission
Line Corridor Screening Report, Development Selection Report and
the Fish and Wildlife Mitigation Policy.
Initially, some confusion arose over these requests. In
his letter of November 16, 1981, Mr. John D. Lawrence {ACRES)
identified the sources of confusion, explained which documents
were to be reviewed and extended the comment period to 45 days.
While we appreciate this clarification, we feel a more formal and
explicit plc;m for formal coordination of the Susi tna Project must
be developed. Mr. David Wozniak of your staff addressed the
Susitna Hydroelectric Steering Committee on ·this subject at their
meeting of December 2, 1981, and presented the coordination pla.n
developed by ACRES (letter of August 12, 1981, from John D. Lawrence
to Eric Yould) : . Mr. Wozniak's briefing. was very beneficial to
·our understanding of this process, however we feel it is important
that the Alaska Power Authority understands the position of the
NMFS .on this i .. ssue. The FERC regulations require a FERC license
application to document coordination with concerned federal agencies
under Exhibit E. Agencies must be afforded a minimum of 60 days
for review and comment. 18 CFR §4. 41 (f) (46 FR 55926, 55937;
November 13, 1981). We interpret this requirement to apply to
each document submitted to us for consultation, including in
particular the drafts of Exhibit E and the license application
itself. Moreover, we expect that while there may be documents
which can be reviewed by us in less than 60 days, there are very
likeJy going to be instances where we will need more time than
that in order to perform a thorough review.
One reason we expect to be accorded longer than 60 days
for consultation in some instances, is that formal agency input
is often to be solicited before necessary background reports and
2
data are available. An obvious example of this is foundin the
formal coordination plan-product list, where 'the Draft Feasibility
Report will be released for agency review two months prior to
release of the 1981 Annual Reports. It is unrealistic to assume
that meaningful comment can be generated in the absence of such
information.
We are also concerned about another apparent deficiency
in the proposed coordination plan. The decisions as to how
coordination is to proceed are left to the contractor, who has
discretion to decide which documents are of concern to a particular
agency, and what level of coordination will take place. This
approach has the potential for having the concerns of some agencies
overlooked, and we would urge that the ·contractor make a special
effort to insure that the consultations are as inclusive as
possible.
We believe a meeting should be arranged by your office
to define the objectives of the requ~red coordination and to
develop a plan suitable to both the APA and the federal resource
agencies. In the interim we will attempt to respond in a timely
manner to all appropriate project documents, but will withhold
comment on those documents which must be supported or clarified
by the results of other studies. ·
-
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I
I .. January 8~ 1982
P5700.11. 92
T1415
Mr. Ernest W. Mueller
Corrin iss i oner
Alaska Department of Environmental Conservation
Juneau. Alaska 99801
Dear Mr. Mueller:
Susitna Hydroelectric Project
Formal Agency Coordination Program
As you are aware, Acres American has, on behalf of the Alaska Power
Authority. instituted a Formal Agency Coordination Program for the Susitna
Hydroelectric Project. This program has apparently resulted in some
confusion among var.ious agencies as to its intent and scope.
To resolve this, a meeting has been arranged for 10:00 a.m. on January 21,
1982, at the office of the Alaska Power Authority, 334 West 5th Avenue.
Anchorage. The purpose of this meeting wi 11 be to explain the rationale,
intent, scope, and regulatory requirements for this program.
If you feel you could benefit from this meeting, your attendance is welcome.
MMG/jgk
ACRES AMERICAN INCORPORATED
..... : ··, . :. -' ·~ . . . ( ... ' .: .
. ~~ r . • :
Sincerely yours.
John D. Lawrence
Project Manager
. . ;; : '-··· :.:c..
Preceding Letter Sent To:
Mr. Ernest W. Mueller
ronmenta
c Preservation cer
as Department of Natural
Reso'urces
619 Warehouse Avenue
~ "'t\K 99501
nald 0. Skoog
Department of sh and Game
L::r;F;i3U ~ AK 9980"1
sheries Service
neau ~ 99802
Mr. Keith Schreiner
Regional Director
U.S. Fish and Wildlife Service
1011 E. Tudor Road
Anchorage, AK 99503
Colonel lee Nunn
U.S. Army Corps of Engineers
P.O. Box 7002
Anchorage, AK 99510
Regional Adminstrator
U.S. Environmental Protection
Agency
1200 South Avenue
Seattle. WA 98101
Mr. John Rego
U.S. Bureau of Land Management
701 C Street
Anchorage. AK 99501
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APPENDIX EllB
CORRESPONDENCE RELATING TO PLAN OF STUDY
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APPENDIX .11. B
PLAN OF STUDY
The Plan of Study was circulated for review in March 1980 with public and
agency meetings being held in April 1980. The Plan of Study was further dis-
cussed with the Steering Committee in September 1980 with Environmental
Procedure Manuals being circulated for review in October 1980. Comments on
the Plan of Study and Procedure Manuals were subsequently received and re-
sponded to.
This appendix contains correspondence from· APA to the agencies and their
responses concerning the Plan of Study and Procedure Manuals. APA's response
to these comments are included.
Correspondence is presented primarily in chronological order. However, in
some cases, a response to a letter directly follows the letter to facilitate
an understanding of the flow of communication. This results in an interruption
in the chronological sequence~
"""
Alaska Power Authority
333 West 4th Avenue
Suite 31
Anchorage, Alaska 99503
Attention: Eric Yould
Dear Eric:
RECEIVEQ
~·~ /.1! .
• . . ~ ; '" . ,r
August 21, 1980
P5700.11
T.375
Susitna Hydroelectric Project
Distribution of TES Procedures
t-lanua 1 s
Enclosed please find copies of the TES Procedure Manuals as requested
by yourselves and the Susitna Steering Comnittee. A distribution list
is attached.
Since Mr. Al Carson, Chairman of the Steering Committee is out of town
until August 27, the distribution list for the committee is based on
the key contact list as supplied by Don Baxter on July 18," 1980. Please
advise if any changes are made in distribution.
KY:pg
Enclosures
Sincerely,
J. 0. La\'lrence
Project Manager
DISTRIBUTION:
Copies of all procedure manuals to:
APA -E. Yould, R. Mohn
USF&W -Don McKay
DEC -Dave Sturdevant
ADF&G -Tom Trent
ADNR -Al Carson
BLM -John Rego
AEIDC -Chuck Evans
Copies of Fisheries Manual:
NMFS -B, ad Smith
Copies of Manuals for Subtasks 7.05, 7.06, 7.07 & 7.08:
HCRS -Larry Wright
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MEMORANDUM State of Alaska
TO:
FROM:
DEPARTMENT OF NATURAL RESOURCES
DIVISION OF RESEARCH & DEVELOPMENT
SUSITNA HYDRO ELECTRIC
STEERING COHMITTEE ~1EHBERS
(See Distribution List)
DATE.
FILE NO·
TELEPHONE NO:
Steering Committee Chairman
A'-"-.:.::r. fOWE:i r..: . .:TH~RIT'f . -·---.
TI1e purpose of this letter is two-fold:
September 4, 1980
279-5577
Summary of 7/17
and 18 Meetings
.and Review of
Procedures Manuals
1. To summarize the major points discussed in the July 17 & 18
meeting of the Susitna Hydro Electric Steering Committee.
2. To transmit to you copies of the Acres American contractor's
field manuals which describe in detail how they will conduct
studies during the 1980 and 1981 field season.
The first item of business on July 17 was discussions and decisions
leading to the appointment of a chairman. Those in attendance
agreed that Al Carson, Department of Natural Resources, would serve
as chairman of the Steering Committee with Tom Trent, Department of
Fish and Game, serving as Assistant Chairman. There were two
representatives from the Federal Energy Regulatory Commission
(FERC}, Hr. Dean Shumway and Mark Robinson. A considerable amount
of time was spent by Messrs. Shumway and Robertson explaining the
role of FERC in the proposed Susitna Hydro Electric Project. The
rest of the morning meeting was devoted to contractor briefings
about the studies included under Task VII (environmental studies)
for the Susitna plan of study. Two significant items were identified
by this review. First, it was obvious from the comments from the
agency representatives,.contractcirs, and subcontractors present
that the agencies were unable to provide a detailed·· critique of the
plan of study. This is because the widely circulated-plan of study
did not have adequate detail regarding methodology, approach, or
scope of the proposed studies to enable the reviewer to make reasoned
or useful comments on these matters. Acres American and their
subcontractors stated that this level of detail would be found in
their yet to be published field manuals which describe in detail
the work that the contractors will be doing in the 1980 and 1981
field seasons. The Steering Committee members will be provided
with copies of these field manuals for their review when they are
available. The significance of this is that the studies that are
peing accomplished under the Susitna plan_of.study for the field
year of ·1980 .are being carried out without benefit of review,'
comments, or approval by the various state an4 federal agencies.
Second, was a concern regarding hQw thflsocio-economic studies
being conducted under the Susitnaplan of stud)' related to the fish
Susitna Hydro ~ctric 2 September 4, 1980
·~
and game impact concerns identified by agency representatives. It
was agreed that the Steering Committee wil.L meet with the socio
economic consul t.:J.rrts to learn hm.,r these studies relate.
The meeting on July 18 \vas devoted exclusively to revie\ving in
detail and discussing the studies that are necessary in the FERC
filing concerning fisheries, hydrology, and instream flow. The
most significant issue which appeared from these discussions was
the need to insure that mitigation for fisl1, wildlife and other
environmental values are integrated into the project designs, etc.
rather than being an add-on or appendage at a later date.
The second purpose of this letter concerns revieH of the field
manuals. Accompanying to this letter you will find copies of the
field manuals to be used by the Acres American subcontractors .for
carrying out various studies as discussed in a general way within
the Susitna plan of study documents. Please carefully review these
manuals giving proper emphasis fo those studies which are included
within your field of expertise and your agency's authority and
responsibility. The intent is to have all tP!e Steering Committee
mQmbers review these manuals and forward your revie1.,r comments to
me. I will then synthesize these comments into a draft letter from
the Steering Committee to APA. Then we will meet to review and
finalize the letter. For the sake of convenience and saving time
in synthesizing comments, please place your comments and concerns
within the appropriate framework as discussed here: The review of
the field mnnuals is intended to detail problems or concerns within
the following six areas:
1. \.Jhat is the <Ippropriateness and utility of the studies, i.e.,
do the studies attempt to answer the questions that need
answering in light of the proposed Susitna Dam?
2. The scope of the studies, i.e., is the methodology approach
and techniques properly formulated to provide valid and germane
answer(s) which will apply directly to the proposed Susitna
Darn?
3. The study approach and methodology, i.e., does the approach
and methodology discussed in the manuals result in findings
and recommendations which are or will be scientifically valid?
4. H01.r do the subtasks of the studies "hang together" to give a
comprehensive picture of the impact of the .project?·
5. llO\v do the various disciplines (e.g., fisheries, seismology,
engineering, recreation) study findings and recommendations
affect the other disciplines? The answer to this question
will identify the hierarchy of values that will be attached to
various components of .the project when the "trade offs" decisions
are made.
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Susitna Hydro f,l,_ectric 3 September 4, 1980
6. \fhat other issues and con~erns did you discover while reviewing
these manuals that need the attention of the Steering Committee?
Please provide me your \vritten revie~v comments no later than close
of business, Friday, September 26, 1980. If you have questions,
comments or revisions on the matters discussed in this letter,
please contact me at 279-5577.
cc: E. Yould, APA
Distribution List
Don NcKay
U. S. Fish and Wildlife Service
733 W. 4th, Suite 101 .
. Anchorage, AK 99501
Torn Trent
Alaska Dept. of Fish and Game
333 Raspberry Road
Anchorage, AK 99502
Al Carson
A~aska Dept. of Natural Resources
323 E. 4th Avenue
Anchorage, AK 99501
John Rego
Bureau of Land ~illnagement
Anchorage District OEfice
4700 E. 72nd Avenue
Anchorage, AK 99502
Bob Lamke
U.S. Geological Survey
\~a ter Resources
73J Hest 4th Avenue, Suite t,oo
Anchorage, l\.K 99501
Bill \-Jilson or Chuck Evans
Arctic Environmental Information
and Data Center (U of AK)
707 "A" Street
Anchorage, AK 99501
Susitna Hydro Electric 4
Dave Sturdevant
Department of Environmental Conservation
Pouch "O"
Juneau, AK 99811
Larry Wright or Bill (\felch
Heritage Conservation and Recreation Service
lOll East Tudor Road, Suite 297
Anchorage, AK 99503
Brad Smith or Ron Harris
Na t:i.onal Harine Fisheries Service
701 "C" Street, Box 43
Anchorage, AK 99513
September 4, 1980
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Susit:na Hydro St-.~ Ccmni.ttee
c/o Al Carsm
Al~d~ Dep::a:tn:ent of i~at:urnl i!.aoourccs
313 East 4th Aven.ua
hlchorage, .tUa.ska 9~501
D&.r Al:
C!"nt-:~J""..,. n. 1n~o .u'i.., u~r. ~ u, ..~ .. ,
Last l.reek we fon~chd to you for di;;trlbutio:l to the Susitna
~lydro Stezrl.ng Cet:ruittec. copies of tr-12 envirO:L"'!!!"attal pmce~ nm1uals
applicsble to POS Task 7, as prepared by Terrestrial E.~v'i.:ror:lr.ental.
Special i o;ts, L~. ~). These ru:muals should Dn.St~ maT; of the qtr.:!Sticns
rel.eting to the details of o-ur Plan of Study. ~·:L:.! t.."Otlld a:ppr-1ciata it if
ycrJr cc.cmi.ttee would re"~li.e.·7 and camx:mt on these r:nnuals at its earliest
co:-~-enLr.>Tlee. He. t-ti.ll then p~pa:re t,rltt:en responses to tiny ca:t::xmts re-
ceived. If in fcllaving thb process ~'wre ara still cutstanding qucs~.s
that l."Cquire detailed tec..l-u1ical responses, 'I:Je uill be pleased to ~
the ~prcprlate prlr.cipal :t.."""Vesti.gators nrika n p:r.ese!r1taticn to your or.rrd.ttee.
'I'.E.S. Y.."ishes to rr.:d.nta:in positiv~ control m--er the.'1C ~.arn.mls, and
\;C 't~uld like to facilitate tr..at wish. 'n~ e.ttac.i-tcd forms rni~ht b~ use-
ful to you t:ot-mrds that goal.
'l'rust:ing this procr"~Jre rceet:s with your applX>V'lll.
FO:t 'Il!E EXf':.OJITVE DIRECTOR
cc: J. Lm~en~
J. Gill
E..'lclosurcs: .~ Gt:ated
D'W'.et
(X)NaJR:
EPY:
TJM:
U.V:
Sincerely,
Fobert A. l·nhn
Di:rector of E::Jgi.~ecting
SUB TASK
7.05
ALASKA POWER AUTHORITY
RECORD OF RECEIPT OF
ENVIRONMENTAL PROCEDURE MANUALS
COPIES ASSIGNED TO-------
TITLE
Socioeconomic Analysis
7.06 Cultural Resources Investigation ................. .
7_.07 Land Use Analysis ................................ .
7.08 Recreation Planning ...•...........................
7.10 Fish Ecology-Jmpact Assessment and Mitigation .. .
7 .11 W i1 dl ife Eco 1 ogy -Fu rbearers ................... ..
7.11 Wildlife Ecology -Big Game Impact Assessment
and Mitigation ................................... .
7 .11 W i1 dl i fe Eco 1 ogy -Birds and Non-Game t4amma 1 s .....
7.12 Plant Ecology •....................................
7.14 Access Road Analysis ................... ' ........... .
COPY #
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'K TITLE -
JS sacra-
ECONO!~IC
ANALYSIS
J5 CULTURAL
ilESOURCES
I NV EST!-
GATIONS
·]7 LAND USE
ANALYSIS
JS RECREATION
PLANNING
~0 FI!:H E-COL-
OG'i !HP:;Ci
ASSESSMENT.
AND
M!TIGATHm
· PLAN;>;ING
SUSITNA STEERING COMMITTEE
Record Of Distributio~ Of
Environmental Procedure Manuals
COPY SUB-
II RECIPIEtn .. TASK TITLE
tO 7.11 WILDLIFE
Jl ECOLOGY
-FURB EARERS
13
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21
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9 7.11-WILDLIFE
10 ECOLOGY -
BIG GAME
JZ. IMPACT
j4-ASSESSMENT
AND MITI-
~~ GATION
If.:. PLANNING
1'1
/8
!9
/0 7 .ll WILOLI FE
II ECOLOGY -
BIRDS AND n .. NON-GAME
!<I-MAMMALS
'"' 11
19
21
2Z
/0 7.12 PLANT
,z. ECOLOGY
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2z:.-
/I 7.14 P.CCESS
jz, l ROAD
AtfALYS~S
/3
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~~t .Oi'tll_ U:lTrR tO Tm: PUDLIC ;a um&£ lti\U ·10 t)tl. IUH.HlSU.D AGIJiCIES
AUD ORGAtUZATIOiiS
· On FebrtJiu'·.J:_j; .. ~980:,. it..~. (riC 'Y.Quld. EY.ec.ut.ive Direct.or of the
Al as~a 1-'owcr Au. t.Uorf ~~-. prevared a ·forwa rd1 ng le t.ter i nt.n)ducht!J Uu!
«1ctclHcd r'lan ot· St.ud,.v -for the Susttn!l' -Hyd..-or: l~c.t.rfc PrcJcct. He nui.ed
at the time th~t the. plan did not. pul'!Mnently fi:c· thP. m:mnet .. in wt\1en:
the pi"Dposed worl(. would be -li:CCo:tq,li'sbed anoiexpre~sed his des.1 n·~ Uli!t
you.r ass1Stimt~ W&uld conb"'ibirte. to its stead_v in~)rav-ement.
The Pt--oject Team.-has bc.~n heavily engaged during the pa~'t-n1nc-
~mntb~ in acc.ouo,Hs-ft1m;.tJu! JniU\V task~ ~nd ~ubtasks \rh\ch together wil1
uH.itntttcht luad t.o the basis. upim which Un::-SUite-of li.l aska can INtkc an
fnfo-mn:-d decision as 'to wne'ther 1t ei'E.-t or stm.uld f'roc-et!'-d wit-h tt·rE Susitna :.
Hydroelectric Pt'"Cject •. Con~tc;uct.ton of a camp was C('r.npleted in hjn'il 1980
DP.i.'t"' the Wilti'na d&ru· s.-1 te~. Ffcld crews have nPP.rated--since then from: Urc
llt'tana Callil f!_m.f .f-rom a number of ot.hef'" lEJe(l1'. !(lr(S. ltj!f)Ort"'nt itiftn·rr~titm
has bl!an and continue..o; to be collect.cd. W.:-know mtJ.c:h twre now about
the geology, hydrology~' ·sehto)}o{ly. ~nvironment ... and especially ahoot
the coocerns. and interests of the public_ .
: • . Evert while the w{)rJi·hets progt~ss.~d .. trlc Youldis prok.ctic d~ires
::-.~~-a, PO'.'\\~ iT~w been realized. 1 .. number of 1n~ortm~t ehanges have been made to th~
· ;-,-;-{Q!iiTY phn. lhis volui'ne duc:uments the t"'e\f1Sions and briefly U£:-SCf'ibt'S theh·
: ~~is.~n-;A gt-nesfs. Or1~ B9~tn ... your careful 1-eview and com:~nt.~ WOi.•ld be-\'OrJ'
:: ---=-· -::r. ·"'~ mt.rch apprec1 a ted~ I 51 nee"' ly hope ,Y<;u wi11 tiJkt! the time to Clddt"ess . '-' ...,, u_ "f_h m to~ . . _-,_· ,_·_~!e . . • . .
-;--~,--JC:E ~•o.l MJ.. Jhmcy B-1 unck
· f Publ1c · Part.icip~tion Officer·
' AliJ.Sk" Powf:!r Authority
-n ! ~ 333 West ~th .Avenue~ Suite 31
'; ,_ f,Jlchorage. J\1 ;Jska !l9501
/~ :-:;·.··. · -=··:\ On behdlf of the entire Prnject learn, f \o:nnt. t.o exru~!i>~ OU!~_t\ltprcch, ..
_. :t.1on for the !;.trr.tng int.et-est you have CXflr'CS~·etf lo d!7le. \h lh yuur
__ J-r--c:Lasr1stancep tJ•e t"e\~1s.ed plan wan cont1nue to be a· dynamic document.
\,.(__~ri-+1
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Sincerely.
John o. t.al«ence
Proj cct. ManiP'~cr
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DIVISION OF RESEARCH 8lDEVELOPMEtvr
November 21 , 1980
Eric Yould
Executive Director
Alaska Power Authority
333 W. 4th Avenue, Suite 31
Anchorage, AK 99501
Dear Hr. Yould:
r~~l~~iVED
JA r S. HAMMOND. &OVfRIIOI
323 E. ·1TH A VENUE
ANCHORAGE, ALASl(A 99501
279-5577
The purpose of this letter is to pravide you with the.Susitna Hydro
Steering Committee review comments regarding the procedures manuals
which d-escribe the Task 7 studies being done tmder the contract between
APA and Acres American. As you know the Susitna Hydro Steering Committee
is composed of representatives from state and federal agencies and.the
University of Alaska. ·Function of this commlttee is to provide coordinated
exchanges of information between APA and the interested resource
management agencies.
The Steering Committee met with representatives from Acres American
and its subcontractors on July 17 and 18, 1980. The purpose of this
meeting was to review the environmental studies portion of the contract
with Acres American and their subcontractors.. It soon became apparent
that the subcontractors tvere unable to provide the Steering Committee
members with an adequate level of detail concerning the. scope and
methodology which would be used to carry these s tu,dies out. The Acres
American representative stated that the level of detail that we were
looking for would be found in their yet to be published procedures
manuals. ~-le agreed that it would be appropriate for Acres American to
provide copies of these procedures manuals to members of the Steering
Committee for their review and comments. The following procedures
manuals were provided by Acres American for our review:
Sub task 7.05 Socioeconomic Analysis
Sub task 7.06 Cultural Resources Investigation
Suhtask 7.07 Land Use Analysis
Sub task 7.08 Recreation Planning
Eric Yould 2 Nc~mber 21, 1980
Subtask 7.10 Fish Ecology Impact Assessment and Hi.tlgation Planning
Subtask 7.11 Wildlife Ecology (Big Game Impact Assessrr.ent and Mitigation
Planning, Fur Bearers, and Birds and Non-Game HamT!'.als)
Subtask 7.12 Plant Ecology
Subtask 7.14 Access Road Analysis
The following agencies were provided copies of the procedures manuals
and have responded with revieH· comments: Alaska Department of Environmental
Conservation, Alaska Department of Fish and Game, Alaska Department of
Natural Resources, U.S. Geological Survey, National Marine Fishery
Service, Heritage Conservation and Recreation Service, U.S. Fish and
Wild life Service, and the Arctic Environmental Information and Data
Center. The following.is a synthesis of the comments from these
agencies. Appended to this letter are copies of the written comments
which were received from those agencies identified above.
SUBTASK 7.05 SOCIOECONOHIC ANALYSIS
Review of the procedures manuals indicates that "this study may not
address the indirect but highly significant impact of construction and
operation of the project on residents living in the region. The boom
that occurred during the construction of the Trans-Alaska Oil Pipeline
(TAPS) gives us an insight into the sorts of impacts that may be
expected. For example, traffic congestion, strip development of small
communities, stores out of necessary goods and materials because of
accelerated demand by construction. In order that the socioeconomic
impact studies may be more comprehensive and address these sorts of
impac~ts we make the follmving seven recommendations:
1. Local and regional recreational facilities and opportunities
should be assessed to determine the ability of those facilities
to handle additional users in light of increased demand.
2. The study should address the probability of additional
industrialization of the region as a result of pmver from the
project. Then the study needs to assess the impacts and
socioecomomic implications of industrialization scenarios that
would be driven by this project.
3. The study should address the cost and availability of products
and services. This should also address the inflationary impacts
that are.usually associated with a boom type cyclical expansion
such as construction of a project of this magnitude may cause.
4. The study should address the cultural opportunities and how they
may be affected in both positive and negative ways by the proposed
project.
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Eric Yould 3 Nt.-••·~mber ,21, 1980
5. The study needs to address the implications of the project on a
composition of the people who live in the region. An obvious
6.
7.
first step would be to establish baseline survey data in the
preconstruction era so that we know ~.mat the population composition
is in this area before construction begins.
An assessment of the changes in the sociopolitical structure of
the region that could be expected result from the change in the
economy as a result of construction an operation and ~ubsequent.
developments that would be driven by this project.
The analysis does not address the impacts .of. the. project on users
of fish and wildlife resources. I refer you here specifically to
memos included in the Department of Fish and Game revie~" submittal
which indicate that Acres and others deemed rt inappropriate for
the Department of Fish and Game to carry these studies out.
However, in our revie\\1 of all the s tud.i.es identlf led above we
find that neither Acres American nor any of other of the sub-
contractors have included this important issue ln th.eir plan of
work. The scope of the analysis does not include any work designed
to mitigate the project impacts on fish and wildl.if.e.
SUBTASK 7.06 CULTURAL RESOURCES INVESTIGATION
Although this study ~ras not formatted or laid out in a way similar to
the others the review comments indicate that the approach in the scope
and methodology proposed. is appropriate and sufficient f0r the task at
hand.
SUBTASK 7.07 LAND USE Al.~ALYSIS
The follovling comments were made:
l. The scope of the land use analysis needs to be expanded so that
the downstream impacts all the way to salt water are adequately
addressed. As an example of a downstream impact which is not
included but needs to be addressed is the is sue of navigab Ui ty
on the Susitna River below the proposed dam.
2.. There is no apparent linkage or coordination between the land use
analysis and the socioeconomic and recreational studies.
3. APA should seriously reconsider the decision that has been made
to delay future land use analysis. The contractors state that
data from other disciplines may be needed to "fine tune" this
study. However, we can assume most of these values or issues and
get on with one of the most critical studies that could provide
data to be used in making the decision as to whether Susitna
should be built or not. It is recommended that APA consider the
use of-scenarios to describe future land use with and without the
project.
Eric Yould 4 NL~mber 21, 1980
A recommended way to begin addressing dotmstream impacts is to
become informed about the work currently being done in thls area
by local, state, and federal agencies. This will help to elLminate
any dup licatlon of work. Once APA Ls atv-'lre of 1•lu1 t studies ·
agencies,have done the APA contractors can be tasked to synthesize
the existing studies and complete only additional studL:s needed
to complete the scenarios.
SUBTASK 7.08 RECREATION PLANNING
1. Scope of the recreation planning appears to be incomplete. The
total thrust of the study appears to focus on recreational opportunities
Ln the impoundment area with the obvious underlying assumption
that Susitna Dam will be built. ~.Jhat is absent Ls any sort of
assessment of the proposed project lmpacts on exlstlng recreation
navigation and land use in the river valley above, within, and
below the proposed project. There Ls no question that we have to
carefully plan for reservoir recre~tion development assuming
there is a project. It is also obvious that the compelling need
that needs to be met today ls a valid and accurate determination
of existing recreational values so that this decision can be
factored into the ultimate decision as to whether Susitna should
be built or not. An equally important result 'muld be Identification
of those values for mitigation which will be required if the
project is built.
2. This study needs to include a documentation of the flowing water
resources and uses that •·muld be impacted by the project.
3. This study needs to document the existing upstream uses of Susitna.
SUET ASK 7.10 FISH ECOLOGY U:!PACT ASSESSl-fENT At\lD HITIGATION PLA..l,JNING
1. It is acknowledged that none of the reviewers had a comprehensive
picture of how this task will be carried out. The reason is the
Department of Fish and Game will be actually doing much of this
work as a subcontractor to Acres American and has not had the
staff or the resources necessary to put together its procedures
manual for this facet of the work. The comments given below
should be qualified with acknowledgement of this fact.
2. The contractors need to broaden their scope of mitigation concepts
tha are included in the studies. There are other options available
for mltigation planning above and beyond wh.:tt is included 1n the
procedures manual as it is nm.r ~rritten. I refer you to the
detailed comments made by ADF&G.
3. We recommend that an assessment of effectiveness of mitigation
used on other projects to reduce impacts also be studled before
we determine what sorts of mitigation techniques will be applied
to the proposed Susitna project. The reason for recommending
this is to enhance the pr.obability that the mitigation ~ve apply
to the Susitna project will be successful.
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Eric Yould 5 N~~mber 21, 1980
4. Table 2 should be amended to identify the issue of the effect of
the project on rearing. fish passage and egg I.ncuhati.on in the
Susitna River from its mouth upstream to the proposed dam site .•
5;, The mitigation alternatives should include a cost benefit analysis
in phase 2.
6. There is a lack of adequate participation by resource management
agencies in the impact assessment or mitigation planning as
proposed in this procedures manual.
7. The water quall ty subtask within this study needs further revieto~
regarding the extent of data required and details about timing of
the data collection~
SUBTASK 7.11 WILDLIFE ECOLOGY
A. Big Game Assessment and Mitigation Planning
1. This study does not describe the methodology that \-lill be
used for assessing impacts to be mitigated. The procedures
manual discussion of formation of a mitigation team and a
series of meetings and conferences as a. methodology is
inadequate.
2. The scope of mitigation concepts needs to be broadened in
this study. The National Environmental Policy Act (NEPA)
defines mitigation in five different ways:
a.
b.
c.
d.
e.
Avoiding impact all together by not taking a certain
action of parts ~f an action.
Minimizing impacts by Hml tlng the degree or magnitude
of the action and its implementation.
Rectif iying the impact by repairing, rehabilitating, or
restoring the effected environment.
Reducing or limiting _the impact over time by preservation
and maintenance operations during the life of the
action.
·compensating for the impact hy replacing or providing
substitute resources for environments.
Since the Sustina project will be subject to an environmental
impact statement the Alaska Power Authority should
assure that the contractors preparing the application
adequately address all aspects of mitigation in ordet
that the submittal will be adequate fo,;r the E.I.S.
Eric Yould 6 Na:-~mbe.r 21, 1980
B~ Wildlife Ecology -Fur Bearers
l. Scope of these studies needs to be extended to salt water.
The reason is the proposed Sus.i.tna hydropower project will
have impacts all the way to salt ~•a ter.
2. This manual does not acknowledge the need for mitigation for
these living resources. It is recommended that the procedures
manual be revised to reflect the need for mlt igation for fur
bearers.
3. The manual describes surveys which will he done only in the
winter. The seasonality of this approach will result in
certain data biases and lack of data for the intervening
months.
4. The studies state that radio collaring of animals will be
done. Hmv will the radio collar data be used?
C. Wildlife Ecology -Birds and Non-game Hammals
1. The scope of these studies needs to exteno to satt water.
2. The procedures manual falls to acknowledge the need for
mltigation of birds and non-game animals. It is recommended
that the procedures manuals be revised to reflect this need.
General comments on wildlife ecology procedures manuals.
There is a compelling need to integrate the ,.,ildlife and the
plant ecology studies so that the end results are meaningful and
useful to the decisions which will be made. Each of these study
elements should apply appropriate quantitative methodologies to
evaluate animal habitats. The methodology used may depend on the
characteristics of the species or group of species they are
d~aling with. ~.Jhatever method is adopted, it must be biologically
justifiable and provide a relative estimate of the habitat value
per area unit for the study area.
SUBTASK 7.12 PLANT ECOLOGY
l. The scope of these studtes needs to be expanded from the dam site
all the way to salt water. The reason for this is that construction
and operation of the dnm will impact vegetation to that extent.
2. TI1ere needs to be a high level of integration and coordination
between the plant ecology, hydrology, and thewildlife impact
assessment studies. This is because a great part of the wild life
impact mitigation will be based on vegetation.
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Eric Yould 7 NL~mber 21, 1980
3. The definition of wetlands used for classifying habltats should
be compatible with data already collected in the Susltna Basin by
the cooperative study undenmy with DNR, ADF&G, and SCS. \ve
recommend that the classification system developed by the U.S.
Fish and Wildlife Service and described in "Classification of
\-letlands and Deep Water Habitats of the United States" (F~>lS/OBS79/31)
be considered as the wetland classification for these studies.
SUBTASK 7.14 ACCESS ROAD ANALYSIS
1. The analysis of alternatives does not indicate whether stream
·crossings will be reviewed to determine extent of icing and
adverse environmental impact as a result of crossing these streams.
Stream crossing and structures should be designed to avoid creating
icing and erosion problems.
2. This analysis should include assessing the effects of an increase
in fishing due to newly opened road access as part of its scope
of work.
3. There is an obvious linkage between access roads for this project
and land use/fish and wildlife studies. Review of the manuals
does not indicate that the appropriate process or-mechanism is in
place to see that this occurs. ·
GENERAL COHMENTS
It is the consensus of the Steering Committee that each study task
procedures manual should include two maps:
1. A map that delineates the boundaries of the specific study tasks
described in the respective manual.
2. A second map delineating the overall study area, ie from the
mouth of the Susitna River to the Denali Highway.
SUHHARY
In conclusion, the above comments should be considered as summary
comments designed to flag the most significant and compelling issues
which require correction or rectification in order to assure that the
procedures and approaches used in the studies will yield the answers
necessary to make the most infonned and best decision regarding the
proposed Susitna project. The Steering Committee members believe the most
compelling need is for a well-conceived process to improve the linkage
and·coordination of the various studies •. This is particularly true in
several of these studies where one element .ls dependent upon f.lndlngs
of other studies. · An example is the need for fisheries impact mitigation
to be built upon the assessment of the existing fishery resources and
the instream flow/hydrology studies. TI1e recognition of the sequential
nature of this process is lacking in the procedures manuals reviewed.
Eric Yould 8 N~mber 21, t-9-&e
He also ~•ould like to emphasize the importance o[ the relationship
between the ultimate design of the procedural manuals and a particular
study product; that product being identification of and development of
mitigation measures for the human and natural resources being studied.
1-Je have recommended several times above that mitigation be added or
broadened in scope on a resource by resource basis. This concern is
based on our collective experience in assessing the adequacy of the
mitigative features of countless environmental statements; they are
often very weak in this critical area. As the mitigation efforts may
be a key to assessing the feasibill ty of this project and a key to the
success of the environmental statement that may follm-T, we urge you to
integrate "mitigation" into all systems designed to assess human and
natural resource impacts.
Sincerely,
ill~
Al Carson
Chairman Susitna Rydro Steering Committee
cc: Steering Committee Members
Reed Stoops
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MEMORAf\JfbUM
To SUSITNA HYDRO ELECTRIC
STEERING COMMITTEE MEMBERS ·
(See Distribution List)
QL
FROM AL CARSON
Steering Committee Chairman
Statl of Alaska
DEPARH1ENT OF NATURAL RESOURCES
DIVISION OF RESEARCH & DEVELOPMENT
DATE: October 29, 1980
FiLE NO.
TfLEPHOt-JE ~10:
suBJECT November 5, 1980 Meeting
There will be a meeting of the Steering Committee at 8:30A.M. on vJednesday,
November' 5, 1980 at the University of Alaska Anchorage Campus Center
Executive Conference Room. The Campus Center is located approximately 3
blocks east of the corner of 36th Avenue and Lake Otis off Providence.
Attached is a sketch showing the location of the conference room on the
lower level.
T~put·pose of this meeting is:
(1) To finalize Steering Committee review comments on the
procedures manuals used by ACRES and their contractors.
(2) To comment upon ACRES approach to identification of
power alternatives in the railbelt. Attached please
find a packet of information for your revie~t before
the meeting .
(3) To identify any other tasks or actions that the members
of the steering committee wish.
The 8:30 A.t~. to Noon session will be devoted to items 1 and 3. The 1:oo·
to 5:00 P .r~1. session wi 11 address i tern 2.
Please give this meeting your highest priority for 11/5/80. Your partic-
ipation is vital if our effort is to be successful.
DISTRIBUTION LIST
Don McKay
U. S. Fish & Wildlife Service
733 W. 4th Ave., Suite 101
Anchorage, Alaska 99501 ·
Tom Trent
AK Dept. of Fish & Game
333 Raspberry Road
Anchorage, Alaska 99502
John Rcgo
Bureau of Land Management
Anchorage District Qffice
4700 E. 72nd Avenue
Anchorage, Ala~ka 99502
02-0CJ.:>.(Rev.10t79k
OCT 30 1980
;~ POWEk AUinUJdfY.
SUSITNA HYDRO ELECTRIC
STEERING COMf~ITTEE MEMBERS
DISTRIBUTION LIST CONTINUED
Bob Lamke
U. S. Geological Survey
Water Resources
733 W. 4th Ave., Suite 400
Anchorage. Alaska 99501
Bill Wilson or Chuck Evans
Arctic Environmental Information
and Data Center (U of A)
707 11 A" Street
Anchorage, Alaska 99501
Dave Sturdevant
Dept. of Environmental Conservation
Pouch "0"
Juneau, Alaska 99811
Larry Wright or Bi 11 \·Jel ch
Heritag~ Conservation and
Recreation Service
1011 E. Tudor Road. Suite 297
Anchorage, Alaska 99503
Brad Smith or Ron Morris
National Marine Fisheries Service
701 "C" Street, Box 43
Anchorage, Alaska 99513
Attachments
bee: R. Stoops -R&D
D. Wozniak -A.P.A.
October 29, 1980
Page 2
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t'lr. John Lawrence
Attn: Kevin Young
Acres ~~~rican, Inc.
900 liberty Bank Building
Nain @ Court
Buffalo~ t1e~>J York 14202
Dear Kevin~
ALASKA POHER JI.UTHORITY
r·lovember 26 , 1930
Attached 1s the finished version of the Susitna Hydroelectric Steering Com-
mittee findings to the Task 7 Procedures f4anuals. A working draft was presented
to us during the November 5, 1980 meeting; this version incorporates comments made
at that meeting. AS you will see, it differs from that ~rorking draft 1n minor
deta11 only. Also attached are agency source documents, resources previously un-
available to us.
As I sunmar1 zed to the Steer1 ng Coomi ttee at the flovcmber 5 meeting. the
Po!tJer Authority considers the majority of the comments to be reasonable, help-
fult and worthy of immediate incorporation. He accordingly solicit your posi-
tive approach to accOffimadation of the Steering committee comments and reccmmend-
ations.
I suggest we very quickly address the acceptable recommendations and then move
on to focus our energies on those that require detailed evaluation. To insure \·le
are in agreement, I suggest you advise us on a point by point basis those comments
you rccor:ur.end accepting, with. narrative as to method of incorporation. In separate
correspondence. advise us of those camtents for which you have reservations, and
your reco.'I1il'.endations thereto. In view of the fact that He have been pr1vy to the
Steering Committee thinking since early November. you should be able to do this
~tell before the Christmas Holidays. Such a timetable \'1111 hopefully facilitate
early resolution of all the comments fn time for a report to the Steering Commit-
tee at their next convening.
FOR THE EXECUTIVE DIRECTOR
Attachment: As noted
Sincerely,
David ~!ozniak
Project Engineer
cc: J. Haydel.. Acres Buffalo w/o attachment
J. Gill~ Acres. Anchorage. w/o attachment
CONCUR
RAM
A. Carson. Department of Natural Resources, Anchorage. w/o attachment
!~ark Robinson. FERC~ 825 N. CapitOl St., NE. Washington, D. C. 20426
~1FR: Next convening tentative1y scheduled for Februrary, 1981.
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ALASKA PO\~ER AUTHORITY
f.1r. A 1 Carson
State of Alaska
Department of Natural Resources
323 E. 4th Avenue
Anchorage, Alaska 99501
Dear Al:
f~ovember 26, 1980
Thank you for your efforts in pulling together the Susitna Hydroelectric
Steering C0111nittee review of the Task ,7 Procedures nanuals. I have fonnally
forwarded ... he conF.ents to Acres American, Inc., with instructions to act prompt-
ly on the h~COlmlendations. 1 anticipate the vast ma.1ority 1r1ill be considered
by the end of the year, with the remainder addressed shortly thereafter.. I am
planning on giving a report on their dfspositfon at the next convening of the
committee, which I am assuming w111 be 1n February, 1981.
Once again, thanks to you and your comnittee members.
FOR THE EXECUTIVE DIRECTOR
cc: Don HcKay u. S. Fish & Wildlife Service
733 W. 4th Ave., Suite 101
Anchorage, Alaska 99501
Tom Trent
Alaska Department of F1sh & Game
333 Raspberry Road
Anchorage~ Alaska 99502
John Rego
Bureau of land Management
Anchorage District Office
4700 E. 72nd Avenue
Anchorage, Alaska 99502
Bob Lamke
U. S. Geological Survey
l1ater Resources
733 W. 4th Ave., Suite 400
Anchorage, Alaska 99501
Bill Wilson or Chuck Evans
Arctic Environmental Information
and Data Center (U of A)
707 MA" Street
Anchorage, Alaska 99501
Sincerely,
David t~ozniak
Project Engineer
CONCUR
RAM
Nr. Al Carson
November 26, 1980
Page 2
Dave Sturdevant
Oepartrne~t of Environmental ConserJat1on
Pouch uo"
Juneau, Alaska 99811
larry Wright or Bill Helch
Heritage Conservation and
Recreation Service
1011 E. Tudor Road, Suit~ 297
Anchorage, Alaska 99503
Urad Smith or non norris
Nationa1 i4ar1ne Fisheries Studies
701 "C .. Street, Box 43
Anchoragr~, A 1 aska 9'3513
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ALASKA POtiER AUTHORITY
r.tarch 25, l9i31
Hr. Al Carson
Chainnan, Susitna liydro
Steering Corrm11ttee
A 1 aska Department of f~atura 1 Resources
323 East 4th Avenue
Anchorage~ Alaska 99501.
Dear !1r. Carson:
I regret that it has taken so long to react to the Steering Corrm1ttee's
suggestions on improving the Susitna hydroelectric project environmental plan
of study. It took a number of months for Acres and its subcontractors to de-
velop and transmit their set of responses and plan of. action. The Power
Authority received that transmittal on March 2~· 1981. ~le have not been able
to make any final decisions on scope changes, however, for hio reasons. First.
Acres. has not yet provided the program modification suggestions in any detail
of scope or cost. Secondly, the Power Authority has had to '~a1t for other
program components {such as Tasks 4 and 5) to be evaluated for necessary scope
changes. It is only 1n revi(!Wing the entire first year program that we can
identify area,s for improvement~ assess their cost impact, evaluate their rela-
t he rr.er1 t and es tab 1 i shed prf ori t1 es among the myrf ad competing needs.
The Power Authority will have prepared its set of recommended scope changes
and resultant supplementary budget request by Aprfl 3~ 1981. It remains to be
seen whether all, none or a portion of the supplemental funds will be forthcom-
ing.
I have requested previously that you organize a Ste~ring Coomittee meeting
for eitl1er April 13. 14, or 15. At thfs meeting. we ~111 present our proposed
program ~rl0d1f1cat1ons. which I trust you wi 11 find go a long way toward satisfy-
ing the Coumfttee's concerns. In preparation for that meeting,. I have attached a
copy of the Acres response to the Steering Comn1ttee conments. The detailed re-
corn:r..endations, while not contained in the attachment. will be presented at the
Steering Cmnm1ttee meeting.
FOR THE EXECUTIVE DIRECTOR
Attac~~nt: As stated
cc: Susitna Hydro Steering CO!ml1ttee f1embers
with attachment
Sincerely~
Robert A. Hohn
01rect~r of Engineering
In response to the Susitna Hydro Steering Committee's review of the TES pro-
cedure manuals we submit the following:
Introduction
We appreciate the time and effort expended by all the members of the Steering
Committee in their review of our procedure manuals. In general our responses
are 1Trect eci towards each of the specific comments as presented in the
sythes.is prepared by t·1r. Al Carson. Comments presented in the introduction
and conclusion are addressed first f'.s appropriate our response to some comments
are combined to present a clarification regarding subtask interactions.
General Comments
1} In defense of our subcontractors it was nat our understandinQ that the
purpose of July 17, 1980 meeting.was·to review the environmental studies
but rather to compare the requirements of FERC to other federa 1 and state
government permitting agencies. rn this context an overview of our
environmental program was pr-esented. ~Je concur that· in some of the more
controversial areas i.e. socioeconomics, adequate study details were not
avai1able. ·
The. offer \'las then extended, and agreed to by the Steering Committee, that
procedure manuals be made available for review.
2) As the Steering Conimittee have stated "the most compelling need is for a
\o~ell-conceived process to improve 1 inkage and coordination of the ·various
studies." \-le concur that this is e!:sential and have expended conside1·able
effort in this direction. Some misunderstanding may have precipitated
from the revie\·1 of the procedure manuals as these manuals were prepared
as practical subtask-specific documents designed for (1) exchange of
program design details (2) control of adhei·ence to the study program
(3} and assurance of continuity in the event of changes in oroject per-
sonne 1.
Our coordination efforts will concentrate on the following areas:
1)
2)
3)
interaction among study participants
infonna.l interaction with government agencies to acquire insight
into concerns and general policies -
forma1 interaction with government agencies to allow input and
revie'"' of study design, development selection. project design and
mitigation planning
4)" interaction \"'ith the public in the form of information supply and
input into the decision making process
Documentation of coordination to date will be included in the environmental
annual reports to be available in April 1981. rn addition we have requested
TES. to prepare an outline of their coordination process which will be supple-
mented by Acres and supplied to the Steering Committee for review if desired.
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3) An area of primary concern appears to be the extent of effort directed
towards studying the Lower Susitna Bas in bet;,1een Talkeetna and Cook Inlet
during the Phase. I period.
Our approach to date as outlined under Subtask 3.10 of our POS is ~to
estimate the flow regime, sediment regime and morphological characteristics
. of the lower Susitna River under natural conditions and (prepare) a
preliminary determination of morphological impacts which could result.
from flow regulation and sediment trapping at the Susitna Project."
"A preliminary evaluation of the .potential morphological changes, and
impact on the river cha·racteristics due to flow regulation will be made
during the early part of 1981. If considered necessary at this stage, an
expanded field data collection and study·proqram aimed at evaluating
impacts in more .. c1e.tai1 w911 be developed in conjunction with the DNR and
presented for consideration to APA."
It is our opinion that the results of this study are necessary before
the ~rits of any detailed downstream studies can be fully assessed.
It is obvious that we require a more comprehensive understandin'J of the
resource a.genci es concerns, the reasons for these concerns and the study
approach they would like us to adopt. To facilitate this TES during the
nw:'nth of March 1981 will contact the respective agencies directly, to
d1 scus ~-these ·.and any other concerns that may exist.
7.05 Socioeconomic
Although major projects like the Trans-Alaska Oil Pipeline provide justification
for the need of adequate preproject soicoeconomic analysis, care must be taken
in making direct comparison as to the types of impacts associated \'l'ith a large
centralized project such as Susitna vs a transient type construction associ a ted
with a pipeline. Susitna should produce a relatively self contained, controlled,
centralized work camp established for a 10 -IS year period. For this reason a
first step in our socioeconomic program, through a review of other similar
type projects, is to identify the most probable types of impacts to be antic-
ipated. Our studies will then concentrate on the~e areas of most probable
impact.
We have. hoWever, for some time been considering the need to advance some of
the Phase II socioeconomic studies into Phase I. The extent of changes in
scope and timing of our studies will be discussed in more detail with the
Steering Conr.tittee and FERC fo·llowing their review of these responses.
To present a .clarification as to the comprehensiveness of our socioeconcimic
program a listing of categories and variables being incorporated into our
socioeconomic profiles is attached (Exhibit 1). This listing is refered to
in our response to the seven Steering Committee comments.
Conment 1:
Local and regional recreational facilities and opportunities should be
assessed to determine·the ability of those facilities to hand-le additional
users in light of increased demand.
Response:
Recreational facilities \vill be addressed on two fronts within the
context of the Socioeconomic Analysis during Phase I. \·fork Package
2 entails development of a detailed socioeconomic profile, the
methodology for which is described on pages 7-10 in the Procedures i·tanual.
" ... The profiles will include ... public facilities, availability,.
adequacy, and cost ... ". This includes public recreation facilities. To
the extent applicable in Phase I, this analysis will address the "ability
of those facilities" at local and reg_ional levels to handle additional
users" as suggested by t!ie Steering Committee.
Additinally·, we have become aware of a special study currently underway
.by t~at-~u Borough, the resul.ts of which will be considered as an aid in
·our analysis. Recreational categories and variables to be investigated
are shown in Section VIII Exhibit I.
Cormnent 2:
The study. should address. the probability of additional induS:trialization
of the region as a result of power from the project. Then the study
needs to assess the impacts and socioeconomic implications of indus-
trialization scenarios tht3:t would be driven by this project.
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Response:
In our evaluation of the economic base we will be deveroping a profile
of tre·major basic industry components. (Exhibit I section V) ~le "Vti'11
review potential .incenti.ves for industrial development created by stable
energY. availability and assess the socioeconomic implications of having
these incentives materialize.
Comment 3:
The study should address the cost and availability of products and
services. This should also address the inflationary impacts that are
· usually associ a ted wi·th a boom type cycli:c.al expansion such as con-
struction of a project of this magnitude may cause.
Response:
The availability of products will be addressed under the headings of
wholesale trade, retail trade, services etc. as indicated in Exhibit I
section V. The· cost and relationship of cost to income wi 1.1 be addressed
through our assessment of the Consumer Price Index, in-come and employment
patterns (Exhibit I section VI). ·
Coament 4:
The study should address the cultural opportunities and how they may
be affected in both positive and negative ways by the proposed project.
Response:
Our present study addresses cultural opportunities under the categories
of:
H Conmunity organizations, social interaction, entertainment
etc. (Exhibit I section II) ·
2) Public services-parks, recreation, libraries, education.
(Exhibit l section IV)
3) Recreation -Exhibit I section IV}
We do appreciate, however, through your comments and co~m~ents from the general
public that cultural aspects, especially at the local level, are not being fully
addressed. · .We at"e preparing the deta i1 s of a program to respond to this and
will Present it to the Steering Committee an outline of our scope as soon as
it is available.
Comment 5:
The study needs to address the implications of the project on a com-
position of the people who, live in the region. An obvious first step
would be to establish baseline survey data in the preconstruction era
so that we know what the population composition is in 'this area before
construction begins.
4
Response:
As stated in the procedure manual, a purpose of Phase I socioeconomic
studies is to 11 identify and describe the existing socioeconomic conditions
and to determine which are most likely to be impacted by the Susitna
Hydroelectric Project". Sections I and II of Exhibit I identify the
categories for which secondary data on the composition of the people
who 1 i ve in the region wi 11 be co 11 ected. The adequacy of this· data base.
will be reviewed prior to making any decisions regarding program modi-
fications.
Conr.tent 6:
An assessment of the changes in the sociopolitical structure of the·region
that could be expected (to) result from the change in the economy as a·
result of construction .•. (and) operation and subsequent developments that
would.._be driven by this project.
Response:
Our study.efforts are directed towards an assessment of the socioeconomic
changes that could result from the project. In this context we will be
assessing impacts on local governr.tent ser..-ices, revenues and expenditures.
In our opinion •. however, an assessment as to changes in the soci opo 1 i ti ca 1
structure of the region resulting from these socioeconomic changes would
be very speculative, not cost effective and ·beyond the requirements for
a license application. ·
Conment 7:
(a)
(b)
(c)
(d)
The analysis does not address the impacts of the project on users of
fish and wi ldi i fe resources.
I refer you here specifically to memos included in the Department of
FishandGame review submittal which indicate that Acres and others·
deemed it inappropriate for the Department of Fish and Garne to carry
these studies out. .
However, in our review of all the studies identified above we find
·that neither Acres American nor any of other of (sic) the subcontractors
have included this important issue in their plan of \·tork.
The scope of the analysis does not include any work designed to mitigate
the project impacts an fish and wildlife.
Response:
(1) Due to the sequential nature of our studies the analysis of the impacts
of the project on users of fish and wildlife resources cannot be accom-
plished until the impacts on the resources themselves have been 1dentified.
As indicated in the procedure manual, .,.1orlc packages 8 and 9 dealing with
these topics will be performed in detail during Phase II.
(2) \~e did deem it inappropriate that AOF&G, cr any other permitting agency
conduct the impact assessment and mitigation planning components of our
study. To do otherwise.would have compromised the legitirnacy of agency
objectivity during license review. However under all the components of
our study we intend to provide a format for revie>rl and consideration of
all potential concerns from appropriate State and Federal agencies
5
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{3} Refer to response 1.
(4) Fish and wi-ldlife mitigation is not considered as a socioeconomic com-
ponent of our study but is addressed in detail under Subtasks 7:10 and
7:11 as indicated in the procedure manuals.
Subtask 7.06 Cultural Resources Investigation
Comment:
Although this study was not formatted or laid out in a 'ltay similar to
the others the review comments indicate that the approach in the scope
and methodology proposed is appropriate and sufficient for the task at
hand.
Response:
No corrmen t.
Subtask 7.07 Land Use Analysis
Comnent 1: .
(a) The scope of the land use analysis needs to be expanded so that the
downstream impacts all the way to salt water are adequately addressed.
(b) As an example of a downstream impact which is not included but needs to
be addressed is the issue of navigability on the Susitna River below the
proposed dam.
Response:
(a)
(b)
As stated in our procedure manual our study area for land us·e is con-
centrated in the Upper Susi tna Bas in· and extends downstream as far as
Gold Creek. In our opinion the majority of 1 and use impacts directly
related to a Susitna development will occur in this area. Certain land
use components outside this study area are being addressed as part of
our socioeconomic, fisheries and wildlife studies.
As you are aware concern has been raised regarding recreational navigation,
and riverine based recreational/1and use activities in the section of the
river between Talkeetna and Cook Inlet. We are in the process of
assessing these concerns and foresee the possibility ~~an extension to
our fisheries and hydrology studies a program to identify: 1) access
to the river by water, air and land and 2) movement within the river
itself. Any such study would provide input into the land use, recreation,
socioeconomic and fisil/wildlife··resource utilization .components of our
study. The details-o{any such ._ program modificationWT11 be submitted
to the Steering conmittee for review as soon as available.
Comment. 2:
There···is no apparent linkage or coordination between the land use
a·nalyslS and the socioeconomic and recreational studies.
6
Response:
There is a definite linkage and coordination between land use, socio-
economic, recreation, hydrology, and fish and 1·1ildlife components of
our study. Although this coordination exists at the study team level
it is ··bvious that a lack of communication does exist between the study
team and the resource agencies.
Throughout the remainder of the Susitna studies we \·till be exerting
considerable effort to bridge this gap and will be soliciting your
advice on means of-establishing efficient avenues of communication.
Comment 3:
APA should seriously·reconsider the decision that has been made to
delay future land use analysis. The contractors state that data from
other disciplines may be needed to "fine tune" this study. However,
we can assume most of these values or issues and get on with one of the
most cri·tical studies that could provide data to be used in mak{ng the
decision as to whether Susitna should be built or not. It is recoll1ll~nded
that APA consider the use of scenarios to describe future land use with
anc'l without the'project. A recorrmended way to begif!, addressing down-
stream impacts is to become informed about the work currently being done
in this area by local, state, and federal agencies. This will help to
eliminate any duplication of work. Once APA is aware of what studies
agencies have done the·APA contractors can be tasked to synethesize the
existing .studies and complete only additicnal studies needed to complete
the scenarios.
Response:
We accept the Steering Committee's recommendation that we review and
synthesize the information available from existing studies being con-
ducted by local, state and federal agencies. This has been accomplished
to some extent by our socioeconomic, land use and recreation consultants
however, we will ensure, through additional contact, that all available
information has been acquired. Once obtained we will assess the applica-
bility of these studies to the Susitna Project, incorporate the infor-
mation into our studies as appropriate and determine if additional studies
during Phase II are required.
We do, however, identify the need for a recognition of the differences
in-objectives and scope between a Susitna Project Environmental Assess-
ment study and studies conducted by agencies under their mandate of·
overall Susitna Basin Resource Management.
Subtask 7.08 Recreation Planning
Corrments:
L Scope of the recreation planning appears to be incomplete. The tote:!
thrust of the study appears to focus on recreational opportunit·le:s .'
·the impoundment area with the obvious underlying assumption that SusJ ~~n,~
7
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Dam will be built. \~hat is absent is any sort of assessment of the
proposed project impacts on existing recreation navigation and land
use in the river valley above, within, and below the proposed project.
There· is no question that we have to carefully plan ·for reservoir rec-
reation development assuming there is a project. It is also obvious
that the compelling need that needs to be met today is a valid and.
accurate determination of existing recreational values so that this
decision can be factored into the ultimate decision as to whether Susitna
should be built or not. An equally importcmt result would be identification
of those values for mitigation which will be required if the project
is built.
2. This study needs to include a documentation at the flowing water
resources and uses that would be impacted by the project.
3. This study needs to document the existing upstream uses of Susitna.
Response;
He have made a clear distinction between 1) · FERC requirements for the
development of a recreation plan within the project boundaries and
2} an overall assessment of recreation resources and impacts on these
resources.
Subtask 7;08 responds.directly to FERC requirements and is directed
towards a reservoir recreation plan that would be ir!lplemented if a
Susitna development is approved. Thus the study focus is on recreational
opportunities in the impoundment and surrounding area and does assume
that the plan would only be implemented if the Susitna dam is bui 1 t.
. o--cR~ --..Rr-:r. --
The assessment of existingArelreation resourcesAand the impacts upon
them are addressed under appropriate subtasks, specifically 7:07 -
Land Use Analysis and 7:05 Socioeconomic.
Subtask 7:10 Fish Ecology Impact Assessment and Mitigation Planning
Conment 1:
It is acknowledge.d that none of the reviewers had a~:~omprehensive
picture of how this' task will be carried. out. The ~eason is the
Department of Fish and Game will be actually doing much of this work
as a subcontractor to Acres American and has not haa the staff or the
resources necessary to put together its procedures manual for this facet
of the work. The comments given below should be qualified with ac-
knowledgment of this fact.
Response:
AOF&G have made substantial progress in their fisheries data collection
program. The present emphasis is to establish the basis of their
program and to implement the field studies. Follo.,.ling this, detuiled
procedure manuals will be prepared and should be available for Steering
Committee review by April 1981.
8
Corrvnen t 2 :
The contractors need to broaden their scope of mitigation concepts that
are included in the studies. There are other options available for
mitigation planning above and beyond what is included in the Procedures
Manual as it is now written. I refer you to the detailed comments made
by AOF&G.
Response:
We view mitigation planning as a dynamic process and are prepared to
consider any additional options available. As a means of obtaining
agency~input and review we plan to establish a fisheries mitigation task
force similar to that organized under Subtask 7.11.
Comment 3:
We recommend that an assessment of effectiveness of mitigation used
on other projects to reduce impacts also be studied befor~ we deter-
mine what sorts of mitigation techniques will be applied.to the proposed
Sus itna project. The reason for recommending this is to enhance the
probability"that the mitigation we apply to the Susitna project will
be successful. ·
Response:
The intent of our review and evaluation of ~itigation measures used
on other projects is to assess their effectiveness and to determine
their applicability to the Susitna Project.
Corrment 4:
Table 2 should be amended to identify the issue of the effect of the
project on rearing, fish passage and egg incubation in the Susitna
River from its mouth upstream to the proposed dam site.
Response:
It is our intent to address these issues and Table 2 will be ammended
accordingly.
Comment 5:
·The mP.igation alternatives should include a cost benefit analysis in
Phase II.
Response:
The costs associated with recommended mitigation will be identified in
Phase I with actual cost-benefit analysis considered in Phase II.
9
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Conment 6:
There is a 1 ack of adequate pa rtici pati an by resource management agencies
in the impact assessment or m.itigation planning as proposed in this
Procedures Manu a 1.
Response:
See response to corrment 2.
Conment 7:
The water qua.l ity subtask within this study needs further review
regarding the extent of data required and details about timing of the
data collection. -
·Response:
R&M Consultants has prepared a Procedures Manual for the water quality
program. Review of this document may provide the required deta i1 s about
timing and data collection.
S)J-btask 7.11 Wildlife Ecology
A. Big Game Assessment and,Mitigation Planning
Comment 1:
This study does not describe the methodology that will be used for
assessing impacts to be mitigated. The Procedures Manual discussion
of formation of a mitigation team and a series of meetings and conferences
as a methodology is inadequate.
Response:
The methodology for impact assessment and mitigation \'las not developed
in detail because it was believed that a mare effective program could
be prepared following the collection of data in 1980. Rather than
develop more than a general approach, it \'ias considered to be preferable
first to gain an understanding of the. re·lative population levels of
various· species and also identify critical habitat types. In this
manner a detailed approach to.impact assessment and mitigation will
be prepared. based on at least a preliminary understanding of the wild-
1 ife/habitat rea1tionships operativt! in the project area. The Procedures
Manual will be amended as soon as approach details are finalized.
10
Conment 2:
The scope of mitigation concepts needs to be broadened in this study.
The National Environmental Policy Act (NEPAl defines mitigation· in five
different ways:
a. Avoiding impact all together by not taking a certain action ... (or)
oarts of an action~
b. ~inimizing impa~ts by limiting the rlegree or magnitude of the action
and·its implementation.
c. Rectifying the impact by repairing, rehabil it at ing, or restoring
the ... (affected) environment.
d. Reducing or limiting the impact over time by preservation and main-
tenance operations during the life of the action.
e. Compensating for the impact by replacing or providing substitute
resources •.. (or) environments.
Since the Susitna proj~ct will be subject to an environmental impact
statement the.Alaska Power Authority should assure that the contractors
preparing the application adequately address all aspects of mitigati~n
in order that the submittal will be adequate for the E. I. s.
Response:
To date we have concentrated our mitigation efforts on approaches a) and
b) (avoiding or minimizing impacts) through providing environmental
input into development selection and preliminary design. This approach
will be expanded to include approaches c, d and e following development
selection.
8. \-lildlife Ecology -Fvrbearers
Comment 1:
Scope of these studies needs to be extended to salt water. The reason
is the proposed Susitna hydropower project will have impacts all the
way to salt water.
Response:
The scope of the furbearer studies that concern aquatic furbearers
(e.g. muskrats, beaver, and river otters) have already been extended
on a limited basis downstream to the Delta Islands. At the present time
there does not appear to be justification for extending the study effort
any further downstream. Should the results of Phase I indicate that
further extension is in order, it will be proposed for Phase II.
Corrment 2:
This manual does not acknowledge the need for mitigation for these
living resources. It is recommended that the Procedures t~anua1 be
revjsed to reflect the need for mitigation for furbearers.
11
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Response:
Although mitigation was not mentioned in the Procedures 1-tanual, it will
certainly be addressed in the furbearer studies. In order to strengthen
the interctisciplinary cocrdination concerning mitigation, the Principal
Investigator of the furbearer studies has been added to the mitigation
task force as described in the Big Game Procedures Manual.
Conment 3:
The manual describes surveys \'lhich will be ;done only in the winter. The
seasonality of this approach will result in certain data biases and lack
of data for the intervening months.
Response:
As indicated on page 12 of the Furbearer Procedures Manual, field
activities will be conducted throughout the year and are not restricted
to the winter months. Some of the survey activities that are being
conducted during the non-winter months include locating fox dens,
collecting furbearer scats, and monitoring of radio-collared animals.
Canment 4:
The studies state that radio collaring of animals \vill be done. How
will the radio collar data be used:
Response:
Radio telemetry data will be used to determine the home range size of
key furbearers .. ~ This information, in conjunction with the vegetation
maps, wil1 enable the generation of an estimate of how many animals the
area can normally support. The radio telemetry data are also being
used to determine seasonal distribution and habitat utilization of key
furbea rers.
Note Concerni~g Furbearer Procedures Manua 1:
Since _it was impossible, prior to the initiation of these studies.
to est~blish specitlc techniques that would be highly effective in
sampling the furbearers, ~ny of the techniques outlined in the Procedures
Manual have been modified following the first field season. An amend-
ment to the furbearer manual will be prod~!c:ed in spring, 1981, and will
reflect the refined approach that is now being used.
C. \~il dl ife Eco 1 cay -Birds and Non-qame Mamma 1 s
Corrrnent 1:
The scop~ of these studies needs to extend to salt water.
12
Response:
At the present time, bird and non-game mammal studies are being conducted
as far downstream as Sherman. With the exception of a bald eagle nest
survey, there are no studies planned for this discipline downstream of
Talkeetna. Insufficient data exist to support the conclusion that major
terrestrial impacts wil1 take place downstre·am from Talkeetna. At the
present time, the expenditure of funds to study birds and non-game
mamnals in this area does not appear warranted. Should the results of
the Phase I hydrology ·studies indicate that major changes in terrestrial
habitat are likely to occur, an intensive Phase II program will be imple-
mented. ·
Conment 2:
The Procedures Manual fails. to acknowledge the need for mitigation of
birds and non-game animals. It is reconmended that the Procedures
Manuals be revised to reflect this need.
Response~
Although mitigation was not mentioned in the Procedures ~1anpal, it \·till
certainly be addressed in the birds and non-game mammal studies. In
order to strengthen the interdisciplinary coordination concerning mitigation.
the Principal Investigator for 9ird and non-game mammal studies has been
added to the mitigation task force as described in the Big Game Procedures
t1anua 1.
General Comments on Wildlife Ecology Procedures Manuals
Comment:
There is a compe 11 ing need to integrate the wi 1 dl ife and the plant
ecology studies so that the end results are meaningful and useful
to the decisions rthich will be made. Each of these study elements should
apply appropriate quantitative methodologies to evaluate animal
habitats. The methodology used may depend on the characteristics of
the species or group ef species they are dealing with. Whatever method
is adopted, it must be biologically justifiable and provide a relative
estimate of the habitat value per area un·it for the study area.
Response:
The assessment of impacts will be based to a very large degree on
project-related disturbance of wildlife habitat. Although the inter-
relationships between the plant ecolDgy studies and the various wildlife
studies were not emphasized in the Procedures Manuals, there has been,
and will continue to be, a highly coordinated effort between Subtasks
7 .11. and 7. 12. ·
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Subtask 7.12 P1 ant Eco l agy:
Comment 1:
The s-cope of these studies needs to be expanded from the dam site all the
way to salt water. The reason for this 1s that construction and operation
of the dam wi 11 impact vegetation to that extent.
Response:
Under Phase I, the present intent is to extend ·certai"n of the plant
ecology studies· downstream to Delta Islands. The degree and extent of
impact downstream, especially. below Delta Islands, has not as yet been
defined. The impact downstream wi 11 depend, to a cons i derab 1 e degree,
on the faci 1 ity design and hydrological infonnatian which is not currently
available or not finalized. Far this reason, it was initially decided that
it would be best to wait until the extent of hydrologic impact is known
below the Delta Islands •. before. specific vegetation studies are perfonned
for this region. If studies are warranted below Delta Islands. then they
would be proposed for Phase II.
eonvnent 2:
There needs to be a high level of integration and coordination between
the plant ecology, hydrology, and the wildlife impact assessment studies.
This is because. a 9.reat part of the wildlife impact mitigation will be
based on vegetation.
Response:
He agree that a high level of· integration and coardinati an between the
plant ecology. hydrology, and the wildlife impact assessment studies
is needed. The need for this integration and coordination is stated in
several places in the Plant Ecology Procedures Manual. There is a major
section entitled "Input Required From Other Sources 1
' in which subsections
entitled "Hydrology". and '"Wildlife Infonnati an" are included. The need
for coordination among disciplines is also stated in several of the
Wild1 ife Procedures Manua 1 s and was discussed in detai 1 under the response
to the general corrments under Subtask 7.1!" Wildlife Ecology. In surrr.tary,
we believe that the need for .coordination has been recognized from the
outset. We feel that we. have fulfilled this need to date and plan to
continue to do so throughout the study.
Convnent 3:
The deflnition of wetlands used for classifying habitats should be
compatible with data already collected in the Susitna Basin by the
cooperative study underway with ONR, AOF&G, and SCS. We recommend
that the classification system developed by the U.S. Fish and Wild1 ife
Service and described in 11 C1assification of Wetlands and Oeeo Water
Service Habitats of the United States'' (FWS/08579/31) be considered
as the wet1and classification for these studies.
14
Response:
The classification system developed by the USF&HS for wetlands and
deepwater habitats will be used for the wetlands mapping effort: There
has been some coordination with the SCS concerning wetlands and there
are pl:ns for additional coordination with AOF&G and ONR.
Subtask 7.14 Access Road Analysis
Conment l:
The analysis of alternatives does not indicate whether stream crossings
wi 11 be reviewed to determine extent of icing and adverse envi ronmenta 1
impact as a result of crossing these streams. Stream crossing and
structures should be designed to avoid creating icing and erasion
problems.
Response:
Stream crossings are an important part of the. access route envi.ronmental
analysis and will definitely be considered in routing and later in impact~
and mitigation planning for the selected route. Included in impact
assessment and mitigation planning. will be analysis of designs to avoid
potential ice dam problems during break-up, and associated erosion
problems_ Consideration will also be given to minimizing erosion
problems. Consideration will also be given to minimizing impacts
associated with actual construction of bridge facilities and culverts,
i.e. habitat disturbance and erosion potential.
Comment 2:
This analysis should include assessing the effects of an increase in
fishing due to newly opened road access as part of its scope of work.
Response:
The analysis will include assessing the effects of an increase in
fishing du·e to newly opened road access. The potential impacts on
the fish community and habitat from a biological standpoint will be
addressed under Subtask 7.10, Fish .Ecology Studies, and the recreational
impacts or conditions· resulting from increased access to this area will
be handled under Subtask 7.07, Land Use Analysis. In like manner, other
environmental subtasks (e.g. vegetation, cultural resources, wildlife)
will deal with increased access as it affects thes~ specific disciplines.
Comment 3:
There is an obvious linkage between access roads for this project and
land use/fish and wildlife studies. Review of the manuals does not
indicate that the approoriate process or mechanism is in place to see
that this occ:urs •.
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Response:
Subtask 7o14 (Access Road Environmental Analysis) is essentially a
coordination sub task for this specific project component since it has
obviously far-reaching impacts. The Procedures Manual states that
the actual analysis is to be done by Principal Investigators within
each environmental subtask. A major coordination effort was felt to
be necessary due to the interplay of roles between APA, Acres, R&M, TES,
AOF&G -,n d the various en vi ron menta 1 subcontractors. To this end ,
correspondence exchange and maps and information exchange has occurred
since April, 1980. In November, a meeting was held in Anchorage at
which time representatives of APA~ Acres, R&~1. TES, AOF&G, and other
en vi r·onmenta 1 subcontractors discussed various a 1 temati ve routes o
Info·rmation exchange continues on a dai.1y basis, and will continue
through route selection and preparation of the FERC application.
General Comments
Corrment:
It is the consensus of tr.e Steering Committee that each study task
Procedures Manual should include two maps:
lo A map that delineates the boundaries of the specific study tasks
described in the respective manua1.
20 A second map delineating the overall study area, i.e., from the
mouth of the Susitna River to thE Denali Highway.
Response:
1. Maps of specific study areas would ce~ain1y be useful. In several
subtasks, part of the work performed during the first year was a
determination of the appropriate study area. Such maps are thus
planned for the 1980 Annual Reports and will be incorporated into
the respective Procedures Manuals with the next required amendment
to each manu a 1 0
2. A composite map showing the relationship of specific. study areas
wi 11 be presented in. our summary annua 1 report.
16
,_ -,., : :· = _. :-0 ' ':' ~ \ I ~ ~ ..
-..I• ... -•• -.• -... -:..... ~ ...... ~--. --... ' , -. .. .-._...._ .:
l. POPUL.r..T 1 ON
A. ~opulation levels
1. His"torical
2. Present
3. Projected
4. Component of Change (births, deaths,
in-out migration)
8. Ethnicity, Culture, Religion
C. Population Distribution (city, borough,
state) by:
1: Age
2. Sex
3. Race
4. Occupation (general)
5. Education
a. Retired, 1·1age, salary
b. Sector, activity
c. Employment
D. Population Density
E. Family/Household Characteristics
Extent
2. Marital Status
3. Migration patterns
a. mob~lity/stability
b. point of origin
c. out/in migration
4. Length of Residence
a. in house
b. in com:nun ity
c. in state
5. Place of 1..,ork (commuting distance)
· ..
F. Attitudes Toward Change/Economic D~velopment
G. Projections
Each of these categories and variables will be addressed to the extent
that data and information allow and to the extent that they are relevant
for the purposes of this analysis
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A. Historical lnfo (growth rate)
B. Type
1. Single family
2 • Mu lt i .:. family
3. Mobile home
4. Recreation Facilities
5. Transient Faciliti~s
* Variables to be considered for above
a. number of units
b. quality
c. cost/prices
d. vacancy rate
C. Vacancy Rate
-o. Status
l. Renting
2. Buying
J. Own
4. Other·
E. Land availability
F. Zoning/Buil~ing Regulations (&patterns)
G. Financial Climate (incentives/disincentives)
H. Real Estate Activity
1. Sales
2. Construction
3. Plans
I.
A. Government Structure/Organization
1. Tovms
2. Cities
3. Boroughs
8. Government Services
1. Water Supply and Treatment
2. Waste Water Treatment
3 . So 1 i d ~.'as t e 0 i s p o s a l
4. Police Protection
__ Legal System (courts, retention facilities)
6. Fire Protection
7. Health Care (including Social Services)
8. Parks and Recreation
9. Libraries
10. Education (day care, vocational, others)
11. Public Transportat{on
12." Roads and Highway Syste1
13. Telephone Service/Communication
14. Electric Power Service
* Variables to be considered for above
a. Service area
b • U s a g e f i_g u r e s
c. Deployment patterns (distances/response
times)
d. Capacity figures
e. Condition/quality
f. Relevant standards
g. Occurrence rates
h. Plans for expansion
i. Government expenditures
C. Tax Base and Revenues
1. Taxes
a. personal
i. rates
ii. base
b. industry
i . rates
ii. base
c. Sales
i. rates
ii. hase
d. other
,--'
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,..
I... '-o ... ) \\.. nL.
2. Other revenue sources
Government debt (borrowing capacity)
D. Projections
A. General Description (Sis~ory and Area Trends)
B. Total Work Force
C. Employment l~ultipl ier
D. Output Multiplier
E. Major Basic Industry Description
l. Construction
2. l~i n in g
3. Agriculture
4. Timber and related products s: Manufacturing
6. Fishery
7. Oil and gas
8. Transportation
i . Ra i1
ii. Air
iii. Motor transport
iv. Harin~
9. Public Utilities
10. Conrnuni.cations
11. Wholesale· trade
12. Retail trade
13. Finance, insurance, real estate
14. Services
15. Public Administration (Federal, State, Local)
16. Tourism
w Variables t-o be co-nsid-ered for ab-ove
c. history
b. statistics (present sales, prod., etc.)
c. employment
1. labor force
2. percent of total \'IOrk force
3. payroll
4. average wage rate
d. resource base ( 1 and use}
e. service area
f. usage figures
g. capacity
h. condition/quality
i. product value
j. r.,arket i ng patterns
k. relative to state and u.s.
1. future outlook
-
F. Conclusions
G. Projections
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H~ ...
A. Historica1 Labor Ch~nges
B. Efllployment
l. Present Profile (efilp1op,ent by st:ctor)
a. absolute
b. percent age
2. f1ultipliers
a. basic industry to
b. export trade sector
c. services
3. Length of work week
4. Seasonality
C. Occupational Staffing Patterns by
1. Sector/Industry
2. Ethnicity
3. Sex
4. Unemp 1 o,;IITlent
5. Percentaae of work force
6. Wages (s~lected occupations)
0. Working Conditions and Absenteeism
E. Union Presence
F. Unemployment for Area
1. Age
2. Sex
3. Race
G. Income
1. His tory
2. Per Capita Income
a. General
b. Sex
c. Ethnic i ty
3. Source
a. Wages/salaries
b. Social Security
4. Subsistence income (moderate standard of living)
5. Consumer Price Index (CPI)
H. Projections
l.J .. ~ ' l ..
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I '"·•·r .._.:....1' :.} USE
A. H1storica1/Genera1
B. Land Tenure (ownership)
C. Existing
D.
E.
1.
2.
3.
4.
5.
6.
7.
8.
0 -'.
10.
11.
12.
13.
14 ..
15.
16.
Forestry
Aoriculture
t1 in i ng
Timber
Native Lands
Federa 1
State
Parks
Oil and Gas
Unexploited Natural
Industry/Coiilllercial
Urban
Rural
Residential
t1i 1 i tary
Transportation
Resources
*Variables to be considered for above
a. acres
b. value
c. ownership
d. management plans
e. historical trends
f. percent age of tot a 1
Population Density
Land Use Plans and Control
1. Public
2. Private
3; Municipalities
4. Borough
5. Flood plains
F. Projections
•
.r... Uttlizing Fish & Wildli:"e Resources
1. Sport Fishery
a. A 11 species
2. Wildlife
a. Caribou
b. r~oose
c. Black Bear
d. Brown Bear
e. Mountain Goats
f. Sheep
g. Wolverine
i. Waterfowl, Birds
j. Other Furbearers
* Variables to be considered for above
1. Historical
2. Present
a. area (acres and location)
b. effort (visitor days/# of visitors)-
c. Success (harvest)
d. Resident (pt. of origin;r. of total)
e. Non-Resident (g2n. geo. pt. of origin/
% of total)
f. Species (stats relative to State)
g. Subsistence (personal consumption/
business}
h. Trophy
i .-Management P 1 ans
· · i. Reoulations
ii. Revenues (total/:-elative to
state/flow of money)
iii. Enforcement (ways/numbers/capacity)
B. Not Related to Fish & Wildlife Reserves
1. Water Sports (canoe, kayak, rafting)
a. Historical
b. Area
1. eff art
2. resident/non-resident pt. of or1g1n
2. Land Sports (hiking, picnicing, climbing)
a. Historical
b. Area
1. effort
2. resident/non-resident pt. of origin
C. Other
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-
-
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-
D.
E.
?.e1ated Business
l. Guides {#/S)
2. Air Taxi Operators (#/S)
3. lodae Owners (#/$)
4. Land Owners (#)
Projections
~r. Eric P. Yould
Executive Director
Alaska Power Authority
333 West 4th Avenue, Suite 31
Anchorage, Alaska 99501
near Mr. Yould1
2 3 JUN 1980
This letter transml ts to the Alaska Power Authority, (APA) conuDenta
of the U.S. Fish and Wildlife Service (FWS) relative to fish and
wlldl!fe aspQcts of the Sus1tna Hydroelectric Feasibility Study.
Our comments are based on a reviev of the February 1980 Plan of
Ztudy {POS) developed by Acres American, Inc., coordination vith
Acres, other federal and state resource agencies involved in the
Susitna project, and field reviev of habitats of t~e prqject area
rotentially affected by a hydroelectric project.
-Generally we believe that most of the environmental studies outlined
1n the February 1980 POS are adequate to obtain data from which to
assess the lcpacta of a hydroelectric project on the Susltna River
to fish 1and wildife resources. However, the studies outlined :ln the
P0S pro~!de a general overviev of goals and expected results. Thare
is little reference to the specific methodologies of research design,
specific timings of etudy initiation. methods of data analysis, and
anticipated format of results. Consequently. ve are unnble to fully
evaluate study ?lane. Apparently, more ftpecific information ia
available in study-specific procedures manuals. Review of these
manuals may clarify some of the concerns expressed herein. At this
time. ve formally request a copy of the procedures manuals for the
fisheries, wildlife ecology, and plant ecology studies for our
review.
Eased on our review of the POS and discussions with Acres. we believe
that the following deficiencies of the environmental studies require
attention. The schedule for Uceruse application and submittal of an
Exhiblt S to the Federal Energy Regulatory Comoission (FERC) does
not 01llow sufficient time to include a rigorous evaluation of project
impacts to fish and wildlif(! re·sources or p·rcparat!on of a plan to
mitigate and conpensatc impacts to those r~sources.
Although wlldlife ecology studies are comprehensive in _that they
include avifauna and big game. furbearer. and nongame mammal investi-
gations, much less enphasiR io placed on obtaining data on nongame
l!lacimals and avifauna than selected game and furbearer specieo. In
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-
....
addition. no M1t1&ation plan, or study of these animals dovnstream
from the dar.-.sit<~ ls u:ent ioned in the POS. Discussions wl th repre-
~cntatJves of Terrestrial RnvirOJIDentol Specialists (TES) indicate
th.!lt they lnt.end to develop r•1ltir,at1on plans for nongame wl.ldllfe
nnd e6tablish st11dy areas i:m.-nstream from. the damsltes. It is
Jr::pcrative that W!? review these tasks for adequacy. The National
Fnvlronncntal Polley Act (f!EPA), Pish and \Hldlife Coordination Act,
and other ptldellnes require that ·inpocts to 811 fish and wildlife
resources he Identified and mitigated. Furthetlllore. we believe that
the asscss,~C'nt of project !npacts he h:tecrl on ~the overall value of
habitats to endemic species Yilich includes but is not solely dependent
on population data.
Co~nf'nts anc! qu£'stions specific to tasks described in the February
19130 POS follow:
Subtask 2.10-Access Roods
D Please provide us a rnap of the alternative access routes as
s-oon as available und !ndicRtC 1f the selected route'(s) will be
temporary or pen::anent.
f.ubtask 2.16 Hydrographic Surveys
0 \-Jhy are rJ.v.er profiles limited to TAlkeetna and above? In
ord-er to cfltab lish hackr,round dat.a to measure potential change
in the river co'nfiguration and habitats dovnstrearn frOQ Talkeetna.
should prcfiles also'be taken !n t:.his area ln conjunction vlth
data ~o he collected under Subtask ).10?
Subtasks 6.o09 and ·6.10 -Establish Design Criteria for the \riatana
and Devil Canyon Development
• Are designs of potential mitigation 6tructures included here?
Subtask 6.14 -Spillway Design Criteria
• Do these criteria include contingency neasurcs to avoid water
quality problems such as nltror,en supersaturation?
Task 7 -l:nvironmental Studies
• Because the F\IS is invol vcd in a nunber of perm! t tinp. and
review functions relative to the SuRitna Hydroelectric project 0
we YOuld appreciate being l~ept infonaed of project progress.
nms. 'IOIC <Jre rcquestinf; curies of reports prepared for cnvlron-
QentaJ disciplines (hydrology, fisheries, wildlife ccolo~y.
plant ecology, habitat analysio) as they ar~ revieued by APA.
$ubtar>k 7.2 -HonltorJng of FJeld Activities for Environmental
Acccptablllty •
• ~everal study nctJvlt!cs will potentlRlly l~pact migratory
birds lnclu<!tn~ \1aterfowl an1i rRptors. He sugr,est that the
Acres or ArA field representative contact the FWS to be certain
that he ls a~are of data on bald eagle nestlng locations,
trumpeter 6Yan nesting habitats, and other pertinent data.
Also, we 'I.'Ould like to be provided the opportunity to periodi-
cally monitor activi tics that r.I8Y disturb rap tors and other
migratory birds. Therefore, ve request a schedule of the
tirnt.ng and duration of study events that Include activities
that potent !ally disturb \oraterfowl and raptore. We are
particularly concerned vith survey and aerial photography
activities requiring helicopter support.
Suhtnsk 7.09 -Susitna Transmission Line Assessment
• Remote lakes In the Matanuska-Susitna Valley are utilized by
trumpeter swans for nesting and rearing cygnets durlng aummer
f .
and fall. Recent data indieate·that continued developaent·and
disturbance on !likes U&ed for nesting ls cauaing birds to
abandon cer~ain areas. The selection of a transmlaslon corridor
should be accomplished cognizant of the habitat requirements
and movement patterns of migratory birds.
Subtask 7.10-Fish Ecology Studies
• ~~jor comments concerning ftshery investigations were pr~vided
to APA in previous ~orrespondence. From the information pro-
vided !n the February 1980 POS, ve are uncertain of ~he precise
tlmlng of initiation of study tasks. •le vould appreciate ·
receipt of the present schedule of fishery related studies at
your convenience.
Subtask 7.11 -Wildlife· Ecology Studies
•
•
•
Data collected for habitat analysis should be done in a manner
to accommodate all terrestrial wildlife. This will permit an
evaluation of the effects of habitat alteration on wildlife In
terms of hebitat unit values.
Any mitigation plan developed muat be developed In cooperation
vith resource agencies as def !ned In the Fish and lo:lldllfe
Coordination Act. Also, the r..ltlgatlon plan should be incor-
porated into the Exhibit S of the FERC license application •
necause many of the field studies have been 1nlt1ated or .are
scheduled to coi'IIC\ence soon, it is Jmperotlve that "n Intense
survey of the project nrea be conducted for peregrine falcons
prior to the lnitiatlon of potentially distu~b!ng activities.
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-
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-
•
•
Um!er. the FERC process. sufficient data must be obtalnod ·to
develop a b!ologicel assessment of t:ndangered species relative
to the potential Impacts of project activities. Based on the
biolor,icaJ assessnent. the FERC 111ay be required to consult lllth
the l-1~S concerning endangered species unrler Section 7 of the
Endnn~£'rcd Species Act. The consultation process will be
greatly ('Xpedlted !f. sufficient data hRve been gathered and
evaluated ln the initial study phase.
The outllnes for avifauna and nongame rnaf'!lll'.al studies are quite
general and it is difficult to deternine what will be accom-
plished. The objectives and goals need to be presented in more
detnll •
Recent surveys of the Susitna River and tributaries located
more bald eagle nests along the Jllain river below tho damsite
~han previously expected. Consequently, the impact of altered
flow on eagles aeeds to be assessed.
Subtask 7.12 -Plant Ecology Studies
•
•
An l~portant objective of the plant ecology studies Is ~o
measure potential habitat change over tl.r.!e. Habitats in the
area of project influence should he ~pped st 1:63,360. This
acale should be expanded to 1:25.000 in riparian habitats
downstream from the dams1te(a) that will potentially be altered
by the project.
Vegetation cover maps and habitat requirement charac-teristics
of wlldlife should be compared to determine the quantity and
quality of habitat lost for wildlife groups and to predict
impacts on species of wildlife. This impliea that wlldllfe and
vegetation studies be conducted in a complementary manner and
that the purpose of plant ecology studies be kept in full view.
Cover type maps are of little use for predlctLnr. impacts If the
habitat requirements of ~lldlif~ specl~s are not known.
Subtask 8.04 -Tower, Hardware, and Conductor Studies
• Studies should include design of a transoisslon line to avoid
electrocution of l"Bptors and collision3 ~,ith rucratory birds.
Subtask 9.02 -Prepare Preliminary Co5t Estimnte
• Cost estlmates should include the costs of added features to
~itigate impacts to fish and wildlife re!'fourccs.
As you are avare 9 the f'-IS !s required by federal lavs and ;"~ollcic;s
to ensure that de.cislonmakcrs Arc provldcd Jnfbrnatlon ""hereby
vlldllfe values can be fully considered ttnd velKhcd equally lolith
other features lo the planning of water resource development pro-
jects. As; a result of these responsiblllties, we have an ot-ligatlon
for Insuring that an adequate Exhibit S is prepared. F~hibit S is
paranount to the designing of an environmentally sound project since
Its purpose ls: (1) to identify and evaluate the effect of alter-
native project proposals; and (2) to describe measures necessary to
conserve and enhance fish and wildlife resources. F.xhlblt S, there-
fore, should contain a mitigation plan and functional design dra~Ings
or other project features as ~y be determined necessary for the
protection, conservation, Improvement, and mitigation of losses to
fish and wildlife resources.
\.Je can see no advantage in presenting an application to FERC. which
will be reviewed by F\.J'S, that does not .contain an adequate assess-
ml!:nt of project impacts to fish and wildU.fe resources and practiclil
Ditigatlon plan. Submission of an P.xhib!t S under a compressed tlme
fra~e can only hlnder the designing of an environmentally sound
project. Tite FWS recommends that the lLcenee application be delayed
until sufficient biological rlata are available.
Thank you for the opportunity to co~mcnt on th!R project.
cc: AGES, WAES
P.LM. ADF&C, NNFS, Anchorage
n'S/OEC, FERC, 'Haahlngton D.C.
Sincerely,
. 1 Signed by Orlgtn~ Schretner
l<.eith ....
A~ea Direc-tor
ALASKA PCMER AUl1IORilY
:~r. Keith Sct1rei ner
Area Director
Ftsh & ~ildlife Service
Department of the Interior
lOll East Tudor Road
f,nchorage. /\1 aska 99503
Dear Mr. Schreiner:
September 12. 1980
This is a response to your letter dated June 23, 1980 transmitting
comr.;ents relative to fish and wildlife aspects of the Susitna Hydroelectric
Project feasibility Study. We would have wished that you had been able
to ;;rovide your written comments sooner in as much as our Plan of Study (PC'S)
was published and distributed in February. It was difficult to alter our
first field season program with your comments arriving as they did in late
,June. Despite the lack of timeliness, we definitely appreciate your
comments and have given them careful consideration. Hy responses are
keyed to the page numbers and paragraphs of your letter, a copy of which
has been attached for easy reference.
Page 1, Paragraph 2
The studj'-specific procedure manuals for the majority of the environmental
subtasks have been completed and were submitted to the Susitna Steering
Committee during the week of September 1, 1930. A complete set has been
designated for Mr. Don McKay, F&WS.
f~ge 1, Paragraph 3
~e view our POS as a two-phased effort with impact analysis and mitigation
planning (as well as data collection) extending beyond the date of license
application. In the Plan of Study (POS) and Procedures Manuals, pre-license
application and post-license application studies are referred to as Phase I
and Phase II, respectively. The anticipated post-license appli~ation studies
are summarized in Section A-6 of the February 1980 Plan of Study and were
described in even greater detail in the Technical Appendix of the September
1979 POS; these plans will be refined on the basis of Phase I findings.
Page 1, last Paragraph. continuing onto
Page 2, Paragraph 1
The nongame studies cannot be rigidly compared to game and furbearer
studies. Differences in study effort, as reflected in budget allotments.
f""" result from a variety of reasons. including equipment and logistic expenses,
~r. Keith Schreiner ALASKA POWER AUIHORITY
September 12. 1980 •
Page Two •
differences in home range and habitat use, recreation and economic importance,
and life span. The nongame studies will allow a thorough evaluation of impact
and, if necessary. sufficient data to develop a mitigation plan.
At the present time,, 1imited furbearer surveys are planned downstream of
the Devil Canyon dam site as far as Delta Islands. Some avian studies will
be conducted downstream as far as Gold Creek. No avian studies are planned
for the area south of Gold Creek other than an aerial survey for raptor
nests, which will be conducted in 1931 if deemed necessary (as discussed in
the response to the comment of Page 4~ Paragraph 3). The approach of Phase I
studies is to concentrate in areas where impact \'fill definitely occur, such
as the impoundment zones. Since the extent of impact on downstream habitats,
particularly those south of Talkeetna, cannot be predicted untfl further
progress 1s made ,on the hydrology and engineedng design studies, only limited
effort was appropriated for this aspect of the project. If the results of the
Phase I hydrology and engineering work indicate that major changes will occur
downstream. the Phase II ecology studies will be designed to evaluate in more
detail the downstream habitats.
page 2, Subtask 2.10 -Access Roads
As soon as available we will provide a map of the alternative access routes.
The question of whether the selected route(s) \'1111 be temporary or permanent
is part of our ongoing studies which will require input from various dis-
ciplines and government agencies including F&WS. F&WS advice will be sought
in this regard during the impact/mitigation phase of our studies.
Page 2, Subtask. 2.16 -Hydrographic Survexs
As discussed and agreed to in the Susitna workshop of July 17-18. 1980, the
question regarding the necessity or feasibility of establishing detailed
river profiles downstream of Talkeetna would be postponed until the spring
of 1981. Following the acquisition of 1980/81 winter fisheries data and
a reconnaissance assessment of the Susitna hydraulic characteristics, a
decision on the development of river profiles downstream of Talkeetna will
be made.
Page 2, Subtask 6.09 and 6.10 -Design Criteria for Watana and Devil Canyon
Development ·
These subtasks will include the establishment of design criteria for mitigation
structures as required.
fage 2, Subtask 6.14 -Spillway Design Criteria
These criteria will include contingency measures to avoid or alleviate water
quality problems such as nitrogen supersaturation.
1 il" • l.._t; t L..ll .J\....IH .._I, • ..._'
September 12. 19ti0
Page Four
An aerial survey was conducted for peregrine falcons 1n early July 1980, and
none were found. Other study team members have been advised to report any
incidental observations to the TES Field Representative. If any peregrines
are seen in the course of the study, team members will insure that all
potentially disturbing activities are scheduled to avoid areas known to be
used by the peregrines. We are confident that our endangered species program
will provide adequate data and analysis thereof for review of the Susitna
Project by both F&WS and FERC.
The Procedures t~anua 1 for Birds and Non-game r,~ammal s provides many additiona 1
details concerning the study effort.
The aerial survey for raptors. conducted in the impoundment zone during
1930, will be evaluated and 1f deemed necessary altered or expanded to
cover the downstream area. Serious consideration will be given to extending
the 1981 aerial raptor survey to Talkeetna. A more intensive analysis
will probably not be conducted until sufficient hydrology and engineering
work has been perfonned to determine \>thether the expenditure of additional
funds is warranted.
£!._~ Subtask 7.12 -Plant Eco 1 ogy Studies
The plant ecology mapping efforts are in exact agreement with those recommended
by Ff..WS. These mapping scales were identified 1n the February 1980 Plan of
Study, having been determined on the basis of a coordination meeting held in
October 1979 at which F&WS was representated.
One of the major purposes of the plant ecology studies is to allow a compre-
hensive evaluation of habitat alteration that may result from the Susttna
Project. Habitat data are being collected in conjunction with cover type
mapping that is being performed in Phase I; plant succession studies are
being conducted in Phase I; and an in-depth moose habitat study is planned
for Phase II. In addition, ADF&G is collecting habitat data throughout
the study.
Page 4, Subtask 8.04 -Tower, Hardware, and Conductor Studies
The transmission design team will review literature on design consideration
to avoid raptor electrocution and incorporate this, as required, fnto the
design criteria. If the transmission corridor routing analysis to be per-
formed under Subtask 7.09 indicates a potential collision problem at any
specific location, special mitigation efforts will be incorporated.
Page 4, Subtaslc. 9.02 -Prepare Preliminary Cost Estimate
Cost estimates for mitigation efforts will be prepared on a preliminary basfs
during Phase I. Cost estimates w111 be refined during Phase II.
r·-·--
Pa~e Five
P a 51.~-~_:_E_~• i b i_!:_~
As outlined in our POS it is our objective to submit the FERC an adequate
license application by June 1932. Our application will contain an assessment
of impacts to fish and wildlife resources and practical mitigation measures.
It is realized that Phase II studies will be required to confirm some aspects
-of our assessment and to finalize mitigation plans. If for unforeseen reasons
it is detennined in 1982 that an adequate application cannot be prepared on
schedule. we will reassess our position. Once again your timeliness in the
future "'ould be very much appreciated.
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-
Attachment:
Sincerely,
Eric P. Yould
Executive Director
Letter from ·Keith Schreiner dated June 23. 1980
cc: Tom Trent. ADF~G
Brad Smith. NMFS
Curt t1cVee. Bu.!
Dean Shumway. FERC
,...,
APPENDIX EllC
CORRESPONDENCE RELATING TO
DATA COLLECTION AND PROJECT ASSESSMENT
·-
-
-
APPENDIX ll.C
DATA COLLECTION AND PROJECT ASSESSMENT
\
All big game and fisheries baseline data were collected by the Alaska
Department of Fish and Game (ADF&G) under a Reimburseable Services Agreement
with the Alaska Power Authority. ADF&G had a major influence on the direction,
scope, and schedule for these studies. Annual reports for all the environ-
mental subtasks were distributed in April-Mqy 1981.
This appendix contains correspondenceconcerning transmittal of documents to
resource agencies and their response to-these.documents. Subjects include
review of access road reports, transmission line siting reports, annual
o .o•
environmental reports, and the Susitna Hydroelectric Project Mid-Study Report.
Correspondence is presented primarily in chronological order. However, in
some cases, a response to a 1 etter directly 'follows the 1 etter to facilitate
an understanding of the flow of communication. This results in an interrpution
in the chronological sequence.
RECEIVEO·ocr I 0 1~79
RECEl~l:O
UNITED STATES
DEPARTMENT OF THE INTERIOR
~~. B~ic P9 tou1d
E~~cutiv~ Director
F~S'H A~D WtLDllfE SERVICE
10h (~ 1 I,I(X)f\ It (l
A~CHORAGE,ALA!KA~9SOl
. t907J 276 33:00
Ala~kA P~r AuthQT.ity
333 W~t 4th hv~n~~7 S~ite 31
~.ncl~orase. A1ask~ 99501 ·
De..sr Mr .. Yould:
S£P 2 7151,9
W$.1\ P'~~ AulHC~lt
:~-.
FlLE ~rc,
:
;
z ::E· cO
0 a:· iE
i= a ...
11:.: en 0 ~ a <
:· DCW
_,
< E
!!:
:
' 1---t--1----i-----:
Ye \fe!:e · inf.o~d 'l;;y yQn'f' l~ttel:' o£ Au.P.\l~t 23,. 1979 .. tb~t th.i.!t-J.J.aek. M RV i
Po~~ ~t.h9·d.ty (API\) is prepari~ an· application for licen.se to ~
.Fede:rs1 Energy Rt::gulatury C..."""iilt:U.~:daza (PERC) for t:he: prcpo$ed liydro rrt::~~;:e~
electric ~over beveiopment v~tbin the Upper Sa~~tD~ River ~iD 7
A1aslta. the purpcse o.£ th1~ letter u t:u point out fedei:'al fi:;b ~· -1 t~ildlife r~pQn~i.biliti" and to insltr~ ~dsq\.tat~ eonside.ration of -:-rl1iC ~
l!:sb and Vl.ldli.fe rer.o~t'~~ lot::2S p~~vention 7 =it1.1p~ti011,. c:o~cnt:u;-C-\t -:--1
tion~ and enha.nce~ut tln:oughout tbe p1a.tL1..Lng s.m1 deciif.i.~n-roaUng _ ---i
proc:ess a~.Aoc:i~tcd ~ th th~ Su6itTMa r-roj~et. · · ·ri,.---1
--t "lb~ P.t'(l•appl.ieation plarurl~ period assoc!at~.i w.ttb the propo:fed i
Su:tit:~ Byd!."'Q~lectric Paver DiL\!.{!lcp'!JIC,nt it: very er.it'te!.:al. Qon~i~eril!t...,.-1---!1.----l-.
• 1 I the magnitud~\af the project, 1i.mitcd ex.!f}ting d::U:.a £or !.tab olin~ 1--1
. v1ld1.!.fe res:o~c~~7 3;sd amount o£ e££ort requi~ed ior the f'il!.ng Qf · . ·-~_J
a V~Jll .. conc-Etivl?d .application for !it":enae ~L~ PERC. "Ill···adtlitiou, 1
1
!
c~prebc~sivc o.-.yJ.y pl~nniti~ 111 T~qt.dtd:tc:a to th~ d»llir.ni~ji f}f .IJ'Il ·.· · . t--!
c:ovi~onment.slly AQund projol,lt;t ;;T;d opti~Dl ~c of the pl;,sn~illg pcdQ ., _I . 1 .. ~
. the.reby m:f.a:i!dzing the potential for dda:y in tbe processin~ of i 1LJ n~c::;:;;~;lry pnmit and lic(t.n8~ ~pplio;~tioneo i'nd C!O'l.OPll"i!IF. with v~rlQlJ tTkC\f .. _~!
euvi rollm=!n ta 1 r:::v i~v rt:qu i rt:!l!:cn til. ·
:Feoer:U s.senc!ru' imro1"1:t!d in tboe aniilyd.J:S t~rJd/a~ .::pprov.:sl df a
nt)~-!eder~l water-~alated proj=ct have m&uy ~f:~poo~ib.111.ti.es un•Jer
various lt~ecutive Orders (EO>. l;nrs .. aud polt~::tea 'to pr.cvent i1.nd
Dit{gate· impftc;ts ·to f;tan ~:nd vildlife rc~our~~9~ a$ voll ~~ ~o
l;l'Jln.Q®a C.bosc= t'C9Q\1t'C.•.u•.t T.o idan~ifl' and intn:;-c rec:cgnition Qf
di.reet.1vee o£ u!Dost Importanc:e and r~leva~ce tl) tbe prote~ttoa of
fish and V.i!d.l:i.fe r-asources, \:0'\\· list thEt f<lllovi~ and includ') &
br isf SUJIU!.\B.I)" of !!ll?esures requ i t'ed:
(1) · 'J:be 1•1sb .and Wildlife Coordi.Dation Aet~ draft Uc.!.forra
Proc.~dure-s for Co!!l:pli.ance, .'HaY 18~ 1979 .. at-~ndardir.~et
p1:oc:edure» :Snd .idt.~:era;~ne)• relat.!onsbi.pis .lo l.n~u:e, "that
v.Udl:.t fe c-ona4!-rv.:ttfQn ie f•.t11y .,_oneidr.rn~ i&nd wt'l!ienQ4
equally vl.th othe-r prcJ.:c::t f~.sture-s · in a~cncy decision~ .
!lAking p.roc.e-ese.s by inte:,rat·inf. ~1.1r.h c.o'tl&id$t'ations 1:n;o ·
PTQjl;lct plan11ing, l~ati-onal Eovirvi'l!f.l@ntal Policy Act (NEftA)
complianca procedures, fin&ncial and e~onomic Analyses.
authorizet1on do~u~ut$. aud proJect ~p1ece~~t1on."
(l) The Co\1noi.l Q11 ~nviro~ntal Qnalit.y':; (CE.'}) Rc!u.lation'
.Cor laj:•l~at1GS the rroc~ural Pr<"•vie.ione of th~ l~.ational
Enviro~~nt~l PQJi~ AQt (40 CPR~ Part~ 1500-1508, July
)0, 1979) ~p~cifie~ pruvi~lc~ re~uir~g tbe ~tegration
of the. trePA pr-oce.ss into Mrl:r pl-!1'i111i-az~ tnc in~1;:g~atinn
of NEPA requirements with. otber emriTof'G:!Klnt.sl revi~ <md
consultation requir~ment~. an4 th= U$C of the ~~opi~
pr9~;c..;.s.
(S) Sect.l.o..o 404 rl! the Clt::S!\ Water· Act of 1977 and re9ult1~
final rule.s for i~l~~~tiQn of the ~egul~~Or)" p~~t
prcgr;za of -the Carp~ cf Engiu~r~ (.33 CF!..., P~rt.a 320-329 ..
July 19t 1~17) reqU1%e~ that a Department of th& Army
permit (e) be t)'\:rt.aitted fo-r ecTt."''i.n ;;tructu:cw; or "WOx:k. in or
•ff~~tina w~tcrs of the United StaLeb. The 4pp1~cat1on(s)
for such·~ pe~i~(~) will be ~bJeet to review by wildlife
:tgem:ic$ ..
(4) Exe~ut1ve O~de:r 11990 (~tland~) "-'";l~ i.;:wcd "in order to
avoid to tba extant po::::sible th~ long-'Lt::l::'m a"Od a-bort-terM
ad~er~= ~pact~ ~&~e1ated Yith the dest~~ction or modi-
. f~~tian u£ weti~de a~d to avoid direct or i~d~rc~t
support of ncv con~tru~tion in vetl~nds ~t1erever thet~ is
~ p~a~ti~~ble ~ltcra~t~ve.n aod £~eutive Order 119~8
(:Flo6i]pla1:U) \lli&S l.asuH 1•to ~VQid 'tl1 t.hc extent. pa~:o.!ble
the lo~-te.rm ~nd ~nort-term adver~e ~paets associated
vit.h tne Qt:C:llp.Sncy aud mOtU.fl.cat~on of floodpliiitts <:~ncl to
avoid direct ;;nd indirect ~upport of floodplain de-v~lop
~*~t vner~~cr thete i~ a·pract1cable slt~rn~tivG." All
.. f~.:e;ral agenc.!ea are :r:~sponsibltt t9 i.:O'l<!PlY vit.h thes;e EO':~
1n t:he plafJU..lng and .decie.ion-Mking PTPC~l;.
(5) s~~tion 7{c) of tbe £~d~~gered Sp~ci~~ Act, 87 ~tat. 834~
&$ ~ended 7 requif~e FERC to aak tb* S*cret~ry ~f the
l.tlterior. ac.till?. tl'rr!lugh tha: UAS .. Fish ~~d \Ultil1fe St.trvic(:\,
vhether ~:o· lietetl or propose-d er.danP.~!E:'-d qr thrc;1tcncd
s;pt:cies ~y be present in th~ nr~, of the Su5itu& tlydrD-
ele.ctri~ PmR:r Proj~ct::.. It the fish .and \,':fldlif.o j;~rvi.cc:
.olQviseM t..h.,t. fmcb species GaY btt prcF.r.llt ill th~ a~e::i o.f
th~ project, F~C 16 r~qui~ed by S~~~io11 7(c) to cood~ct a
Biologic~l Ass~~~~~t ~o ide~tlfy 8ny listed or propos~
enden~er~d or thrc~tcncd Hp~c~ea which ar~ liK~ly to b~
affect~~ by tb~ co~~tn1~tion p~oject. TI1~ asseaev~nt ~~
to \le t;:Ol:lp1c.ted \olitl11e 180 days, unlCJaS a ti:me c.xt.cn:si(nl
ifs T.:Utually ar;rei:d upon.
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r
Mr. HriG P. Yould
Ro cm::~t~act for pbysic~l con:;t.ru\!tiou 'bay bt" entered inLo
~md no phy:;ic:.e1 COll:ltruction '1:10£:/ bcgil1 unttl the ilit:llngic.:11·
Aasessm~nt i~ ~ompl~t~d. ln thQ ~vr.nt the couc1~1ons
d~a~ from the 3iolo;lca1 Aase~~~n~ ~re that l!gt&J
endanaer~d oc tllri!ateoed sp~cir:H:; al!~ llk~ly to 0.~ aff'.\ctcd
~Y th~ cu~ettuction projec~, !ERC 1a required by Secti~
7{a) to'init~~te the cu~sultation prncc~s.
(n} W~te~ Reg~urcas r~uncil, r~1oe~plea ~nd St~ndard~ !or
r1~nnin~ Wat~r·and Uelated Land R~~o~rce~ (18 CFH~ Part
704~ April 1? 1978) were established fa~ pl~~ the ue~
of the ~~ter and r~lat~d l~nd te$o~rcea of the United
St.:1tc:s to ach:!ev~ Qbj«t:tivc."' det:e:rtrl.Ded coopo-;r;a.tively,
~h~ough th~ coordin~~ed nctioua of the·red~r~~w St~te~ and
locsl gover~~nt=t p~ivate ~Aterpri~~ ~d org~zat1ona~
and indivi4ual&~ Th~sc principle~ in~lude prov!din~ th~
basi~ fQr pl~ai~S of federal ~nd fcder~~iy a=~Lsted-vater
a!ld land r~eOt1TC@.(O progr::m~ aud pro.}eets an<! fedar.ozl.
licsnsing ~9tiviti~ as listed in the Stand~rds.
It ~ our underatsndina tb~t yuu~ a&~ncy bas contr~ctad with three
i~dep~ndent coneult~nt fires fur ~A~h to d9V3lop 3 ca.cprehe~iv~
plan of stud:r (POS} tu· icc1ud<! biological {;1;ndic~ .;ss!Soc1ated ~:Lth
tbc Su~itna project. and that frr.a tne three 1o.depe.nden:t Post.s and
the exist!~g Co~e of ~ngineer~· Plan of $tudyy Qn ultim~t~ compre-
lzems1VI1LPOS will bs d~Tiv~d. The 12ctions necessscy t(l cv.aply with
th~ ab9v~d liYted laws, policies, and F~·~ dcmons~~ate the aeceasity
for clo~~ t:on~u1tat1on vith fed~T.;11 i'211d st.tte wtidlife ag~ncie.a
tllJ:"cmgbout project plaDl!:in~ and tnpl(.T..t:nL.iil!uu.
It i~ ~~at~~e thst coord1~~t~d planning be 1alt~at~j ncv ·~t~ ~11
apprupr!.ate partie.s, «nd that sncb plAw:til-1~ includ~ th~ convening of
seo?1ns msetin?.~ to inciude purt1c~pation by $t~te and fed~r~l
wildlif!; :!~encit:!l. "!11e purpose of thQ ~;.::::oP'ina 12:t!t1llgs ahould
includ4l~ ·<:lc;vclqpins .a c:t.-::lpreben.a1v8 POS which i:u;ut"e~ full wildlife
~gcncy· part1e1pation -tln:·m,ghout ~aell philee of tht?L pl;Jnnina and
rcv~ev proceaaes; de-t~~ining whut aco~ the f~~9ra1 ~~d ~t~te
\ri..ldU.fe ~g.eoel.es or the appliC::!int~ 1A111 uodertake iind m .. cr.;:cc t.b~
required studies ~nd iuveatigs~ions; ic~1ring ~~~u~te ~dd timely
funding af those perfor=1o~ th~ $t~dic~; and ~~t~b11ah1ng BOtu8lJy
~C~Qptable targ~t dates for t~e initiatlon aod co~l~ti~n nr ~~udie~.
The t~:dhcrcnce to th-=$~ $uuestiona -:,l.ll iP!..-ute that ade·~uat9 infor-
.. ~t-i·cn ·!:~ ~o!-le-cted to \\n.;~blt: the detertrlnation of p&ojr.ct it~~pactu
~-:2d develop Q&~tu.•rns to pr~vf!l1~t m.iti~at(t~ ~nd •::cm:pcnso:s t~ fC~r f1.sh
~d wildlifo lo~~~~.
Ht"., Eric P. Yould
Y~ lonlc. f:;rrv;~rd to VQ4lt'in_~ cloeElly ;,i th yorJt' af,~nc.y snd otb~rs t.nv<Jlv~ 'in 'this ~t\~l}y, -9nd trust to~t this letter vtll serve ~ 'n~>t.ice u£ the il~c.e=s.$1ty i:or t:~rl::t i~·a~olv~~nt o£ :irid con~v.l.t;atton WLL~ Wild11£e ag~~c1es. .
cc: AO!S, WAlS
i'F.RC., ~<a<;hinatcn
c$, '\i.l&binat-on .
OEc. WAs~gt.on
c::. A!>P&G. Ancho%-age
llMF~i-BL!i. ADN~t, Allc:horese
AVEC. EPA. SCS, USGS, Anen9T~R~
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Mr. Gary Hiclanan
Area Director
United States Department of
the ~Interior · ·
Fish and Wildlife Service
1011 E. Tudor Road
Anchorage, AK 99503
Dear Mr. Hickman : Susi-tna. Hydr.oel ectri c Project
Thank you for your 1 ~tter dated September 24 concerning federal fish and
wildlife responsibilities for FERC licensing of the Susitna Project. We
wholeheartedly concur that all activities related to 1 icensing of the
project require careful planning and coordination with all local, state
and federal agencies involved. We also agree that the environmental base-
line studies, and the ensuing assessments and development of appropriate
investigation, compensation and enhancenent measures are of particular
concern. We fu 11 y intend to address these matters in as comprehensive and
thorough a manner as possible either through the Corps of Engineers or our
consultants, Acres American Inc. Selection of the Corps or Acres is
anticipated in November.
Some preliminary seeping meetings have already been initiated on our behalf
. by Acres American Inc and Terrestrial Environmental Specialists Inc with
the Alaska Departments of Fish and Game and Natural Resources, the U.S. Fish
and Wildlife Service and National Marine Fisheries Service. We have also
been in touch with Ron Corso of the FERC to solicit his views on the approach
we should take in obtaining the necessary .1 icenses for .. the project. It is
our understanding that a key factor in the 1 icense application will be a
valid demonstration to the FERC that all involved agencies have been consul ted
and that plans for compliance with the appropriate regulations have been
agreed. We have every intention of meeting this requiranent to the complete
satisfaction of FERC. Referring to the list of ·regulations in your letter
we have been advised by Mr. COrso as follows:
(1) Fish and Wildlife Coordination Act: FERC's own regulations will
govern for federal licensing of the Susitna Project.
(2) CEQ Regulations: FERC's own regulations will govern for federal
licensing. · · ·
(3) Section 404 of the Clean Water Act: compliance is necessary.
(4) Executive Order 11990 (Wetlands), and Executive Ord~rl1988
(Floodplalns): FERC's own regulations are expected to govern
in the case of Susitna .
(5) Endangered Species Act: compliance is necessary~
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(~) Water Resources .Council, Principles and Standards: these only apply
for federal projects, and would not apply if the state selects a
private consultant to undertake the Susitna Feasibility Study·.
You should also be aware that we are planning to directly involve the
ADF&G, ADNR, and possibly other state and federal agencies in appropriate
areas of study. We will gladly keep you informed of progress in all
aspects of the study which are subject to your jurisdic~ion and look for-
ward to a close and mutually productive relationship~
Sincerely yours,
Eric P. Yould
Executive Director
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~IIOWI!II
AU'IMORI1Y
r"" SUSITNA
f1LE.7f1Jf
DIVISION OF RESEARCH & DEVELCRfENJ'
March 26, 1981
Eric Yould
"Executive Director
Alaska Power Authority
6 tS81
JAr .t HUIIID/ID, 'DYCIIID6
323 E. 4TH A VENUE
ANCHORAGE. ALASKA 99501
279-5517
.. ~&l.2 2? 1981
,EQUENCE NO. 333 'lest 4th. Suite 31 F I { I 7 t k Anchorage. AlC 99501 Jt.J..}S.A P0\..,;1 J..UTHOR1T
' I ~.·.'[+ ~ ~ Dear Mr. You~d:
Z--~ t z' ~ ~·-V a The purpose of this letter is to transmit to you the findings and
~--i~--frecommendations of the Susitna Hydro Steering Committee in response to .-... _ t J_D_G . --~~~APA's request for input and recommendations on the selection of an
' iBJB access toad to the Susitna Hydro Dam sites. On March 6, 1981, Alaska
f JKL Power Authority staff, contractors and subcontractors provided several
,_ lRRH agency representatives with a briefing and a request for comments in
-c=J~PB order to make a determination for surface access to the dam sites. It r-:-tc;RI was requested that our comments be provided to APA by March 23, 1981. t=---:H&N As a result of com~nts and concerns expressed by agency representatives
---+-~at the March 6 meeting, I agreed to convene the Susitna Hydro Steering
r-+-+A_AA Co~mittee in order to identify and coordinate the concerns of those
[r-+--+-A_PA agency representatives regarding access to the Susi tna Hydro sites.
=-WCC The Susitna Hydro Steering Comzr.ittee met on Friday, March 20, 1981 •.
TES We spent the afternoon discussing various issues and concerns surrounding
i--f-~ ·I ~&M access to the dam sites with the subcontractors to Acres American. As
~ ~DF_&_G-r--~ a result of these discussions and review of the pertinent documents,
• ..::·--BUiT.--ifi·;;( ·report studies, etc., the Susitna Hydro S,teering Committee makes the
following comments and recommendations: l . ·ax.
1. The Steering Committee representatives recommend coordination
betYeen the decision about access road routes and transmission
line routes. Until this issue was raised by a Steering Committee
member at the March 20 meeting there had been little discussion.
The documents reviewed indicate that this was not a criterion for
establishing potential access routes.
2.· There needs to be a systematic decision-making process explicitly
laid out for determining an access route for the Susitna dams.
This decision-making process should be straight forward so that
agency participants can understand and effectively participate· in
establishing proposed access routes. There needs to be a broad
range of criteria established for determining the acceptability
or nonacceptibility of various route alternatives. Information
provided by Acres and their subcontractors to date indicates that
Eric Yould 2 March 26, 1981
3.
4.
the criteria used to determine access.roads were eight in number
and are roadway and railroad technical design parameters exclusively.
It is the recommendation of the Steering Committee members that
there are numerous other criteria which are critical and need
consideration along with the technical road and railroad design
parameters. I would refer you to an attached document entitled
11 Suitability for Haul Roads" to give you an example of a more
comprehensive lists of criteria that need to be incorporated in
any decision with respect to access to the dam sites.
There needs to be a clearer explanation and understanding of the
decisions regarding the timing of building access roads vs. FERC
approval for the project. We were advised by subcontractors that
the timing depends on which access mode and route is determined.
The time of construction and design of these routes varies from
one to three years. The agencies on the Steering Committee need
.t-o have a better understanding of how these facts and assumptions
interrelate to each other in order to make informed recommendations
to APA ..
There are numerous specific decisions that will be required
regardless of which access mode and route is ultimately determined
the most appropriate. The location and development of these
facilities could significantly affect the preference and recommendations
from agencies. For example. identification of gravel sites,
spoil sites, stream crossings; construction camp service and
maintenance facilities will be needed.. The members of the Susitna
Hydro Steering Committee unanimously felt that it was important
and necessary for APA to provide an understanding of how these
decisions will be made and how a quality control system will be
in effect to ensure that tasks are accomplished in accordance
with approvals and designs.
5. The Susitna Hydro Steering Committee members in reviewing the
March 6 and 20 meetings and discussing with subcontractors have
determined that data gathering planned for this summer should be
carried out on several access routes in order to make the final
decision as to which one is most acceptable. To make a determination
on a specific route with the lack of data/information that we are
currently dealing with and then s~nd researchers and data gatherers
into the field this summer to gather site specific data on only
one route is of questionable utility and logic. The primary
reason why this is questionable is because unless comparable data
on several of the prime routes is provided, the agencies will be
unable to provide comments as to which route is most acceptable.
In summary, we see the gathering and analysis of data on several
proposed routes as the rational basis for makingu:a determination
as to which access route should be ultimately chosen.
In summary, the Steering Committee wishes to e.ptphasize that it is
willing and anxious to work cooperatively and expeditiously with APA
in identifying and resolving the numerous questions which need to be
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Eric Yould 3 March 26. 1981
answered in order to make rational decisions with respect to access to
Susitna Hydro sites. Once you and your staff have had an opportunity
to review this letter, I would appreciate an opportunity to sit down
and. discuss the specifics of these comments in further detail.
Sincerely yours,
AI Carson, Chairman
Susitna Hydro Steering Committee
cc: Susitna Hydro Steering Committee Members
R. E. LeResche
Reed Stoops
WILLETT
WITTE
if LAMB -1·
"l;IAYPEN-y II
~rfBERRY
----' ~(_/,V•'-
1-,;.
I
I )I( (' H]), -'"'1.7 I(' I
IJii GILL /"-'/..-/'
LOWREY
~.qETZ t-~ r-~ ·\.k!
HUSTEAD
BOVE
CHASE
v 711,7-
Mr. Al canon. Cha1naan s usitM Hydro Steering Coamittee
A
3
1aska Department of Natural Resources
23 East 4th Avenue -
Anchorage. AK 99502
May 4. 1981
P5700.11.74
T.871
Dear Hr. Carson: Sus 1 tna Hydroe 1 ectr1 c Project
Access Road Studies
I
y
w
a
acknowledge receipt of your letter of March 26. 1981, to Eric
ould, APA. P1"'8Hnt1y. I Ut 1n the process of reviewing your COIRo>
ments and reCOIIIRendat1ons. 1 appreciate the Steering Coan1ttee • s
1111ngness to ~rk cooperatively with APA 1n identifying and
resolving the numerous questions relating to access roads and other
spects of the Sus1tna studies.
w e are presently developing a systematic decision-making process
that can be ut111zed for access road selection and for other
major decisions that wt11 be made as part of the Susitna studies.
The decision has been Nde to obtain atr photos on an three
major access corridors. thus. eliminating the necessity of an
ar1y decision for a preferred corridor. e
Our decision as to which corridor or corridors w111 receive detailed
study w111 not be made untn we complete our evaluation of overall
objectives. selection criteria, and data base. The Steering
Committee wtll be given the opportunity to review our selection
process and recommendations prior to us making a final decision.
Trusting this meets with your approval.
Sincerely.
Kevin R. Young
KRY:db
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ALASKA POWER AUTHORITY
~1r. Bill Law1 ~nee
Anchorage Operations Office
Envirostmental Protection Agency
710 C Street ·
Anchorage, Alaska 99510
Dear Mr. Lawrence!
April 15, 1981
Attached is a mid-point report on Susitna Hydroelectric Project. It is
forwarded for your information fn response to your earlier expression of in-
terest within the context of the Susitna Hydroelectric Pro,ject Steering
Coom1ttee.
l have asked Mr. A11an Carson. the Chairman of that C0111ll1ttee. to forward
meeting minutes to you and to ensure that you are advised of scheduled meetings.
FOR THE EXECUTIVE DIRECTOR
Attachment: As noted
cc: Allan Carson w/o attachment
Sincerely,
gavid 0~ Wozniak
Project Engineer
CONCUR:
ow RAM
ALASii.A J:»O\VEII. AUTUOiliTY
MEMORANDUM
\
\ TO: For the Record DATE: May l, 1981
FROM: David D. Wozniak~~ SUBJECT: Steering Committee Mailings
511./£)'1
On April 23, 1981, copies of the APA mid-yea; report and the Plan of Study
were hand carried to USGS and AEIDC. Co~ies of the mid-year report were
earlier mailed to other members of the Steering Committee. With this
action, a11 member of the Steering Committee either possess or have access to both documents.
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May 8, 1981
279-5577
n:..:cr.:IVED
:.:/•.'/1} 1981
Eric Yould
Executive Director
Alaska Power Authority
333 W. 4th Avenue, Suite 31
Anchorage, AK 99501
Dear· Eric:
The Susitna Hydro Steering Committee has reviewed the Alaska Power
Authority's March 1981 Mid Report to Governor Hammond and the Alaska
Legislature. Specific comments from the Steering Committe members
regarding this report are provided below. In general, ho~ever, the
Committee was disappointed that APA did not permit our review of this
report. prior to its circulation, as several members have discovered
factual errors in several locations in the text, and most have reservations
about conclusions reached by APA regarding environmental feasibility.
Dave Wozniak has assured me that, in the future, the Steering Committee
will be included as reviewers of all APA documents of this nature on
the Susitna Project,. and in particular I have been assured that the
Steering Committee members will be provided an opportunity to comment
upon the draft of the final feasibility report to the Governor and
Legislature scheduled for March, 1982.
The following are specific comments on the 1981 Mid Report:
1. There appears .to be a great deal of misunderstanding on the
part of the External Review Panel (and perhaps others associated
with this project) regarding both the scope and the completion
date for the feasibility studies. The feasibility studies
currently underway will not, as we understand it, terminate
in mid-1982 when the Application for License is filed with
FERC (assuming the decision is made to file). Feasibility
studies will in fact continue for several more years in
order to gather sufficient environmental or other information ·
with which a reasoned decision can finally be made whether
or not to construct (FERC staff alone will require a great
deal more information than will be available in 1982 with
which they can prepare a draft environmental impact statement).
The March 20, 1981 letter signed by five members of the
External Review Panel refers to " ••• feasibility studies •.•
completion in April, 1982" ancf " ••• present studies, supplemented
by appropriate additional investigations, to their 1982
completion date." While "Phase I" may end in 1982., "Phase
Eric Yould 2 Ma ., 1981
II" will continue for several more years, as we perceive it.
We suggest you make this point clear both with the External
Review Panel and with the Governor and Legislature. We also
suggest that, via your public participation activities, the
public be fully and accurately informed about the length of
time required to (a) determine whether or not to apply for a
FERC license, (b) finally determine project feasibility, and
(c) obtain a FERC license and actually begin construction.
2. The Steering Committee is of the opinion 'that the report is
too much of a "sales document" rather than a balanced assessment
of what is known to date regarding Susitna feasibility. For
example, it is stated on page 7-6 "Whether positive or
negative the overall change in the Cook Inlet salmon fishery
will probably be slight." Recognizing the paucity of supporting
data the committee feels this conclusion, and others like it
in the Environmental Implications chapter, are premature.
3. Individual Steering Committee members have found technical
errors in various places in this report. Rather than enumerate
these detailed comments at this time, you may expect comments
from individual Steering Committee members or their agencies
in the near future.
Finally, I have been informed that the External Review Panel plans to
convene in Alaska in the near future. I request an opportunity for
the Steering Committee to meet with the Panel, perhaps when they are
briefed on this year's field studies. Also, in order to keep members
of this External Review Panel appraised of future Steering Committee
concerns and technical comments on the Susitna studies, we feel it
appropriate to circulate to Panel members letters, memoranda, etc,
generated from the Steering Committee. We believe the Panel members
would benefit from Steering Committee comments, particularly sin~e
they might not otherwise have an opportunity to gain insights into
state and federal agency scientific/technical, regulatory, and public
interest concerns.
I hope you find these comments constructive. We will provide Mr. Wozniak
a detailed outline of steering committee interests and concerns regarding
the Plan of Study at our May 28 meeting.
Sincerely,
Al·carson
Chairman
cc: Dave Wozniak
Steering Committee Members
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ALASKA POWER AUTHORITY
Mr. Al Carson
Cha1nnan
Sus1tna Hydroelectric Steering_
Conmittee
Department of Natural Resources
323 E. 4th Avenue _
Anchorage. Alaska 99501
Dear Al:
June z. 1981
Thank you for your letter dated Hay a. 1981 concerning the 1981 Mid Report
and associated matters. Regretfully, heavy travel commitments within the
office have sl<Ned this response somewhat. Nonetheless, 1t is important
tt1at the points raised by you,: letter be addressed.
Our current schedule calls for the publishing of a very well developed
draft of the final feasibility study report by March 15, 1982. I reaffirm
our commitment to provide this draft to y~~ and fellow members of the
Steel 'ng COUIDittee for review. I tb1 nk there 1 s some confus 1 on. however,
concerning other documents to be reviewed. J,,_ principle, the Power
Authority welcomes the Steering C0111nittee review of our various effort . .-.
Unfortunately. we have not yet agreed as to the 1tems worthy of Steering
Conm1ttee review. As I have noted to you on several occasions. we would
1 ike to interact with the C00111ittee rather than continue the intenn1t'b!nt,
somewhat adversary contacts that have characterized our past discussions.
If we are to be truly interac~ive. your cont:oibution to defining the areas
of interaction is ess-ential. To that object1'fe, let me repeat my suggestion -
that the Steer1ng Comnittee~ u,t11iz1ng the Plan of Study as its gu1de11net
identify specific areas and/or events and the assocht"<t degree of depth
with which they wish to be involved. Given a clear undi!rstanding of
expected areas of interaction,_ the problem of Steering Conlnittee review
or nonrev1ew of the Mid Report might not have occurred.
Insofar as future project milestones are concerned, the effort currently
in progress. var1ous1y called 11 Feas1bi11ty Study 11 and/or "Phase I",. has
as major objectives. determining the technical and economic feasibility
of the proposal. and, tf feasiblet. generating the data necessary for a
Federal Energy Regulatory Commission {FERC) license appltcation. This
step 1s bounded by a Power Authority contract with Acres American. Inc ••
a contract which terminates in mid-1982. That date fs consistent with a
pa.ge T~o
legi slathely mandated Po\ter Authority recommendation to the Governor
and Legislature by Apr11, l98Z on project continuation or abandonment.
The underlying assumption is thnt sufficient information will be available
by that time to r:mk.e a reasone'd and reasonable judgment on •.'f'hether or not
to submit the license application. (Please note that this is not a
decision to .. build" or "not bu11d" ~ a point I will address further on.)
Str1ctly speaking then~ the 11 Feasibi11ty Studyn 'fd 11 1n fact tenninate
1n rnid-1982, by virtue of the contract terminating.
If the mi d-1982 decision is to continue w1 th the Sus itna Hydroe 1 ectri c
Project proposa1, we wfll enter a period frequently referred to as
Phase II. It \Vould be characterized by submittal of the FERC license
application, comnencement of detailed engineering development, and contin-
uance of a substantial amount of'1nvest1gatfons of the project area,
including such subjects as fish resources. By m1d-l9S4. 1t is anticipated
the license application, as su nlemented and modified b the cont1nuin
1nvestilat1ons, wi11 be approv • ven C approva· and a n er o
other,esser regulatory approvals). the question of build or not build
wi11 then be referred to the State government. where a decision on con-
struction will emerge through .the political process.·
Recent discussions with the EXternal Review Panal suggests that they are
v-ery clear on this sequence o~ events, and th1s s~~ concept. {although
worded slightly differently) was advanced in the nid Report. Accordingly,
I must conclude that both the panel and the public have been fully and
accurately informed about the project flow.. Certainly, there was no intent
to be anything less than accurate. and intimations to that effect warrant
strong objection.
I regret your letter arrived too late to accommodate a joint convening of
the Steering Committee and th~ External Review Panel. As a partial accom-
modatfon to your request for such a joint convening, please let me note
that the meetings of June 3-5~. l9Bl are open to the public, and members
of the Steering Comnittee are more than welcome to observe the proceedings.
(The Committee was made aware of this last week.) We agree ~ith your
suggestion that the External Review Panel be kept appraised of Steering
Committee concerns and technical comments. and have no objection whatsoever
to circulating letters • memoranda, etc. • generated by the Steering Coomrittee.
However, a review of such material indicates the only data generated by
the com;tittee to date are comrients to the procedures manuals. a letter
concerning the access proposals, and your ~~Y a. 1981 letter. Finally,
with respect to a joint conven.1ng. we are certainly agreeable. I think
we need further discussion to define format and attendance; for example,
1 am not sure that our geotechnical representative would gain greatly from
coments advanced by the natural sciences community. Perhaps we will
want to focus our efforts on the environmental representative, Dr. Leopold.
Further. to be efficient (substantial expense is involved in bringing the
Page Three
ALASKA. PO\{ER AUTHORITY
panel members to Alaska and paYing their per diem) as well as professt-l,.
1 am sure you wi 11 want to give some thought to the structurtng: and .. , ..•
content of your fonnal presentations. l wou1d welctXt.e continued dfat.,:
on thfs subject.
. CONCUR: RAM
EPY
Sincerely.
David o. Wozniak
Project t>tanager
DEPARTJUENT OF FISII A~D GA J'tiE
JAYS. HAM MONO, GOVERNOR
2207 Spenard Road
Anchorage, Alaska
August 21,
Mr. Jeffrey 0. Barnes
Environmental Study Manager
Terrestrial Environmental Specialists
R.D. 1 Box 388
Phoenix, New York 13135
02-V-81-TES-8.0
RE: Anchorage-Fair-banks Preliminary Transmission Route Selection
Dear Je.ff:
Attached are the comments by Region II of the Habitat Division to the
proposed Anchorage-Fairbanks Transmission Route.
I might note that Sport Fish Division•s Regional Supervisor, Russ
99503
Redick, indicated in a recent meeting that a State Division of Parks
access and wayside development extending from the Parks Highway on the .
north side of Willow Creek to the Susitna River is envisioned for possible
development if funding is approved the Legislature this next session.
Consideration should be given to the potential impact of the transmission
1 ine to that proposed development, which is expected to receive heavy
recreational use.
The Su Hydro Aquatic Studies Team has no additional comments at this
time.
;;+.~
Thomas W. Trent
Su Hydro Aquatic Studies Coordinator
Telephone: (907) 274-7583
cc: C. Yanagawa
~: ~~g~~~der
c9 z-:c-~~ -1fJrFrE:::>--D.
-,VlEMORANDUM State ot~lcisk~~~-IE!>-£;.
,_ To: Thomas W. Trent DATE:
·tr L_o..
Augus.t 6, 198~ .. ~.· '·9~/p Su-Hydro Aquatic Coordinator
Sport Fish Division
Anc;:horage
FILE NO:
TELEPHONE NO:
:~~.. . . . -.) -. · .. ~b·
344-0541, Ext.~l>., · .,..
. . : "'~)0~ .· . ~~~ .. ~
-78~ 0;-ol
....fROM: Carl M. Yanagawa W
Regional Supervisor
SUBJECT:
#v~ ~-. Anchorage~Fa i rbanks ~84;.r~ cf .
Preliminary Transmission q ~ Q~
Route Selection ~o s Habitat Divisi
~e ~Y: ....--Th"AJhrm1nsk.i,
-
-
-
-
Region II has reviewed the preliminary route selection for the prop~sed
transmi~sion line and.submits the following corrments:
-. . .
In areas where the line approaches or infringes upon Susitna State Game
Refuge, alignment should be adjusted to avoid areas utilized by moose
and waterfowl. Clearing and construction near these areas should .be
scheduled to minimize disturbances to wildlife.
The R-0-W segment from Cook Inlet· to Talkeetna especially ~east of the
Parks Highway north of Willow should be cleared and encourag-ed to regenerate
as moose browse. Between Willow and Talkeetna this ·has the benefit of
possibly halting the westward winter migration of-moose to the Susitna
River. On years with heavy.snowfall as many as 200 moose have been·
killed by motorists· and trains as they wander through the area. "In ·
addition, R-0-W clearing and construction must be scheduled to prevent
conflicts. with moose and sport hunting activities.
With respect ·to stream crossings, most of the streams within the proposed
corridor provide spawning and rearing habitat for anadromous fish. We
do not expect any significant fisheries impacts from an aerial line,
however, R-0-W clearing must be avoided at crossing sites to maintain
watershed integrity and preserve riparian wildlife habitats.
We suspect that there will be a great public outcry with respect to the
aesthetics-visual impacts related to the proposed alignment, especially
where it nears the highway, popular recreation areas and small COff!llU'!ities.
We suggest that APA conduct pubi ic hearings regarding the proposed · .
alignment and delete or relign those segments· of the route that are· ·
most objectionable. Most of our concerns can be met through use of .
timing constraints, stream buffers, selective clearing, h-el i~opter
and/or winter construction.
If you have further questions, please contact us.
ifr.; &ie 1~14, &ecutive Dir«w
Alaska Power ~tty .m Vest fovrtn AYem.e
~,. Al.u.ta ggsQJ
Dear ftr. l'ou.ld:
I Mr£:.aa•aw a
I
f{"E.CciYED
The. ~e of tbts 1e'tter is tc t~t to the Alaska Pt:M!r Authority
'APAl ... ~ .. -....a... r •• --+-~.AT -~-_. r-.a...-· ... ~ ....... (SliSC} -\ ~ z .....--·~ ~ 'l.f~ ~1~~ H, __ ectrlc !iteer".ng '-Uii~P.!t .. ld-""""'1: • • CCd
t.ern1ng AM.•s ~sals for ilCC$S to tne ~sed Susit.na iiv~ d.ia sttes.
These ~s are in Te5poose to information proyidt!d t.~ sust fl""C'C t1110 4c:cess
ro~te ~~eeting;s 'lritb APA and 'their-amtrA-Ctcr-s: and tbe docu;ients ~re-:i by APA
cuntnd:Dl'$. and distribfrted durir.q these JeetiPQSr At t:he October 20., 19tH
~t.1ng f..flA ~~t.td SHSC O"'aet?nts by imvember 6., 1981.. The 5HSC ~;o-precia·!'"cs ·
the fact that APA c-cntimA"d deailet:I CQ.'lSidaratiQn ami ~1es ~ sf.!Yer:gl ~Q;ess
T'o.\lte cptic.~s th1~ year 'r"atr~r t..~ fCCl.IS'ing O."l a. :single ~..e ..
The St'i..SC review iGefitifie-J four arus of ~rn that merited ~tr'"~~, ... _:rr::,~
Thu~e four ~ce= I
! $_:}.TNA .,...,..,_.
1.. A crtt11;lue of the studie! of .11:cess roo.J~ idlif;oiot ¥'"ovid!! fo:r amtt:l"J''1i"E ,-c>~f(}'l,
tion of t.~ dam... J .·//. c
i<:L<=r>' :..· .. • ..... ; 2~ 1r.e. relatiOl'.ship be~ t1-.j~ \lf access root.! con!!.tr.sc:HD» ~ndtr·"t;·~~-.:, 7
fee~al Energy ~qliJttiry ~;(s:s:ion (FERC) approv4l f\l.f" ~<=-ft. -~/" I f4'-
l:z ~ ::::
The relationship of ac---~s F-~te d.~ision 4t'.d ~e:s af·<i«-es:s: to g c ~ _
rc';Jian.d land use EWla.g~t ¢Hc;1es. ·. -lit ; .. --~
I--./ --
Thl! ·issues resultant frf:m la.nd sta:tu.s and lar.-d O!!mership Affect.~~.).; __
~~~~~ 1r"~
} ' ; Tt-e f!ssessment of c.orridor rcute oi7t..."'r"natives should a;sre adEq"uat.l?ly ~Sfi"-R~-;.: ··
tl'".e: pottttia.l ~c:ts of boM"''W sites a~ access to t.hese sites. and tra.-1s-r ;-; . .,
~ission l.ine{~) mn:i!";S-Access corri~J'"S ~ich serie a -~17 0(-t:r1p1e. ijur-Po~~;--ii "CC
1n f"e9:aro -to tr.ese atrif!'" project acr!Ss r:~ would be fnghly des1rabte fiqm-t:ll· ..
decis1on-m~ing crite..-ia... 1-. ! i
t ~ §0'-!h
:. ;_~ {:;: ~---,. c-·
. ~ ~;.;..
j...--.l-; --;--
1 i ;~-7-
r·~ Li r.:7U
I ~ t::::-?. ,..._... . I ~ ·.
~·
-
-
-
,_
-
The ~cess preferences-expressed be. low pertain tc the ~emmt 1 loc.tt1ons
~;ited. for tnt! comdors and il"t! based upon the envil"tH1iiii!fltAl d4.t4 l!r4_c.tme1u-
sions contained . · + envirotmertta.1 dooEGf!llts prepared for S\lbU$k ·2.~10.
ACc.tis Road Asses~t~ It dQe!i not represent. our. . --rs.euent c a part.1cu1ar
I ~1e-'!ride arridcr,. as presented~
'Tht! SHSC ~ w1~\ the Terrestrial fnviroJIIl!el1tal S;Jec;'ialist.s. Inc.-pos.i-
tion that aa:esi via t.M Alaska. Raflraa<i to Gold Crea is-environeerltally pn::-
ferable.. bilr1*1 access to at least Devil Canyon wuld alienate the need for
il St.i.9ing !Tea ilt Gold. {;.roeek and the CQDSequertt luil.\n ACtiVit,Y~ 14r.4 ~ •. fuel
iiiHls.., ~w other illlpacts oo the Gold ~ ~•~ We·· recogft1z.et.t ti\at • $tilging
iln!il. at Detil Canyon ~ld ·be required in ~·cu-e-. Tbe use--of tiris an!& as tnt!
teratnus cf a raili"aila ~r"$ to •e iJ grat deal of ser.se~ Addittcr.aHy., tile
feel 'fjat the-~-side ~ -m.:. Qfld "-eek to Dr!vil tanym is preferable
since a trail illread.Y e:ists: ~. f'nll Devil ~ to atana. w.. PN4er a
rou.te en the north ;.1de of the Si.rsi~ .River... lit the Oc.tcber zo .. 1.981 ~:c1~
me SHSC 1lillS iaronr4 by i'lr' .. ilitv1ct wozntak of NJA th&t ~ were net (2}
~ddftitmll ra.tlrcad :'CltteiiiOde options (a total of 10:) • If feas1ble • ~
~ny pn!fer a nH IIOC:!2 of acces.s to-and within l:he project site.
The sn-sc identtfi~ three (l} aw.t~tail.Y sensitive •reus that should
be 41\tOide<t. Those ire~
2. T~ route crossing the lnd1an River and t.hrooqh ~damis to t.'!e Parts
iitg~Y~
3. The rnu+..e on fr.e: sooth side \'lf L~ Su.sitr.a. Riv\!1" fn:m DaBs Cdnyoo to
t."ie prcpQSed \ia. t.iUiA C-.ia S l t@ ..
in evaluattntj w access nr.Jte-selr:ct'ic.n p~"C~5~ ur..dertak~ by the APA ana
tr-...s contnc"'L.Ors, the Steering Ca!lrlittee questions the validity af t."li! pcwer-::Jfi-
1 i.ne 1R I:f-93 aSSI.Iiiiptior./~te.. lr~ ~lie' ve got to hurry up and put in ···ot road
to Ee.t the 1!#93 daa.dlir.e~ ;;.pp:roach appears, ~ currently available repor~
ar.d t..~ briefings received by the Susitna Hydroelectr-tc Steerin9 ~1 ttee an
Ocwber 20,. 1981'" to point 'tL-;ward tiE necessity of a pigneer ro.,=d c.on~=rt:t-..w;tf;d
before 4 f£RC He....c..nse 1s gr~nte<iw or se:Jectton af an ilpp.s:1nmt.ly enviro~n~TTy
ur.a(;ceptable Oef>A~li Higt:-l'!!fay ;;~cc-5s rotrte ..
local utilities a~ not a.ppi*O.!ichinq c--onstruction of !1. pr-oject the magnitude
of S~sitr.a in 1993 as a fo~one conclusion arlfl are ~king co~t1ntj,::-t.-c.r ~11ans to
meet projected pm;cr r.eeds£ Sas and CC41 !j£neriit81 ~"""A!er "'-ptions are being
ex~inett~ ln i1-1d1t1on, fEaSibility studi~ are cu.' e.ntly being underuken by
t:'::-.e: U.S. Amy Corp~ cf £r.9inettrs and t.lte Ju0 A at mE-!!:--ous pa~ntial hydr~lectric
generatir .. -a ~ites£ ~H~.t bHt-elt ~lo:dric ?r:rm;r A1ti?I1".ative Study should
provide ins1aht into add'{ i..lo~-T . n •~»" H m (' ,t" "cnc-.. ks sucn~ we believe:
.. a;:-.. t.~ 199.3 &deadHr.e~ for-p:mr.:r"-<m-Hne fl""a'a Susit.'iil £ay r10't t-e t.t>.a.t. fin:! ~d
i~erative. Thus the S.HSC !i.':fes r,ot believe th@ 19:13 ~d.Hne s.hould const.. ... ain t.ne 0<1~an decision ;:-;ak.ing prne.2Ss a.r:-rl t.~ on:ierly pr09ress of various studies
o.n project feasibility an.d snvirorEStta1 ~r.acts. Pe:rmittir;q il.nd resource
age-r-.c.1es. \-nc.Jud'ifl9 f£RC~ ::.oo.;ld ba &P£ded to 1tnk ~ pioneer read to tt.c:
overall proj~~.
Pub11c auess tu the da:n sites and t.brough the Upper Susitr-4 Ya11ey is
canpl~ ana 1 controv(•rs1al subjec:t ar.d we ~lieve this issue S&t-.au1d be 9~ve11
thorough eva1uat1on in the route $elect1on process. How can~truction~related
access is obt41ned to a gre11t ext.ent determines t.h.e project·l"'elated wildlife c1nd
soc1~i~ impacts. The APA has been ~o1ic1ting the views of local residents
(T41keetna. Trapper Creek .. etc.) in reqard to the access question. The mjor'ity
of resfdents wnt to minimize iqtacts to both the1~ camwnity An<£ t.t.e Upper
susitr.a Vdley_ lhe APA. has solicited the w-1cws of the· state .tnd federal resource
igeneies.. !t has been the prv.dOIAinant v1ew of these agencies. which represent
public interes'U on a: state or n9tionat le.vel; t.ha.t projett ... related wildlife
impacts should .be limited to the §lXiiUR extent practicable. In addition .. the
APA has expressed the desire ~~·nl'h:-the. option!., for future public access.
We· believe that these views JIM!Sih,. M~i.drt9 1mpact.s ilnd maximi.ting options tor
future public access an be achi~.ved t~y J:JiJr:ickingr to the e.xteo.t possible,. the
status quo. for exlBJ'Jc. to provide full publjc acCl!ss through a road systeJta
forecloses the: future option of maintaining the ex1sting tharacter of the Upper
Susitn4 vaney ..
Use of r~t,n a.s tfle access mode tncreases the .POtential for management a.nd
control of setdaecananic and enviromtenta'l impi%c:::ts~ ~ h':lized rail use provid~s
for the fo llni.ng advantages over road access:
1.. . lb•tntains a ~x.imt.l!!. range af future decision options.
2. ~'lid~~ fur control of worH\" impacts on )oc~l t~Jn1t1e~ and wild-
life ..
3.. DecN.~ses the potential of fta.z.~r-tious :r~t.eriil1 spills due t.o adver$e
~ther condition$ and multiple handling~
4. Disturbance t.o wi ldl He adjacent ;;o the route can lie ~ft easily
controlled.
5~ Di~t ~cc~~s r\9ht-of-way ~Tate4 habitat losses can~ stqnificantly
1\mf ted ..
Sriefl:t tm! 1and status of the ?m.Iect anN! has not changed significantly
within t."'e la.st year& There a1~ severa1 .wm~lex prut>l~.s c.onccrnin9 land status
that ~~ve been brought to your attention by BL~-
Thank ycu for the o~,portunity tQ -re:\!iew <md co;rrr.ent on the Ar.ce~s Road
A~5.cssment doc~-ents. we 1ook fprw{!rd tl.2 rc.-ce1ving the final ver.iil~m of these
docw.:enb after flove1iber 15, 1981~ ami anticipate prov1d1fi<J ad.ditjo:Jal recom-
IDe:-ndiitiQns into this dedsian-making proce~s~
Slncere!y,
P.l carson; C:hai'f'i!'.an
Susitna Hydro:1Ectr1c
SteertniJ <:o.:-mitte~
ce: 0. Woznia~. ft~A
Steerfr~ Caffrnitt~ ~~nhers
~L Stooy~
-WILLETT
WITTE
BERRY
HAYDEN
LAMB
1""' LAWRENCE
SINCLAIR
r-----
• r-. 'I· ... •
Mr. John Rego .
Bureau of land Management
701-C Street .
Anchorage~ Alaska 99501
November 9, 1981
P5700.11.75
T .1258
Susitna Hydroelectric Project
Transmission Corridor Report
VANDERBURGH
Dear Mr. Rego:
~-
1""' ...,
.....l ~
CARLSON
FRETZ -JEX
" LOWREY
SINGH
F""
HUSTEAD
BOVE
r ~
I CHASE
I
./
V' :;;/ /,-
-
As you know~ Acres.Amer)can~ Incorporated is under contract to the Alaska
Power Authority to conduct a feasibi 1 ity study and prepare a Federal Energy
Regulatory Coii1Dission (FERC) license application for the Susitna Hydro-
electric Project. The scheduled date for submission of the application is
in June of 1982.
Federal law and FERC regulations require that the reports supporting the
FERC application be prepared in consultation with Federal and State agen-
cies having managerial authority over certain project aspects. This coor-
dination must be documented in the 1 icense application •.
A great deal of coordination has taken place at .agency staff levels by dir-
ect participation in studies or by participation in committees and task
groups. This input, however, has been prim.arily by staff and may not nec-
essarily reflect the views of the agency. For this reason, we are conduct-
ing a parallel formal coordination process, by requesting agency comments
on key study outputs. The plan of study was the first document coordinate<il
in this manner. Over the next year, there will be several more. This par-
allel process will affect the other coordination activities of the study.
At this time, we request that the Bureau of land r~anagement review the
attached Report, "Transmission line Corridor Screening Closeout Report",
particularly in the areas of aesthetics~ land use, and land management.
. ACRES AMERICAN INCORPORATED
Development Selection Report - 2 November 9, 1981
Your prompt attention to this matter will enable us to continue planning
the best possible development for all interests. A response within thirty
days of receipts would be greatly appreciated. Please send a copy of your
comments to:
JOL/_MMG:jgk
Mr. Eric Youl d, Executive Director
Alaska Power Authority
333 West 4tll Avenue ,
Anchorage, Alaska 99501
Very truly yours,
--4.AJ
f[J,~)/;VI~ tAuft
John D. La'wrence
IT Project Manager
cc: Eric Yould, Alaska Power / Authority )·
ACRES AMERICAN INCOnPORATtu
-
Preceding letter Sent To:
·Mr. tee Wyatt
Planning Director
Matanuska-Susitna Borough
Box B
Palmer AK 99645
Mr. John Rego
Bureau of Land Management
701 C.Street
Anchorage, AK 99501
Mr. Tom Barnes
Office of Coastal Management
Division of Policy Development
and Planning
Pouch AP
Juneau, AK 99811
Mr. John E. Cook
Regional Director
National Park Service
540 West Fifth Avenue
Anchorage, AK 99501
Mr. Ernest W. Mueller
Conmissioner
Alaska Department of
Environmental Conservation
Juneau, AK 99801
Ms. Lee McAnerney
Department of Regional Affairs
Pouch B
Juneau, AK 99811
Mr. Ronald 0. Skoog
Conmissioner
Alaska Department of Fish and Game
Juneau, AK 99801
Mr. Keith Schreiner
Regi ona 1 Director
U.S. Fish and Wildlife Service
11011 E. Tudor Road
Anchorage, AK 99503
Colonel lee Nunn
District Engineer
U.S. Army Corps of Engineers
P.O. Box 7002
Anchorage, AK 99510
Mr. John Katz
Alaska Department of Natural
Resources
Pouch M
Junean, AK 99811
• Mr. Robert Shaw
State Historic Preservation
Office
Alaska Department of Natur'al
Resources
619 Warehouse Avenue
Anchorage, AK 99501
Regional Administrator
U.S. Environmental Proection
Agency
1200 South Avenue
Seattle, WA 98101
Mr. Robert McVey, Director
Alaska Region
National Marine Fisheries Servi/ce
P.O. Box 1668
Juneau, AK 99802
JA'f S. HAMMOND, GOVERNOR
DEPARTMElWT OF N&I'IJRAL RESOIJRCES 619 WAREHOUSE DR •• SUITE 210
ANCHORAGE, ALASKA 99501
December 4, 1981
Re: 1130-13
John D~. Lawrence
Project Manager
Acres American, Inc.
DIVISION OF PAIIICS
RECEIVED
DEC 14 1987
ACRES Amt1HiiiUi mt:naeORAT£0
The Liberty Bank Building, Main at Court
Buffalo, New York 14202
Dear Mr. Lawrence:
ALASKA POWER
AUTHORITY
SUSITNA
F; .,00
.. .:.: ....
F..d/'7/
w: have reviewed the 1980. reports by t~e University of. Alask~ Museum de Tifg -5:-: T --
W1th the cultural resources of the Sus1tna Hydroelectr1c proJeCt area. 'fh -0 w L
report documents the survey activities conducted during 1980 which adequ&~~
accomplish the tasks outlined in the proposed work plan. The sampling
designed on the basis of geomorphic features and known use areas seems
surpassed our expectations of site incidence in the area. The report s
· that the first level inventory was very competently conducted and recor
The second year activities as outlined in the procedures manual was acco~
plished in the 1981 field season according to information gained throug
verbal conununication with the principle archaeological investigators.
understand that the field research strategy was changed slightly from th --l
expected due to information gained during 1980. These changes appear tOUJ..<L\L.t:.------'-_j
more directly addressed problems which surfaced during the course of analysis
of the 1980 data. A final review of the 1981 results and reports will have to
await receipt of that document.
We feel that the steps taken thus far in the cultural resource management of
the project have been excellent and one of the few instances of adequate lead
time. We would like to make the observation that the work thus far is only
preliminary to the work yet needed for the Susitna Hydroelectric project.
Reconnaissance and testing of yet to be examined areas should continue. The
clearances of specific areas of disturbance provided as additional survey by
the Museum should indicate the continued need for clearances of ancillary
projects which could affect cultural resources. Also, a formal mitigation
plan for those sites to be affected by the project must be formulated. Once
definite decisions on the route of access to the project area from existing
road systems are made, those·access routes and material sites must be examined
for conflicts and needs for mitigation. Issuance of a permit by the Federal
Energy Regulatory Commission should and probably will include provisions
specifying under federal law the need for such protection.
John D. Lawrence
December 4, 1981
Page 2 -
If you have any questions regarding our comments contained here, please call
us. We look forward to receiving the report on 1981 field work.
Sincerely,
Chip Dennelein
Director
cc: Dr. E. James Dixon
Curator of Archaeology·
University of Alaska Museum
University of Alaska
Fairbanks, Alaska 99701
Eric Yould
Executive Director
Alaska Power Authority
333 W. 4th Avenue ·
Anchorage, Alaska 99501
DR: elk
U. S. E N V I R 0 N M E N T A l P R 0 T E C T I 0 N A G E N C Y
REGION. X
1200 SIXTH AVENUE
SEATTLE, WASHINGTON 98101
RECEIVED
DEC 2 8 1981
REPLY TO. M/S 443 A.nN OF:
DEC 2. 1 1981
John D. Lawrence
Acres American, Incorporated
The LiDerty Bank Building
Main at Court
Buffalo, New York 14202
SUBJECT: Susitna Hydroelectric Project, Summary Annual Environmental
Report-1980 and Transmission Line Corridor Screening Report
Dear Mr. Lawrence:
Thank you for sending us the above reports for our review. We have also
received the Development Selection Report and will be forwarding our
comments to you on that report before the end of December.
ALAsKA PowER We appreciate the extensive coordination effort and the opportunity to
AUTHORITY review and comment on Susitna reports as they are prepared. I further
appreciate your attempts to ensure that the views of the Agency are SUSITNA
FILE P5700 adequately reflected in this process. While we have been coordinating
· -·/ ,:-, with the sus itna Interagency Steering Committee, our budget restrictions
s~QUE~C~ NO. have limited our active participation more than I would like. In this
r.J.J/. regard, it would be extremely helpful to us if you could provide us an
I : \overview of your consultation plan and the schedule for future reviews.
z :~! ~ ~ 1This will better enaole us to give you timely comprehensive comments on
~ I-': § ~ I {~em~;~~ ous segments of the study. with the overall project perspective
_l d?;::';~_l __ EPA is particularly interested in information on wetland mapping, water
~~-· '".::_j __ quality and water quantity modeling and project alternatives. The 1980
_t_:-:~·-'Z.J_;~Environmental.Report appropriately points out the inte-rrelationships and
~~· 1 't-Y..Jf importance of these areas to wildlife survival and downstream fish
-~~~ · ecology. However, it .does not cover EP.A's areas of interest directly.
-·-~1 -J ":::.--~· We_· waul d 1 il<e to review the reports on these subjects when they are ------=----av ai 1 ab 1 e i I PC H j . •
--r:::~-si
-;:---~-;· . r-~~----j< ~.-:-· -1-·1.-,'_:,:-.~1-·1 •• \:
--:-H"~-ci
-l-----
>.1m11&i -~t~-~~~
-~-· ·-
' _,
-
-
....
2
l~e support the empnasis in the Environmental Report and related studies
on identifying \"Jays to minimize the environmental impacts of the Susitna
project. In particular, selection of the access route and type of access
is an issue witn long term environmental consequences wnicn offers many
opportunities for minimizing impacts. EPA supports tne concept of
minimizing impacts Dy use of a single corridor for both access and trans-
mission needs, as pointed out in ootn tne Transmission Line Corridor
Screening Report and the Environmental Report. We encourage you to
incorporate tnese kinds of suggestions from agencies and the Steering
Committee into the project selection, construction and operation plans.
Sucn commitments will certainly positively influence reviews of any FERC
license application.
We have some concerns with the conclusions aoout the Central Study area
in the Transmission Line Corridor Screening Report. There appear to be
different opinions on the ~nvironmental consequences of selecting Corri-
dor 1 versus Corridor 14. We feel that additional areas should be ·
included in future studies of the central corridor, to~rovide a broader
data base from which such conclusions canoe drawn. More specifically,
in this area, Corridor One (ABCD), which roughly follows the south side
of the Susitna River, is the recommended corridor based on Acre•s techni-
cal, economic and environmental criteria. Corridor 14 (AJCD) follows the
same route as Corridor 1 from Gold CreeK to Devils Canyon, out crosses to
tne north side of the Susitna River for the section from Devils Canyon to
the Watana dam site. Corridor 14 nas tecnnical and economic ratings as
high as Corri dar 1, but was not recommended because of environmental and
land use conflicts in segment CJ. On solely environmental grounds, it
appears that an access route similar to Corridor 14 is preferred to
Corridor 1 by Doth Terrestrial Environmental Specialists, Incorporated
(Environmental Report page 73 and 82) and the Susitna Hydroelectric
Steering Committee (letter from Al Carson, Chairman, to Eric Yould, dated
November 5, 1981 • ) Therefore, the are as of the centra 1 corri dar to be
further studied should include the north side of the river between Devils
Canyon and the watana dam site to encompass segment CJA as well as
segment CBA.
one reason for the different conclusions regarding the environmentally
preferable route oetween Devils Canyon and the watana Dam site may be the
Environmental Report•s and the Steering Committee•s identification of the
most environmentally sensitive areas, wnich then have tne nighest priori-
ty to be avoided. It may be desirable to use a similar approach during
the more detailed route selection studies, especially in areas where
wetlands must be crossed. Identifying and-then avoiding primary and
secondary impacts to the most valuable wetland habitats snould be an
important part of the more detailed studies of all three transmission
study areas.
3
we appreciate tne opportunity to review tnis report. Please contact me
or Judi Sc warz, of my staff, if you would 1 ike to discuss our comments.
We can be eacned at (206) 442-1266 and (206) 442-1096, respectively.
Eric. You1 d, A1 asK a Power Authority
A1 Carson, Department of Natural Resources
-;TT II I.e
11TTE e,.A..,
I .
January 4, 1981..
P5700.11.91
T.l~90
....... ~ ;; /./r. J'l egi
John R. Spencer
anal Administrator
7 7"-1 s. Environmental Protection Agency
on X I -"" . rr .:::·
-:-·r _1__1 0 All\
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NCI..AI A
0 Sfxth Avenue
ttle. Washington 98101
ANO£A8U.PIGM r Mr. Spencer-; Susitna Hydroel~ctric Project
Formal A6ency Coordination -~
~ 'r -7
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Irtan
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t.U t
k you for your letter of December 21, 1981; your constructive
estions are very much appreciated. I will attempt to respond
he issues you raised:
1. I am enclosing a description of our formal agency coordination
plan, indicating which agencies will receive which reports.
Regarding schedule, EPA will be receiving the following
reports on or a round the fo 11 owing dates :
a) Ffsh and Wildlife Mitigation Options -January 1982
b) In stream F1 ow Study Plan -February 1 982
c) Susitna Feasibility Study -1-tarch 1982
Under separate cover you will be receiving an invitation to
attend a meeting. in P..nc~orage on January 21, 1982 explaining
our Formal Agency Coord1naaion Program.
2. Wetland mapping has been conducted as part of the study.
For your infonnation, I am enclosing the 1980 Plant Ecology
Summa~ Report and a set of vegetation maps. All wetlands
"r<~ithfn the proposed impoundment zones (including a one half
mile buffer) and t-lithin known borrow area \·Jere mapped, utilizing
the new U.S. Fish and H11dlife Service Classification (Coward1n
et. aL 1979}.
Mr. John R. Spencer January 4, 1982
page 2
3. · Project alternatives are discussed 1n the Development Selection
Report which you have received and w111 be disaussed further
in the Feasibility Study.
4. Water quality 1ssues and water quantity modeling results will
be found in the Feasibility Stucty.
5. Following selection of the access route, the trans~ss1on line
corr1dor in the centra1 study area has been expanded (as
1nd1cated on page 7-4 of the Transmission Line Corridor Screening
Report} to include a larger area on the north side of the Sus1tna
River. This will result in a single corrddor being used for
both the access route and the transmission 11ne corridor. This
was done both to eeduce impacts via access and to avoid the
large wetland areas on the south s1de of the Susitna River.
6. Transmission line routing studies are currently being conducted.
Wetlands 1s a parameter 1n the selection process~ I think you
can appreciate, however. 1t will not be possible to avoid all
wetlands in the area, simply because there are so many.
Aga1n7 thank yog for your comments.
let me know.
~lrftG/jh
.cc: E. Yould, APA
If you have further questions, please
Sincerely yours,
~/
John D. Lawrence
Project Manager
""'1
r
-
~SKA POWER
AUTHORITY
t 5USITNA
S't.QUENCE NO.
/:
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
NationaL Marine Fisheries Service
P.O. Bo:r: 1668
December 31, 1981 Juneau, AZaska 99802
Mr. John D. Lawrence, Project Manager
ACRES American Incotporated
Consulting Engineers
The Liberty Bank Building Main at Court
Buffalo, New York 14202
Dear Mr. Lawrence:
R t::"'~--,~ n::o . ··-·.-c. v 1::;.
JAN 0 4 1982
ACR;;..; unitrUtil\1~ ht6UKfURATED
We have received the Susitna Hydroelectric Project ~nvironmental Report
prepared by Terrestrial Environmental Specialists (TES). We have limited
our review of this series of documents to those concerning the fisheries
studies, i.e., the Summary Annual Report and Fish Ecology Annual Report.
The presentation of 1980 work done byTES towards assessing the impacts
of development and operations of the project on the fishery and proposing
measures to minimize or mitigate adverse impacts was reviewed without
substantial comment, as much of it was very preliminary. Also, no
review was made of the 1980 fish ecology program due to delay in pub-
lishing the detailed procedures manual. In addition to ~he lack of
substantial infonnation presented in these reports, we believe the timing
of this review request makes an in-depth agency review inappropriate.
The main benefit derived from this review would have been to allow changes
or redirection of efforts to be made in the 1981 field studies. However,
as of this date, the 1981 environmental studies have been completed.
We look forward to receiving the 1981 Environmental Studies Annual Reports,
as these documents should provide the basis for our review of the draft
Feasibility Report.
Sincerely, ·
.----~J;··' ~ --$--df?~ /Robert • McVey
(/ r, Alaska Region
'~. (~--J.-, v~j, \.
i •/
I
United States Department of the Interior
IN REPLY REFER TO:
FISH AND WILDLIFE SERVICE
1011 E. TUDOR RD.
WAES
Mr. Eric Yould
Executive Director
Alaska Power Authority
334 w. Fifth Avenue
Anchorage, Alaska 99501
Dear Mr. Yould:
ANCHORAGE, ALASKA 99503
(907) 276-3800
Mr. John Lawrence of Acres American, in his letter of November 9, 1981,
requested that we review the Transmission Corridor Report. We offer the
following comments:
Although we realize that the Anchorage-Fairbanks Transmission Intertie was
assessed by Gilbert/Commonwealth and not Acres American, the two studies
need to be fully compatible, coordinated, and unified in a single document
for submission to the Federal Energy Regulatory Commission (FERC).
· .HUJ$tfA il'<bWI!R
l!IIUJHORITY The conclusion of the Intertie study was that it is justifiable in the
absence of the Susitna Hydroelectric Project. However, the Susitna
Project is not viable without the Intertie. In that we anticipate
reviewing the Intertie as a component of the Susitna Hydroelectric FERC
license application, we believe it should be included in the pre-license
coordination process.
s;!~rrrN"'
SEQl1ENCE ~
Fd.
l·ts :E Di
0: ii 0 ~ The extensive public participation workshops undertaken for the Intertie
were well done and provided for an effective interagency and public
dialogue. We highly commend the Alaska Power Authority (APA) for that
program. We recommend that a similar effort be undertaken for the Susitna
Transmission corridors selection process.
i= u b.
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0
DC:W
i -··
Land ownership is a potential major issue and needs to be fully explored.
It is not evident from this report that a sufficient effort was expended.
The list of authorities contacted (p 8-3) does not list representatives of
either the Bureau of Land Management or the Alaska Department of Natural
Resources, the principal state and federal land management agencies.
--=1-SF.:,.,ill/
Remote lakes, such as those in the Matanuska-Susitna Valley, are utilized
by trumpeter swans for nesting and rearing cygnets during summer and
fall. Recent data indicate that continued development and disturbance on
lakes used for nesting is causing birds to abandon certain areas.
Selection of a transmission corridor should be accomplished cognizant of
the habitat requirements and movement patterns of waterfowl and other
migratory birds.
---,-. ,~~~--·---~----:--. -__ -----~ --~-----------
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-'
,, ...
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Mr. Eric Yould Page 2
As required by the Endangered Species Act (87 Stat. 884, as amended), the
FERC, or their designee, should formally request a list of threatened or
endangered species. from this agency. If the list indicates that these species
are present in the project area, FERC is required under Section 7(c) to
conduct a Biological Assessment. This assessment would identify any listed
or proposed threatened or endangered species and discuss potential project
related impacts~ The assessment is to be completed within 180 days a.fter
receipt of the official list, unless a time extension is mutually agreed
upon. It should be noted, that this work toward the assessment may have
already been completed through your previous investigations, and should be
included as part of the Environmental Impact Statement for the project. In
any event, no contract for physical construction may be entered into and no
physical construction may begin until the Biological Assessment is completed.
If the conclusions drawn from the Biological Assessment indicate that endan-
gered or threatened species are· likely to be affected by the construction
project, FERC is required by Section 7(a) to request formal consultation.
Management of the transmission line right-of-way (ROW) could result in positive
or.negative habitat value impacts. In.certain situations clearing of the
entire ROW width can.be undertaken to enhance moose browse. In other places
minimal habitat disturbance may be the most appropriate management·. Once
transmission corridors have been .agreed to, discussions as to appropriate
habitat management practices should be initiated with the FWS and the Alaska
Department of Fish and Game (ADF&G). Clearing for the purpose of enhancing
moose·browse should only be done after an on-ground evaluation by the ADF&G
and Alaska Plant Materials Center to ensure that vegetation within that
corridor can be enhanced by clearing.
Where the proposed alignment follows the existing highway, railroad, or
utility corridors, the potential for disturbances to wildlife habitats would
be minimized. Access to the dams should be fully coordinated with transmission
line routing. Access corridors which serve a dual purpose in regard to
project access needs would be highly desirable from several decision-making
criteria.
Public access to the damsites and thro.ugh the Upper Susitna Valley is a
complex and a controversial subject and we believe this issue should be given
thorough evaluation in the selection of access routes, mode of access, trans-
mission line routing, and method of maintenance access for the transmission
lines. How construction-and maintenance~related access is obtained to a
great extent determines the project-related wildlife and socioeconomic impacts.
Construction and maintenance of transmission lines should not provide for
additional public access over that provided by the dam access route.
We concur with the report conclusion that of the three corridor alternatives
presented for Healy to Fairbanks, segment AB.C is the most acceptable. Our
preference would be for the transmission line to closely parallel and when-
ever possible to share the existing Healy-Fairbanks transmission line ROW.
Also, we believe that an additional alternative, that of sharing the railroad
ROW, should be evaluated.
We concur with the Acres American position that segment AEF is the least
desirable alternative of those presented for the Willow to Anchorage
Mr. Eric Yould Page 3
segment. We also agree that segment AB would have extensive adverse
environmental impacts. However, we believe further study should be
undertaken to evaluate corridor options from Willow to Palmer which are
closely aligned with the highway or other existing ROWis.
Mitigation for transmission line construction and maintenance impacts
would need to be incorporated into the overall mitigation program for the
project. In addition to recommendations emanating from aforementioned
points we would expect recommendations such as the following to be
incorporated into the plan:
(1) Should any eagle nest be found in specific siting of the iine, a
330-foot windfirm buffer would be established around the nest trees;
(2) winter construction would be used in lvetlands to minimize adverse
impacts and in the vicinity of rivers so crossing can be by ice
bridges;
(3) helicopters would be used to construct and maintain the transmission
line in areas not easily accessible from existing roads, trails,
railroads, or planned ground access for which the primary purpose
~ould not be related to the transmisson line;
(4) where overland maintenance access is adopted, such access would be
minimized to no more than one route between major stream crossings or
other geographic barriers; and
(5) 100-foot-wide vegetation buffers remain alongall streamsand rivers
crossed by the transmission lines.
Specific comments:
1.2 Existing Transmission Systems in the Railbelt: The implication of
including the Glennallen-Valdez transmission system is that the Susitna
Hydroelectric Project would serve this area. If this is the intention,
then transmission line corridor alternatives to interconnect with the
Glennallen-Valdez system need to be evaluated and circulated for review.
5.6 Description of Corridors
{c) Northern Study Area
(i) Corridor One -Healy to Fairbanks via Parks Highway: Paragraph 4.
We do not believe that the option of closely paralleling and sharing
rights-of-way with the existing Healy-Fairbanks transmisson line
should have been dropped from further consideration prior to public
and agency participation.
Table 5.1 Technical, Economic, and Environmental Criteria Used in Corridor
Selection: Additional environmental selection criteria should be: minimize
wetland impacts; minimize river crossings; minimize visual, esthetic impacts;
m1n1m1ze impacts on natural systems; minimize erosion; and minimize impacts on
existing life styles.
-
Mr. Eric Yould Page 4
6.4 Reliability -Access: The proposed construction and maintenance access
needs to be presented. Also a discussion of the proposed method of
construction for the different segments.
6.5 Screening Criteria
(a) ·Technical Screening Criteria
(i) Primary Aspects: Topography: . Steep terrain would increase erosion
potential and would thus be a negative environmental factor.
(ii) Secondary Aspects: Vegetation and Clearing: Heavily forested areas
need riot be cleared. Selective cutting and topping of trees are
environmentally and esthetically more acceptable. Habitat modifica-
tion to enhance values for target species should be thoroughly
evaluated. Also, clearing of bankside vegetation is not generally
considered an acceptable procedure.
(b) Economic Screening Criteria
(i) Primary Aspects: Right-of-Way: Paragraph 3. Refer to comments
above (6.5(a)(ii)}.
(c) Enviroumental Screening Criteria: Enhancement opportunities as well
as potential negative impacts to fish andwildlife resources should
be evaluated in relationship to habitat modification. In addition,
.r~fer to co.mments above (Table 5.1). ·· " ·-
(ii) Secondary Aspects: Length: The consideration that the longer the
transmission line the greater the environmenal constraints is not
borne out by experience. Minimizing adverse environmental impacts
can usually be achieved by closely paralleling or sharing existing
transportation or utility ROW's. This rarely results in the shortest
transmission line.
Soils: It should be recognized that scarification of the land would
not be considered an environmentally acceptable procedure.
Cultural Resources: Contacts should be made with the appropriate
state and federal agencies. Contactshould be initiated with the
National Park Service and the Alaska Department of Natural
Resources.
Vegetation: Proper timing of construction would help to minimize
impacts.
Fishery Resources: Refer to comments"immediately above. Secondary
impacts related to increased access also need to be examined.
Wildlife Resources: Increased access could have serious secondary
impacts such as increased hunting pressure and increased human/
wildlife co'nflicts.
Mr. Eric Yould Page 5
7. Conclusion~ and Recommendations: The Anchorage-Fairbanks Transmission
Intertie study should be fully integrated into the Susitna Hydroelectric
Project Transmission Line Corridor report. The entire package should be
circulated for public and agency review.
Thank you for the opportunity to review and comment on the Transmission
Corridor Report.
cc: FWS-ROES, WAES, NAES
Quentin Edson/FERC
Sincerely,
(l,f} !7 r)_ ~ ... -~~~ ~ :JaP~Regional Director
NMFS, EPA, NPS, BLM, USGS, ADEC, ADF&G, AEIDC
Carson/ADNR
Lawrence/Acres American
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.....
.~
-I
April 14, 1982
P5700. 11.71
T.l647
Mr. John A. Morrison
Acting Assistant Regional Director
U.S. Fish and Wildlife Service
1011 East Tudor Road
Anchorage, AK 99503
Dear Mr. Morrison: Susitna Hydroelectric Project
Transmission L1ne Corridor
Screening Report
Thank y~u for your letter of January 5, 1982, to Mr. Eric Yould, conment1ng
on the Transmission Line Corridor Report. The flurry of activity 1n
producing the Susitna Hydroelectric Project Feasibility· Report has delayed
this response for whfch I apologize.
I will attempt to address, in the same order, the issues you raised in
your letter:
1. The fntert1e 1s a separate transmission line and does not require an
2.
3.
FERC license. The fntertie will be constructed, operating, and carrying
non-Sus1tna generated power prior to completion of the Sus1tna Project.
The Susitna Project will only require additional of lines to the existing
1ntertie right-of-way. We are currently discussing w1 th FERC 1f these
new lines will be under FERC jurisdication.
The transmission 11ne route selection 1s not be1ng addressed through
separate meetings but through the public and agency meetings ocaurring
in March and April. The results of these meetings will provide input
to the dec1s1on making process as to f1na1 route selection.
Land ownership by major category was provided for the entire trans-
mission line study area on maps developed by the resource planners of
CIRI/HN. This material was utilized in the corridor screening and
route selection process. TES discussed the location of the transmission
lines \'11th Art Hosterman and John Rego of BU1 and Dean Brown, Michael
Franger, and Linda Arndt, among others, of DNR.
4. ADF&G and the U.S. Fish and \~ildl1fe Service were contacted during
this study. ADF&G was provided a copy of the preliminary routing study
and their comments incorporated in the final route selection. Bruce
Conant of the U.S. F1sh and l·J1ldl'ffe Service in Juneau, who conducted
recent swan nesting surveys. was also contacted and the information
provided utilized 1n the corridor selection.
Hr. John A. Morrison
U.S. Fish and Wildlife Service
Apr i 1 14, 1982
- 2
5. With regard to endangered species, ADF&G personnel were contacted to
obtain infonnation on known location and habitats of these species
within the study area. The corridors reflect consideration of this
data. FERC will conduct the Section 7 consultation process.
6. Resource agency requirements regarding right-of-way management will be
incorporated into construction and maintenance activities through the
pennittfng process.
7. Since publication of the transmission line corridor screening report,
further studies on both the corridors between the dam sites and the
access route studies have been conducted. The access route report, to
be issued in Apr11,·conc1udes the most environmentally acceptable
route between the two dam sites fa on the north side of the Susftna
River. In order .to utilize a common corridor, it is now planned to
~lace the transmission lines on the north side of the Susitna River;
this routing is contained in the Susitna Draft Feasibility Report.
Should proposed access routing change, consideration. will be given to
moving the transmission line route to maintain the common corridor
concept.
8. We agree that public access is a complex and controversial subject.
We experienced the wide range of opinions on this subject when con-
ducting public meetings on the access route. Decisions on extent of
public access will be made 1n the broader forum of the pennitting
process which includes concerns of the resource management agencies.
9. Due to existing land use, aesthetic and lifestyle constraints, con-
sideration was given to paralleling existing rights-of-way and utilizing
existing access points whenever possible. The existing Healy-Fairbanks
transmission line was the focus of studies in the northern study area.
Closely paralletdgg this line, the Parks Highway or the railroad right-
of-way was considered but rejected due to the extent and severity of
resultant impacts. These impacts were: the need to remove buildings
located adjacent to these corridors; placement of conspicuous trans-
mission facilities in the foreground viewshed of existing houses; and
placement of transmission facilities in the foreground viewshed of the
major travel corridors of the railbelt region.
10. Consideration of alternatives south and east of Willow, including those
aligned with existing rights-of-way, was undertaken in the corridor
selection process. Due to the presence of the proposed capital site,
topographic limitations, and existing land use limitation, especially
in the area from Eklutna to Anchorage. it was concluded routing options
to the south and west of Willow would result in fewer environmental
impacts.
11. As mentioned above, the pennitting process will incorporate resource
agency requirements regarding right-of-way clearing and maintenance. The
techniques you mention may be stipulations to construction with which the
Power Authority would comply.
-Mr. John A. t·1orr1 son
U.S. Fish and Wildlife Service
April 14, 1982
- 3
12. It is not the· intention for the Susitna Hydroelectric Project to
provide service to the Glennallen-Valdez area in the near future. If
service was provided, it would be based on economics and need; current
load forecasts indicate no such needs until after the year 2000.
13. See response number 9 regarding the Healy-Fairbanks line.
14. With the exception of existing lifestyle~ all the technical environ-
mental criteria you suggest be added to Table 5.1 for corridor selection
were utilized in the corridor screening process as discussed on Pages
6-5 through 6-9 and displayed in Tables 6.4, 6.5, and 6. 6. .
15. Access for construction and maintenance wi-ll be defined following final
right-of-way selection. Ttre corridor selection process has resulted
in much o~ the proposed cor~idor being located in close proximity to
existing seconaary roads, survey lines, tractor trails, or existing
transmission lines, thereby reducing access needs.
16. Steep terrain was considered as a negative environmental factor as
discussed on Page 6-7.
17. Clearing needs will be more fully evaluated following fijht-of-way
selection.
18. The result of the corridor screening report was the selection of
corridors several miles in width. A final right-of-way, 400-700 feet
~ wide~ will be selected at a later date. Enhancement opportunities will
be considered when selecting this final right-of-way.
-
-
19. We agree that longer lenqth of a transmission 11ne does not necessarily
mean greater environmental impacts. Tihe wording on Page 6-6 reflects
this, stating "A longer line will require more construction activity
than a shorter line, will disturb more land area, and will have a
greater 1nhl!rent (underlining added) probability of encountering
environmental constraints.u
20. Construction procedures will be designed to minimize scarification.
The permitting process may result fn st1piuations to prevent or mitigate
scarification.
21. The National Park Service and the State Hfstoric Preservation Offices
will be contacted regarding cultural resources.
22. I assume your comment regarding proper timing of construction would
minimize vegetation impacts refers to winter construction in wetlands.
This_is recommended as a mitigation technique on Page 7-6 of the
report.
~1r. John A. Morrison
U.S. Fish and Wildlife Service
4pri 1 14 ~ 1982
- 4
23. The opportunities far increased access, \'lhere desirable. and for
restricted access {through use of discontinuous access roads, physical
barriers~ etc.) will be considered during right-of-way selection. The
requirements of the resource management agencies will be included fn the
permitting process which will result in a decision on the extent of
public access to be allowed.
I appreciate your comnents on our report and hope these responses are
satisfactory. In summary. addttional studies and mitigation planning will
be consucte6 in the near future; this reviewed report and the Feasibility
Report mark the beginning of this process.
GG:ccv
Sincerely.
John Lawrence
Project t~anager
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Dear
I am enclosing for your review the following reports prepared by the
Alaska Department of Fish and Game for the Susitna Hydroelectric
Project:
1. Final Draft Report, Adult Anadramous Fisheries Project
2. Resident and Juvenile Anadramous Fish Investigations on the Lower
Susitna River
3. Aquatic Habitat Investigations.
These reports are provided for your information only; they are not part
of our formal Agency Coordination Program. Corrnnents are not requested
but will certainly be accepted.
Sincerely.
b
Preceding Letter Sent To:
1'1r. Al Carson
Division of Research & Development
Department of Natural Resources
323 East Fourth Avenue
Anchorage, Alaska 99501
Mr. Bradley Sm1th
Environmental Assessment Division
National Marine Fisheries Service
Federal Building & U.S. Court House
701 C Street, Box 43
Anchorage, Alaska 99513
Mr. Michael Scott
District Fisheries Biologist
U.S. Bureau of Land Management
4700 East 72nd Street
Anchorage, Alaska 99507
Mr. Gary Stackhouse
U.S. Fish & Wildlife Service
lOll East Tudor Road
Anchorage, Alaska 99502
7"' Mr. Carl Yanagawa
Regional Supervisor for Habitat Division
Alaska Department of Fish & Game
333 Raspberry Road
Anchorage, Alaska 99502
Ms. Jud 1 Schwarz
Environmental Evaluation Branch
U.S. Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington 98101
-
Mr. Gary Stackhouse
. U. S. Fish & Wildlife Service
1101 E. Tudor Road
Anchorage, Alaska 99501
Dear Gary:
ALASKA POWER AUTHORITY
April 15 ~ 1931
Attached is a copy of our report to the Legislature as promised by me
earlier this week. I am also sending n copy to Bruce Apple.
Bruce tells me he has.a copy of the Plan of Study. Since these are an
endangered species. I would appreciate 1t ff you would share his copy as
you structure your shopping 11st of areas of concern.
FOR THE EXECUTIVE DIRECTOR
Attachment: As noted
Sincerely,
.David 0. Wozniak
Pro,fect Engineer
CONCUR:
ow
RAM
ALASKA POWER AUTHORITY
Ns. Judy Schwartz
Environmental Evaluation Branch
Hail Stop 443
Re9ion 10. EPA
1200 6th Avenue
Seattle, Washington 98101
Dear Ms. Schwartz:
April 15 ~ 19a1
Attached 1s a mid-point report on Sus1tna Hydroelectric Project. It 1s
forwarded for your information in ·response to your earlier expression of in-
terest within the context of the Susitna Hydroelectric Project Steering
Committee.
I have asked Hr. Allan Carson, the Chairman of that cmrmittee, to forward
meeting odnutes to you and to ensure that you are advised of scheduled meetings.
FOR THE EXECUTIVE DIRECTOR
Attachment: As noted
cc: Allan Carson w/o attachment
Sincerely,
David D. Wozniak
Project Engineer
CONCUR:
DW
RAM
r
December 4, 1981
Re: ll30-13
John D. La~reoce
Project Manager
Acres American~ Inc.
DIVISION OF PARKS
The Liberty Bank Building, Main at Court
Buffalo, New York 14202
Dear Hr. Lawrence:
JAYS. H,I.MMOND, GOVERNOR
619 WAREHOUSE DR •• SUIT£ :UD•
ANCHORAGE • .ALA~KA 99501
PHONE: 214..4616
We have reviewed the 1980 repoits by the University of Alaska Museum dealing
with the cultural resources of the Susitna Hydroelectric project area. 7be_
report documents the survey activities conducted during 1980 which adequately
accomplish the tasks outlined in the proposed work plan. The sampling plan
designed on the basis. of geomorphic features and known use areas seems to have
surpassed ou_r expectations of site incidence in the areef. · The report shows
th?t the first_level invento~ was very competently conducted and recorded.
The second year activities as outlined in the procedures manual was accom-
plished in the 1981 field season according to information gained through
verbal communication with the principle archaeological investigators. We
understand that the field research strategy was changed slightly from that
expected due to information gained during 1980. These changes appear to have
more directly addressed problems which surfaced during the course of analysis·
of the 1980 data. A final review of the 1981 results and reports will have to
a\Ja it receipt of that document.
~e feel that the steps taken tbus far in the cultural resource management of
the project have been excellent and ooe of the few instances of adequate lead
time. ~e would like to make the observation that the work thus far is only
preliminary to the ~ark yet needed for the Susitna Hydroelectric project.
Reconnaissance aod testing of yet to be examined areas should continue. The
clearances of specific areas of disturbance provided as additional survey by
the Huseum should indicate the continued need for clearances of ancillary
projects which could affect cultural resources. Also, a formal mitigation·
plan for those sites to be affected by the project must be formulated. Once
definite decisions oo the route of access to the project area from existing
road systems are made, those access routes aod material sites must be examined
for conflicts and needs for mitigation. Issuance of a permit by the Federal
Eoergy Regulatory Co~issioa should and probably will ioclude provisions
~pecifying under federal law the need for such protection.
John D. La~rcnce
December 4, 1981
Page 2 -
If you have any questions regarding our comments contained here, please call
us. We look forward to receiving the report on 1981 field work.
Sincerely,
Chip Dennelein
Director
By:
A
• Shaw ~
Preservation Officer
cc: D~E. James Dixon
Curator of Archaeology
University-of Alaska Museum
University of Alaska
Fairbanks, Alaska 99701
Eric Yould.
Executive Director
Alaska Power Authority
333 W. 4th Avenue
Anchorage, Alaska 99501
I ·t
DR:clk
-
-
Colonel Lee R. Nunn
Department of the Army
Alaska District, Corps of Engineers
P. 0. Box 7002
Anchorage, AK 99510
February 19, 1982
P5700.11. 92
Tl519
Dear Colonel Nunn: Susitna Hydroelectric Project
Plant· Eco 1 ogy-Report· · · · · ·
Thank you for your letter of February 1 regarding your review of the
following reports: Environmental Surrmary Annual Report-. 1980, Development
Selection Report, and Transmission Line Corridor Screening Close Out Report.
As a result of your comment concerning wetlands, I am enclosing for your
.-. information a copy of the 1980 Plant Ecology Report which more specifically
addresses the wetlands issue. Also enclosed is a copy of the vegetation
and wetlands maps which are referred to in thei-r report.
+A~.::>
Thank you again for your letter.
MG:ccv
Enclosures
cc: E. Yould -APA
ACRES AMERICAN INCORPORATED
~erely,
John Lawrence
Project Manager
L C.. L. R E C-b ·s } I 0, /S I! Pfl'65.
ct e : E:Jnc~_::{i_.ej.,tf3-a?
JOf-\IJ ~Av'bE.tJ
United States Department of the Interior
J.IM 'PL V M 1-\ e.R.
FISH AND WILDLIFE SERVICE STEvE FA!Vl... '(
IN REPLY REFER TO:
WAES
Eric p, Yould
Executive Director
Alaska Potver Authority
1011 E. TUDOR RD.
ANCHORAGE, ALASKA 99503
(907) 276-3800
334 w. 5th Avenue, 2nd Floor
Anchorage, Alaska 99501
Dear Mr. Yould:
1 7 AUG J982
The Alaska Power Authority (APA), by letter dated 29 July 1982, requested
comments from the Fish and Wildlife Service (FWS) regarding construction
access alternatives for the proposed Susitna Hydroelectric Project. We hope,
with this letter, to convey our immediate concerns regarding this subject to
facilitate your decision-making. This letter should not be construed as
providing in toto our concerns related to project access. We fully intend to
provide substantive comments on this, and related issues, upon receipt of the
draft Federal Energy Regulatory Commission (FERC) license application Exhibit
E. (Federal Register Vol. 46, No. 219, November 13, 1981).
The FWS has expressed, through our participation on the Susitna Hydroelectric
Steering Committee (SHSC) (letters dated 26 March 1981 and 5 November 1982),
concerns as to the direction and emphasis which this issue has taken.
It is apparent that the APA has been lead to the present .3" access alternatives
by the conclusion that power must be the forthcoming in 1993. Presently, the
1993 deadline is constraining the overall decision-making process and the
orderly progress of various studies on project feasibility and environmental
impacts and alternatives. The External Review Panel, in their Report,
presented to the Board of Directors, Alaska Power Authority on 15 April 1982,
did not acknowledge the 1993 mandate, prefering to state that:
"The arrival of any opportune time to proceed with construction will
depend on critical issues of finance and marketing of power which cannot
now be accurately forecast. Our recommendation is that tender documents
with all supporting geotechnical investigations and design studies be
developed. We estimate that a total period of three to four years will be
required for this phase of work. The project will then be ready to be
implemented whenever the financial climate for contracting becomes
favorable. The advantages of proceeding in this manner are:
(1} The economic benefits of being ready for financing;
(2) the momentum of the ongoing study and an informed staff; and
(3) the ability to avoid a crash design program.
-
-
!'""'
-
The disadvantage is the small risk of loss of the design costs in the
event that, for some reason, the project is never built.
This Panel is of the opinion that the economic climate will
eventually indicate that it is advisable to proceed with the construction
of the Susitna project and at that time it will be in the best interests
of the State of Alaska to develop this important natural resource."
Given the above the FWS continues to endorse the views expressed in the
Steering Committee letter dated 5 November:
"The SHSC agrees with the Terrestrial Environmental Specialists, Inc.
position that access via the Alaska Railroad to Gold Creek is
environmentally preferable. RailJ:'oad access to at least Devil Canyon
would alleviate the need for a staging area at Gold Creek and the
consequent human activity, land use, fuel spills, and other impacts on the
Gold Creek area. We recognize that a staging area at Devil Canyon would
be required in any case. The use of this area as the terminus of a
railroad appears to make a great deal of sense. Additionally, we feel
that the south side route from Gold Creek to Devil Canyon is preferable
since a trail already exists there. From Devil Cariyon to Watana, we
prefer a route on the north side of the Susitna River • If feasible
we generally prefer a rail mode of access to and within the project site.
The SHSC identified three (3) environmentally sensitive areas that should
be avoided. Those are:
1. The routes from the Denali Highway.
2. The route crossing the Indian River and through wetlands to the
Parks Highway.
3. The route on the south side of the Susitna River from Devil
Canyon to the proposed Watana dam site •
• • • Use of rail as the access mode increases the potential for
management and control of socioeconomic and environmental impacts.
Maximized rail use provides for the following advantages over road access:
1. Maintains a maximum range of future decision options.
2. Provides for control of worker impacts on local communities and
wildlife.
3. Decreases the potential of hazardous material spills due to
adverse weather conditions and multiple handling.
4. Disturbance to wildlife adjacent to the route can be more easily
controlled.
5. Direct access right-of-way related habitat losses can be
significantly limited."
we· b~lieve that rail, in conjunction \.lith air access, would provide dependable
se;vice· and that a redundant system of rail and road is not a necessary pro-
ject feature and, as stated above, is environmentally undesirable.
An assessment of corridor route alternatives must weigh the potential impacts
of borrow sites and access to these sites, and transmission line(s) routing
and maintenance. Access corridors which serve a dual, or triple, purpose in
regard to those other project access needs would be highly desirable from all
decision-making criteria.
Public access to the damsites and through the Upper Susitna Valley is a
complex and a controversial subject. and we believe this issue should be given
thorough evaluation in the selection of·access routes, mode of access, trans-
mission line routing, and method of maintenance access for the transmission
lines. How construction and maintenance related access is obtained to a great
extent determines the project-related wildlife and socioeconomic impacts.
The following comments are provided in light of our concerns and are not an
endorsement of these routing alternatives.
Alternap.ve 17
Terrestrial Environmental Specialists, Inc. expressed the op1n1on that the
Denali Highway alternatives should not be considered. The view that the risk
of substantial negative impact to the Nelchina caribou herd from a Denali
Highway route is high has also been expressed by Karl Schneider, Research
Coordinator, Susitna Hydroelectric Big Game Studies, Alaska Department of Fish
and Game. We concur. There may be a difference of opinion amongst partici-
pants in the Susitna Hydroelectric Project Study as to the extent of the
risk. However, we must conclude that the Nelchina caribou herd could be
substantially negatively impacted by an access route connecting the Denali
Highway to the Watana camp; and that these risks are avoidable.
In addition to potential risk to the caribou, the Denali route cuts across
valuable moose, brown bear, and black bear habitat between the Watana camp and
Deadman Lake. Although no major river crossings would be involved, numerous
small river and tributary crossings would need to occur along this route and
could pose .extensive problems to numerous virgin grayling fisheries.
Alternative 16
A southern routing between the dam sites could intersect movements of large
numbers of brown bears to and from Prairie Creek. The upper Prairie Creek,
Stephan Lake, and the Fog Lakes regions support large year-round moose concen-
trations. Impacts to furbearers and waterfowl also appear to be less
avoidable in a southern routing between Watana and Devil Canyon in comparison
to a northern access route.
'""'
-
Alternative 13
\ole favor an access route to the north of tn..: Susitn<i River bcu,een the:: t\olO darn
sites. However, we cannot endorse the proposed routing. Given the stated
rationale that the siting of the Devil Canyon dam was partially an attempt to
avoid adversely impacting the important salmonid fishery of Portage Creek we
are highly concerned with any plans to place a road in close proximity to the
creek for approximately 1 mile. This places the fishery in a highly
vulnerable position in respect to erosion and hazardous spills.
In summary, the FWS recommends:
1. That justification for the power-on-line in 1993 planning objective be
clarified.
2. Rail access into the project site, to the exclusion of a road connection,
with routing north of the Susitna River between the two dam sites.
3. That alter-natives for borrow sites and their access, and transmission
line(s} routing be provided so that they can be considered in conjunction
with construction access routing.
4. That public access to the upper Susitna.basin should be evaluated within
the context of the project's need to minimize, to the e~tent possible,
adverse impacts to fish and wildlife, and their habitats.
Thank you for the opportunity to comment.
cc: FWS-ROES,WAES
Quentin Edson/FERC
Sincerely,
.bsfsta1u /Regional Director .. ·
APA, NMFS, EPA, NPS, USGS, ADEC, AEIDC
ADF&G, Hab. Div., Su Hydro/Aquatic Studies
Robin Sener/LGL
APA Board :t>lembers
United States .Dcpartn1en t of the Interior
NATIONAL PARK SERVJC£
IN REJ"LY REFER TO:
L7621(ARO-PCR}
Dr. E. James Dixon, Jr.
Curator of Archeology
University of Alaska Museum
University of Alaska
Fairbanks, Alaska 99701
Dear Dr. Dixon:.
Alaska Regional Office
540 West Fifth Avenue
Anchorage, Alaska 99501
OCT 2 2 1982
Our staff has examined the Susitna Hydroelectric Project cultural resources
final report,. tin. particular the identification and testing program elements of
the research'i de$ii9Jll, and find these and their field application to be very
adequate methods am:t procedures for the discovery and evaluation of archeologi-
cal and bistorical! resources in the project area. Consultation between our
staff a:rchenloqis;ts: and project personnel from the University of Alaska Museum
and Acres. JA!ner.ic.cmi,.. as you well know, have occurred several times since the
project's; tnc:e:p:ti''oo, and we have thus been kept abreast of most developments
relating· to, Cl!lllinil:ral resources management matters. We hope that the 1 evel of
identifka,tt.i'o:n·, t.esting, and evaluation conducted to date continues as the
project proceeds, to assure the highest levels of resource protection and
compli:ailitCe with Federal and State historic preservation 1aw.
We look ff~~w.ward' to evaiuclting your mitigation plan for cultural resources
occurring fn the project area.
Sincerely,
Regional Director
Alaska Region
cc:
Floyd Sharrock, Alaska Regional Office
-
NOV -21982
United States Department of the Interi9r
NATIONAL PARK SERVICE
JN REPLY RER.R. TO:
L7621(ARO-PCR)
Dr. E. James Dixon, Jr.
Curator of Archeology
University of Alaska Museum
University of Alaska
Fairbanks, Alaska 99701
Dear Dr. Dixon:
Alaska Regional Office
540 West Fifth Avenue
Anchorage, Alaska 99501
OCT 2 2 1982
Our staff has exam:ined the Susitna Hydroelectric Project cultural resources
final report, in particular the identification and testing program elements of
the research design, and find these and their field application to be very
·adequate methods and procedures for the discovery and evaluation of archeologi-
cal and historical resources in the project area. Consultation between our
staff archeologists and project personnel from the tlniversity of Alaska Museum
and Acres American, as you well know, have occurred several times since ·the
project•s inception, and we have thus been kept abreast of most developments
relating to cultural resources management matters. We hope that the level of
identification, testing, and evaluation conducted to date continues as th
project proceeds, to assur~ the highest levels of resource protection-and
It .6.1 /!{~ .t\ 'POWiiR
AlmfoRny
compliance with Federal and State historic preservation law. 8US11NA
We look forward to evaluc.Lting your mitigation plan for cultural resources FILE P57~
·lL: 1_1 occurring in the project are~.
SEQUENCE NQ.
Sincerely,
Regional Director
·Alaska Region
cc:
Floyd Sharrock, Alaska Regional Office
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NOTES OF MEETING
DATE: April 6~ 1981 PROJECT . NUMBER: AAI 218
LOCATION: DNR, Division of Minerals and Energy Management; 703 W. Northern
Lights Blvd., Anchorage
ATTENDEES: Glenn Harrison, Director; Division of Minerals and Energy
Management. J.O. Barnes, R.J. Krogseng, TES
SUMMARY OF DISCUSSION:
Mr. Barnes gave a short presentation summarizing the history of the Susitna
Project and the role of Acres and TES in the present studies being conducted
for the Alaska Power Authority.
Mr. Harrison responded that his divisions main interests involved coal~ oil
and gas -alld that he foresaw few problems that :the Susitna project would
cause in his areas of interest.
Mr. Harrison felt that the project 11 sounds good 11 and was well thought out.
Mr. Harrison also commented that it would be good, as far as his division
was concerned, to have some roads built into the Susitna area.
Mr. Harrison stated that he appreciated the meeting and that he would like
to be.kept informed on a periodic basis.
Prepared by~c :J. KrOgsen 7 TES
NOTES OF MEETING
DATE: April 6, 1981 PROJECT NUMBER: AAI 218
LOCATION: Alaska Department of Transportation, Aviation Building, Anchorage
ATTENDEES: Jay Bergstrand, DOT, Area Planner; J.O. Barnes and R.J. Krogseng, TES .
SUI·tMARY OF DISCUSSION:·
Jeff Barnes outlined the history of the Susitna Project and Acres and TES's
role in the present studies. Mr. Bergstrand was familar with the project
and had been present at some of the Susitna project meetings.
Mr. Bergst'rand requested a copy of the Environmental Annual Reports, and
he was referred to Nancy Blunck.' s office at APA.
Mr. Bergstrand asked about transmission line high voltage effects, fish
'" . passage problems around the dams; what was planned for disposing of the
timber in the impoundment areas, and was burning being considered as a
mitigation measure for moose?
·""" Mr. Bergstrand was particularly interested in the planning process for Access
Roads, Transmission Line routes and transportation corridors. He showed us
proposed routes for new roads in the Lower Susitna Basin and we discussed
where they would cross the proposed transmission lines.
-
Mr. Bergstrand requested more information regarding the impact and amount
of flying activity during the study and construction periods the Susitna
Project would have on the Talkeetna Airport. This information would be
used to ascertain if the state would have to provide more services at the
Talkeetna airport. ( A letter. requesting this information was sent to
Mr. Brownfield of Acres on April 16, 1981 ).
Prepared by ~a 'L
.J. K gsengpES
Page 2
Mr. Baya inquired about the status of legislatiY.e funding to cover the rest
of Phase I studies and the tran~ition period.
Mr. Baya wanted to know if any incremental instream flow work was being done
on the Susitna River by the state.
Mr. Baya feels that more attention needs to be paid to instream flow impacts,
the effects can be far-reaching. He pointed out that the move of the state
capitol, urban growth of Anchorage and the Mat-Su,.the proposed causeway to
Point MacKenzie, all could cause serious impacts and need to be considered in
a regional planning effort. He also pointed out the need to recognize the
secondary impacts that a large supply of hydroelectric power would cause.
Mr. Baya pointed out that the Fish and Wildlife Service will be asked by the
Secretary {of Interior) to respond with comments during the FERC review process.
The F&WS also has the requirement to coordinate fish and wildlife view points
from the different agencies. Mr. Baya feels that the Susitna project has moved
forward too far without funding for Fish and Wildlife Service participation.
He would like to have a man assigned full time to the Susitna project to
monitor the studies and keep him up to date because in the near future he will
have to ask himself "can I sign off on that?••
Mr. Baya feels that the APA needs to find a way to get the F&WS actively involved.
They need money to finance a staff position (approximately $50 -60,000 a man
year). Normally when the Corps of Engineers have a project they would give the
F&WS money eve~ six months through an allocation transfer.
Mr. Baya commented that recent cutbacks have caused problems and will probably
result in a reduction in staff. In spite of these problems Mr. Baya said "we
want to help plan a sound program .••.. we don't want to be obstructionists. ••
•• ••• but without· funding for a full time position it will be virtually impossible
to completly review the study in a short period of time.
Mr. Baya commented that in projects in the lower 48 states they have found that
often they had not looked far enough down the road to be aware of all of the
impacts~ For instance, along the Mississippi River the State of Mississippi
is ·losing 16 miles of Delta every year, because river channelization is dumping
sediments in deep water instead of spreading them over the delta areas.
....
-
NOTES OF MEETING
DATE: April 6, 1981 PROJECT NUMBER: AAI 218
LOCATION: DNR Office, 323 East 4th Ave., Anchorage
ATTENDEES: Mr. Ted Smith, Director, State Division of Forrest, Land & Water
Management, ADNR. Mr. J.O. Barnes, Mr. R.J. Krogseng, TES
SUMMARY OF DISCUSSION:
Jeff Barnes outlined the history of the Susitna Project and TES's role in the
studies.
Mr. Smith had recently talked to Brent Petrie (now of APA) about the Susitna
project and he appreciated the briefing and the concerns shown for his departments
interests.
Mr. Smith expects to get relief from the Legislative mandates which he feels
are causing many of the problems in the state land disposal program.
Mr. Smith feels that the access roads for the Susitna Project will help to
.open up and provide access for more state disposal lands.
Mr. Smith strongly feels that the Alaska Power Authority should file applications
for water rights as soon as possible to both reserve the water rights and to help
DNR plan. (Alaska has recently adopted a water righ~s law similar to that of
Montana and other Western states}. He also would like to see applications
from APA designating approximate routes for access roads and transmission lines
so they can be included in DNR's planning at the earliest possible date.
Prepared by --:(j=F-' ~::---:-:-7~"f--'-·~,..-.==:::----Jr.filihseng {'RES
NOTES OF MEETING
DATE: April 7, 1981 PROJECT NUMBER: AAI 218
LOCATION: State Parks Headquarters, 619 Warehouse Avenue, Anchorage
ATTENDEES:· Jack Wiles~ Robert Shaw, Doug Reger, Alaska State Parks; Kevin
Young, Acres; Jeff Barnes, Lew Cutler, R.J. Krogseng, TES.
SUf1MARY OF DISCUSSION:
Mr. Barnes gave a short presentation covering the histo~ of the Susitna
Project and the role played by Acres, TES, and other subcontractors in the
present study for the Alaska Power Authority.
Mr. Shaw and Mr. Reger requested a copy of the Plan of Study and the Archaeology
Procedures Manual. (Mr. Cutler will go over the Annual Report with Mr. Reger
on the 8tlr of April ) •
Mr. Wiles was concerned that if the State Parks Department would be the manager
around the reservoir area, how. big was the area going to be, or would it just
be the 200 foot buffer strip.
·Mr. Reger wanted to know what was~the FERC application. He also wanted to know
if the FERC people would consult with· his staff office. He also commented that
they hadn't been involved up till now.
Mr. Shaw wanted to know what the overall construction schedule would be.
Mr. Wiles inquired about the status of the-access road and what the present
plans were.
It was also established that artifacts that came from native owned ground are
usually placed in the University of Alaska Museum to be held in trust for the
natives.
All attendees agreed that the Susitna Project "sounds good" and they were
satisfied with the planning that had gone into the. studies.
Prepared by ~·Jf R.J. Kr seng ES
·-
NOTES OF MEETING
DATE: April 7, 1981 PROJECT NUMBER: AAI 218
LOCATION: USF&WS, Tudor Road, Anchorage
ATTENDEES: Keith Baya, Assistant Area Director F&WS; Kevin Young, Acres;
J.O. Barnes and R.J. Krogseng, TES.
SU~mRY OF DISCUSSION:
Mr. Baya was recently assigned to Alaska so Mr. Barnes's presentation covered
the history of the Susitna Project, the role of Acres and TES in perfonning the
studies for the Alaska Power Authority, and an outline of the studies in
progress to ijelp bring Mr. Baya ~p-to~date on the project~
Mr. Baya appreciated the briefing on the project and conmented that he would
1 ike to see the Susitna River studied all the way down to the estura~y to be
r sure there were no unforeseen problems. He acknowledges that.effects. on the
lower river may be difficult to measure." He also felt that another question
that will arise is .. why isn't it like other hydro projects?••
....
Mr. Baya felt that the NEPA decision making process should be followed.
Mr. Baya believes that the Sus·itna study is going to be one of the major studies
for the next few years. He feels that the Fish and Wildlife Service needs to
be involved in these studies and that his people have some expertise, but they
need to be on the ground to be able to see -and -s-upervise the studies~-·-If __ :...:
they are not included Mr. Bayabelieves the "----FERC coordination may take
longer than felt politically wise or timely.•
Mr. Baya expressed an interest in what studies were pl_anned for the coming year.
If there is an early June tour for Starker Leopold, Mr. Keith Baya would_ like
to be included.
r~r. Baya wanted to know. if Habitat Evaluation Procedures (HEP) were being used
in the studies. He felt that it may be necessary to do a HEP analysis ·later on.
Mr. Baya inquired about Dr. B. Kessel's Avian and Small Marrmal Studies and what
was scheduled for the summer field studies.
Page 3
Mr. Baya also commented on the EIS that will be written on the Beluga Coal
fields in the next few months, and how they plan to build a model to help
figure out what (data) is drivi.ng the system •• They also will be looking
at the question of whether it would be better to build a port at Tyonek or
haul the coal by railroad to Seward.
Prepared·by ~ .J. K gsen TES
-
NOTES OF MEETING
DATE: April 7, 1981 PROJECT NUMBER: AAI 218
LOCATION: Department of Community & Regional Affairs, 225 Cordova,
. Building B. Anchorage .
ATTENDEES: Ed Busch. Senior Planner; Lamar Cotten, Associate Planner;
. Kevin Young, Acres; J~O. Barnes and R.J. Krogseng, TES.
SUMMARY OF DISCUSSION:
Mr. Barnes gave an overview of the history of the Susitna project, Acres
and TES's involvement in the present studies and our reason for talking
to people from their department.
Mr. Busch was aware of the steering committee through Al Carson. f-1r. Busch's
department provides planning· assistance to conmunities upon request. The
Department·also has a management program. One of their programs provides
coastal zone management for the Matanuska-Susitna Borough. This could
extend up the Susitna River.
f-1r. Busch's office has had sporadic involvement with the Susitna project.·
He was on the review committee on contractor selection and also attended
some of the workshops.
Mr. Busch voiced some concerns that his office has about planning for the
Susitna project. He feels there will be a number of impacts on local
governments~ and he wanted to know if their concerns had been considered?
Mr. Busch believes that the-Matanuska-Susitna Borough will bear the brunt
of the impacts (positive and negative) caused by the Susitna project. A
major problem will be providing increased services.
Mr. Busch wanted to know if the access roads would be kept open after the
project was fini~hed and who will maintain them. He also wanted to know,
if the railroad is built, has anyone considered the impact to Talkeetna
caused by people driving to Talkeetna. parking and taking the train?
Mr. Busch . reco1m1ended that TES do comnun i ty profiles on the towns and vi 11 ages
that would receive most of the impact. As ~ minimum he suggested coiJillunity
profiles on Talkeetna, Cantwell;, Paxson and Gold Creek. · A cormJunity p~o-file ·
is a collection of information with photos and a map of the conmunity.
(examples were provided). The profiles have been costing $10-11.000 to produce
with the majority of the expenses going for per diem expenses and cartography.
PAGE 2
(Northwest Gas Pipeline Company produced some of the examples).
Mr. Busch pointed out that if a village is incorporated into a second class
city (such as Talkeetna) they are able to have more input in planning and
governing themselves. For the smaller villages the State Legislature is
the governing body, with the actual planning done by Mr. Busch•s department.
Wildlife planning is done by the ADF&G,and the Matanuska-Susitna Borough
provides the schools. Mr. Busch does not speak for the Borough unless he
has been requested to do so.
Mr. Busch feels the number of construction workers has been under-estimated,
as an example, the Alyeska pipeline was under-estimated.
Mr. Busch recommended that a permanent construction camp be built for the
projec~The temporary camps built for the pipeline are still being used
and it would have been cheaper in the long run to build permanent camps.
Mr. Busch collJ1lented that people from Frank Orth and Associates have talked
to personnel in· his office.
Mr. Busch also pointed out that the only way his office gets involved is
when they have been asked to by the community.
Prepared by tJfit -p• ijf:
J. Kr eng, TES
. I
-
-
-
NOTES OF ·MEETING.
DATE: April 8, 1981 PROJECT NUMBER: AAI 218
LOCATION: Department of Public Safety, Division of Fish and Wildlife
Protection, 5700 E. Tudor· Road, Anchorage ·
ATTENDEES: Colonel Robert J. Stickles, Director; Lt. Col. Tetzlaff, Capt.
. Wayne Fleek, Lt. Rod Mills, Department of Public Safety; Kevin
Young, Acres; J.O. Barnes and R.J. Krogseng, TES.
SUl>MARY OF DISCUSSION:
Mr. Barnes presented an overview of the history of the Susitna project and
the part played by Acres and TES in the present studies being conducted for
the Alaska ~ower Au~ori~.
Col. Stickles· requested that his department receive copies of the annual
reports for Fish, Big Game and Access Roads.
Col. Stickles asked what effect the dams would have on the {low of the Susitna
River below Talkeetna.· He also wanted to know what water temperature changes
may occur. He was very interested in the possible effects the.project would
have on moose and caribou. Col. Stickles also wanted to know how many miles
of access roads were planned.
Col. Stickles wanted to know what ice effects were expected in the impound-
ment area and also the effects expected in the downstream reaches of the river.
He also wanted to know what the construction time table was and when it would
start. He needed_ this infonnation to bel p plan for the placement of officers.
He will probably assign an officer to Chulitna when· construction starts.
Capt. Fleek asked about the amount of helicopter useage during the studies.
He also wanted to know where the transmission ·1 ine routes would be and if
there would be access roads along them.
Capt. Fleek wanted to know how inany people would .be living near the dams for·
maintenance and operation of them.
Capt. Fleek wanted to know if the impoundment areas were going to be logged.
He also was concerned that i~e shelving might cause caribou crossing problems.
Capt. neek conmented on t~e large ntnnber of bear in .the area and wanted to
know if we had had any bear problemS. He also requested that Fish and
Wildlife Protection Division be sent the results of the Mitigation Committee.
Their division would ·like to be in on mitigation planning. . .
PAGE 2
All agreed that Protection Division•s greatest concern would be the access
provided· to the area. They wanted to know if a landing strip was going to
be built. They would also be interested in getting.permission to store
extra gas for their helicopter at Camp Watana later on.
Lt. Mills said that they could tell us the number of guides using the area,
and he agreed to send Krogseng a list of the guides and their best guess on
the number of hunters using the area.
Reported by
r' --,
NOTES OF MEETING
DATE: April B. 1981 PROJECT NUMBER: AAI 218
LOCATION: Department of Energy, Federql Building, A~chorage
ATTENDEES: Fred Chiei. Deputy Regional Representative; Kevin Young. Acres;
J. 0. Barnes and R.J. Krogseng, TES.
SUMMARY OF DISCUSSION:
Mr. Barnes made his presentation covering the history of the Susftna project
and the role of Acres and TES in the present studies being conducted for the
Alaska Power Authority.
Mr. Chiei appreciated being kept informed on the status of the project.
Mr. Chiei conmented that his office is an off-shoot of the Secretary's office
!"'"" and that he deals prima.ri ly with energy' po 1 icy •.
,....
I
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Mr. Chiei noted that the FERC people operate out of his office when they are
in town •. while the FERC engineers operate out of San Francisco. He also
commented on the need for energy planning.
Mr. Chiei said that his office tries to stay out of the states territory in
energy matters, although a lot of things have not surfaced yet. He prefers
it to be more of a state project and is happy to see state funding for it.
Mr. Chiei commented that hydroelectric_ projects_1i.ke the_Sus1tna PIEj_~c~ .
. .
release energy like coal, oil and_ gas tJ:iat can be sh·ipped elsewhere in the
U.S. which helps to distribute the country• s energy more evenly.
Mr. Chiei said that he doesn't see any problems at this point and periodic
reports (like this meeting) would be sufficient. He would also be interested
in seeing the development scenario when it is developed.
Mr. Chiei would like to receive information from Acres on the Tidal Power
Study.
NOTES OF MEETING
DATE: April 8, 1981 PROJECT NUMBER: AAI 218
lOCATION: National Park Service, 540 West 5th Avenue, Anchorage
ATTENDEES: Howard R. Wagner, Associate Director, Carl Stoddard, Terry
Carlstrom, Ross Cavenaugh, National Park Service; Kevin Young;
Acres; J.O. Barnes, R.J. Krogseng, TES.
SUMMARY OF DISCUSSION:
Mr. Barnes outlined the history of the Susitna project and the role Acres
and TES have in the pres.ent studies being conducted for the Alaska Power
Authority.
Mr. Cavenaugh asked how the Fish and Wildlife studies fit into the overall
planning process. He also asked what was being done about cultural resources.
Mr.Cavenaugh, also wanted to know what effect the project would have on the
proposed Denali Scenic highway.
Mr. Wagner said that he would be very interested in the transmission line
route, especially where it is near the park (Denali). If the route passes
through park boundaries, the right-of-way approval may .need congressional level
approval. They want to keep the transmission line out of 1:he park.
. .
Mr. Carlstrom wanted to know what range of considerations or options were
available. He coiiiTlented that access could be a direct·problem. The Denali-
National Park is only on the west side of the Parks highway, but the trans·
mission line would have a direct impact on the land across the road. He
also wanted to be sure that someone was looking at indirect impacts caused
by the project.
Mr. Wagner also commented that USGS would soon have 1:250,000 scale maps with
thenew park boundries marked on them.
Reported by: ~c. ~
-~Krogpiig • TES
....
NOTES OF MEETING
DATE: April 8, 1981 PROJECT NUMBER: AAI 218
LOCATION: U.S. Army ~orps of Engineers, Elmendorf AFB, Anchorage
ATTENDEES: Lt. Col. Perkins, Deputy District Engineer; Kevin Young. Acres;
J.D. Barnes and R.J. Krogseng, TES.
SU~JMARY OF DISCUSSION:
Mr. Barnes briefly covered the role of Acres and TES in the present studies
of the Susitna project being perfonned for the Alaska Power Authority •
Lt. Col. Perkins stated that the Corps has no funding for any work on the
~""" Susitna project.-
Lt. Col. Perkins strongly feels that the state should be asking the Corps;
What permits will -~e required? The state should also inqujre about getting
one blanket permit for the project.
Lt. Col. Perkins wanted to know if we knew what permits would be needed, in
particular any section 404 classification of wetlands would be filled in.
-He reconmended t_hat the head of his environmental group be contacted.
Lt._ Col. Perkins also noted that the access roads will require permits to
cross wetlands; also any dredging or filling that is required. Permits will
also be required for constructing the transmission lines, especially if access
roads are built.
Lt. Col. Perkins pointed out that it takes a minimum of 200-220 days to process
a pennit. and if there are any objections they may have to be resolved in
Washington, which will require even more time~
Reported by ~·W R:JYJ=Ogs g, lES
\
NOTES OF MEETING
DATE: April 9, 1981 PROJECT NUMBER: AAI 218
LOCATION: NOAA National Marine Fisheries Service, Federal Building,
Anchorage
AJTENDEES: Ronald Morris, Supervisor, Anchorage Fie19 Office, Brad Smith,
NOAA Fisheries Biologist; J.D. Barnes and R.J. Krogseng, TES.
SU~~RY OF DISCUSSION:
Mr. Barnes gave a presentation covering the history of the Susitna project
and the role of Acres and TES in the present studies being conducted for
the Alaska Power Authority.
Mr. Morris and Mr. Smith are both members of the Susitna Hydro Steering
Committee and they will coordinate their work with the state fisheries
people.
Mr. Smith will be in contact with Dr. Dana Schmidt of TES concerning the
fisheries studies.
Mr. Morris asked about dam design features and said that he will be in contact
with NOAA engineers in the Oregon office.
Mr. Morris said that they appreciated the contact.
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NOTES OF MEETING
DATE: April 9, 1981 PROJECT NUMBER: AAI 218
LOCATION: Alaska Department of Environmental Conservation, 437 E. Street,
Anchorage
ATIENDEES: Bob Martin, Regi anal Environmental Supervisor, Steve Zrake, DEC;
Kevin Young, Acres; J.O. Barnes and R.J. Krogseng, TES
SUMMARY OF DISCUSSION
Mr. Barnes outlined the history of the Susitna Project and the role of Acres
and TES in the present studies being conducted for the Alaska Power Authority.
Mr. Martin asked what impacts or changes were expected on water quality or
air quality. He also wanted to know if the studies were long enough to
establish a proper baseline ~eriod.
Under socioeconomic, Mr. Martin wanted' to know if we had studied power genera-
tion needs. He was referred to the ISER study.
Mr. Martin wanted to· know if the studies would continue after the FERC applica-
tion has been made. Mr. Martin also wanted to know "why the FERC application
date was set so soon". As an example, Mr. Martin wanted to know why the
decision on the access road had to be made so soon; he wasn't even "comfor-
table" with how the three routes had been selected. He stated that his
department would like to keep access down because it would be easier to manage.
The Department of Environmental Conservation's interests in the Susitna area
are administered out of Mr. Martins Anchorage office. His major point of
contact is the Susitna Hydroelectric Project Steering Conmittee.
DEC's direct regulatory responsibility is waste water, drinking water, and
solid waste disposal. DEC also has an interest in instream activities.
Mr. Martin recom'Tiended applying for a variance to build the construction.
camps to provide for drinking water and waste water and solid waste disposal.
Mr. Martin feels that the major impacts of construction activities are going
to be the access roads and the locations of construction camps.
Mr. Martin said that it may be easier to have just one transportation corridor.
,..... As an example, in transportation and handling of fuel,. accidents are bound
to happen, like a truck may roll off the road. He feels that it is important
to avoid as many critical habitat areas as possible.
Mr. Martin was also interested in the water quality studies. He feels it is
very important to get a complete water quality series before road construc-
tion starts. He wants to be able to measure construction effects. such as
the run off into streams.from road building.
Mr. Martin is also interested in the .smaller feeder streams that would be
impacted by roads. He feels that 2-3 years .of data from studies would be
sufficient.
Mr. Martin expressed a concern about communities along the river disposing
of wastes in the Susitna River.
Mr. Martin was especially concerned about the fuel transportation and storage
system and the amount of fuel that would be used in a large project like
Susitna. He feels it is necessary to plan to avoid or minimize accidents
or spil~
-Mr. Martin commented on the need to maintain ecological integrity through
land use and public use planning, and to have a voice in other areas that
he can't regulate. He wants to see rational land use development. something
that doesn't interfere with·habitat.
Mr. Martin also wants to see more attention paid to using energy alternatives
such as Retherford•s recommendation to use electricity to run pipeline pumps
instead of using oil or gas.
Mr. Martin strongly recormnended building a centralized constructi·on camp.
He also recommended building where the permanent facilities will be located.
Mr. Zrake wanted to know if under sociocultural impacts we were looking at . .
individual desires too? He also wanted to know if this would cover the trans-
mission line too.
Mr. Martin stated that DEC does .not have any studies_in progress that affect
Susitna. They are working on a wetlands study with specific Alaska guidelines.
Prepared by____.fl:...:~~ ..... ,..,.~:..........:..-~-· ---,tc-?' __ _
R.J. fJD9S""v
-
NOTES OF MEETING
DATE: April 9, 1981 PROJECT NUMBER: AAI-218
LOCATION: U.S. Fish and Wildlife Service, Tudor Road, Anchorage, Alaska
ATTENDEES: Mel Munson, Chief Ecologi~al Services; Gary Stackhouse, F&WS;
Kevin Young, ACRES; J. 0. Barnes and R. J. Krogseng, TES.
SUMMARY OF DISCUSSION:
Mr. Barnes outlined the history .of the Susitna Project and the role of Acres
and TES in the present studies being conducted for the Alaska Power Authority.
Mr. Munson asked what ADF&G's role was in the studies. He also wanted to
know· what the time frame was for all of the studies a·nd when the EIS came
into the picture. Mr. Barnes.outlined the FERC process and where the dif-
ferent parts fit in.
Mr. Munson wanted to know if we had a preliminary permit for the project. He
felt that it was important that the state file soon.
ln 1952 Mr. Munson looked at 20 different proposed dams for River,Basin Studies.
-Devil Canyon and Watana Dams were part of that study. At that time he did not
find any salmon in ·the upper Susitna River.
Mr. Munson wanted to know if ADF&G was looking at winter moose range in the
study area. From personal experience in the area, he felt that the south
facing slopes on the north side of the canyon from half way between Devil Can-
yon to Watana were important to the moose population during the winter.
Mr. Munson has watched caribou swim the river in many different places in the
Watana area, they appear to get out any place they can get up the canyon wall.
Mr. Munson commented that during peak numbers of caribou he has seen 6-8000
caribou on Mt. Watana alone. Also during peak. numbers be has watched them
crossing the Susitna River where many trying to swim the river would be carried
do\'m-stream and drown. He has seen hundreds of dead caribou washed up on shore.
Mr. Munson wanted to knowwhat was planned to mitigate for losses of moose habi-
tat. He also commented that he opposed the Denali Dam because it would flood a . .
highly productivity area.
Mr. Munson also wanted to know if we were looking at the area above the
Tyone River.
Mr. Young outlined the various dam schemes that had been considered and why
the Devil Canyon -Watana scheme had been selected. Mr. Munson commented
that it was a good choice.
Mr. Munson said that one of the things he was interested in was what we were
going to do to mitigate for lost moose habitat. He felt that there was a
need for habitat development on upper Watana Creek. -Mr. Munson also suggested
burning, cutting or even sprigging willows as things to consider on Tsusena
Creek.
Mr. Munson was interested in the mitigation task force and its review group,
although he commented that there is not much you can do for caribou.
Mr. Stackhouse asked · what the status of the mitigation policy was. He
hoped the group would be able to produce a policy for APA. Mr. Stackhouse
also wanted to know what the basis for mitigation would be, was it going to be
based on an acre. for an acre or an animal for an animal?
Mr Stackhouse also asked about the vegetation analysis that was being per-
fonmed;he was concerned that the studies be of a h1gh enough quality to be
able to use HEP (Habitat Evaluation Procedures) on the vegetation studies at
a later date.
Mr. Stackhouse wanted to know if any hydraulic changes were expected in the
river or if any 1c1ng problems were anticipated. He was also concerned about
the possibility of ·any vegetation changes.
Mr. Stackhouse felt there was a possibility of some problems ·below Devil Can-
yon and he wanted to know. if are-reg dam was going to be put in. Mr. Stackhouse
wanted to know what the planned construction periods for the dams were going
to be, and if the Devil Canyon Coffer Dam would oe big enough to serve as a
'~ .
daily re-reg dam •.
Mr. Munson asked about the expected water quality for the Susitna River between
Devil Canyon and Talkeetna. He cormnented that it probably would have similar
conditions to that found in Tazlina Lake. Mr. Munson wated to know if any
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enhancement of the fisheries was expected, like in Kenai or Skilak Lake.
Mr. Munson would like to receive a copy of R&M•s Hydrology Report. He was
interested in their prediction of.winter ice conditions.
Mr. Stackhouse commented that he felt that one of the biggest ·problems in the
study was the fact that AOF&G hadn•t published a procedures manual for the
fisheries study yet. He was .. also concerned that one person from ADF&G wore
two hats; he worked on the Susi tna project and was a 1 so invo 1 ved in the state
permitting process.
Mr. Stackhouse was ·very concerned that APA had not filed a preliminarr penmit
yet. ·He co~ented that withput the permit the F&WS has no Qfficial position
to initiate a formal seeping process under their normal NEAPA-FERC procedures.
Mr. Munson commented that under standard conditions the state and federal
F&ws·work together on ExhibitS.
Mr. Stackhouse pointed out that they need to tie in with the work being done
. '
on transmission corridors and they also need to work with the Steering Conmittee.
Mr. Stackhouse feels that time is the over-riding factor in the studies. For
instance, if a railroad is constructed for the access method, it would cost
an extra year.
Mr. i~unson surrmed up his corrments on a recreational standpoint by pointing out
that the reservoirs were not going to be good for fishing; that the Devil
Canyon reservoir would provide some recreati anal boating, but that ·the main
uses for the reservoirs would be to provide access for hunting.
I
Mr. Stackhouse commented that he would like to see a copy of the instream flow
studies.
NOTES OF MEETING
DATE: April 9, 1981 PROJECT NUMBER: AAI 218
LOCATION: Bureau of Land Management, District Office, Anchorage
AITENDEES: Art Hosterman, Lou Carufel, Gary Seitz, Bob War~ •. _John ~ego,
BUM; Kevin Young, Acres; J.O. Barnes and R.J. Krogseng, TES
SUMMARY OF DISCUSSION
Mr. Barnes made a presentation covering the history of the Susitna Project and
the role of Acres and TES in the present studies being conducted for the
Alaska Power Authority. He also covered the studies and reports that are
being prepared as part of the .study •.
Mr. Seitz wanted to know if -FERC was responsible for the EIS. He also wanted
to knOW/if FERC would be asking BLM for penmits or when BLM would get a chance
to outline their requirements.
Mr. Rego wanted to know if FERC would be the lead agency. The present permit
is good for three P> years of studies .. After that construction pennits would
probably be necessary.
Mr. Rego stated that he would like to see all three access routes studied;
the Denali route north, the south route to Devil Canyon and the north service
road between both dams. He commented that their Mr. Beckley has built a lot . ~
of roads and that he ought to take a look at the different routes.
Mr. Hostennan wanted to know 11 What are the biggest problems?.. Also, what is
the role of the State Fish and Game Department in the studies. He also wanted
to know about Cultural Resources and how they were being·taken care of. Mr.
Hostenman also asked about Human Resources and the Natives and their interests.
Mr. Hosterman wanted to know if induced seismicity caused by .the weight
of the dam and reservoir was being considered. Also asked the question of
how much pennafrost was in the area and whether or not it was being studied.
The group also felt that public participation in study changes was a good idea.
It was also felt that 11 if you are going to do one right this is .the one.•• ---
Prepared by );.. '"t:::p
R.J. rogs ·
-"-----~-, .. -., ~,_---;----~:--.---... -,-·-·--,, ---·
NOTES OF MEETING
DATE: April 9, 1981 PROJECT NUMBER: AAI 218
LOCATION: Alaska Department of Fish & Game, 333 Raspberry Road, Anchorage
ATTENDEES: Carl Yanagawa, Regional Supervisor, Habitat Protection; Kevin
Young, Acres; J.O. Barnes and Robert J. Krogseng, TES
SUf>tMARY OF DISCUSSION:
Mr. Barnes gave a short presentation outlining the history of the Susitna
project and the role of Acres and TES in the present studies being conducted
for the Alaska Power Authority.
Mr. Yan~gawa outlined the state penmit system in whi.ch Mr. Trent is still the
State Coordinator for the Department of Fish and Game for permits, although
.-Mr. Yanagawa issues the pennits. Mr. Trent gathers the data and other infonna-
tion that Mr. Yanagawa uses to issue the permits·. The oonnal procedure is for
Mr. Yanagawa to get a consensus from the different departments to help make
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the final decision.
Mr. Yanagawa commented that he is presently short-handed in his department. He
has a position number but no funding for it.
Mr. Yanagawa had some questions about the access roads. He especially wanted
to know when the road was going to be used. He said the Department .of Fish
and Game would be prepared to make reconrnendations and trade off in regards
to the access roads, but they did not have any real hang-ups about them.
As a result of a decision made in Juneau in March, Mr. Yanagawa will not be a
member of the Steering Coamittee. The policy of the department is that Mr.
Trent is the coordinator for ADF&G. The coordinator helps make the departments
decisions. Mr. Trent is the only one who can raise official ouestions on the
Susitna project.
Drawing from his pipeline experience, Mr. Yanagawa commented that this was the
wrong job ·for a total preservationist, because sometimes you just have to get
in and do your best to find the best route or method available and go with that,
that not everything will be perfect~ He recorrmended getting in and looking at
routes early. ·Sometimes a prob1em can be solved by just moving the road 20 feet
left or right.
Mr. Yanagawa also feels that you need to keep asking yourself ••;f you spend
another million dollars. how much more infonnation are you going to get•'?
He also feels that it is important to make everyone aware of the assumptions
that you are making up front.
Mr. Yanagawa also feels that you need to pick a starting place, because you
cannot wait for all the answers to come in before you start.
Also, drawing on his experience in building the pipeline, Mr. Yanagawa
reconmended forgetting about building a constrcution camp for temporary use
and go ahead and design for permanent use, because you will save money in
the long run.
NOTES OF MEETING
DATE: April 10. 1981 PROJECT NUMBER: AAI-218
-LOCATION: University of Alaska. Arctic Enviromental Infonnation and Data
Center. 707 A Street. Anchorage. Alaska 99501 (907) 279 -4523
ATTENDEES: William J. Wilson. Fisheries Biologist AEIDC; Kevin Young, Acres;
J. 0. Barnes and R. J. Krogseng, TES.
SUMMARY OF DISCUSSION:
Mr. Barnes gave a short presentation covering the history of the Susitna
Project and the role Acres and TES have in the present study being con-
ducted for the Alaska Power Authority.
Mr. Wilson was the project Leader for the Terror Lake project on Kodiak Is-
land, and he discussed his experience in filing the FERC license application.
Mr. Wilson was concerned about the slow start by ADF&G on the fisheries study.
He felt that FERC's immediate reaction will proba~ly be to reject_ the application
~""" and ask for more infonnation. He also felt that organizations like "Susitna
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Now" should be aware of this and be expecting the request for more information.
Mr. Wilson feels that some of the fishery stu9y tasks will requ:ire alot of
work, because some drainages in the Susitna basin do not have very much that
is known about them.
Mr. Wilson also commented that the instream flow studies may be a problem,
because there is not much expertise available capable of doing the studies.
On the Terror Lake Project Mr. Wilson said that they used joint participation
where USGS. F&WS and AEIDC crew members walked the streams together to pick
out the study sites, because you can't pick them off from a map. Mr. Wilson
feels that you have to know what the project is going to do to the stream
flows and that incremental instream flow studtes will give you that flexi-
bility.
Mr. Wilson commented that FERC would like to see an agreement between State
and Fe.deral agencies over policies and requirements.
As a member of the Susitna Hydroelectric Project Steering Committee~ Mr.
Wilson is concerned about the lack of infonnation on what is going on.
He felt that it took too long to hear back on the Steering Committee•s
comments on the procedure manuals, and that Acres should have responded
sooner. Mr. Wilson also felt that the Steering Coii111ittee should have seen
the access road report earlier. He feels that preliminary infonnation
should be made available to the Steering Committee ~s soon as possible.
Mr. Wilson feels that Acres should publish more data in a 11 this is what we
found .. format and not just ••this is what we conclude ...
Mr. Wilson feels that the S~eering Committee should be a competent and helpf~l
sounding board for the project. He feels that the Steering Committee can help
save steps by pointing out pitfalls and other regulation mandates that need
to be complied with as part of their advisory capacity. The Steering Committee
cannot play a part in policy decisions~ but they can give feedback on what
was discussed to both sides.
As part of a University of Alaska policy, Mr. Wilson would like to see more
knowledge made available to the public. He would also like to see a centra-
lized depository or library of information on the project that would make
available the procedures manuals, maps, _photos, charts, diagrams, and reports
from the project.
Mr. Wilson is also interested in seeing an informal Steering Committee meeting
at Acres to provide an opportunity to open a dialogue with the Acres engineers.
Prepared by ;c._ 7
R.J.O'Kro
NOTES OF MEETING
DATE: April '10, 1981 PROJECT NUMBER: AAI 218
,... LOCATION: Alas lea Division of Natural Resources, 323 East 4th Avenue, Anchorage
ATTENDEES: Al Carson, Deputy Director, Division of Research and Development,
.....
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DNR; Kevin Young, Acres; J.O. Barnes and R.J. Krogseng, TES
SUMMARY OF DISCUSSION:
Mr. Barnes summarized the ideas and concerns that had been expressed during
the series ofmeetings with the various agencies.
The primary request from those who were also me.mbers o·f the Steering Conmittee
was the request to get information to the Steering Committee in time for them
to review it before the meeting.
Also high on the 1 ist was the desire for a central depositqry at the 1 ibrary
where all of the information would be available to more people.
Not everyone was knowl edgeab 1 e about access roads; more i nfonna ti on has to be
distributed to get people up to speed. It should also be understood that some
areas are incremental, that some minor impacts may work together to cause a
major impact. It is also felt that it is important to send out the criteria
on objectives that are to be used in making decisions to the Steering Committee
members and ask for their 'corrments on the fitness of the criteria.
It is also important to get the ground rules set up before a dispute has started
in order to avoid tunnel vision or having people argue about different parts of
a question.
There is still some confusion on how the FERC process works. It also appears
necessary to get docketed or to put in a preliminary license application which
will also authorize the Fish and Wildlife service to become involved in the
study.
Mr. ~arson said he wot.rld be willing to help reinforce any concerns such as
engineering disputes that may arise.
Mr. Carson commented that he liked his meeting with APA~ Acres and TES. He
felt that it was open and not defensive. He also said that he is willing to
start having Steering Committee meetings for discussion of problems, instead
of fighting over problems.
Mr. Carson would like to see a copy of the Acres and TES monthly progress
reports sent to the Steering Committee because it provides an overview of
' what is happening.
Mr. Carson said the Steering Committee would like to know the decision making
time lines. They also would like to know when studies and reports come in.
Mr. Carson said that a criti~al need which he feels needs attention is the
need for an understanding of technical, engineering, and socio-economic in-
formation, fed together in a hol~stic. approach to the whole problem. He
said that we need to inter-mesh ideas before people such as engineers have a
vested interest in their design.
Mr. Young explained how he works closely with the design engineers to bring
~nvironmental and social concerns into the design at an early stage to t~
to avoid future problems.
Mr. Carson corrmented on the need to get input from the Steering Committee
members before certain design milestones are reached.
Mr. Carson said he would like to see EIS seeping procedures and activities used
in solving some of the problems.
Another suggestion Mr. Carson made was for Acres and TES to touch base with
the Steering· Committee with a conceptua 1 type outline. To ask the Steering
Committee members 11 dO you think this wilJ do it?11 11 Wi11 it achieve our
purpose?•• He feels it is important to make sure you are using the right process
before you go out and do all the work.
Mr. Carson also commented that enlightened engineers are better to work with
than biologists.
Prepared by: ~?
.J. K seng
APPENDIX EllD
CORRESPONDENCE RELATING TO
DEVELOPMENT SELECTION
-
APPENDIX ll.D
DEVELOPMENT SELECTION
In March 1981, the Development Selection Report was circulated to agencies for
review and comment. This report compared various development scenarios within
the 1"1iddle and Upper Susitna Basin as well as alternatives outside the basin.
The following are comments received on the Development Selection Report.
Correspondence is presented primarily in chronological order. However, in
some cases, a response to a letter directly follows the letter to facilitate
an understanding of the flow of communication. This results in an interruption
in the chronological sequence.
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!. :,: ~ .~·-.·~ I
: 'i ';'i ~ .. ! I
• ~ ~~ ·;·J:.=•'!~:-,all
Mr. Al Carson
Chairman, Susitna Hydro Steering Committee
Department of Natural Resources
619 Warehouse Drive
Suite 210
Anchora'ge, Alaska 99501
November 14, 1980
P5700.11.74
T.546
Dear Al: Susitna Hydroelectric Project
Steering Committee Review of Potential
HYdroelectric Development Sites
Thank you for the opportunity of meeting with the Steering Committee
on November 5, 1980. I personally found it disappointing that my
objective of establishing a workshop atmosphere where the members of.
the Steering Committee could have a positive input into our selection
of candidate hydro sites did not materialize. However, I realize
that our objectives for this component of the Susitna studies may not
have been adequately explained. In this regard I have attached a
further explanation of our objectives as prepared by Robert Mohn of
APA.
I have accepted your suggestion that the most efficient means of obtaining
input from the Steering Committee is to 1) identify in-house the short
list of candidate sites we propose for further study; 2) present this
list to the Steering Committee for review and comment, and 3) incorporate
these comments into our final selection and review.
Presented on Table 1 is our short list of c~ndidate sites proposed for
further study. As mentioned on November 5 it is essential for planning
purposes to retain 4-6 sites within each of the size categories listed.
These sites were selected from the list presented on Table 2. Table 2
represents sites that have passed through our r.ough economic and
environmental screening. Although I realize that the Steering Committee
disagreed with our rough screening criteria it is my opinion that using
this criteria allowed us to eliminate the least environmentally acceptable
schemes.
.. : ,_. _ . .-. ; . -~ .. ~ ~. . . -· ·"': .. n
•: •..;! • ~ ••. ~_.. ..;;._.-
Mr. Al Carson
Chairman, Susitna Hydro Steering Committee
November 14, 1980
page 2
I would appreciate rece1v1ng the Steering Committee's review and comments
on the sites presented in Table 1. If for any reason you find that any
of these sites are totally unacceptable, I request that you recommend
a replacement of similar size from the sites listed 'in Table 2. This
replacement is essential so that we can retain 4-6 candidate sites in
each size category. Information relating to location and design para-
mete~for each site was included in the information packets distributed
prior to our November 5 meeting.
Trusting this approach meets with your approval.
KRY/jmh
Attachments
Coordinator
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Table I
Candidate Sites for Future Study
<25 MW
Tustumena
Allison Creek
Silver lake
Strandl ine Lake
25-100 MW
Snow
Hicks
Cache
Keetna
Talkeetna-2
Lower Chulitna
>lQo MW
Chakachamna
Johnson
Browne
Land
Tokichitna
Table 2
Sites Passing Rough Screening
Size <25 MW 25-lOOMW >100 MW
Strandline L. Whiskers Snow Lane
Lower Beluga Coal Kenai Lower Tokichitna
Lower Lake Cr. Chulitna Gerstl e Yentna
Allison Cr. Ohio Tanana R. Cathedral Bluffs
Grant Lake Lower Chulitna Bruskasna Johnson
McClure Bay Cache Kantishna R. Browne
Upper Nellie Juan Greenstone Upper Beluga Tazilna
Power Creek Talkeetna 2 Coffee Kenai Lake
Si 1 ver Lake Granite Gorge Gulkana R. Chakachamna
Solomon Gulch Keetna Klutina
Tustumena Sheep Creek Bradley Lake
Skwentna Hick's Site
Talachulitna Lowe
-
TO:
FROM:
ALASKA PO\VEIC. AUTIIORITY
Susitna Steering Conmittee
Members
-~/ Robert A. Mohn ivr-?'
Director of Engineer4ng
· Alaska Power Authority
MEMORANDUM
DATE:
SUBJECT:
November 25, 1980
Environmental screening
of hydroelectrjc
sites
There has been some measure of frustration and disappointment on all sides
associated with the attempt by Acres American to solicit input from the Steering
Committee at the committee's last meeting. It seems to me that an important
factor in the lack of success may stem from misunderstanding or uncertainty
about this exercise in relation to an "alternatives study~.
As you probably remember, the original Acres plan of study (POS) called for
a study of alternatives to Susitna as the primary element of Task 1. Information
about alternatives was to be developed, a screening mechanism was to be employed
to narrow the range of acceptable options, and the Susitna project was to be
compared against the preferred alternative. This work was to be conducted in
parallel with the detailed studies of the Susitna project, and its goal was to
formulate several optimized "without Susitna 11 plans. In other words, Task 1 was
meant to be a thorough search for a plan that would be preferable to Susitna
development.
The Power Authority requested supplemental funding to adequately fund Task
1 after some early criticism of the funding level and study scope. The requested
$1.3 million was appropriated but with the caveat that the alternatives study
would be performed by someone other than Acres. The Governor's 4-person policy
review committee (Ulmer, Lehr, Quinlan and Conway) selected BatteTle to do the
work.
The elimination of Task 1 from our study-plan left a significant hole.
This was the case because information that was to be developed in Task 1 was
critical to the formulation of the preferred Susitna basin development plan and
to the economic evaluation of the Susitna plan. River basin planners cannot
formulate an optimal Susitna plan without knowing what the remainder of the
Railbelt power system components are likely to be, and the economic analysts
cannot evaluate beriefits and costs without having a "without Susitna" plan to
compare to.
So, the Power Authority and Acres responded to the termination of Task 1 by
augmenting the design development work in Task 6~ This permitted .the Susitna
study to stay on track by incorporating that portion of Task 1 needed for Susitna
plan formulation. The objective of this work is not to formulate an optimal set
of alternatives; that is being done by Battelle. Instead the purpose is to
gather information about likely components of a future Railbelt power system as
a frame of reference for Susitna project formulation.
ALASKA POWER AUTIIORITY
MEMORANDUM
TO: Susitna Steering Committee
Members
DATE: November 25, 1980
It is in this gathering of information about likely system components and
in establishing the frame of reference that your assistance has been sought. To
reiterate, the exercise is in support of Susitna· project formulation; it is not
meant to replace the Battelle alternatives study or be the final word on alter-
natives.
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D/VISIOAIOFRESEARCH&DEVELOPMEfiff i ANCHORAGE. ALASKA 99501
December 11, 1980
Don McKay u. S. Fish & Wildlife Service
733 W. 4th Ave., Suite 101
Anchorage, Alaska 99501
Dear Mr. McKay:
279-5577
Enclosed please find a 11/14/80 letter from Kevin Young of Acres American
concerning review of potential hydroelectric sites. You will recall that we
discussed this with Mr. Young during our afternoon session on November 5, 1980.
There. is also a memorandum from Robert Mohn of the .Alaska Power Authori\~~hflliW!!n ... 1
descr1bes why A.P.A. has contracted ACRES to do th1s task. _f A .. rHOR:rv_ ·1 J·-.. i SUSITNA ·,
Please review the documents as explained in Mr. Young 1 s letter and ~~1it p 57;;;-i';
your comments to me either in writing or by phone by December 31, 1~.:_-~~~-~·~±::.r-.. 1
' :.-,~;;.u::;-.:; :1~· f·Jr)· 1 ; ; • ,_ ~ -: :· .. . I Sincerely,
Al Carson, Chairman
Susitna Hydro Steering Committee
Enclosures
cc:. Eric Yould -A.P.A.
Kevin Young -ACRES
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DIVIS/ONOFRESEARCH&DEVELCPMENT j ANCHORAGE. ALASKA 99501
December 11, 1980
Tom Trent
AK Department of Fish & Game
333 ~pberry Road
Anchorage, Alaska 99502
Dear Mr. Trent:
279-5577
Enclosed please find a 11/14/80 letter from Kevin Young of A_cres American
concerning review of potential hydroelectric sites. You will recall that we
discussed this with Mr. Young during our afternoon session on November 5, 1980.
There is also a memorandum from Robert Mohn of the Alaska Power Authority which
describes why A.P.A. has contracted ACRES to do this task.
Please review the documents as explained in Mr. Young's letter and forward
your comments to me either in writing or by phone by December 31, 1980.
Sincerely,
()\~
Al Carson, Chairman
Susitna Hydro Steering Committee
Enclosures
cc: Eric Yould -A.P.A.
Kevin Young -ACRES
.-
....
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UEP.:\IlT~IENT ot· NATUR.41. RESOURCES
DIVISION OF RESEARCH & DEVELOPMENT
December 11, 1980
John Rega
Bureau of Land Management
Anchorage District Office
4700 E. 72nd Avenue
Anchorage, Alaska 99502
Dear Mr. Rego:
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JAr .t HAMMOND, &DVEIIIDI
i 323 E. 4TH A VENUE
l ANCHORAGE, ALASKA 99501
279-5577
Enclosed please find a 11/14/80 letter from Kevin Young of Acres American
concerning review of potential hydroelectric sites. You. will recall that we
discussed this with Mr. Young during our afternoon session on November 5, 1980.
There is also a memorandum from Robert Mohn of the Alaska Power Authority which
describes why A.P.A. has contracted ACRES to do this task.
Please review the documents as explained in Mr. Young 1 s letter and forward
your comments to me either in writing or by phone by December 31, 1980.
Sincerely,
(JQ~
Al Carson, Chairman
Susitna Hydro Steering Committee
Enclosures
cc: Eric Yould -A.P.A.
Kevin Young -ACRES
UEP.~\.RT-'IENT o•· NATURAl~ RESOURCES
DIVISION OF RESEARCH & DEVELOPMEM"
December 11, 1980
Bob Lamke
U. S. Geological Survey
Water Resources
733 W. 4th Ave., Suite 400
Anchorage, Alaska 99501
Dear Mr. Lamke:
' i
I ! 323 E. 4TH A VENUE
1 ANCHORAGE, ALASKA 99501
JAYS. HAIIMDIID, SDV£11101
279-5577
Enclosed please find a 11/14/80 letter from Kevin Young of Acres American
concerning review of potential hydroelectric sites. You will recall that we
discussed this with Mr. Young during our afternoon session on November 5, 1980.
There is also a memorandum from Robert Mohn of the Alaska Power Authority which
describes why A.P.A. has contracted ACRES to do this task.
Please review the documents as explained in Mr. Young's letter and forward
your comments to me either in writing or by phone by December 31, 1980.
Sincerely,
01~
Al Carson, Chairman
Susitna Hydro Steering Committee
Enclosures
cc: Eric Yould -A.P.A.
Kevin Young -ACRES
-
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ltJU•.:\.IlT~IENT Ot' NATURAl .. R.:SOURCF.S
DIVISION OF RESEARCH & DEVELOPMENT
December 11, 1980
Bill Wilson or Chuck Evans
Arctic Environmental Information
and Data Center (U of A)
707 nAn Street
Anchorage, Alaska 99501
Dear Messrs. Wilson & Evans:
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I
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J
f 323 E. 4TH A VENUE
ANCHORAGE, ALASKA 99501
279-5577
Enclosed please. find a ll/14/80 letter from Kevin Young of Acres American
concerning review of potential hydroelectric sites. You will reca 11 that we
discussed this with Mr. Young during our afternoon session on November 5, 1980.
There is.also a memorandum from Robert Mohn of the Alaska Power Authority which
describes why A.P.A. has contracted ACRES to do this task.
Please review the documents· as explained in Mr. Young's letter and forward
your comments to me either in writing or by phone by December 31, 1980.
Sincerely,
Ol·~
Al Carson, Chairman
Susitna Hydro Steering Committee
Enclosures
cc: Eric Yould -A.P.A.
Kevin Young -ACRES
.-, -. _...... ...........
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J)EP.\.HTlUENT 01' NATURAl~ Rt:SOURCt:S
DIVISION OF RESEARCH & DEVELOPMENT
December 11, 1980
Dave Sturdevant
Department of Environmental
Con~vation
Poucli 11 011
Juneau, Alaska 99811
Dear Mr. Sturdevant:
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JAr i HAIIIIIDIID, GOYCIIIOI
I 323 E. 4TH A VENUE
1 ANCHORAGE, ALASKA 99507
279-5577
Enclosed please find a 11/14/80 letter from Kevin Young of Acres American
concerning review of potential hydroelectric sites. You will recall that we
discussed this with Mr. Young during our afternoon session on November 5, 1980.
There is also a memorandum from Robert Mohn of the Alaska Power Authority which
describes why A.P.A. has contracted ACRES to do this task.
Please review the documents as explained in Mr. Young•s letter and forward
your comments to me either in writing or by phone by December 31, 1980.
Sincerely,
()j~
Al Carson, Chairman
Susitna Hydro Steering Committee
Enclosures
cc: Eric Yould -A.P.A.
Kevin Young -ACRES
-
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IUUI!.\.IlT~IENT en: ~ATURAI. Rt:SOURCES
DIVISION OF RESEARCH & DEVELOPMENT
December 11, 1980
Larry Wright or Bill Welch
Heritage Conservation and
Recreation Service
1011 E. Tudor Road, Suite 297
Anchorage, Alaska 99503
Dear Messrs. Wright & Welch:
. l
J JAY S. HAMMD/10, "Y!IIIOI
I
I 323 E, 4TH AVENUE
ANCHORAGE. ALASKA 9950'
279-5577
Enclosed please find a 11/14/80 letter from Kevin Young of Acres American
concerning review of potential hydroelectric sites. You will recall that we
discussed this with Mr. Young during our afternoon session on November 5, 1980.
There is also a memorandum from Robert Mohnof the Alaska Power Authority which
describes why A.P.A. has contracted ACRES to do this task.
Please review the documents as explained in Mr. Young's letter and forward
your comments to me either in writing or by phone by December 31, 1980.
Sincerely,
01~
A 1 Carson~ Cha i nnan
Susitna Hydro Steering Committee
Enclosures
cc: Eric Yould -A.P.A.
Kevin Young -ACRES
(jl':;?
'~,~; u
ltEI~\IlT.\IENT 01• NATURAI4 R..:SOURCES
DIVISION OF RESEARCH& DEVELOPMENT
December 11, 1980
Brad Smith or Ron Morris
National Marine Fisheries Service
701 "C" Street, Box 43
Anchorage, Alaska 99513
Dear Messrs. Smith & Morris:
~
/
!
I JArS. HAIIIIOIID, SO'IEIIIOI
I 323 E. 4rH AVENUE
j ANCHORAGE. ALASKA 99501
279-5577
Enclosed please find a 11/14/80 letter from Kevin Young of Acres American
concerning review of potential hydroelectric sites. You will recall that we
discussed this with Mr. Young during our afternoon session on November 5~ 1980.
There is also a memorandum from Robert Mohn of the Alaska Power Authority which
describes why A.P.A. has contracted ACRES to do this task.
P1ease review the documents as explained in Mr. Young•s letter and forward
your comments to me either in writing or by phone by December 31, 1980.
Sincerely,
~~
Al Carson, Chairman
Susitna Hydro Steering Committee
Enclosures
cc: Eric Yould -A.P.A.
Kevin Young -ACRES
Al Carson
State of Alaska
UNITED STATES
DEPARTMENT OF THE INTERIOR
GEOLOGICAL SURVEY
Water Resources Division
733 W. Fourth Ave., Suite 400
Anchorage, Alaska 99501
July 27 , l98l
Department of Natural Resources
323 E. Fourth Avenue
Anchorage, Alaska 99501
Dear Mr. Carson:
RECEIVED
.lUL)) 1981
ALASKA POW~:: . .:.:.:~:~(JkiTY
I have reviewed the Draft Development Selection Report for the proposed
Susitna Hydroelectric Project as requested in the APA transmittal of
June 18, 19.81. The review was limited to the evaluation process used
by Acres, the relative impacts of several alternative development plans
of SusHna hydroelectric resources, and the conclusion that the Watana-
Devtl Canyon plan is the preferted basin alternative.
There were no problems involved in understanding the selection process
used by Acres and there were enough data and information presented to
compare the final candidate {_alternative) plans. The relative impae:ts
of the candidates were presented in an understandable and credible manner.
Although enly a qualitative eva 1 ua tion of impacts is presented· (pending
reports of on-going studies), a reasonable conclusion is that the Watana-
Deyil Canyon plan is the preferred candidate for Susitna hydroelectric
development.
,. ;" / ~a· t' }1 I :"),..('if ,A./ . J_. Ci,-4-./ u
1 Robert D. Lamke
cc: David D. Wozniak, Project Engineer, APA, Anchorage, AK I
.• onmentQI Information and Data Center
707 A Street
PHONE 19071 279·4523
Anchorage, Alaska 99 50 1
UNIVERSITY OF ALASKA
RECt::IVED
August 4, 1981 ·" r fr'\ C' }98} '··"·.J :.;
ALASKA POWER AUTHORITY
Dave Wozniak
Alaska Power Authority
333 W. 4th AVenue, Suite 31
Anchorage, AK 99501
Dear Dave:
Per your request to the members of the Susitna Steering Committee, I
have ·quickly reviewed the Development Selection Report prepar·ed by
Acres. In general I found it logical in approach and complete in re-
gards to the relevant factors one should evaluate when reducing multiple
options.
I haveonly the following specific comments:
1. The location and environmental effects of developing borrow
material sites is not well documented and incorporated into
the first part of the report. Enormous qunatities would be
required for most of the dams, and the removal, stockpiling,
and transport of this material could be a significant factor
influencing the decision-making process.
2. Significant efforts are currently being expended in environ-
mental study of this region, the results of which are not yet
available. Factoring this new knowledge·into the decision-
making process could have influenced the nature of the final
scheme; or is the current environmental study effort geared
only toward the effects of the "selected plan (page 9-1)" and
not for input to the overall selection process? In general I
found the environmental effects of the alternative options
addressed very superficially.
I hope my comments are of interest.
WJW/g
cc: Al Carson
Sincerely,
-L. /' 7lL ~ L L
William J. Wilson
Supervisor, Resource and Science
Services Division
Senior Research Analyst in Fisheries
United States Departme_nt of the Interior
NATIONAL PARK SERVICE
IN REPLY REFER TO:
1201-03a
Mr. David D. Wozniak
ALASKA STATE OFFICE
334 W~st fifth Avenue, Suite 250
Anchorage, Alaska 99501
AUG 5 1981
Susitna Hydro Project Engineer
Alaska Power Authority
333 West 4th Avenue, Suite 31
Anchorage, AK 99501
Dear David:
RECEIVED
!\UG 7 1981
N.ASKA POWER AUTHORITY
In response to your request I have reviewed the Draft Devel-
opment Selection Report for the Susitna Project. Based upon
the information presented in the report, I would judge the
evaluation process to be satisfactory. However, I would not
want to recommend or otherwise comment on a prefe.::.red basin
alternative prior to the completion of ongoing studies which
will further quantify the anticipated environmental impacts.
I assume the final report will refl~ct a more precise com-
parison of environmental impacts for the dam sites under
consideration.
An additional item of interest which should perhaps be
included in the final report is a comparison of the expected
life of the project for each alternative dam site considering
the effect of silt accumulation in the reservoirs.
Thank you for the opportunity to review the report. The
above comments are my own and should not be interpreted as
representing the official position of the National Park
Service.
Sincerely,
_ _/ ~ \ l/-/£wJ UYJ c , ) ~r~
Larry .. Wr1ght ·
Outdoo Recreation Planner
Save Energy and You Sen•e A me rica!
j
!
' i
/
I
I
i
I
437 E Street
Second Floor
Anchorage, AK 9950:
SOUTIICI Nih'/./ fiifi'f'',.; -'·,.I
PO. Bm 1207
Soldolna. ''la!.>ka 99669
(907} ~52 'i210
;:-,:,:::_iJ~D
Dave 'Wozniak
Project Engineer
Alaska Power Authority
333 W. 4th Avenue, Suite 31
Anchorage, Alaska 99501
Dear Mr. Wozniak:
lSR1
P.O. Box i064
CJ Wasilla, Alaska 99687
(907) 375·5038
August 14, 1981
We have reviewed sections 7 and 8 of the Susitna Hydroelectric Project
Development Selection Report (second draft June 1981). We find that the
plan selection methodology used in section 8 meets the objectives of
determining an optimum Susitna Basin Development Plan and of making a
preliminary assessment of a selected plan by an alternatives comparison.
The increased emphasis over previous analyses of the environmental
acceptability of the alternatives is good.
At this time, this Department does not endorse any particular plan. We
would, however, recommend the Steering Committee openly discuss the
\~atana Dam -Tunnel option because of _its reduced environmental and
aesthetic impact.
Thank you for the opportunity to review this document. We appreciate
your effort in soliciting Su-Hydro Steering Committee involvement. If
you have any questions regarding these comments please contact Steven
Zrake of this office.
cc: Steve Zrake
Dave Studevant
Al Carson -DNR
BH/SZ/mn
Sincerely,
fiR?r~~
Bob Hartin
Regional Environmental Supervisor
-
....
Mr. Lee Wyatt
Planning Director
Matanuska-Susitna Barough
Box B
Palmer, Alaska 99645
Dear Mr. Wyatt:
October 21, 1981
P5700.10
Susitna Hydroelectric Project
Development Selection Report
As you know, Acres J1merican, Incorporated is under contract to the Alaska
Power Authority to conduct a feasibility study and prepare a Federal Energy
Regulatory Commission ( FERC) 1 i cen.se application for the Sus itna Hydro-
electric Project. The scheduled date for submission of the application is
in June of 1982.
Federal law and FERC regulations require that the reports supporting the
FERC application be prepared in consultation with Federal and State agen-
cies having managerial authority over certain project aspects. This coor-
dination must be documented in the license application.
A great deal of coordination has taken place at agency staff levels by dir-
ect participation in studies or by participation in committees and task
groups. This input, however, has been primarily by staff and may not nec-
essarily reflect the views of the agency. For this reason, we are conduct-
ing a pa~allel formal coordination process, by requesting agency comments
on key study outputs. The plan of study was the first document coordinated
in this manner. Over the next year, there will be several more. This par-
allel process will affect the other coordination activities of the study.
At this time, we request that the f.'latanuska-Susitna Barough review the
attached Report, particularly in the areas impacting on the environment.
ACRES AMERICAN INCORPORATED
Co,.,sulting Engineers
The Liber~;· B<!nk Bui!o•"g t-.1ain at Court
8\J~!a!o. N-s··.·. York 14202
Tt e•. o~ -642c /-C. RES E:UF
Development Selection Report - 2 October 21, 1981
Your prompt attention to this matter will enable us to continue planning
the best possible developnent for all interests. A response within thirty
days of receipts would be greatly appreciated. Please send a copy of your
comments to:
JDL:jgk
~
Mr. Eric Yould, Executive Director
Alaska Power Authority
333 West 4th Avenue
Anchorage, Alaska 99501
Very truly yours,
John U. Lawrence
Project Manager
cc: Eric, Yould, Alaska Power Authority
,....
-
Preceding letter Sent To:
Mr. Lee Wyatt
Planning Director
Matanuska-Susitna Borough
Box B
Palmer AK 9%45
Mr. John Rego
Bureau of Land Management
701 C Street
Anchorage, AK 99501
Mr. Tom Barnes
Office of ·Coas ta 1 Management
Division of Policy Development
and Plann·i ng
Pouch AP
Juneau, AK 99811
Mr. John E. Cook
Regional Director
National Park Service
540 West Fifth Avenue
Anchorage, AK 99501
Mr. Ernest W. Mueller
Commissioner
Alaska Department of
Environmental Conservation
Juneau, AK 99801
Ms. Lee McAnerney
Department of Regional Affairs
Pouch B.
Juneau, AK 99811
Mr. Ronald 0. Skoog
CollVllissioner
Alaska Department of Fish and Game
Juneau, AK 99801
Mr. Keith Schreiner
Regional Director
U.S. Fish and Wildlife Service
11011 £._Tudor Road
Anchorage, AK 99503
Colonel lee Nunn
District Engineer
U.S. Army Corps of Engineers
P.O. Box 7002
Anchorage, AK 99510
Mr. John Katz
Alaska Department of Natural
Resources ·
Pouch M
Junean, AK 99811
Mr. Robert Shaw
State Historic Preservation
Office
Alaska Department of Natural
Resources
619 Warehouse Avenue
Anchorage, AK 99501
Regional Administrator
U~S. Environmental Proection
·Agency
1200 South Avenue
Seattle, WA 98101
Mr. Robert McVey, Director
Alaska Region
.National Marine Fisheries Service
P.O. Box 1668
Juneau, AK 99802
Mr. Ronald 0. Skoog
CoiTITiissioner
RECEIVED
{ !0'·/ 1 3 1981
itove::·,oer S, l9Sl
P5700.06
Alaska Dept. of Fish & Game
Sport Fish/Susitna Hydro
State of Alaska Department of Fish and Game
Juneau~ Alaska 99801
Dear Mr. Skoog:
Susitna Hydroelectric Project
Development Selection Report
As you know~ Acres American Incorporated is under contract to the Alaska
Power Authority to conduct a feasibility study and prepare a Feder a 1 Energy
Regulatory Commission (FERC) license application for the Susitna Hydro-
electric Project. The scheduled date for submission of the application is
in June of 1982.
Federal law and FERC regulations require that the reports supporting the
FERC application be prepared in consultation with Federal and State agen-
cies having managerial authority over certain project aspects. This coor-
dination must be documented in the license application.
A great deal of coordination has taken place at agency staff levels by dir-
ect participation in studies or by participation in conmittees and task.
groups. This input~ however~ has been pr imari 1 y by staff and may not nec-
essarily reflect the views of the agency~ For this reason, we are conduct-
ing a parallel formal coordination process by requesting agency comments on
~ey study outputs. The plan of study was the first document coordinated in
this manner. Over the next year, there will be several more. This parallel
process will affect the other coordination activities of the study.
At this time~ we request that the Department of Fish and Game review the
attached Report, "Development Selection Report"~ particularly in the areas
impacting on the"flsh and game resources.
ACRES AMERICAN INCORPORATED
Consu':;c.il Eng:ncers
The l•l:''"!y 5~'1k Bui!c!mg. r.~ain at Court
au:faiC' ~;=··· 'rcrk 1~202
Deve1opment Se:ection keporL -" f·iOve::;oer 9, 1961
Your prompt attention to this matter will enable us to continue planning
the best possible development for all interests. A response within thirty
days of receipts would be greatly appreciated. Please send a copy of your
comments to:
Mr. Eric Yould 9 Executive Director
Alaska Power Authority
333 West 4th Avenue
Anchorage 9 Alaska 99501
JOL/MMG:jgk
cc: Eric Yould 9 Alaska Power Authority
Very truly yours 9
Q'!J-/lm ~~ltiip/
~n D. Lawrence
Project Manager
Mr. Thomas Trent 9 Department of Fish & Game
ACRES AMERICAN INCORPORATED
WILLETT
WITTE
BERRY
HAYDEN
LAMB
LAWRENCE
SINCLAIR
VANDERBURGH
'r-'{
\
CARLSON
FRETZ
JEX
LOWREY
SINGH
HUSTEAD
BOVE
CHASE
[vf-' /,//
~/~ ,· ~
//
Mr. Lee Wyatt
Planning Director
Matanuska-Susitna Barough
Box B
Palmer, Alaska 99645
Dear Mr. Wyatt:
December 4, 1981
?5700. 11 • 92
T. 1330 '
Susitna Hydroelectric Project
Document Transmittal Form
Enclosed is a document transmittal form which should have accompanied our
package dated November 10 containing copies of the Developnent Selection
Report and its appendices. The document transmittal form is part of a
newly-implemented procedure at Acres which is intended to verify the arrival
of documents shipped via various carriers and thus alleviate as quickly as
possible any problems which may arise due to documents being misplaced
during transit. ·
If you have any questions, please do not hesitate to call.
JEM/jh
Enc1 osures
ACRES AMERICAN INCORPORATED
Tt-.r! LtbE=-~::,· ec·-;~ 8 ..... 1 ::·~; '.~e:·r. at C0urt
2 .... ~';;'o ~;f-.·. Yo·io.. 1-'L02
Sincerely yours,
~e:Yn~
.~John D. Lawrence
Project Manager
-
Preceding Letter Sent To:
Mr. Lee Wyatt
Planning Director
Matanuska-Susitna Borough
Box B
Palmer AK 99645
Mr. John · Rego
Bureau of Land Management
701 C. Street
Anchorage, AK 99501
Mr. Tom Barnes
Office of Coastal Management
Division of Policy Development
and Planning
Pouch AP
Juneau, AK 99811
Mr. John E. Cook
Regional Director
National Park Service
540 West Fifth. Avenue
Anchorage, AK 99501
Mr. Ernest W. Mueller
Commissioner
Alaska Department·of
Environmental Conservation
Juneau, AK 99801
Ms. Lee McAnerney
Department of Regional Affairs
Pouch B
Juneau, AK 99811
Mr. Ronald 0. Skoog
Commissioner
Alaska Department. of Fish and Game
Juneau, AK 99801
Mr. Keith Schreiner
Regional Director
U.S. Fish and Wildlife Service
11 011 E. Tudor Road
Anchorage, AK 99503
Colonel Lee Nunn
District Engineer
U.S. Army Corps of Engineers
P.O. Box 7002
Anchorage, AK 99510
Mr. John Katz
Alaska Department of Natural
Resources
Pouch M
Junean, AK 99~11
Mr. Robert Shaw
State Historic Preservation
Office
Alaska Department of Natural
Resources
619 Warehouse Avenue
Anchorage! AK 99501
Regional Administrator
U.S. Environmental Proection
Agency
1200 South Avenue
Seattle, WA 98101
Mr. Robert McVey, Director
Alaska Region
' National Marine Fisheries Service
P.O. Box 1668
Juneau, AK 99802
}lr. £ric Yould
Lxecutive Director
Alaska Power Authority
)33 W. 4th Avenue
&1chorage, Alaska 99501
Dear Hr. Yould:
17 DEC-191n
Mr. John Lawrence of Acres American, by letter of November 9, 1981,_
requested that the Fish and Wildlife Service review the Development
Selection Report for the Susitna Hydroelectric Feasibility Study. We
offer the following comments: ·
l. The decision-tuBking methodology (selection process) does not pro-
vide an equitable basis for comparison of all study el~ents. lbe
preble~ that ve have identified is that at the time major decision
points arc :reached, information is much more detailed in regard to
engineering and economic factors than environmental considerations.
We recommend that the process be modified so that all study elements
are equal (scope and depth), before they are presented to the ·
decision-maker.
2. Although alternatives to Susitna are being studied separately by
Battelle, cocparisons were drawn within the selection report. The
comparison of Susitna development to alternative hydroelectric
power development is stated as economic only. The eomparison to
thermal generation is, although not noted as such, solely based on
an econ01nic evaluation.
In regard to sensitivity testing of the all the~al versus Susitna ·
power development options the report states (p. 9-11), "A comparison
of alternatives to Susitna is outside the realm of these studies •••• ''
The following conclusion is, however, offered on p. 9-1, " .•. the
future development of Railbelt electric power generation souTces
should include a Susitna Hydroelectric Project." These statements
are in apparent conflict.
-
The following statement addresses the Susitna development environmental
studies and review (p. 9-11), ''Irlentifyins compensation measures ,and the
actual prediction of environmental impacts are the subject of ongoing
studies. The results of these studies will be included in our 1982
feasibility report to be available prior to making the decision as to
whether or not to proceed with FERC licensing." It should be noted that
:1<uch of theinforrnation for inclusion in the feasibility report will be
prelir.dnary. It is our opinion that the rudimentary nature o! this
1nfon:l3tion l.lould preclude a credible impact analysis at that time.
!hank you for the opportunity to revi~ and comment on the Design Selection
Report:.
Sincerely.
;s; s~ HfnJrt.S~
Adfng
A!JII-.nt Regional Dirac-tor
cc: F~IS-ROES, WAES
i\r!FS, Anchorage
Quentln Edson, FERC
Lavrence, Acces Amori:can
The preceding letter was received and reviewed. Although no formal response
was prepared, our comments are as follows:
(1) It was most efficient to detenn·ine if a site could technically be developed
and it it would be economically attractive prior to collecting environ-
mental information. Once a site passed the initial economic and engi-
neering screening, full consideration was given to environmental consider-
ations. Figures E. 10.1 and E. 10.4 depict the selection process.
{2) Environmental factors were considered when comparing Susitna to other
sources of power. This information is included in an expanded form in
Chapter 10, Section 4 of Exhibit E of the license application.
{3) Thychedule for filing the license application was developed from June
1982 to February 1983 to allow incorporation of additional environmental
data and to refine the impact analysis and mitigation planning. In
addition, the Alaska Power Authority will be funding continuing environ-
mental studies.
------~----------~~~~---~---~~---~---~~
-
l76l9(AAO-F)
·~~.Eric Yould, Execut1ve Director
Alaska Powe~ Authority
33~ W. fifth Avenue
Anchorage. r'\ll1ska 5?5.51
Desr f'~r. Ycu1d:
RECEIVED
JAN 0 4 1982
ACL.; ·•~'-···~• .. i jnburtrORATED
3 0 DEC 1981
ALASKA POWEF
WTHORITY
SUSITNA
FILE P570C
SEQU£f\:CE N
.. -9_~ (,/
z .:EI ~ ! : Q!c:l c: .• · .,..o, t; I i Ir. response to a tiovsuber 16, 1931 letter frc.-n the lkrcs Ame~fcan lnc. P ~3~· 6 1 :
~·:ar,ager. Hr. John 0. La\trence, we have the followinq coorn1ents concerning t· :ed __ ._
Sus.itn-l project reports. The re;>orts reviewed include: 19SO EfJVironr.;cnt l/~l~c 3_ _
Su:;.:;1ary Report (i!~C:y 1981); Trans."11ssion Une Corridor Screel'}ing Re>i'ort {S pt§~~~\ •
1?~1); ar.d the Devslor'\i<ent ~lectiGn R~po-rt (Oetoner 1981). · · l_l-:f-~a :-=
. . . I ; J (j •; .
Provision for ~ultural resource fde;.t1ficat1on a;.d ma11a9f:ffier:t. app~ars to ·~:;; ~~; -
apprcpriat.e ana adequate. J\1so. 1t would .appear that recr!:!at1on 1s being --·,-J ;;-e:-!-
ad~ouatcly· addressed b'-' the !)lannfn~. process. · -,-·---:-
. · · J • · • JIPG;;· -------
Ttlc:-Evaluation process descrit-ed fr. the Dcvelopr-.ent Selection Re;.crt app;:; r9-~N~J ...
to t;J;: very ad.:cuc.te. T!~is a:enc:y dces not reco;-;r.:cnd a particular t1as in p w~r s-.; T I
c•wt:'lopGent plan. 1-:o~~·::ver. we de note on pa~e G-26 that the tunnel schrn~ liS-D~'iL! --
reco::;ni:::c;l! t;y. thr! report a.s t-ein:: env1ronr!ental1j• surerior. a11d hould pre. i-··~'le "M-R' vj--
oany of the resuurc~ Villues curr~ntly assoc1atc:d with the De'lfl Canyon. H-Rc1--
--l-
It wuu1d ce helpful to thf! r~~Jcr 1 f an indt!.X could be includect with each ----:-
rc.port cr ;n:~r:1ap$ prepared sznarately for the entir~ S(~ries of rrojE:ct re, -~ts. J --
~fe lao. r. fcrwo.rd to. th-e op~r;rtun1ty to r~v1~w subs~quent prc·j .. e.ct re;:crts. .b . =!~~
addition to t•c1n:J i1~ciud:::d in thG historfcz.l an~ archeolot}ical, and rccr~ t1 n !
f?rO~~s id.2J~t1fie:;d for fan-::al coordination. thfs ~·;~ncy should p?rhaps a1s =rr FI\;E ! -
1i1CJUd::c Hithin the \r!ater quslity and use, ~estl~etics artd land use srour.s ~as \":.e-··----
~r.:: t:-~te:rtst12c in project r~lat~<! recrr~tion i:~::;z,cts that w1i1 occur ~iU1in au<!
t-::ycJJd the: project. t;~J;;r.darx.
J~J Douclas G. ~arnoel
cc:
.:c, ·,;. ~-Un.r•.::;c,:. Acres J.:·;.:dcar. lnc •• 5'Q-J Uberty t;~nk ~~dlci:~;. =-~;ffalos -::::~
Y~;r~: IC'!?
I r ~---_;;
I -
I ! ·~-__ ,___
Mr. Douglas G. Warnock
Assistant Regional Director
Alaska Region
National Park Service
540 West Fifth Avenue
Anchorage, Alaska 99501
Dear Mr. Warnock:
~larch 1, 1982
P5700.ll
T. 1425
Susitna Hydroelectric Project
I thank you for your December 30, 1981 response to our request for
review and comment on Susitna project reports forwarded to your agency.
I am pleased that you are satisfied to date with our cultural resource
identification and management, recreation planning and Development
Selection evaluation process.
In regards to the review of subsequent reports we are receptive to
including your agency in the water quality and use, aesthetics and land
use groups if you consider this information beneficial in performing
your formal review of project related recreation impacts. We are entlosing
the 1980 Land Use Annual Report.
KRY/jmh
Enci osure
xc: Eric Yould, APA
ACRES AMERICAN INCORPORAT£0
i . .r. • ... ..•• ..;: -. -:. :::. •• p ... -. ~ .. : -~.... -..; . . ': ..... :
-
r
l ! .
APPENDIX EllE
CORRESPONDENCE RELATING TO
MITIGATION PLANNING
-
APPEND·IX 11 . E
MITIGATION PLANNING
Mitigation planning for the Susitna Project has involved APA, its consultants,
and· the state and federal resource agencies. A Fisheries Mitigation Core
Group, Wildlife Mitigation Core Group, and Fish and Wi.ldlife Review Group.
were established. A Fish and Wildlife Mi,tigation Policy was developed, re-
vised three times following receipt of comments, and finalized during the
1981-1982 period. Various mitigation options papers were also drafted,
circulated for comments, and discussed in meetings with the agencies.
This section contains correspondence and meeting notes of the above activities.
Correspo.r:Hience is presented primarily in chronological order. However, in
~-some cases, a response to. a letter directly follows the letter to facilitate
·-
-
-
an understanding of the flow of communication. This results in an interruption
in the chrohological sequence.
It should be noted that correspondence and meeting notes, regarding the
modeling workshops, are not included. Although this workshop relates to
mitigation planning, it also relates to ongoing studies. Hence, it is in the
Additional Studies and Project Refinement section.
-
SUSITNA WILDLIFE I~ITIGATION TASK FORCE
NOTES OF MEETING
January 30, 1981
Anchorage, Alaska
Compiled by: Edward T. Reed
Wildlife Ecology·Group Leader
Terrestrial Environmental
Specialists, Inc.
The meeting was corrmenced at 9:00 a.m.
Hr. Reed gave a brief introduction and requested that all participants
{see attached list) introduce themselves ~nd indicate the organization
they represented.. In his introduction, Mr. Reed identified the major
problem associated with the development of a Susitna wildlife
mitigation program as .the fact that in some cases data collection will
not be completeuntil after the submittal of a license application to
FERC (July 1, 1982). Thus the level of detail that can be incorporated
into a program at the end of Phase I wi 11 vary among the various ~
components of the wildlife studies, and in some cases there will be
insufficient data available to develop a finely-·tuned mitigation plan.
:. Carson asked what the relationship was between this meeting and the
Steering Committee comments on the Task 7 Procedures Manuals. Or.
lucid and Mr. Reed responded that, although mitigatiori planning was
among the topics commented upon by the Steering Committee, this Task
Force had been planned prior to the Steering Comnittee 1 s comments and
was not in response to the comments.
Mr. Wozniak explained some of the historythat preceded this meeting,
including the role of the Steering Conmittee and indicated that this
meeting represented a forma 1 consultation between the Power Authority
(including the Power Authority 1 s representatives, i.e. Acres and TES)
and federal and state agencies as called for by the ~ish and Wildlife
Coordination Act.
Mr. Reed presented a brief outline (attached) describing the
organization and functioning of the task force. At the request of Mr.
Carson, the word "procedures" (Purpose of the Task Force, Item #1) was
changed to "options".
-2-
dual role of Mr. Schneider as a represent9tive of ADF&G was
.cussed by Schneider,. Trent, Reed. Lucid, Carson, and Wozniak. A
concensus was reached that 11r. Schneider's participation in the core
group was appropriate due to his technical participation on the $usitna
study Team as leader of the big game studies. All official responses
from ADF&G as a participant in the review group will be handled by Mr.
~ent, who will consult with Mr. Schneider on technical matters. This
arrangement was satisfactory to the meeting participants.
There were no comments concerning information on the outline pertaining
to the Role of the Core Group, the Role of the Review Group, or the
Role of the Task Force Coordinator.
Mr. Carson raised the issue of whether or not members of the review
group should be required to prepare a written discussion of concerns,
issues and pol icy statements. Mr. Carson felt that it was the
responsibility of TES to prepare such material for review and comment
by the review group. Following discussion of this issue, it was agreed
that the Task Force Coordinator would draft a policy statement
incorporating agency concerns and submit it to the review group for
comment. It was suggested that agency concerns could be better
identified through personal interviews with representatives of each
agency. TES and Acres will consider this approach.
Mr. Wozniak questioned whether or not all appropriate agencies were
included in the mitigation task force. The involvement of the U.S.
Corps of Engineers, the Environmental Protection Agency, and the
National Marine Fisheries Service were raised. TES and Acres will keep
these agencies in mind as the task force proceeds, althou~h Mr. Reed
indicated that the participation of these agencies may be either
premature at this point in time, or be more appropriately included in
the fisheries mitigation effort. Mr. Wozniak also raised the question
of involvement by special interest groups. Mr. Reed and Dr. Lucid
responded that the cpncerns of special interest groups were more
appropriately coordinated throu~h the Power Authority's public
participation program. TES will prepare a list of agencies and/or
groups that may be considered for consultation in the future if
pertinent issues concerning such groups develop.
It was discussed, and generally agreed upon, that there are limitations
to the level of detail of mitigation planning that can be performed
within the Phase I time frame. Dr. Lucid, Mr. Reed, and Mr. McMullen
pointed out, nevertheless, that to comply with FERC regulations, the
license application must represent a commitment on the part of the
applicant and that identification of "options" may not be sufficient.
-
~ 8 decided that individual review group members will address all
•• :espondence to the APA, with a copy being sent directly to Mr. Reed, '~~will back-channel a copy to Mr. Young at Acres. Mr. Wozniak
. 1rized the Task Force Coordinator (Mr. Reed) to represeht th~ core
...... up and correspond directly with members of the review group. Mr.·
~~requested written confirmation of this authorization from Mr.
~~g. Mr. Young indicated that Acres would provide the requested
"·cumentat ion. -
Following discuss ion, it was agreed that Hr. Reed would reevaluate the
schedule outlined on the handout. Mr. Carson requested that a meeting
~e held following preparation of a pol icy statement and review by the
review group members.
Mr. Stackhouse indicated that the USFWS had recently (within the past
week) published a statement of mitigation policy in the Federal
Register. Mr. Reed thanked Mr. Stackhouse for this information and
indicated that the pol icy statement would be reviewed at the earliest
possible date.
Followin~ discussion it was decided that the core group should first
prepare a mitigation policy, and following review, proceed with the
preparation of a mitigat1on plan .
. Stackhouse stated that cost effectivenes~ of mitigation plans is an
.• nportant concern of the USFWS.
The question was raised by Dr. lucid as to whether the applicant had
any responsibility to enhance a resource, as opposed to avoidance of
impacts or compensation. It was agreed that TES, in its mitigation
planning, would 11 identify enhancement opportunities .. and stop there.
The subject of compensation of impact on one species (e.g. moose) by
enhancement of another (e.g. salmon) was mentioned. No agreement was
reached on the validity of this concept.
The question of whether or not the review group should have a chairman
was raised. Mr. Reed expressed concern that some details may be lost
if one person was responsible for compiling and possibly summarizing
agency comments. Mr. Carson also advised against the appointment of a
chairman at this time. For the present time, the idea of a review
group chairman was dropped:
Mr. Reed requested that a list be prepared with the name, mailing
address, and phone number of all review group members. This list was
completed and is at.tached.
The meeting was' adjourned at approximately 11:15 a.m.
PARTICIPANT
Edward Reed
Joseph McM u 11 en
Vincent lucid
Robert Krogseng
Richard Taber
Jay r,ic:Kendr i ck
William Co 11 ins
Brina Kessel
Steven Me Donald
Ph i 1 i p G i p son
Kar 1 Schneider
Thomas Trent
Kevin Young
David Wozniak
Bruce Bedard
Alan Carson.
Mike Scott
Gary Stackhouse
Bruce App ie
SUSITNA WILDLIFE MITI~ATION TASK FORCE
MEETING OF JANUARY 30, 1981
ANCHORAGE, ALASKA
LIST OF PARTICIPANTS
REPRESENTING
Terrestrial Environmental
Terrestrial Environmental
Terrestrial Environmental
Terrestrial Environmental
Terrestrial Environmental
University of Alaska
University of Alaska
University of Alaska
University of Alaska
University of Alaska
Specialists,
Specialists,
Specialists,
Specialists,
Specialists,
Alaska Department of Fish and Game
Alaska Department of Fish and Game
Acres American, Inc.
A 1 ask a Power Authority
Alaska Power Authority
Alaska Department of Natura1 Resources
United States Bureau of Land Management
United States Fish and Wildlife Service
United States Fish and Wildlife Service
Inc.
Inc.
Inc.
Inc.
Inc.
--//'A ""'t"'" ,_ ... r .-,_ '--r 1 ~ I ./ .-::-~ c l · ·-.= :::: L 1 c
RECE!Vi=D JUN 1 7 tS81
:=:·; ."::::.:, ~ I !. I r-=:~-~<~ n v 1 ron mEn c a .
'-f-~'"_~ c:; . [ . .!. I ~-r_i7'-pECla lS LS ~InC.
•'-:i R.D. 1 5o OX 366 P"'O EN IX. N.Y. 13135 (J 1 Sj~95·7ZZ8
ALASKA POWER MEMO
AliTHORITY
'jUSITNA
, ILE P?7QO .
. II· ..30
)UENCE NO.
, : lt.dl' Q
...J
TO Members of the Susitna Wild·i ife Mitigation Task Force
FROM: Edward T. Reed, Task For~e Coordinator
DATE: 'June 16, 1981; 218.683
< RE: E
~
Comments concerning the preliminary policy outline.
Enclosed please find another copy of the preliminary outline for the
wildlife mitigation policy statement. I have inserted review comments
that have been received todate. The comments have been plac~td
----~-..:,<'"--'( immediately following the appropriate item. In the case of those
comments that pertain to an entire section, they follow the last item
of each section. In most cases, comments have been transcribed
l---1---f verbatum, although some comments had to be extracted from the
correspondence and minor editorial changes were made~
It should be noted that this was a detailed outline and 'Some of the
--~---~comments would have been unnecessary if a fleshed out text version was
available for review. It was impossible to totally explain all of the
-..........,;i---t details and ramifications of each item within the context of an
-'J...L..t..:.......,L-J --;'r-;--i o u t 1 i n e •
Please review the carninents made by other task force members and be
-+~-l----r prepa.red to discuss possible adjustments to the pol icy statement. As
noted in my memo of May 8, 1981, the next meetingof the mitigation
-1-..,..----i.---ttask force will be held at 9:00 a.m. on 1'.onday, June 29th, in the Acres
Anchorage Office. Hopefully a final version of the po11cy statement
can be agreed upon during that meeting and we can move forward with a
discussion of how best to develop a mitigation plan bas'Ed upon the
policy statement.
1 -BACKGROUND
1.1 -The Need
WILDLIFE MITIGATION
A STATEHENT OF POLICY
PRELIMINARY OUTLINE
Included will be a general discussion of.the'value of the
environment and why it is necessary to reduce or avoi~ negative
impacts while still permitting reasonable energy development.
Comment
USF&WS:
This section should include a discussion of the need to
adequately assess the environmental resources of the study area
to determine the compatibility of the proposed project and to
evaluate mitigation to adequately reduce or avoid negative
. impacts to environmental resources, including fish and wildlife
resources, so that no net loss of habitat value occurs.
1.2 -Legal Mandates
The Federal Energy Regulatory Commission regulations, the Fish
and Wildlife Coordination Act, and the National Environmental
Policy Act will be discussed, as well as a consideration of the
role of state and federal natural resource agencies whose task it
is to protect and manage wildlife resources.
1.3 -Definition of Mitigation
This will be the 5 part NEPA definition.
·-
2 -GEliERAL ?OLICIES TO BE CARRIED OUT BY THE APPLICANT
2.1 -Basic !ntent of the Applicant
(a) The goal of the applicant is to strive, within the bounds of
.feasibility and reasonable costs, to minimize the negative
impacts of the Sus itna Project and compensate for
unavoidable losses of wildlife and wildlife habitat.
Comment
USF&WS:
The goal of the applicant should be to develop a plan to fully
mitigate unavoidable impacts which would result from the
construction and operation of the project with full compensation
for unavoidable losses to fish and wildlife resources.
{b) The success of the mitigation effort will be considered the
difference between impacts without mitigation and impacts
with mitigation. A "no net loss of habitat value" will
serve as the benchmark for measuring both the success of the
mitigation effort and project impacts.
Comment
USF&WS:
Success of the mitigation effort should be assessed through
comparison of habitat value of the study area with the project,
including the mitigation plan, vs. witho~,tt the project, over the
project life. No net loss of habitat value, as determined by
pre-and post-project studies is the goal. Acceptable habitat
evaluation procedures {such as the Fish and Wildlife Service•s
~abitat Evaluation Procedures and Instream Flow Methodology)
should be used to accomplish this goal.
t~cMullen:
11 NO net loss of habitat value" looks good, but it must be decided
how to assess habitat value. Also, are with and/or without
project scenarios going to be considered?
Gipson:
Good statement.
{c} The applicant will provide assurances that the agreed upon
mitigation plan will be a stipulated part of the
construction and operation plans of the project and will be
executed by either the applicant or any other organization
charged with managing the project.
Comment
USF&WS:
The mitigation plan should be developed by the applicant, in
coordination with the state and federal resource agencies. The
plan, as agreed upon by the coordinating agencies, should be
submitted by the applicant to the Federal Energy Regulatory
Commission (FERC} as a component of the application to be
incorporated into the license.
2.2 -Input From Agencies and the Public
(a) The applicant will provide opportunities for the review and
evaluation of concerns and recommendations presented by the
public as well as by federal and state agencies.
Comment
USF&WS:
Additional review and evaluation of the project will be provided
through formal agencies comments in response to state and/or
federally administered licensing and permitting programs.
{b) Agency comments and recommendations wi 11 be provided by
those members of the Mitigation Task Force that represent
agencies, while the concerns of the public and special
interest groups will be coordinated through other means.
-
CoiTITient
Gipson:
You may wi.sh to spell out how input will be obtained from the
public and how to weight the recommendations from individuals,
interest groups, and governmental agencies.
McMullen:
One of the comments at the Steering Committee meeting was that
the agency representatives in many instances cannot "officially"
represent their agency.
2.3 -Avoidance and Reduction of Impacts
(a} During the feasibility studies {prior to FERC license
submittal) and the subsequent preparation of preliminary
engineering specifications (following FERC license
submittal}, the applicant will take into consideration, and
where practical {both from the standpoint of actual
feasibility as well as cost}, incorporate recommendations to
avoid and/or reduce negative impacts on wildlife resources.
Comment
USF&WS:
The project, including mitigation found to be acceptable to the
state and federal resource agencies, should be evaluated in
regard to reasonable cost; not with and without the mitigation
plan. The total cost of mitigation then becomes part of the
total project cost.
{b) Also considered under this policy will be operation
stipulations that can be implemented to reduce negative
impacts on the wildlife resource. Recommend at ions for
operation stipulations will be prov-ided to the design
engineer during both the feasibility studies and the
preliminary engineering phase as appropriate.
Comment
USF&WS:
Construction and operating stipulations to reduce negative
impacts to fish and wildlife resources should be evaluated during
the feasibility studies. Stipulations found acceptable by the
coordinating agencies should be incorporated into the mitigation
plan submitted as part of the license application.
2;4 -Compensation for Unavoidable losses of Wildlife Resources
(a) Where biologically feasible and cost effective management
techniques are available, the applicant will institute
management efforts to compensate for unavoidable impacts.
Comment
USF&WS:
Compensation for unavoidable losses to fish aod wildlife
resources should be in accordance with a plan developed by the
applicant, in coordination with state and federal resource
agencies. The plan, found acceptable to the coordinating
agencies should be submitted to FERC for incorporation into the
project license. The compensation plan, a component of the
overall mitigation plan, should be the result of a habitat
evaluation, utilizing a procedure judged acceptable to the state
and federal agencies with primary responsibility for fish and
wildlife resources.
{b) Where possible, compensation will be of an in-kind nature.
Comment
USF&WS:
This applies to both wildlife species as well as
habitats.
In-kind compensation where "possible"; should be mutually
I determined by the applicant and the coordinating state and federal
agencies, prior to licensing.
,._
-
2.5 _ G:~g;aphic :~~verage of the Wildlife Mitigation Policy
{a) In rc;~"cd to both impact avoidance and compensation, the
mitigat~:on policy will address all wildlife species
utilizi~gg the impoundment zone and other project related
'
Comment
USF&WS:
areas (~.g., borrow sites), as well as the riparian zone
downstrram to Ta 1 keetna.
Determination of the extent of impacts attributable to the project
needs to be ac:complished. Formulation of a mitigation plan cannot
proceed until the extent of the impacts, both direct and indirect,
has been identified.
McMullen:
If key or target species are used to eva 1 uate habit at va 1 ues then
this inay requ-;-:re rewording.
Gipson:
What treatment will be given to access roads, power line rights-
of-way, and pcssible buffer zones around the impoundments?
(b) Downstream from Talkeetna to Cook Inlet the primary
mitigation effort will be directed towards any impacts that
might occur in regard to rip.arian habitats.
Comment
USF&WS:
The mitigation effort should be directed ·at reducing impacts where
they are identified, addressing all primary and secondary impact
areas, for a:ll project features.
Taber:
It seems probable that lQO% mitigation above the dam will not be
feasible, so mitigation below the dam may be one of the next best
choices. If a broad view of what "below the dam" consists of is
maintained, then more mitigation options will be available than if
the view is narrow.
2.6-Establishment of Priorities
(a) Although all wildlife species will be considered (including
big game specie5, non-game species, and furbearers), it will
be necessary to identify the "key" or "target" species and
establish some order of priority in regard to the development
of a mitigation plan.
Comment
McMullen:
If key or target species are used to evaluate habitat values then
this may require rewording.
{b) In order to prepare a mitigation plan that can be
Comment
. Gipson:
successfully implemented while at the same time placing
mitigation efforts in perspective, certain wildlife species
and/or habitats will be given priority in mitigation planning
based on: 1) importance of the species/habitat both to
Alaskan residents and the ecosystem; {2) availability of
practical mitigation measures; (3) species with special
status, such as threatened or endangered; {4) estimated costs
required to execute mitigation measures. This list of·
criteria is not organized in any priority order.
Possibly something should be added to indicate that some
ecological criteria will be used to establish priorities, in
addition to human values. For example, those species that
contribute significantly to total energy flow through the system
(small mammals and nesting birds) and/or those species that make
up the bulk of animal biomass (again small mammals) should be
considered important.
McMullen:
These criteria could be easily expanded to be uti 1 i zed in the
generation of relative value indicies.
-
USF&WS: (pertains to 2.6 in general)
Since all wildlife species are to be considered, "key" species
should be chosen so that they represent particular segments
(guilds) of the community. Species which provide guild
representation and are also con$idered "important" by the resource
agencies and/or public should be given priority. Species which
are federally listed a~ threatened or endangered, or proposed for
listing. must be handled separately in accordance with Section 7
of the Endangered Species Act. The practicality of the mitigation
plan developed, in regard to the concerns of the applicant and
coordinating agencies, would be demonstrated through its
acceptability to these agencies.
2.7 -Impact-Related Versus Non-Impact-Related Lands
(a) To the greatest extent possible, mitigation me~sures will be
implemented on or immediately adjacent to the area where the
impact takes place.
(b) Where. this is not possible, priority will be given first to
suitable areas as close as possible to the area of impact.
(c) As a last resort, areas totally removed from the impact area
will be considered for mitigation efforts.
Comment (pertains to 2.7 in general)
USF&WS:
Statements apply to both direct and indirect impacts.
Schneider:
In sections 2.7 and 2.8, you emphasize mitigation close to the
impact area even to the point of enhancement of a different
species rather than move to a more distant area. The problem is
in definition of such terms as "reasonable proximity". Users of
wi-1 dl ife are fairly mobile and tend to greatly favor one species
over another. This, combined with practical considerations, might
make it difficult to stick with the policv
1 h:·.-::=n't given this a great deal of thought, but an alternate
appr:.=..:h might be to direct mitigation measures at the animal
pop~-~ion or subpopulation impacted when this is clearly
feas -:=le.
When :=he feasibility of this approach is in doubt, perhaps
mitis~ion measures should be directed at user groups. A series
of a1-':.:rnate mitigation masures could be drawn' up and submitted
for pt~.Lbl ic review.
The j:C'int is that the public might agree with your pol icy, but
· disag:-::e with your plan when they see what it means in reality.
Why nc= recognize that the issue is complex and subjective from
the st.:J.rt?
2.8 -In-Ki~d Compensation Versus Availability of Areas Suitable For
Mitis3tion
(a) In the event that suitable areas for in-kind compensation
for a particular species/habitat do not exist within
reasonable proximity to the impact area, the first priority
will be to compensate for such loss by enhancement of a
different species and/or habitat that is close to the impact
area.
{b) If compensation by means of a different species proves
impractical or unacceptable, in-kind compensation in areas
totally removed frbm the impact area will be considered.
Comment (pertains to 2.8 in general)
Schneider:
See comment under 2.7.
2.9 -Land Ownership
(a} Interviews will be conducted with private owners as well as
pertinent state and federal agencies to preliminarily identify
land use policies or ownership that may act as constraints on
mitigation efforts.
(b) Where no land use constraints have been identified~ the
an~lysis of mitigation alternatives will proceed based on
biological factors.
(c) Following review by agencies and private landowners for·
compatibility with land use policies~ the mitigation plan will
then be reassessed and adjusted as necessary in order to
insure that proposed actions can be legally and practically
executed. Where mitigation opportunities exist~ the applicant
Will work closely with land management agencies to insure the
successful implementation of the plan.
2.10 -Restoration of Disturbed Areas
Comment
USF&WS:
The applicant will consider various options (e.g. regrading .and
revegetati6n~ permitting natural invasion and succession~ etc.)
inthe reclamation of areas that will be disturbed by project
activities such as borrow areas and construction camps.
Restoration of disturbed areas should be in accordance with a plan
developed by the applicant. in coordination with the state and
federal resource agencies. The plan, found acceptable to the
coordinating agencies should be submitted to FERC for incorporation
into the project license.
l~cKendr i ck:
I would emphasize that the revegetation, etc., of borrow areas be
coordinated with land use policies of owners. Also, considering
such areas as prospective browse production sites may be feasible,
if there is any soil available after excavation. They may be
considered potential sites to compensate for browse losses in the
impoundment areas.
Heavy grass seeding will probably retard natural succession of
browse species. We really need to examine some of the myriads of
highway and seismic disturbances to see if we can identify
successional sequences and bypasses and develop some reasonable
scheme in habitat formation for this region.
2.11~ Nuisance Animals
Comment
USF&WS:
In order to avoid altering the natural behavior of animals
resident to the project area, rules designed to prevent, or
reduce nuisance animal problems will be established. Procedures
will also be formulated to relocate problem animals.
A plan, found acceptable to the coordination agencies, should be
developed and submitted to FERC for incorporation into the project
license.
Schneider:
Relocation is generally a poor policy as animals usually return or
cause problems in other areas. Animals can be captured only under
permits issues by the Commissioner of Fish and Game. He will set
policy on this issues, not APA.
Gipson:
Other possibilities may be: 1) strict garbage control and
disposal, 2) fencing of semi-permanent camps, 3) education
programs for workers to prevent feeding and harassing wild animals
in order to reduce impacts and conflicts with people.
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2.12 -Access
(a) Since the potential impact of increased human access on
wildlife is a major concern, measures will be considered and
the most appropriate ones implemented to reduce impacts on
wildlife as a result of improved access.
(b) This will include access policies during both the
construction and operation phases of .the project.
Comment (pertains to 2.12 in general}
USF&WS:
\
A plan, found acceptable to the coordinating agencies, should be
developed and submitted to FERC for incorporation into the project
license.
2."13 -Hunting
{a) Acknowledging that sport hunting is an important component
of the Alaskan 1 ifestyle and etonomy, it will be
incoiporated as a major component in mitigation planning.
{b) Hunting rules and/or recommendations to insure the safety of
project personnel and the public will be considered.
(c) For obvious reasons, any policy determination concerning
hunting inust be integrated with access pol icy and the
applicant will consider both aci:ess and hunqng pol icy in a
coordinated manner.
Corranent (pertains to 2.13 in general}
USF&WS:
This section should be expanded to incTude other forms of wildlife
recreation as well, e.g., bird watching, photography. A plan,
found acceptable to the coordinating agencies, should be developed
and submitted to FERC for incorporation into the project license.
Gipson:
I would like for you to include trapping and fishing in this
section if you feel they are appropriate for inclusion ..
Schneider:
Reed:
Replace "sport hunting" with "hunting and trapping". Many
Alaskans would interpret your wording to exclude.subsistence
hunting. This issue is both difficult to define and highly
emotional. There is no need to raise it here. Obviously, we want
to preserve all legal hunting and trapping options.
Any hunting rules or policies other than those instituted by an
employer on their employees are the responsibility of the Board
Game. APA can make recommendations as can any group or
individual, but it is up to the Board of Game to examine all
factors and set regulations for dealing with pro~lems.
It may be that this section is not appropriate at all for
inclusion with a wildlife mitigation policy effort and may be
better suited for ·prime consideration under the recreation
planning portion of the Susitna study effort; although
coordination between recreation planners and the wildlife
mitigation group is certainly necessary.
of
2.14-Responsibility For Implementation of the Mitigation Plan
Comment
USF&WS:
(a) Prior to the initiation of construction an agreement will be
reached for determining responsibility for implementation of
the mitigation plan.
Responsibility for implementation of the mitigation plan rests
with the applicant. Any agreements entered into by the applicant
for the delegation of direct implementation authority for the
mitigation plan would need to include stipulations to prevent
deviation from the accepted plan.
i'~
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Reed:
Due to wording there is some confusion between 2.14 (a) and 2.1
(c). The intent of the wording in 2.1 (c) was to indicate that
the applicant (APA) was ultimately responsible for seeing that the
mitigation plan is executed as agreed upon. The purpose of 2.14
(c) was not to indicate that any organization other than the
applicant would have ultimate responsibility, but to indicate that
an agreement would have to be reached as to exactly who (ADF&G 7
USF&WS 7 TES, etc.)would actually execute the plan. A rewording,
or further explanation is needed to prevent;; a misunderstanding
between these two items.
(b) Realizing that a mitigation monitoring team will be
necessary to insure the proper and successful execution of
the mitigation plan, part of the plan will detail the
structure and responsibilities of such a monitoring body.
Comment
USF&WS:
The mitigation monitoring team should include representatives of
the applicant, FERC, and the state and federal agencies with
designated responsibility for fish and wildlife resources. The
financing, composition, and plan of study should be agreed to by
the prospective participants during the formulation of the
mitigation plan as a component of the mitigation plan to be
submitted to FERC for incorporation into the license.
2.15 -Modification of the Mitigation Plan
(a) As part of the mitigation plan a monitoring program will be
established, the purpose of which will be to monitor
wildlife populations during the construction and operation
of the project in order to determine the effectiveness of
the p 1 an as we 11 as to identify problems that were not
anticipated during the initial preparation of the plan.
Comment
USF&WS:
See comments above (2.14.b}.
Gipson:
This section, 2.15 (a) is good.
(b) The mitigation plan will be sufficiently flexible so that if
adequate data secured during the monitoring of wildlife
populations indicate that the mitigation effort should be
modified, the mitigation plan can be adjusted accordingly;
Comment
USF&WS:
this may involve an increased effort in some areas where the
original plan has proven ineffective, as well as a reduction in
some cases where impacts failed to materialize as predicted.
Any modification to the mitigation plan should be coordinated with, and
agreeable to, the state and federal agencies with designated
responsibility for fish and wildlife resources.
General Comments
McKendrick:
Bill Collins and I both received and read the Preliminary Outline.
Generally, it appears acceptable and comprehensive.
Wozniak:
We have no comments relative to the version of the Mitigation Policy
outline transmitted to us by Ed Reed's memo of May 8~ 1981. (Note:
The APA did review an earlier version and provided suggestions and
comments that were incorporated into this review version}.
Gipson:
This is a well written outline. You may want a section treating use of
4-wheel drive vehicles and snow machines.
USF&WS:
We appreciate the opportunity to review; the prel:~~i nary out l·frie ·
"Wildlife Mitigation: A Statement of Poli.cy". ·We have done so in
light of the Fish and Wildlife Service's Mitigation Policy (copy
attached) and have provided comments which are consistent with that
policy.
:Terrestrial
RECEIVED JUt 2 7 i93\,
~. nvironmental
~~Specialists, inc.
AI.D. t BOX :u• PHOENIX. N.Y. 1313.B (31Sit1B•7ZZI
MEMO
TO: Members of the Sus_itria Wildlife ~1itigation Task Force
FROM: Edward T. Reed, Task Force Coordinator
DATE: July 24, 1981; 218.730
.RE: Meeting notes
Enclosed please find a copy of the notes of the June 29, 1981 meeting of
the wildlife mitigation task force. I have compiled these notes based on
my interpretation of the conunents made during the meeting. If you feel
that I missed any major items or misunderstood certain statements please
let me know and I will prepare a revised version of the notes. I am now
moving forward with the preparation of a draft pol icy statement an..r-:!101:;;;;;-sK_A_P_o_w_ER----.
development of a decision making methodology. You will be receivi g AUTHOr<ITY
copies of these as they are completed. SUSITNA
Fll~.P5;2;0 1
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SUSITNA WILDLIFE MITIGATION TASK FORCE
NOTES OF MEETING ,
June 29, 1981
Anchorage, Alaska
Camp il ed by: Edward T. Reed
Wildlife Ecology Group leader
Terrestrial Environmental
·. Specialists, Inc.
The meeting was commenced at 9:00 a.m. A list of partiCipants is
attached.
Mr. Reed gave a brief introduction and description of ~at had taken
place since the last meeting. He then asked if the participants would
1 ike to make any general comments concerning the pol icy outline prior to
beginning a detailed discussion of the items contained within the
outline.
Mr. Wozniak requested that the purpose of the meeting be to move towards
a finalized statement as the next product.
Mr. Trent stated that although the policy addressed federal regulations,
there are state regulations concerning mitigation in draft form, and the·
mitigation effort should stand prepared to include the intent. and
approach presented in those state regulations. He also indicated that
the state regulations would use the five basic forms ofmitigation as
defined by NEPA, but will go further in stressing the priority of the
forms. He indicated that the new regulations would be incorporated
under Title 16 1 aw. Mr. Trent also suggested that a matrix type
approach be developed to be used in reviewing the various forms of
mitigation that might be used on the Susitna Project.
-2-
Mr. Trent said that for the purpose of developing mitigation policy it
would be advisable to involve the personnel responsible for the
fisheries mitigation effort. Mr. Schneider agreed that the policy
statements for both fish and wildlife should be basically the same. Mr.
Wozniak also indicated that this would be preferable. Mr. Wozniak then .
requested that Mr. Reed take the appropriate steps to obtain the
involvement of the fisheries group. Mr. Reed agreed to contact the
appropriate fisheries personnel and request that they accelerate the ..
establishment of a fisheries mitigation task force and be provided with
information pertaining to the policy statement currently being prepared
by the wildlife task force.
~
A discussion took place concerning the level of mitigation planning that
would be available for inclusion with the FERC license application
versus what will have to follow during Phase II. Mr. Wozniak warned
that Phase II should not serve as a convenient excuse for not having
critical portions of the application prepared for the projected
submittal date. Mr. Carson indicated that a corrunitment to the process
that would be used throughout the mitigation effort should be an
important item for the application. Since the discussion indicated that
.:~,t a minimum, it will be possible to have prepared a policy statement,
Jn approach to mitigation, and an outline of the ol~n~ Mr. Reed asked
representatives of the U.S. Fish and Wildlife Service if that level of
2ffort would satisfy their review needs as stipulated under the Fish and
Wildlife Coordination Act. Mr. Stackhouse replied that in the absence
of a complete, detailed mitigation plan, they {USF&WS) would not be able
to make a final recommendation.
Mr. Schneider suggested that the next step should be the development of
a process, or methodology, to be used in making mitigation decisions.
This suggestion was received favorably by the other participants.
In reviewing the meeting to this point, Mr. Reed and Mr. Wozniak agreed
that the next steps should be to expand the outline to a draft policy
statement, prepare a decision making methodology. and develop an outline
of the plan.
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At this point it was agreed to review the policy outline, item by item,
commenting on the information and determining which items are
appropriate for a policy statement and which items might be more
suitable for inclusion in other sections The following notes are
organized by items co.rresponding--'to-··the outlirte.
Ll -Mr. Trent indicated that there is a need to study the resources
and for the APA to commit to mitigation. ··He suggested substituting
"mitigate" for ••reduce or' avoid •11
1.2 -Mr. Trent reiterated the need to take into consideration state
~licies and regulations. Mr. Carson suggested consideration of the DNR
Instream Flow Bill and the Coastal Zone Management Group.
1.3 -Mr. Trent suggested that the remaining items discuss mitigation
collectively rather than identifying only certain forms of mitigation.
2.1
(a) -Mr. Trent said that a compromise position is needed somewhere
between the phrases "agreeable to all agencies .. and "feasible and
reasonable.•• Mr. Carson sugQested removinC! thj!:a e_hra~e "feasible and
reasonable." Mr.. Trent suggested using a phrase such as, .,to strive to
mitigate the negative impacts.•• Mr. Schneider mentioned that reality
should be kept in mind when defining the intent. ·
(b) -Mr. Wozniak indicated that there was ~o problem with this item but
felt that it should be removed from the pol icy statement and
incorporated at a diff~rent point in the mitigation plan~ Mr. Carson
agreed.
(c) -Mr. Wozniak indicated that this item would be part of the license
and indicated that an associated goal would b~ to reach an agreement
between the resource agencies and the applicant.
-4-
2.2 -Mr. Carson discussed the roles of the APA and the resource
agencies as they pertain to public input. The possibility of agency
personnel being available at public workshops to present the position of
their respective agencies was discussed. Mr. Wozniak liked the idea of
agency personnel being available during public meetings.
2.3
(a·) -Mr. Carson reiterated a previously expressed concern about the
wording of this· item. Mr. Wozniak remarked that the agencies and the •.
APA are polarized in regard to this item. Following discussion it was
agreed that what is needed is a rewording that will provide the agencies
with stronger assurances, while at the same time not totally committing
the APA.
(b) -It was agreed that this item is too specific for a policy
statement and might be more appropriately incorporated into a
"methodology" section.
2.4 -Mr. Trent suggested that the forms of mitigation be combined under
a more general category. It was agreed that this section should be
removed from the policy statement and placed elsewhere.
2.5 -Mr. Stackhouse expressed interest in how the coverage would be
defined. It was agreed that this section may also be more appropriately
covered in a subsequent portion of the mitigation ~lan.
2.6 thru 2.13 -It was agreed that these sections would also be more
appropriately addressed in other portions of the mit·igation plan.
2.14 -Mr. Wozniak indicated that the APA is in agreement with this item
and has no problem with the wording. Mr. Carson felt that 2.14(b)
should be reworded to include the word "funding" and suggested the
following wording," ••. part of the plan will detail the structures
fund~ng, and responsibilities .•• " Mr. WOzniak felt that this may be a
problem at this time and indicated that funding arrangements are an
itemthat would have to be negotiated at a later date. Mr. Wozniak also
felt that is was a good idea for the agencies to provide a commitment to
cooperate in this effort.
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2.15 -Mr. ~ozniak stated that the APA is in agreement with this item
and has no problem with the wording.
Mr. Carson expressed the opinion that the mitigation effort was going
well and he was pleased with the approach being taken so far·.
The meeting was adjourned at approximately 11:30 a.m.
PARTICIPANT
Edward Reed
Leonard Carin
Gary Stackhouse
~ David Wozniak
Brina Kessel
Thomas Trent
Joseph McMullen
Karl Schneider
Philip Gipson
Alan Carson
Robert Krogseng
Jay McKendrick
SUSITNA WILDLIFE MITIGATION TASK FORCE
MEETING OF JUNE 29. 1981
ANCHORAGE. ALASKA
LIST OF PARTICIPANTS
REPRESENTING
Terrestrial Environmental Specialists, Inc.
United States Fish and Wildlife Service
United States Fish and Wildlife Service
Alaska Power Authority
TES/University·of Alaska
A 1 ask"a Department of Fish and Game
Terrestrial Environmental Specialists, Inc.
Alaska Department of Fish and Game
TES/University of Alaska
Alaska Department of Natural Resources
Terrestrial Environmental Specialists, Inc.
TES/University of Alaska
"""' I
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UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmo_spheric Administration
NC. :i.e~'-..::.~ . .'•:.::.:·: );e F'i!3he~ies Service
October 6, 1981
Mr. Eric P. Yould
Executive Director
Alaska Power Authority
3334 West 5th Avenue
Anchorage, Alaska 99501
Dear Mr .. Yould:
F.O. E~= 1cf5
Ju.nec:.u~ .4Z.asr..:: 998C2
RECEJVEO
OCT 1 5 1981
Involvement of this agency with efforts by others to explore the .
potential for hydroelectric development on the Susitna River dates
back to 1973. In 1974, we had contracted Environaid for a study titled
"A Hydrologic Reconnaissance of the Susitna River Below De;,vi.l's Canyon",
and more recently we have been a participant on the Susitna Steering
Committee.
He appreciate the opportunity presented in your 1 etter of September 25, 1981
to extend ourparticipation by becoming a member on the Susitna Fisheries
t·litigation Task Force, Review Committee. I have directed Brad Smith of
our Environmental Assessment Division (EAD}, Anchorage Field Office to-
represent National Marine Fisheries SerVice {~MFS} on this important com-
mittee.· Mr~ Smith \oJill fully participate on the Review Committee and be
responsible for drafting the recommended NNFS' position.
Please continue to send official correspondence through our Regional
Office. Delays in NMFS response time associated w~th our routing of
your materials to and from the Anchorage EAO Field Office could be
reduced if you would provide a courtesy copy of correspondence dir-
ectly to Mr. Smith.
Should you have further questions regardi~g Mr. Smith•s involvement,
please contact Ron Morris, the supervisor of the Anchorage EAD Field Office:
Sincerely,
Bradley K. Smith and Ronald J. Morris
National Marine Fisheries Service
Federal Building & U.S. Court House
701 C Street, Box 43
Anchorage, Alaska 99513
Phone: {907) 271-5006
\dh0~V1-C~~ -d't '\ ', (1Robert W. tkVey
Director, Alaska Region
RECEIVED g Ci 11981
ALASKA POWER AUTHORITY
334 WEST 5th AVENUE· ANCHORAGE, ALASKA 99501
Mr. Robert McVey
Director, Alaska Region
Alaska Marine Fisheries Service
P.O. Box 1668
Juneau, Alaska 99802
Dear Mr. McVey:
September 25, 1981
Phone: (907) 277-7641
(907) 277-0851
(907) 276-000 1
Integral to our study of the potential effects of hydroelectric
development of the Upper S~sitna River Basin is the formulation of
fisheries mitigation plans. To that goal, a Fisheries Mitigation Task
Force, in two parts, is being formed. One part will be a core group of
the principal investigators. Their task will be to identify and address
impacts, and develop appropriate mitigation plans. A second group will
act as a review committee commenting on the efforts of the core group.
You are invited to be a member of the Review Committee. If you
agree, your role would be to work in concert with other concerned agencies
to assess the adequacy of the impact predicitons and associated mitigati'.te--......... -
planning. In addition to reaping the benefits of your expertise, your Att~~~oi?-'1'r"-R
participation would also fulfill key consultation requirements outlined SUSITNA
in the Federal Energy Regulatory CommiSsion (FERC) regulations and in
the provision of the Fish and Wildlife Coordination Act. FILE P5700
A similar structure was established early this year for wildlife
mitigation. An early objective will be to reorganize into one common
review committee for mitigation, overviewing separate core groups for
fisheries and wildlife. You might consider this when you appoint your
organizational representative.
We welcome your participation in this key planning area, and we
hope to hear from you soon with the names and telephone numbers of your
designated representation.
cc~ John Lawrence
Jim Gill
Sincerely,
~c~~Jj
Executive Director
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DEPARTMENT OF THE ARMY
ALASKA DISTRICT. CORPS OF ENGINEERS
P.O. eox 7002
REPLY TO
ATTENTION OL
NPAEN-PL-EN
Mr. Eric P. Yould
Executive Director
Alaska Power Authority
334 West 5th Avenue
Anchorage. Alaska 99501
Dear Mr -You 1 d:
ANCHORAGE. ALASKA 99510
oc120 1981
t30CT1981
This is in response to your letter of 25 September 1981 concerning Corps of
Engineers participation in the Upper Susitna River Basin Fisheries Mitigation
Review Committee.
Unfortunately, the continued funding and manpower constraints under which we
must operate make it necessary for me to de«:line your invitation. However, we
will provide the reviews required for the issuance of permits .under our
regulatory program.
If I can be of further assistance, please contact me directly. If further
details are desired by your staff, contact can be made with Mr. Harlan Moore,
Chief, Engineering Division at 752-5135 •
LEE R. NUNN
Colonel, Corps of Engineers
District Engineer
··----------------------------------........!
DEPART,U::\:T OF FISII .-\.,() G..\..UE
OFFICE OF THE COMMISSIONER
October 23, 1981
Mr. Eric P. Yould
Alaska Power Authority
334 West 5th Avenue
Anchorage, Alaska 99501
Dear Mr. Yould:
~
I
JA I' S. HAMMOND, GOVERNOR
SUBPORT BUILDING
JUNEAU, ALASKA 99801
Thank you for your invitation to place a member of my staff on the
committee being established to review mitigatory recommendations for the
Susitna Hydroelectric project. I have designated Mr. Carl Yanagawa,
Regional Supervisor for the Habitat Division, to sit as our represent-
ative on the review committee.
I anticipate that Mr. Yanagawa will work closely with the other members
of the committee, and with Tom Trent and Karl Schneider, to develop
sound policy recommendations for Su-Hydro.
Nr. Yanagawa's office is in the Fish and Game building at 333 Raspberry
Road and he can be reached at 267-2138.
Sincerely,
Q
1 Ronald 0. Skoog
--+6\.. Commissioner
J . -(907) 465-4100
11-K11LH
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U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION X
REPLY TO /S. 44J ATTN OF: M
·. . : v •. .
12~0 SIXTH AVENUE
SEATTLE, WASHINGTON 98101
Eric P. Yould~ Executive Director
Alaska Power Authority
534 West 5th Avenue
Anchorage, Alaska 99501
DearMr~~
i1ECEIVEo
OC} ~ _ .
Al.ASK!, pnwr:r> _ ~·~en AP"I""I'7 ~ '• Ll 1 )'
RECEIVED
OCT 3 n 1531
AU\SKA POWER AUTHORITY
The Environmental Protection Agency {EPA) accepts your invitation to
participate on the Review Committee for the Fisheries Mitigation Task
Force on the hydroelectric development of the Upper Susitna River Basin.
-EPA generally relies on the state and Federal fish and wildlife agencies
for the technical input and evaluation on such task forces. However, I
feel that we may be able to provide as a member of the Review Committee •
a different perspective which may help your efforts. Because of our
limited resources both in staff and travel money, our participation will
have to be somewhat limited.
I have designated Ms. Judi Schwarz as our .formal contact for the activi-
ties of this Review Colllllittee. Ms. Schwarz is in the Environmental
Evaluation Branch in our Seattle Office and has had primary contact with
the Susitna project through our EIS review responsibilities. She can be
reached at (206} 442-1285. I have also asked Jim Sweeney, Director of
our Alaska Operations Office to provide support in this effort because of
his proximity and knowledge of the unique Alaska conditions. His tele-
phone number in Anchorage is {907) 271-5083.
We look forward to actively participating on this Review Corrrnittee. Any
infonnation you can send us on the act ivifies of the wild1 ife mitigation
task force would be appreciated.
Thank you for giving us the opportunity to become actively involved in
this important development.
cc: Jim S\'Jeeney
10-J91..H
UEI•AUT~IENT ot· l\'.'\TUR.i\1. IU•:SUUilCt:S
OFFICE OF THE COMMISSIONER
December 1, 1981
Mr. Eric Yould
Executive Director
Alaska Power Authority
334 West 5th Avenue
Anchorage, AK 99501
Dear Eric:
JAYS. HAMMOND, &OVERIIOR
POUCHM
JUNEAU. ALASKA 99811
PHONE: (907) 465-2400
This letter is in response to your September 28, 1981 letter
offering an opportunity for DNR participation on the mitigation
review committee for the proposed Susitna Hydroelectric
Project.
Al Carson of the Division of Research and Development will
be our representative for the committee. He can be reached
by phone at 276-2653. '
Thanks for providing us with the opportunity to participate
in this important endeavor.
Sincerely,
~.
Commissioner
cc:· Reed Stoops
-ALASiiA POlfER AUTHORITY
334 WEST 5th AVENUE-ANCHORAGE, ALASKA 99501 Phone: (907) 277-764
(907) 276-0001
RECEIVED
DEC 14 1981 December 9, 1981
,_ ACkt~ nanuuliM lnliultrUKATID
ALASKA '"POWER. -AUTHORITY
SUSrTNA
!5r~l a: ;;_ .t=l2· 1-;:::
! tJ I '7' I o:n -l c(r-. o ::!:
--~ I uCW
-,~-j ,-rc :~ ~~
i c-l_j-10~1 ,_l_z:~~ I
j_ __ j~~~
!I PG HI
' -:t~.eyl_ J-mm
Mr. Keith Schreiner
Regional Director, Region 7
U.S. Fish & Wildlife Service
1011 E. Tudor Road
Anchorage, Alaska 99503
Dear Mr. Schreiner:
A member of your staff advises me you did not receive
my letter of September 25, 1981 1 inviting your participation
to the Susitna Hydroelectric Project mitigation Review
Group. Let me hasten to repeat the invitation.
Integral to our study of the potential effects of
hydroelectric development of the Upper Susitna River Basin
is the formulation of fisheries mitigation plans. To that
goal, a Fisheries Mitigation Task Force, in two parts, is
being formed. One part will be a core group of the
principal investigators. Their task will be to identify and
address impacts 1 and develop appropriate mitigation plans.
A Second group will act as a review committee commenting on
the efforts of the core group.
You are invited to be a member of the Review Committee.
If you agree, your role would be to work in concert with
other concerned agencies to assess the adequacy of the
impact predictions and associated mitigative planning. In
addition to reaping the benefits of your expertise, your
participation would also fulfill key consultation
requirements outlined in the Federal Energy Regulatory
Commission {FERC) regulations and in the provisions of the
Fish and Wildlife Coordination Act.
A similar structure was established early this year for
wildlife mitigation. An early objective will be to
reorganize into one common review committee for mitigation,
overviewing separate core groups for fisheries and wiJdlife.
You might consider this when you appoint your organizational
representative.
Mr. Ernest W. Mueller
Commissioner
November 19, 1981
P5700.11.92
Alaska Department of Environmental Conservation
Juneau, Alaska 99801
Susitna Hydroelectric Project
Fish and Wildlife Mitigation Policy
Uear Mr. Mueller:
As you know, Acres Jlrnerican, Incorporated is under contract to the Alaska
Po~ Authority (APA) to conduct a feasibility study and prepare a Federal
Energy Regulatory Commission (FERC) license application for the Susitna
Hydroelectric Project. The scheduled date for submission of the application
is in June of 1982.
· Federa1 law and FERC regulations require that the reports supporting the
FERC application be prepared in consultation with Federal and State agen-
cies having managerial authority over certain project aspects. This coor-
dination must be documented in the license application.
A great aeal of coordination has taken place at agency staff levels by dir-
ect participation in studies or by participation in committees and task
groups. This input, however, has been primarily by staff and may not nec-
essarily reflect the views of the agency. For this reason, we are conduct-
ing a parallel formal coordination process, by requesting agency comments
on key study outputs. The plan of study was the first document coordinated
in this manner. Over the next year. there will be several more. This par-
allel process will affect the other coordination activities of the study.
At this time, we request that the Alaska Department of Environmental
Conservation review the attached Fish and Wildlife Mitigation Policy, which
has been developed by APA, the resource agencies and Terrestrial
Environmental Specialists.
ACRES AMERICAN INCORPORATED
·':. _. · .~~:~·:; E-;; ~e:e:rs
-
-
·-
Fish and Wildlife Mitigation Policy
Page 2
November 19, 1981
Your prompt attention to this matter will enable us to continue planning
the best possible development for all interests. A response within thirty
days of receipts would be greatly appreciated. Please send a copy of your
comments to me and to:
Mr. Eric You1d, Executive Director
Alaska Power Authority
JOL/ MMG: j gk
En c.
333 West 4th Avenue
Anchorage, Alaska 99501
cc: Bob Martin
{letter only)
ACRES AMERICAN INCORPORATED
Very truly yours,
jk-4.._ J>, /..," ~ I..M ~
John 0. Lawrence
Project Manager
Mr. Robert McVey
Director~ Alaska Region
National Marine Fisheries
NOAA
P .0. Box 1668
Juneau~ Alaska 99802
Dear Mr. McVey:
Service
November 19t 19~1
P5700.11.91
Susitna Hydroelectric Project
Fish and Wildlife Mitigation Policy
As you know, Acres American, Incorporated is under contract to the Alaska
Power Authority (APA) to conduct a feasibility study and prepare a Federal
Energy Regulatory CoiMJission (FERC) license application for the Susitna
Hydroelectric Project. The scheduled date for submission of the application
is in June of 1982.
Federal law and FERC regulations require that the reports supporting the
FERC application be prepared in consultation with Federal and State agen-
cies having managerial authority over certain project aspects. This coor-
dination must be documented in the license application.
A great deal of coordination has taken place at agency staff levels by dir-
ect participation in studies or by participation in committees and task
groups. This input, however~ has been primarily by staff and may not nec-
essarily reflect the views of the agency. For this reason, we are conduct-
ing a parallel formal coordination process, by requesting agency comments
on key study outputs. The plan of study was the first document coordinated
in this manner. Over the next year~ there will be several more. This par-
allel process will affect the other coordination activities of the study.
At this time, we request that the National Marine Fisheries Service review
the attached Fish and Wildlife Mitigation Policy, which has been developed
by APA, the resource agencies and Terrestrial Environmental Specialists.
ACRES AMER1CAN tNCORPORATED
.~
-
-
.~
-
Fish and Wildlife Mitigation Policy
Page 2
November 19, 1981
Your prompt attention to this matter will enable us to continue planning
the best possible development for all interests. A response within thirty
days of receipts would be greatly appreciated. Please send a copy of your
comments to me and to:
Mr. Eric Yould, Executive Director
Alaska Power Authority
.. lDL/Mr-tG: j gk
Enc.
333 West 4th Avenue
Anchorage, Alaska 99501
cc: Ron Morris
(letter only)
ACRES AMERICAN INCORPORATED
Very truly yours,
~ J),L-.,~/A-~
John D. Lawrence
Project Manager
Mr. Keith Schreiner
Regional Director, Region 7
U.S. Fish and Wildlife Service
lOll E. Tudor Road
Anchorage, Alaska 99503
Dear Mr. Schreiner:
November 19, 1981
P5700 • .11.91
Susitna Hydroelectric Project
Fish and Wildlife Mitigation Policy
As~ know, Acres American, Incorporated is under contract to the Alaska
Power Authority (APA) to conduct a feasibility study and prepare a Federal
Energy Regulatory Commission (FERC) license application for the Susitna
Hydroelectric Project. The scheduled date for submission of the application
is in June of 1982.
Federal law and FERC regulations require that the reports supporting the
FEI<C application be prepared in consultation with Federal and State agen-
cies having managerial authority over certain project aspects. This coor-
dination must be documented in the license application.
A great deal qf coordination has taken place at agency staff levels by dir-
ect participation in studies or by participation in corrmittees and task
groups. This input, however, has been primarily by staff and may not nec-
essarily reflect the views of the agency. For this reason, we are conduct-
ing a parallel formal coordination process, by requesting agency comments
on key study outputs. The plan of study was the first document coordinated
in this manner. Over the next year, there will be several more. This par-
allel process will affect the other coordination activities of the study.
At this time, we request that the U.S. Fish and wildlife Service review the
attached Fish and Wildlife Mitigation Policy, which has been developed by
APA, the resource agencies and Terrestrial Environmental Specialists.
ACRES AMERICAN INCORPORATED
Orr.(·' Cl''.c(::: Cc.'~-~:a t.~:J F.1!~t..:!g., PA =ate•;~ :;: ;;;::.:·. · s~o., OC
---------------------------------------
-
-
-
-
Fish and Wildlife Mitigation Policy
Page 2
November 19, 1981
Your prompt attention to this matter will enable us to continue planning
the best possible development for all interests. A response within thirty
. days of receipts would be greatly appreciated. Please send a copy of your
comments to me and to:
. JOL/MMG: j gk
Enc. ·
Mr. Eric Yould~ Executive Director
Alaska Power Authority
333 West 4th Avenue.
Anchorage, Alaska 99501
Very truly yours,
John D. lawrence
Project Manager
ACRES AMERICAN INCORPORATED
l.,r. Rona 1 d Skoog
Corrmissioner
November 19, 1981
P5700.11.92
State of Alaska Department
Juneau, Alaska 99801
of Fish and Game
Susitna Hydroelectric Project
fish and Wildlife Mitigation Policy
Dear Mr. Skoog:
As you know, Acres American, Incorporated is under contract to the Alaska
Power Authority (APA) to conduct a feasibility study and prepare a Federal
Energy Regulatory Commission (FERC) license application for the Susitna
Hydroelectric Project. The scheduled date for submission of the application
is in June of 1982.
Federal law and FERC regulations require that the reports supporting the
FERC application be prepared in consultation with Federal and State agen-
cies having managerial authority over certain project aspects. This coor-
dination must be documented in the 1 icense application.
A great deal of coordination has t • ..::en place at agency staff levels by dir-
ect participation in studies or by participation i,n committees and task
groups. This input, however, has been primarily by staff and may not nec-
essarily reflect the views of the agency.· For this reason, we are conduct-
ing a parallel formal coordination process, by requesting agency comments
on key study outputs. The plan of study was the first document coordinated
in this manner. Over the next year, there will be several more. This par-
allel process will affect the other coordination activities of the study.
At this time, we request that the State of Alaska Department of Fish and
Game review the attached Fish and Wildlife Mitigation Policy, which has been
developed by APA, the resource agencies and Terrestrial Environmental
Specialists.
ACRES AMERICAN INCORPORATED
c..:·,.·-:··:~.:~ r.-.· -· ~ ....... .:..-··--.:·~ ... r;.. ::-c•;..: ; ... _,~:::. '.".'G!.'1 .-;~:.-. uc
-
-
Fish and Wildlife Mitigation Policy
Page 2.
November 19, 1981
Your prompt attention to this matter will enable us to continue planning
the best possible development for all interests. A response within thirty
days of receipts would be greatly appreciated. Please send a copy of your
comments to me and to:
Mr. Eric Yould, Executive Director
Alaska Power Authority
JDL/MMG:jgk
En c.
333 West 4th Avenue
Anchorage, Alaska 99501
cc: Tom Trent
{letter only)
ACRES AMERICAN INCORPORATED
Very truly yours,
~ .JJ. !, .. ~ /_.Af&
John D. Lawrence
Project Manager
DEP.-\RT :'tU·::\T Of' 1-'ISII :\ :\U G.\ llf:
December 30, 1981
Mr. John D. Lawrence
Project Manager
Acres American, Inc.
OFFICE OF THE COMMISSIONER
The Liberty Bank Building, Main at Court
Buffalo, New York 14202
Dear Mr. Lawrence:
The fuska Department of Fish and Game has reviewed the 11 Susitna Hydroelectric
Project Fish and Wildlife Mitigation Polic/1 dated November 1981 and has several --
comments to offer. The Department is drafting a mitigation policy approval we
-__ _ ____ irr gnd to use for a 11 hydroelectric projects throughout the State. We
A~sK~ Poa~pre'~iate your effort but feel our parallel effort is the alternative we select
' AurHc_::1tb ta e. In the interim, however, I have provided comments to your document
SUSI __ !.Jifia.t.... an be used to improve your policy as drafted.
FILE P57~Q I
_ ~..Si~;!F; c Comments
\ ·~ZCQ\_jj;[._;('::= fj(J i tt-:'-~.1-;::;t~~~Section 1 -Introduction
\;0 1~!,! (i i ~· ~n this section which reads as follows, we recommend inclusion of the
:: !(.,i ;·: :;: underlined phrase. b t ]'. '! ' -; l ·~ ~~; :~.--~·-;.-;~j'A mandate of the Alaska Power Authority (APA) charter is to develop
_i_..:_-_-· :_-~upplies of electrical energy to meet the present and future needs of the
I _:~:_!J_Jitate of Alaska. APA also recognizes the value of our natural resources
, ---. ~ _ ~nd accepts the responsibility of insuring that the development of any new
-~---0--projects is ~s compatible a~ possible with the fish and wildlife resources
~-~.·-~-h ud he hab1tat that susta1ns them) of the State and that the overall
-1-J'~;..:'·'"'"~;t cts of any such projects wi11 be beneficial to the State as a whole.
~~'--; _ --!In this regard APA has prepared a Fisheries and Wildlife ~1itigation Policy
--.. for the Susitna Hydroelectric Project as contained herein."
-~-i-~·-, Comment: The primary goal of mitigation is to avoid, m1n1m1Ze, rectify,
-~-;-~ .-;---;reduce or compensate for impacts on fish and wildlife habitats.
-,-. ' I
-1--2.----Section 2-Legal f1andates ' . =!·:~In thi~ section v1hich reads as fo11ows, we suggest inclusion of the -~=:-:~,>~· __ t:J~~lned phrase:
-_ i=L_ . . -_ ~ I I' ~ tr
_j_! __ --!i
-J _./, FILE I
-
-
Mr. John D. Lawrence -2-December 30, 1981
.,There are numerous state arid federal laws and regulations that
specifically require mitigation planning. The mitigation policy and plans
contained within this document are designed to comply with the collective
and specific intent of these legal mandates. Following are the major laws
or regulations that require the consideration (and eventual implementation)
of mitigation efforts."
Corrment: Consideration of mitigation is not an end in itself, the
implementation of mitigation is the eventual goal and obligation which the
APA must meet under the terms of State and Federal law and regulation.
3. Section 2 -Protection of Fish and Game
4.
5.
In the first paragraph, first sentence, that reads as follows, we suggest
the underlined phrase be inserted:
The Alaska state laws pertaining to the disturbance of streams important to
anadromous fish address the need to reduce (or preveht) impacts on fish and
game that may result from such action.
Comment: Avoidance as well as minimization of impacts is also of concern
to ADF&G.
Section 2 -Federal Energy Regulatory Commission, 2nd paragraph
We suggest the paragraph include a statement which indicates measures of
mitigation as well as facilities for mitigation be described~ To describe
only facilities suggests that only engineering solutions for mitigation are
considered. It will be necessary to describe any measures for mitigation
that may involve, for example, in-kind replacement of habitat or avoidance
of impact alternatives.
Comment:·· For this statement to be an accurate portrayal of FERC
regulation, this addition is suggested.
Section -3.3 Implementation of the Mitigation Plan
In the first paragraph of this section, it is stated that, 11 Prior to
implementing the plan; an agreement will be reached as to the most
efficient manner in which to execute the plan ...
Comment: It should be stated with v1hom this agreement is to be reached.
Perhaps suggestions can be \'Jorked out vdtl't the Su Hydro Steering Cor.~mittee.
Also it is stated in the second paragraph of this section, 11 Realizing that
a mitigation monitoring team will be necessary to insure the proper and
~uccessful execution of the mitigation plan, part of the plan will detail
the structure and res pons ibi7 iti es of such a monitoring body."
Corrment: APA should be avmre that this monitoring body or its functions
will not supersede individual. agency mandates.
Mr. John D. Lawrence -3-December 30, 1981
6. Section 3.4 Modification of the Mitigation Plan
In the second paragraph of this section which reads as follows, we suggest
the insertion of the underlined phrases:
11 The mitigation plan will be sufficiently flexible so that if data secured
during the monitoring of fish and wildlife populations and habitats
indicate that the mitigation effort should be modified, the mitigation plan
can be adjusted accordingly. This may involve an increased effort where r
impacts failed to materialize as predicted. ·Any·modifications to the
mitigation plan proposed by the monitoring team will not be implemented
without consultation (and approval of) appropriate state and federal
agencies and approval of APA. The need for continuing this monitoring will
be reviewed periodically. The monitoring program will be terminated when
the need for further mitigation is considered unnecessary ...
Comment: APA approval alone does not supersede the mandates of state and
federal agencies to assure that mitigation to be performed is prudent and
feasible and in concert with what is known about project impacts.
7. Section 4 -Approach to Developing the Fish and Wildlife Plans
The third paragraph of this section reads as follows:
11 Following the identification of impact issues, the Core Group will agree
upon a logical order of priority for addressing the impact issues. This
will include ranking res~urces in order of their importance. The ranking
will take into consideration a variety of factors such as ecological value,
consumptive value, and nonconsumptive value. Other factors may be
considered in the ranking if deemed necessary. The impact issues will also
be considered in regard to the confidence associated with the impact
prediction. In other words, those resources that will most certainly be
impacted wjll be given priority over impact issues where there is less
confidence in the impacts actua1ly occurring. The result of this dual
prioritization will be the application of mitigation planning efforts in a
logical and effective manner. The results of the prioritization process
will be sent to approp~iate state and federal resource agencies for review
and comment ...
Comment: The Department of Fish and Game does not consider what appears to
be a subjective r'anking of resources in their 11 order of importance11 to be a
satisfactor·y approach to addressing impact issues. There is no substitute
for a factual assessment of data voids, studies to fi11 these voids, and a
rational approach to impact assessment based on factual evidence. Ranking
as suggested here only supports this Department's long-time conviction that
adequate information to make reasonable impact analysis and mitigation plan
development cannot be done in the time frame established for the FERC
lice·nse application by the Legislature and APA.
The fifth paragraph of this section states:
-
-
-
Mr. John D. Lawrence -4-December 30, 1981
11 Mitigation for each impact issue will be considered according to the types
and sequence identified by the CEQ (Figure 2). If a proposed form of
mitigation is technically infeasible, only ~artially effective, or in
conflict with other project objectives, the evaluation will proceed to the
next form. All options considered will be evaluated and documented. The
result of this process will be an identification and evaluation of feasible
mitigation options for each impact issue and a description of residual
impacts."
CoJTJTient: The statement in the second sentence of this paragraph, "or in
conflict with other project objectives, .. indicates equal consideration of
fish and wildlife values would not be given in the mitigation planning
effort conducted by Acres American, Terrestrial Environmental Services and
APA. It is doubtful that any fish and wildlife impact issue would not be
in conflict with APA' s primary objecti.ve to construct the Su Hydro Project,
and automatically mitigation alternatives would generally fall into the
compensatory realm of mitigation defined in Section 3.5. This Department
will closely examine the products of the impact evaluation and mitigation
planning effort to be sure equal consideration is given to fish and
wildlife resource values and that surrmary and arbitrary dismissal of
fe.asible mitigation alternatives which may be in conflict with "project
objectives .. is not the primary factor in arriving at a mitigation plan.
·Paragraph 7 of this section states:
11 Additional items that may be addressed by the Core Group include an
identification of organizations qualified to execute the mitigation plan
and recommendations concerning the staffing, funding and responsibilities
of the mitigation monitoring team."
Comment: The Core Group may make its recommendations, but agencies such as
this Depq,rtment with a direct responsibility for the management of fish and
wildlife resources will in accord with its resource management and
protection responsibilities, make its own recommendations to define
staffing or funding levels and responsibilities for the mitigation
monitoring team. It is our view that APA and its subcontractors do not
have oversight on mitigation alternatives or means of implementation.
Mitigation and the final approval of its acceptability lies with this
Department and other resource agencies with similar mandates. It will be
the obligation of APA to implement mitigation plans in accord with the
approval of these agencies. In addition, it appears that the 11 mitigation
review group 11 is responsible for 11 informal agency review and comrnent 11 on
the proposed mitigation options. This informal review is 41 considered by
APA and the Core Group prior to the preparation of ••. mitigation plans."
However, the option being reviewed (informally) by the mitigation review
group are those developed by the Core group in Step 2. · This needs to be
clarified.
In paragraph 8 of this section it states:
Mr. John D. Lawrence -5-December 30, 1981
"During the implementation of the plan, which will include both the
construction and operation phases of the project until further mitigation
is deemed unnecessary, the mitigation monitoring team will review the work
and evaluate the effectiveness of the plan {Step 5). To accomplish this
goal, the monitoring team will have the responsibility of assuring that the
agreed upon plan is properly executed by the designated organizations. The
team will be provided with the results of ongoing monitoring efforts. This
will enable the team to determine in which cases the mitigation plan is
effective, where it has proven to be less than effective, and also in which
cases the predicted impact did not materialize and the proposed mitigation
efforts are unnecessary. The monitoring team will submit regularly
scheduled reports concerning the mitigation effort, and where appropriate,
propose modifications to the plan."
Comment: It should be resolved now as to who pays for the participation by
agencies in the mitigation monitoring team. The APA should state its
commitment to funding participation by agency team members or mitigation
study groups.
General Comments
1. This Department does not believe adequate opportunity will be afforded the
natural resource agencies to evaluate or review mitigation plans due to the
accelerated nature of APA's schedule.
To date, for example, the Fisheries Mitigation Task Force Review Group has
not been afforded an opportunity to assess ongoing impact assessment and
mitigation plans being developed by Terrestrial Environmental Services.
Also, the Department has relayed to the APA on numerous occasions our
concern that a more extended period of fisheries studies needs to be
performed before adequate impact analysis is made and thence feasible
mitigation alternatives developed.
2. A section outlining the membership and relationships of the Mitigation Task
Force, and Core Group will need to be included.
I am interested in obtaining a copy of a plan that clearly sets out the
schedules for formal review of specific products by appropriate agencies in
order that this Department can adequately respond in a timely and responsible
manner to APA.
If you have questions, please do not hesitate to contact us.
Sincerely,
.~o. Skoog
1
. . mm1 ss1oner
-
-
-
-
WILLETT
WITTE
BEARY
"' 1:: y ......... 1--,.~ ....
... HAYDEN ""'rrm "'~"
LAMB 1'1as
Ronald 0. Skoog
issfoner
February 23. 1982
P5700 .. 11.92
T.1527
o:.. LAWRENCE p .0.
ka Department of Fish and Game
Box 3-2000
1\(
ri..
~-
SINCLAIR
VANDER BURGH" ~ne au,.Alaska 99802
v
;'{ "'"'" v'T r:.ar Susitna Hydroelectric Project
Con111ents on Fish and Wtld11fe
1-"--~
CARLSON
FRETZ
JEX
LOWREY
SINGH
JSTEAD
BOVE
CHASE
r-2ftfaatfon Pol fey .
Lr<-ar Hr. Skoog:
!.o a ppreciate receiving your corrments on the 11 Susitna Hydroelectric
ect Fish and W11d1ife r.11tigation Policy•• dated December 30, 1981.
ddition to addressing your conments in our revised edition of the
-cy, I have elected to respond directly to the concerns you have
ed. My comnents are organized in the order presented in your
mber 30 letter.
.-raj
l n a
.. ili I" , Qis
r ece
.
rur
::: ust
· habi
Section ·1 -Introduction
definition of fish and wildlife resources included-the habitat which
afns them but for clarification we will include the phrase "and the
tat that sustains them" as you recommended.
Cor.ment: We accept the CEQ definition and priority sequence for
mitigation.
2. Section 2 -legal Handates
We accept that the implementation of mitigation is the eventual goal
and will include the phrase 11 and eventual implementation" as you recor:tncnded.
Conment: · APA fs conmitted to implement appropriate mitigation plans.
· 3. Section 2 -Protection· of Fish and Game
To broaden the perspective of the first sentence in the first paragraph
we tt111 substitute the word mitigate for reduce. The definition of
mitigate fn this context being avoid, minimize, rectify, reduce or
Mr. Ronald 0. Skoog
compensate ror impacts.
February 23, 1982
page 2
Comment: Avoidance of impacts will be the first mitigation option explored.
4. Section 2 -Federal Energy Regulatory Commission, 2nd paragraph
We will add the phrase "measures and" in the last line of this paragraph.
Comment: This addition meets your request.
5. Section 3.3 -Implementation of the Mitigation Plan
It is our intent to reach an agreement, through FERC, with those resource
agencies having the mandate to approve the mitigation plan and the implementation
specific agencies have not been stated since it is not considered appropriate
for APA to define other agencies mandates.-It is also considered inappropriate
to discuss such agreements through an informal group such as the Susitna
Hydro Steering Committee.
Comment: APA accepts that the proposed monitory body or its function would
not supersede individual agency mandate. In fact such._ monitoring
may be conducted through agencies fulfilling their mandates. ·
6. Section 3.4 -Modification of th~ Mitigation Plan
APA intends to work with the appropriate state and federal agencies during
implementation of. the plan, including any modifications. The Federal
Energy Regulatory Commission must approve any modification to mitigation
stipulation in the license. It is anticipated FERC would not approve these
modifications without first consulti_ng with the appropriate agencies.·
Comment: It was not intended to imply APA approva 1 superseded the mandate
of state and federal agencies.
7. Section 4 -Approach to Developing Fish and Wildlife Plans
Third paragraph:
The intent of the ranking of resources is "order of importance was to
direct mitigation efforts towards those resources where, even without an ·
extensive data base, it is predicted the greatest impacts would occur.
As an example, the concentration of the fisheries mitigation efforts
has been towards the anadromous fisheries between Ta 1 keetna and Devil
Canyon, as this is an important reserve and there is higher potential for
impact in this section than further downstream.
ACRES AMERICAN INCORPORATED
~~ ---.-----·-· .----·-. --------·--·---· -------·--
-
-
-
Mr. Ronald 0. Skoog February 23, 1982
page 3
Comment: The delay in the license application will permit a more detailed
mitigation plan to be developed.
fifth paragraph:
Comment: The intent of this procedure is to consider each impact issue
and to review all practicable mitigation options within the
intent of the National Environmental Policy Act. If a mitigation
option that avoids an impact is identified which is technically
feasible, effective and not in conflict with any other project
objective, the need to address other alternatives was not
considered necessary. The intent of sentence.2, paragraph 5
was to state that if such an option does not exist, we will pro-
ceed to evaluate other options. ·
No mitigation options will be arbitrarily dismissed. As stated
in the po 1 icy, "ALL options wi 11 be eva 1 ua ted and documented. 11
The policy will be revised to make this clear.
Paragraph Seven:
Comment: FERC requires APA to prepare a mitigation plan prepared in
consultation with appropriate resource agencies. This plan
will be based on_recormnendations from the core groups and
review and comment from the agencies via the fish and Wildlife
Mitigation Review Group and the formal agency review process ..
Subsequent to the FERC filing, the plans will be reviewed by
fERC and other agencies and an acceptable plan finalized. It
is not APA 1 s intent that the mitigation planning be in conflict
in any way with the management and protection responsibility
of any agencies. ·
Paragraph Eight:
Comment: The Susitna project is being prepared by a state agency. As
such, it would be premature to commit funding for involvement
of other agencies at this time. ·
General Comments
1. The three month delay in the license application will permit agency
review and input to the mitigation plan.
2. The Policy will be revised to include a description of purpose of
the core and review groups. You w.ill be receiving a letter with
the Feasibility Report outlining what reports will be sent to your
department.
ACRES AMERICAN INCORPORATED
Mr. Ronald 0. Skoog February 23, 1982
page 4
We very much appreciate your comments on the policy and hope my responses
are satisfactory. If you have any questions, please call.
MMG/jh
ACRES AMERICAN INCORPORATED
~Efely yours,
4::(?~~~
(., 'Jo'hn D. lawrence
Project Manager
-
United States Department ofthe Interior RECEIVED -
· ,N REPLY REFER TO:
FISH AND WILDLIFE SERVICE
JOJ I E. TUDOR RD_
ANCHORAGE, ALASKA 99503
(907) 276-3800
JAN 12 1982
-
.WAES
Hr. Eric Yould
Executive Director
Alaska Power Authority
333 Y. 4th Avenue
Anchorage, Alaska 99501
Dear Mr. Yould:
3 0 DEC 1981
This lett~r responds to a request by John Lawrence of Acres American that the
Fish and tYildlife Service (FWS) review the Fish and Wildlife Mitigation Policy
for the Susitna Hydroelectric Feasibility Study. The request was made by
letter dated November 19, 1981. Our review of the Alaska Power Authority's
(APA) Policy Statement has been undertaken in light of the FWS Mitigation
Policy (Federal Register Vol. 46, No. 15, January 23, 1981). We have enclosed
a copy of our Mitigation Policy and havepreviously transfer~ed a copyto your
subcontractor, Terrestrial Enviromental Specialists, Inc. (see enclosed letter
~ dated 4 June 1981). By maximizing consistency between the two policy
----~tatements, avoidance of policy disagreements between the APA and the Fl~S can
LU<. '" POW£R e accomplished. Long-term benefits would accrue throughout the process
AUTHORITY s.11 ~ · ITNA "ncluding when and if project mitigation monitoring is in place and modifica-
-=--:::: ions to ongoing mitigation c:Juld be evaluated under one policy.
=u:
-:--=======:J riefly, the Service's mitigation policy reflects the goal that the most
important fish and wildlife resources should receive the greatest level of
i tigation when the environment of a particular area is changed. the no~s
..... ~~.....jlnolicy divides the mitigation planning process into three components: (1)
resource category determinations; (2) impact assessment; and (3) mitigation
recommendations. By creating four resource categories, the FWS can vary the
degree of mitigation it recommends according to the value and scarcity of the
habitat at risk.
Our resource category, ·· ••• determinations will contain a technical rationale
consistent with the designation criteria. The rationale will: (1) outline
the reasons why the evaluation species were selected; (2) discuss the value of
the habitats to the evaluation species; and (3) discuss and contrast the
relative scarcity of the fish and wildlife resource on a national and
~---1ecoregion section basis.·· (F.R. Vol. 46, No. 15, p. 7658). Special con-
sideration would be given to notable, •· ••• aquatic and terrestrial sites
including legally designated or set-aside areas such as sanctuaries, fish and
wildlife management areas, hatcheries, and refuges, and other aquatic sites
such as floodplains, wetlands, mudflats, vegetated shallows, coral reefs,
riffles and pools, and springs and seeps. (F.R. Vol. 46, No. 15, pp.
7658-7659)~. In the aforementioned sites, the mitigation goal to which the
Service would strive for is either no·loss of existing habitat value (Resource
---f---1 Category 1) or no net loss of in-kind habitat .value (Resource Category 2).
·:Hr. Eric Yould Page 2
The Service intends to recommend mitigation where a biological change
constitutes an adverse impact. Our evaluation of project impacts and
recommended mitigation would be based, to the extent applicable, on the
Service's Habitat Evaluation Procedures and Instream Flow Incremental
:Hethodology. Both of these methodologies have been suggested to APA and its
consultants on several occasions. It should be recognized that streamlining
the mitigation process can be accomplished by conformance between the
Service's and an applicant's impact assessment techniques. The larger the
proposal, the greater the potential savings in time. This idea was a
principal behind the formulation of our mitigation policy and adoption of
official evaluation procedures.
In accordance with our mitigation policy, "The Service may recommend support
of projects or other proposals when the following criteria are met: (1) they
are ecologically sound; (2) the least environmentally damaging reasonable
alternative is selected; (3) every reasonable effort is made to avoid or
minimize damages or loss of fish and wildlife resources and uses; (4) all
important recommended means and measures have been adopted with guaranteed
implementation to satisfactorily compensate for unavoidable damage or loss
consistent with the appropriate mitigation goal; and (5) for wetlands and
shallow water habitats, the proposed activity is clearly water dependent and
there is a demonstrated public need." (F.R. Vol. 46, No. 15, p. 7659).
Specific comments:
1.0 Introduction: This section should include a discussion of the need to
adequately assess the environmental resources of the study area to
determine the environmental compatibility of a proposed project and to
evaluate mitigation to adequately reduce or avoid negative impacts to
environmental resources, including fish and wildlife resources, so that no
net loss of habitat value occurs.
2.0 Legal Mandates: It should be recognized that the intent of the specified
laws and regulations is that project-relate~ adverse biological impacts be
fully mitigated. In addition, that a plan be developed, acceptable to the
resource agencies with mandated fish and wildlife management responsi-
bilities, and implemented as a component of the proposal.
2.2 National Environmental Policy Act (NEPA): It is the responsibility of the
lead federal agency, the Federal Energy Regulatory Commission (FERC), to
fully comply with NEPA.
2.3.Federal Energy Regulatory Commission: Regulations for, .. Application for
License for Major Unconstructed Projects and Major }!edified Projects,··
(F.R. Vol 46, No. 219, November 13, 1981) were adopted December 14. 1981.
References in your policy to FERC regulations should reflect this. It
should be recognized that within the Exhibit E. "The applicant must
provide a report that describes the fish, wildlife, and botanical
resources in the vicinity of the proposed project; expected impacts of the
project on these resources; and mitigation. enhancement, or protection
measures proposed by the applicant. The report must be prepared in
consultation with the state agency or agencies with responsibility for
these resources, the u.s. Fish and ~ildlife Service, the National Marine
Fisheries Service (if the proposed project oay affect anadromous,
estuarine, or marine fish resources), and any state or federal agency with
I~
-
-
Mr. Eric Yould
cc: FWS-ROES, WAES
Quentin Edson, FERC
NMFS, EPA, NPS , BLM, USGS, ADEC, ADF&G
Carson/ADNR
Lawrence/Acres American ----
Page 5
Jo-
'-
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A(
WILLETT
WITTE
BERRY
"H_AYDEN
LAMB
-t::AWRENCE
SINCLAIR
~ ... • ft'.elvin A. r-1onson
_A
_u
ting Assistant Regional Director
S. Fish and Hildl1fe Service
ll 11 E. Tudor Road
Jl . chorage, Alaska 99503
February 24, 1982
P5700. 11.71
T.1528
VANOERBURGH
n
)(. TouNh
f"•' f-. ' •j .'"':·il
CARLSON _T
FRETZ
JEX Ul
LOWREY ~
SINGH ~
t
ar Mr. Manson: Susitna Hydroelectric Project
Fish and Hildlife mtillation Pol icy
ank~u for your letter of December 3C, 1981, co~enting on the Fish
d Wildlife Mitigation Policy for the Susitna l!ydroelectric Feasibility
udy. ~·1e appreciated receiving a copy of the F&~~S f.11tigation Policy
d your explanation of it.
~~. HEAD
~ ...
will attempt to aespond to each of your comments, numbered as in
ur letter.
r-t10VE
I 0 Introduction:
c. Ht>Ov'<T. f-l
I
CHASE
I
'
This section was purposefully kept short so that the pol icy vrould not
be overbearing. He do not feel it necessary to discuss the issues
you mentioned, as they are covered in detail in the Feasibility
Report. At the suggestion of the Alaska Department of Fish and Game,
we have added the phrase "~lidH and tlildlife resources of the state".
2. 0 Legal t·~andate:
The entire policy and particularly sections 3 and 4 explain that
APA intends to develop and impler.ent a mitigation plan in coordination
with the agencies \'lith mandated fish and wildlife mitigation
responsibilities. ·
2.2 National Environmental Policy Act:
Since FERC is a federal a~ency, they are covered by the statement
"Federal agencies shall to the fullest extent possible~.
-
-
Mr. Melvin A. Monson · February 24~ 1982
page 2
2.3 Federal Energy Regulatory Co1m1ission
The policy will reflect the fact these regulations were adopted.
Exhibit E will be prepared as described in the regulations.
2.4 Fish and Wildlife Coordination Act
3.1
Reference to FERC has been incorporated.
Basic Intent of the Applicant
The statement 11 The FERC will resolve any disputes which APA and the
agencies cannot resolve" has been added.
3.2 Consultation with Natural Resource Agencies and the Public
A section explaining the mechanism for coordination with the agencies
has been added to the beginning of the policy. The agencies will be
involved in the plan both prior and subsequent to FERC filing.
3.3 Implementation of the Mitigation Plan
The implementation of the mitigation plan is recognized by APA to
be its responsibility.
3.4 Modification of the Mitigation Plan Paragraph 2
It is recognized any modification to or termination of the mitigation
efforts would be subject to FERC approval. It is assumed FERC would
consult with the agencies during this process.
4.0 Approach to Developing the Fish and Wildlife Mitigation Plan Paragraph 3
The intent of this paragraph was to direct mitigation efforts towards
those resources where, even without an e~tensive data base~ it is
predicted the greatest impacts would occur. As an example~ the
concentration of the fisheries mitigation efforts has been towards the
anadromous fisheries between Devil Canyon and Talkeetna, as this is
an important resource and there is a higher potential for impact
in this section than further downstream.
Paragraph 5
The intent of this procedure is to consider each impact issue and to
review all practicable mitigation options within the intent of the
National Environmental Policy Act. If a mitigation option is
identified that avoids an impact~ is technically feasible, effective
and not in conflict with any other projeQt objectives, the need to
address other alternatives \olas not considered necessary. The
ACRES AMERICAN INCORPORATED
Mr. Melvin A. Monson February 24, 1982
page 3
intent of sentence 2, paragraph 5 was to state that if such an
option does not exist, we will proceed to evaluate other options.
As stated in the policy, "All options will be evaluated and docu-
mented... The pol icy wi 11 be revised to make this clear.
Paragraph 7
This paragraph has been expanded to include the Fish and Wildlife
Mitigation Review Group involvement in the plan 1 s development.
Paragraph 9
Your statement has been incorporated.
Paragraph 10
We agree with your statement. The FERC must approve any modification
to mitigation stipulations in the license. It is anticipated FERC
would not approve the modifications without first consulting with
the appropriate agencies.
Thank you again for your time. If you have any questions regarding my
responses, feel free to contact me.
MMG/jmh
cc: E. Yould, APA
K. Schreiner
ACRES AMERICAN INCORPORATED
Sincerely yours,
4~/
'{?/?-~~
~'"o. Lawrence
Project Manager
r
-
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ALASKA l"OWEK
AUTHORITY 1 SUSITN;t..
FILE P5700
December 31, 1981
Mr. John D. Lawrence
Acres American, Inc.
900 Liberty Bank Building
Main at Court
Buffalo, New York 14202
Dear Mr. Lawrence:
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
NationaZ Marine Fisheries Service
P. 0. Bo:x: 1668
Juneau, AZaska 99802 R E C E 1 V E 0
JAN 0 4 1982
AtRlS AhttiUCl\t~ \ttCuRrU\\AUD
We have received your 1 etter of November 19, 1981, requesting the comments
of the National Marine Fisheries Service (NMFS) on the Fish arid Wildlife
Mitigation Policy for the Susitna Hydroelectric Project. Having reviewed
the statement we offer the following comments.
The statement adequately reflects the intent of such a mitigation policy
and presents an accurate overview of those legal mandates which require
mitigation to be considered in designing hydroelectric projects. We
have several specific comments dealing with the operation of the proposed
mitigation plan, which follow.
3.1. Basic Intent of the Applicant
The last paragraph states that this methodology outlines a
process for resolving conflict between the Power Authority and
resource agencies. We do not feel this has been satisfactorily
accomplished within the general policy statement (Sec. 3) and
suggest additional effort be made to establish such a conflict
. 'I?/ ·':--=-==· :::· =_J l SEQUENCE NO.
resolution methodology .
,-., ,.-
1--·._?,,)
v
3.2 Consultation with Natural Resource Agencies & the Public
Realizing that Section 4, step 3, development of an acceptable
mitigation plan, is to be completed by March 1982, we assume that
steps 1 and 2 of the same section are by now substantially completed.
Yet, contrary to the second sentence of 3.2, "During the early
stages of planning, representatives of state and federal agencies
will be encouraged to consult with the applicant and the applicants
representatives, as members of the Mitigation Task Force.",
we have yet to be contacted regarding the status of this impor-
tant element, and the Mitigation Task Force review committee has
not met as of this date.
3.3 Implementation of the Mitigation Plan
We are pleased to see the plan include provisions for post-
construction monitoring of mitigation measure? and opportunities.
The applicant should note, however, that such a provision will
be integral to the mitigation plan and the associated costs should
be included with the license application, and not 11 resolved through
parties after the mitigation plan is complete.11 This is supported
in the FERC regulations, 4.41 (F)(3)(iv)(D), which require
Exhibit E to contain an estimate of the costs of construction,
operation, and maintenance of any proposed facilities or imple-
mentation of any (mitigation) measures.
3.4 Modification of the MitigatiQn Plan
The last sentence, dealing with termination, should state that
termination of any mitigation measure stipulated in the FERC
license will require an amendment to that license.
4 Approach to Developing the Fish and Wildlife Mitigation Plans
Paragraph 3, sentence 6. Change 'will • to •may•, as priority will
be assigned both by the likelihood of impact and sensitivity of
the resource.
Paragraph 5, sentence 2. The fact that a form of mitigation is in
conflict with project objectives or only partially effective should
not prevent it from further consideration. Such a statement strains
the term .. reasonable alternatives .. and does not comply with the
spirit or intent of the National Environmental Policy Act.
Paragraph 7. As outlined, no formal agency input into the mitigation
plan will occur prior to application to FERC. FERC regulations
require Exhibit E to contain a report describing proposed mitigation
measures, prepared in consultation with state and federal resource
agencies. The process described here falls short of this required
consultation. We suggest formal agency review of the draft fisheries
and wildlife mitigation plans occur prior to license application.
We appreciate this opportunity to comment.
Sinc~rely, . _ ·~ ·I.~;; ___ ·// . :r~ 7/'~ , .... v----~
.• . / J,.r-Robert. W. McVey '
l . Direc'tor, Alaska Region ' ..... '·
\..../ ..
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WILLETT
WITTE
BERRY
HAYDEN
LAMB
LAWRENCE
SINCLAIR
Mr. Robert W. McVey
tor. Alaska Region 1 free
atio
.D.
~ unea
ear
nal Marine Fisheries Service
Box 1668
u. Alaska 99802
Mr. f1cVey:
February 23. ]982
P5700. 11.91
1.1424
Susitna Hydroelectric Project -
Fish and Wfld11fe Mitiqatfon Policy
tha nk you for your December 31. 1981 response to our request for
VANDERBURG_~-( ormte nts .on the Susitna Ffsh and Hildl ffe Mitigation Pol fey. I have
nd~d to your comments fn the order in which they were presented. t-Tc.l>of
10 Spo
-.
.1 -
CARLSON
FRETZ
JEX ·~ ur a
LOWREY JPA a
SINGH ~it
/"{ "r....;71.;'1: }' th
r~sou
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II OU STEAD
Basic Intent of the Applicant
pproach to resolving fish and \':ildlife mitigation confHcts between
nd the.resource agencies is outlined in Step 3, Section 4, of the
ation Policy. As stated. it basically involves revie'tr and cornent
e Fish and Wildlife Hitfgatfon Review Group representing the
rce agencies. In acdition. although not specifically stated.
I~ BOVE d~enc
r policy, any draft mitigation plans will be submitted to resource
ies for fonnal co1m1ent and review prior to the submission of a
I
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CHASE
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F RC
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1 icense application. Our policy will be modified to include this.
Consultation with Natural Resource ACJencies and the Public
on 4, Step 3, Development of an Acceptable r'!itigation Plan. \-:111
e completed by r·~arch of 1982. Holt!ever, miti9ation options \'rill
sessed and preferred options tot'ether with their technical feaxt-
b1lity and potential effectiveness will be presented in the r'larch 1982
Feasibility Report. ·
The first meeting of the f~itigation Review Group \•1111 occur in March.1982.
An invitation will be sent to Bradley Smith as a representative of your
agency. This meeting will provide the resource agencies with an opportunity
to discuss, ~lith the f.iitigation Core Groups, the various mitigation options
presently being considered. The details of a draft mitigation plan will
be completed subsequent to the Feasibility Report and prior to the FERC
license application.
3.4 -f·loclification of the ~litiqation Plan
We agree that the termination of any mitigation measure stipulated in
the FERC license would require FERC approval. In regards to the mon-
itoring program. we anticipate that the FERC license will allow for
Mr. Robert W. ~1cVey February 23~ 1982
page 2
the termination of the monitoring program when the need for further
mitigation is considered unnecessary. We have modified the policy to
state termination would be subject to FERC approval.
4.4-Approach to Developing the FiSh and Wildlife Mitigation-Plans
Paragraph 3~ sentence 6~ refers to the functioning of the Mitigation
Core Group which will be concentrating its efforts towards resources
most likely to be impacted. ·
Paragraph 5, sentence 2. This sentence is ~ontained under Step 2 en-
titled "Option Analysis Procedure 11
• The intent of this procedure is
to consider each impact issue and to review all practicable mitigation
options within the intent of the National Environmental Policy Act.
If a mitigation option that avoids an impact is identified which is
technically feasible, effective, and not in conflict with any other
project objectives. the need to address other alternatives was not
considered necessary. The intent of sentence 2, paragraph 5, was to
state that if such an option does not exist, we will proceed to evaluate
other options. "All options considered will be evaluated and documented.
The result of this process will be an identification and evaluation of
feasible mitigation options fo~ each impact issue and a description of
residual imp.acts. 11
The selection of which options are to be further considered in the de-
velopment of an acceptable mitigation plan is addressed under Step 3.
Paragraph 7. Mitigation options wlll be forwarded to the Fish and
Wildlife Nitigation Review Group allowing for agency review and corranent.
In addition, our mitigation pol icy will be modified to reflect our
intent to have the draft mitigation plan formally reviewed by agencies
p~ior to application to FERC.
I appreciate your comments and trust our response satisfies the concern
you have expressed.
KRY/jmh
ACRES AMERICAN INCORPORATED
Sincerely,
6~~~
John D. Lawrence
Project Manager
u.s. ENVIRONMENTAL PROTECTION
REGION X
1200 SIXTH AVENUE
SEATTlE, WASHINGTON 98101
AGENCY
-~~'r"::')
R I= ~ ~ ;::_ i .: --· -· ·-
FEB 8 lS3Z
'
ACRES A~ffiltAX UtCURPOrJ.lEB
-
,_ AL POWER
.tORlTY
..iiTNA
,_ FILE P5700
. IJ.qJ;
REPL't 10 M/S 443 ATlN OFi
4 FEB 1982
Kevin R. Young
Acres American Incorporated
The liberty Bank Sui ldi ng
Main at Court
Buffalo, NY 14202
Subject: Susitna Hydroelectric Project Fish and Wildlife Mitigation
Policy and Draft Analyses of Mitigation Options ·
Dear Mr. Young:
Thank you for sending us copies of the above papers for our review. From
conversations with Mike Grubb, of your staff, we understand that Acres
American has decided that further work is necessary on the mitigation
options papers before agency comments will be solicited. Therefore, this
letter will-address EPA•s comments on the mitigation policy paper only •
In general, we believe that the overall mitigation approach i-s good •. In
particular, the ~se of the CEQ definition of mitigation encourages the
most satisfactory types of mitigation to be considered first. This is
reflected in Figure 2, OptiDn Analysis. The establishment of a long-term
monitoring plan and acknowledgment that the mitigation plan will be
changed if necessary is also commendable.
We do have spme concerns about implementation of this policy, especially
over the next year while the mitigation plan for the FERC ~icense appli-
cation is still being developed. Some issues and mitigatio-n measures must
be incorporated into the preliminary engineering and design stages of the
projects and, from our review of the Acres Jlmerican reports, we are aware
that this is being done. One good example is spillway design to avoid
nitrogen supersaturation. However, there are a great many other issues
where the agencies and the public do not have sufficient information yet
on the impacts to judge either how much mitigation will be needed or what
sort of mitigation might be successfu~·. For example, EPA will not have
any pre-and post-project water quality data unti 1 the feasibility study
is ci~culated (letter fro~ John n Lawrence to John R. Spencer, January 4,
DWL 1982~.) Development of an option analysis vJhich r"€flects the possible suc-
t-'-1---+--'--"~':; cessful mitigation measures for the entire range of potential impacts,
,...._ · including the wars t case, appears to be a usefu 1 step at this time.
HO~o1ever, the agencies and the public may have difficulty eva·luating the
adequacy of a mitigation plan until more impact information is available.
EPA would have been faced with this situation in reviewing the fishery
mitigation plan if Acres American had wanted our comments at this time.
We have one other suggestion for your consideration. Because of the
location and magnitude of the impacts, new mitigation methods or methods
new to this region of Alaska may eventually be identified. Because it
will be several years before the mitigation plan is finalized, it may be
possible to test the feasibility of some of these ideas before mitigation
itself must start. Such an approachc may have long-term environmenta 1 and
economic benefits.
Some additional minor comments are presented in the attachment.
We look forward to reviewing the option papers. If you would like to dis-
cuss our comments, Judi Schwarz of the Environmental Evaluation Branch may
be contacted for more information. She can be reached at (206) 442-1096.
Sincerely,
Qt ... oqW :O~eal, Director
Environmenta 1 Services Division
cc: Al Carson, DNR
Dave Wozniak, APA
,., ..
Susitna Fish and Wildlife Mitigation Policy
Attachment ·
FERC Regulations
For your information, FERC published the new regulations on license
applications on November 13, 1981. The section of fish and wildlife
mitigation can be found at 46 FR 55938. FERC has made some wording
changes, but the substance is essentially unchanged.
Definitions
The policy statement refers to a Mitigation Task Force, a Mitigation
Review Group, and a Core Group of the Mitigation Task Force. The com-
position and method of selection ofeach group should be described.
WILLETT
WITTE
BERRY
IV HAYDEN
LAMB
SINCLAIR
~r • Gary O'Neal, Director
vironmental Services Division n
l.
February 23, 1982
P5700. 11. 91
T.l526
VANDERBURG!-( e
S. Environmental Protection Agency
gion X
v y.,v!.J"""'
X l'l>"'Vhh v
CARLSON
FRETZ
JEX
' LOWREY
SINGH
" p ~..! ,_~ u.-...
--...JSTEAD
BOVE
CHASE
I,..
I'" 00 Sixth Avenue
le, attle, Washington 98101
ar Mr.~O'rteal: L !'=' Susitna Hydroelectric Project
Fish and Wildlife Hitiqation Policy
lh
l-i
ank you for your letter of February 4, 1982 regarding the Susitna
sh and \~fldlife Mitigation Policy.
1'1~
t)l
will be discussing Hitigation further in early riarch meetin§s with
e Core and Review Groups and attempting to focus in on the major
pact issues and define further studies necessary to develop adequate
tigation. You will be invited to this meeting.
"'11
hi
"T :11 ank you again for your coffiffients.
~'tMG/jh
cc: E. Yould, APA
J. Spencer, EPA
Sinccra]..y.
&-
John D. La\>~rcnce
Project r·~anager
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errestrial
nvironmental
~-pecialists, inc.
RECEIVED
NOV 3 0 1981
R.D. t BDX 388 PHOENIX, N.Y. 131311 (3f15l111!1·7228
MEMO
TO: Members of the Fisheries Mitigation Technical Group
FROM: Russell J. Nemecek
DATE: November 25, 1981; 218.880
RE: Mitigation Options
Enclosed are initial evaluations of impacts and mitigation options
available for operational flows on the downstream fisheries and the
flooding of streams in the impoundment zones. Please review this
material before our December lOth meeting in Seattle, since this will
be the essence of our discussions. If you have any cormnents or
additional input to make prior to our meeting, please contact me.
ALASKA POWER
.c>.UTHORiTY
SUSITNA 1------!
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DIVISION OF RESEARCH & DEVELOPMENT
December 9, 1981
Mr. David Wozniak
Alaska Power Authority
334 West 5th Avenue, 2nd Floor
Anchorage, Alaska 99501
Dear Mr. Wozniak:
JAr S. HAMUOitD, &OrEIIt0/1
323 E. 4TH A VENUE
ANCHORAGE; 'A~ASK"\ 99501
The Susitna Hydroelectric Steering Committee (SHSC) would like to receive
additional information from your office regarding the status and progress of
the Mitigation Task Force. As you know, preparation of an adequate Federal
Energ~egulatory Commission (FERC) license application requires that Exhibit
E identify the proposed measures to mitigate impacts or to protect and en-
hance the resources. We believe coordination of this vital study item
should occur early and on a continuing basis. I am aware that the APA has
also recognized this need by creating two Mitigation Task Force core groups
composed of principal investigators and a Mitigation Review Committee com-
posed of representatives of various concerned agencies. While several mem-
bers of the Review Committee sit on the SHSC, they have received no informa-
tion on the progress of either core group. Additionally, the Fish and Wild-
life Mitigation Policy recently developed by APA for the Susitna Hydroelec-
tric Project stresses the need for close coordination. Although no time
schedule is established in this mitigation plan, it is obvious that steps 1
and 2 (identification of impacts, ranking of impacts and identification and
review of mitigative alternatives) should be substantially completed by now
if step 3 (development of an acceptable mitigation plan) is to be achieved
by the March 15, 1982 draft feasibility report deadline.
Therefore, I am requesting that you provide any applicable information
regarding the Mitigation Task Farce groups and their progress to date. The
minutes from past meetings would be particularly helpful here. As the SHSC
is eager to discuss these concerns, I believe a short briefing may be most
effective. I will be contacting you to arrange for such a meeting, hopefully
during the week of 12/13/81.
Sincerely,
Al Carson
Chairman, Susitna Hydroelectric Steering Committee
AC:db
cc: Steering Committee
R. Stoops
Quentin Edson, F.E.R.C.
ALASKA POWER AUTIIORITY
334 WEST 5th AVENUE-ANCHORAGE, ALASKA 99501 RECEIVED Phone: (907) 277-7641
(907) 276-0001
l. ALASKA 'POWER
AUTHORITY
SUSITNA
Mr. Al Carson
Depart::rcent of Natural Resources
Division of Research and
Develq:nent
555 Cordova
Anchorage, Alaska 99501
Dear Al:
DEC 21198i
ACRt;) nm~rtlliJ\H litt;thtrORATED
December 15, 1981
I am in receipt of your letter of December 8, 1981 soliciting (on
behalf of the Susitna Hydroelectric Project Steering.Cammittee)
additional inforrration concerning the Mitigation Task Force.-I am happy
to comply, in part because it affords me an opportunity to correct same
apparent misconceptions.
First, while I have no objection to Steering Ccmnittee
participation on our mitigation planning, I am scmewhat surprised. As
was :rrade clear early on, mitigation planning (and specifically the
Mitig~tion Task Force Review Group activities) is being done within the
fo:rmal ccordination and consultation frarret.o.Drk of the Fish end Wildlife
Coordination Act and F .E.R.C. Regulations. By contrast, the Steering
Carrnittee has worked vigorously to remain infernal cormentators to the
Sustina Hydroelectric Project proposal. If the Steering Comni ttee
elects to join us in mitigation plarming, it should ~understood that
we will t.reat their participation as "forrral". That in turn leads to
other minor procedural concerns, such as what to do about dual
l?;:~Ef:::"'::, 1,.-i:'.Tl'l-\ representation, etc.
Second, you misjudge slightly our ·tirretable on mitigation planning.
We are just now in the midst of ide.ntification of inpacts. Physical
constraints have led to this tirretable: Field studies had to be
corrpleted and surrmarized, hydrology data fo:rmulated so that p::Y>Ver
generation simulation (which leads to water release/stage information)
could be done, etc. We have by no rreans fully scoped irrpact yet, but we
are rapidly advancing.
Which leads me to the key ]?Oint; when will an assessrrent be
possible? ~he most comprehensive will appear in the draft feasibility
re]?Ort, to be published March 15, 1982. A less canprehensive, but
nonetheless fairly rigorous, assessrrent will be provided to the Review
Group when they convene January 20, 1982. I kna.v you are a rrember of
that Review Group. You should be receiving your fonna.l invitation very
soon, if not by nON. I suggest Steering Cornnittee involverrent, if any,
be subsequent to tbat convening.
FOR 'lliE EXECUI'IVE DIREC:roR
Sincerely, J2 !j/J . n Dav~~ Prolect Manager ,
-'
DO.Y/blm
cc: John Lawrence, Acres Arrerican (w/cy of Carson letter)
Quentin Edson, F .E.R.C.
-
-
Ms. Janet McCabe
Area Director
U.S. Geological Survey
1011 E. Tudor
Suite 297
Anchorage, AK 99501
Dear Ms. McCabe:
December 18, 1981
P5700 .11. 91
T.1355
Susitna Hydroelectric Project
Fish and Wildlife Mitigation
Review Group
In September of this year the Alaska Power Authority (APA) invited you or
a member of your staff to participate in a Fish and Wi1dlife Mitigation
Review Group for the Susitna Hydroelectric Project. To date, APA has
received no response.
The first Review Group meeting is to be held January 20, 1982, at 10:00 a.m.
at the offices of APA~ Please inform APA if you will be attending this
meeting and if you wish to participate in future mitigation planning efforts.
If so, we will ·send material for your review prior to this meeting.
Thank you.
Sincerely,
Kevin Young
MG:adh Environmental Coordinator
cc.: APA
ACRES AMERICAN INCORPORATED
1· ~-' ; -. '=.: ~ -; .• ;. ::: ~ -· ;-
Mr. Carl Yanagawa
Regional Supervisor for Habitat Division
Alaska Department of Fish & Game
333 Raspberry Road
Anchorage, Alaska 99502
Dear Mr. Yanagawa:
December 18, 1981
P5700.11.92
Tl360
As a member of the group established to review fish and wildlife mitigation
recommendations on the Susitna Hydroelectric Project, I request your atten-
dance at a meeting on January 20, 1982, at 10:00 a.m., in the office of the
Al-aska Power Authority. In the first week of January, I will forward for
your review, a preliminary outline of project operations, impact issues, and
mitigation options as prepared by our design team and the fish and wildlife
mitigation technical core groups. I would appreciate receiving by January
30, 1982, any written comments you may have regarding our approach, results,
or evaluations to date.
Following the preparation of the Feasibility Report, which will contain more
detailed information on project operations and our evaluation of these oper-
ations, an opportunity will be provided for you to perform a more thorough
review.
If you have any questions relating to this meeting or the proposed functions
of the review group, please contact Mr. Dave Wozniak of APA or myself at
716-853-7525.
MG/jk
ACRES AMERICAN INCORPORATED
Consult.ng Er.gincers
The LibE:rty Ban~ eui::;:,ng. l.la•n a! Courl
eu!lalo. Ne·:. Yor"~ 1 ~2Ci2
Te!es;hor.e 71£·853·7~25
Sincerely,
Kevin Young
Susitna Environmental Coordinator
-
·-
Preceding Letter Sent To:
Mr. Carl Yanagawa
Regional Supervisor for Habitat
Division
Alaska Department of Fish and Game
333 Raspberry Road
Anchorage, AK 99502
Ms. Juli Schwarz
Environmental Evaluation Branch
U.S. Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, WA 98101
Mr. Bradley Smith
Environmental Assessment Division
National Marine Fisheries Service
Federal Building and U.S. Court House
701 C Street, Box 43
Anchorage, AK 99513
Mr. Al Carson
Department of Natural Resources
323 East Fourth Avenue
Anchorage, AK 99501
Mr. Michael Scott
U.S. Bureau of Land Management
4700 East 72nd Street
Anchorage, AK 99507
Mr. Gary Stackhouse
U.S. Fish and Wildlife Service
lOll East Tudor Road
Anchorage, AK 99502
January 7. 1982
P5700.11.70
T.l395
Mr. Carl Yana~awa
Regional Supervisor for Habitat Division
Alaska Department of Fish & Game
333 Raspberry Road
Anchorage. Alaska 99502
Dear Mr. Yanagawa:
Enclosed for your review:
Susitna Hydroelectric Project
Fish and Wildlife Mitigation
Review Group Meetinq
1} Susitna Hydroelectric Project Fish and W1ld11fe f1it1gation Policy.
2) Draft ,O.nalysis of ~~ildlife nitiqation Options.
3) Draft Analysis of Fisheries t~itigation Options.
These documents \~111 be discussed at the F1sh and Wildlife Mitiqation Review
Broup Hect1ng to be eeld at 9:08 a.m. {note change of time from-lett~r
of Deccr:b~r 1n, lS31) on Janua:--:: ZJ. 1!?:2 at the office of the Alaska
Poi-;<;~~ Authority, 334 l~est 5th A.venue s f.nchoragel;! I hope you will be
able to attend the meeting.
Sincerely yours.
Kevin R. Young
Sus1tna Env1ronmenta1 Coordinator
HhG/jr.Jh
Enclosures
-
-
....
-
-
Preceding Letter Sent To:
Mr. Carl Yanagawa
Regional Supervisor for Habitat
Division
Alaska Department of Fish and Game
333 Raspberry Road
Anchorage, AK 99502
Ms. Juli Schwarz
Environmental Evaluation Branch
U.S. Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, WA 98101
Mr. Bradley Smith
Environmental Assessment Division
National Marine Fisheries Service
Federal Building and U.S. Court House
701 C Street, Box 43
Anchorage, AK 99513
Mr. Al Carson
Department of Natural Resources
323 East Fourth Avenue
Anchorage, AK 99501
Mr. Michael Scott
U.S. Bureau of Land Management
4700 East 72nd Street
Anchorage, AK 99507
Mr. Gary Stackhouse
U.S. Fish and Wildlife Service
lOll East Tudor Road
Anchorage, AK 99502
Mr. Carl Yanagawa
February 26, 1982
P5700.11.70
T.l543
Regional Supervisor for Habitat Division
Alaska Department of Fish & Game
333 Raspberry Road
Anchorage, Alaska 99502
Dear Mr. Yanagawa: Susitna Hydroelectric Project
Fish and Wildlife-Mitigation
As discussed through Vern Smith of our Anchorage office, meetings to re-
view fish and wildlife mitigation efforts are scheduled for March 11 and
12, 1982 in the offices of Acres American, 1577 C Street, Suite 305,
Anchorage, Alaska.
As these meetings are expected to be in the fonn of technical workshops,
a complete day on each of the topics of fish and wildlife is considered
necessary. Proposed agendas are enclosed. I will also forward, within
the week, updated information packets addressing fish and wildlife im-
pact issues and mitigation options.
As fisheries issues are being discussed on a separate day from wildlife
issues, please feel free to have different technical personnel attend
each of the meetings if you consider it appropriate.
As we consider these meetings to be an important component in improving
the coordination between your agency and our fish and wildlife mitigation r
core groups, your attendance is encouraged.
If you have any questions relating to these meetings please contact my-
self or Vern Smith (907-276-4888).
Sincerely,
Kevin Young
Environmental Coordinator
KRY:dlp
Enclosures
-
Preceding Letter Sent To:
Mr. Carl Yanagawa
Regional Supervisor for Habitat
Division
Alaska Department of Fish and Game
333 Raspberry Road
Anchorage, AK 99502
Ms. Juli Schwarz
Environmental Evaluation Branch
U.S. Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle~ WA 98101
Mr. Bradley Smith
Environmental Assessment Division
National Marine Fisheries Service
Federal Building and U.S. Court House
701 C Street, Box 43
Anchorage~ AK 99513
Mr. Al Carson
Department of Natural Resources
323 East Fourth Avenue
Anchorage, AK 99501
Mr. Michael Scott
U.S. Bureau of Land Management
4700 East 72nd Street
Anchorage, AK 99507
Mr. Gary Stackhouse
U~S. Fish and Wildlife Service
1011 East Tudor Road ·
Anchorage, AK 99502
Mr. Carl Yanagawa
March 2. 1 ~B2
P5700.11.7C
T .1552
Reglonal Supervisor for H!tb1tat Divts1on
Alask~ Denartment of F1sh & Game
133 Raspberr,y Road
Anchorage, Alaska 99502
Dear Mr. Yanagawa: Sus1tna Hydroelectric Project
f'fsh and Wildlife f11tfgation
Review Group r~t1no
Enc1osec for your information ~re:
1. The Susitna Hydroelectric Project Ffsh
and Wildlife ·Mft1gat1on Policy (Revised)
2. Wildlife r-~1tfql't1cn Options (Revised}
3. Fisheries M1t1gatfcn Options (Rev1sed)
Please rev1el1 thes~ docum~rt~ prior to the neet1r.:'1 of the
Fish and Hild11ffl ;~ttiar~tfon Rev1~" Group on ~~rch 10, p,qz
at 3: 31) ar. in the offi C\:S o~ Acr(!S fi.~ri cant 1577 C ~treet,
Anchorage. lJe '·rill d1scus~ the Poltcy and H1ldl1fs ~~itkr<'!
tion Options nn th~ lCth ~~1 t~~ Fish~ri~s Mftigati~~ n"-
tions on the 11th, as refo:-rr~n to fn tk inv1t;:.tior: l"'ttr.r
of February 25, 1982. ·
Th<ml< you V£-ry IT':scii.
K.~Y:dlp
Enclosures
Since-rely.
~~?.vin ¥o:.m("''
Su$1 t!l<l En vi rrmr.Fnt;d
Coordini'!:t.Jr
-
-
-
....
-
Preceding letter Sent To:
Mr. Carl Yanagawa
Regional Supervisor for Habitat
Division
Alaska Department of Fish and Game
333 Raspberry Road
Anchorage~ AK 99502
Ms. Juli Schwarz
Environmental Evaluation Branch
U.S. Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, WA 98101
Mr. Bradley Smith
Environmental Assessment Division
National Marine Fisheries Service
Federal Building and U.S. Court House
701 C Street, Box 43
Anchorage, AK 995l3
Mr. A1 Carson
Department of Natural Resources
323 East Fourth Avenue
Anchorage, AK 99501
Mr. Michael Scott
U.S. Bureau of land Management
4700 East 72nd Street
An~horage, AK 99507
Mr. Gary Stackhouse
U.S. Fish and Wildlife Service
1 Oll East Tudor Road
Anchorage, AK 99502
SUSITNA HYDROELECTRIC PROJECT
FISH AND WILDLIFE MITIGATION REVIE~ GROUP MEETING
March 10, 1982
Held at the Offices of Alaska Power Authority, Anchorage
Attendees: See attached list.
The meeting followed the attached agenda. The revised Fish and Wildlife
Mitigation Policy was discussed. Agreement was reached on all areas where
further revisions were suggested. The policy will be modified and circulated
to the review group members by April 15, 1982.
Ed Reed and Karl Schneider presented the results of the wildlife baseline
studies and impacts prediction. Attendees were provided with the sections of
the Feasibility Report addressing these issues.
General mitigation options were discussed. HEP was not dismissed but
questioned as to its validity to big game species in Alaska. It was agreed
some kind of habitat evaluation, in addition to population studies would have
to be conducted. TES has developed a habitat analysis method (used on the
access road studies) and this may be modified and used. The question of
land set aside was also discussed but no decision reached.
Ed Reed suggested, for discussion purposes, the option of APA funding a
permanent research station in the Upper Susitna Basin. It was agreed this
was an option but should be considered only if other options (avoid, reduce,
etc.) fail, i.e. it would be used on out~of-kind compensation.
Studies for Phase II to quantify impacts and for mitigation planning were
reviewed with Attachment A forming the basis for discussion. The BLM burn
in the Alphabet Hills may not proceed dur to lack of burn plan being written
and possible requirement for an archaeological clearance. APA may contact
BLM to determine how a go decision could be reached.
ft;. ~ 'f "'J lv I) d J t le ~ II 1 ~ vv b i " -' p
_________ ----=3/J.,/-?:~ /'1,~P:AT.f~I'J /1.#7:~;J_c __ _
--,----------'----·------------------------------
ES2AS2 S~M~c~rr~(------~~N~N\~~~S~-~----------,,... _______ AJ ___ -~vso"~-~tK_ .Qi e _______________________ _
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____ __ L~o.~'0? ~'""\~ ucs.~~ 'S ·-----------·----
-· . ____ (ba,s1_L _ Sro..c.._f-\-ko-'="v6~e.-~·.-----=u"--· =-s_;._F __ w ___ .S __ _
_ . -~-1_~ 4. ~ · C:, r v · b h · de"~,; AV"\f'l"\·c -t ~---______________ . ___ _
~"""' ___ _?_ 8_N_ f/_--. £._ /I·Ar_-£'""1CI_LL...f2 ___ --4~-/)~-[_~ ~-l..ll.:rtu. ~-/.YM1.4cl~-~~s _ ~-Tfi~_t!Q~J:gt;r~L_
_... __ (.!ft<t-_p_~_-11-&_. _/1-!:!!n /J:QP d <r ____________________________________ _
__ __ _ / o_h-? __ Ax~~~)~/--~---/J-=[)£...._-..;..._-;. _6_ _ _______ _
--·~ 6/ ___ ~~----.-----=--"--ts_S~., _
_ ____ _ !i}_£ ___ _6_ f. 11 (..{ <-t...£_N=----~--~b t_;. --------------· -------·· -·
-_---·-~--_D. Mf:t.£Mo£.,c.U. LlaP .4 -/-R...._ ___ _
!""'"·-····-------------,---------
-------------------------------------·------------------------------·-------------·-----
--------------'-----------------------------------·---
--------------~--------------·--------------------
----· ---------------------·---. -·-·
. -----------.----------------
~-
--------·-----------~ -
Mr. Karl Schneider
Research Coordinator
Division of Game
Alaska Department of Fish and Game
333 Raspber~ Road
Anchorage, AK 99502
Dear Karl:
March 16, 1982
P5700. 11.70
T1598
Susitna Hydroelectric Project
Proposed Phase II Studies
I am enclosigg a copy of the document briefly describing the proposed
Phase II Susitna Wildlife and Vegetation studies. This was prepared based
on the work of the Core Group and Review Group on March 10-12, 1982.
I wish to thank you for your time and input during both the review and
Core Group meetings. I feel we made real progress toward resolving some
of the issues that had been hanging, pBrticularly the wildlife/habitat
relationship issue. I understand Dr. Taber w111 be sending you a brief
description of a system he proposes and, following your review, we will
proceed to discuss the issue with the Core Group and others whom you feel
appropriate. As we discussed, TES wfll take the lead in arranging for the
\rorkshop.
Thank you again for your time; I w111 be fn touch.
MG:ccv
Enclosure
cc: E. Yould, APA
Sincerely,
Michael Grubb
-
r-ts. Judi Schwarz
Environmental Evaluation Branch
Mafl Stop 443
U.S. Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, WA 98101
Dear Judi:
March 24, 1982
P5700. 11 • 91
T1610
Sus1tna ~droelectric Project
Fisheries Mitigation
As we discussed, I am enclosing a copy of two documents distributed at
the March-19th meeting of the Susitna Fish and Wildlife Mitigation Review
Group. One document 1s a revision of the fisheries document provided to
you and .other menbers of the group on March 8th. The other document 1s a
sunmary of wildlife and vegetation studies proposed for Phase II of the
project. Thf.s document was based on Phase I studies, corrments from the
Review Group on the lOth, and work of the Wildlife Core Group on March 11th
and 12th.
The Fish and Wildlife Mitigation Policy was also discussed on the lOth.
You w·111 shortly be receiving what is hopefully the final version of this
policy. as the group reached agreenent as to the changes and the wordings
of these changes during the meeting on the 10th. ~
' '
Your comments on the two enclosed documents are invited. We are particularly
interested in your .thoughts as to:
1. Are the proposed studies relevent?
2. Do the proposed studies address the issues in question?
3. Which studies should receive priority, should funding become a
constraint?
Thank you for your continued role 1n this aspect of the project.
MG:ccv
Enclosures
cc: E. Yould -N'A
Sincerely.
Michael Grubb
Mr. Max Brewer
Office of the Director
Special Assistant for Alaska
U.S. Geological Survey
218 East Street
Anchorage, AK 99501
Dear Mr. Brewer:
April 1, 1982
P5700.11.87
T1633
Susitna Hydroelectric Project
Fish and Wildlife Mitigation
Policy
Enclos~ is the Susitna Hydroelectric Fish and Wildlife Mitigation Policy.
This policy is the culmination of a cooperative effort between the Power
Authority, its consultants, and the natural resource agencies.
Originally initiated in January 1981, this policy has been reviewed and
commented upon by the Fish and Wildlife Mitigation Review Group and revised
and reissued by the Power Authority and its consultants in May, June and .
November 1981 and March 1982. It has also been discussed at meetings held
wjth the Fish and 1-/ildlife Mitigation Revie\-1 Group in January.and June 1981
and March 1982.
This policy will serve as the foundation for further mitigation planning for
the Susitna Project. We look forward to working with you and your staff in
this important effort.
JOL:ah
Enclosure
cc: E. Yould
ACRES AMERICAN INCORPORATED
C::;r.sul:ir.g E~r;ir.eers
n.e li~e:ty !!ank !:!uilc'ng. r.~a:n at Court
Sincerely,
~ /...-<v~ftL-~~ ;0tt (;.
John 0. Lawrence
Project Manager
-
-
'~
-
-
Letter #3
Mr. Max Brewer
Office of the Director
Special Assistant for Alaska
U.S. Geological Survey
218 East Street
Anchorage, AK 99501
Mr. Ernest W. Mueller
Co11111issioner
Alaska Department of Environmental Conservation
Pouch 0
Juneau, AK 99801
Mr. Bob Martin
Alaska Department of Environmental Conservation
437 East Street, 2nd Floor
Anchorage, AK 99501
Mr. John Rego
U.S. Bureau of Land Management
Anchorage District Office
4700 East 72nd Avenue
Anchorage, AK 99503
r , "~ .. _,., I I , I • il
I . ~~;A~·;~ .... ..~.L.J
Mr. John Katz
Alaska Department of Natural Resources
Pouch M
Juneau, Alaska 99811
Dear Mr. Katz:
April 15 1982
P5700.11. 74
Tl624
S~sitna Hydroelectric Project
Fish ~nd Wildlife Mitigation
Policy
Enclosed is the Susitna Hydroelectric Project Fish-and Wildlife Mitigation
Policy.· This policy is the culmination of a cooperative effort between the
Power Authority, its consultants, and the natural resource agencies.
Originally initiated in January 1981, this policy has been reviewed and
commented upon by the Fish and Wildlife Mitigation Review Group and revised
and reissued by the Power Authority and its consultants in May 5 June, and
November 1981 and March 1982. It has also been discussed at meetings held
with the Fish and Wildlife Review Group in January and June 1981 and March
1982.
This policy will serve as the foundation for further mitigation planning for
the Susitna Project. We sincerely appreciate your efforts and those of your
staff in the review of the various drafts of this document and attendance ·
and input to the meetings. We look forward to working with you on future
mitigation efforts. Again, thank you for your assistance.
JOt: ah
Enclosure
cc: E. Yould
A. c-.,j .. ..,
ACRES AMERICAN INCORPORATED
5t."::o. ::e·_ ... v'Jrfl 1.:202
Sincerely,
John D. Lawrence
Project Manager
'"'"" Letter #2
Mr. John Katz
Pouch M
Alaska Department of Natural Resources
Juneau, Alaska 99811
Mr. Robert McVey
Director, Alaska Region
National Marine Fisheries Service
NOAA
P. 0. Box 1668
Juneau, Alaska 99802
Mr. Ron Morris, Director
Anchorage Field Office
National Marine fisheries Service
701 C Street, Box 43
Anchorage, Alaska 99513
Mr. Keith Schreiner
Regional Director
U.S. Fish and Wildlife Service
1011 East Tudor Road
Anchorage, Al aslca 99503
Mr. Robert Bowker
U.S. Fish and Wildlife Service
Western Alaska Ecological Service
733 West 4th Avenue
Anchorage, Alaska 99501
Mr. Ronald Skoog
Commissioner
Alaska Department of fish and Game
P .0. Box 3-2000
Juneau, Alaska 99802
Mr. Thomas Trent
Alaska Department of fish and Game
2207 Spenard Road
Anchorage, Alaska 99502
Mr. John R. Spencer
Regional Administrator
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Mr. Curtis McVee
Stat-e Director
Bureau of Land Management
Federal Building and Court House
Anchorage, AK 99513
Mr. Al Carso'n
Department of Natural
Pouch 7-005
Anchorage, AK 99510
Dear Mr. Carson:
Resources
April 1, 1982
P5700.11.74
T1616
Susitna Hydroelectric Project
Fish and Wildlife Mitigation
Policy
Enclosed is the Susitna Hydroelectric Project Fish and Wildlife Mitigation
Policy. This version has .been revised based upon-comments received and _
agreements reached at the Fish and Wildlife Mitigation Review Group Meeting
on March 10, 1982. We would like to consider this version as final and ask
your tnaulgence in any minor wording disagreements. If you have substantial
problems with the policy, we will, of course, be glad to discuss them with
you.
The plan has been revised to include the following major points:
1. Goals of the mitigation plans will be specified in the plan and the
goals considered in the modification and termination decision process.
2. It is the intent of the Power Authprity to negotiate directly and
resolve conflicts with the resource agencies.
3. The responsibility for implementing the mitigation plans rest with the
Power Authority.
4. The mitigation plans will be flexible to accommodate unexpected impacts
or shifts in prioritization of mitigation of i~pacts.
5. Project modifications will be included as a mitigation option to be
considered.
6. Alaskan agency involvement is more clearly defined.
To simplify your review, the .follo\.'ling sections and paragraphs have been
changed from the version discussed at the March 10 meeting:
3:1-Paragraph 1: The last sentence has been added.
-Paragraph 2, Sentence 4: The words "ultimate" and "insuring" have
been deleted.
ACRES AMERICAN INCORPORATED
C:.~!.uHii"~g i:r.gir.f:e!S
The LiC~:rly ~en~ eJi1::::ng. !'.,':.ain at Cl)url
=l.:~·c:o. ::ew vc .. ~ ~.:202
I~
-
-
-
-
Fish and Wildlife Mitigation Policy
Page 2
April 1, 1982
3.3 -Paragraph 1, Sentence 1: The words ''ultimate11 and 11 insuring" have
been delted.
-Paragraph 2: This entire paragraph is new~
-Paragraph 3, Sentence 1: The phrase "and to determine its effective-
ness" has been added.
3.4 -Paragraph 2, Sentence 3: The phrase "the Power Authority' has been
deleted.
-Paragraph 2. Sentences 4 and.S: These entire sentences are new.
-Paragraph 2, Sentence 7: The sentence has been revised and Sentence 8
added.
4 -Paragraph 3: The last two sentences are new.
-Paragraph 5, Sentence 2: The phrase "including project modification"
has been added.
-Paragraph 5, Sentence 3: The second half of this sentence is new.
-Paragraph 6, Sent·ence 2: The phrase "and an explanation of those
deemed infeasible" has been added.
/
-Paragraph 6, Sentences 4 and 5: These have been revised for clarity.
-Paragraph 7: This has been moved from the original location of two
paragraphs earlier. The last sentence is new.
-Paragraph 10: The last three sentences are new.
-Paragraph 11: This last paragraph has been revised to incorporate the
issue of obtaining mitigation goals.
Figure 1: Goals of Plan has been added to the first box.
Originally initiated in January 1981, this policy is the culmination of a
cooperative effort between the Power Authority, its consultants, and the
natural resource agencies. This policy will serve as the foundation for
further mitigation planning for the Susitna project.
ACRES AMERJCAN INCORPORATED
Fish and Wild1~:€ Mitigation Policy
Page 3
Apri 1 1, 1982
We sincerely appreciate your efforts in the reviews of the various drafts of
this document ar,~ your attendance and input to the mitigation meetings. We
look forward to ~orking with you further on this very important aspect of
the Susitna proj"£-ct. Again, thank you for your assistance.
JDL:ah
Enclosure
cc: John Katz
E. Yould
ACRES AMERICAN INCORPORATED
Sincere 1 y',
John D. lawrence
Project Manager
r~--
Letter #1
Mr. Al Carson
Department of Natural Resources
Pouch 7-005
.Anchorage, AK 99510
Mr. Bradley Smith
Environmental Assessment Division·
National Marine Fisheries Service
Federal Building and U.S. Court House
701 C Street, Box 43
Anchorage, AK 99513
Mr. Michael Scott
District Fisheries Biologist ..
U.S. Bureau of Land Management
4700 East 72nd Street ·
Anchorage, AK 995~7
Mr. Gary Stackhouse ·
U.S. Fish and Wildlife Service
lOll East Tudor Road
Anchorage, Ak 99503
Mr. Carl Yanagawa
Regional Super~isor for Habitat Division
Alaska Department of Fish and Game
333 Raspberry Road
Anchorage, AK 99502
Ms. Judi Schwartz
Environmental-Evaluation Branch
Mai 1 Stop 443 -
U.S. -Environmental Protectjon Agency
Region X
1200 Sixth Avenue·
Seattle, WA 98101
Mr. Lenny Carin
U.S. Fish and Wildlife Service
733 West Fourth Avenue
Suite 101
Anchorage, AK 99501
r r.· i. 'Ti
f"t t·' '· ·.·· ·.-. -D l . ' '· I • L:.J~i ~
Mr. Ronald 0. Skoog,
Alaska Department of
P.O. Box 3-2000
Juneau, AK 99802
Dear Mr. Skoog:
Conmissioner
Fish and Game
April 2, 1982
P5700.11.70
T. 1645
Susitna Hydroelectric Project
Fish and Wildlife Mitigation
Thank you for your letter of February 18, 1982, corrmenting on the Susitna
Hydroelectric Project Draft Analysis of Wildlife Mitigation Options and
Draft Analysis of Fisheries Mitigation Options. We appreciate the time
you and your staff have taken to respond to our request.
A meeting was held with the Susitna Fish and Wildlife Mitigation Review
Grou~n March 10, 1982, to discuss these wildlife mitigation options,
proposed Phase II studies, and the revised Fish and Wildlife Mitigation
Policy. Mr. Carl Yanagawa, Tom Arminski, and Karl Schneider of your
agency attended that meeting. The Wildlife Mitigation Core Group, of
which Karl Schneider is a member, met the following two days to formulate
studies for Phase II, the purpose of these studies being both to quantify
impacts and to plan for mitigation.
The points raised in your letter of February 18 concerning the mitigation
options and those raised in your letter of December 30, 1982, concerning
the Fish and Wildlife Mitigation Policy, were discussed at these meetings.
The results of these meetings, particularly as they refer _to the issues
in your letter, were as follows:
1. A revised Fish and Wildlife Mitigation Policy, incorporating many of
your agency and other agency comments, was discussed at the March 10
meeting. Agreement was reached on further changes; what will hope-
fully be the final version of the policy will be circulated by
April 15, 1982.
2. Utilization of HEP and the issue of replacement lands was discussed at
both meetings. No concensus of opinion materialized or final decision
reached. It was agreed that some type of big game habitat analysis
work would be conducteain Phase I I to complement the c·ensus and radio
collaring studies conducted in Phase I and continuing into Phase II.
It was also decided that one goal of this habitat analysis work would
be to evaluate lands identified as potential replacement lands. The
identification of these lands will be a Phase II task.
ACRES AMERICAN INCORPORATED
Con~ul1ing Enginters
Tr,e Libtrly !!;Jnk Burld•ng Ph!in al Court
Bu!falo N~.·. York 1'202
C~t.er O"ret·~ C~:~~! a. r.l:J. t '1~t..u•!;h. PA. ,,,:,_.·g· •. UC ~·:;,,~ .• r.~;;tc'l D_C
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Mr. Ronald 0. Skoog
Alaska Department of Fish and Game
April 2, 1982
- 2
3. The issue of burning to provide moose habitat was also discussed at
both meetings. It was decided the proposed BLM burn in the Alphabet
Hills provides a unique opportunity for asse~sing the effectiveness of
burning as a moose management tool in the Upper Susitna Basin, and as
such, pre-and post-burning studies would be proposed as part of
Phase II. These studies would, hopefully, provide the information to
determine if this option should be further pursued. As you suggested,
the Alaska DNR Plant Material Center staff was contacted by members
of Terrestrial Environmental Specialists.
I am enclosing, for your infonnation, an Overview of Proposed \~hase II
Wildlife.and Vegetation Studies, which was prepared by the Wildlife Core
Group, based on Phase I studies and input from the Fish and Wildlife
Mitigation Review Group.· This document was circulated to the Mitigation
Review Group on March 19, 1982. Detailed scopes, budgets, and schedules
for these studies will be submitted to the Alaska Power Authority for
their consideration.
A clarification is requi~ed regarding the purpose and e~tent of the
Fisheries Mitigation Options package submitted to your agency January 7,
1982. The intent of this document was to list the various fisheries impact
issues that had been identified and to indicate the generic type of
mitigation options that were being considered by the Fisheries Core Group.
The purpose-in submitting the document to your agency, which is represented
on the Fisheries Mitigation Review Group, was to supply some premeeting
information so that your representative would at least have a feeling for
the gener.al direction being pursued by the Mitigation Core Group.
Considering much of the information on the fisheries resources and project
design was not available until December 1981, the document submitted
January 1, 1982, was never intended to represent 11 an adequate assessment
of the fisheries resources in the Susitna River or adequate evaluation of
project impacts on that resource 11
• We a pol og i ze for the misunderstanding
if your staff spent time reviewing the document under this context.
Even without a complete assessment of the fisheries resources and complete
evaluation of project impacts, we do consider that most, if not all,
significant impact issues have been identified. In this context, pre-
liminary mitigation planning is being pursued.
Rather than responding to your specific comments on the Draft Fisheries
Mitigation Options Package, I have enclosed updated documents on fisheries
impact issues/mitigation options and a listing of fisheries question~ and
proposed studies. Both these documents were distributed to the Susitna
Fish and Wildlife Review Group in early March 1982.
The Fisheries Impact Issues and Mitigation Options Package was prepared by
the Fisheries Mitigation Core Group. The purpose of the document is to
identify key impact issues, ·not to present a detailed impact analysis,_and
to provide a discussion of tne-various mitigation options presently be1ng
ACRES AMERICAN INCORPORATED
' I
Mr. Ronald 0. Skoog
Alaska Department of Fish and Game
April 2, 1982
- 3
developed, not to provide a detailed assessment as to the suitability of
the various options. ·An impact assessment and draft mitigation plan are
forthcoming, however, such are premature until further analysis can be
completed.
Thank you again for your time and that of your staff in reviewing these
documents and attending meetings. It is very much appreciated. We are
most anxious that the review process for the Susitna Project be as
constructive and effective as possible. Ple~se ~o not hesitate to advise
us of any difficulties or problems you may encounter in the fulfillment
of our agency coordination program.
KRY:ccv
Enclosures
ACRES AMERICAN iNCORPORATED
Sincerely,
Kevin R. Young
Susitna Environmental Coordinator
-
.....
ALASKA POWER AUTli-ITORITY
334 WEST 5th AVENUE· ANCHORAGE, ALASKA 99501
Mr. Mike Small
Bureau of Land Management
P. 0. Box 147
Glennallen, Alaska 99588
Dear Mr. Small:
Phone: (907} 277-7641
(907) 276-0001
April 5, 1982
Our efforts in mitigation planning for wildlife
losses from the proposed Susitna Hydroelectric Project
include exploring possibilities of habitat management
in the upper Susitna basin. We have been advised by
Karl Schneider of the Alaska Department of Fish and
Game (ADF&G) and by our environmental consultants that
your agency is planning an experimental burn of
approximately 47,000 acres in the Alphabet Hills
Region. We have been further advised that this burn
provides an excellent opportunity to determine the
effectiveness of burning in the upper basin as a
habitat management tool, a subject on which little is
currently known.
Studies have been proposed to us by ADF&G and by
our consultant to conduct both pre-and post-burn
vegetation and moose surveys in this area. If the burn
is to occur this summer, these studies must be
conducted this spring.
During the last meeting of the Susitna Fish and
Wildlife Mitigation Review Group, Mr. Scott of your
agency indicated the decision to proceed with the burn
had not been reached and potential delays included
the areas of burn plan and archaeological clearance.
In the spirit of obtaining the best information
possible on which to make mitigation decisions, the
Power Authority would very much like the burn to
proceed. We are prepared to make a substantial
commitment of our resources to fund the studies
proposed by ADF&G and our consultants. We are also
willing to work cooperatively with BLM and provide
whatever assistance we can.
We must very shortly make decisions regarding the
direction of the coming field season studies, including
Mr. Mike Small
April 5, 1982
Page 2
spring studies in the proposed burn area. A timely
decision from you or indication on how we may assist
you would be greatly appreciated.
If you wish to discuss this, please give me a
call. Thank you very much.
FOR THE EXECUTIVE DIRECTOR
DDW/es
cc: Mike Scott, BLM
Mike Grubb, Acres~
Karl Schneider, ADF&G
sr;cer,rl?, f)~1Jil tP)J
David D. Woz~iak
Project Engideer
-
Mr. John Rego
U.S. Bureau of Land Management
Anchorage District Office
4700 East 72 Avenue
Ancho~age, AK 99507
Dear John:
April 13, 1982
P5700.11.75
T.1660
Susitna ~droelectric Project
Mitigation Planning
Thank you for meeting wfth me and Don Follows last week.• I appreciated
your suggestions and input regarding the Susitna 'reject mitigation
efforts and how we may help to expedite the Alphabet Hills burn. I have
been in contact with Mike Small and Jim Cbase to offer our assistance.
Thanks again for your help and fnput fnto our studies.
MG:ccv
Sincerely,
Michael Grubb
Senior Scientist
Mr. Carl Yanagawa
Alaska Department of Fish and Game
333 Raspber~ Road
Anchorage, AK 99502
Dear Carl:
Apr11 12. 1982
P5700. 11.70
T.1650
Susftna Hydroelectric Project
Wildlife Studies
Thank you for meeting with me last week. I am sure you and Tom are busy
andsappreciated your time. Your suggestions were helpful and aid in the
continued mitigation planning efforts for the Susitna Project.
As discussed, I am enclosing a copy of the Overview of Proposed Phase II
Wildlife and iegetation Studies. Thfs document was distributed at the
~~rch 19, 1982 Fish and Wfldlffe Mftfgatfon Review Group Meeting.
Thank you agafn for your time.
MG:ccv
Enclosure
Sincerely,
Michael Grubb
Senior Scientist
-
•tr. A1 Carson
Alaska Oepart.."tent of Natural Resources
Pouch 7·005
Anchora~e. Alaska 99510
Aprfl 13, 1re2
P5700. 11.74
T.1655
Dear Al: Sus1tna Hydroelectric Project
~.t1t1o~t1on P1ann1nr
Thank you for meeting with rne last week and discussing your concerns
regarding the Sus1tna project. I realize you hav~ a busy schedule and
app~c1ated y~ur tfme.
As I sr.antioned, I rnet last week with all tho mer.,bers of the f1sh and
Wildlife rHt1gat1on Review Croup tncl receiv2~ val u~ble 1nput an<! suggest1ons.
I look forward to t.!Ork1n~ furbher with you on m1ti~at1on p1ann1n9 for
this project.
f1NG/ jh
Sincerely,
f·'fchael r.rubb
Senior Sc1ent1st
Hr. ~.el Monson
Acting Assistant Rag1onal Director
U.S. Fish and Wfldlffe Service
1011 E. Tudor Road
Anchorage, Alaska 99503
April 13, 19&2
P5700.11.71
T.1657
Oear Hr. •':onson: Susitna t~droelectric Project
T~ft1qatfon Planninn
Thank you very much for arrang1n9 the moetfr.g lP:ith the members of
your staff last week. I feel we are making progress 1n our mitigation
planning efforts and look forwnrd to working further with the U.S.
Fish and Wildlife Servfcp, on th1s 1mpor~nt as~cct of the Susftna
project.
TI1ank you again for your holp.
NNG/jh
Sincerely.
Hichael Grubb
Senior Scientist
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Mr. Gary Stackhouse u.s. Fish and Wildlife Service
1011 East Tudor Road
A"choraue. Alaska 99503
Dear Cary:
~.f'!"i1 1 ~, 1 Of32
P5700.11.71
T.1659
Sus1tna Hydroelectric Project
P1ti9!tfon PilininQ
Thilnk you for meeting with Don Fol10\o!S and me last week; I'm sure
you W!!re t.usy reviewing the Feasibility Report and ttf.preciated your
time.
riext tit>.e we t.ieet "-'e can discuss ~ugar r.:tSples, brcol~ trout, !1ickey-
L1ncoln. Seabrook, lobsters. Peldrim ihor.1pson and other ~ood Uew England
topics. I'm looking forward to it.
HHG/jh
Sincerely,
f-t1 chae 1 Grubb
Senior Scientist
Mr. Lennie Corrin
U.S. Fish and ~!1ld11fe Service
1011 East Tudor Road
Anchorage, AK 99502
Dear lennfe:
April 13, 1982
P!700.11.71
T .1658
Sus1tna Hydroelectric Project
Mitigation Planning
Thank you for meeting \·lith Don Follows and me 1 ast week. I realize you
have Feasibility Report review responsfbflfties and appreciated your
time.
I feel we are makingpprogress in mitigation planning for the Susitna
Project and look fon;ard to working further with you on this matter.
MG:ccv
Sincerely,
f;ff chael Grubb
Senior Scientist
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Mr. Michael Scott
U.S. Bureau of Land ~fanagement
4700 East 72 Street
Anchorage, AK 99507
Dear Mfke:
Apr11 13, 1982
P5700.11.75
T .1661
Sus1tna HYdroelectric Project
Mitigation Planning
Thank you very much for meeting with me and Don Follows last week. I
appreciate both your time and help in advising us on the Alphabet Hills
burn. I have been in contact with Mike Small and Jim Chase and discussing
what we can do to expedite matters.
Thanks again.
MG:ccv
Sincerely,
f·1ichae1 Grubb
Senior Scientist
LJ .
.
;-----------.
rT. Al Carson
Department of Natural Resources
Pouch 7-005
Anchorage, AK 99510
Dear Mr. Carson:
April 21, 1982
P5700.11.74
T1665
Susitna Hydroelectric Project
Wildlife Mitigation Options
Paper
Enclosed is one copy of the Susitna Hydroelectric Project Draft Wildlife
Mitigation Option Paper. This document is part of the continuing process
leading to a wildlife mitigation plan.
Please review this paper. I will be contacting you shortly regarding a
meeting to discuss this document.
Thank you for your continued cooperation.
MG:m
Enclosure
cc: D. Wozniak, APA
ACRES AMERICAN INCORPORATED
Consulting Engin"e's
-------;:_·----::-;-~ ... ~ .. -' ~-?!---~-----=---------~-----·--------
Sincerely,
Michael Grubb
Senior Scientist
....
-
Preceding Letter Sent To:
Mr. Al Carson
Department of Natural Resources
Pouch 7-005
Anchorage~ AK 99510
Mr. Bradley Smith
Environmental Assessment Division
National Marine Fisheries Service
Federal Building and U.S. Court House
701 C Street~ Box 43
Anchorage~ AK 99513
Mr. Michael Scott
District Fisheries Biologist u.s. Bureau of Land Management
4700 East 72nd Street
Anchorage, AK 99507
Mr. Gary Stackhouse
U.S. Fish and Wildlife Service
1011 East Tudor Road
Anchorage~ AK 99503
Mr. Carl Yanagawa
Regional Supervisor for Habitat Division
Alaska Department of Fish and Game
333 Raspberry Road
Anchorage, AK 99502
Ms. Judi Schwarz
Environmental Evaluation Branch
Mail Stop 443
U.S. Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, WA 98101
Mr. Lenny Cori n
U.S. Fish and Wildlife Service
733 West Fourth Avenue
Suite 101
Anchorage~ AK 99501
Ms. Judi Schwarz
Environmental Evaluation Branch
Mail Stop 443
U.S. Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, WA 98101
Dear Ms. Schwarz:
April 26, 1982
P5700.11.91
T1680
Susitna Hydroelectric Project
Fish and Wildlife Mitigation
Review Group Meeting
You are invited to attend the next meeting of the Susitna Hydroelectric Fish
and Wildlife Mitigation Review Group, to be held at 8:30a.m., May 17, 1982,
in Room C121 at the Federal Building, 6th and C Street, Anchorage, Alaska.
The purpose of this meeting will be to discuss the Draft Wildlife Mitigation
Options Paper mailed to you on April 21, 1982. Please review this document
prior to the meeting.
Thank you for your time and input.
cc: D. Wozniak, APA
ACRES AMERICAN INCORPORATED
Cc..nso..:::.ng Engi~.e-ers
1·_-·. __ .. ~-·.( .~;,_ ,._ ~r·~~ t=:_rF
'
Sincerely,
Mi chae 1 Grubb
Senior Scientist
-
-
-
, ....
LJ
Mr. Bradley Smith
Environmental Assessment Division
National Marine Fisheries Service
Federal Building and U.S. Court House
701 C Street, Box 43
Anchorage, AK 99513
Dear Mr. Smith:
April 26, 1982
P5700.11.91
T1682
Susitna Hydroelectric Project
Fish and Wildlife Mitigation
Review Group Meeting
You are invited to attend the next meeting of the Susitna Hydroelectric Fish
and Wildlife Mitigation Review Group, to be held at 8:30a.m., May 17, 1982,
in Room C121 at the Federal Building, 6th and C Street, Anchorage, Alaska.
The purpose of this meeting will be to discuss the Draft Wildlife Mitigation
Options Paper mailed to you on April 21, 1982. Please review this document
prior to the meeting.
Thank you for your time and input.
cc: D. Wozniak, APA
ACRES AMERICAN INCORPORATED
Consu!lmg Engineers
?;j"c:io r:e-~·. Yor..-. '7.~20.2
~ ,.. • r::... ; · , t· ..-: ·
Sincerely,
Michael Grubb
Senior Scientist
.,. .~ :-·· r:.: ...... I
: ; t •• ~~: ~ : : i'·~:.q_ i I r, ~ . I l~l:..~i. .. ~
Mr. Michael Scott
District Fisheries Biologist
U.S. Bureau of Land Management
4700 East 72nd Street
Anchorage, AK 99507
Dear Mr. Scott:
April 26, 1982
P5700.11.75
T1681
Susitna Hydroelectric Project
Fish and Wildlife Mitigation
Review Group Meeting
You are invited to attend the next meeting of the Susitna Hydroelectric Fish
and Wildlife Mitigation Review Group, to be held at 8:30a.m., May 17, 1982,
in Room C121 at the Federal Building, 6th and C Street, Anchorage, Alaska.
The purpose of this meeting will be to discuss the Draft Wildlife Mitigatior
Options Paper mailed to you on April 21, 1982. Please review this document
prior to the meeting.
Thank you for your time and input.
cc: D. Wozniak, APA
ACRES AMERICAN INCORPORATED
Con~ulli'>g Er.gineers
Th~ Libe-rty Ba~k BudC,ng t~•.~:r at C~utl
ec·"·. :c. t~r:''· Yo·~ 1::?')2
Sincerely,
Michael Grubb
Senior Scientist
-
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Mr. Al Carson
Alaska Department of Natural Resources
Pouch 7-005
Anchorage, AK 99510
Dear·Mr. Carson:
April 26, 1982
P5700.11.74
T1679
Susitna Hydroelectric Project
Fish and Wildlife Mitigation
Review Group Meeting
You are invited to attend the next meeting of the Susitna Hydroelectric Fish
and Wildlife Mitigation Review Group, to be held at 8:30 a.m., May 17, 1982,
in Room Cl21 at the Federal Building, 6th and C Street, Anchorage, Alaska. ,,
The purpose of this meeting will be to discuss the Draft Wildlife Mitigation
Options Paper mailed to you on April 21, 1982. Please review this document
prior to the meeting.
Thank you for your time and input.
cc: D. Wozniak, APA
ACRES AMERICAN INCORPORATED
Con~u!:ing Engineers
Tr,e Liberty eank Sui!dir.g. IM::., at Court
2ur:alo 1~~:.· .. Yor~ 14202
' T<'"' !.'1·f.(;<j 1-CRES !:UF
Sincerely,
Michael Grubb
Senior Scientist
Mr. Carl Yanugawa
Regional Superv1sor for Habitat 01vis1on
Alaska Department,of Fish and Game
333 Raspberr.y Road
Anchorage, AK 99502
April 27, 1982
PS700.11.70
T .. 1684
Dear carl: Susttna "'droeleetrfc Project
Fish and Wildlife Mitigation
Review Group Meeting
You are 1nvfted to attend the next meeting of the Susftna Hydroelectric
Ftsh and Wildlife Mitigation Revfew Group, to be held at 8:30 •·•·•
May 17 fn Room ClZl at th! Federal Buildtng, 6th and C Street, Anchor-
age. The purpose of thfs meeting will be to dfscuss the Draft Wild-
life Mitigation Options Paper mailed to you on Apr11 21, 1982. Please
review this document prior to the meeting.
The issue of quantiffcatfon of habftat loss wfll be discussed at a
workshop on May 18. This workshop will be attended by members of the
Susftna Wfldlffe Core Group and, because of the nature of the subject.
the U.S. Fish and Wildlife Service. Mr. Karl Schneider of your agency,
a member of the core group, wfll attend. I have asked him to contact
you regarding other members of ADF&G who may wtsh to attend. To keep
the meeting to a workable sfze, 1 have asked Karl to limit the number
of ADF&G attendees to three. ·
I look forward to seeing you on the 17th.
MG:db
cc: D. Wozniak, APA
E. Reed. TES
Sincerely.
Michael Grubb
Senior Sc1ent1st
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MINUTES OF May 13, 1982
Fisheries Mitigation Review Group
The meeting of the Fisheries Mitigation Review Group was held at the
Acres American Incorporated conference room on May 13, 1982. Or. John
Haydens Deputy Project Manager for the Susitna Hydroelectric, called
the meeting to order at 9:00 A.M. Those in attendance were:
Mr. Al Carson, Alaska Department of Natural Resources
Mr. Carl yanagawa, Habitat Divison, Alaska Department of fish
and Game
Mr. Ken Florey, Commercial Fish [)::ivision, A.D.F and Game
Mr. Tom Trent, Sus itna Hydro Aquatic Studies, A. D.F .. and Game
Mr. Mike Scott, Fisheries Biologist, Bureau of Land Management
District Office
Mr. Gary Stackhouse, U.S. Fish and Wildlife, Land and Water Department
Mr. Bill Wilsons Arctic Environmental Information and Data Center
Mr. larry Moulton, Woodward-Clyde
Mr. Allen Bingham, Susitna Hydro Aquatic Studiess A.D.F. and Game
Mr. Christopher Estes, Susitna Hydro Aquatic Studies, A.D.F. and
Game
Dr. Dana Schmidt, Susi tna Hydro Aquatic Studies, A.D. F. and Game
Dr~ John Hayden, AcPe.s ·.American Incorporated
Mr. Don Follows, Acres American Incorporated
Those absent were:
Mr. Brad Smith, National Marine Fisherie·s Service
Mr. Lennie Corin, U.S. Fish and Wild]ife Service
Mr. Paul Krasnowski, Fisheries Rehabilitation'Enhancement Development,
A. O.F. and Game
PURPOSE
The meeting was called by Dr. John Hayden to review the recent developments
in the management and organizational changes prompted by the need to
refocus disciplines towards a more productive and cooperative approach
of the common goals envisioned. Basically, the attached organizational
chart strives for improved coordination of the integrated studies required
for FERC licensing by separating primary responsibilities for scientific
investigation and data collections (pure science} from the management
and time constraints imposed by the Acres'American Incorporated on
behalf of the Alaska Power Authority. The new organizational approach
strives to allow more ·flexibility in designing critical data collection
programs required by the aquatic studies team while providing objectivity
through the data analysis and impact assessments component. This portion
of the program will be integrated through the close working relationship
of ADF&Game Arctic Environmental Information and Data Center. Working
hand-in-hand, this interrelated team will still meet critical production
milestones in the project schedule, but should be less pressured by
the mitigation planning and Exhibit E preparation deadlines.
To strive for improved data flow and professional integrity, the September
30th milestone for FERC license application is being relaxed. Negotiations
are still underway by Acres American Incorporated in the selection
of the ~ubcontractor to direct the mitigation planning. This entity
will be announced when the final selection is made.
PROBLEM
As with any project that deals with the diversity of resource and distance
from the various subcontractors~ Acres American Incorporated has suffered
from poor communications and a rumor mill that operates quicker ~han
actual management decisions.
In a sincere attempt to correct this situation, Dr. John Hayden is
personally moving his family to Anchorage, Alaska~ for closer contact
with the environment program and any potential problems that may need
addressing. Additionally, Acres American Incorporated has been actively
seeking to strengthen the environmenta.l team by employing companies
with previous Alaska experience.
By streamlining the chain of command and personal interactions, it
is hoped that the overall effort wi 11 become more productive and positive
in its approach to the tremendous task ahead. In dealing with personnel
problems, an attempt has been made to save individual e~pertise by
encouraging the best placement of the position within the overall framework
for professional contribution.
-ORGANIZATION MAY \3, l~8l
FISHERIES
A los~a Po\JeY Auttova~~ _ A cv~s Awaaicr.n Inco .. rov•ft.J
ERlC Youl.O t----.. ~-pRIME CoNTRACTOR
ov. ~ohn H4~deY\
L
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• • • • I I • • f~we.-1\\-n~ Constvllints
-
Because the process deals essentially with a variety of agency policy
mandates, both environmentally protective and regulatory in nature,
agency representatives have sensed some frustration in providing professional
input which goes beyond the administrative norms of the normal review
process. Yet the common bond created by this awareness and the sincere
efforts already contributed to the process are highly complimented.
Working together to mitigate environmental concerns within a truly
' unique State resource, while under the umbrella of social, economic,
and political realities, requires the full sensitivities and dedication
of all involved.
DISCUSSION
In the previous meeting, held on April 20, 1982, in the Acres American
Incorporated conference room, Dr. Dana Schmidt presented an excellent
paper on the proposed fisheries approach and mitigation plan. Since
then, Dr. Schmidt has decided his best input will be as a working member
of the Susitna Hydro Aquatic Studies team. He resigned from Acres
American Incorporated on May 3. Comments on the paper, either formally
or informally, will still be received by Dr. Hayden It is hoped that
they can be sent in by Friday, Hay 21st.
In a related management decision, Mr. Woody Trihey has submitted his
resignation from the company. His plans are still unknown at this .
time and the status of his fine instream flow work remains in question.
As a vital component of the fishery mitigation plan,' instream flow
work will continue in one form or another.
Recently Dr. Hayden and others attended a FERC workshop in Washington
D.C. to discuss the work and informally set the parameters for the
studies required. Such discussion was very helpful. Based on the
uncertainty of the full field season ahead and the viewpoint of resource
agencies, a recommendation is now being formulated for transmittal
to the Alaska Power Authority Board which will relax the September
submission date for license application.
Acres American in now in the process of pulling together a new fisheries
team (reflected in the organizational chart) to address anticipated
needs and to maximize benefits from the coming summer field season.
-
pm".l!,
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To dispel local rumors that Acres American Incorporated automatically
has the right to continue work on the next design and engineering phase
of the project, Dr. Hayden pointed out: in response to the questions,
that a Request for Qualifications for the next phase of the project
was released by the Power Authority on May 11, 1982. Acres American
will compete with other firms who have the full expertise in a large
project of this nature. Selection of the next prime contractor will
probably take place this fall. This Pahse II Contract will run from
the fall of 1982 to the time that the power is on line. Our company
will strive to maintain the continuity of the environmental program
so that undue disruption will not take place during changeovers. Acres
would hope to stay involved with the pursuit of the FERC license application.
While most of the other en vi ronmenta 1 studies will wind down· in scope)J
the ffsberfes and wildlife. programs .wi.ll basically continue towards
an acceptable mitigation plan which can be implemented prior to reservoir
fill i.ng~ Low.er levels of involvement wiJl be required in the environmental
subtasks as the project moves from the larger baseline studies to specific
applications of the mi.tigat'Lon plans.
Mr. Al Carson encouraged the continuation of the Susitna Steering Committee
as a mechanism to advise the Alaska Power Authority. Their function
could be to review and comment on the plans. Hopefully, the steering
committee~ operating from a higher level of authority, could contribute
directly to project decisions. A memorandum to the Alaska Power Authority
has been sent out for consideration.
Mr. Tom Trent expressed his past concerns over the "gray" area of responsiblity
which he felt had not been adequately defined between subcontractors
when it came to addressing fishery data analysis and impact assessments
in the past phase. This is an important area of concern. The products
need to be defined. Pure data collection alone is not enough. Close
coordination with the A.E.J~~-C. will be required to structure these
products in a mutually acceptable mode.
Mr. Ken Florey suggested that the previous pattern of review groups,
mitigation groups~ core teams and what all tended to confuse members
as to what their roles actually were.
Without a better understanding of the interrelationships of all these
groups and exactly what part each contributes to the overall process~
the individual becomes lost in the process. This is an excellent point
from the perspective of the prime contractor, who may have encouraged
more agency input than what could be realistically achieved. The suggestion
was made by the group to focus on the idea for a Steering Committee
to advise the A.P.A. at the higher level and to rely on the present
Fisheries Mitigation Group for the remainder of the input. Therefore,
only two review groups would be needed in the future.
Bill Wilson recognized the need to work closely with the Susitna Hydro
Aquatic Studies so as to provide one dynamic organization working from
two overlapping boxes of .responsibility. This will require teamwork
and constant interplay. Bill also expects to add some ~dditional expertise
to his team at A.E.I.D.C. ~
The group discussed various funding problems which are becoming a daily
concern. Mr. Trent mentio~ed that his team has anticipated needs and
is ready to run~ when and if~ the noney is appropri_ated. Mr. Carson
encouraged everyone. to flesh out the \tmrk program at various funding
levels so that when funding levels are known, the manager will h'ave
an immediate program response. The idea is to 1'hit the street running."
In summary, the mitigation review group felt that Acres American Incorporat~d
has recently reached more of the "listening" mode of response and that
they see an end to the two year period of basic frustration. Mr. Carson
expressed his belief that recently he has personally observed a change
in attitudes. Hopefully, the group can take that new creation of a
positive attitude about the project and carry it forward to its fruitful
camp let ion. ~li1y throug1J s.ucn posit f..ve. efforts can the evvtronmental
concerns of the project reach their achiev~ble goals.
Next week, Dr. Hayden will meet with Tom Trent to scope out the activities
of _the Susitna Hydro Aquatic Studies for thi_s coming fi.eld season.
The group adjourned at 10:50 a.m.
Respectively submitted:
Donald S. Follows, Acres American Incorporated
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MINUTES OF MEETING
held at the Federal Building
with the Bureau of Land Management
Anchorage, on Friday, May 21, 1982
SUSITNA HYDROELECTRIC PRQlECT
BLM Burn
PRESENT:
J. McMullen ) TES, Inc. E. Reed )
L. Byrne ) BLM-Glermallen M. Small )
L. Buoy )
M. See ) BLM -State Office
D. Taylor )
K. Rowdabaugh ) BLM -Anchorage District
R. Fleming ) APA
s. Fancy ) LGL Alaska
J. McKendrick ) University of Alaska
M. Grubb ) Acres
May 24, 1982
P5700.13.30
The purpose of the meeting was to discuss BLM's proposed Alphabet Hills
Burn and coordinate Susitna studies with BLM studies.
BLM views this as a management burn, not a research burn. The objective is
to kill off the spruce and produce browse for wintering moose. Weather
~ conditions required are 6-7 days of warm weather after August 15. The DEAR
is not yet completed, but Michael Small foresees no problem.
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BLM will be establishing transects and collect pre-and post-burn data. The
data will be species composition and percent cover along each 100 meter long
transect. Dr. Verick, from USFS Institute of Northern Forests, will also be
collecting vegetation data and measuring fire intensity.
Or. McKendrick (University of Alaska) outlinedAhis study which is to deter-
mine total vegetation response with browse as a priority item. He will
~ monitor soil nutrient response and measure fire intensity at the sample
sites. Sampling will be at 15 vegetation sites including 5 outside the burn
area. Biomass will be measured by life forms (browse, forbs, etc.}. Photos
for the area have been ordered, and mapping will be done at a 1:24,000 scale.
A meeting will be arranged for BLM/INF/University of Alaska to coordinate
location of study plots and data collection.
BLM requested a letter of agreement be drawn up between BLM and the Power
Authority. This should, basically, state who is doing what, where and why,
what information will be available, and what support will be provided. This
should be sent to Michael Small. For support, BLM requests:
1. Twenty hours of helicopter time before mid-July for cultural resource
personnel. ·
2. Helicopter support for vegetation studies. It is believed this can be
done concurrently with helicopter support required by University of
Alaska people. · ·
3. Helicopter support (approximately two 100 mile round trips by a 206 to
sling load and install a weather station between June 15 and July 1).
Michael Small will provide Michael Grubb with a list of BLM approved heli-
copter contractors. Michael Small will also supply a copy of the BLM DEIS
relating to mining, settlement options for BLM land south of the Alaska
range, and east of the Parks Highway.
MG:ccv
Reported by :)?'1 ~
M. Grubb
ALASKA POWER AUTHORITfUN 2 5 198 2
334 WEST 5th AVENUE-ANCHORAGE, ALASKA 99501
'L.. AU.~:: •. PCWER
AUII:GRITY
·' _SLS!1_~l:~
l Fl LE. P[ff• 't
-~Mr. Mike Small
S~QUENCE NO.I' Bureau of Land Management
I t 1//.e II _P.O. Box 147
_ Glennallen, Alaska 99588 z~ 2:! ~~
0 0 "" - ' I~,~ ~ ~ 1
1
. Subject: Draft ,.lemorandum of Under-
jl_ standing Alphabet Hills Burn
JOG t
June 22, 1982
Phone: (907) 277-7641
{907) 276-0001
:.-r--t-Thank you for your input during our telephone conversation on
1--1~-:--:=-lr----lJune 16, 1982. I have included your suggestions on the revised draft of
""""--1--+T-=:..'--'t-----!,the Memorandum of Understanding (MOU). We should proceed to have the
~MOU executed as rapidly as possible, so that studies can get underway.
~-1If the MOU is adequate, please initiate its being executed. If you have
, ......
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any questions or comments, please contact Richard Fleming at
(907} 277-7641.
-1---\
Sincerely,
~r:~~Ld~
Environmental Analyst J
t
cc: ~ John Hayden, Acres. Anchorage
Karl Schneider, AK Dept~-of Fish & Game
Jay McKendrick, Agricultural Experiment
Station
ALASKA POWER AUTHORITY
MEMORANDUM OF UNDERSTANDING
BETWEEN THE
ALASKA POWER AUTHORITY
AND THE
U.S. BUREAU OF LAND MANAGEMENT
PERTAINING TO COOPERATIVE INVESTIGATIONS OF
THE PROPOSED ALPHABET HILLS BURN PROJECT
WHEREAS, the Alaska Power Authority was established to reduce
consumer power costs arid otherwise to encourage the long-term
economic growth of the state, including the development of its
natural resources, through the establishment of power
projects; and
WHEREAS, the proposed Susitna Hydroelectric Project will affect
existing terrestri a 1 wi 1 dl ife hab·i tat by flooding portions of
the Upper Susitna Basin; and
WHEREAS, the Alaska Power Authority is committed to mitigating to the
extent possible this loss of wildlife habitat; and
WHEREAS, the use of fire through controlled burning may be an
applicable management tool for mitigating habitat loss by
improving habitat on other lands; and
WHEREAS, the effectiveness of burning as a management too'l is not fully
understood for areas similar to the Upper Susitna Basin; and
WHEREAS, the U.S. Bureau of Land Management is planning a burn in the
Alphabet Hills Region of Alaska;
NOW BE IT RESOLVED THAT it is in the best interest of the State for the
Alaska Power Authority and the U.S. Bureau of Land Management
to cooperate in determ·ining the nature and magnitude of the
effects on soils, vegetation, and wildlife which occur as the
result of the burn in the Alphabet Hills so that the
effectiveness of burning as a management technique can be
determined, thereby aiding in the deve 1 opment of a wi 1 dl i fe
mitigation plan for the Susitna Hydroelectric Project;
AND THEREFORE, it is the purpose of the Alaska Power Authority and the
U.S. Bureau of Land Management to enter into this agreement,
to wit:
1. The Alaska Power Authority and its contractors and the
U.S. Bureau of Land Management will work together to
monitor the effectiveness of fire as a method of managing
habitat in the Alphabet Hills area~ These studies
address the use of large scale controlled burns for the
management of wildlife habitat.
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2. The Alaska Power Authority will provide helicopter
support to the U.S. Bureau of Land Management for the
purpose of studying vegetation and cultural resources in
the Alphabet Hills burn study area and for establishing a
weather station. This helicopter support shall not
exceed 40 hours for U.S. Bureau of Land Management
personnel only. The company supplying the helicopter and
pilot will be subject to the U.S. Bureau of Land
Management approval.
3. The U.S. Bureau of Land Management will initiate a burn
in the Alphabet Hills region during August, 1982. If
weather or operati ana 1 constraints prevent a successful
burn during August, 1982~ then the Bureau will attempt
the burn in August~ 1983, provided appropriate conditions
occur. A successful burn shell be defined as one that
includes at least 25% of the presampled vegetation plots.
4. The U.S. Bureau of land Management will allow personnel
of the Alaska Power Authority and its subcontractors to
conduct vegetation, soil, and wildlife studies on the
land owned and managed by the U.S. Bureau of Land
Management in the burn study area.
5. All data collected by the Alaska Power Authority and its
contractors in the course of monitoring the effects of
the burn will be available to the U.S. Bureau of land
Management. All data collected by the U.S. Bureau of
Land Management in the course of monitoring the effects
of the burn will be available to the Alaska Power
Authority and its contractors.
6. The terms of this agreement do· not relieve either agency
from its legislated responsibilities.
7. This agreement may be amended at any time or terminated
by either of the parties following forty-five (45) days
written notification or within a lesser period by mutual
consent of both parties.
Eric P. Yould
Executive Director
Alaska Power Authority
U.S. Bureau of Land Management
Date Date
Susitna Hydroelectric Project
Fish and Wildlife Mitigation
Review Group Meeting
Date: May 17, 1982
Attendees: See Attached List
Held at Federal Building, Anchorage
May 25, 1982
The purpose of the meeting was to discuss the April 1982 Draft Wildlife
Mitigation option paper prepared by TES. Comments were as follows:
1. The best way to determine brown bear response to new roads
will be expert opinion. (USFWS)
2. FERC has changed EIS format to include alternatives Exhibit
E requirements not changed. APA should get most recent FERC
EIS. (APA)
3. Money spent for clearing may be better spent elsewhere.
Is this considered a mitigation cost? (USFWS)
4. The option of no recreation or designation of the area as a
wilderness should be considered a mitigation option. This
would reduce or avoid many of the access-caused impacts. (USFWS)
5. ADF&G asked for policy on access, will they favor consumptive
use? Agencies should express their opinion on what they want
done. (APA)
6. Some type of matrix should be developed for trade-off of re-
creation use vs wilderness and other considerations. (APA)
7. Peregrine falcon issue will require official correspondence
with USFWS. Contact a Dennis Money at Ecological Services. (USFWS)
8. Bald Eagle nests in reservoir area may be protected by Bald
Eagle Act. Mitigation plan should include what integration
has occurred with fisheries study. Will there be a reservoir
fishery? (US FWS)
9. We should look at Ashetna-Tyone area as mitigation land areas;
also along Denali Highway. (USFWS)
10. Mineral closures and other zoning laws may be used to protect
replacement lands without having to manage. (ADF&G)
11. Issue of predator-moose-burning issue was discussed. If burn
for moose who are impacted by bears then why mitigate for bears?
12. An artificial lick should be established prior to inundation
to acclimate sheep to use it. Could water levels be manipulated
to preserve the lick? (ADF&G-USFWS)
13. Agreement should be reached from all agencies on proper pro-
tection to take for new caribou calving ground before it is
established. This would include prevention of mining, settling,
ORV use, etc. There should be a contingency plan for all sec-
tions. (USFWS)
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Page 2
14. APA should determine what BLM and ADNR are planning to do with
land in Denali access route area. This also relates to land
replacement and caribou land replacement bill. (APA)
15. Entire issue of construction camp configuration, operating mode
and rail use road access was again discussed. These should not
be accepted as givens in the mitigation options but scenarios
presented which would avoid impacts. Example -flying people
in and out daily instead of construction camps, etc. Then show
if it is not cost effective. (USFWS)
16. For safety of people and dogs, dogs should not be allowed in
camp. ( USFWS) '
17. It is important restrictions are enforced {speed limits, ORV's,
etc.).
18. Type 2 impacts: It was requested that justification should be
presented as to why dropping pool elevation cannot be done.
Should be presented as a mitigation option then dismissed if
economics shows it. (USFWS).
19. Option of creating flooding every 10-15 years by opening flood
gates was discussed. This would be to simulate natural flooding.
However, would wipe out fishery mitigation. USFWS sees no problem
with downstream vegetation changes but wants information to sub-
stantiate it.
20. Transmission line mitigation lacking in mitigation plan. Needs
to be beefed up.
21. Research station should be considered only as low priority; only
for compensation.
MMG:dlp
NAME
Mi chae 1 Grubb
Tom Arminski
Richard Fleming
Don Follows
Joe McMullen
Ed Reed
Leonard P. Corin
Gary Stackhouse
David D. Wozniak
ATTENDEES
May 17, 1982
REPRESENTING
Acres American
ADF&G
APA
Acres American
TES
TES
USFWS
USFWS
APA
A+-k~~
____ M_ ~-'1-J.l __ .I _t! --~----
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-~~~ --------_d~~--~----
___ .j_~£_/1_5/fq~"-~P-------~----------------------____ -~E5.,./;_,c.~----____________ _
-c./ ~~~-.; 765 ~ ---~ ----··------·'--~-----------------.. ------------·----------------.. .1 ------------------·
----_iA~, ~~,~-~~-------
t! 5FtJ S
----.. -----/f (/ /} .
~ . ' :
= .. ~ '-· .. 0. ~: --
Mre Lenny Carin
U.S. Fish and Wildlife Seruice
733 West 4th Avenue
Suite 101
Anchorage, Alaska 99501
Dear Mr. Corin:
June 1 p 1982
P5700.11 .. 71
Tl726
Susitna .Hydroe 1 ectri c Project
Wildlife Mitigation Planning
Thank you for attending the May 18th meeting to discuss the objectives and
general approach for a terrestrial habitat evaluation system for the Susitna
project.
Due to the change in environmental consultants, we have not yet formalized a
plan for further development of this system. We will be contacting you
shortly and ask for your patience in this matter.
Thank you again for your input.
MG/jk
cc: R. Fleming, APA
ACRES AMERICAN INCORPORATED
Cc,nsu:ting Er.gineers
r ' ...... r . ' j ' r__ •. ~~ •• < • ' t :c \'::_I '
Sincerely,
Michael Grubb
Senior Scientist
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Preceeding Letter Sent To:
Mr 1 Lenny Cori n
U.S. Fish and Wildlife Service
733 West 4th Avenue
Anchorage, AK 99501
Mr. Greg Konkel
U.S. Fish and Wildlife Service
lOll East Tudor Road
Anchorage, AK 99503
Ms. Ann Rappaport
U.S. Fish and Wildlife Service
733 West 4th Avenue
Anchorage, AK 99501
Mr. Gary Stackhouse
U.S. Fish and Wildlife Service
1011 East Tudor Road .
Anchorage, AK 99502
Mr. Kark Schneider
Alaska Department of Fish and
Game
333 Raspberry Road
Anchorage, AK 99502
(-::--~
-I ... \. . ; .
..... -
' I
DEP.'\RT .''IE~T Ot' FISII .-\ :"il) G.-\ .lit: I
!
OFfiCE OF THE COMMISSIONER I
! JA Y S. JIAMMOIID. GOVERNOR
P.O. SOX 3·2000
JUNEAU. ALASKA 99802
PHONE:
July 27, 1982 i"'l E c 1: I \ ~ o..J
,• .. ,-
Mr. Eric Yould
Executive Director
Alaska Power Authority
334 West Fifth Avenue
Anchorage, Alaska 99501
Dear Mr. Yould:
~ The Alaska Department of Fish and Game has been involved with the
Mitigation Review Group in attempting to fonnulate a workplan that
would eventually arrive at mitigative solutions to probable adverse
impacts to fish, wildlife and their habitat resulting from the Susitna
Hydroelectric project. Internally, my Department is also analyzing an
array of mitigation options that may be acceptable if they are
demonstrated to be workable and satisfy the Department•s mandate to
mitigate adverse impacts. The following is a list of options•that we
hope the Alaska Power Authority is considering as part of their
mitigation planning.
I must emphasize that these are by no means the only options that should
be considered. In addition, because environmental studies to assess
impacts of the proposed project are incomplete and specific mitigation
plans have not been identified, these suggested mitigation options
either individual1y or collectively may not satisfy the.requirements of
this Department. However, we believe that they should be evaluated now
so that data regarding feasibility and desirability are available when
project impacts have been quantified.
By evaluating these mitigation options concurrently with ongoing impact
assessment studies, we believe that considerable time will be saved in
completing the permitting and licensing process.
1. Fisheries
a. Instream flows required to maintain present populations
of fish below the two dams should be carefully eva 1 uated.
Included in this evaluation should be an array of flow
regimes that~ when considered with the anticipated loss
of fish habitat associated with each, cou1d be a basis
for further mitigation measures. The areas immediately
below the dam sites, as well as areas further downstream,
should be included. Temperature regimes should also be
I'"'"
....
Eric Yould -2-July 27, 1982
eva 1 uated concurrently with stream fl C\'IS. These
ev~luations should be made on construction as well as
operational temperature and flow regimes.
.... If it appears that onsite mitigation of fisheries impacts
cannot be accomplished, hatcheries should be considered.
Locations of possible hatchery sites should be identified
in accordance with my Department•s policies on
artificial production of fish. My Department•s Fisheries
Rehabilitation Enhancement and Development (FRED) staff
has considerable expertise in selecting sites and
designing hatcheries in coordination with other Divisions
of my Department. I \'lould suggest that the FRED Division
be contracted immediately to do the site evaluations. A
specific proposal is enclosed.
c. My Department has been funded by the Legislature to study
the salmon enhancement potential of the upper Susitna
River without respect to the project. In the case where
mitigation of fisheries impacts cannot be.mitigated
within the project area, enhancement of the Upper Susitna
system may present a viable option. Results from this
study will be made available to you and should be
included in the array of options for mitigation.
2. Hildlife
a. Habitat enhancement options for wildlife species should
be evaluated. For example, habitat manipulation to
enhance moose browse could be considered in areas where
present habitat is considered 1 ow in productivity.· This
option would need to consider the long-term effectiveness
of the project, since moose browse is only available at
early successional stages.
b. Replacement lands should be considered as another option.
Lands outside the development area (preferably adjacent
to the development} should be identified and possibly set
aside by legislative designation for the purpose of
mitigating wildlife habitat losses from the project •
This option may be the most viable option for wildlife.
3. Both Fish and Wildlife
a. Impacts from construction and maintenance of the
transmission and road corridors should also be evaluated.
As I have stated previously, the above list is to be used in developing
a total mitigation package and is transmitted for that purpose.
The following briefly sumnarizes my Oepartment•s hierarchial approach to
implementation of mitigation {mitigation policy enclosed):
Eric Yould -3-July 27, 1982
1. Avoiding the impact altogether by not taking a certain action
or parts of an action;
2. Minimizing impacts by limiting the degree or magnitude of the
action or its implementation;
3. Rectifying the impact by repairing, rehabilitating, or
restoring the affected environment; '
4. Reducing or eliminating the impact over time by preservation
and maintenance operations during the life of the action; and
5. Compensating for the impact by replacing or providing
substitute resources or environments.
If you have any questions, please feel free to contact me.
Sincerely,
Ronald 0. Skoog
Co11111issioner
Enclosures (2)
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Alaska Depar~ment of Fish & Game
F.R.E.D. Division
PROJECT PROPOSAL
I. Title: Susitua River Hatchery Site Investigation
II. Description:
r
1. Objective: Identify locations of possible hatchery sites in
the vicinicy of the Susicna River.
2. Ti.meframe: July 1, 1982 -June 30, 1984
III. Justification: If the Susitna Hydroelectric Project is determined
to have a negative impact on existing salmon povuJ.a.tious in the Susit:na
R:iver, various uasures may be employed to mitigate this imi'act. A fi.sb
hatchery is an option that could be used to supplement or replace
natural producti.on. '!he potent:ia.l for successfully employing thi.s
ovtion depends on the species of salmon involved and. the avai.labili.cy of
good hatchery sites.
A. critical stel) in the planning pha.se of develoving a fish hatchery is
the systematic and careful selection of an al)proprlate site. The key
fac'tor, of course, is to fi.n.d a location, with a rel.iable and adequa'Ce
wa'ter ·supply. In addi.tion, this water supply should be located where
logisti~ problems can be minimized. Broods'toc:k.s must be iden'ti.fied
an.d developed.
Strategies for produc:'tion releases must be considered al,ld the management
of returning stocks mu.st be biologically sound.
Since the seleetiou proc:e.ss for a hatchery site is, perhaps, the most
critical step in the development of a successful hatchery, it is
tmpor'tant to collect thoroagh and detailed information. This process
requires at least two years. Dud.ag the first year, a large number and
a wide variety of sites w:U.l be screened and the most likely candidate
sites will be selected. During the second year, these priJ:ary sites
will be investigated UlOre intensively·.
IV. Methods and Procedures:
A. First year: During the first year of the hatchery site
selection survey, a large number of system& will be surveyed
and categori.:z:ed to assess thel.r value as a possible hatchery
site. Ini.tially, ADF&G files will be examined and discussions
held nth other study groups to determ:i.ue which systems will
be surveyed. Available data will be evaluated and data needs
will be.identiiiid. Field surveys ~~ll theu.be mobilized eo
collect: the pettittent: infomation so that the best candidates
can be selected for fur1:her studies. Data to be collected
will include: wacer source, size of the wacer source, water
teul.lJeratures, thorough water chemist:1:y, land s'ta.tus.
engineering analysis. fish stocks present, logistics, basic
management considerations, and potential broodstocka. A
minimum crf one field survey will be conducted at each
potential site. By the end of the first year of the survey,
the Eour most likely hatchery sites will be identified.
During the second year of this hatchery site selection survey,
the most likely hatchery site candidates will be studied more
thoroughly. They will be monitored much more frequently or
continuously. It is particularly important to determine the
~eliability and predictability of the water supply, the water
temperature, and the water chemistry. The suitability for
construction will be analyzed. The size, location, and
availability of particular broodstocks will be ~erified.
Stocking strategies will becdetermined and the most likely
management schemes for returning adults will be developed.
By the end of the second year, the best site will have been
identified. Approximate costs and a preliminary development
schedule will be provided. !he potential for successfully
producing the ~arious species will be analyzed and
recommendations given on alternatives to explore should a
hatchery not appear to be a feasible method for replacing
expected losses of a particular species.
V. Personnel:
VI.
A. Project Leader: Fishery Biologist IV, F.R.E.D Division.
B. Schedule:
Fishery Biologist IV
Fishery Biologist III
Fishery Technician III
Engineer
Cost:
"Line 100
Salaries: FB IV
FB III
FT III
Engineer CE II
Line 200
Travel & per diem
Line 300
A:i.r charter -
fixed wing. $180/hr x 25 hrs
$500/hr x 10 hrs
First Year
4 man months
7 man months
3 man months
2 man months
First Year
21,000
37,700
7,700
9,700
500
4,500
5,000
x 30 hrs
x 14 hrs
Second Year
4 man
8 man
5 man
4 man
Second
21,000
43,200
12,800
19,500
600
5,400
7,000
months
months
months
months
Year
Line 300 cont.
Vehicle m:i.leage 800 900
Vehicle rental 1,000 1,000
Telephone and photoco~y 500 500
Photo processing 200 200
J~ W'at:er analysis 2,500 4,000
Line 400
Scient:ific s1.;pplies
(e.g. chemi.c:al.s) 200 300
Film 100 100
Gasoline (outboard) 100 100
Supplies 600 800
Line 500
Mon:Lt:oring equipment: 3,000 -TOTALS: 92.1 120.1
ALASKA DEPARTMENT OF FISH AND GAME
STATEMENT OF POLICY
ON MITIGATION
OF FISH AND GAME HABITAT DISRUPTIONS
Prepared March 1982
ALASKA DEPARTMENT OF FISH AND GAME
Statement of Policy
an
Mitigation of Fish and Game Habitat Disruptions
I. The ~eed for Policy
Logging, construction, mining, agriculture, and other developmental industries
r which use land· or watar are of great importance. to many Alaskans. When
-properly pur'Sued, these undertakings can be compatible with proper management
and use of A 1 aska • s va 1 uab 1 e fish and game resources. However, improper
practices can lead to significant degradation of the State• s fisheries and
game resources through alteration or destruction of important habitat
components.
-Development includes a multitude of practices such as road building, bridge
construction, culvert placing, excavation, dredging,. clearing, dragging,
dumping, and other activities. At issue is 1 and and water, the very bases of
all development and all fish and wildlife habitat. Each development action
requires space, and thereby a 1 ters fish and game habitat and compromises other
types of uses. Development activities, when disruptive to fish or wildlife
resources, may, for ·example, increase erosion or sedimentation, divert,
obstruct, alter, or pollute water flow, aggravate temperature extremes, alter
and destroy populations of animals and vegetation, reduce food supplies,
restrict movement of fish and game, disturb or destroy spawning, nesting· and
breeding areas, change adjacent or downstream habitats, or change the capacity
of a stream or wetland to store and use stonn or fiood waten.
Often, such habitat losses are inevitable and little can be done to prevent or
control them, but often they can, in the public interest, be abated or
_,-
"mitigated." The avera 11 mitigative goa 1 of the Department of Fish and Game
is to maintain or establish an ecosystem~ the project in place that is as
nearly desirable as the ecosystem that would have been there in the absence of
that project. The decision levels through which a project is reviewed -
preventing, minimizing, and replacing ecosystems -is outlined and discussed
in t.,i s po 1 icy~
The magnitude of devel opmenta 1 inf1 uences on fish and game habitat is to a
large extent dependent on the ~'!grse· to which development operations and
faci1 ities and land or water use projects are properly planned and upon the
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consc1 ent1 ous adhe~nce to practices designed to protect fi sheri es and wi 1 d-
1ife values. Therefore, it is the primary objective of the Department of Fish
and Game that fish, game and habitat values be prominently considered by
developers and regulatory agencies prior to development or issuance of regula-.
tory approvals. Consideration should take place during the planning and
implementation of land or water associated development to avoid or minimize
foreseeable or potential adverse environmental effects before the fact of
damage, and early enough to consider beneficial a 1 ternatives. Simi 1 arly, it
is imperative to provide for repair, restoration, or rehabilitation of habitat
damage after it occurs, should it occur at a 11 , as well as maintenance of the
reconstructed habitat over time. However,. it is appropriate that this option
of after-the-fact redress assume a second priority status to mitigation
planning before the fact of damage.
These concepts--preventing, minimizing, replacing~hen ~molded into a worting
definition of mitigation, will contribute to the sustained functioning of
aquatic and terrestrial systems, and the continued viability of common
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property fish and game resources, •,o~hi 1 e provi rt'!ng for the ather ne~.js of
Alaskans arising from beneficial public land and water use programs. A
mitigation po1icy, therefore, is essential to ouide, ~ ~, deve1opment
actions by insuring considerations of alternatives to or in 1and and water
conversi ans and to fu 1 fi 1 1 the sustained yi e 1 d management precepts of A 1 asl<a
law.
II. Authority
The Department's basic responsibi1ity as a conservation. agency derives from
the Conmissioner's authority to manage, prote~t., maintain, improve, and extend
fish, game, and aquatic plant T"T!sources of the State ~AS 16.05.020). This
Statute, in combination with constitutional direi:tives, provides imp1icit
direction for the Department to offset losses to fish, wildlife, and their
habitat ..
The Department's responsibility to impose mitigation measures also derives
from the same laws which authorize it to issue written approvals (permits) fa~
land or water use_prognms. In each instance the developer must obtain the
Department's approvaT .as the sufficiency Qf the developerJ s plans to provide
fer fne passage of fish (AS 16.05.840-), or provide. proper protection to fish
and game when conducting projei:ts in anadromous fish streams (AS 16.05.870),
State game refuges (AS 16.20.060), State game sanctuaries (AS l6.ZO.l20}, the
natural habi.tat of endangered species (AS 1'6.20.185), fish and game critical
habitat areas (AS 16.20.Z60), and State range areas (AS 16.20.300-320).
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Simultaneously, a strong basis for prescr~bing mitigation lies in the public
trust doctrine. In simple tenns, this doctrine, founde.cf in common law,
asserts the pub 1 i c' s right to unimpaired use of pub 1 i c 1 ands and waters for
fish and wildlife production. The Department, as trustee for the public, is
obligated to protect'that right. The public trust doctrine t~us provides
additional· ability as well as an obl igatian to be, rigorous in mitigating
disruptions to public fish and wildlife resources. including their habitat.
III. Statement of Policy
A. Definition
The directive to mitigate is clear. The nature of and extent to which
mitigation is carried aut is left to the Department 1 s discretion. In
considering mitigatory options it is essential· to recognize the differing_
degrees of stress that may be place.cf on natural fish and wildlife
habitat. Lightly-stresse.cf aquatic or terr!strial systems adjust to
change, and recovery takes place through natura 1 processes when the ·
stress is removed. In contrast, a heavily or overstressed natural system
cannot· restore itself to original conditions through natur-al processes
alone. In this case, the system's capacity for maintenanc~ and repair
has been impeded, and at this point man must provide assistance for the
system to be restored. These differences in recovery potentials dictate
different Pr:"iority approaches to implementing mitigation measures.
Accordingly, the Department of Fish and Game, when administering miti-
aation measures oursuant to its permit authority under AS 16, embraces
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the defi ni ti on of mi ti ga ti Ol"! ~romu 1 gated in the Federa 1 regu 1 a ti ons ( 40
CFR 1508.20) which effectuate the National Environmental Policy Act (42
U.S.C. 4321 et seq.). Mitigation includes, in· orioritv order of iiY1lJle-
mentation:
( 1) avoiding the impact a 1 together by not taking a certain action or
·parts of an action;
(Z) minimizing impacts by 1 imiting the de9ree or magnitude of the action
or its implementation;
(3) ' rectifying the inrpact by repairing, rehabilitating, or restoring the
affected environment;
(4) reducing or elimin:ating the impact over time by preservation and
maintenance operations during the life of the action;
(5) compensating for the impac~ by replacing or providing substitute
resources or environments •
. a. ImolP.mentation
rne Department will implement the five· fonns of mitigation punuant to
its statutory autho.rity in the fo11 awing manner~
1. Mitigation to Avoid or Minimize Habitat Damage
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a. Avoidance
The Oepartment 1 S primary approach to mitigation is one of oreventive
ccnservati on designed to avoid an evershri nki ng base of natura 1
habitats and costly man-~ssisted restoration efforts. rt i~ founded
on preventing adverse, predi ctab 1 e ,. and irreversible trends or
changes in natural aquatic or terrestrial systems. rne objective is
to maintain as much existing natural habitat as possible, even if
the relative importance or interrelationships of living organisms
are not fu 11 y known. Apart from denying outright the i ssuance of a
permrit, this can be accomplished by attaching stipulations or
conditions to pernsi ts for proposed deve 1 apments.. Oi senti an at the
field level is required to allow tailoring of various developmental
activities to sites and times for maintenance of individual or
groups of fish and game species and various habitats used annually
or seasonally. Mitigation by permit stipulation can be employed to
avoid activities in areas with a high risk of adverse impact, such
as nest sites, winter ranges, or critical habitat. Development
consistent with the objectives for designated areas can proceed
according to the stipulations or conditions. rnis fundamental
approach provides for beneficial land and water use programs in
natura 1 systems.
b. Minimization
This concept differs from avoidance in that it is acknowledge? that
some habitat damage will occur. The Oepartmen~ recognizes that land
and wate:-deve 1 opment projects are mandated by pub 1 i c need,
1 egi sl ative
pervading
or constitutional prioritization
economic considerations. It is
or land use, or
recognized that
industrial, agricultural and residential development in Alaska will
cause some amount of habitat destruction, and t~at this damage has~
been accepted by developers and pal icy makers as the price of
economnc benefit. The second priority mitigative approach to
habitat management is to make that 1 ass 1 ess sever-e, or to minimize
foresee~ble disMJptions to aquatic and terrestrial systems. The
focus of this approach is to maintain habitat diversity and the
capacity of each system to restore itsalf naturally from stress or·
damaqe, while accomnodating preemptive uses o'f land and waters
frequented by fish and wi 1 dl i fe -uses which may reduce species
abundance to some degree or cause some disturbance ·to natura.!
species behavior.
Minimal adverse habitat disruption may be· achieved by permrit
stipulati-ons which 1 imit development actions when and where
necessary and to the extent needed to ma.ximnze conservation of fish
and wildlife va 1 ues. For example,_ tempera 1 mitigation measures.,
which involve adjusting the timing of project activities to reduce
impacts in areas of high risk, cah be used to restrict development
to the seasons when the impact is least, or to reduce the amount of
time spent in a sensitive· area. Habitat . may be stressed
tetl11lorarily, but recovery can take place through no-cost natural
processes.
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2. ~itigation In "Lieu of Habitat Damage
a. Rectification
ThE!' third priority mitigative approach is to reoair, rehabilitate,
or restore· abused aquatic or terrestrial, systems. This requires
ansite or post-construction evaluations of water and land
developments after· the fact of damage, or estimation, during the
planning stage, of likely environmental damage. Rectification is
less desirable than avoidance or minimization because, even .if
restoration is complete, there is a net lass of fish and wildlife
resourt=e and habitat resulting from the time lag between the impact
and full replacement. Such time lags may vary mm days to decades.
Thus, gains or benefits to be realized fT"'m this fonn of mitigation
are somewhat less than those of full prevent1 an.
The objective is to restore the same functions as those that were
lost.,. or, to restore the habitat to pre-disturbance conditions.
However, if the factor restricting the number of a species_using an
area is also limited further by the development, it makes little
sense to devise and implement facton which cannot alleviate that
~ituation. Additionally, the simplistic view of maximizing one kind
of habitat at the expense of another should be avoided. The
Department recognizes that there will be situations where no
rehabilitation of the loss incurred is possible.
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If proper planning occurred and rectification was not considered
necessary, rectification should only be necessary when the developer
has. not complied •,o~ith his plan, applicable laws, permit
stipulations. Rectification of disruptions to habitat may be
implemented through permit stipulations and amendments or imposed as
a court ordered penalty. It is 1 ikely that. many completed or
partially completed projects can be retrofitted wi·th feasible
restoration requirements that could result in the reeoverJ of
substantial ·amounts of project-caused fish and wildlife losses.
b. Preservation and Maintenance Actions
Mitigation should be recognized as a cont.inuing obligation,
inextricably tied to a project and carried out during the entire
1 ife of the project. The Department recognizes. that if mitigation
measures are approved but not ooerated and maintained during the
life of the project, 1 ittle or no mitigation, which may have helped
justify the project in the first place, wi11 be realized. The
Department holds to the principle that costs of mitigation are all
nonnal costs of any land or water. development project ·and must be·
borne by the develop~rs and beneficiaries of the project.
Preservation and maintenance operations may be imposed through
pennit stipulations or amendments to pennits. For example, drainage
structures instal led__.An fish streams should be required to be
~intained properly; and erosion must be corrected when it occurs.
Re.veqetated areas wbi ch are not successful, for whatever reason;
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must be revegetated until they have become estab1ished. In these
ways, adverse impacts wil1 be reduced or eliminated over time.
A requirement (or pennit stipulation) tha't developers continue to
mitigate by maintenance operations during the 1ife of the project
wi 11 ensure tnat conseroiati on objectives . are rnei; and 1 iti gati on ; s
avoided.
c. Compensation
~henever a project will cause a reduction or loss of values to the
public-losses in tenns of fish and wildlife populations or habitat 7 .
recreation opportunities, access, and other foregone resource use·
opportunities--the project sponsor must create or restore an equi-
valent part of the aquatic or terrestrial ecosystem' to comcensate
for the 1 ass. The most di ffi cu 1 t prob 1 em encountered with this
approach is detenni ni ng what kind of action is appropriate and how
much mitigation is adequate. The problem can be resolved qualita-
tively, throuah neaotiation and quantitatively through the
estab 1 i shment of eva 1 uati on procedures.
It· is the Oe~artment• s position that co~ensation should not involve
a simple payment of dollars, but instead should involve replacament
of lost habitat, populations or recreational opportunities.
Compensation by replacing or providing substitute resources or
environments is the least desirable fonn of mitigati-on because it
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accepts loss of habitat at the outset and and often cannot result in
total reparation for those losses. When it must be implemented 7
however, the preferred fonn of compensation is onsite mitigation;
that i.s, all damage caused by a project should be replaced within
th~ development site or project area where damage occurs. The same
functions as an!-lost should be directly restore~; replaced, or
compensated .. Only secondarily should compensation by substitution,
or trade-off of . an unavoidable ·eccl ogica I 1 ass for an ecol ogica 1
improvement e1 sewhere, be . used. Trade-<lffs or conversi ans only
change one kind of' envtronment for another, and may be desirable or
not, depending upon the viewpoint considered. There are diver9~nt
views· and interests. between 1 oca 1 and more di stan't users regan:iing
the value of the ecological ••;mprovement 11 to the natural system that
was already in place.
·Any type of compensation wi 11 be costly, and the va 1 ues of 1 ost
resourees cannot be measured solely through economic cost/benefit
ratios or man-<fay evaluations. This sort of analysis must be
accompanied by evaluations which measure factors other than human
uses of 1 and, water, and the resources within. The va 1 ue of the
interdependent biologica1 relationships within an entire ecosystem
is too often ignored. Since some ecosystems, such as wetlands, may
never be successfully replaced or substituted, it is important that
the land owner, developer, and the various g~vernment agencies •,o~ari:
together to salvage such 1ands to. rectify the loss of the resouree
values of those areas. The Department recognizes, however, that in
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some rare casas, the only compensation negotiable may be prevention
of future losses in another or adjacent area.
C. The Role of Plannina
Proper mitigatiarT of fish and game habitat los~as requires that land and
water use projects be properly designed and planned. This requires basic
decisions by field personnel at the earliest project conceptualization or
design state, before permits are issued.
Proper planning, particularly at the area or re9ional level. will assist
in abating a conman cause of fish and wi1d1 ife habitat decline, that of
piecemeal habita~ lasses which cumulate from sequential projects.
R29ional or area planning, when it prece<ies significant land or water use
programs, will allow reduction of the cumulative effects resulting from a
variety of. projects.
Prior to pennit issuance there should be a realistic assessment of the
specific ,·lasses which likely will be incurred~ rne lasses should be
i denti fi ed first in terms of 1 ost resources and second 1 v in terms of the
uses which may be foreqone. This is because human use and resource
productivity do not always correlate. The Department cannot accept
analyses which equate low human use figures to low estimates of losses.
Low human use has no bearing on how much fish, wildlife, o.r their habitat
may have been 1 ast; or how much productivity, biological diversity or
critical procasses were impaired. However, the lass of .human use should
be a factor that will need to be mitigated.
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Losses of fish and wildlife habitat that cannot be mitigated will affect
the peocle who utilize those resources. ~Jherever the carrying capacity
of the land or water is reduced, harvest of species by subsistence,
ccrrmercial, a·nd reeraational users may have to be reduced. Recreational
opportunities to view resources may also deeline. As the population of
the State of Alaska increases, ccmpeti.tion for fish and game resources
will surely increase. Decreased abundance of these resources will mean
that some resource users wi 11 get 1 ess of the resource than they may have
had in the past. · As more and more habitat is damaged or 1 ost, the
prob 1 em of a growing popu 1 a ti on base and its pressure on fish and
wildlife, will be aggravated.
The impacts of a proposed project and alternatives ·to it on all the
natural resources affected. therefore, should be assessed early in the
project planning process. The effects of a· project on ather resources,
such as timber or water, and human use should be assessed, as well as the
direct effect on fish and wildlife. Nonstructural alternatives, e.g.,
providing minimum stream flows rather than a hatchery to maintain a· .
population of fish, for achieving the project. objective should be
required and. considered first since these caul d be expected to have the
least negative impact on the ability of the project area to provide
natural resource values.
Including consideration of all natural resourcas early in the planning
process shou 1 d 1 ead to deve1 oprnent of ways to minimize effects on these .
resourees in all phases of pro~ect development and reduce the nee<! to
later add on the more costly, canspicuous, and less desirabl!! remedies
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after the fact of damage. rne specific p~perties and characteristics ~f
the natural system which must remain after development should be defined
prior to initial permit issuance. The developer is then al1owed to
proceed with the project under pre-established mitigation measures, which
will guarantee functioning of a natural system and not cause permanent or
costly public harm.
0. Assessment of Oama~es
The combination of population pressures, diminishing space, energy needs,
and the necessity of considering economic variables in most decisions
t.ave a11 culminated in questions regarding the intrinsic values of man•s
surroundings. Attempting to place price tags on an area•s worth, whether
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in t~rms of its retention as a natural system or its value in an altered
condition, is inherently difficult.
The state of the art in habitat valuation will lag behind the need to
make permit decisions. The Department holds that fish and wildlife
habitat should be preserved unless the expected benefits of the develop-
ment is demonstrably ••large•• relative to loss of fish and wildlife
values. Of course, what is deemed acceptable must be a broad social
decision which necessarily ·requires assessment of the resource damage
1 ike 1 y to be i ncun-e<i as a res.u 1 t of the deve 1 opment.
In theory, it would seem a simple matter to ob$erve the impact of a .
construction pr1lject, determine if fish or wildlife are killed, and then
assess damage. In practice, it is anything but. Damage may be
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incremental, and not identifiable without extensive basel in~ and post-
project data. Mortality may affect juveniies as well as adults. Damage
to habitat or to populations of juveniles may not impact resource users
or be measurable for several years hence when particular species should
have reachett adulthood. Other damages, such as tho~e affecting migratory
species or the lower elements of a marine food chain, may be visiole but
nat ~enable to markat place valuation. Less tangible aspects of
resource damage include decreased aesthetic worth and decreased ability
to provide a specific wildlife habitat. Finally, in an environment
possessing many, often only partially understood, natural interrelation-
ships -and impacted by any number of man-n!lated activities -definitive
assessment of precise cause and effect re 1 a tionshi ps ·between ~eve 1 opment
impacts and fish or wildlife -mortalities will be difficult and often
impossible.
This problem is intensifie<t by the absence of even rudimentary data at a
lar-9e number of site-specific 1 ocations. It follows that assessment of
damage will, at best, be a combination of assessment of the partial data
base available concerning stock levels, seasonal and cyclical abundance
and location, together with a scientific judgement of the "most 1ikely1
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resu 1 t of envi ronmenta 1 damage, based on a genera 1 understanding of fish
and wildlife habitat dependencies and tolerances.
These type$ of judgements put extreme pressure on fish and wi 1 dl i fe
scientists and pose unknown ri sk.s for the resource. In sudl cases, and
where the only other alternative is to stand mute and observe a steady
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erosion of fish and wildlife values -uncorrecte~ and Lulcompensated for -
a judgement decision is necessa~J.
The Department holds that the appropriate standard for measuring damages
to natural resoun:es is the cost which would be reasonably incurn!tt by
the State to restore or rehabi 1 itate the environment in the affected area
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to its pre~xisting condition, or as close thereto as is feasible without
grossly disproportionate expenditures.
The question is prompted: at what point do indirect or cumulative
effects become so remote-that mitigation should not be require<!? The
Department recognizes the 11 'Without-the-projec~ baseline assumption for
resource eva·luation purposes when imposing mitigation measures. It is
from this baseline that the degree of project impact, and hence the
degree of mitigation required, may be measured.
Because damage estimates wi11 be based upon scanty or incomplete
knowledge, and will often be probabilistic in nature, it is possible that
estimates of ••most likeli' 1eve1 of damage may, from time to time, vary.
It is this Department's belief that in such cases of difference, the
onus of proof to explain any lower estimates must lie with the developer.
Thi·s position is based upon the recognition that the deve1op~r is the
potential beneficiary of both an early start (relative to time required
for adequate environmental inventory) and. of any lower damage estimate
that is put forth.
IV • Surrma ry
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' ·(1} Mitigation is necessary to guide development in order to preclude, abate,
repair, or indemnify the adverse effects upon fish, game, and their
habitat resulting from development projec~s in fish streams and in
refuges, sanctuaries, critical habitats, and the natural habitat of
endangered species.
(Z) Oepartment•s authority to approve development plans in streams and
special areas, as well as the public trJst doctrine asserting the
public's right to uni111llaired fish and game production on public lands,
provide the means and the obligation to compel mitigation measures.
(3) Differences in recovery potentials due. to differing· degrees of stress
placed upon fish, game, and their habitat dictate that mitigation
measures be selected accordingly.
(4) Mitigation before the fact" of damage is the preferred means, with
avoidance of damage as the primary objective, and minimization
rectification, maintenance, and compensation fo11 owjng in that order.
Each may be implemented through pennit stipulations.
(5) . Mitigation measures imposed after the fact of damage or in 1 ieu of
' expected damage, may require n!Ctification of damage, maintenance of
con-ecti ons over time, or compensation by rep 1 acing a r substituting.
resouM:es or environments.
(6) Rectification, necessary only when the permittee has not fulfilled his
obligation, may be ifl1l'osed by _permit stipulation or by court ordered
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pena1ty. Projects may be r-:trofitted \1~th feasible r-:storatian r-:quire-
ments to recover fish, game, and habitat lasses.
(7) · Maintenance mitigation actions are project related. rne Department holds
that maintenance mitigation costs are. nonna1 development costs to be
borne by the developer and project beneficiaries. This form of
mitigation may be impose<:! by pennit stipulations or later amendment.
(8) Co~ensation by providing substitute resources or environments is the
least desirable form of mitigation. When impose<:! it preferably should be
impTemented onsite rather than by 11 improving1
' an existing ecosystem
elsewhere. Compensatory mitigation wi11 only be implemented by negotia-
ting a written agreement with the developer.
(9) Mitigation should be considere<i at the earliest project conceptualization
or design stage. A11 impacts should be assessed early in the project
planning process with first consideration given· to nonstructural alterna-
tives to the project objective.
(1.0) Fish and wildlife habitat should be prf!served unless the public benefit
of the project is demonstrably lartJe. Assessment of damages will be a
Department .decision base<:! in part on existing data bases and in part on
11 most~• 1 ikely judge.rnents.
( 11) The burden of proof to justify 1 ower estimates of damage to fish and
wildlife habitat lies with the developer.
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Mr. Ronald 0-Skoog, Commissioner
Department of Fish and Game
P.O. Box 3-200
Juneau, Alaska 99802
. Dear C:O.iss1oner Skoog:
September 2, 1982
Susttna Hydroelectric Project
During the second quarter of thts year, the Alaska Power AUthority
circulated the draft Feasib11fty Report on the Sus1tna ~droelectric
Project and numerous supporting documents to State. Federal and local
agencies with interests in the project. This circulation included
virtually all of the data and analysis done to that date during the
study.. Currently, efforts are proceeding towards completing the first
phase of planning efforts and submitting a license application to the
Federal Energy Regulatory Commission 1n the first quarter of 1983.
During the remaining time before filing, the Susitna study team
will be refining the plans presented earlier this year and continuing to
evolve proposed mitigation plans for project fmpacts. This effort will
include requesting another review of the projects Environmental Report,
which 1s the draft of the FERC license application Exhibit E, by your
agency. We will be circulating the draft in mid-November of this year.
After f111ng with and acceptance of the appHcatfOA by FERC. there will
be another opportunity to. e0111ent oa the application, including Exhibit
E.
At this time we are requesting that the reviewing agencies provide
us with input to the mitigation planning whtch w111 go into the draft of
Exhibit E. Your letter of July 27, however, included the type of
response regarding mitigation measures and preferences which we are
proceeding to solicit fro. other agencies.
I appreciate the timely guidance which your Department has provided
to the Susitna project planning effort. We w111 be responding to your
recommendations and comments by further correspondence in the draft
Exhibit E.
September z. 19'.
Coai1Ss1oner Rona 1 d o. Skoog
Page 2
Tour continued support and efforts 1n the study of the Sus1tna ~droelectr1c Project are appreciated.
EPT:tllb
cc: Mr. J. Hayden
Mr. c. Yanagawa
Mr. J. Schneider
Mr. T. Trent
Mr. T. AJ"'linsk1
Sincerely.
SIGNED
Eric P.. Yould
Execut1ve-D1rector
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Dt:PARTBENT OF FISH .>\NO GA.llt:
October 15, 1982
Mr. Eric Yould
Executive Director
Alaska Power Authority
334 West Fifth Avenue
Anchorage, AK 99501
Dear Mr. Yould:
RE: Mitigation
DFRCE OF THE COMMISSIONER P.O. BOX 3·2000
JUNEAU, ALASKA 99802
PHONE: 465-4100
ocr 2 21982
AL SKit f·v~ . . \U
• .. l1 / THO.'~IT't
.The Susitna Hydroelectric Project and other Alaska Power Authority
projects may create conditions that would require changes in hunting,
trapping, and fishing regulations. For example; improved access might
redistribute harvest pressure in a manner that would tend to increase
harvest levels. Such situations may require changes in seasons, bag
limits, or methods and means to ensure that harvests are not
excessive.
APA will have to address these problems in its environmental assess-
ments and mitigation plans. However, I need to point out that under
State law the Board of Game and Board of Fisheries are the
governmental bodies responsible for allocating the fish and wildlife
resources by appropriate regulations. A strong feature of the State?s
fish and game regulatory process is its ability to quickly respond to
changes in population levels, user demand, and management objectives.
Fish and wildlife management suffers when management actions are
implemented through some less flexible authority such as statute,
judicial order, or regulation or stipulations set
by agencies not directly responsible for maintenance of fish and
wildlife populations. It would be particularly inappropriate to
commit the State to regulatory regimes to offset impacts that may not
occur for several years. There is a substantial possibility that the
impacts may not be as predicted or that populations or management
objectives would have changed. Consequently, any plans or
recommendations for mitigation that might require or suggest changes
in fish and game regulations should be directed to the Boards of
Fisheries and Game for their consideration.
This procedure does not apply to restrictions placed on individuals
brought into the area to engage in construction activities. It
applies only to regulations affecting the general public. It is
entirely appropriate for APA and its contractors to limit project
personnel, because construction projects create unusual concentrations
Eric Yould 2 October 15, 1982
of people brought into the area by means not available to the general
public.
In summary, APA still has a responsibility to attempt to avoid or
minimize impacts first, and for those impacts that are unavoidable APA
should seek alternative mitigation measures other than restrictive
fish and game regulations. As longer term effects emerge, requiring
adjustments in management controls, the only legal authority for
regulatory response will be through Board action. As long as APA and
the Department actively monitor these projects, the existing system
should be adequately responsive.
Sincerely,
Ronald Skoog
Commissioner
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Mr. Robert McVey, Director
Alaska Region
National Marine F1sher1es Se"1ce
P.O. Box 1668
Juneau, Alaska 99802
Dear Mr. McVey:
September 2, 1982
Susitna Hydroelectric Project
During the second quarter of this year, the Alaska Power Authority
circulated the draft Feasibility Report on the Susitna Hydroelectric·
Project and numerous supportin~ documents to State, Federal and local
agencies with interest in the project. This circulation included
virtually all of the data and analysis done to that date during the
study. Currently, efforts are proceeding towards completing the first
phase of planning efforts and submitting a license application to the
Federal Energy Regulator,y Commission in the first quarter of 1983.
During the remaining time before f111ng, the SUsitna study team
will be refining the plans presented earlier this year and continuing to
evolve proposed mitigation plans for project impacts. This effort wtll
include requesting another review of the project•s Environ~~ental Report,
which is the draft of the FERC license application Exhibit E. by your
agency. We will be circulating the draft 1n mid-November of this year.
After filing with and acceptance of the application by FERC, there w111
be another opportunity to comment on the application, including Exhibit E. .
At this time we would appreciate any input into the continued plan
developt~~ent you could provide. In particular, we request your guidance
with regard to project impacts and the mitigation opportunities your
agency would recommend. These comments will be helpful both in identi-
fying and addressing the most important areas of concern in the next
draft Exhibit E and in documenting agency comments and recommendations
before FERC. In order to address these comments in the draft, 1t would
be most helpful to have them by the first Qf October.
As you know. the planning process 1s dynamic. Current efforts are
focused on project access, transmission corridors and project operation
alternatives.. Althcugl\ ttt1s i••f"rmation has not yet been distributed·
for comment, it w111 be included in the Exh1b1t E drQft.
I
September 2. u._ -
Mr. Robert McVey
Page 2
We welcome your comment on all areas of the project, but, in
accordance with Section 4.41 of the FERC regulations, we are particular-
ly interested 1n your cmaaents with regard to anadTomous fisheries. In
these areas, we would like to address your concerns on potential impacts
and 11itigation measures which _can be included in project plans.
Your continued support and part1c1pat1on in the development of the
Susitna project license application 1s greatly appreciated.
EPY:mb
cc: Mr. J. Hayden
Mr. Brad Sm1tt.
Very truly yours,
'
SlGNED
··Eric P.-Yould
Executive Director
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UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
NationaZ Marine Fisheries Service
P.O. Box 1668
Juneau, AZaska. 99802
R E. ;.., ..; . 'I E D
October 15, 1982 OCT 2 !1982
Mr. Eric P. Yould
Alaska Power Authority
334 West 5th Avenue
Anchorage, Alaska 99501
Dear Mr. Yould:
I have received your letter of September 2, 1982, regarding the current
status of the Susitna Hydroelectric Project Feasibility Studies. You
have requested any input our agency may provide at this time, particu-
larly with respect to project impacts and mitigative measures associated
with anadromous fishery resources. Such consultation is specified by
the FERC regulations for Major Unconstructed Projects, 18 CFR Part 4.
Realizing the latest schedule for preparation of the draft Exhibit E and
submission of license application, I feel it is important to state or
re-state the position of the National Marine Fisheries Service (NMFS) so
that the license application may incorporate our views or respond to
them as outlined in 33 CFR Part 4.41(f}. This section specifies that
the application must contain nA description of any measures or facili-
ties recormnended by State or Federal agencies for the mitigation of
impacts on fish, wildlife and botanical resources."
NMFS's primary concerns regarding the Susitna project include provision
of adequate instream flow regimes for spawning, rearing, and migration
of indigenous fish species; maintenance of water quality for these
species; and provision for compensation of all resource damage in in-
stances where such impacts cannot be mitigated. These concerns are
discussed below. ·
I. Flow Re 1 ease
Jl.dequate flow regimes are critical for anadromous fish. Conse-
quently, water flows for successful spawning, rearing, and
migration must be established and maintained downstl~eam of the
project area. If flow reduction or modification of flew regimes is
anticipated in the operational scenario for this project, anadro-
mous fisheries could be adversely affected within the entire
Sus itna River system downstream of the faci 1 i ty.
To address these matters, flow studies must be performed to de-
tennine flow re 1 eases that wi 11 conserve and protect stocks of
.anadromous fish in the Susitr.a River. Specific flow regime pro-
posals based on studies and acceptable to NMFS must be submitted
part of your license application. With regard to this issue, we
are particularly concerned with the side channel/slough environ-
ments of the T~lkeetna to Devil Canyon reach which appear to be
particularly important to anadromous fish. Significant post
project flow alterations will occur below Talkeetna during winter
months, and the impact of these changes must also be addressed.
II. Water Quality
Adequate water quality is also essential to viable populations of
anadromous fish. Several concerns exist with regard to water
quality parameters that may be altered by the Susitna project,
these include:
A.
B.
c.
D.
E.
Siltation and other construction related im acts: Construc-
tion should proceed at times of east bio og1ca activity and
should employ best management practices to further reduce
these impacts.
Temperature changes: The license application must describe
temperature changes related to project operation~ discuss the
impact such chang~s would present to fish, and propose miti-
gation measures which will avoid or lessen such impacts. The
applicant must also describe the specific studies, reservoir
models, and riverine models upon which temperature projections
are based.
Dissolved gases elevation: Gas supersaturation may occur due
to plunging water near dam sites and result in fish/gas-bubble
disease. The license application should describe measures em-
ployed to mitigate this impact; e.g., cone valves.
Turbidity changes: The application must describe, for the
entire year, the effect of the project on glacial till
suspended in the Susitna River water column.
River morphology chanTes: Altered flows and interruption of
bedload transport cou d effect channel changes~ perching of
tributary confluences, and armoring of the streambed below the
damsites. ·
III. Compensation for Unavoidable Losses
Effective flow releases and water quality conditions are intended
to avoid losses to existing and potential anadromcus fish re-
sources.
Despite maximum use of these mitigative measures, unavoidable
damage to fish resources may occur either during or after
construction. Compensation in the form of fish habitat improve-
ments, artificial production or similar methods is required to
fully replace such unavoidable loss. An initial plan which rec-
ognizes contingencies such as unanticipated construction impacts
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-·
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must be developed as part of your license application. Subsequent
refinements or modification of this plan may be necessary once the
project begins operation and the success of mitigative measures has
been assessed.
Recognizing the proposed construction schedule for the Susitna project
and the political, economic, and environmental concerns which may con-
tinue to influence project development, it is likely that the project
may operate as a one dam (i.e., Watana) system for a considerable period
of time. Therefore, the license application should identify and discuss
those resources, impacts, and mitigative/compensative measures associ-
ated with the construction and operation of the Watana Dam in the
absence of the Devil Canyon Dam. NMFS will provide additional comments
upon review of the 1982 Environmental Report and draft Exhibit E and in
response to the FERC license application. In the interim, we are
available to discuss any concerns you may have regarding the positions
.of our agency in this matter.
Sincerely,
., ~----:' -' •7 _/
',' /"/ / ·-&---<---t--;1-r?---'.
'/i/1~ ::.1 . " . .... -
r ...... Robert w. McVey
/' /-'Reg iona 1 Di rector
The preceding letter was received. Responses are as follows:
I. Flow Release
The Alaska Power Authority recognizes the need for adequate flows to maintain
fishery habitat. The flow releases proposed for the project were based on a
compromise between 11 no impact 11 flows and "maximum pow!i!r" flows. Chapter 2
and 10 of Exhibit E explain the methodology and rationale of flow releases
selected. Chapter 3 discusses the potential impacts to fish and mitigation
plans to reduce these impacts.
II. Water Quality
A. Siltation and Other Construction Related Impacts
Best management practies will be utilized to control siltation. These
are discussed in the mitigation sections of Chapter 2 and 3 of Exhibit E.
B. Temperature Changes
All of the requested infonnation is presented in Chapter 2 and 3 of
Exhibit E.
C. Dissolved Gases Elevation
Gas supersaturation is not predicted to result from project operation.
Fixed cone valves have been proposed. This subject is discussed in
Sections 4.1 and 4.2 of Chapter 2 of Exhibit E. ,
D. Turbidity.· Changes
Seasonal impact analysis is discussed in Sections 4.1 and 4.2 of Chapter
2 of Exhibit E.
-
E. River Morphology Changes
This subject is addressed in Sections 4.1 and 4.2 of Chapter 2 of
Exhibit E.
III. Compensation of Unavoidable Losses
The mitigation plan in Chapter 3 of Exhibit E includes methods for fish
habitat improvements and other methods to replace unavoidable loss. The
mitigation planning process will continue.
The Susitna Hydroelectric project has been studied and is proposed as a
two-dam project. Thus, the license application addresses the impacts of two
dams. Included is a discussion of impacts during the period when Watana is
complete and Devil Canyon is not.
Detailed comments from your agency will be addressed when received.
Mr. Ty D111iplane
State House Preservation Officer
Depart.ent of Natural Resources
Division of Parks
619 Warehouse Avenue. Suite 210
Anchorage, Alaska 99501
Dear Mr. Dilliplane:
September 2, 1982
Susitne Hydroelectric Project
During the second quarter of thh year, the Alaska Power Authority
circulated the draft Feasibility Report on the Susitna Hydroelectric
Project and numerous supporting documents to State. Federal and local
agencies with interest 1n the project. This circulation included
virtually all of the data and analysis done to that date during the
study.. Currently. efforts are proceeding towards completing the first
phase' of planning efforts and submitting a license application to the
Federal Energy Regulatory Comaiss1on 1n the first quarter of 1983.
During the rema1ning t1me before filing. the Sus1tna study team
will be ref1n1ng the plans presented earlier this year and continuing to
evolve proposed mitigation plans for project impacts. Th1s effort will
include requesting another review of the project•s Environmental Report.
which is the draft of the FERC license application Exhibit E, by your ·
agency. We will be circulating the draft in mtd-November of this year.
AFter f111ng with and acceptance of the application by FERC, there will
be another opportunity to comment on the application, 1nclud1ng Exhibit
E.
At this time we would appreciate any input into the continued plan
development you could provide. In particular, we request your guidance
with regard to project impacts and the m1t1~t1on opportunities your
agency would ree0111end. These c01111ents will be helpful both 1n identi-
fying and-addressing the most important areas of concern 1n the next
draft Exhibit E and in docu.ent1ng agency· caa.ents and recommendations
before F£RC. In order to address these comments 1n the draft, it would
be mast helpful to have them by the first of October ..
As you know, the planning process is dynamic. CUrrent efforts a~
focused on project access. transmission corridors and pl"'ject operation
alternatives. Although this information has not yet been distributed
for comment, 1t will be included in the Exh1b1t E drift•
.....
-·
September 2, li..
Mr. Ty D1111plane
fage2 -A .• ..;_ ..... -_
We welcome your comment on all areas of the project, but. 1n
accordance with Section 4.41 of the FERC regulations, -. are particular-
ly interested fn your comments with regard .to historical and
archeological resources. In these areas, we would like to address your
concerns on potential impacts and m1t1gat1on measures which can be
included 1n project plans. ·
Your continued support and participation 1n the development of the
SUs1tna project license application 1s greatly appreciated.
EPY:mb
cc: •tr. J. Hayden
Mr. Alan Carson
Ver.r truly yours.
~iGNED
Eric P. Yould
Executive Director
DEPARDIElft' OF X.D'IJIUL RESOITROW
DIVISION tW PAIUCS
October 15, 1982
Re: 1130-13
Mr. Eric P. Yould
Executive Director
Alaska Power Authority
334 W. 5th Aven1.1e
Anchorage, Alaska 99~01
Dear Mr. Yould:
JA'I S. HAIIIIOND, GOVERNOR
619 WAREHOUSE OR .• SUITE 27t,
ANCHORAGE. ALASKA 99!J01
PHONE: 274-11676
REGE!VED
OCT 2 11982.
' . 'l A lll'Hf'ID!TV ALASKA PO~J;.;, .-., ·"' ·
Thank you for your letter of September 2 soliciting our recommendations on
Susitna Hydro Project impacts and mitigation measures with respect to cultural
resources.
First of all, we wish to commend archaeologists Dr. E. James Dixon of the
University Museum and Mr. Glenn Bacon of the Alaska Heritage Research Group,
Inc., for the excellent job they have been doing in locating cultural re-
sources prior to ground disturbing activities.
Preconstruction survey is, of course, the first s~ep in impact mitigation -
the location and boundaries of cultural resource sites must be known. While
this work is fairly far along, more needs to be done as plans become more
concrete.
Secondly, these cultural resource sites must be evaluated in terms of eligi-
bility for inclusion in the National Register of Historic Places. For eval-
uation, each site within the project area must be sufficiently investigated
such that their boundaries, stratigraphy, relative age, cultural affiliation
and potential to yield significant scientific information are known. Many of
the currently known sites require further, more intensive, investigation for
eligibility determinations to be made. Since so little is known about the
prehistory of the area, each site discovered takes on added significance. In
addition, groups of sites within a river drainage have been classic study
areas throughout the history of anthropological archaeology. It would appear
that a high percentage of the discovered sites may be eligible for the Na-
tional Register.
Thirdly, each eligible site must be examined in terms of "Effect." Will the
proposed action have "no effect," "no adverse effect," or an "adverse effect"?
This would have to be done on a case by case basis. The criteria for deter-
minations of effect may be found under Title 36, Code of Federal Regulations,
Part 800.
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,,.....
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Mr. Eric P. Yould
October 15, 1982
Page 2 -
Please note that every effort must be made to mitigate future nadverse effectt•
activities to National Register or eligible properties. In the few expected
cases where very large, complex sites will be adversely effected, it may be
more economical to build a barrier around the sites. In many cases, substan-
tive investigation may be necessary. If so, this will usually mean relatively
complete excavation ~f the site in order to recover as much scientific infor-
mation as possible.
These recommendations are essentially those suggested by Dixon, et al, in the
Cultural Resources Investigation Phase I Report (April 1982).
We are confident that impacts to significant cultural resources will be fully
mitigated throughout the course of the Susitna Hydroeleetric Project.
Sincerely,
Judith E. Marquez
Director cz·:J ~ c ( (\ __
By: Ty L. )>illiplane .
Stat:eHistoric Preservation-Officer
cc: Ms.
Br.
Mr.
Dr.
Mr.
TS:clk
Leila Wise, DNR, A-95 Coordinat~r
Edward Slatter, FERC Archaeologist
Lou Wall, Advisory Council on Historic Preservation
E. James Dixon, Lead Archaeologist, Susitna Hydro Project
Glenn Bacon, Lead Archaeologist, Alaska Heritage Research Group
MEMORANDUM State of Alaska
DEPARTMENT OF NATURAL RESOURCES DIVISION OF RESEARCH AND DEVELOPMENT
TO:
FROM:
ERIC YOULD
Executive Director
Alaska Power Authority
DATE:
FILE NO:
,...\'J~o
~c~
TELEPHONE NO:
\\ ~ \~'Ot
nr:'\ '2. P-\1'( vv ~1\\0··
/ REEJ~l;~S
Dirlctor
SUBJECT:
October 11, 1982
276-2653
Proposed Susitna
Hydro Project
vo¢\\
The Department of Natural R~es appreciates the opportunity to comment
on project impacts on the proposed Susitna Hydropower Project and to
recommend mitigation strategies. The department has cooperated with Alaska
Power Authority (APA) on this proposed project during the last two years and
refers the APA to earlier comments, specifically DNR's testimony on April
16, 1982, to APA's Board of Directors (attached). The issues listed in
DNR's testimony, water appropriations, instream flow reservations, and
access to the project, continue to be major concerns. Additional comments
are listed below. In some cases comments may repeat earlier DNR comments.
As you are aware, the department is now in the process of preparing a
regional land use plan in cooperation with the Matanuska-Susitna Borough
which includes the lands surrounding the hydro project. This plan, which
will be completed in 1983, will result in land use designations and land
management policies for state and borough lands throughout the area.
To date, the planning team responsible for developing this land usc plan has
consciously avoided any direct involvement in Susitna Hydro issues, relying
instead on the more detailed work being done by other individuals within DNR
and DF&G. The planning process is now at a point where it makes more sense
that there be closer coordination between the two projects, specifically in
the two areas outlined below.
1) The planning team can review and comment on information regarding
regional, indirect impacts of the plan (e.g. population growth,
changes in resource demand, etc.).
2) The plan can be used as a tool. to guide use of public lands to
mitigate or control secondary impacts of the proposed project.
I suggest that you designate a staff person to coordinate these two
projects with Chris Beck (Susitna Plan project manager).
As stated in DNR's recent comments on recreation planning, we are concerned
that recreational facilities planned in conjunction with the hydropower
project may be under-utilized. A related concern is the higrr cost to the
state of maintaining potentially over-developed, under-used public
recreation facilities.
02-00lA(Rev.l0/79)
-
Susitna Hydro Project -2-October 11, 1982
The Division of Geological and Geophysical Survey has completed a detailed
review of the soils and geology components of the feasibility study. Those
comments (attached) are intended to be informal and for the consideration of
APA and its contractors. Other geological and geophysical concerns are
listed below.
1) Existing information indicates that glaciers in the project area
are retreating; this and their seasonal nature may affect water
availability.
2) The two large bodies of water created qy the proposed project may
affect the micro-climate of the area.
3) The dams, by blocking sediment travel, may increase erosion
downstream.
4) There may be a substantial change in the area between the two dams
over a period of time in response to changes in flow regime, the
amount of sediment introduced and transported, and the hydraulic
geometry of the valley (gradient, width~ depth, discharge, and
velocity of the channel).
The department requests that any trees felled in the project be made
available to the public and that commercial quantities of forest products be
made available to the commercial community for harvest and utilization.
Attachments
cc: Chris Beck, DRD
Leila Wise, DRD
Al Carson, DRD
RS:LW:lln
MEMORANDUM
TO.
FROM
AL CARSON
Deputy Director, DRD/DNR
RANDALL UPDIKE
Geologist V, DGGS
State of Alaska
Departma1t of Nattral Resor.rces ,-
Division of Geological & GeoJ:hysical St.J'Vey
DATE: 4-26-82
FILE NO:
TELEPHONE NO: 688 _3555
suBJEcT: Review of Susitna
Hydro Feasibility Study
I have been requested to review Volume II, Section 6, Soils and Geology of
the Susitna Hydroelectric feasibility study,representing DGGS. My conments will
sometimes refer to specific paragraphs within the section but are generally of a
summary nature based upon the discussion of the entire section.
To insure the long-tenn integrity of a high masonry dan such as those under
consideration in the Susitna Hydroelectric Project, three fundamental issues of
geotechn1cal siting must be addressed: (1) geologic foundation conditions at
the damsite, (2) suitab-ility of the reservoir based upon the geologic
interaction between the basin, stored water, and dam, and (3) seismic exposure
of the system. My following discussion will be essentially limited to item (2)
above which is the prime concern of Section 6. These comments are based upon
the nine page summary that I was provided for review.
We can identify five criteria which are essential, but complex, geologic
variables in evaluating the suitability of a given terrain for reservoir
development: (1) nature and variability of bedrock within, adjacent to, and
beneath the proposed reservoir basin, (2) composition and distribution of
unconsolidated deposits over bedrock within the basin, (3) basin geometry
(including slope angles), (4) distribution and flow gradients of surface and
ground waters within and adjacent to the basin, and (5) ambient stress fields
within and adjacent to the basin.
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The overwhelming majority of hydroelectric darns in the \\()rld have safely met and
exceeded design specifications since construction. In fact, masonry dams have
performed better than mQst manmade structures during earthquakes. However,
catastrophies asso€i ated with dams and their reservoirs have occurred frequently
enough to warrant our utmost concern. One of the most serious threats to the
dam-reservoir-basin systen is the potential for massive, high velocity 1 andsl ides
entering the reservoir. Such slides can propagate destructive surface waves which
impinge on opposite shorelines and occasionally the dan itself. Such was the case
of the Va.iont Dam, Italy, 1963, when a 230 foot-high wave was generated by a
sJide, leaving 2,600 dead and missing.
1.) Bedrock-related concerns.
-The majority of great landslides in recorded history have involved the slope
failure of indurated sediments, or bedrock. These failures typically occur along
one or more discontinuities within the rock, which, for a variety of reasons, have
shear stresses exceeding resi·sting frictional stresses. Discontinuities are often
planar, and may be repeated in a subparallel manner through the rock body. In
F-some cases failure results from the intersection of t\\(1 or more sets of weakness
-
planes. from the bedrock geology descriptions fo~ the basins upstream from the
two damsites I would 1 ike the following to be considered:
LA} MetamQrphic rocks are of concern due to the foliation and Jo.int patterns
which typically develop in such rock, as well as the mineral assemblage
itself which often can be easily sheared-to-. further lubricate~ failure
planes (p. 6-2, para. 3).
l.B) Conjugate joint sets typ.ical of intrusive rocks-. (which are also
indkated to be present in the basins) can generate complex failure schemes
(p. 6-2, para. 2; p. 6-5, para. 2).
-Susitna Hydro. Feasibility Study Review Randall Updike Page 2
'
1C.) The contacts between rock units, for example those between the intrusive
rocks and arg·i 11 ite-graywacke sequence, can serve as extensive planes of
discontinuity (p. 6-2, para. 3; p. 6-5, para. 2).
1.0) Although no active faults may be identified in or near the project area,
numerous older inactive faults probably exist and, in conjunction with
mylonitization along these zones, can provide additional planar trends for
failure. Often, major river valleys follow regional fault trends with
subsidiary faults paralleling the trend of the master fault. Thus, the
subsidiary faults may tend to parallel the valley walls, enhancing the
failure susceptability along these trends (p. 6-5, para. 3).
~In addition to planar discontinuities within mappable bedrock of the
valley walls, concern should be expressed for bedrock structures 11 hidden 11
beneath the unconsolidated sediments in the valley floors. This would be of
prime concern as reservoir filling proceeded, which induces profound physical
stresses on the underlying rock masses, as well as imposing large hydraulic
head values over a broad saturated 11 foot print .. of the reservoir floor (p.
6-2, para. 1; p. 6-4, para. 2).
2.) Unconsolidated sediments.
Whereas bedrock failures usually occur as moving blocks or slabs, unconsolidated
sediments (e.g., soil, till, alluvium, colluvium) lack strong interparticle
bonding and, therefore, are more susceptible to slope failure. Concerns I have,
based upon the summary geologic report are:
2.A) Contacts (discontinuities) between unconsolidated sediments and
underlying bedrock are usually abrupt, at high angles along valley walls, and
saturated with groundwater (p. 6-3, para. 1; p. 6-4, para. 2-3).
2 .B) Typically gl aci ally-related sediments vary significantly in texture and
degree of consolidation which can produce:
Susitna Hydro Feasibility Study Review Randall Updike Page 3
2.B.l) Underconsolidated (soft) sediments below grade (p. 6-4, para.2)
2.B.2) Seismically liquefiable sands and silts {p. 6-7, para. 1)
2.B.3) Textural discontinuities which can act as failure planes {p. 6-4,
para. 2-3)
2.B.4) Confined aquifers having substantial hydraulic head
2.C) Old landslides were identified in the report. Often such slides are in
equilibrium with existing conditions which can be dramatically modified by
reservoir water encroachment with associated ground water table rise. This
can cause reactivation of old slides {p. 6-3, para. 5).
3.) Concerns related to thawing permafrost.
Unconsolidated deposits under a permafrost regime have a passive rigidity which is
• abruptly diminished when thawed. Often this results in slow solifluction-like
flows which may prove more of a nuisance than a hazard to facilities. However,
the identification of permafrost in unconsolidated sediments an moderate to steep
s 1 opes prompts:
3.A) The rapid flowage of supersaturated, thawed debris, often over
still-frozen sediments in the subsurface (p. 6-3, para. 2; p. 6-5, para. 4).
3.B) Both surface infiltration and groundwater flow regimes will be enhanced
by the thawing process, transmitting larger volumes of water to potential slide
interfaces.
4.) Changes in groundwater regime.
In addition to the groundwater affects mentioned above, the rise of water level in
the reservoir filling process, and fluctuations qf that level, will significantly
change the hydraulic gradient of groundwater in sediments and bedrock upslope from
the water line. This causes both failure plane lubrication and hydraulic
unloading ~f shear-resisting stresses on discontinuities.
Susitna Hydro Feasibility Study Review Randall Updike Page 4
5.) Stress-state concerns.
As far as I can discern the stability of the slopes within the reservoir basins is
assumed to be a steady-state system. T~ variable stress conditions come to mind.
5.A) The oversteepened valley walls are presently in disequilibrium with
respect to previous rapid glacial unloading. This will occassionally be
manifested by rock failure along steep, bedrock, glaciated surfaces {p. 6-1,
para. 5-6).
5.B) Seismic accelerations which may not be'of concern to dam design, may be
very significant in· slope stability. I saw no mention of this.
6.) Rapid slides into reservioirs.
It seems that one must be predisposed to consider that design-life big slides will
occur into the reservoir. With this in mind I am concerned about:
6 .A) The affect of slides along the margins of the reservoir which may
over-run operational of recreational facilities (e.g., roads, campgrounds).
6. B) Where s 1 ab failures are potentia 11 y to occur on steep s 1 opes, the mass
may be airborne and enter the lake along a ballistic path. This can generate
'Wave'S several tens of feet high which, in turn, affect:
6.B.l) Boats on the reservoirs
6.B.2) Facilities along the shore (across the lake, downstream and/or
upstream)
6.B.J) Where the reservoir follows bends in the valley causing an
enhanced additive affect off of these curves, resulting in progressively
bigger waves at unpredicted locations downstream.
6.B.4) The dam itself, if the slide is near the dam, due to surging of
water away from (drawdown), against, and over the dam, resulting in
stresses exceeding dam design 1 imits
Susitna Hydro Feasibility Study Review Randall Updike Page 5
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6 .C) Landslides may occur in part or Y.holly below water-level in the
reservoir which may not generate surface waves but could displace very 1 arge
vo1umes of water resulting in surge or drawdown at the darn.
Based upon the foregoing conmentary I feel that a strong plea must be made to
examine the locations, types, magnitude, and potential frequency of
reservoir-basin landsl.ides. The soils and bedrock at the tY.O sites support the
feasibility of the project. However, slope studies, wave modeling, and possibly
stabilization measures should be an integral part of the design and construct ion.
Please reel free to contact me at 688-3555.
RU/jlw
Enclosures
cc: Ross G. Schaff
Bill Barn we 11
Dick Reger
s;,usitna Hyd.ro Feasfb11 ity Study RevJew' Randal1 Updike Page 6
ATTACHMENTS TO UPDIKE MEMORANDUM
RE: Susitna Hy.dro Feasibility Study
,_,.
I
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Figure 8 from Patton and Hendron (1974) on the following page
shows some of the stress release phenomena that might
be expected in the Susitna Project where steep glacial
terrain is encountered.
-------__.:::::: ---rffr'--~ ~ ..
/,I ___.L - .
~ , I ,·
v "1::1:-. ~
~
/'-<. POSSIBLE FAULTING
~I I OR_ MXL.ONITIC SEAMS
'~ --. ~ ~, \\ "/,,,_.
\'"'="""II .. ~ --?>( --ZONE OF STRESS CONCENTRATION
fvv
A) DEEP NARROW CANYONS
TOPPLING AND OVERTURNING OF _LICE OR ROCK REMOVED
STEEPLY DIPPING BEDS DUE TO _ _ ____ ---
RELEASE OF HORIZONTAL STRESSES -----,,, .
~ . / LINEAR T.RO,UGHS \\ \ \ \ \
\ , \ \
,, I "'=.-~ -. / "" ' \ \ ' \
\
\ \\ ~£ i i ,-, / ,,, ·.,, \ \ . \ \ ' ·, \
\
' I (( \ \ \ \ • \ \ . \~\ \\ .J !.. ' \\ ~ \ \ ~ \' \ • • . \ \ ' ~\,~\ \ \ \\\~ \\,~\ ~~\\ ,<(/h
\ \ \ \\\. \\\ \ \ \\\ \\ "' \ ' ,,, ' \ '.\ ,,;,,\ ,\\ \ '''\'
t FAULTS DUE TO UNLOADING OF
v v VALLEY BY EROS I ON OR
DEGLACIATION
s) COMPLEX LARGE-SCALE MOUNTAIN STRUCTURES
FIG. 8 GEOLOGIC STRUCTURES RELATED 10 STRESS RELEASE IN MOUNTAIN VALLEYS
Figure 9 from Patton and Hendron (1974) shows the potential for
failure along the interface between unconsolidated surficial
deposits (referred to as 'residual soil') and bedrock.
Note the authors' emphasis on water conditions, which is
also important at Susitna.
A) POSITION OF SLOPE IN
REGIONAL FLOW SYSTEM
PIEZOMETRIC LEVEL IN
WEATHERING PROFILE
B) DETAILED FLOW AND PORE-PRESSURE CONDITIONS
FIG. 9 POTENTIAL SLIDE IN RESIDUAL SOIL~ TYPICAL ENVIRONMENT
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-
Figure. 4 from Patton and Hendron (1974) showing the change in
Piezometric levels as a result of the reservoir influence
on aquifers. Figure 17 (following page) further shows
how this piezometric change can influence a potential
slide plane.
FIG, 4 CROSS SECTION~ SOUTH SASKATCHEWAN RIVER VALLEY~ RIYERHURST
2000-NORTHWEST SOUTHEAS
...
SOUTH SASKATCHEWAN
1~00-~.~ .. ~~-~.~---.~.-.~.-. ~-~.-.7~~~~·-==-=.~~~: ~~~~~
• t • t ' ' • • II
. . . . .. . .... . ... • . . . . . . . .. . ., ·. . : . . ... " -. ~ ... . .... • .... -. .. .. ... .. . .. •• • p . ,., . . . .
J'
r4oo-2·~·~·.:·~·:·~·~·~·:J:~.tb~·:·~·I:~·.:·~·~.·~·::·:·~·:·~:.~~~-;:5··2·5.~~::·:~:::~}::2···~.t~::·~'2··z:z.·.~·~~~.:·~··:Z: .. ~·~3E=.=z·~-·~·3·-~;:·~-~-Z-~·.::~·~:::3;~
t ...., . . . . . . . . . . . . . . .. '·.f::· =:::::::::.·::3-E::::::::::::::::::::~=:::=;:::::::=::::= Z:: . • • • . ._.. • .. • • ..
l2 00 __ · -=-· _· ·_· _· . -=--· !...t' __ ··_~ ·_· _· _· -:-=:==--:---;-;--:-~-:--:-· ~-~~~·~·:-:· ~~ ~~~--:------:--:----:-
• I • I • • • • • • • • • • • • • • • • • • • • • • • • • • • . . . . . . . ... . . . . . . . . . . . . . . . ..... . . . . . . . . .. . . . . . . .
ETERS 0 1000
FEET 0 2000 4000
HORIZONTAL SCALE
•'·' ...... ·.·· ... . -·
2000
6000
PIEZOMETRIC LEVELS AFTER RESERVOIR
, PIEZOMETRIC LEVELS BEFORE RESERVOIR
~~~;! SAND AND GRAVEL
1-:-·.j SANDSTONE
D SHALE
J ] l
Piezometric surface on plane
abc after reservoir fills
Piezometric surface on plane
abc before reservoir fills
b
...._ SURFACE OF SLIDING
FIG. 17 ILLUSTRATION OF THE SIMPLIFIED METHOD OF ANALYSIS
I have included the following table which shows the measured
wave heights associated with landslides entering large
bodies of water.
Tobie 2
Kht<>rle 811~• O.n•rated ll&ve!
'W'ave *" 8llde GHd• 8Udo 81140 V•t•r ........
Htll19.t•t ~liiUp 'l)'JI<! ~ Vol Oltdo Yel..,lty 'l'hickntal Width Depth BU4e Yeloctt.y •.. at
!!"!"-"'~ --"-·-_n_ (I'~ U !<>n c;£1 6101!! -.ill-__ n __ --!L ft IJ!!5 S sravitl --..!£!!.__ Want
r~ ~ "t. ~rt 7('J' 'J/'J (.114 l'~h) 2.2!1 (JMY.) 30' 115-}(,5 170 300 ]59( .... )
At . .l•.lJ!I<'!'fl.
3:! -~ "'!' 21~.'"·' '-'Lr. !;n ~·!!L_ 4.]5 (!MX) 27.7' 115-18:> }20 300 359 (!I!!Ll!)
L1~u;r.s B""Y• A~e.P.:JO..Al
q Ju!y J:-1'5~ 110 lj./0 ~~-40.0 40' 93 2700 400-700 e.1 97-1]0 1
]~') 100-250 JarXJ Submarine 400-100 21! 3
J.')?} 200 /jOQ-700
: ~~7lt 80 llock 40' 400-700
:~1)3 ()r S4 3J5 400-700
V-.ki!! Kfon&.J., All!u!!.l!:a?
;,? ... ,..,, ,_,.;4 30 7'2 Sodi-.nt
Del t.l!l. ~llou,gh
0.2
II!:!~+ t '· !', AlAr;i-:&3
~7 !Jft.r.o:h l ..r.~, 2~ 104 ~'no onool1d• ted 15' 3 (1 atuo~ II
!Ant! a lid• Breolti111!J
Va!a"lt P.'!!"~r""lt)~ r, Italy 4
') l.):tct,r:r :·Y:: 2]0 D/5 ll85 Rock. .. 45' to e6.5' 50.100 775 (IOU) 2.7
]10 Total
1~0 ln VILt.er
Jaya."'l. Y.:f'JL:~,u !!!!. l
; 1 !'"h.,.r :!.7'"1? 33 Rock I SoU 700 10' 16,000 eto (..,.) 3
t; .. ....,./ z...n;.:r~orrl 1
( .... ) ~ F~h;Ja.r~· ! 7~•6 130 Sock"' non 15.1 e5' 1100 3
!lnrVJLI J..al-:e L-•)l"'l
'~ J~~) :1\rJ )";''") 1~ 111 fk><:~ o.~5 65' 4]6 (mx)
l! ~· ~i'•-, .. ~I • ra 1 )1'• 3-6 230 Rock 1.] 11165" 1300 4]6 ( .... )
:?! ~,., .... '"tr\t:~'f ! )~(, 4~ Sock o65'
1!. n .. ·.·~.ll!'r 1!~1l ~30 Rook 1.3 o65· ~36 (INUI)
!i<...•'W'••; '1'nr.:•.n1 1
1 A~ri l 1 fjlf l'QI. Rock t?,O 4~· 700 ( .... ) 13.·-~6.8
J).J-:,.t.e-h~t"''"'"t flay-, AJalk& l
b ."•aly 1'115 15-1?0 Jl5 Glaet•r Blldo 16' 3500 942 (..,.) 1,0
PnnJ.l;n D. hvt:~~·J~~ott !.a:ke 1
1
VB:,;h~l'll::'-•.n !l,.flti Ter~e 6' ltocon•ul!dated el' 160 ( .... ) 4'
April l ~.! .. :, ~Au.1. .ort n53 Bll4u
lt"'"-Cr··•k lhtct11t110Udflted :-, .h.]j ll''':l "5 3J ~tl.r:.-ff )1. ~0 (Mil)
l .'t; ll.otr (l•J(i_~)
~ ~ull--·h (1'"/.)
l T.ach'i.J~X•r1U ~J~~~)
~ ICJrr<cl! (1•,..-h
From: Banks, 1972, Libby Dam Study
April 16, 1982
DEPAR~!ENT OF ~J..Tt:R.AL RESOVRCES 'S
IESTH-lO:iY TO THE ALASKA POWER AUTHORITY BOARD OF DIRECTORS
I appreciate the opportunity to provide comments to the Power Authority
Board of Directors on the Susitna Hydroelectric proje~t. 1 regret that,
because of other commitments in Juneau, I am unable to personally deliver
these comments.
At the invitation of the Alaska Power Authority, the Department of
Natural Resources has been working informally ·with the Authority over
the last two years to help formulate and carry out studies designed to
ans~er the questions which ultimately will determine whether the Susitna
Darn proposals are feasible. The purpose of this testimony today is
twofold: First, to identify Susitna Hydroelectric issues that are
.~ithin-.£!.t.e __ sP._l:l~~-~.:.:.£f. ~~R!.s·:_~uthor,~-~y;--ap.d-_~~condy-to-!D~~C::O]!lP.l_~r!.c!~.:::.
tions to the Board of Directors on the continuation_of project develop-
ment, as reques~ed in the January 26 letter from Mr. Conway.
SUSITNA HYDROELECTRIC RELATED ISSUES WITHIN THE PURVIEH OF THE DEPARTMENT
OF NATURAL RESOURCES
The Departillent of Natural Resources will be required to make decisions
on two major facets of the Susitna Hydroelectric Project. These are:
1. DNR responsibilities for water appropriation (and possibly instream
flow reservations)' fron: the Susitna River.
2. Rights-of-T,.;ay penni ts for access into the dam' sites and transmission
line routes. Other land use permits for access to construction sites,
gravel for construction, and other land use related needs as they occur
on state o~~ed 1ands.
The role of the Department of Natural Resources in water rights appro-
priation will be an adjudicatory one. According to Alaska Statute
46.15.030 (b), the impacts of water appropriation on the public interest
shall be considered during adjudication. Areas of public interest are
defined in the Statute as follows:
1. The benefit to the applicant resulting from the proposed
appropriation.
2. The effect of the economic activity resulting from the proposed
appropriatior:.
3. The effect on fish and game resources and on public recreational
opportunities.
4. The effect on public health.
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,._
I
5. The effect of loss of alternate uses of ._.ater that might be
made ~o~i:hin reasonable time if not precluded or hindered by the
proposec appropriation.
6. 'Harm to other persons resulting from the proposed appropriation.
7. The intent and ability of the applicant to complete the appro-
priation.
8. The effect upon access to navigable waters.
The DNR will be looking to the Feasibility Study data and information to
describe the relationship between various streamflow levels and hot.O" they
will impact fisheries.and aquatic habitat downstream. Thus, from this
Department's perspective, instream flow studies and the relationship of
various floW' levels to aquatic habitats and fisheries resources are
vi tal. The studies administered by the A2A will be the fundamental
so_y,rc:£...,2.£ dat?_ an<! .... ~n.t~aE"l.-9£ -~~ed I?,y_!>~.-R~~k.£. ~-Qe .. public int~res t
f1-ndi1rg'S"""des-cr±b-ed"-al1ove. we-ar'e ea"g'et""'"t'u *re~:tl!W"-and--cormnenr upotc the-
present and future plans for instream flow sfudie-s. To date, we have
not been provided an opportunity to review or comment upon the instream
flow study approach.
The access to the dam sites and the policy surrounding the extent of
access after construction ~~ll lead to one of the most significant
impacts of the project. The Power Authority has stated that the permit
for use of a "pioneer road" is needed in 1982 (before a F.E.R.C. permit
is issued) if the power is to be on line eleven years later. One signifi-
cant issue is the possibility of the construction of a road to the
proposed dam sites and a subsequent decision by the state not to construct
the da~s. It would appear to be in the best interest of the Power
Autiwrity, the land managin~; agencies, and the public to identify other
alternatives which will allm.· the necessary access to the proposed dam
sites in a manner which prevents irreversible impacts. In order to
prevent this issue from bein£ a potential delay in progress, we recommend
that the MA take the lead in convening a multi-agency, multi-disciplinary
effort to accomplish the goal stated above.
The second issue is the long term land use implications of access to the
proposed dare sites. The provision of access to the dam sites should not
unwittingly determine the types and extent of land use impact on the
surrounding lands in the upper Susitna Valley. Carefully determined
access route decisions could result in a multiple purpose route which
could facilitate and enhance other uses of the surrounding lands. In
order 1:0 accomp.1.1sn this, 1:n"' dam access route decision should be made
in conjunction ~o~ith surrounding land o1.mers, land managers, and the
general public. As on the other-issue above, the DNR is willing to
participate cooperatively with the Alaska Power Authority, other agencies,
and the public to resolve this matter so thac it does not: become a
potential delaying factor for the proposed project or a future manage-
ment problem for land Olo.'llers and managers.
Sffi-!}l.ARY AND RECm-fr1ENDATIONS
In sua~ary, che Department o£ ~atural Resources has three reco~enda
t ions:
1. The Department supporcs continued studies in the socio-economic,
technical, and environmental areas. The preliminary work accomplished
so far indicates that the project is technically feasible. ·Further
work is needed to establish the information and data for water
appropriation and fishery mitigation. Additionally, we recommend
further work on the timing, route and conditions of access to the
proposed dam sites.
2. With respect to the question of.whether it is desirable to
submit an application to the F.E.R.C. on September 30, 1982, we
offer the following comments. The APA Board of Directors and the
staff should carefully weigh the advantages and disadvantages of
jmbmi t ting ·the-formal app-lica:t>-icn · an .,.S~ptember--30r·l982. If that
course of action would result in the iti'A acqu.~.~.~u!!. a r.r...R.C.
permit to construct in the most timely and economical way, the~
that course of action makes sense. However, if on the other hand,
a formal application would result in delays, increased potentials
for litigation, and a hardening of adversarial roles between the
APA, other agencies, and other interested parties, then the possibility
of these delays should be considered. We believe that the APA
Board and the Staff are in the best position to evaluate pros
and cons and to determine whether a F.E.R.C. application on
September 30, 1982, is desirable or not. From our more narrow
agency standpoint, DNR is not opposed to a F .E.R.C. application so
long as our agency concerns and responsibilities can be fully and
openly determined through the traditional intervenor process.
3. We compliment the APA Board of Directors and staff for encour-
aging inter-agency interdisciplinary approach to identify ways to
improve the coordination and ultimately the results of the feasibility
studies. We believe that strength-eriirig this approach will facilitate·
a more cooperative and constructive role for those agencies which
have responsibilities that require them to take action on the
Susitna Hydroelectric Project. Specifically, we recommend strength-
ening and enhancing the role of a group similar to the Susitna
Hydroelectric Steering Committee which has been providing informal
agency comments to the APA on this project for the last two years.
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September 2. 1982
Ms. Lee McAnerney. C011111issioner
Department of Coaun1ty and Regional Affairs
Pouch B
Juneau, Aliska 99811
Dear Coaa1ss1oner Mc:Anerney: Sus1tna Hydroelectric Project
During the second quarter of this year, the Alaska Power Authority
circulated the draft Feasibt11ty Report on the Sus1tna Hydroelectric
Project and numerous supporting documents to State, Federal and local
agencies with interest in the project. Tbis circulation included
virtually all of the data and analysis done to that date during the
study. Currently, efforts are proceeding towards completing the first
phase of planning efforts and submitting a license application to the
Federal Energy Regulatory Coasiss1on in the first quarter of 1983. ,,
During the remaining t1• before f111ng, the Susttna study team
wtll be refining the plans presented earlier this year and continuing to
evolve proposed m1t1gat1on plans for project irapacts. · This effort will
include requesting another review of the project's Environmental Report,
which 1s the draft of the FERC license app11catiGn Exh1b1t E, by your
agenc.y. We will be circulating the draft in mid-November of this year.
After f111ng with and acceptance of the application by FERC, there wi11
be another opportunity to comment on the application, including Exhibit
E.
At this time we would appreciate any input into tbe continued plan
development you could provide. In particular, we request your guidance
with regard to project impacts and the m1t1gat1on opportunities your
agency would recommend. These comments w111 be helpful both in identi-
fying and addressing the most important areas of concern 1n ttte next
draft Exhibit E and in docu.ent1ng agency comments and recommendations
before FERC. In order to address these cou.nts fn the draft, it would
be mst helpful to have them by the first of October.
As you know, the planning process ts dynamic. Current efforts are
focused on project access. transaission corr1dors and project operation
alternatives. Although this information has not yet been distributed
for comment, 1t will be included 1n the Exhibit E draft.
September-: z t 19~
Coaa1ss1oner McAnerney .
Page 2
We welcome your comment on all areas of the project. but, in
accordance with Section 4.41 of the FERC regulations. we are particular ...
ly interested 1n your comments with regard to archeological and
historical. and socioeconomic issues. In these areas. we would like to
address your concerns on potential impacts and mitigation measures which
can be included in project plans.
Your continued support and participation 1n the development of the
Sus1tna project license application is greatly appreciated.
EPY:mb
cc: Mr. J. Hayden
Mr. Lawrence H. K1mba 11 , Jr.
Very tru'ly yours.
SIGNED
Eric P. Yould
Executive Director
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DEPT. OF COMMUNITY A REGIONAL AFFAJRS
Mr. fric P. Yould
Executive Director
Alaska Power Authority
334 W. 5th Avenue
Anchorage, AK 99501
Dear Mr. Yould:
October 4, 1982
225CORDOVA, BUILDING 8
ANCHORAGE, ALASKA 99501
OCT 121982
ALASKA POVJER AUTHORITY
Your letter of September 2, 1982 requested this Department's guidance
regarding potential impacts of the Susitna Hydroelectric Project and
mitigation measures that might be appropriate. Regarding potential
project impacts, we would refer you to our letter of May 28, 1982 which
expressed our concerns relative to impacts. The issues raised and
points made in that letter remain valid.
In terms of mitigation measures, it would be more productive to offer
detailed suggestions once the draft Feasibility Report is revised to
incorporate comments of reviewers and then circulated for review.
We would at this time encourage continued close coordination with the
Matanuska-Susitna Borough, Cook Inlet Region, Inc. and appropriate State
and federal agencies during revision of project reports and preparation
of FERC application materials.
cc:
Sincerely,
/..u. f,M.~
Lee McAnerney ~
Commissioner
Lawrence H. Kimball, Jr., Director
Division of Community Planning
Al Carson, Chairman
Susitna Hydroelectric Steering Committee
Gary Thurlow, Manager
Matanuska-Susitna Borough
Claudio Arenas, Planning Director
Matunuska-Susitna Borough
Hr. Keith Schreiner
Regional Director, Region 7 u.s. Fish and Wildlife Service
1011 E. Tudor Road
Anchorage. Alaska 99503
Dear Mr. Schreiner:
September Z, 1982
Sus1tna Hydroelectric Project
During the second quarter of· this year, the Alaska Power Authorityc
circulated the draft Feasibility Report on the Sus1tna Hydroelectric
Project and numerous supporting documents to State, Federal and local
agencies with interest in the project. Thfs circulation included
virtually all of the data and analysis done to that date during the
study. Currently,. efforts are proceeding towards completing the first
phase of planning efforts and sublntt1ng a license application to the
Federal Energy Regulatory C01111hsion in the first quarter of 1983.
During the re~~~ining t1me before filing,. the SUsitna study team
will be refining the plans presented earHer tMs year and continuing to
evolve_ proposed ait1gat1cm plans for project impacts. This effort will
include requesting another rev1ew of the project's Environmental Report.
which 1s the draft of the FERC license application Exhibit E, by your
agency. We will be circulating the draft in mid-November of this yearQ
AFter filing with and acceptance of the application by FERC. there will
be another opportunity to conment on the application, 1nclud1ng Exhibit
E ..
At this time we would appreciate any input into the continued plan
development you could provide. In particular, we request your guidance
with regard to project impacts and the mitftat1on opportunities your
agency would recOIIIDef\d... These coaments will be helpful both 1n 1denU-
fy1ng and addressing the most important areas of concern 1n the next
draft Exhibit E and in documenting agency comments and recommendations
before FERC.. In order to address these COII!IIetlts in the dnft. it would
be. 1110st helpful to have them by the first of October ..
As. you know, the planning process is dynamic. Current efforts are
focused on project access. transmission corridors and project operation
alternatives.. Although this information has not yet been distributed
for comaent, it will be included in the Exhibit E draft.
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/
Septellber 2. 19~-.
-Mr. Keith Schreiner
Page 2
We welcome your comment on all areas of the project. but, in
accordance with Section 4.41 of the FERC regulations. we are particular-
ly interested in your c011111ents with regard to fish, wildlife and
habitat. In these areas. we would like to address your concerns on
potential impacts and mitigation measures which can be included 1n
project plans.
Your continued support and participation in the develoJ)IIent of tbe
Susitlla project license application 1s greatly appreciated.
EPY:mb
cc: Mr. J. H&yden
Mr. Robert Bowker
Mr. Gary Stackhouse
'
Yer.y truly yours.
SIGNED
Eric P. Yould
Executive Director
United States Departinenr of the Interior
IN REPLY f~EFEI1 TO
lii\ES
FISII :\NU \~'ILDLII·l·. Si·.R V ItT
1011 E. TUIJO!{ 1\D.
1\NCHOR:\CL, ALr\SK:\ 94503
(907) :!76-JHOO
Eric Yould, Executive Director
Alaska Power Authority
334 l~est s!!!_ Avenue
Anchorage, Alaska 99501
Dear Hr. Yould:
0 5 OCT 1982
This responds to your letter dated 2 Septe~ber 1982 requesting Fish and
Hildlife Service (FWS) input on Susitna Hydroelectric project impacts and
potential mitigation pertaining to fish and wildlife resources. We have
previously provided as input to the Alaska Pmver Authority (APA) and its
consultants some of our concerns. Please reference the testi~ony presented to
the APA Board by Deputy Regional Director LeRoy Sowl, FHS, on 16 April 1982,
our letters dated 15 November 1979, 23 June 1980, 30 December 1980, 5 January
1982, and 17 August 1982, and the Susitna Hydro Steering Committee (SHSC)
letter dated 5 March 1982. We expect that the issues raised in these letters
,and testimony would be addressed in the license application. vie anticipate
~aking additional comments after our review of tile 1982 field data and
analysis and during our formal consultation review of the draft Federal Energy
Regulatory Commission (FERC) Jicense application Exhibit E.
Presently, the FWS is internally reviewing a draft document prepared under the
auspices of the FWS Hitigation Policy (F.R. VoL 46, 14o. 15, 23 January
1981). The purpose of this document is to establish for this agency project
area Resource Categories and the corresponding mitigation goals. Following
completion of our internal review, the draft document will ~e provided to the
Alaska Department of Fish and Game (ADF&G), the Environmental Protection
Agency, and the National t·1arine Fisheries Service for a 30-day review period.
Following incorporation of comments from these agencies the document will be
released to the APA and the FERC. We expect to issue the document around 15
December 1982. By providing this analysis we intend to: (1) a11oH the AP.A.
and FERC to anticipate FWS recommendations and plan for mitigation needs; and
(2) reduce potential conflicts and project delays. It is the intention of the
FWS to protect and conserve the most important and valuable fish and wi1dlife
resources while facilitating balanced deyelopment of the nation's natural
resources. Copies of our Mitigation Policy have been previously provided to
you. If you need additional copies please do not hesitate to contact the
Field Supervisor, U.S. Fish and Wildlife Service, 605 W. 4!!!. Avenue, Room
G-81, Anchorage, Alaska 99501· (907-271-4575).
The following comments should not be considered as superseding comments
previously provided or foreclosing future opportunities to provide input on
fish and wildlife resouce impacts and mitigation options, prior to, and during
the FERC licensing process.
,,
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I"''"
....
'r"J'' •· ~tt~i.\Ir~:... -!~~ ,I· I·:·. --~------
' I. .lit: irtJ~_r·t;J; flu· ... -if:~ r._•ur.·· ~-d~.ur•_J r0~;ir;1c~ ~ur~)i·ji~.f, bt~:~~ilo-~, chCJ.iic._1;
,cJI:I!JOSi~io;l, ,1:1-.i liuu··,c:l~ i•.:·vt.:1::. ;:o ro~ainuin ln.: ::xi:::ti11~1 ~i:ii1er~· SIIJUic!
, · , · f u 1 1.:,• (~ v _. I u u. t e J . Tr. i:. •. '-' u 1 d p r oJ v i tk t h ~ b <1 s •.: 1 i n c lJ::: 11 h i:: h p l"l:i j e c t
ILliJctct::; couJ.J ue ev::ludU.:<. f7ur in:>tJnce, 110\-: and to ~.'hat ext~nc t!le
:"·ujCCt ~IOUld nocifj' :ll·t::;er;:. CJilditiOilS, hoi! t.1<25C Cliilil(_JeS ~iOUld lf•lj)J.Ct
i!'o:;itivcly 01· negai.iv::l:,-; tn:: !Jio'ca, 1·:hat project modifications could be
urde1·~aken to r;Jinii;:i:e, Clt" elii.iinat~ adverse impacts, and ir.1pa::ts of
1ncrementa1 changes in ttles:: parameters should be fully assessed.
:-:itigation options ,r:1ust Lle examined on the basis of a defensible,
oj\lil.ntified ililpact analysis.
rlan:-of thest! concerns ·.-~ere ro ised previously. l·Je refer you to Su!:ltG.sk 7.10
risli Lcology: A Surve/ of Question:; anc! Concerns Pertaining to Instrear.1 FloH
Aspt··· ts of the ?ruposed Sus i tnu Hydroelectric Project (r:ay 1981) anc! Su~task
7. l,' :;ish Ecology: Instrean Flo" Assessment for the Proposed Susitna
H~·-.::·,··-~12ctric PrJject ~ssu.: :Je:;:ifica:ion and Baseline Data Analysis 1981
Sumn.u·y Report \?1al'C:~; 19S2). lie exp.:::t ti1at til~ is::;ues identified in these
rep,·!·~s 1JiT1 be reeva bated in 1 ight of the 1332 fi€ld season.
To .1o 11ieve the afor~tJer.:ioneC: goals, the ai1aiysis raust provide the fol10\·;ing:
a .. _:uantify the relationshiu ~et\Jeer. r:Jain::;tream disc~:arge and the
.:v<..ila!:Ji'ity of fis.'". rta:Ji<:a~ l.:.:' 7ife stage (oassa.je, ni1ling, spa~·mir.~,
~-~arin~l, in t\:' slougn5, side ::nannels, and r;Jain::;treai.l.
b. ,:.sess the inter!"'eiu.tio:Js!;i;; of the Susitna Rive: t:; it:; trillutaries in
l';.·gar-J to fishery ha.il!i:a~ r:quirements vs. 1ift:: stage.
c .. !:,Jntif} tilt re1.:tions~i~: ~je:;ieer, ar: arra;' of 7101; re;;ime=. and fish
•u:.~itar 6::nms:rear.1 ~1:" -:-C!I<:e•:?-;;nc: tt;roug~lOU~ the yeat·.
d. ~dentify the source, f1o"'· cner.:ica1 and ter.1perature characteristics of
\opi"Je1ling ~-later ·in ::ne slough~ an:J ~heir relationship tc r:Jainstreai:'l
;onditions throughout the year. This should include an evaluation of the
:>1fluence of ice cover on tno2 rela!:ionsbip betr1een the mainstrean anc! the
:-loughs.
e. ::Jsei ine surface and intt>~grave1 temperature data sufficient to describe
:.ne annua 1 therma 1 re:. i:;;es af th·~ rna in5tream river. side channe 1 s, and
:-: lough;; above Tu lkeetna. The relationship of these three river cor.liJOnents
r:;ust be establisi1ec to :!il0\1 a realistic assessment of potential project
:::1pacts.
f. :i1e relationship bet~veen a~bient and potential project-caused temperature
.:-onditions and salr.1on er.ibryo survival and rate of development.
9· -:'"ne viability of slough 1:1odifications to increase fishery habitat needs to
"'.:: der:Jonstrated •
j.
(, ...
1
I •
T:ll lon0 r.~II-Jc.' ir:;plfco.;:io:J:., :.;i p~·:);.h;,(:,, jJI',I,~~-, ,u,:~ v;,. ld~ur·.t:
flO\IS JIHJ pui:e11tia.J liu:Jil.l~ IIIJi!:~cllJtiC·~ fi~J· .. : 1: L'nL ;;; 'lJ~~iulr_•
:; I 0\ I i 0 s s 0 .,c _; I () u g: ' s ' t111 : : 1 J s -~ 1.) : : L I s . : j >] : ; ,j .. ' ~ • i I I ·' -· ' J .... I ; : ~ <.L: ._.
in~o COII::iderJtiCJr: ]Oil'j Cl•rt:l OIIC lJ.i.i ctliu ~'"--JMd CUil;"i'Jlii"JtiOti~.
SJln0n e:Jila.ncei:T!?II:. ootc!il i...:l i.iL.h..JV•_ U<.:v i ~ · .. :li:~·J: ;: i L11vUL. cirec ~lL i C:l.-
projf;!ct, 1:iti1 tile S~:;itrlci pr-oject il"'-1 ~ile :r;riJ<lC:_; uf JII.Y iJrO;_)tiJ.I,I c:
~stabifsh ~Jl1::on in t;le uppc:· ;·ivc:1· or, ,;;.;i:;·~l:l_; FiSii121"h.!.:;,
particularly grayli11g. Conside,·ation snoul.:r u•..' ~iven to potential
conflicts bet~1een mitigation options to offset p1·oject-caused losse!;
to grayling vs. salmon.
The potent i<:. l to esta!J l i sll/expant1 tile SJ liiiOtl fi :>he1·y lJetueen t:1e
Devi 1 Canyon and Watana dalil sites iii ti1e absence of a Devil Canyon
developr.1ent.
~Jiti1in and out-of-uasin oppor~unities tu of-Fset losses to fisire,~ies
sucl1 as strea1;1 stocking, 1a!~e fertilization, o:xtension of existin:!
fis!"leries, and increasin:j pujJic fisi1ing ac:~ss a.1d oppurtuni:ies.
Extent ·of de~·Jaterin9 uet;veea the Devi 1 Car1yo;: dau ano its pOIJerhouse
anc Q.~Sociated fiSi1C!r~· li:lpaCtS, an..; f1liti;Ja:ior: OiJtiOnS.
r::. Pre-and post-project nitrogen 1evels in Devil ~anyon and impacts.
n. Je:1a v-i o ru 1 iiilpacts , ... ~ ~ c: t2d to c;, an ce.s i i~ ~ 1 ;;,4·:..., ·~eiilDe1~ a tut~, a i"l~
ci1er.1ica i compcsitior: of tiH: Sus ima :-~ive!' :!..:~ -::c :ne proposed proj:=:'.:.
~. T;,~ ir.:pa:: of :h.:l:1g2~ 1:·; ~:1;-;::er 710" .• '$, ~~i:.:~~~t .... , C~1er.i~C~1
composition, salinity levels, and ti~ins an: exten: of ice formation
anc :Jrear:-up or, tiH:: e!:tual~:,.
p. Tne vic.I.Jility of a n~seno;r fis;·,:;r} nc:~·:L :;.. <.~: evai\Ji:T.c;:.; tn1qous., a11
assessment of: predicte<i res:rvoi; te1:1perc:.:ures, turbidity, cller,iica 1
composition ana aili:lClpute': orir,Jat·~· produc·.:ivi;:j.·, av"iiai;Ie ~pa;min~
habitat, potential for establisning spa1min: naoitat, and the
q.
,~::: l at i onsfi i p of a reservoir f i silery to '.: 5~il"-' 1 i s;i eJ tri uutar-./
fisheries.
rne timing, extent, and :;.:asonal variaLi1it~· o;· Jaiiy peal~in:; 1·1hic!:
~-lOu l d occur vd th either a one or t~o .:iar.i :;y:; t<:i.i and tnc.: associ a tee;
aquatic ir.;pacts.
r. Hydraulic turbine configuratioti.:> ;rith ;;oti. a 011<: an(j tiJO daht
configut~ation related to maxir.1izi11g fior1 t·eiease options vs. more
flexible turbine system alternatives.
s. The impacts of anticipated operation flm-1 re1eas~~chedules on tilE
aquatic system during a critica1 l0\1 \later period.
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T~IL' Ull•Juin~_; 1:iltilifl: ~;tudic·~ Jre rwuvldin£_; t!1c ~JJ:;i::; updi: ·,;l;ic:i ii.ipJC
as:;essr,lcnr. und ,,iiti']rHiJn ;JIJnnin-:; Ll!~·.: ~Jlucc. lie iJ,~liC!vc 1~hc present ::;:.u·Ji(!:.;
net::d ~CJ be rc:liltt:!rl to tlabita~ vd1u~. Population ~stiu.-t:t:::;, ~Y the1;::;elv·=s, -1re
often t;nrcliuL:l.: inJicJtor::; for ~:valuatin~ project ir;i!JdCt::. ur, fisti J.rhi
IJiJ,_:lifc n:sourcc::;. Saf:i~'lin'] ct~rors, cyclic fluctuations ~f populations, and
tl1e lac~: :Jf ti!Jc:s series dat<~ all contribute to this unreliJ:>ility. The Fl..JS
lH!lieves that nabitat value uas~d upon predicted carr~yin;; capucitJ and ltu1nan
use data is a much better basis for determining mitigation requirements.
liO\<~ever, consideration of impacts of a project directly to fish and 1·1ilJlife
populations should not be foreclosed. Population information can be an
important supplement in fish and \·:ildlife r.1itigation planning.
lle support the species specific ~itigation planning based upon the National
Enviro~cntal Policy Act guidelines (i.e., to first try :o avoid any adverse
ililpact.s, then if that is not pos~ible, to r.1inioize, etc.). naxir.1um efforts
siJOu1d be put forth to avoid adverse ililf)acts to r.~oos~. :aril>ou, urmm bea1·,
clac~ bear, gray ~olf, Dall sheep, baaver, ~ine ~ar:en, bald eagle, golden
ea']le, and trumpetet· s~:an. \lu con:>ider tt1ese ·,liidlife specie;; as ~•avinCJ high
pu~lic interest, economic value, and ecologic&l significance in terms of
trac~i~~ project-related i~pact~ to ha~itat values.
Additiona7 terrestrial icpact~ and ~iti;ation inv~stigations shouJj examine:
l. disposa1 of l:iate·rial e·.:avat2d at the Dc:vil Can:/on saddladar,i.
::. Procedures anc! evaluation a-:" the pot:entia1 and ;;r-z.c~i::~lit~· of distul"t>e·1
area rehabilitation.
3. Viability of presc~ibed ~ur~in; in the u~per Su~itna ~asi~ to cocpensate
for l'loose habitat lcz:;es eva. luated through an exar.;ina.t ion of 3!-ireau of
Land r1anagemen: bur::s, historic burns, and enclosure studies. Poten;:ia1
areas of lmt habitat value tlnich could be enhanced through bur:-~ing should
be identified. flr~:as of interest should include sites ·dllich presently
have lm~ or declining numbers of moose and gooci public access, and it can
be established that ~abftat ~anipulation, such a~ prescribed burning,
v1ou ld increase ha!J itat va lu:.
4. Anticipated project-related changes to the riparian ve9etation fran Devil
Canyon to Tal~eetna and riownstr~ao from-Talkeetna should be evaluated with
ccn:>ideration being ·~iven to the tJen!!fits or dril\:bac!~~ of acceleratin:;,
decelerating, or lilaintaininJ the existing conditions.
5. Teraporal use of the Jay Creek Oall sheep l!iineral lie!~ sl1ould be
documented. The chemical co~position of the mineral Tick 11ould need to he
determinec and identical artifical blocks set out experimenta11y if
inundation of the mineral lie:!~ ~1ould be U[lavoidable at the time it is
norma Tly used.
L'r t'"C(.:U:J!ll~t· ::;i.~t .~r; tJ lor~,c ;~!-tJj~CL ~~c~· Ll~ ':.n~. ~u.~i~~i ..... ;y~~~ .. u~;~'Ctl .. iC
jH·o.,;~c~, ::; :.u:ly ·:01::>0r1en t:; dr0 u::,u;J J l.i ::rn:;JJr~;:J..c:~l:c:;; ;::,;.,. ...::· ;::-, i:.; ::;ethud, <.;
:ou~1c:·: pro:;l~1.: ~l~C01:1es ::Ja:Ju:;eu.:lle. i;iJ•:...:ver, 'J:' ·~'Ji.u,:,·t:Jcnt;.di.:i!I'J, u larg~
ourti~l! i:; ;::lace.j 011 com·din:.tti:JII. T:.~ p1eces );· ':.!.-::.::,;;:::).,:;.Just u€ con~tantly
::l(J!l itnr2d to ilSSurC th.lt the;,: ;;i I J rii: w:iNiiC!' a: t!ll' ~:1:~ 'JT tllC-~H"{n:.'i?"SS. He
.:11·e co;:ccrneci that. the present s~'s:::2,~, <Jf h.}vin~ ~<2ililrate sui.>con~ractors
~~ritinj tiH:: aquatic an~ terrestrial conponents o' ti1e r~T: license application
Ext:ibit £ and the scheduiin'} constraints placed vpon these subcontractors wi11
not al10\t for a thorough analysis of the intetT-=lu.:ionship of the aquatic and
terrestrial studies"
~dditional Jquatic and terrestria1 ililpacts and niti;J:ion considerations
should be examined.
1. ~~~an'Jes in the ex.istin:; ice patten1s and rel i~bl~ predic~ion::; of vJhat
ti1ese pa~erns--><G;rl--a---he-ffith t!':e project nust be ;Jrovided to aiio~1 a full
~s:;-ess8ent of poten:ial ir::pacts tc the fis!~ an..: i;i1::lif~ resources. The
follm:in~ inforQatic~ wou1~ ai~ in an eva1uatio~ of project ice-related
re~ervoir i~?acts.
c.. The tir.lin; of fonna-::i::m, e::tci1::, th i;:;i~ne:::;, a~d tin~ of brea::up of
reservoir ice. Th~~ vould need :o De re!a:ed :o potential wildlife
l ... '2servoir Ci"'OSsin~ ~ite:: s~c!; as lJaL:5.nc. :r-~~~~ f:r-c:z:.riCGua
u. Tile car.1oositior: u.n~. ;:my:;ica: :iiarac-ce'·~:;:i:::. J-; t!1·:: reserv~ir
shoreii~~~ and ::;a\;cim-m :ones an~ expe:;:atiJ::.:: .::;l· ~c~ ~he1vin:J.
Tile f::J/Tm·:in; ir.fon;~atior. 11uuJd aid in an .:vaiua~io:~ J7 ;,rcjec: ice-related
ir::iJc::t:: dmms:rr::a;-frau [Jevi ~ Canyon:
c.. tn~~ '.:irTin9 of fornation, extent, thic::n·.:s5, a:1·.:i ~ilile of )reakup of
ice vs. d range of water rel~ases and winter conditions. Evaluation
a~ tr.is inforr.1ation should then be directeC.: tOIIol'""-d: 1:hat ;-1ould be
the i@pact on beaver, moose, salmon utilization of the mainstrea~.
grayling and other resident fishery use of th2 nainstream, the extent
an~ ir.1pact of ice fog conditions on riparian vegetation.
!:J. Tile extent to ~.rllici; ice functions in cilann~i fon:wtion and
lilodification and predicted cnange: in this rJIE.
c. The pre-~rcject ir.1portance of ice as an influ2nce in nabitat changes
and anticipated post-project condition~.
IrntJact:; of the project on users of fish and 1:ildlife resources, such a:;;
a. ::ommer::ial fishery use_;
b. llig game and fishin'J pt-ofe~sional guide:;;
c. subsistence use;
d. trappers;
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c
I o
']. increased fi:;h c111d l'lild1ife user popu1ation liT the rJibe1t.
.-. lh~ inte:-relation~hip between poten:ial impacts to and r,riti;ation o;::>tions
for sal~on and wildlife species dependent upon aquatic habitats, such as
beaver, moose, sflOrebirds, and t'lJack and br01m bears.
4. Adjustments to the Watana reservoir filling schedule to rn1n1rn1ze impacts
to fish and ~ildlife resources such as salmon, grayling, cari~ou~ and
!lOOSe.
·· Quantification of aquatic ~nd terrestrial haLitat to be inundated due :o
the proposed dau h~ight and what an array of lower dam heights would mean
in :er;;is of lessenin~ ha:.Jitat losses.
~-:ia~Jrlitude, duration, ~nd fr·equenc) of occurrence :>f da.il~' fluctl.!ations and
:h2ir ir::pacts on fiii: and 1:ildlife 1·~sources ;dtl·, both a one and two da1;;
sys~er.;.
7. Disposal of r.;ateria! excavated fror;; ta~lrace an\~ po11e1· t~nn::ls, :;addlcdar,:
dn~ Jenera) aa~ cons:ruction and potentiJl uses.
:.. I~~act~ of the construction viJl30e. uer~anent village, anj alternative:
to the propo5ed sy~~e~ to ~ini~iz; ad~ersc fi:h a~d ~iJdlife r?sources.
ilD1n; restrictions to oinirnize adverse impacts due to ac~ess road,
tra~5!:1ission lines, and aar:i construction.
lu. Tne i~pacts due to construction and maintenance of the transnission Jines
and acces5 roaj need to bE fully evaluated. This should include a
coGplete fish anG wildlife impact assessrnent of borrow areas and access to
thes~ sites.
11. :1hi:1izir::J ffsh and :·tild1ife impact: through proper tif.li:1G oi ''oody
r,1aterial rer:toval in tile iopounaoent areas. Consideration needs to be
giv~n ~o acceptable ~ethods of dispo~al of this ~aterial.
r:. lian~liny of hazardous materials ::J ami at the con~truction sites and
safety precautions.
Although \le are f.Jrovidin·:;J inforr.1ation which v1ould facilitate-your project
objective of ~ubmitting a license application in February 1933,-\IE: continue to
urge you to defer license submittal at least until the 1982 field data can be
fully evaluated. Com.JUnicattons between mi staff and those involved in
]Jthl!riiiJ ;!JrJ inJiCJl...: tililt Ill.: SIIOU1d ~Xpec:. tv Utt<..il!t":.i~.lti•J !.IUCII I.IUI"l'
thoroughly tile resour·ces of the Sus i tnil study .JYeJ il fter· tit 1:. ~'t.:ill".
::itiJ.l~iOII ~l<ltlltifl·j s:wul.J :.J0 f01·::.it LIJSet; 'ljlli<l ::itL t.IUI"'.: CUI.ijtlel>..:
•Jnderstandir~g cf tile resourc~s JnJ thl' re:.u 1 tant asscs~r:1ent vf tJI"uject
iupacts.
, ·'f. •
... \~ L~v----~ tv\D-~
~'t.tJ.. . I . ~ Reg1ona D1rector
cc: F\JS -ROES, IJAES
Questin Edson(FERC
Larry f·toulton/Uooduard-Clyde
Robin Sener/LGL
!lllFS, EPA, :IPS, USGS, ADEC, .t\EIOC
A l Carson/ AOIIR
ADF&G, Hi:lb Div •• S:1 Hydro St:.ldics
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The preceding letter was received; responses appear below.
Aquatic Studies
We believe that many of the questions raised in your letter have been
addressed in the draft license application and the license review workshop.
However, to reiterate somewhat, we recognize the need to develop a
data base respective to the physio-chemical process of the Susitna River
which, in turn, will allow us to predict the ·impact of the project.
Realizing that factor by factor analyses is insufficient to predict
project aquatic impacts, a model which incorporates the factors is being
developed. The model is project specific and complex. Preliminary physical
data for use in the model will be included in the February 15th FERC license
application. The model, however, will not be available for use until June
1983, and we expect that useful analysis will begin to be available in the
fall of 1983.
With respect to the specific aquatic analytical goals mentioned in
your letter, please refer to the following:
"a. Quantify the relationship between maintream discharge and the
availability of fish habitat by life stage (passage, milling,
spawning, rearing), in the sloughs, side channels, and mainstream."
Determination of fisheries habitat requirements, availability of said
habitats, quantification, and incremental changes in habitat quantity re-
sponsive to discharge will be accomplished in the basic steps. The first is
development of relationships that describe habitat suitability in terms of
physical parameters. This first step is underway, and we expect those re-
lationships to be available by June 1983 in the ADF&G habitat analysis
report. The second step will be to use the aquatic habitat model to pre-
dict the changes in habitat availability with respect to various project
operating scenarios.
"b. Assess the interrelationship of the Susitna River to its tri-
butaries in regard to fishery habitat requirements vs. life stage ...
We recognize the significance of the mainstem Susitna River to provide
for migration and rearing of tributary bound or spawned fish. Efforts are
underway to further refine our understanding of mainstem utilization.
"c. Quantify the relationshp between an array of flow regimes and
fish habitat downstream of Talkeetna throughout the year."
We have not embarked on a program to estabJish the relationship of
flow regimes and habitat availability below Talkeetna, although physical
data has been collected below Talkeetna. Impact assessment has been con-
ducted on an area priority basis. The highest priority areas are those
within the _impoundment zone. The second priority area is that between Devil
Canyon and Talkeetna. The lowest priority area is that below Talkeetna. To
date, investigations related to the area up river of Talkeetna have not in-
dicated a need to rigorously assess aquatic impacts below Talkeetna. If,
however, it becomes apparent that impacts below Talkeetna may be significant,
that area too will be rigorously investigated.
"d. Identify the source, flow, chemical and temperature character-
istics of upwelling water in the sloughs and their relationship
to ma,i'nstream conditions throughout the year. This should include
an evaluation of the influence of ice cover on the relationship
between the mainstream and the sloughs."
The relationships between mainstream conditions and slough upwelling
waters have always been recognized as being potentially significant. To
define that relationship, ground water studies have been initiated in rep-
resentative sloughs. Ground water observation wells indicate that the up-
welling in the sloughs, which is necessary for ·egg .incubation, is caused by
ground water flow from the uplands and from the mainsteam Susitna. The
higher permeability of the valley bottom sediments (sand-gravel-cobble-
alluvium) compared with the till mantle and bedrock of the valley sides
indicates that the mainstem Susitna River is the major source of ground water
inflow in the sloughs. Preliminary estimates of the travel time of the
ground water from the mainstem to the sloughs indicate a time on the order of
about six months.
We also recognize that ice cover on the mainstem will influence ground
water hydraulics, for example, when there is an increased stage due to ice
cover.
In addition, ground water wells have been equipped with thermistor
strings and piezometers to monitor temperature and pressure. The dissolved
oxygen content of these ground waters is also periodically determined.
"e. Baseline surface al')d intergravel temperature data sufficient to
describe the annual thermal regimes of the maintream river, side
channels, and sloughs above Talkeetna. The relationship of these
three river components must be established to allow realistic
assessment of potentia 1 project impacts."
Temperature data, especially as it relates to salmonid habitat, is
being gathered. Surface and intergravel water temperatures will be monitored
both instantaneously and continuously.
11 f. The relationship between ambient and potentia 1 project-caused
temperature conditions and salmon embryo survival and rate of
development."
This relationship is currently being investigation by U.S. Fish and
Wildlife Services at the Anchorage research facilities. Chum and sockeye
salmon eggs from Susitna River slough are being incubated at four thermal
regimes including one that mimics a representative slough. Development rates
are followed, noted, and compared to the in situ development.
"g. The viability of slough modifications to increase fishery habitat
needs to be demonstrated."
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There are plans to conduct a slough modification demonstration project
this year. This program will help ascertain whether the types of slough
modification that have been proposed to date are viable.
11 h. The long range implications of proposed project flows vs. natural
flows and potential habitat maintenance flows in terms of possible
slow loss of sloughs, and loss of flushing flows. This should
take -into consideration long term one dam and two dam configur-
ations.11
The Power Authority has partially funded the U.S. Geological Survey to
conduct sediment transport studies on the Susitna, Chulitna, and Talkeetna
Rivers. The study will be entering its third year this year. We envision
that the data from the study wi 11 enable us to model bedload and sedi-
mentation processes, none of which may impact slough habitats. However,
since most of the sediment contribution to the sloughs is from sources
other than the Susitna, emphasis will be placed on developing flushing cri-
teria. This criteria will be based on known physical relationships related
to water borne transport of sediments and other pertinent data specific to
the project. -
11 i. Salmon enhancement potential above Devil Canyon without the Susitna
project, with the Susitna project, and the impacts of any program
to establish salmon in the upper river on existing fisheries,
particularly grayling. Consideration should be given to potential
conflicts between mitigation options to offset project-caused
losses to grayling vs. salmon ...
The Alaska Department of Fish and Game•s Fisheries Enhancement,
Rehabilitation and Development (FRED) Division is, at the direction of the
State Legislature, preparing a study which addresses this issue. We under-
stood a draft study has been completed and will be finalized by February 1983.
The study concludes that there is a potential for salmon enhancement in the
upper Susitna drainage by either construction of a fish pass to provide for
migration to the upper basin or by establishment of a hatchery. While techni-
cally feasible, the fishpass scheme is not cost effective.
The hatchery scenario envisions propagation of sockeye, chum, king, and
coho salmon for release into Lake Louise or Susitna.
The study also addresses the impact of this program on existing resident
fisheries resources. Apparently, the preliminary study indication is that
the impact may not be significant.
11 j. The potential to establish/expand the salmon fishery between the
Devil Canyon and Watana dam sites in the absence of a Devil Canyon
development ...
There is the potential for increase of the salmon escapement above
Devil Canyon with a Watana only project. ADF&G has observed that king
salmon have successfully negotiated Devil Canyon during periods of lower
flows in 1982, chinook salmon spawned at the mouth of Cheechako Creek (RM
152.5), and in an unnamed creek (RM 156.8), both of which are above Devil
Canyon.
"k. Within and out-of-basin opportunities to offset lo~s to fisheries
such as stream stockinq, lake fertilization, extens n of existing
fisheries, and increasing public fishing access and portunities."
Ideally, the Power Authority will try to confine mitigation for
fisheries losses to within the basin. One measure that has been proposed is
the stocking of barren lakes within the project area with grayling to offset
losses that may be realized when tributary spawning habitat in the reservoir
is inundated.
11 1. Extent of dewatering between the Devil Canyon dam and its power-
house and associated fishery impacts, and mitigation options ...
No flow supplementation will be provided immediately below the dam.
Depending on backwater effects, this will result in a dry channel for
approximately 3,300 feet below Devil Canyon dam. The gradient below the dam
is quite steep and the bed is composed of coarse substrates. To provide a
flow will result in insignificant fisheries habitat at a substantial capital
cost.
"m. Pre-and post-project nitrogen levels in Devil Canyon and impacts."
Nitrogen supersaturation is a naturally occurring phenomenon on the
Susitna River. Since 1981, the Power Authority's contractors have been
collecting data on gas saturation in the Devil Canyon area. Preliminary
relationships have been developed that relate dissolved gas saturation to
discharge and decay rates to the distance downstream from Devil Canyon.
Gas supersaturation resultant of the project will be minimized by
virtually eliminating spills through reservoir management. Only significant
flood events (greater than a once in 50-year occurrence) would necessitate
spilling over spillways. It is proposed that all other releases be through
fixed cone valves, which have been shown to be effective in preventing gas
supersaturation.
"n. Behavioral impacts related to changes in flows, temperature, and
chemical composition of the Sus.itna River due to the proposed
project."
Behavioral response to changes in the aquatic environment will be in-
vestigated in conjunction with the fisheries modeling effort.
"o. The impact of changes in winter flows, turbidity, chemical
composition, salinity levels, and timing and extent of ice
formation and break-up on the estuary."
To date, the most intensive impact investigations have been focused on
the area above Talkeetna realizing that project impacts are substantially
attenuated at the estuary. However, from these investigations, a preliminary
assessment of estuarine impacts have been made and are discussed in the
license application. If it becomes apparent that there may be significant
impacts in the estuary, these will be investigated.
!"""
11 p. The viability of a reservoir fishery needs to be evaluated through
an assessment of: predicted reservoir temperatures, turbidity,
chemical composition and anticipated primary productivity, avail-
able spawning habitat, potential for establishing spawning habitat,
potential for establishing spawning habitat, and the relationship
of a reservoir fishery to established tributary fisheries. 11
Reservoir modeling, with respect to temperature and water surface
fluctuation, is currently underway. Sedimentation processes, as they relate
to reservoir turbidity, have also been investigated. Current assessment in-
dicates that tributary spawning habitat subject to inundation by the Watana
reservoir may be lost for that purpose .. There may be changes in species
composition. The Devil Canyon reservoir does appear suitable for supporting
a reservoir fishery. The reservoir areas presently support grayling white-
fish, longnose sucker, burbot, and Dolly Varden.
11 q. The timing, extent, and seasonal variability of daily peaking
which would occur with either a one or two dam system and the
associated aquatic impacts.11
It is currently proposed that Watana alone would be base loaded. With
the two dam scenario, Watana would be peaked and Devil Canyon base loaded.
However, consideration of peaking with Watana only should not be ruled out.
To date, there has not been an assessment of aquatic impacts associated with
daily peaking, we expect that, if necessary, the impacts of peaking scenarios
could be investigated by means of the aquatic modeling effort.
11 r. Hydraulic turbine configurations with both a one and two dam
configuration related to maximizing flow release options vs. more
flex i b 1 e turbine system a 1 tern at ives. 11
The Watana plant output may vary from zero, with the units at stand-
still or at spinning reserve, to approximately 1,200 MW when all six units
are operating under maximum output at maximum head. The load following re-
requirements of the plant results in widely varying loading but because of
the multiple unit installation, the total plant efficiency varies only
slightly.
The Devil Canyon plant output may vary from zero to 700 ~1~J wi.th all
four units operating at maximum output. The combined plant efficiency
varies with output and number of units operating. As with Watana, the plant
efficiency varies only slightly with loading due to the load following
capabilities of multiple units. · ·
11 S. The impacts of antic-ipated operation flow release schedules on
the aquatic system during a critical low water period.11
It is anticipated that the project will always be operated to provide
a minimum flow for fisheries. It is currently envisioned the releases will
maintain Gold Creek flow at 12,000 cfs during the month of August. This is
a preliminary figure and may be adjusted, along with other monthly flows,
during the course of design and licensing.
Terrestria1 Studies
Where possible, wildlife impact assessments at mitigation will be based
on habitat requirements for the species in questions.
In response to your point related to mitigation planning based on the
National Environmental Policy Act (NEPA) guidelines, please find enc1osed
The Susitna Hydroelectric Project Ffsh and Wildlife Policy (1982}. The
policy is consistent with the NEPA hierarchic approach to mitigation of pro-
ject impacts.
Your specific points related to additional terrestrial impacts and
mitigation are addressed, as follows:
"1. Disposal of material excavated at the Devil Canyon saddledam."
Material excavated at the Devil Canyon saddledam will be disposed of in
depleted Borrow Site G. During operations, Borrow Site G will be approxi-
mately 450 feet below the pool elevation.
"2. Procedures and evaluation of the potential and practicality of
disturbed area rehabilitation.11
Initial procedures to rehabilitate disturbed areas are based on past
experience on similar projects in Alaska and primarily confined to replace-
ment of topsoil, grading, fertilization, scarification, and seeding (if
necessary). It is envisioned that site specific rehabilitation effort will
continue for three growing seasons. Within that period of time, there should
be ample time to assess the practicality of the effort and effect necessary
modification.
"3. Viability of prescribed burning in the upper Susitna basin to
compensate for moose habitat losses evaluated through an examin-
ation of Burueau of Land Management (BLM) burns, historic burns,
and enclosure studies. Potential areas of low habitat value could
be enhanced through burning should be identified. Areas of interest
should include sites which presently have low or declining numbers
of moose and good public access, and it can be established that
habitat manipulation, such as prescribed burning, would increase
habitat value.11
Efforts to assess past burns, studies, and the proposed BLM Alphabet
Hills burn are underway a~ is the identification of sites and quantification
of acreage required.
11 4. Anticipated project-related changes to the riparian vegetation
from Devil Canyon to Talkeetna and downstream from Talkeetna
should be evaluated with consideration being given to the benefits
or drawbacks of accelerating, decelerating, or maintaining the
existing conditions.11
These effects have been evaluated and are discussed in Chapter 3 of the
license application.
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11 5. Temporal use of the Jay Creek Dall sheep mineral lick should be
documented. The chemical composition of the mineral lick would
need to be determined and identical artificial blocks set out
experimentally if inundation of the mineral lick would be unavoid-
able at the time it is normally used.11
Studies currently being conducted by ADF&G wi 11 determine both temp ora 1
and spatial use of the lick. Soil samples will be collected and analyzed in
1983. This information will be utilized in future mitigation planning.
Aquatic and Terrestrial Studies
11 We recognize that on a large project such as the Susitna hydro-
electric project, study components are usually compartmentalized.
By this method, a complex problem becomes manageable. However, by
compartmentalizing, a large burden is placed on coordination. The
pieces of the puzzle must be constantly monitored to assure that
they will fit together at the end of the process. We are concerned
that the present system of hav_ing separate subcontractors writing
the aquatic and terrestrial components of the FERC license appli-
cation Exhibit E and the scheduling constraints placed upon these
subcontractors will not allow for a thorough analysis of the inter-
relationship of the aquatic and terrestrial studies.11
Extensive coordination activities have occurred between all contractors
during preparation of the FERC license application.
11 Additional aquatic and terrestrial impacts and mitigation consideY'-
ations should be examined.
1. Changes in the existing ice patterns and reliable predications
of what these patterns would be with the project must be pro-
vided to allow a full asseesment of potential impacts to the
fish and wildlife resources. The following information would
aid in an evaluation of project ice-related reservoir impacts.
a. The timing of formation, extent, thickness, and time of
breakup of reservoir ice. This would need to be related
to potential wildlife reservoir crossing sites, such as
Watana Creek for caribou.
b. The composition and physical characteristics of the reser-
voir shoreline and drawdown zones and expectations for ice
shelving.
The following information would aid in an evaluation of project
ice-related impacts downstream from Devil Canyon:
a. The timing of formation, extent, thickness, and time of
breakup of ice vs. a range of water releases and winter
conditions. Evaluation of this information should:. then be
directed toward: what would be the impact on beaver,
moose, salmon utilization of the mainstream, grayling and
other resident fishery use of the ma·instream, the extent
and impact of ice fog conditions on riparian vegetation.
b. The extent to which ice functions in channel formation and
modification and predicted changes in this role.
c. The pre-project importance of ice as an influence in
habitat changes and anticipated post-project conditions."
The Power Authority's contractors have used state-of-the-art methodology
in ice modeling studies. It is not possible, utilizing currently available
technology, to supply all of the information requested. As much information
as possible to predict is included in the license application. This infor-
mation has been related to changes in habitat and resulting impacts to
fisheries and wildlife.
"2. Impacts of the project on users of fish and wild 1 i fe resources,
such as:
a. commercial fishery use;
b. big game and fishing professional guides;
c. subsistence use;
d. trappers;
e. river guides;
f. winter access across the Susitna River; and
g. increased fish and wildlife user population in the railbelt."
Information on b, c, d, e, and g are discussed in Chapter 5 of the
license application concerning socioeconomic impacts on fish and wildlife
resource users. Effects on the commercial fishery are discussed in Chapter 3;
effects on winter access across the Susitna River are discussed in Chapter 2.
"3. The interrelationship between potential impacts to and miti-
gation options for salmon and wildlife species dependent upon
aquatic habitats, such as beaver, moose, shorebirds, and black
and brown bears."
These interrelationships have been addressed in both the impacts and
mitigation sections of Chapter 3.
"4. Adjustments to the Watana reservoir filling schedule to
minimize impacts to fish and wildlife resources such as salmon,
grayling, caribou, and moose."
Filling of the Watana reservoir has been scheduled to provide power by
1993. Clearing of the reservoir will be conducted in a manner and within a
schedule to minimize impacts to fish and wildlife.
"5. Quantification of aquatic and terrestrial habitat to be inun-
dated due to the proposed dam height and what an array of lower
dam heights would mean in terms of lessening habitat losses.
6. Magnitude, duration, and frequency of occurrence of daily
fluctuations and their impacts on fish and wildlife resources
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with both a one and two dam system. 11
The above two subjects are discussed in Chapter 10 of the Exhibit E in
the license application. They were also in the Development Selection Report.
11 7. Disposal of material excavated from tailrace and power tunnels,
saddledam and general dam construction, and potential uses.
8. Impacts of the construction village, permanent village, and
alternatives to the proposed system to minimize adverse fish
and wildlife resources.
9. Timing restrictions to minimize adverse impacts due to access
road transmission lines, and dam construction ...
These subjects are all discussed in Chapter 3 of Exhibit E of the
license application.
11 10. The impacts due to construction and maintenance of the trans-
mission lines and access road need to be fully evaluated. This
should include a complete fish and wildlife impact assessment
of borrow areas and access to these sites.''
These issues have been considered and addressed in the license appli~
cation. Further consideration will be given to fish and wildlife impacts
during final alignmerit of the transmission lines and access road. Restora-
tion of those borrow areas above the reservoir pool will occur.
11 11. Minimizing fish and wildlife impacts through proper timing of
woody material removal in the impoundment areas. Consideration
needs to be given to acceptable methods of disposal of this
material.
12. Handling of hazardous materials to and at the construction
sites and safety precautions.11
These issues are addressed in the mitigation plan of Chapter 3 of
Ex hi bit E.
11 Although we are provid·ing ·information which would facilitate
your project objective of submitting a license application in
February 1983, we continue to urge you to defer license sub-
mittal at least until the 1982 field data can be fully evalu-
ated. Communications between my staff and those involved in
gathering data indicate that we should expect to understand
much more thoroughly the resources of the Susitna study area
after this year. Mitigation planning should go forth based
upon this more complete understanding of the resources and the
resultant assessment of project impacts ...
Mitigation planning will continue.
Mr. Claudio Arenas
Planning Director
Matanuska-Susitna Borough
Box B
Palmer. Alaska 99645
Dear Mr. Arenas:
September 2. 1982
Susitna Hydroelectric Project
During the second quarter of this year. the Alaska Power Authority
circulated the draft Feasibi11~ Report on the Susitna Hydroelectric
Project and numerous supporting documents to State, Federal and local
agencies with interest in the project. This c1reulat1on included
virtually all of the data and analysis done to that date during the
study. Currently, efforts are proceeding towards completing the first
phase of planning efforts and submitting a license application to the
Federal Energy Regulatory Commission in the first quarter of 1983.
During the remaining time before filing, the Susitna study team
will be refining the plans presented earlier this year and continuing to
evolve proposed mitigation plans for project impacts. This effort will
include requesting another review of the project•s Environmental Report,
which is the draft of the FERC license application Exhibit E, by your
agency. We will be circulating the draft in mid-November of this year.
After filing with and acceptance of the application by FERC. there will
be another opportunity to coanent on the application, 1nchtding Exhibit
E.
At this time we would appreciate any input into the continued plan
development you could provide. In particular, we-request your guidance
with regard to project impacts and the mitigation opportunities your
agency would recommend. These comments will be helpful both 1n identi-
fying and addressing the most important areas of concern in the next
draft Exhibit E and in documenting agency comments and recommendations
before FERC. In order to address these comments in the draft, it would
be most helpful to have them by the first of October.
As you know. the planning process is dynamic. CUrrent efforts are
focused on project access, transmission corridors and project operation
alternatives. Although this information has not yet been distributed
for comment, it will be included in the Exhibit E draft.
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F"'
I
September 2, 1g~
Mr. Claudio Arenas
Page 2
We welcome your comment on all areas of the project, but. 1n
accordance with Section 4.41 of the FERC regulations, we are particular-
ly interested in your comments with regard to land use and socio-
economic issues,.. In these areas. we would like to address your
concerns on potential impacts and mitigation measures which can be
included 1n project plans.
Your continued support and participation in the development of the
Sus1tna project license application 1s greatly appreciated.
EPY:mb
cc: Mr. J. Hayden
Ve~ truly yours,
S\GNED
Eric P. Yould
Executive Director
Director of Planning
Fairbanks-North Star Borough
520 5th Avenue
P.O. Box 1267
Fairbanks. Alaska 99701
Dear S1r:
September 2. 1982
Susitna Hydroelectric Project
During the second quarter of this year. the Alaska Power Author1ty
circulated the draft Feas1bi11ty Report on the Sus1tna Hydroelectric
Project and numerous supporting documents to State, Federal and local
agencies with interest 1n the project. This circulation included
v1rtually all of the data and analysis done to that date dur1ng the
study. Currently. efforts are proceeding towards completing the first
phase of planning efforts and submitting a license app11cat1on to the
Federal Energy RegtJlatory COIID1ss1on in the first quarter of 1983.
. During the remaining time before f111ng. the Susitna study team
w111 be ref1n1ng the plans presented earlier th1s year and continuing to
evolve proposed mitigation plans for project impacts. This effort will
include requesting another review of the project's Environmental Report.
wh1ch fs the draft of the FERC license application Exhibit E, by your
agency. We will be circulating the draft in mid-November of this year.
AFter filing with and acceptance of the application by FERC, there will
be another opportunity to comment on the application. including Exhibit
E.
At thh time we would appreciate any 1nput 1nto the continued plan
development you could provide. In particular. we request your guidance
with regard to project impacts and the mitigation opportunities your
agency would recommend. These comments will be helpful both in identi-
fying and addressing the most important areas of concern in the next
draft Exhibit E and in documenting agency comments and recomaendat1ons
before FERC. In order to address these comments fn the draft. it would
be most helpful to have them by the first of October.
As you know, the planning process 1s dynamic. Current efforts are
focused on project access, transmission corridors and project operation
alternatives. Although this information has not yet been distributed
for comment, it will be included 1n the Exhibit E draft.
-
September z. lS
D1rector of Planning.-Fa1rbanks-North Borougb
Page 2
We welcOIK! your coanent on all areas of the project, but, in
accordance with Section 4.41 of the FERC regulations, we are particular-
ly interested in your comments w1th regard to socioeconomic issue. In
these areas, we would like to address your concerns on potential impacts
and mitigation measures whfch can be included fn project plans.
Your continued support and participation 1n the development of the
Sus1tna project license application is greatly appreciated.
EPY:IIIb )
cc: Mr. J. Hayden
Very truly yours,
SIGNEfF--
Eric P. Youlcl
Executive Director
Mr. John E. Cook
Regional Director
Alaska Region
National Park Service
450 West 5th Avenue
Anchorage. Alaska 99501
Dear Mr. Cook:
September 2, 1982
Sus1tna Hydroelectric Project
During the second quarter of this year. the Alaska Power Author1ty
circulated the draft Feasibility Report on the Sus1tna Hydroelectric
Project and numerous supporting documents to State, Federal and local
agencies with interest in the project. Th1s c1rculat1on included
virtually all of the data and analysis done to that date 4uring the
study. Currently, efforts are proceeding towards completing tbe first
phase of planning efforts and submitting a 11cense application to the
federal Energy Regulatory Commission in the first quarter of 1983.
During the reMaining t1me before filing. the Sus1tna study team
will be refining the plans presented earlier this year and continuing to
evolve proposed mitigation plans for project fmpacts. This effort will
include requesting another review of the project's Environmental Report,
which is the draft of the FERC license application Exhibit E. by your
agency. We will be circulating the draft in mid-November of this year.
AFter filing with and acceptance of the app1icat1~n by FERC, there will
be another opportunity to comment on the application, including Exhibit
E.
At this time we would appreciate any input into the continued plan
development you could provide. In particular, we request your guidance
with regard to project impacts and the mitigation opportunities your
agency would recommend. These comments will be helpful both in identi-
fying and addressing the most important areas of concern in the next
draft Exhibit E and in documenting agency comments and recommendations
before FERC. In order to address these comments in the draft, it would
be most helpful to have them by the first of October.
As you know, the planning process 1s dynamic. Current efforts are
focused on project access, transmission corridors and project operation
alternatives. Although this information has not yet been d1str1buted
for comment, it will be included 1n the Exhibit E draft.
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-
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September Z, 1~
Mt. John E. Cook
Page 2
We welcome your COIIIII8nt on all areas of the project, but, in
accordance with Section 4.41 of the FERC regulations, we are particular-
ly interested 1n your comments with regard to historical and
archeologicals recreation, aesthetics. and resources. In these areas,
we would like to address your concerns on potential impacts and
m1tigat1on measures which can be included in project plans.
Your continued support and participation fn tbe development of the
Sus1tna project license app11cat1on is greatly appreciated.
EPY:mb
cc: Mr. J. Hayden
Mr. Larry Wright
Ver.y truly you~.
S!,..,'\ .,~-,
1\df"~-)
Eric P. Yould
Executive Director
Colonel Neil E. Saling
District Engineer
· U.S. Army Corps of Engineers
P.O. Box 7002
Anchorage, Alaska 99510
Dear Colonel Saling~
September 2, 1982
Susitna Hydroelectric Project
During the second quarter of this year. the Alaska Power Authority
circulated the draft Feasibility Report on the Sus1tna Hydroelectric
Project and numerous supporting documents to State, Federal and ·local
agencies with interest in the project. This circulation included .
virtually all of the data and analysis done to that date during the
study. Currently, efforts are proceeding towards completing the first
phase of planning efforts and submitting a license application to the
Federal Energy Regulatory Commission fn the first quarter of 1983.
During the remaining time before filing, the Sus1tna study team
will be refining the plans presented earlier this year and continuing to
evolve proposed mitigation plans for project impacts. This effort will
include requesting another review of the project's EnYironmental Report,_
which is the draft of the FERC license application Exhibit E, by your
agency. We will be circulating the draft in mid-November of this year.
AFter filing with and acceptance of the appl1cation by FERC, there w111
be another opportunity to comment on the application, including Exhibit
E ..
At this time we would appreciate any input into the continued plan
development you could provide. In particular, we request your guidance
with regard to project impacts and the mitigation opportunities your
agency would recommend. These comments w111 be helpful both 1n 1dent1-
fying and addressing the most important areas of concern in the next
draft Exhibit E and in documenting agency comments and recommendations
before FERC. In order to address these couments in the draft, it wct~ld
be most helpful to have them by the first of October.
As you know, the planning process is dynamic. Current efforts are
focused on project access, transmission corridors and project operation
alternatives. Although this information has not yet been distributed
for comment, it will be included in the Exhibit E draft.
r--,
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September · 2, H .
Colonel Neil Sal1ng
Page 2
We welcome your comment on all areas of the project, but, 1n
accordance with Section 4.41 of the FERC regulations, we are particular-
ly interested 1n your comments with regard to water quality • In these
are~s, we would 11ke to address your concerns on potential impacts and
mitigation measures which can be 1hc1uded in project plans.
Your cont1nued support and participation in the development of the
SUs1tna project license application 1s greatly appreciated.
EPY:mb
cc: Mr. J. Hayden
Very truly yours,
SIGNED
Eric P. Yould
Executive Director-
District Chief
U.S. Geological Survey
1515 E. 13th Avenue
Anchorage, Alaska 99501
Dear Sir:
September 2, 1982
Susftna Hdyroelectr1c Project
During the second quarter of this year, the Alaska Power Author1ty
circulated the draft Feas1b111ty Report on the Susftna Hyrdoelectr1c
Project and supporting documents to State. Federal and local agencies
with interest in the project. This c1rculation included virtually all
of the date and analysis done to that date during the study. Currently.
efforts are proceeding towards completing the first phase of planning
efforts and submitting a license application to the Federal Energy
Regulatory Comm1ss1on in the f1rst quarter of 1983.
During the remaining time before filing. the Susitna study team
will be refining the plans presented earlier this year and continuing to
evolve proposed mitigation plans for the project impacts. This effort
will include requesting another review of the project's Environmental
Report, which 1s the draft of the FERC license application Exhibit E, by
your agency. We wfll be circulating the draft 1n mid-November of tbfs
year. After filing with and acceptance of the application by FERC,
there w111 be another opportunity to comment on the application, includ-
ing Exhibit E.
At this time we would appreciate any input into the continued plan
development you could provide based on the materials which you have
received. These comments will be helpful both in identifying and
addressing the most important areas of concern in the next draft Exhibit
E. Your continued support and participation in the development of the
Susitna project license application is greatly appreciated.
cc: John Hayden
Very truly yours,
. SIGNED
Eric P. Yould
Executive Director
,.,.,.
!
......
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September 2, 1982
Ms. Wendy Walt
Office of Coastal Management
D1v1s.1on of Policy Development and Planning
Pouch AP
Juneau, Alaska 99811
Dear Ms. Wolt: Sus1tna Hdyroelectr1c Project
. During the second quarter of this year, the Alaska Power Authority
circulated the draft Feasibility Report on the Susitna Hyrdoelectric
Project and supporting documents to State, Federal and local agencies
witb interest in the project. This circulation included virtually all
of the date and analysis done to that date during the study. Currently,
efforts are proceeding towards completing the first phase of planning
efforts and submitting a license application to the Federal. Energy
Regulatory Commission in the first quarter of 1983.
During the remaining time before f111ng, the Sus1tna study team
will be refining the plans presented earlier th1s year and continuing to
evolve proposed m1t1gat1on plans for the project impacts. This effort
will include requesting another-review of the project's Environmental
Report, which is the draft of the FERC license application Exhibit E, by
your agency. We will be circulating the draft in mid-November of this
year. After filing with and acceptance of the application by FERC,
there will be another opportunity to comment on the application, includ-
ing Exhibit E.
At this time we would appreciate any input 1nto the continued plan
development you could provide based on the materials which you have
received. These coaaents will be helpful both in identifying and
addressing the most important areas of concern in the next draft Exhibit
E. Your continued support and participation in the development of the
Susitna project license application is greatly appreciated.
cc: John Hayden
Very truly yours,
SlGN£D
Eric P. Yould
Executive Director
Mr. David Haas
State-Federal Ass1stan~e Coordinator
State of Alaska
Off1ce of the Governor
September 2, 1982
Division of Policy Development and Planning
Pouch AW
Juneau, Alaska 99811
Dear Mr. Haas: Susitna Hdyroelectric Project
Our1ng the second quarter of this year, the Alaska Power Authority
circulated the draft Feasibility Report on the Susitna Hyrdoelectr1c
Project and supporting documents to State, Federal and local agencies
with interest 1n the project. This circulation included virtually all
of the date and analysis done to that date dur1ng the study. Currently,
efforts are proceeding towards completing the first phase of planning
efforts and submitting a license applfcatfon to the Federal Energy
Regulator,y Commission 1n the first quarter of 1983.
During the rema1n1ng ti111e before f111ng, the Susitna study team
will be refining the plans presented earlier this year and continuing to
evolve proposed mitigation plans far the project impacts. This effort .
will include requesting another review of the project•s Environmental
Report, which 1s the draft of the FERC license application Exhibit E, by
your agency. We will be circulating the draft in mid-November of this
year. After filing with and acceptance of the application by FERC.
there w111 be another opportunity to comment on the application. includ-
ing Exhibit E.
At this time we would appreciate any input into the continued plan
development you could provide based on the materials which you have
received. These cements will be helpful both in identifying and
addressing the most important areas of concern in the next draft Exhibit
E. Your continued support and participation in the development of the
Sus1tna project license application 1s greatly appreciated.
cc: John Hayden
Ve~ truly yours.
SiGNED
Eric P. Yould
Executive Director
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-
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Mr. Richard J. Vern1men
Acting District Manager
U.S. Bureau of Land Management
4700 E. 72nd Avenue
Anchorage, Alaska 99507
Dear Mr. Yernimen:
September 2, 1982
Susitna Hydroelectric Project
During the second quarter of this year, the Alaska Power Authority
circulated the draft Feasibility Report on the Sws1tna Hydroelectric
Project and numerous supporting documents to State. Federal and local
agencies with interest in the project. This circulation included
virtually all of the data and analysis done to. that da·te during the
study. Currently, efforts are proceeding towards completing the first
phase of planning efforts and submitting a license application to the
Federal Energy Regulatory Ca.1ss1on 1n the first quarter of 1983 ..
During the remaining time before f111ng, the Susitna study team
will be refining the plans presented earlier this year and continuing to
evolve proposed mitigation plans for project impacts. This effort w111
include requesting another review of the project 1 s Environmenta 1 Report,
which is the draft of the FERC license application Exhibit E, by your
agency. We will be circulating the draft in mid-November of this year.
After filing with and acceptance of the application by FERC, there will
be another opportunity to comment on the application. including Exhibit
E.
At this time we would appreciate any input into the continued plan
development you could provide. In particular, we request your guidance
with regard to project impacts and the mitigation opportunities your
agency would recommend. These comments will be helpful both in identi-
fying and addressing the most important areas of concern in the next
draft Exhibit E and in documenting agency comments and recommendations
before FERC. In order to address these c011111ents in the draft, it would
be most helpful to have them by the first of October.
As you know, the planning process is dynamic. Current efforts are
focused on project access, transmission corridors and project operation
alternatives. Although this information has not yet been distributed
for comment, it will be included in the Exhibit E draft.
September 2, 1£ .
Mr. Richard J. Yern1men
Page 2
We welcome ycur ccitmlent on a11 area$ of the project, but, in
accordance with Section 4.41 of the FERC regulations, we-are particular-
ly interested 1n your comments with regard to land use and aesthetics~
In these areas, we would like to address your concerns on potential
impacts and mitigation measures which can be included in project plans.
Your continued support and partic1pation in the development of the
Sus1tna project license application is greatly ~ppreciated.
EPY~mb
cc: Mr. J. Hayden
Mr. John Rego
Very truly yours,
SIGNED
Eric P. Yould
Executive Director
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....
Mr. John R. Spencer
Regional Administrator
Region X u.s. Environmental Protection Agency
1200 6th Avenue
Seattle, Washington 98101
Dear Mr. Spencer:
September 2, 1982
Sus1tna Hydroelectric Project
During the second quarter of this year, the Alaska Power Authority
circulated the draft Feas1bi11ty Report on the Sus1tna Hydroelectric
Project and numerous supporting documents to State, Federal and local
agencies with interest 1n the project. Th1s circulation included
virtually all of the data and analysis done to that date during the
study. Currently, efforts are proceeding towards completing the first
phase of planning efforts and submitting a license application to the
Federal Energy Regulatory Commission in the first quarter of 1983.
During the remaining time before f111ng, the Susitna study team
will be refining the plans presented earlier this year and continuing to·
evolve proposed mitigation plans for-project impacts. This effort will
include requesting another review of the project's Environmental Report.
which 1s the draft of the FERC license application Exh1b1t E. by your
agency. We will be circulating the draft in mid-November of this year.
AFter filing with and acceptance of the application by FERC, there will
be another opportunity .to connent on the application. including Exhibit
E.
At this time we would appreciate any input into the continued plan
development you could provide. In particular, we request your guidance
with regard to project impacts and the mitigation opportunities your
agency would recommend. These comments will be helpful both in identi-
fying and addressing the most important areas of concern 1n the next
draft Exhibit E and in documenting agency comments and recommendations
before FERC. In order to address these comments in the draft, 1t would
be most helpful to have the~~ by the first of October •
As you know, the. planning process is dynamic. Current efforts are
focused on project access, transmission corridors and project operation
alternatives. Although this information has not yet been distributed
for comment, 1t will be included 1n the Exhibit E draft.
September 2. 1~-~
Mr. John R. Spencer
Page 2
We welcome your comment on all areas of the project. but, 1n
accordance with Section 4.41 of the FERC regulations, we are particular-
ly interested in your comments with regard to water quality. In these
areas, we would like to address your concerns on potential impacts and
mitigation measures which can be included in project plans.
Your continued support and participation 1n the development of the
Sus1tna project license application is greatly appreciated.
EPY:mb
cc: Mr. J. Hayden
Mr. W1111aa Riley
Mr. William Lawrence
Very truly yours.
StG~NH=D
'1,·1 l -
Eric P. Yould
Executive Director
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Mr. Ernest w. Mueller, Commissioner
Department of Environmental Conservatfon
Pouch 0
Juneau, Alaska 99811
Dear Commissioner Mueller:
September 2, 1982
Sus1tna Hydroelectric Project
During the second quarter of this year, the Alaska Power Authority
circulated the draft Feas1b111ty Report on the SUs1tna Hydroelectric
Project and numerous supporting documents to State, Federal and local
agencies with interest in the project. This circulation included
virtually all of the data and analysis done to that date during the
study. Currently, efforts are proceeding towards completing the first
phase of planning efforts and submitting a license application to the
Federal Energy Regulatory Commission 1n the first quarter of 1983.
During the remaining t1me before f111ng, the Sus1tna study team
w111 be refining ~he plans presented earlier this year and continuing to
evolve proposed m1t1gat1on plans for project impacts. This effort will
include requesting another review of the project•s Environmental Report,
wh1ch is the draft of the FERC license application Exhibit E. by your
agency. We will be circulating the draft in aid-November of this. year.
AFter filing with and acceptance of the application by FERC. there will
be another opportunity to comment on the application, including Exhibit
E.
At this time we would appreciate any fnput into the continued plan
development you could provide. In particular, we request your guidance
wfth regard to project impacts and the mitigation opportunities your
agency would recommend. These comments will be helpful both in 1dent1·
fying and addressing the most important areas of concern fn the next
draft Exhibit E and in documenting agency comments and recommendations
before FERC. In order to-address these coaments in the draft, it would
be most helpful to have them by the first of October.
As you know, the planning process 1s dynamic. Current efforts are
focused on project access, transmission corridors and project operation
alternatives. Although this 1nfomat1on has not yet been distributed
for c011111ent, it wfll be included in the Exhibit E draft.
September 2 • l!t...'"
Commissioner Ernest W. Mueller
Page 2
We welcome your comment on all areas of the project. but, in
accordance with Section 4.41 of the FERC regulations, we are particular-
ly interested in your comments w1th regard to fish. w11d11fe and
habitat. In these areas. we would like to address your concerns on
potential impacts and mitigation measures which can be included in
project plans.
Your continued support and participation 1n the development of the
Sus1tna project license application is greatly appreciated.
EPY:mb
cc: Mr. J. Hayden
Mr. Robert Martin
Yer.y truly yours,
SIGNED
Eric P. Yould
Executive Director
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Mr. Michael Meehan, Director
Planning Department
Mun1c:1pal1ty of Anchorage
Pouch 6-650
Anchroage. Alaska 99502'
Ilea r Mr. Meehan:
September Z, 1982
Sus1tna Hydroelectric Project
During the second quarter of this year, the Alaska Power Authority
circulated the draft Feasibility Report on the SUsitna Hydroelectric
Project and numerous supporting documents to State, Federal and local
agencies with interest 1n the project. This circulation included
virtually all of the data and analysis done to that date during the
study •. Currently, efforts are proceeding towards completing the first
phase of planning efforts and submitting a license application to the
Federal Energy Regulatory Commission in the first quarter of 1983.
During the rema1ning ti• before f1l1ng, the Susitna study team
w111 be refining the plans presented earlier this year and continuing to
evolve proposed mitigation plans for project impacts. This effort wfll
include requesting another review of the project's Environmental Report,
Which is the draft of ~ FERC license application Exhibit E, by your
agency. We will be circulating the draft in m1d-Hovember of this year.
After filing with and acceptance of the application by FERC* there will
be another opportunity to comment on the application, including Exhibit
E.
At this time we would appreciate any input into the continued plan
development you could provide. In particular, we request your guidance
with regard to project impacts and the mitigation opportunities your
agency wou 1 d recoamend. These coments wi 11 be he 1 pfu 1 both in i dent1-
fying and addressing the most important areas of concern in the next
draft Exhibit E and 1n documenting agency comments and recommendations
before FERC. In order to address these comments in the draft. it would
be mast helpful to have them by the first of October.
As you know, the planning process is dynamic:. Current efforts are
focused on project access, transmission corridors and project operation
alternatives. Although this information has not yet been distributed
for ccmment, it will be included 1n the Exhibit E draft.
September 2, 1982
Mr. Michael Meehan
Page 2
We welcome your comment on all areas of the project, but, fn
accordance with Section 4.41 of the FERC regulations, we are particular-
ly interested 1n-your comments with regard to soc1o-econoa1c issues. ln
these areas, we would like to address your concerns on potential impacts
and mitigation ~~easures whfch can be included 1n proJect plans.
Your continued ~upport and participation 1n tbe development of the
Susitna project license app11cat1on is greatly appreciated.
EPY:IIIb
cc: Mr. J. Hayden
Very truly yours,
-S\GNID
Er1c P. Yould
Executive Director
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September 10, 1982
Dr. Robin Sener
i:
; ..
I' l . .i
S.FA~C..'(
I<.E.'-'E.e 1 T\ /ESSA
JAYS. HAMMOND, GOVERNOR
333 RASPBERRY ROAD
ANCHORAGE, ALASKA 99502
344-0541
1: . EL..t-1 sotJ 1 \JE.L-trr
<tdh5~·rl~t.~~;..._-----. JE!:~!:Y~ ~~ ..... .w ... -RECEIVED
LGL, Alaska Research Associates
1577 C Street
SEP 1 3 1982
LG L ALASKA
Anchorage, AK 99501
Dear Robin,
Since I was one of the more vocal participants at the recent Adaptive
Environmental Assessment workshop and was responsible for deviations
from the original agenda, I thought it would be useful if I summarized
my impressions of the workshop. Some background on my experience and
the history of the Susitna Project wildlife studies may be helpful in
understanding my perceptions.
I have been involved in a number of impact assessment programs in
Alaska. Some of these such as the nuclear testing at Amchitka Island,
the Trans-Alaska Pipeline and the Outer Continental Shelf Environ-
mental Assessment Program were fairly large programs. In most cases
interdisciplinary coordination among field studies was poor or after
the fact. Impact statements were prepared by people who had no input
into the field studies and either didn't understand the studies or
received the results too late or in a form they couldn't use. The
result was that decisions were made \,rith inadequate environmental in-
put, even though hug~:: amounts of money were spent.
I became involved in the Susitna Project when the Corps of Engineers
r~::-activated the project in 1974. Planning was poor and funding iuad-
equate. As a result, ir, 1977, ADF&G unilaterally drew up a plan of
study listing a i.lUIIiDL'.r of specific proj~.::.cl:s and pointing UU[ tht.: n'=:ed
for interdisciplin<_;_ry coor:d1.nation, p.:;:::-cicularl)' ·t:>c. Lween fish, wild-
life, vegetation, hydrology, recreation, and socio-economic studies.
Many of the specific projects listed were incorporated in Acres' POS
in fall of 1979. huwever much of the interdisciplinary coordination
failed to materialize. I repeatedly asked TES to provide this coordi-
nation and develop an overall study design that woBld integrate wild-
life and vegetation studies and ensure collection of adequate hydro-
logy and climate information. When no concrete action was taken, we
made a number of requests for changes iu plant ecology and clir.1ate
Dr. Robin Sener 2 September 10, 1982
studies, more or less guessing what would ultimately be needed. We
asked that a workshop of outside experts be held to review the plant
ecology studies. We were told that these things would be taken care
of in Phase II. We started holding meetings on our own to try to re-
solve these problems and even attempted to design vegetation and snow
sampling schemes that we could implement ourselves. Most of these
efforts failed due to lack of money, manpower and expertise.
In spite of these problems, I believe the program has been more suc-
cessful in identifying impacts and providing environmental input into
the decision making process than any other. program of similar size in
which I have been involved. However I felt we'could do much better.
Things began to improve as we got into Phase II planning, but the
planning process wasn't well organized and a number of aspects, espe-
cially those related to habitat, had not been fully resolved. It was
at this point that LGL joined the project and proposed use of the AEA
simulation modelling process. The workshop was the first major step
in that process. While the stated objective of the AEA workshop was
to develop a working model, I viewed it as a potential good first step
in a systematic planning process that was badly needed regardless of
whether simulation modelling is used. The model itself helped to fo-
cus the workshop, but I had some deep concerns about the modelling
process as it was outlined.
The following is a partial list of issues I hoped would be addressed
during the workshop and subsequent meetings.
1. Design a coordinated, interdisciplinary approach to assessing
impacts on wildlife. This would provide a framework for identi-
fying information needs and help ensure that all the pieces of
information needed for a comprehensive impact assessment are col-
lected in a form that is useable.
2. Initiate a process for reviewing the design and methodology of
the plant ecology studies. The plant ecology people have re-
ceived inadequate input from individuals conducting wildlife
studies and the wildlife impact assessment. There have been con-
cerns about the usefulness of some of the information collected
in Phase I. We need to clarify what we want.
3. Select a habitat based approach for measuring impacts. Hany of
us have reservations about HEP. We needed to develop a better
approach that achieved the same objectives.
4. Review on methods of handling data. We had discussed the value
of using a geoprocesser for analyzing data. He needed to decide
how certain types of data would be used before we could weigh
costs against benefits.
5. Identify products and a timetable for ADF&G's Phase II contract.
The reporting schedule in our contract became obsolete with the
submission of our Phase I report.
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Dr. Robin Sener 3 September 10, 1982
6. Provide fresh viewpoints from individuals outside of the project.
We have always been at our best when we had outside people chal-
lenging our ideas and injecting new lines of thinking.
7. Develop good working relationships. There has been a tremendous
turnover in personnel in several of the participating groups. It
is essential that good communications and cooperation be main-
tained. We had already had one counterproductive incident.
It has been my experience that workshops are
ple to develop good working relationships.
spect for each other and an appreciation for
good forums for pea-
People develop re-
the points of view.
The following are some of the concerns I had about the planned model-
ling process.
1.
2.
The quality of the model could be poor. With the short time
frame, the lack of familiarity of the project by the modellers
and many other workshop participants, the geographic remoteness
of the modellers from the investigators after the workshop, and
the lack of a specific commitment for follow up workshops, the
model could end up poorly designed and filled with inadequately
scrutinized data. This could lead to serious errors that would
never be corrected. I felt the project warranted a more deliber-
ate, thoughtful approach.
Use of a canned modelling process could result in fitting the
project to the model, rather than vice versa. Any process de-
signed to be quickly applied. to a wide variety of situations is
likely to be less desirable than one tailored specifically to the
objectives of a single project.
3. The model could be misused. Models can be useful tools for test-
ing ideas and examining potential relationships. However, what
comes out of them is no better than what goes into them. Our
knowledge of natural systems is inadequate for developing models
that can make accurate predictions. The outputs need to be care-
fully scrutinized with full consideration of the assumptions and
potential biases and errors that went into the model. I am aware
of numerous cases where predictions have been blindly accepted,
even by people who developed the model and should know better. I
felt that the superficial treatment a model would receive in a
one week workshop, combined with the tight FERC license applica-
tion schedule, could lead to improper use of a very poor model.
5. The rush to have a running model by the end of a week could waste
time that should be spent on planning and coordination. The
schedule of the workshop dictated that people spend time digging
out data. I felt this time should be spent on designing the
model and interactions between people from different disciplines.
It is unusual to get such a broad spectrum of expertise together
Dr. Robin Sener 4 September 10, 1982
and I didn't want to waste the time.· Digging out data can be
better handled in small groups back at their offices.
6. The modelling process could divert attention from important im-
pact issues. Modelling can be a very seductive process. Even
skeptics can become so involved that they fail to step back and
look at the entire picture. The model will address only some
impact mechanisms for some species. There are many issues that
the model will not address or will address only indirectly. If
the model consumes too much attention these issues could be ig-
nored.
The work shop addressed all of the issued I listed above. Some of
the issues were treated only indirectly and superficially, but this
was to be expected from such a large, diverse group. Overall the
workshop was a very good first step. Substantial progress was made in
designing an interdisciplinary approach to impact assessment. Plans
were made for a subsequent meeting to review plant ecology studies.
The models seem to provide a basis for a habitat based assessment
while avoiding some of the problems with HEP. Once decisions are made
on how habitat data will be used, we should be able to evaluate
geoprocessing as a tool. I came out of the workshop with a clearer
idea of what products LGL wants from ADF&G and plans were made to firm
things up over the next couple of weeks. The infusion of fresh view-
points was excellent and I think a good basis for future working rela-
tionships was formed.
My concerns about the modelling process itself remain. They were
somewhat alleviated for the time being by the fact that LGL personnel
seem to share some of my concerns. If we develop the models care-
fully, and use them properly they can be useful tools. However if we
fail to document and continually remind ourselves of the assumptions
and biases built into the models, if we allow ourselves to think of
the model as an accurate representation of the real world, or if we
fail to address impact issues not covered by the model, then the model
could do more harm than good. It would be helpful if we drew up a
complete list of potential impact mechanisms for each species. We
should get input on this list from as many people as possible to en-
sure that all the issues are on the table. Then we can identify an
approach ,to assessing each impact mech.anism. Some issues can be ad-
dressed by the model and some may require a unique study design. This
list would help keep us on track and put the model in proper perspec-
tive.
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Dr. Robin Sener 5 September 10, 1982
In summary, I was very satisfied with the workshop as a first step in
a planning process. The canned AEA modelling process was tempered by
LGL's awareness that the workshop had broader value than simply con-
structing a working model. . If we continue the process with smaller
more specialized meetings and lots of communication between groups, as
you outlined in your closing statement, we snould end up with a good
impact assessment and a useful basis for mitigations planning.
Sincerely,
~:.:er
cc: Richard Flemming, APA
United States Department of the Interi9r
IN REPLY REFER TO:
WAES
FISH AND WILDLIFE SERVICE
1011 £. TUDOR RD.
ANCHORAGE, ALASKA 99503
'(907) 276-3800
£ric P. Yould, Ex~utive Dir~ctor
Alaska Power Authority
334 West 5th Avenue
Anchorage, Alaska 99501
Dear Mr. YouM:
2 4 JAN 1983
The fish and Wildlife Service {fWS), as part of our overall participation in
planning for and evaluating the feasibility of the ~usitna hydroelectric
project, has determined ~roject area Resource Categories and corresponding
mitigation goats. This as been~e, 1n accordance with the fWS Miti9ation
Policy {fR Vol. 46, No. 15, 23 January 1981) and in consultation and
coordination with the National Marine fisheri~s Service, the Environmental
Protection Agency and the Alaska Department of Fish and Game. Both agencies
agree that it is appropriate and timely that guidance be provided for
mitigation planning for the Susitna Hydr-oelectric Project.
The Alaska Department of fish and Game had specific comments that have been
addressed. They did point out that from the state or ecoregion basis, the!
habitat of all evaluation species is abundant. We agree, but have concluded
that the habitat for those species listed in Resource Category 2 is scarce or
becoming scarce, considering its historical quantity and quality from the
national perspective.
Principles of the FWS Mitigation Policy
Four Resource Categories are described in the FWS Mitigation Policy, with
corresponding mitigation planning goals of decreasing stringency. Designation
of project area fish and wildlife habitat in Resource Categories serves as a
guide to insure that the level of mitigation recommended by FWS will be
consistent with the fish and wildlife resource values involved. It is within
this framework that the FWS will evaluate project impact and formulate
mitigation recommendations. Table 1 summarizes FWS Mitigation Policy Resource
categories and their goals.
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Resource
category
1
2
3
4
Table 1. Resource Categories and
Mitigation Planning Goals
Designation
criteria
Habitat to be impacted is of
high value for evaluation
species and is unique and
irreplac-.eab le on a nationa 1
basis or in the ecoregion
section.
Habitat to be impacted is of
high value for evaluation
species and is relatively
scarce or becoming scarce on
a national basis or in the
ecoregion section.
Habitat to be in1pacted is of
high to medium value for
evaluation species and is
relatively abundant on a
national basis.
Habitat to be impacted is of
mediumlto low value for
~valua~ion species.
Mitigation planning
goal
No loss of existing
habitat yalue.
No net Toss of in-
kind habitat
value.
No net loss of
habitat value
while minimizing
loss of in-k·in<l
habitat value.
Minimize loss of
habitat value.
Taken from FWS Mitigation Policy (FR Vol. 46, No. 15, 23 January 1981).
Focus of the FWS Policy on Habitat Value
Specific guidance the FWS wishes to provide is in mitigating losses of habitat
value. Predicted carrying capacity or population data by themselves are often
unreliable indicators for evaluating project impacts upon fish and wildlife
resources. Causes include sampling errors, cyclic fluctuations, and poorly
defined life requisites for the species involved. Therefore, the FWS feels
that habitat value, based upon predicted carrying capacity, current and
historical use, and consideration of the influence of disturbance on
capability of the habitat to support fish and wildlife populations, is the
appropriate concept to be used in determining mitigation requirements.
Although the primary focus is on fish and wildlife habitat value losses, the
polic.v covers impacts to fish and wildlife populations and the human uses
thereof. In many cases, compensation of habitat value losses should result in
replacement of fish and wildlife populations and human uses. But where it
-does not, t-he Service will recommend appropriate additional means and measures.
hs stated in the FWS Mitigation Policy, specific ways to achieve the
mitigation goal when loss of habitat value is unavoidable include, •(l)
physical modification of replacement habitat· to convert it to the same type
lost; (2) restoration or rehabilitation of previously altered habitat; (3)
increased management of similar replacement habitat so that the in-kind value
of lost habitat is repla~ed, or (4) a combination of these measures. By
r~placing habitat value losses with similar habitat values, populations of
sp~ies associated with that habitat may remain relatively stable in the area
over time.''
The mitigation goal of in-kind replacement of lost habitat is not always
a-chievable. 'Further, opposition to a project on that basis alone may not be
warranted. In ~uch cases there are two instances when deviation from this goal
is appropriate. These ar.e: •When {1) different habitats and species
available for replacement are determined to be of greater value than those
lost, or (2) in-kind replacement is not physically or biologically attainable
in the .ecoregion section. In either case, replacement involving different
habitat kinds may be recommended provided that the total value of the habitat
lost is recontnended for r.ept acement."
£valuation Species
Determination of Resource(ategories is based upon the habitat value and
retative abundance of species selected for evaluation. The choice of
evaluation species will, ultimately, have a prominent role in determining the
~tent and tYPe of mitigation achieved in a project.
~wo basic approaches to selecting project impact evaluation species ~an be
tai<en. First, speci-es with high pub 1 ic interest, subsistence or ~onomic
vatue may be 5elected. The second approach would entail the selection of
species which would provide a broader ecological perspective of an area. In
actual practice, ~pecies are selected to represent social, economic,
subsisten~e and broad ecological aspects.
It should be recognized that the evaluation species will, to a large extent,
define the geographic scope of both the direct and indirect fish and wildlife
resource impacts resulting from a project. Direct impacts to species such as
chinook salmon, brown bear, and caribou can have indir~t impacts to others
with which they have an interdependent rehtionsh ip.
Nineteen species have been selected by the 'fWS to determine the habitat
mitigation Resource Categories for the Susitna Hydroelectric Project {Table
2). We consider these species as having high DUblic interest, economic and/or
subsistence value, and ecological significance!/. Brief descriptions of
these species as they relate to the project are provided in the Appendix.
The species selected to establish the habitat mitigation Resour-ce Categories
need not comp 1 ete ly correspond to the 1 i st of species -chosen to quantify
project impacts and mitigation. The species selected for impact assessment
and miti~ation planning by the APA, through its consultants, and coordinated
with
11 The Bald Eagle meets several of these tests but was not included as an
evaluation species for mitigation purposes because it is specifically
protected by the federal Bald Eagle Protection Act~
the resource agencies, includes all of the FWS evaluation species. Study of
those species other than the FWS evaluation species should continue since they
provide confidence in predictions of project impacts and potential mitigation
alternatives. For example, cons·i<l.eration of high public interest and economic
value led to the selection of the golden eagle and the pine marten as
evaluation species. However, our ability to directly monitor project impacts
through these species is questionable. Monitoring of small mammal and
songbird populations dependent upon forested habitat, lends additional
confidence to predictions of i.llll?act on the ~valuation species.
Resource ~ategory Determination
The resource category determination was made by the .. fWS in consideration of
the relative abundance on a national basis of the evaluation species habitat
and the value of tfl.eir habitat to be impacted in t~ pre-project status.
For purposes of ~his document the area of direct project impact is defined as
the ar~a to be disturbed or inundated by project features such as the dams,
reservoirs, ac-cess roads and -transmission line; the nood plain of the Susitna
River from the lower ~am to Talkeetna; and the riparian area beiow Talkeetna.
Spec'f.es using each area are directly impacted. Species dependent on directly
impacted species ar~ indirectly impacted.
The criteria used for determining evaluation species habitat relative scarcity
or abundance from the national perspective are: (a) the histori-cal range and
habitat quality of the evaiuation species, and ·(b) the status of that habitat
today. If a significant reduction in extent or quality of habitat has
occurred for an evaluation species, that habitat is considered scarce or
becoming scarce. If that is not the case, ,the habitat is considered abundant.
The tack of ecosystem diversity in arctic and subarctic environments is widely
recognized (Kormandy 1969, Whittaker 1975). Losses to one species will
quickly reverberate through the ecosystem due to lower stability found in less
diverse ecosystems (Kormandy 1969). Buffering of adverse impacts upon one
species by others does not occur to the extent found, for instance, in the
tropical and temperate zones. for example, Tosses to moose will lead to
increased predation pressure on caribou eventually leading to reductions in
populations of caribou, wolves, black bears, and brown bears.
Most of the evaluation species (e.g., moose, caribou, wolf, Dall sheep, brown
bear, black bear, and the five salmon species) are dependent upon large
habitat areas as well as upon specific habitat types which receive seasonal
use. This necessitates long term monitoring and causes difficulty in clearly
evaluating impacts and formulating mitigation measures. As a result,
seemingly minimal habitat losses could severely impact a population throughout
the upper Susitna basin.
'The FWS has placed the habitat of the evaluation species in the following
resource category designations Y:
Resource Category 2
-Caribou
-to Brown bear
Gray wolf
"-..Chinook salmon
'"Coho salmon
'-Chum salmon
Resource Category 3
Moose
Oall sheep
Arctic grayling
Black bear
Beaver
Pine marten
Golden eagle
Trumpeter swan
Sockeye salmon
Pink salmon
Rainbow trout
Bur bot
Resource Category 4
Dolly Varden
Y Once the vegetative cover types have been delineated and evaluated
as habitat for these evaluation specf.es, r-esource category determinations
can be made by~over type. In instances where evaluation species habitat
overlap, the most conservation (highest) Resource Category will determine
~WS mitigation goal for that area.
lhe fWS provides this analysis to further Susitna Hydroelectric Project
planning. By establishing project and species habitat specific
mitigation goals the FWS intends to protect and conserve the ~ost
important and va~uabte fish and wildlife resources while facilitating
balanced development of the Nation's natural resources.
Sincerely,
Assistant Acting Director
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Table 2. fish and Wildlife Service Mitigation Evaluation Species for the
Susitna Hydroelectric Project.
Colliilon Name
Moose
Caribou
Brown bear
Black bear
'Gray wolf
Dall sheep
Beaver
Pine marten
Golden eagle
Trumpeter swan
Chinook salmon
Coho salmon
Sockeye sa 1mon
Chum salmon
Pink salmon
Arctic grayling
Rainbow trout
Dolly Varden
Burbot
Scientific Name
Alces alces
Rangifer tarandus
Orsus arctos
0. amer1canus
Canis lu~us
Ovis dal i
taStor canadensis
f~artes amer 1 cana
Aquila chrysaetos
Cygnus buccinator
Oncorhynchus tshawytscha
0. kisutch rr. nerka
0. keta
0. gori)uscha
Thymallus arcticus
Salmo sairdnerl
sa1vellnus malma
Lata lata
Literature Cited
Kormondy, E.J. 1969. Concepts of Ecology. Prentice-Hall, Inc. Englewood
Cliffs, New Jersey
Whittaker, R.H. 197S. Communiti~s and Ecosystems. 2nd Ed. Macmillan
Publishing Co., Inc. New York, New York.
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Appendix. Susitna Hydroelectric Project Evaluation Species
Terrestrial Species
1. Moose CAlces alces). In terms of hunting pressure, moose are probably thE
most important big game species in Alaska. Historically, moose were an
important source of food, clothing, and implements along the major
rivers. On a local, regional, and state-wide basis, this species
cont·im:~es to be an important source of food and recreation. ---The monetary
value of moose is compounded by the number of non-resident hunters which
are attracted to the state. Spending by hunters results in benefits
throughout the State•s economy. Moose also have a high non-consumptive
value. They are easily observed and thus provide high photographic value.
In terms of sus~ptability to project impacts moose provide a good
evaluation subject. Commonly associat~d with riparian zones, especially
during harsh winters, moose will be adversely impacted by the project.
Yet, because moose are generally responsive to habitat modifi~ations,
post-project habitat manipulations could potentially benefit moose.
Information on moose, both in t~rms of general life history and project
area specific data is comparatively good. With continued
project-sponsored monitoring of the area populations, adequate information
will, eventually, be available for mitigative planning.
Moose play an important ecologfcal role in the project area. lhey are an
important prey species for wolf {Canis lupus), black bear (Ursus
ameri~anus), and brown bear (U. arctos). In addition, predation on moose
may provide caribou (Rangifer-taranaus) with some relief from pr~dation.
The moose population and habitat quality downstream of the impoundment
areas is relatively high {~bdafferi 1982). Upstream of the Devil Canyon
dam site the population level could be described as low to moderate
(Ballard et a 1. 1982a). It has been suggested that predation is ·
restricting population growth in the upstream area (Ballard et aT. 1982).
Moose habitat, relative to its historical range, is considered abundant
from a national and ecoregion section basis.
2. Caribou (Rangifer tarandus). Caribou have traditionally been and still
are an important food source for humans on a local, regional, and state
basis. As a favored game animal, caribou attract many resident and
non-resident hunters. Benefits accrue throughout the State•s economy as a
result of these hunters.
The project area is within the range of the Nelchina herd. The herd
contains approximately 20,000 animals and js of very high value to
resident hunters because of its size and proxigity to population centers.
The herd contained 60,000+ animals during the 1960 1 s. Caribou habitat,
from ~ national perspective, has not been significantly reduced from its
histor~al range, However disturbances such as highways. pipelines, North
Slope Oil field activities and human/equipr~nt presence have cumulatively
threatened the quality of caribou habitat statewide. Accordingly, we
consider caribou habitat of historical quality is becoming scarce.
The herd has been continuously studied since around 1948 (Pitcher 1982}.
Intensified investigations, through radio-tracking, are being carried out
as a component of the Susitna Hydro Big Game Studies undertaken by Alaska
Department of Fish and Game (ADF&G) (Pitcher 1982}. Management of the
caribou herds is aimed at balancing population levels with their habitat
and avoiding the sharp fluctuations in numbers that have previously
characterized the herds.
Migratory behavior by <:aribou limits this prey speci-es to an ephemeral
role to its somewhat more sedentary predatory species; wolf, and black and
brown bear. Caribou do not provide a dependable year-round food source.
Just as caribou would provide relief from predators for moose, the reverse
would also be true. · ·
Disturbances would be the principal mechanism by which the project could
adversely impact the Helchina caribou herd. Additionally, the impoundment
behind Watana dam may interfere with caribou migration to and from the
<:alving grounds. Utilization of access from the Denali Highway south to
Watana dam would he expected ·to have adverse impacts on a sub-herd ~alving
ground {Pib:::h-er 1982}. Also, if the main herd reacts to -the Watana
impoundment by seeking a ~alving area north of the reservoir, ~he presence
of an a<:~ss road in this area would compound the potential impacts
problem. The potential adv-erse eff-ects of the project on caribou relate
more to habitat quality than quantity. Project impacts to th-e nerd could
be negligible to substantial. Thus, although population levels are
approa<:hing "optimal", drastic proj-ect impacts could result in this
species becoming scarce in the basin.
3. Brown bear (Ursus arctos). This species is considened to be a valuable
big game animal and attracts numerous resident and non-resident hunters.
The non-consumptive value of brown bears is exemplified by the state-
operated McNeil River Sanctuary. Hundreds of people yearly submit
applications to obtain an opportunity to observe brown bears in this
sanctuary. A lottery system limits the number of observers at the
sanctuary to minimize disturbance to the bears.
Although not considered threatened or endangered in Alaska, the brown bear
is listed as threatened under the Endangered Species Act in the 48 con-
terminous states. As such, it can be considered a species of particular
national interest and one whose habitat has been significantly r-educed in
extent and quality from the national perspective. Accordingly, it is
considered scarce on that basis.
Project-specific and scientific information on this species is relatively
good. Studies funded by the Susitna project have been on-going since
1980. Information on movement patterns, population levels, and location
of denning sites is providing a basis for analyzing project impacts.
The project would be expected to result in a high degree of direct and
indirect disturbance. Although some disturbance impact is unavoidable,
the degree to which it can be controlled is large. The type and design of
construction camps, mode and route of access, and timing of construction
are factors which will dramatically influence the extent of disturbance
resulting from this project. Neither direct habitat nor denning sites
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losses appear to be major project-related impacts (Miller 1982). Prey
reduction, however, is expected to result in adverse impacts to brown
bear. Losses due to prey reductions may be masked by the reductions due
to disturbance.
Proj.ect-caused losses to a variety of habitats and species wi 11 impact the
brown bear. Project impacts to the berry-rich shrublands, salmon fishery,
areas of early green-up, prey species such as moose and caribou, will all
ultimately affect brown bear.
According to the ongoing ADF&G studies, "In comparison with other North
Ameri-can brown bear populations, the study area population appeared highly
productive and moderately dense.•• (Miller 1982). Even though the
population is considered to be moderately dense in the project area,
actual numbers are not very high in even the best habitat. A rough
estimate of the study areas population is 1 bear/41-62 km2 {Miller and
McAllister 1982).
4. Black bear (Ursus americanus). This speci~s is widespread in Alaska as
well as in the 48 conterm1nous states. Black bear habitat is considered
abundant on a national and ecoregion basis.
Seasonal availability of foods strongly determine the occurrence of black
bears in a particular area. Movement will occur from spring green-up
areas, to salmon streams in sununer, and then to berry-producing shrubland
in summer/early ·fall. In the project area, brown bear appear to restrict
black bears to the forested habitat along the Susitna River and the
adjacent shrublands to which the forested ar~as serve as escape cover
{Miller an& McAllister 1982). Because of this habitat restriction, black
bear wi 11 b:e strongly impacted through direct habitat losses due to the
project.
Black bear habitat value in the inundation area and downstream from the
dam sites appears to be relatively high. In the ADF&G Big Game Studies
report {Miller and McAllister 1982) is was noted that, "In comparison with
other North American black bear populations, black bears in the study area
appeared to be productive although possibly having an older age of
reproductive maturity and higher rate of cub mortality than an intensively
studied population on the Kenai Peninsula. No good density estimate was
obtained for the study area although a rough estimate of 1 bear/4.1 km2
was obtained in one relatively open area based on aerial observations of
marked and unmarked bears. ••
Black bear would appear to be highly susceptible to impacts from the
project. Indications are that upwards of 90% of the black bear habitat
could be lost through inundation. Avoidance of significant losses to this
species through project modifications does not appear to be possible. The
following is a summary of expected project impacts on the black bear:
"1. Inundation of scarce denniny habitats {especially in the upper
impoundment area), .2. Habitat elimination through inundation, 3.
Increased human disturbance and hunting resulting from project con-
struction, operation, and improved access, 4. Increased predation by brown
bears resulting from decreased availability of berry-rich shrublands which.
are also adjacent to forested escape habitat, 6. Reduction of prey items
(downstream salmon, moose calves and, perhaps, caribou), 7. Impoundment
related climatic changes which alter the availability or abundance of food
resources." (Hiller and McAllister 198Z).
Black bear are being examined as a component of the project's environ-
mental studies program. Information will continue to be gathered on this
species through the project-funded studies and should provide an adequate
data base for assessing project impacts. General scientific knowledge of
this species is good and thus would facilitate the evaluation of project
impacts to b·l ack bear.
5. Gray wolf {Canus ~upuj). Interest in the wolf is relatively high on a
statewide and nat1ona basis. However, concern for managing wolves to
maximize population levels is mixed. Due to its status as an endangered/
threatened -species in the conterminous 48 states there is high national
interest in protecting this species. from the national perspective, the
quantity of wolf habitat has been significantly r~duced, thereby placing
it in a scarce status. On ecoregion basis, wolf habitat is abundant and
state game management has frequently been directed at reducing wolf
populati<>ns in selected ar..eas.
Information on wolves in the project area has been accumulated over more
than 30 years (Ballard et al. 1982b). Studies specific to the Susitna
project have been carried out for the last two years. The scientific data
base is relatively good and it is anticipated that continued project-
related studies will r~u1t in sufficient information for mitigation
planning.
The wolf packs residing in the Susitna study area largely depend upon
moose and caribou. A minor proportion of their diet is composed of small
mammals (Ballard et al. 1982b). Because they are highly dependent upon
the availability of moose and caribou, losses to those species due to
project impacts would directly impact the wolf populations.
The wolf is susceptible to project-related impacts. Impacts to wolves
would primarily occur through reductions in prey density, particularly
moose. Initially, the project may lead to an increase in wolf numbers due
to increased vulnerability of prey which have been displaced from the
impoundment areas {Ballard et al. 1982b). Disruptions in moose and
caribou movements could adversely impact wolves quite distant from the
impoundments. indirect adverse impacts could also be anticipated fror.1
increased access resulting from the project.
6. Dall sheep {Ovis dalli). In the United States, Dall sheep are unique to
Alaska. Interest on a national basis is high. The importance of this
species as big game and an observation subject also creates high interest
from a state and local perspective. On a national and ecoregion basis,
Dall sheep habitat has not significantly changed from its historical
status and is therefore considered abundant.
Consuraptive/nonconsurnptive use of Da 11 sheep is high. Numerous hunters
are attracted to the state to sheep hunt. The value of this species for
nonconsumptive purposes is exemplified by the state having a prohibition
on hunting in areas where sheep can be readily observed.
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Three distinct sheep populations, Portage-Tsusena Creeks, Mt. Watana, and
Watana Hills, were identified in the upper Susitna basin study area
(Ballard et al. l982c). In that the range of these bands correspond to
different portions of ·the project area, ·the type and extent of project-
related impacts vary. The Portage-Tsusena band would be impacted
primarily through disturbance. However, place~ent of borrow pits with
associated roads, and project-access roads could result in a significant
shift in sheep distribution and a loss of critical winter range (Ballard
et al. 1982c) • __ Although the project could have a. severe adverse impact on
the sheep, the impacts are, if not unavoidable, substantially controllable.
Information on the three populations of Da 11 sheep wi 11 continue to be
acquired through project-related studies. The studies will be designed to
assess potential impacts of the project. Additional scientific
information on this species is available, being relatively qualitative in
nature. Project-specific data are extremely important with this species
due to its fidelity to traditional use areas, which makes assessments of
habitat value very d-ifficult in absence of project area-specific
information.
The Ht. Watana band has not been clearly defined. Apparent use of ran-ge
adjacent to the Watana reservoir would indicate that project-caused
impacts would include disturbance and possible loss of habitat (Ballard et
a l. 1982c).
Impacts to tM Watana Hills band could be severe due to its proximity to
the proposed Watana reservoir. Potential project-caused impacts would be
related to disturbance: alter-ed behavior, ~creased lambing success, and
abandonment of the apparently important Jay~reek mineral lick (Ballard et
al. 1982c). · -
Project impacts to the Mt. Uatana and Portage-Tsusena Creeks populations
would be related primarily to disturbance rather than loss of habitat. if
long-term, this would result in a decrease in habitat value. Principal
concern rests with the Watana Hills band \'thich could lose the use of what
is apparently a highly valuable mineral lick at Jay Creek. If the Jay
Creek mineral lick proves to be critical to the band and irreplaceable,
the value -of this habitat would obviously be very high. Studies to
ascertain the nature of this sheep population's dependence on the mineral
lick are being undertaken as part of the project.
7. Beaver {Castor canadensis). This species plays an important ecological
and econo~1c role in Alaska. Trapping beaver continues to be an important
component of traditional lifestyles. Beaver trapping is pursued on a
recreational basis as well as being an important source of revenue for
bush residents. Beaver habitat is neither unique to Alaska nor scarce in
the United States or Alaska. They do, however, play an important
ecological role. Actions by this species results in habitat modifications
\'lhich benefit other wildlife species that are also of high interest (e.g.
waterfowl and moose).
Beaver are dependent upon both aquatic and riparian habitats. Projects
impacts to these habitats would impact beaver distribution and population
levels. Although beaver are scarce in the Susitna system above the
proposed Devil Canyon dam site, from that point downstream existing
population levels gradually increase. At the present time, it has not
been clearly established how the project would physically modify the
~usitna River downstream of its confluence with the Talkeetna and Chulitna
Rivers. Impact questions which are presently outstanding include:
1. What is the potential for beaver-caused fish passage blockages which
may be associated with stabilized flows?.
2. What would be the effects of relatively stable water levels on beaver
and their habitats?
3. H~w would the alter~d ice conditions impact beaver and their habitats?
4. What ar~ the plant species that beaver are dependent upon and how
woul<i these plants be effected by the proposed proj&t? {<iipson et
a 1. 1982).
5. To ~mat extent ar~ moose dependent upon beaver for habitat creation?
As a c~mponent ~f project furbearer studies, beaver are bein9 examined.
location of habitations was cornp~eted during the early phase of work.
During the second stage of the study potential impacts will be assessed
for t~ purpose of mitigation planning. Baseline scientific inforlilation
is relatively ~omprehensive and should lend a high degree of certainty to
ililpact predicti-ons for this species, if post-project water regimes can be
adequately identified.
Existing conditions in the proposed impoundment areas are not favorable
for beaver. Aquatic habitat created by the reservoirs potentially could
benefit beaver, however, water level fluctuations could negate this area
as habitat. Below Devil Canyon the value of the habitat increases with
distance frolil the dam site. Below Talkeetna beaver populations exist in
quantities that can sustain a high and continuous harvest (Gipson et al.
1982) •.
8. Pine marten (Martes americana). The pine marten is restricted to
coniferous forests and, in the United States, is abundant relative to its
historical range in A)aska, the Rocky Mountains, and the northern areas of
the Midwest and the Northeast. Low population densities are
characteristic of this species. Narten are locally abundant in the
vicinity of the proposed ililpoundment area which corresponds to the
forested areas in the upper Susitna valley (Gipson et al. 1982). This
furbearer has, historically, been highly important to trappers.
Economically, the pine marten is considered the most important furbearer
to trappers in the vicinity of the impoundments (Gipson et al. 1982).
In that pine marten inhabit coniferous and mixed coniferous-deciduous
forests, inundations would eliminate much of the habitat of highest value
for this species. Sus~ptibility of this species to project-related
impacts can thus be considered high. In addition, as this species is
associated with older age vegetation, mitigation modification for other
species, such as moose, may be in conflict with the pine marten.
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As a component of project furbearer studies, information on this species
is being accumulated. Although the present level of detail is not
considered high, additional studies are being undertaken.
9. Golden eagle (Aquila chrysaetos). As with the bald eagle, nonconsumptive
interest in this species is high. Although protection is also offered to
the golden eagle by the Bald Eagle Act of 1940, as amended, this
~egislation is Tess restrictive for the golden eagle in that their nests
may be taken when they interfere with resource development. A permit from
the Department of Interior is required in those instances.
Susceptibility of the golden eagle to project impacts would be similar to
that indicated for the bald eagle. Disturbance type impacts, loss of
important habitats, particularly nesting cliffs, and loss of important
prey species would all be project-related negative effects which could
occur to this species.
Habitat to be impacted by the project is not of high value for the golden
eagle. Ten active nest sites were identified during the last t\w years of
studies undertaken for the proposed project (Kessel et aT. 1982). This
concentration of active golden eagle nests is similar to the highest
populations noted for Alaska {Kessel et aT. 1982). However, in a 1974
study C.M. White (1974) did not locate any active gol~en eagle nests in
the proposed impoundment areas. This suggests that relating changes in
nesting density to project actions could be difficult.
10. Trumpeter swan (Cy~nus buccinator). Interest in this species, on a
nonconsumptive bas1s, is high. Recently close to extinction, the
trumpeter swan is still very rare in the conterminous 48 states. Although
restricted to breeding in western Wyoming and t4ontana the trumpeter swan
has recently shown substantial population increases (Robbins et al. 1966).
Swan populations in Alaska are associated during nesting and rearing with
wetlands and ponds found, primarily, along the major river systems in the
southern half of the state. Information on habitat use is concentrated on
coastal areas such as the Kenai Peninsula and Copper River (Konkel et al.
1980). Specific habitat to be impacted by the proposed project is not of
high value for trumpeter swans.
Project-related tracking of trufilpeter swans has focused on the impoundment
areas. Swans are now considered common in the eastern section of the
Susitna study area from the Haclaren River to the Oshetna River. In the
last five years the population there has more than doubled (Terrestrial
Environmental Specialists, Inc. 1982).
Trumpeter swans are susceptible to disturbance type impacts during nesting
and rearing of cygnets. Lacustrine waters are utilized by this species
for nesting and rearing •
Aquatic Species
Five-year studies are being conducted by the ADF&G, Woodward/Clyde
Consultants, and the Arctic Environmental Information and Data Center for the
purposes of:
(1) providing fish population estimates;
(2) identifying valuable aquatic habitats;
(3) evaluating project impacts;
(4) assessing potential mitigation; and
(5) evatuating the potential for salmon enhancement above the dam site.
Water quality, quantity, and other instream flow parameters are to be analyzed
to allow an evaluation of project-caused changes vs. fishery resource
requirements. Project impacts to salmon habitat will be most apparent in the
reach from the Devil Canyon dam site downstream to the confluence of the
Susitna, Chulitna, and Talkeetna Rivers. Except for a small run of chinook,
salmon do not go above the dam site.
1. Chinook salmon (Oncorhynchus tshawytscha). Development of hydroelectric
potential in the northwestern United States has resulted in the loss of a
significant portion of the salmon spawning habitat. On a national basis,
i-nterest is very high in minimizing losses to chinook salmon, and, if
possible, expanding existing stocks. State, and local interest is very
high in maximizing populations of this highly prized commercial,
recreational, and subsistence species.
The Susitna River is considered the major contributor of chinook salmon to
Cook Inict (ADF&G/Su Hydro 1981). Although chinook salmon of th€ Susitna
River are not managed at present for commercial harvest, they provide
important sport and subsistence fisheries. In 1982, approximately 10,000
chinook salmon were taken by sports fishermen with a fishery effort of
28,000 man-days.
The primary Susitna River habitats which could be lost between the Devil
Canyon dam site and the tri-rivers confluence are the side channels and
sloughs. Chinook salmon juveniles rear year-round in the mainstream
Susitna River and associated side channels, sloughs, mouths of tributaries
and lateral tributaries. Because studies to determine the importance of
this reach of the Susitna River to salmonids are still ongoing, project
impacts to this species have not been adequately established nor have
potential mitigation alternatives been evaluated.
2. Coho salmon (Oncorhynchus kisutch). Hydroelectric development in the
Northwest United States has resulted in a significant depletion of coho
salmon stocks.
The coho salmon is an important commercial resource and a highly prized
sport fish in Alaska. The 1981 commercial harvest of cohos for the Upper
Cook Inlet was just under 500,000 (ADF&G/Su Hydro 1982). The contribution
of the Susitna River to this fishery has been estimated as 50 percent.
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Coho salmon are also an important sport fish in the Susitna River system.
In 1981, sport fisherman harvested over 13,500 coho from. the Susitna River
system. The commercial harvest of coho in 1982 attributable to Upper Cook
Inlet was 777,000 fish.
For spawning, cohos predominantly dep.end upon clear water tributaries with
limited use of the side channels and sloughs. The sloughs also provide
important rearing habitat (Schmidt and Trihey 1982). Because the side
channels and sloughs will probably be affected, cohos are susceptible to
project impacts above Talkeetna. The potential of the project to
adversely impact important coho salmon habitat below the tri-river
confluence has not been clearly established.
3. Sockeye salmon (Oncorhynchus nerka). Past depletion of sockeye salmon
stocks in the Pacific Northwest as well as in Alaska has resulted in major
interest in this speci.es. Restoration programs have been ongoing in
Alaska for several years. Thus there is considerable national, state, and
local interest 'in avoiding adv.erse impacts to sockeye, the most
commercially important of the Pacifi.c salmon. The 1982 Upper Cook Inlet
sockeye commercial -catch was 3.2 million {ADF&G/Su Hydro). Contribution
from the Susitna River to this catch is estimated to be perhaps 1/2
million. Sockeye salmon is also considered an important species to sport
and subsistence fishing interests.
Spawning -habitat for sockeye salmon above Talkeetna appears to be limited
to the sloughs. Although a small proportion of the Susitna sockeye run,
those using habitat above Talkeetna will be highly susceptible to project
i:lilpacts because the sloughs would be prone to project-caused changes
{terrestrial Environmental Specialists, Inc. 1982). Below Talkeetna, th~
extent of project-related impacts to sockeye salmon has not been
adequately established.
4. Chum salmon (Oncorhynchus keta). Commercially, chum salmon are second in
value to sockeye salmon in~ upper Cook Inlet; the average commercial
catch being just over 700,000 during the last ten years {ADF&G/Su Hydro
1982). The commercial harvest of chur.l salmon in Upper Cook Inlet in 1982
was 1.4 million. Sport and subsistence fishing for chum salmon is
important, however, it can be considered the salmon species of least value
to these interests.
Based on the 1981 fisheries studies data, chum salmon is the predominant
salmon species found in the Susitna reach between Talkeetna and the Devil
Canyon dam site (Terrestrial Environmental Specialists, Inc. 1982).
Predominant use of the sloughs is by spawning chums and as such severe
adverse impacts can be predicted to this species if the project results in
the elimination of access to the sloughs. Without mitigating flows, the
loss of the slough habitats is predicted'. Mainstream spawning by chum
salmon was noted at ten sites in the Talkeetna to Devil Canyon segment of
the Susitna {Terrestrial Environmental Specialists, Inc. 1982). The
contribution of the mainstream beds to overall chum spawning is not
considered to be substantial. Potential project-related impacts
downstream of the confluence of the Susitna, Talkeetna, and Chulitna
Rivers has not yet been clearly established.
Chum salmon habitat historically extended south to the coastal streams of
Washington and Oregon. The quality of its habitat in that area has been
significantly reduced. Accordin~ly, fro~ the national perspective, \le
consider it becoming scarce.
5. Pink salr.10n {Oncorhynchus gorbuscha}. Pink salmon exhibit a two year run
cycle. During even years the Susitna River pinks contribute more than any
other sal~on species to the commercial catch attributable to the Susitna
River. The. cor.1mercial value of this species ,is considered high and the
Susitna River is considered the major contributor to the upper Cook Inlet
commercial catch. Pink salmon are important to sport and subsistence
fishing interests.
Information from the 1981 field season provided insight as to habitats of
i~portance. Spawning pink salmon were found in the sloughs as \tell as the
tributaries to the Susitna River {Terrestrial Environmental Specialists
1982). Data must be obtained from a peak run of pinks to allow a complete
assessment of valuable habitats. Data on odd-year runs may not be
indicative of habitats which receive the heaviest use.
Pink salmon was historically limited in range to coastal streams of
north-\test \-lashington and north. No significant reduction to that habitat
has occurred. Accordingly pink salmon habitat is considered abundant on
the national and ecoregion basis.
6. Arctic grayling (Thymallus arcticus}. Native arctic grayling are found in
1-lichigan, the headwaters of the r.lissouri River, and in Alaska {Eddy 1969).
Due to its relatively rare status in the conterminous states, this sport
fish is of high national interest. In Alaska, grayling are a popular
sport fish. The grayling population within the upper Susitna River basin
is rather large, due principally to lack of exploitation. In that it
comprises a very healthy population of a popular sport fish, interest on a
state and local basis is high.
Arctic grayling is the predominant fish species in the Susitna above Devil
Canyon. The lower Susitna river smaller populations are found and
spawning appears to be restricted to the clear water tributaries
(Terrestrial Environmental Specialists, Inc. 1982).
Based upon data from the 1981 Susitna project field studies the upper
Susitna River impoundment areas presently supports a population of
approximately 10,000 (Terrestrial Environmental Specialists, Inc. 1982).
Since grayling inhabit Susitna River and tributary reaches which would be
inundated, this species will be severely impacted. Downstream from the
impoundments, project impacts have not yet been adequately evaluated.
7. Rainbow trout (Salmo gairdneri) fit all the necessary criteria for a
mitigation evaluat1on species and are well suited to represent fish
species in the Cook Inlet to Devil Canyon reach. They are considered
abundant within their historical range. Habitat to be impacted is of
r.~dium value for this species.
8. Burbot (Lota lota} are relatively abundant in the Susitna River year-round
and are sensit1ve to project impacts. They are considered abundant within
their historical range. Habitat to be impacted is of medium value for
this species.
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9. Dolly Varden [Salvelinus malma) are an important sport fish and should be
considered as an evaluation species as well. They are considered abundant
within their historical range. Habitat to be impacted is of medium value
for this species.
Literature Cited
Alaska Department of Fish and Game/Susitna Hydro Aquatic Studies.
1981. Juvenile Anadromous Fish Study on the Lower Susitna River. Phase I
Final Draft Report, Subtask 7.10. Susitna Hydroelectric Project. Alaska
Power Authority. Anchorage, Alaska.
Alaska Departraent of Fish and Garae/Susitna Hydro Aquatic Studies. 1982.
Stock Separation Feasibility Report, Adult Anadromous Fisheries Proj~ct.
Phase I Final Draft Report, Subtask 7.10. Susitna Hydroelectic Project.
Alaska Power Authority. Anchorage, Alaska.
Ballard, W.B., C.L. Gardner, J.H. Westlund, and J.R. Dau. 1982.
Moose-Upstreara. Biy Game Studies Vol. III. Phase I Final Report. Susitna
Hydroelectric Project. Alaska Department of Fish and Game for the Alaska
Power Authority. Anchorage. Alaska.
Ballard, W.B., C.L. Gardner, J.H. Westlund, and J.R.
Biy Gar.1e Studies Vol. V. Phase I Final Report.
Project. Alaska Department of Fish and Game for
Authority. Anchorage, Alaska.
Dau. 1982. Wolf.
Susitna Hydroelectric
the Alaska Power
Ballard, W.B., J.H. Westlund, C.L. Gardner, and R. Tobey. 1982. Dall Sheep.
Big Garae Studies Vol. VIII. Phase I Final Report. Susitna Hydroelectric
Project. Alaska Department of Fish and Game for the Alaska Power
Authority. Anchorage, Alaska.
Eddy, S. 1969. How to Kno\'1 the Freshwater Fishes. 2nd Ed. ~lm. C. Brown
Co. Publishers. Dubuque, Iowa.
Gipson, P.S., S.W. Buskirk, and T.W. Hobgood. 1982. Furbearer Studies.
Phase I Report, Subtask 7.11. Susitna Hydroelectric Project. Alaska
Cooperative Wildlife Research Unit for the Alaska Power Authority.
Anchorage, Alaska.
Kessel, B., S.O. MacDonald, D.O. Gibson, B.A. Cooper, and B.A. Anderson. 1982.
Birds and Non-Game t·tammals. Phase I Final Report, Subtask 7 .11. Susitna
Hydroelectric Project. Univ. of Alaska Museum for the Alaska Power
Authority. Anchorage, Alaska.
Konkel, G.U., LC. Shea, K.E. Bulchis, L.C. Byrne, D. Pengilly, and K.S.
Lourie. 1980. Terrestrial Habitat Evaluation Criteria Handbook -Alaska
(Review Copy). U.S. Fish and Wildlife Service. Anchorage, Alaska.
Miller, S.D. and D.C. McAllister. 1982. Black Bear and Brown Bear. Big Game
Studies Vol. VI. Phase I Final Report. Susitna Hydroelectric Project.
Alaska Departr.1ent of Fish and Garae for the Alaska PO\Ier Authority.
Anchorage, Alaska
Modafferi, R.D. 1982. Moose-Ommstream. Big Game Studies Vol. II. Phase I
Final Report. Susitna Hydroelectric Project. Alaska Departraent of Fish
and Game for the Alaska Power Authority. Anchorage, Alaska.
, ....
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Pitcher, K.W. 1982. Caribou. Big Ga~e Studies Vol. IV. Phase I Final Report.
Susitna Hydroelectric Project. Alaska Depart~ent of Fish and Game for the
A 1 ask a PO\ver Authority. Anchorage, A 1 ask a.
Robbins, C.S., B. Brunn, and H.S. Zim. 1966. A Guide to Field Identification
Birds of North America. Golden Press. New York, New York.
Schmidt, D. and E.W. Trihey. 1982. Questions and Answers on Fish. Pages 4-5
in the Susitna Hydro Studies January 1982 Newsletter. Alaska PO\Ier
Authority. Anchorage, Alaska.
Terrestrial Environmental Specialists, Inc. 1982. Environ~ental Report.
Susitna Hydroelectric Project Feasibility Report Vol. 2. Alaska Po\ler
Authority. Anchorage, Alaska.
White, C.N •• 1974. Survey of the Peregrine Falcon and Other Raptors in the
Proposed Susitna River Reservoir_Impoundment Areas. U.S. Fish and
Wildlife Service. Unpublished Interir.l Report. Anchorage, Alaska.
February 3, 1983
COMMENTS ON: U S Fish & Wildlife letter of January 24, 1983, project
area resource categories
The Alaska Power Authority concurs with the mitigation goals out-
line for species in the project area. These goals were incorporated into
the Power Authority•s Mitigation Policy November 1981, and revised April
1982. The mitigation plans presented in Exhibit E are designed to
achieve these goals.
The Power Authority does, however, feel that the process that iden-
tifie8 habitat resources in the project area as Resource Category II in-
vites comment. The procedures outlined in CFR 46, No. 15 of January 23,
1981, seem to indicate that if a resource is abundant on a national
scale but scarce in a particular region, then based upon regional scar-
city, in that region, it may be identified as R_esource Category II. To
work in the other direction, where the resource is abundant on a region-
al basis, but not on a national basis does not seem to warrant a finding
of resource scarcity.
The Notice of Final Policy outlines a procedure for determining
Resource Categories. The Alaska Department of Fish and Game, which is
the Resource Manager in the project area, does not consider the re-
sources in question as being scarce in either the eco-region or the
state. Formal comments from the Alaska Department of Fish and Game
Comments/USFWS
Project Area Resources
February 1. 1983
Page 2
state. Formal comments from 'the Alaska Department of Fish and Game
should have been included and commented upon to reflect "consultation
and coordination with the state agency responsible for Fish and Wildlife
Resources".
The technical rationale for designation should also "discuss and
contrast the relative scarcity of the fish and wildife resources on a
national and eco-region basis".
To the best of our knowledge, no area in the eco region (Ml310
Alaska Range province) has been identified as an Important Resource
Pr_oblem area nor has the project area been identified as such. If it
has been so designated, a copy of the designation document from the
Director of the Fish and Wildlife Service is requested.
Fi na 11 y, the Power Authority is concerned that the designation of
resource values in the Project area as Resource Category II is inconsis-
tent in the context of land management activity in Southcentral Alaska.
There seems to be little or no basis, when reviewing past and present
state and federal resource agency actions in the Project vicinity. to
substantiate Resource Category II classification.
Comments/USFWS
Project Area Resources
February 1, 1983
Page 3
While we take strong exception to the designation, it should be re-
iterated that Resource Category II goals are consistent with the
Authority's goals and mitigation plans for the project. Mitigation
planners for the Project would profit by the experience gained in
mitigating in Resource Category II habitat and would appreciate being
informed of such activity as may be presently on-going in Alaska.
JS:gh
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APPENDIX EllF
CORRESPONDENCE RELATING TO
FEASIBILITY ASSESSMENT
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APPENDIX ll.F
ASSESSMENT OF FEASIBILITY
On March 15, 1982, the Susitna Feasibility Report was distributed to federal.
state, and local agencies for review and comment. It was also made available
for general public review. During April and May 1982, all background and
support documents were distributed. This appendix contains the list of
agencies to whom the report was distributed. A1so ·included are agency comments
and testimony concerning the Feasibility Report.
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RECEIPIENTS OF THE
SUSITNA HYDROELECTRIC PROJECT FEASIBILITY REPORT
Mr. James N. Souby
Director
Division of Policy Development
and Planning
Room 450
Court Bu i 1 ding
Pouch AD
Juneau, AK 99811
Mr. Lloyd Pernela
Director
Division of Energy and Power
Development
MacKay Building, 7th Floor
338 Denali Street
Anchorage, AK 99501
Mr. Ron Lehr
Director
Division of Budget and Management
Mai 1 Stop 0102
Pouch AM
Juneau, AK 99811
Mr. Robert J. Cross
Administrator
Department of Energy
Alaska Power Administration
P .0. Box 50
Juneau, AK 99802
Mr. John R. Spencer
Regional Administrator
Region X
U.S. Environmental Protection
Agency
1200 Sixth Avenue
Seattle, WA 98101
Ms. Judy Schwarz
U.S. Environmental Protection
Agency
l\1a i 1 Stop 443
Region X EPA
1200 South 6th Avenue
Seattle, WA ~8101
Colonel Lee Nunn
District Engineer
Alaska District
U.S. Army Corps of Engineers
P.O. Box 7002
Anchorage, AK 99510
Mr. Keith Schreiner
Regional Director, Region 7
U.S. Fish and Wildlife Service
lOll E. Tudor Road
Anchorage, AK 99503
Mr. Robert Bowker
Field Supervisor
U.S. Fish and Wildlife Service
Western Alaska Ecological Service
733 West 4th Avenue, Suite 101
Anchorage, AK 99501
Mr. John Cook
Acting Regional Director
Alaska Region
National Park Service.
540 West Fifth Avenue
Anchorage, AK 99501
l\1r. Larry Wright
National Park Service
lOll E. Tudor Road, Suite 297
Anchorage, AK 99503
Mr. John Rego
Bureau of Land Management
Anchorage District Office
4700 East 72nd Avenue
Anchorage, AK 99507
Mr. Robert McVey
Director
Alaska Region
National Marine Fisheries Service
NOAA
P.O. Box 1668
Juneau, AK 99802
Mr. Ron Morris
Director
Anchorage Field Office
National Marine Fisheries Service
701 C Street
Box 43
Anchorage, AK 99513
Mr. Max Brewer
Office of the Director
Special Assistant for Alaska
U.S. Geological Survey
218 E Street
Anchorage, AK 99501
Mr. Ronald 0. Skoog
Commissioner
State of Alaska Department of
Fish and Game
Subpart Building
Juneau, AK 99811
Mr. Thomas Trent
State of Alaska
Department of Fish and Game
2207 Spenard Road
Anchorage, AK 99502
Mr. John Katz
Alaska Department of Natural
Resources
Pouch M
Juneau, AK 99811
Mr. Alan Carson
Alaska Department of Natural
Resources
Pouch 7-005
Anchorage, AK 99510
Mr. Ty Dilliplane
State Historic Preservation
Officer
Alaska Department of Natural
Resources
Division of Parks
619 Warehouse Avenue, Suite 210
Anchorage, AK 99501
Ms. Kathy McConkey
Copper River Native Association
Drawer H
Copper Center, AK 99573
Mr. Ernst W. Mueller
Commissioner
Alaska Department of Environmental
Conservati.on
Pouch 0
Juneau, AK 99811
Mr. Bob Martin
Alaska Department of Environmental
Conservation
437 E Street, 2nd Floor, Suite 200
Anchorage, AK 99501
Ms. Lee McAnerney
Department of Cornmunity and
Regional Affairs
Pouch 8
Juneau, AK 99811
Mr. David Haas
State-Federal Assistance
Coordinator
State of Alaska
Office of the Governor
Division of Policy Development
and Planning
Pouch AW
Juneau, AK 99811
Ms. Wendy Wolf
Office of Coastal Management
Division of Policy Development
and Planning
Pouch AP
Juneau, AK 99811
Mr. Lee Wyatt
Planning Director
Matanuska-Susitna Borough
Box B
Palmer, AK 99645
Mr. Roy Huhndorf
President
Cook Inlet Region, Incorporated
P.O. Drawer 4N
Anchorage, AK 99509
Mr. Max Dolchak
Executive Director
Cook Inlet Native Association
670 Firewood Lake
Anchorage, AK 99502
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Mr. Herb Smelcer
President
General Manager
AHTNA Corporation
Drawer G
Copper Center, AK 99573
Mr. Michael Meehan
Director
Planning Department
Municipality of Anchorage
Pouch 6-650
Anchorage, AK 99502
Director of Planning
Fairbanks North Star Borough
520 5th Avenue
P.O. Box 1267
Fairbanks, AK 99811
April 16, 1982
DEPAR'D1ENT OF NATURAL RESOURCES'S
TESTIMONY TO THE ALASKA PO~ER AUTHORITY BOARD Of DIRECTORS
I appreciate the opportunity to provide comments to.the Power Authority
Board of Directors on the Susicna Hydroelect::ic project:. I r·egret that.
because of other commitments in Juneau. I am unable to personally deliver
these cotmUent.s.
At the invitation of the Alaska Power Authority. the Department of
Natural Resources has been vorking informally vith the Authority over
the last two years to help fonaulate and carry ou:: studies designed to
ansve~ the questions vhich ultimately vill de~errnine whether the Susicna
Dam proposals are feasible. the purpose of this testimony ~oday is
tvofold: First. to identify Susitna Hydroelectric issues that are
within the sphere of DNR's authority; and second, to make recommenda-
tions c.o the Board of Direc~ors on the continuation of project develop-
ment, as requested in the January 26 letter from Mr. Conway.
SUSITNA HYDROELECTRIC RELATED ISSUES t!I!HIN THE PURVIElol OF 'mE DEPARTMENT
OF NATUPAL RESOURCES
The Department of Natural Resourees ~ill be required to make decisions
on. t~o major facets of the Susitna Hydroelectric Project. These are: . .,_:.~--:"-~.
1. DNR responsibilities for l:ater appropriac.iotl (and .possibly instream
flov reservations) fro~ the Susitna River. ·
2. Rights-of-t.ray pe['l;lits for access into the dam sites and transmission
line routes. Other land use permits -for access to construction sites.
gravel for construction, and other land use related needs as they oecur
on state oYned lands.
The role of the Department of Natural Resources in ~at.er rights appro-
priation vill be an adjudica~ory one. According to Alaska Statute
"6.1S.oao (b), the impacts of uater appropriation on the public interest.
shall be considered during adjudication. Areas of public int.erest are
defined in the Statute as follous:
1. The benefit to the applicant resulting froc the proposed
appropriat.ion.
2. The effect of the economic activity resulting from the proposed
appropriatio:l.
3. The effect on fish and game r~sources and on public recreational
opportunities.
4. The effect on public health.
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~. The effect of loss of alternate uses of water that might be
made within reasonable time If not precluded or hindered by the
propos~~ appropriation.
6. Ham to other perso:1s resulting frorc the proposed appropr:iat1on.
7. The intent and ability of the applicant to complete 'the appro-
priation.
8. The e!fect upon access co navigable ~aters.
The DNR t.:ill be looking to the Feasibility Study daC.a and information to
describe the relationship between various streamflo~ levels and hot.: they
Yiil impact fisheries.and aquatic habitat downstream. Thus, from this
Depart.Ailent' s perspective, inscream flo\1 studies and the -relationship of
various flo~ ievels to aquatic habitats and fisheries 'resources are
vital. The studies administered by the APA will be the fundamental
source of data and infon:~ation used by DNR to make the public interest
findings described above. \.!e are eager to· revieY and comment upon the
present and iu:~.:re plans for instream flov studies. To' date, \.7.e have
not been provided an <>pportunity to revieY or comment upon the instream
flow study approach.
The access to the dam sites and the _policy surrounding the extent of
access after construction t.:ill lead t<> one of the most ~ignificant
im?acts of the project. The Po\ler Authority has seated that the perm:l,t.
for use of a "pioneer road" is needed in 1982 (before a F.E.R.C. permit
is issued) H the power is to be on line ele'l.•.en years later. One signifi-
canc issue is the possibility of the construction of a road to· the
proposed ciax::: sites ana a subsequent decision by the'sta-ce· not ·to cOnstruc-t
the da:!!s. lt vould appear t.o be in the best interest of the Paver ·
Authority, the land managin£ agencies, and the public to identify other
alternatives '-l'hich '!.."ill allo'l." the necessary access to the proposed datU
sites in a manner Yhich prevents irreversible impacts. In order to
prevent this issue from bein& a potential delay in progress, Ye -recomm~nd
that the AI'.A. take the lead in convening a multi-agency, multi-discipl.inary
effort to accomplish the goal stated above.
The second issue is the long term land use implications of access to t:he
proposed dare sites. The provision of access to the dam site~ should not
UnYittingly determine the types and extent of land USe impact on the
surrounding lands in the upper Susitna Valley. Carefully determined
access route decisions could result in a multiple purpose route vhich
could facilitate and enhance other uses of the surrounding lands. ln
order ro accomplish this, tno.: Cii!r. Oiccess route ciecis!.on should be made
in conjunction vith su:-rounc.ling land c~crs, land manage!:"S, and the
general public. As on the other-issue above, the DNR is villing to
participate cooperac.h·ely with the Alaska Paver Authority, other agencies,
and the public to resoive this rcatt~= so that it does no: beco~e a
potential delayin£ factor !or the proposed project or a future manage-
ment problem for land o~:ne:::s .:md ma:tagers.
Sml"4.ARY AND RECO!·IMENDATIONS
In SWll..o:~ary. the Department of l\atural Resources has three recommenda-
tions:
1. The Department supports continued studies in the socio-economic,
technical, and environmental areas. The preliminary uork accomplished
so far indicates that the project is technically feasible. Further
~ork is needed to establish the information and data for uater
appropriation and fishery mitigation. Additionally, ue recommend
further ~ork on the timing, route and conditions of access to the
proposed dam sites.
2. With respect to the ques~ion of ~hether it is desirable to
submit an application to the f.E.R.C. on September 30, 1982, ue
offer the follo~ing com:nents. The ~A Board of Directors and the
staff should carefully ueigh the advantages and disadvantages of
sub~itting the formal application on September 30, 1982. If that
course of action ~ould result in the ~A acquiring a F.E.R.C.
permit to construct in the most timely and economical ~ay, then
that course of action makes sense. Ho.wev.er, if on the other hand,
a formal application would result in delays, increased pot:entials
for litigation, and a hardening of acversarial roles bet~een the
APA, other agencies, and other int~rested parti~, ~hen the possibility
of these delays should be considered. ~e believe that the APA
Board and the Staff are in the best posicion to evaluace pros
and cons and to determine vhether a F.E.R.C. application on
September 30, 1982, is desirable or not. Froc our more narrov
agency standpoint, DNR is not oppoJed to a F.E.R.C. application so
Ions· as our agency concerns and res'ponsibilities can be fully ana
openly det.er.nined through the traditional intervenor process.
3. We co~pliment the APA Board of Directors and staff for encour-
aging inter-agency interdisciplinary approach to identify ~ays to
improve the coordination and ultimately the results of the feasibility
studies. We believe that strengthening this approach vill facilitate
a more cooperative and constructive role for those agencies uhich
have responsibilities that require them to take action on the
Susitna Hydroelectric Project. Specifically, ve recommend strength-
ening and enhancing the role of a group similar to the Susitna
Hydroelectric Steering Committee vhich has been providing informal
agency comments to the APA on this project for the last tuo years.
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1. Inadequacies of population estimates of: 1) moose and other large
animals in the downstream Susitna below Devil Canyon; 2) caribou
subherds in Talkeetna River, Chulitna Hills, and Upper
Susitna-Nenana drainages; 3) wolves in the Keg Creek, Porta~e
Creek, Stephan lake, and upper Talkeetna River; 4) wolverine
throughout the study area; 5) black and brown bear with the entire
study areas; 6) marine mammals such as Beluga Whales in the lower
downstream estuarine area; 7) even year numbers of pink salmon.
2. Major data gaps exist concerning the use of specific types of
habitat of certain species during various seasons. Among these
are: 1) use of downstream vegetative by moose and bear; 2) use of
the main stream reservoir area of vegetation by moose during severe
winters; .3) use of the impoundment area in spring by black and
brown bears; 4) home ranges of black bears; 5} use of sloughs in
the lower Susitna by fur bearers and water fowl;(§j use of the
mainstream Susitna and other sloughs below Talkeetna by salmon and
other fish species; and 7) significance of the mainstream/clea~
" water confluence areas for chum and coho salmon spawning and
distribution of juvenile salmon all resident fish throughout the
main stream Susitna, especially in winter months.
3. Much additional study is needed to address complex issue of
interrelationships between species wfthin th study area. Specific
information needs are: 1) seasonal predation levels upon moose and
caribou by black and brown bear and wolves; 2) importance of moose
and caribou carton to species of wolverine, red fox, and other
1
small mammal; 3) use of salmon population by black and brown bear;
and 4) potential conflicts between black bear and brown bear
populations caused by displacement during project construction.
4. Report fails to project any estimates of potential numbers of
species that would be actually gained or lost as a result of
project construction. Specifically: 1) loses of moose through
starvation resulting from displacement; 2) moose losses through
increased predation by wolves and bear~on displaced population;
3) loss of moose, caribou, bear, wolf,~ther other species through
\o'l~
road strikes; 4)hof moose, caribou, bear, etc. through attempts to
cross the reservoirs; 5) effects of increased predation upon
caribou by wolves as moose populations decline; 6) losses to black
and brown bear through unavailability of Prairie Creek and lower
Susitna Salmon populations; 7) loJses of brown beans through
interspecies conflict caused by human disturbances, displacements,
and reduces food sources; and 8) losses of black bears through
intraspecies conflict with brown bears.
5. Report deficient in fisheries. Specifically: 1) loss of potential
enhancement possibilities for salmon upstream of Devil Canyon; 2)
losses or gains associated with potential alteration of habitat
below Devil Canyon to Cook Inlet; 3) losses to anadromous and
resident fish downstream from Devil Canyon during the filling of
the reservoirs; 4) losses or gains associated with artificial
manipulation of fish habitat recommended as mitigation for salmon
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losses; 5) losses associated with increased fishing, both legal and
illegal, due to increased access.
6. Although report addresses all species and potential impacts, it
fails completely in almost all cases to identify specific losses on
any real means to offset even the very generally identified impacts
to fish and wildlife •
Examples: 1) Upper basin moose,.. .. /eport recommends only
compensation by prescribed burning and also states method is
experimental and needs more study; 2) black bear -report
recommends literatur_e review to identify management techniques
or compensation with other species; 3) brown bear -no
mitigation recommended other than aiding other local species;
4) woJf -unless moose mitigation works no other
recommendation made; 5) wolverine -no recommendation other
than aid to other species; 6) salmon -habitat loss through
flow reduction will be mitigated by modifications of the
existing stream or by adding gravel build spawning areas,
artificial spawning channels and hatcheries are mentioned but
no discussion of the hig~~xperimental nature of these types
of projects in Arctic environments; at and 7) salmon -no
discussion of potential impact of mixing hatchery stocks with
wild stocks; 8) salmon -temperature problems downstream of
Devil Canyon will be mitigated via multi-intake flow system -although no evidence i s presented to substantiate this claim; -9) resident fish -no information is presented to support
3
claim that a viable recreation fishery could be maintained in
reservoirs.
7. Current demand projections are not weighted to consider the last ~ --several years when price -induced conservation has dramatically -reduced the demand for electricity.
8. Acres• report did not address salmon enhancement possibilities in
upper Susitna basin.
9. Acres• downplayed devastating impacts of the project on the
~
'/elchina caribou herd du~ to increased hunting pressures and
interruption of traditional migrating ground.
10. Moose habitat along the River would be greatly diminished by the
decrease in the willow growth.
...s 11. The Hatana studies state that in 100 yea~ the reservoir will fill
some 5% of its)'total volume with sediment ••• All estimates for
sediment load are based on the river carryin~ ~t 10% or 5%, or ,..
even 1% sediment load by volume, but .04% as the sediment load •••
What this estimate says to me is that research is 1ong on watered
' down data and short on practical judgement.
12. The way it is designed now the Watana reservoir would become silted
in 25 to 35 years. This is at a 5% sediment bearing rate -fo.r
below the 30% which is possible for glacial rivers to run at.
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13. I question the amount of mixing Acres• suggests sediment will be
undergoing in the reservoir, and I question the entrapment rate or
the rate at which the silt falls out of the water and settles in
the reservoir~ Despite abundant research which would indicate
entrapment rates substantially high, Acres American advances 70% as
the lower end of their entrapment studies, or entrapment estimates.
It disturbs me that probably the simplest measure of sediment load,
the ratio of sediment to water, in never plainly stated.
14. Scanning Acres American's research ••• I question thP. lakes that
they draw for comparison. There are substantial differences
between natural lakes in _southern British Columbia)"'and the Watana
Reservoir. The one in British Columbia is about a ninth the size
15.
of the Watana reservoir.
Our particular concern is the destruction of salmon spawning area
in the Susitna sloughs ••• before we go or with this project I
believe that they (Acres)
'i'e.l"')
spawn successfully 1'.J. how
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should have figured out how salmon can
d.~'";
the sloughs can be prevented from A up,
how the fish will have clear water, and the sufficient amount of
water with the dams being raised and lowered.
16. I have real problems with this base case plan, in that it is
predicated entirely upon the development of the Beluga coal fields
and to a world class exporting coa~ complex within the next ten
years ••• I feel that the base case plan, with all of its critical
assumptions regarding massive coal production within ten years from
5
what is currently only a potential prospect, and further
restricting this potential to the whims of the foreign coal market '
is a fictitious economic measuring stick.
17. What bothers me most about the proposed Susitna project is the lack
of a complete picture of information ... 'rhe Acres' report seriously
down-played the uncertainties and fail~d to show all impacts and
methods of mitigations. The uncertainties include whether the
project is truly, economically feasible. A cost overrun .of 20%
makes the project uneconomical.
18. I have found that we can~ot adequately evaluated the potential
environmental impacts of the proposed Susitna Dam ... with the first
year of extensive fishery and wildlife studies now complete, I feel
that it is impassible to determine whether the project is
environmentally sound. Similarly, I feel it is also impossible to
compare the environmental impacts of alternatives because of lack
of information.
19 .... if we build one dam, the Watana dam, and then the power needs do
not live up to what we think they are going to be, we can just
build one dam. However, it does not actually come out and say it
in the Acres 1 Report, but their figures show that 70% of the cost
of this project is in the first dam. However, that first dam is
only projecting 50% of the power output and gigawatts, which is the
actual power that we are paying far per kilowatt. If we did build
one dam, with the cost estimates in the project of the 20%, 17 to
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20% overrun, making it unfeasible economically, than building one
dam -the Acres• Report says that in buildin~ one dam will not be
economically feasible, we have to build both dams to make it
economically feasible.
20 ... I would like to address the proposed road access to the dam
site... I feel that it would be a lot more economically viable to
use the old cat trail that goes across the top of the ledge over to
Portage Creek and build one bridge across Portage Creek and then go
on up to where the dam sites are ••• If they go ahead and use the
road access that they are talking about at this time and put the
bridge across the~sitna down below Indian River next to the ---rai~road trestle, that is going to mean enlarging the staging area
at Gold Creek and there is going to be a lot of activity going on
in th~t area; in a real remote situation.
21. The Acres• report also states that this completed project would
result in the shutting dawn of all other generation facilities in
the Railbelt ••• In case of a failure of any sort on the facility,
power generation or transmission wquld cease or seriously be
impaired. It seems more feasible to have numerous smaller hydro,
natural gas, wind, solar, and geothermal-thermal facilities to
distribute the stress providing the electrical power.
22. Why is the preferred or chosen access route a road from the Park
Highwayf, which would, according to the Vice President of Acres
...J"e" American, be double wide and paved, ~e the overwhelming majority
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of th= ~~ole in this area favored and all rail route to the site
of th~ pr~Dosed project.
23. The proj~ itself would add a serious blow to ridding the state of
its boom/~ust economy. A recent report by the Army Corps of
Engineer~: entitled 11 Rainbow or Opportunities .. states that 70% of
the labor -=force for this project would be made up of skilled trades c--
from out$f~~e Alaska.
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RESOURCE AGENCY'S COMMENTS
1. There is been a failure to quantify the habitat types present, a
failure to anticipate impacts, and to identify the required
mitioation ••• Some of the followinq deficiencies have been noted:
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1) Terrestrial studies have focused on the impoundments and their
immediate vicinities~ neglecting in large part the downstream
areas, transmission and access corridors of secondary or indirect
impact; 2) inadequate data to describe the data between various
stream flows and the projective of the fisheries and the aquatic
habitat downstream from Devil Canyon dam site; 3) ant.icipated water
-\-v.or \o iJ ··~ '
temperature and l\ levels "in the reservoirs and downstream of Devil
Canyon have not been satisfactorily investigated, especially
important to determine fisheries impacts; 4) terrestrial impact
assessment and mitigation options are quite general and
insufficient to provide adequate basis for full discussion of the
project; 5) public access and mode and route of construction access
need to be more fully addressed within the context of mitigation;
and 6) insufficient look into the alternative;of the Susitna
project.
2. Access is the topic being discussed. We also have some concerns of
the environmental impacts. Those routes are: 1) the one south of
the Susitna River between Devil's Canyon and l-latana; 2) the
corridor paralleling the Indian River; and 3) the route proposed
so~th of the Denali Highway. The impact here (Denali) is somewhat
mitigated by the western route as opposed t the route via Butte
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3.
Lake. It is still unclear as to the relative magnitude of the
impact on caribou posed by the western route south of the Denali
Highway. While we are concerned as to the impact on that caribou
herd, we feel that the environmental trade off in question is o~e
of the impacts -the caribou herd versus the impacts of more
projective habitats in the area of Indiah River or the Fog Lakes
area. From an environmental standpoin~, the route southerly from
the Denali seems preferable from the aspects of minimizing
disturbance of projective habitat. The route form the Denali,
however, poses a secondary impact; that of human access to the
project area after construction.
General comment that both the Acres• and Battelle studies were
11 Ultra conservative... I would like to point out just a few of the
numerous items that led me to the conclusion previously mentioned.
For instance, the coal alternative anticipates an operating coal
mine at Beluga supplying a major export market. This may or may
not be a reasonable assumption; however, the manner in which it is
applied in the study certainly places the coal alternative in the
best possible situation. In addition, the coal alternative did not
anticipate worst case environmental restrictions over and above
those now on the books. The worst may be yet to come relative to
burning coal and the added cost ..• One other item, as I understand
the environmental assessment, all the moose at Watana over a two
and a half year period are considered dea·d moose. I believe this
assumption to be an unduly harsh evaluation and not realistic.
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Downstre:am water quality changes are certainly going to exist as a
result o-F the project ...• what we do not know at this point is what
c.
do these u:harges mean or what they imply in terms of downstream
biologica] effects or downstream morphological effects on the
actua 1 s'Oream bed itself ...• The second group of concerns ..• are
downstreann flow volumes and water 1 evel s •.. a Apparently the project
envisions as much as a foot and a half of lower water level in the
summer ..... Jtt,w does this effect side channel situation, the habitat --areas, what about sediment transport? How does it effect the
recreatioroal use of certain reaches of the downstream area, what
c.lc....s.S
about river travel, aesthetics, etc •••• Another l\ of concerns waul d
be construction camp impa_cts ...• Where are you going to discharge
sewage, how are you going to treat sewage, where are you going to
get your water supply, what about power?... Another concern,
auestion, I have relates to what are going to be the recreational
impacts of a town of say 4,000 or so 1 ocated in the wilderness? .••
They are going to want to hunt, to fish •••• To what degree;~-that
going to be controlled or managed? What are those impacts; how
serious ar they? •.. The final class of specific questions that I
raise relate to the access issue on transportation issue to the dam
sites themselves. First, I am still exploring my view of the
feasibility work in reasoning behind the model question in why we
are going road transportation as opposed to rail. Are there some
gains to be had in going with the rail transportation or a rail
access situation? ... I am not saying rail is the best way to go, I
am just saying that it seems like we eliminated that possibility
po~sibly out of hand.
11
Charles Conway Jr., Chairman
A.!.aska Power Authority Beard
334 West 5th Avenue
Anchorage, Alaska 99501
Dear Mr. Conway:
SRA Box 1628
Anchorage Alaska 99507
April 16, 1982
The thirty day review period allowed for public comment is way too short of
time to review and formulate comments on such a volume data being presented
by ACRES on the Susitna Hydroelectric Project Feasibility Report. A minimum
of 60-90 days should have been allowed. Because of this short time element,
only the access route to the Dam site is being addressed since this is
probably the most controversial environmental issue. The Dam projects
themselves have only minor en~ironmental impact on both the biological and
social environment.
In reviewing ACRES "Selection of Access Plan" found in Volume 1 Engineering
and Economic Aspects, Section 9-19 Final Draft, and its relation to the
Environmental Assessment Report, Feasibility Report Volume 2 Environmental
Report Sections 1-4 and 5-11 Final Draft, there is not sufficient data
available to verify or uphold their reasons for selecting one route-over
another.
A good example of this is the Upper Susitna-Nenana subherd which is also
called by anothe!" name elsewhere in the report. The Denali route (Plans 6
and 11) was disregarded because of the environmental impact the road would
have on this subhe!"d. Yet in the main environmental assessment on car~bou,
only two sentences where dedicated to this herd. How can anyone make a
sound judgement based on this absolute minimum informat.:.on. Any comments
referred to this subherd in the selection of the access plan can only be
accepted as unconfirmed assumptions. One can also assume from the lack of
data presented in the main environmental assessment that someone is blowing
out of proportion the impact the Denali route will have on the subherd.
The following are specific comments to the various statements made
concerning the recommended selection of the access route.
(2} Page 11-4 11.4 (a) Corridor 1: In .listing the major environmental
constraints the Hurricane-Cold Creek furbeare!" habitat was left out.
This was a major concern in the evaluation portion of selecting the
recommended route.
Page 11-13 11.8 (e){i) Effects on Big Game: ' -
{1) lst Sentence: What is the potential effec~ the selection of an
access plan will have on the Nelchina Caribo~ herd -specifically
the subpopulation? The main environmental assessment only had t>lo
sentences on this particular herd so the importance cannot be too
great.
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(2) · 3rd Sentenpe: It states impacts on hunting for. moose and bear can
be greatly !essened by selecting a route other t~an the Denali
Highway.
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(2)
No matter what route is selected the hunting •.;ill impact any game.
Also under major environmental constraints identified with each
corridor, moose is not mentioned in Corridor 3 (Denali route) yet
it is mentioned in Corridor 1. Bear is not mentioned in any of the
routes.
11-13 11.8 (e)(ii) Effects on Fisheries:
1st Paragraph -What about the angling preasure upon the resident
fisheries of' Miami Lake and the streams of Indian River, Portage
Creek and other streams f'eeding into Susitna River along the Parks
Highway ~ute? In actuality this shouldn't be consern for any
route since through good f'ishery management the lakes and streams
. can be stocked thus improving the fishing. potential.
2nd Paragraph -The impacts on the salmon fishery in Indian River,
Portage Creek and the Susitna River below Protage Creek could be
avoided completly using the Denali access route. Instead the
. solution for reducing the impact was to avoid road access
paralleling the Indian River. But on all.road location maps, the
road is shown paralleling the river and crossing the Susitna River
at Gold Creek. Even if the road doesn't parallel the River, it
will increase the fishing presure both up and dowq stream f'or
several miles where tbe road will cross the River. In this case,
the distance could be greater because of the excellent trail
provided by the railroad bed which· parallels Indian River.
~ Page 11-14 11.8 (e){·iii) Effects on Furbearers:
{ 1) \-1hat type of' potential negative impact will the access road
crossing have on the furbearers? It is questionalble that the road
traffi~ will effect the fox dening areas that are !ocated one mile
from it. Through proper hunting and trapping ~egulations the
furbear impact can be reduced to a nomimal impact for any of the
routes selected. As to loss of habitat, the Denali route ..,ill have
the less disturbance according to 11.5 {d)(iv) which states "The
terrain is relatively flat with few ·;.,etlands involved. '1
(2) Last sentance-This is amisleading statement.· By indirectly
indicating the Gold Creek -Devil Canyon has the least impact on
furbearers by selecting this access, it leads the. reader to believe
this is the prefered route over Denali Highway. There is still the
wetlands between Parks Highway and Gold Creek which are important
to furbearers that has to be addressed further. · G Page 11-1~ 11.8·{e)(v) Effects on Wilderness Setting:
This is a mute question. · There is no ·.ray to maintain the status
quo to the maximum extent possiable due to the type or project
being developed and land ownership envoled. By creating a
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lC&.RaS<----reservoi~ of this magnitude will cause an outc~y of ~he gene~al
public to develop the recreation potenti~l of the area. This will
be compounded by the private landowners seeking to tap this desire
for economical gains. The access will also allow the private
landowne~s to ex?loit the land which is now in a wilderness state.
There are three ways to retain the impact into the area. The first,
is cancel the whole project. The second is by railroad access
only, both during and after construction. This still would allow
the private landowners to exploit their land. It is queationable
if the majority of the public would buy this type of access. The
thLrd way would be a road in from Denali Highway. The route is the
furthest away from the major population 'center of Alaska. This
would have the tendancy to reduce the recreational t~affic. There
would be no road access to the south side of the Susitna River
which would retain it in a wilderness 'catagory unless the private
landowners wants to build a bridge accross the River at their
expense.
A short spur road from Wantana Dam site down stream to the head
waters of the Devil Canyon Dam Reservoir ~auld allow boating
recreationist to use the reservoir. This would allow for
restricting road traffic between the two dams to only project
maintance work. This would preserve the semi-wilderness
characteristics of the area surounding the Devil Canyon Dam Site.
11-19 11.8 (h) Transmission:
2nd Paragraph • It states that if the Denali access route is
selected, one of the reason for not constructing the transmission
line in the same corridor was the adverse visual impact. Yet no
mention was made to the visual impact it would have on the. Parks
Highway route which would be even greater due to the development in
the Gold Creek -Indian River area, the Alaska Railroad and the
access road itself.
11-19 11.9 Evaluation of Access Plans:
2nd Paragraph -When ever a new access is open up into an area it
creats an impact upon the natural resources if left unchecked.
This is where proper resources and land use management planning
comes into being. Prior to creating a new road, in fact for the
whole project, a management plan should be developed to offset or
reduce the overall environmental impacts to an acceptable levels.
The plan should include hunting, fishing, and trapping regulations,
a desirable animal-habitat ratio, ATV closures to protect·the
fragil vegetation or animal disturbance, determine which
archaeological sites are valuable to preserve and excuvate, what
recreational and other development is needed to serve the public,
land use allocation, etc.
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11-20 ~ ~.., 1 1. 9 ( a ){ iii) Biological:
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2nd Pa=--=..g::-:aph -According to 11.5 (d)(iv) the Denali .route ;.;ill
disturt:: ::.=e lease amount of ·.1etland habitat so this can not be a
signiff.:ca.=t concern when comparing one route -..,.i th another. It is
questi.:;ma:,le if the fox denning complex (18 dens) would be effected
by a rc:ad cme mile away.
(2) Just h~ ~portrant is the calving and summer range for the
northwe~te.rn subgroup of the Nelchina caribou herd? As ·previous
stated on.!.y two sentances were devoted to this parti.cular herd in
the main environmental assessment. Even the map which outlined the
caribou calving areas didn't show the loctaion of this subherd
calving a~~a. The location was first mentioned under 11.4 Corridor
Selection and Evaluation where it stated it was near Butte Lake.
Accordi.cg to plate 11.2, the calving ground . ..,.ould be 8-12 miles
from the r-oad so its queationable if .either the road construction
or· traf'!'.ic: would have any effect on. the cows during the calving
period.
Through proper management, the construction period of the road near
the calving area could be restricted until after the calving period
takes place. This could also apply to the migration period. After
construction, road traffie could be reduced to the minimum for the
same periods.
(3) 3rd Paragraph -The consern on opening up the area to more ATV use
can be.stopped through land use management regulations or game
regulations. The area can be closed to ATV use. The USDA-Forest
Service !'las done this quite efficently on the Kenai Peninsula and
the Copper River Delta (which encompess approx. 300,000 acr.es).
T!'le ADF&G has also carried this out through their walk in hunt
areas through out· the State. Therefore, this is not a valid
cons ern.
(4) 4th Paragraph-Who are the particular resource agencies that are
apprehesnsive about 'the success of any mitigation plans for the
Denali route? Are they a one resource agenc.y or a multiple use
agency who deals with these problems on a everday ~asis?
(9 Page 11-24 11 . 9 (c)( iii) :
(1) 1st·Paragraph-The same discussion as stated in comment 8 pertains
to this discussion on the caribou herd.
1oJ Page 11-26 & 27 11.10 (b) Social vs Biological Considerations:
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{ 1) 1st Paragraph -As stated in previous discussions, proper and
timely development of land use and resource management plans can
resol•1e or reduce to a minimum the conflicts discussed for the
Denali access route.
(2)
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These same conflicts mentioned ~ith the exception of the caribou ~
apply to the ?arks Hig~~~y. ?~obably more so after reading the
varius environmental assessments on wildlif~ and fisheries for the
area. Therefore, the only conflict is to the caribou herd. As
stated, through ATV closures and rca~ traffic restrictions this
conflict can be resolved. A few ATV users will be displaced, but
there are other areas to the east of the Susitna River they can use
instead.
2nd Paragraph -Any routes selected could result in unacceptable
delays in licence approval especially if Federal land or wetlands
are envolved. Since the project is a major environmental issue, a
Environmental Impact Statement will have to be filed. This alone
can take up to two years or more to p~epare and be approved.
(2.9 Page 11-28 lt.11 (d):
(1)
(2)
(3)
1st Para~p,h" -This is not a valid statement since through proper
and timely la,nd use management planning the ATV traffic can be
controled t.nraugh ATV closures.
2nd Paragraph -On what bases is the statement made that biological
perspective, t.he Parks Highway is a prefered to a Denali Highway
.access. If land use management planning is done before hand, the
overall biological perspective would be equal.
3r'd Paragraph -Even though the additional 52 miles of haul
distance is invol.ved, the cost of constructing and maintaining the
talked. about pi.oneer road plus ware and tear on the vehicles will
far out weigh. t:he additional cost envolved to haul the supplies an
extra 52 miles over an all weather road. In order to haul the type
and toaage of equipment needed for the dam project, the temporary
haul road will require extensive construction.
Environmentally, construction of two roads in the same area is not
wise. "It will double the disturbance to the environment and the
finally abandoned road '"'ill attract ATV use on an unmaintained road
which eventally will cause erosion problems.
(4) 5th Paragraph -Allowing the access route and transmission line to
use the same corridor would cause a visual impact. Since the
Denali route for the transmission line was dropped because of high
cost and visual impact, the line must go west paralleling the
proposed Parks Highway route. Thus from a visual stand point, the -Denali access route has the advantage over the other routes. This
was never brought out in the write up.
(5) 7th Paragraph -Instead of creating a major railroad head at Gold
Creek, construct the railhead six miles up stream from Gold Creek
on the large alluvial flat located there. This would reduce the
social impact on the co:nmumity except for the additional train
traffic during the construction and several switchmen station there.
{6) 9th Paragraph -This is not a valid assumption. Plan 6 would net
increase the social c!'lange at Gold Creek other than the short
period of' constructing the railroad and the increase train t:""affic
during the Devil Canyon Dam construction period.
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(7) 10th Paragraph ,.. This assu.:nption applies to the other !"Outes.
Because of the major issues involved conbined ;..rith Federal land, an
Snvironmental Impact Statement will be required.
{ 8) 11th Paragraph -Cant~ell will be the only coiJ".muni ty effected and
they are infavor of the socioeconomic benefits :he construction
will bring them. Therefore, the mitigations would be nominal
incomparison to Talkeetna and Trapp.er Creek.
( 9) 12th Paragraph -This is invalid statement •. As stated before, ATV
closures and hunting and trapping regulations can control this
activity. In the long run, an effective management plan using ATV
closures would reduce the harassment of the animals in the area,
preserve the delicate, shallow soil and vegetation from being torn
up by the present unrestricted ATV use, and • .. 10uld allow a fair game
hunt of the caribou by walk in hunters only.
'l'his has been a vary effective tool on the Copper River Delta ATV
closure that was once open to unrestricted ATV traffic. The Denali
!"cute and the Copper River Delta area are similar in nature. This
has also been effective in the ADF&G walk in hunt areas.
(10) 13th Paragraph-The foregoing considerations as presented by ACRES
are not valid for eliminating the Denali route based upon the
comments under this section. For some reason or another, someone
is af'fraid of having a good land use and resourse management plan
de•reloped and approved for the area and car:-ying it out.
0) Page 11-30 & 31 1 1 • 12 Recommended ·Access Plan:
( 1 ) 2 & 3rd. Paragraph -No con·struction of any pioneer road should be
built until an I::'EnC license is aproved. If one is put in from Gold
Creek a.md the license denied, the Native Corp. oratins will press
legislato"rs to retain the road for the development of th~ir lands
at no cost to them. This means public funds would be used to
benefit a private corporation.
(2)
(3)
4th Paragraph
a. What type of special construction <;echniques will be utilized
to minimize the impact eo rurbearers and fisheries? This is a'.
broad statement and has no real meaning. It should be more
specific as to the type. Is this additional cost figured :nto
the overall cost to the project?
b. Under 11.8 (e)( H) Effects of Fisheries it was recommended the
road access avoid paralleling Indian River. This
recommendation ;ms ignored. Why?
5th Paragraph
a. The first sentance percludes to the fact that the highly
recreation value of' the project will be denied to the public.
If this is the case them, a whole new evaluation o.f the varius
road access routes be made conserning the overall recreation·
potential vs nQt allowing recreation potential be developed.
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b. The second sentance creats a two face situat~on consern~ng ATV
'.lse and hunting. It can be assumed 'that ATV and huntir.g
restrictions can ~e imposed and controled for ~he Parks
Highway route but not on· the Denali route.
(q) 6th Paragraph -w~at about the impact the road will have on Indian
River Remote Parcel and Gold Creek? Mitigation measures suggested
for the other communities but ignored for Indian River and Gold
Creek.
(5) 7th Paragraph -This is a poor assumption and probably invaled. An
Environmental Impact Statement will have,to be filed since it is a
major issue and Federal land is involed. The preservation groups
will push this. Even though the road doesn't tie into an exsisting
road, it does tie to a public transportation system -the Alaska
Railroad. The US Borax case in Southeastern Alaska is a good
example. Their request for a temporary ~cad access is still tied
up in court even with a EIS filed.
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The second assumtion is wrong also. The Native Corporation will
bear pressure to use the road for access and development of their
land.
8th Paragraph -This assumtion is correct. ::-~e .:a~ivas ~-:ill ::-eap
from the benefit of public funds spent en the -:.evelopr.::ent of tha
road. It is assumed their not putting up any funds for the
construction therefore their desires should have no bearing on what
route is selected.
11-32 Recommended Access Plan:
1st ?arag::--aph, 2nd Sentance -Again this is a invalid assumption.
Plan 11, the Denali route, offers the best control over public
access during the construction phase since their are no active
private inholdings involved.
3rd Paragraph -This is a positive assumption and it would ':le
advantageous to apply for the necessary permits ~or either Plan 6
or 11 immediately to allow for the length of time involved to
obtain the necessary permits and still meet the time schedual.
@Page 11-32 & 32 11.13 Mitigation Recomlnendation:
(1) Only four of the seven mitigat~on recommendat~ons pertain to
socioecomoni·c. Two pertain to r-oad restrictions and the last one to
putting the pioneer road to bed. None deals with biological or
cultural r-esources.
No attempt was made to develop mitigation recommendations for the
Indian River Remote Parcel or Gold Creek. Th{s should be addressed.
No attempt '..r.!S made to mitigate the real problem Talkeetna and
Trapper Creek are conser-n about -:.he population increase. Putting-
funds into the community for the additional services needed to
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:-.z..-;d~ :.he ::.nf:ux of people. does not answer their conserns. It
a:~,-2:~ :.y increases it since the more services being offered •,;ill
requ~~e a larger ~ocal work force.
{2) T.~e ~~rst mitigation measure would restrict access to the people
t~2t ~ave inholding land along the route. They were denied the
semi~ilderness of the area by the recommended selection of this
r-oute now their ~eing denied the use of the road •.;hich was paid for
by public funds.
(3) Tte second mitigation measure precludes the development of the
recreation potential the area has to offer.
(4) Tr.e Last mitigation measure is fine but through past experiences on
putticg a road to bed, the general public still finds ways to use
it with ATV's or motorcycles thus creating serious erosion ;=~roble!!lS
in the future.
(5) The 1st and 3rd-6th mitigation measures could be avoided by
selecting the Denali Highway route.
The second mitigation measure still has to addressed if the
recreation potential should be developed or not.
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(6) The·dollar figure mentioned for mitigation measures seams quite low
in cot=parison to the figures being prepared by the New Capitol Site
Planning Commision for capital improvement cost. To build just a
new school to handle the influx of new students would cost more
tham the figure given.
@?age 11-33 & 34 11.14 (b)(i) Engineer:!.ng:
(1) 1st concession made discussed a complete loop connecting ?arks
Highway with Denali Highway. No where in the varius access plans
mentioned connecting the two highways via the dam sites. So no
cocessions were made.
(2) 3rd concession made is also invaled because of the pressure the
Native Corporations will bring to bear to keep the road open.
(3) 2nd objective retained is questionalble. As stated, an
environmental Impact Statement will probably have to be filed !'or
the road.
~Page 11-34 & 35 11.14 (b){ii) Biological:
( 1) The concession made is untrue as to providing parcial public access
to the upper basin. The !"'Oad from either Paries or Denali Highways
will open up the lower portion of the basin to the public for
recreational purposes. There is a difference bet~een the two
routes which ~s been neglected. An all Denali route will open up
only the portion north on :he Susitna Fliver which is already being
used ~y ATV 's. Whereas, the Parks Highway route will open up both
the northern and southern side of the lower basin to public traffic
and st!ll retain the ATV use to the north. Overall, from a
biological and wilderness retention standpoint, the all Denali
route ·.;ould be preferable.
(2) !he fourth objective ~etained is vage, misleading and ignoring the
rec~eational value the reservoirs offer. It is vage because it
really doesn't state any pertinent facts. It is misleading since
terrain is not a factor in controlling vehicle traffic. The
traffic is on the road not over cross country terrain. As to ATV
use between Parks Highway and Devil Canyon Dam site, the soil and
vegetation is highly suseptible to environmental damage by the off
road vehicles; probably even more so than the highlands found on
the Denali route because of the deeper and more moist soil
characteristics.
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As to the recreation potential, by mentioning control access beyon
the Devil Canyon Dam site, it presents a strong in~ication that the
!'"ecreation values are not being considered in the overall project.
The last paragraph -The statement "Road management will reduce the
adverse biological impacts associated with an access connection to
a major highway to a minimum 11 would apply to arty route selected
including the Denali access. Yet it is assumed the resource
agencies are willing to apply it for the Parks Highway route but
not to the Denali Highway route. Why?
11-35 11.14 (b)(iii) ·social:
The first concession made is not true. Any of the road access
discussed to the dam sites will provide access to the lower portion
of the upper Susitna Basin. See comments under item 17 (1).
The second concession should be expanded to read Gold Creek and to
the expected population increase in the Trapper Creek area. As
previously stated under item 14 (1), why hasn't any mitigation
measures been ta_ken to reduce the impact to Indian River and Gold
C:-eek area?
(3) The first objective retained would apply for any route selected.
(4)
By taking the same attitude f'or the Denali route co!'!lbined with a
good land use and resource management plan the biological impacts
would be reduce to a minimum. At the same time it will releive
Trapper Creek and Talkeetna of the social-economical impacts.
The second objective retatined
consern of Talkeetna -Trapper
increase. See comment 14 (1).
does not really address the.main
Creek area which ~s the population
It is agreed that the all-rail plan would have a greater impact on
Talkeet:::'la since this •,o~ould be the main jumping off spot for the
construction workers.
(5) Next to last paragraph.
a. If ~ good land use and resource management plan !.s developed
and applied correctly for the area, the Denali route ·..;ould
actually have a better biological advantage over the Parks
Highway route. See comment 11 (9).
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flE-..,:ft>t: --b. As previously stated under comment 12 (6), the preference of
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~:_:;rable 11 .2
the Native lando·~wrs should not be conside~ed unless they are
willing to pay for their share of the cost for the
construction. Public funds should ~ot be used to develop a
private corporations land especially since no access between
communities are involved.
Identification of Conflicts:
{1) The minimized cost criteria for Plan 11 should be changed to '2'
~ating since it is within the $50MM variance.
(2) Minimize Biological !mpacts for Plans 6 and 11 sht lld be changed to
a '2' rating on the bases proper land use and resources management
plans can be developed and accepted which will actually improve the
envioronment over the present condition.
(3) The preference for native landowners should be dropped completely
unless they are willing to pay their share of the cost for
constructing and maintaining the road.
(4) Accommodate local community preference.
a. Plan 2 should be changed to a '1' rating since an all railroad
route will have a greater impact to Talkeetna area.
b. Plan 3 should be changed to a '1' rating since three
communities will be impacted.
c. Plan 7 should be changed to a '1' rating since three
commumities will be impacted.
d. Plan 8 should be changed to a ' 1 ' rating since an all rail
!'Cute to Gold Creek will have a greater impact on Talkeetna.
e. ?lan 9 should be changed to a '1' rating for the same reasons
as 'a' and 'd'.
f. Plan· 10 should be changed to a ' 1 ' rating for the same reasons
as ' a ' and ' d ' •
g. Plan 11 should be changed to a '3' rating since it satisfis
all local commumities.
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~) Ot~e!"' Corl'.ments:
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Not mentioned is the assumption the Devil Canyon Dam may neve!"' be
built. This has been mentioned as a possibility during seve!"'al
public hearings. I( this could be true, them it should be one of
the major factors in deciding which route is selected. What ~ould
be the varius cost pe!"' access routes if this happens? How would
this change the social and biological impacts, etc.? All these
items must be addressed before selecting the perferred route.
(:_~) Summary:
From all indications, the report in its decision making is slanted
one way. There are nume!"'ous assumptions made that apply to all
routes yet they were directed to a particular route and ignored on
~he others This has a tendancy to mislead a person not fully
knowledgable in dealing with the whole parameter of land use
management in making a selection of one land use item over another.
Land use and resource management planning was not injected into the
process of selecting a preferred route other than road management
for the Parks_ Highway. In all projects of this size and nature, it
is probably the most important function to be carried out prior to
making a decision along with the safety of the structual
~ngineering design and economical feasibility study of the project.
The report lacks sufficient detail information for making a rounded
out conclusion on the.varius items discussed in the selection
process.
~ore wildlife data could be gathered a~d analyzed but it is
questionable the additional funding is worth the effort. Overall,
the environmental conserns on the wildlife and fisheries are not
that great either for the route access, the impoundment areas, or
the wildlife and fishery down stream from the dam sites. Any
additional funding should be directed toward a land use and
!"'esource management plan instead. The plan should be developed by
a field oriented multi-resource planning team with representation
from the private landowners being effected. and not by an one
resource oriented group or desk personnel. As a minimum, two years
would be needed to develop and approves the plan. The plan could
be incorporated into an Environmental Impact Statement.
3ased upon the environmental data presented by ACRES, using proper
assumptions for all routest injecting the comments made on the
varius items including a good land use and resource management
practices t and the possibility of the Devil Canyon Dam not being
built, the Denali access route (plan 11) would be the preferred
route.
Plan 6 would be the preferred route if there is an quarantee that
the Devil Canyon Dam will be built.
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UNIT 1:0 ~TATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Adminisrratior
iVa:io,-:.:=l /·!c.~-!,ne. .. ='isher~es 5e:-"Ji~e ?.=. SQ:;: :668
June(.::t, A Z..::; .•:..:.: J 98 0 .~
STATE:·!E!·if :'OR
AU-SN'\ PO•iER AL'THORI'I"l
EOARD OF DI~.EC'mPS
~.nc!iorage, .:Uaska
April 16, 1982
by
RJBERI' ~v. . 1-C~I
RF.GICNj\L D:rnEC'!OR
NATIOW..L MM.nJE FISHERIES SE:RVICE
Juneau, AlasJ.-..a
T:le Naticr.al Marine Fisheries Ser.tice {t~!FS) , within the Deplrt:rer.t of
Ccrnre.:-ce, has Fede..1'"3..1 responsibility for marine, estu,arine, and
a"l.acirarous fisheries. several laws, includi.."lg t."le Fish and ~.Vildlife
CoordL~ticn A~, reoui.:'e our ace...,C"t to assess t.."''e i.rTDact of water
res.--u.:-ce de-lelocre...,tS on fisher{ resources. Reou!a.tions of t:.l-).e Federal
Enercv F.ec:ula"to~., Cannissicn (ri:=c) soeci.ficall•; :-ecui.:-e acolicants fo::-'*· 4 ' .. ... .. ... .. -
lic~se of a ~jcr hyd-~lectric ?reject to consult wi~~
~:·!;S and respcnd t:.o t..~se concerns or rec:::::trn"e.'1ea~icns cur a.ge..,cy :eeLs
are necessar1 to protect fishery resources. Our respcnsibili ties far
a."l.aC..-arous fishery resources have resulted in >:.':e de•.relq::rne.'1t of
considerable t-'!r-!FS e.~..ise in addressing t,.:,e ;:otenti.al .impacts of
hydrcelec-:=ic facilities en the sal.1cn resources cf t..~e ncr'"-~ .... -estern
U.S~. T:-.e Nr-!FS ar.d its p:-er:...ecessor ager:.c:y, tb~ 5u=eau of Ccmrercia.l
fisheries, has been aC""...i'V'ely involved in efforts to st'I..U:iy ar.d preserve
sal.m:::m t"'.J."l$ to t:.".e Ccl\:mbia Ri,ier basin over t.'1ree c!er-aC.es. t·tnile t.'1e
C'..!.rrent sco;:e of cur invalverre.nt with hydropcwer develcprren~ iJl Alaska
is considerably less ti-.an in the nott.~st states, •..e e.~t. to draw
t;,-""Cn cu=· ":-:..-:::-~·· c: ryverall e:q::ertise and involvere.'1t wit..'"l such
develc;m:..'lts duri."lg our review-of the Susit:.'"'.a cam prq;osal.
I
\·1e re<:Cejnize the requi:e:rent placed upon the Alaska ?o.-.-er Authority
(APAl to sul::mit recarrrenC.ations to the Governor and the legislat\lre on a
future course of acticn rega-."'Cting the Susi tna project. ~.ccording 1 y, we
appreciate' t.'1e need for APA to have resource age."'lcies 1 opinions .
available for consideration at this tin'e. · We feel, however that it is M ~
p::erature for ~ll-!FS to give a definitive evaluation en the acceptabilit:'f
of the project ...-it.'"l respect to e.'1erg".f .!::e.."'lefits versus fish losses. It.
is rrore at.--pr•-?riate the......-efore, that we cescril:e our basic e.~tions
wit.~ the cccrC.i."'lation precess and our ge."'le..~l envi..-ome..,tal concems.
First, I WC"..:.ld l.L\ce to at':"'hasize t.~e r:eec. r:o.:-a c~re!•~si·:e
U!'.C.ersta."'ld..L'1<; of t..'":.e i.r.;:cr...ar:ce of fisl":e.:-y ::escu=ces •.-:it.,;":in ':...":e :;r:-oject
a:ea. The Susit.-,a !live.:-era.L'1age is 2..'1 .~ .. ~~errely ?ro::iuc~ive sys.:e.rn \vit.'"l.
an annual sal:ron r-~ ?reducing a large ~erce..'1tage of :.~e c::mrercia.l Cook
Inlet catc...,. These fish are. vecy irr:'...o~...ant to i::oth t."',e cc:rrme.:-::ial
fishing industry and the sport fishing sector. Sa.lr.'cn a."'.d ·several
resident s-~ies such as rair..t::a.l t=cut, Colly ila.:-Ce..'1 a.'id grayl.L'1g are
sought by SFCrt f.ishenren. The .=ish of the Susit.--:a Ri·J"er also
cont=ibute to t.'"'.e ecosvste.rn of t.'":.e areu bv ::rovidina :co:i to ot.."".er :.:.sh,
birds, and wildlife. Here in 1Uaska our fishc.ries :.eoresent cart of a -.
li.fest:vle which, while diffic-J.l t to desc::-i.be and irr.::ossible to olace ... ' -... ...
value on , is r.o less real.
The ~ proposal will br.?act t.~ese :iste.ries. ~~~~le not all of
those fish utilizing the syst~ • ... ·ill te ci.rectly L~.acted, · ... e ._:z-e
conce.tned about any loss of fi.she:-ies resc...:=ces.
Cnly '"ith an L'1-<iept.~ understa!"'.c . .:. . .-,g of t.l;e :ish ar.d ar:tici;.atee :..-:;::acts,
can we fully weigh the costs associated ·,;it.~ hydr·::> C.evelc-;:rre..'it:, .=..-:.:::.
p:rhaps, fi.;.d ways to accam-cC.ate ::Ct.:,. It is i.-r;;:o:-~'1t, :..~erefcr; t:"'..et
fisheries research and stueies :-.ot cnly ice..'1tify t.:,e s;:e;:ies o: r::.sn
oc:::upying the Susitna. d...--ainage ar.c C.esc::-il:e ':.~eir ecclcgical
characteristics and n~.....s, but also icie..'1~i£y areas c£ :..;;:act end ::-eas-.:=e
to avoid cr mitigate t!-.cse L-r:;:acts.
The necessity of obtai:1i.'1g CCT1pre..~o...e..'1si•;e e..'1viror.rrer.tal data is also
recognized by the FEOC in their requi=ere.'1t ::.'1at such ~'"lior.ration be
specific, acOJrate, , a."ld sufficiently quantified to c::mvey .:1 ::recise
?ictu-~ of b~ project: ar~ its ?rcbable effects.
This leads us to my second ::Oil1t in. wt-.ic.h r ·....auld l.:.:<e to disc.:ss
several aspec::s of the Susi.~-,a earn ~reject: ~~t are o£ c::nce~ '::J our
gcn~f.
'l11e Susi.tna Hydroelectric Project Feasibilit'J P.eport. r.as l::ee.'1 prepareC.
to assist decision makers by des.....-::-ibing t.~ econc:mic, social a."ld
e."lviror.rre."ltal conce...T"!'.s associat-ed •..;it.,;'-l ~e project. L'1 t.:...is regard ~lo..e
dooJment e:erfor.ns well. Hc'...ever, ':..~e :eas.iliili ':y Re;:ort :.s 3-lso 1...,. a,
inte."lded to provide the basis for application !or licer:se :.o t."'.e :: ::..'11:. ~ ,-I
The rego..llations of the r.E..'C are clear i..'1 -=escribing t..,e L-r;:cr-•.. ance oi
including adeGuate e.~L""''ntnar.t:.al data i.'1 t!-.e lic~se ·~~lic:::rtion.
E'Urt.'ler, they requi...""'e t!"lis L.-,.fonration ~o te ?rc~Videe en a ievel
cc:mne.!'\5\.L.~te wit'"l t-"le sccce of ti-2 oro~~. ~.t t.,is ~:...~ , .... ~e C.o ::ot feel
t."li.s level of detail has been reac~ed. ~-iit.:,6ut tt.e res-ul.':.S ot
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acCi ':::..cr~l st-.:cy L, seve=al ar-eas,
:::e ~ccrly cesc::il:ed or unce=stcc:C.
Vi:!r::.cuz as~e~.:-:s of :;:e :::cc;:csal '"'il2.
~ese ccfki~cies do not i."!?lY ~"'!at
r..:;e Feasibili~· ~eror::. •...:as irroroce:::-lv ore=-a=ed or :;,rese.teci. ?.at.~e:::-,
t.!··.ei' =efl=c-: ch :..~e limited L;fci:-::-atic~ :~-~ilable ~-s of t..~is da.t.e.
Cne area of L.!.::li ted i.:1fc::::ration in t.~e ?easi.!:i.li ty ?-e;:or': :ieals · . .;i ':.'1 ~'1e
ef:fec":s of t=est ?roject flews en the fis::e=ies rescu:::-ces. The
Feasibil.it:v P.ecort discusses the i.n=ort.ance of sice c.'1annels and slcuchs
l:et:w'ee.!"l Tail.:eetna ane Cevil Canyon.-These areas a=e heavily utilized-by
s-t;4wn.ir.g ar.d rearil1.g saLmn. The ~ct of project flcr""s to tr.ese
areas will dete-.7.:L."le , to a large e.'Ctent, the fishery i.rnpact att=ibuted
to tbe ?reject. n-.ese sloughs tit.e=efore represe:1t an area requiring
consideration of ~te."ltial mitigation and/or e.'1!-.ancere."lt rreasures. To
date, less ti'.an one eighth of the side channel and slcugh areas have /c T
Cee."1 S".L.""Veyed. f\lrt..~, the impacts of various flCW" regi.res on t..l--.e
habitat are unkno...n ber...ause t.'le hyd."'"Olcgical and ecolcgical
relaticr.ships bet'..,ee."l tl1e n-a.instem Susi ~"la a."ld tbese areas have ~ot bee..,
aCeq\lately st':'died. An in-dept.h. study of projected flcr.., regin'es is
r.~-ed. 'I'l":e results o£ a cc:rrprehe.r1.sive In-St=eam Flew Stt!dy · ... culd allo...-
a ba.lar.ci.r.g of fish habitat losses aga.L1st ~-er generation, C'_'1.d ot.~r
mitigation ?QSsibilities t .• "lat CC'I.lld l:e e•1alua-ced.
'!'es:;e=ature c."'..ar.ges wit. .... .il''l t.~e Susit.-.a R.iv'e= are e:<;:e.C'ted to resul':. f:r:::m
ccr.st..'""'.:Ction and operation of t.~e d.:r..s. These chanqes could ;>rese.'lt
i::ct.~ positive and r.egative c.:..:anges ':.0. fish p:pulat.iCl".s. T~e APA ~as
used a. car:puter !i'Cdel to predict and describe these c!:a:.ges. C:..!rr~tly,
wl! eo net believe a f'!.igh level o: confidence e.'Cists i..."l t.he proj~ed jc /
~st. prcje-=::: ten;erat"..::=e wit.~i., t.h.e ~ . ..o :=eser ... -oirs, t.:.,.e Susi':..""2
trai..'1S"Ce.."n, a."'ld t.~ siee .char .. ~els cmd slo~.:ghs. '!'herr.al changes rr.':J.'f
prese.'lt signi~ica."lt problems to saL.cn, anci acditior~l s~~Y will be
necessary before possible i:npacts can l::e adequately cefir.ed.
'!:-:e Fea.sibil.itv Rerort states t.be cbjecti•_-e of the Susit.ia ::-t:..~g2.ticn
effort is t.c achieVe no net loss. To achie".re t.~-..is <;cal, s;:e.:if::..c
stud.ies :::ust cc:::ur \•;hich will develop ;.-..itigation options icenti!ied in
tbe :easibilicy P.e;:ort. i .. ~ co r.c'l: belie-:e ':.~...a~ a mi:.i.g.'!!i.on ?l~"l ~., ::e
develc[X."Cl, L'\.l!lcd upon llVailwlc infornnt:.i{)n,-•.vhich • ... auld :>.:tti:Jfy th~ /cf
requ.ir~i1ts of t."'le FEte. Basic to any ilri.tigaticn plan is a
ccmprehensive \Jt'.derst:.anding of t.l;e rescurcc and. t..~e ;otent:ial lJn?lct tr.e
proj~ will prese."'lt to t."le resource. Ac;ain, ·.;~ do not l:el.ieve t.:.Us
level of Llr'.cerstandi. "lg has bee."l reached.
The ~. regulations cence:=1.L-:g lice.,se appliC.ltich :cequi=e a :=e1=0rt
that descril:es t.~e !ish, wi.ldli;fe, and ::Ot:anical res...~ces. . !:-.fc=::ation ~ ~
i:l this reoor.:. is to i.r.clucie temcoral-a.~d scat;ical dist::ibu't.icns of r J
cer"'..ain fiSh s-cecies. As sam sa.L"TCn w•it:~ the Susit."la ?.i•:er have lite
C'JCles of five· or Il'Cre i"t!ars, it woul.C. see'l'l reasonable to allcw at least
Lcng
t.o &.e :::..;:A ?::.-c-;csa.l. have CC::'.tr=cd :: :· cr-.l·:" cnc :ielc se~sc:-.. :!: t Ls :;.ot.
:-eascr:a.ble ~o ass~ t.~at. such ~ ... ::i:.br-c~: . .:_J.':ed s~ii.-:g :.s aC~ .. ~ate f=r
?rc;:e~ c~ac-:.e.riza.ticn of :rescurc~s. ?·~:-r ~'-:.:~.rrple, ~L...,_k sal-TO~ e_: .. :.!:iJ:i~
~ t-.vao year C.(Cle ·,~·it., e,lt~"1 year :--~:; ::f~i.r.g :-a:c~ st=~nsc= t.~a'1 t.~e cCG
yeazs !:""...14,5 i.4 u;:~::-Cock L"1let. ;..t t.:~i3 :.i..ic I f, •• :e :"1a~:·e ~-0 i..-::o::-:-~~ion C:1
t.~e si=e of eve.'1 year pi:'-"-::a.Lmn r.:.:-:s ::a t..':e u::=e::.-Susi::.::a o::.-':.~e az-eas
of the River. i.'1 · ... t-.ic::J. t:.ese ~ish s:-..a..,yn. '
We feel it is ~~eascnable to disc~ss ~tigation cetails before adequate
kncwleege c= t.':e :ishe:'y :::::-escurces· ~<ist.s. n-.e Po..."er Aut..c~o::.-i '::f has bee....,
L"lfor.red of ~ese concerns and dat.:l cacs, and of t.~e st.ecs :;ecessarr t::>
cor::-ect t."'lem. Our ace.'1C"J" has orevic~siv st.ated :l"..at t.."le. envi=or=e.."':.tal
data available frcn Pr.a.se I stUdies ~.;ill net sl.tF?::Jrt a.., adequate
evaluation of projec": ~c-t. l·le c::mtinue to reccr.rre.'1d tf!.at t..l;e
antici;;:at.ed date for su!::rni.tti.'ig the li~c..'"l.se a;:?Li.~a'::i.cn '::::e delayed ':o
allcw aeciiti.cnal data collec"--icn.
It is au= ~.:.o-.Ce=st.a.r.di.'ig t.l;.at t..l...e c:.=a:-; Ece.!;.se =~?li~~ticn Eo::: ':..~e
sus.:.t..~ ;:reject. will seen =e available :cr re'f.r:.f:!.v. ~~Te are c~r6ce.:::.ed
t.".at ~~e a;:?licaticn ·..;i.ll :-eflect t:.e se=icus ·ief:.c:.e::c.i.es •-:e ::ave f::.'!
:rer~:ticned. If our :-e·vit?.v shc,...·s :..h.i.s :0 =€ ~.'2 :3.se, · ... re :~cl c·t:= -a..c;e:.r:f
vlill ha'J"e ::c alte_~ti'le but. to :-~:es~ t...~e : :...:.'!: tc =cjo/--:. ~~e
2.ppli::aticn or di.ra~ t...~t t..~e de!'ic:_er:ci.es =:e -=~r-::-c:::":.E.C.. Y..Je "le"!:f ~=:1
cesi=e to avoid t.."..i.s sit:~ticn.
Fir'...ally, I ;..ould li.lre to close my st..::.t:e..r:-e::t · . ..rit."l a leek c . .Ja.::.-ds t.':e
:-.~ture and a •...ord of e."l.ccu.=agE!'!'e.!".t. T:-.e ll...-:cc::::-:.;k: .. ::.c; of an e.."lvi=::r.r.ent.al
st~l :cr a prcject such as Susi~--:.a :.s a.~ er.cr:rc.us -:.ask.. .~cc=:-di..;.gly,
t..=.e Po.o~e.r A.ut..':cri ty has in.i tiated a •:er:y co.~·re!"'.er-.s~ ve se1:'ies of s~i..:O~es
wh.ic~ wr~'i ~leted will ?rcvide us wit.~ a better ~•ce1:'sta;dL;g of the
ft.J.ll range of project related ef:Eec":.S. !nC.ced, it rr.ay !:e ?Jssi!::le t:;,
c:;,ns\:.-~ct ar.ci c-...erate t.~ dams i:: s~.::h a •.vav as '::l achie'le t::-.e
Authority's r;o net loss goal by rnitigati.lg fist:erj irr?:tc't.s, a:-.d/or !:::y
enha.,o1cinq fi.si".ecy habi~t L'i cer...ain areas.
r knew the !k'.1rd of Oirctors ,,pprcci.1t0~• t-.hfl ~1Jr.t.1r:c~ of cur :i::>h~::-:!..::;.
I hope I have ccnv~.red to you ~".e l::er.efits of detailed $tudies to obtain
essential infoonation. In fcnr.ulat.ing its reccmneneati.ons to t."'le
legislature, I since-1"'E!ly e."lcourac;e t.~e 3oard to consieer t.."'le c=itical
need fer this i.nfo:aration a."id t..~ i.n;:lications of !?rcce~d.it'lg in its
abse..'ice.
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April 16, 1982
DEP AR.'lliEN't OF NA'!UR.AL RESOU1lCES 'S
!ESTDfONY !0 TilE AI.ASKA POWER AO'IHORII'Y BOARD OF DIRECTORS
I appreciate the opportu~cy to provide comments to the Power Authority
Board of Directors on the Sus~tna ijydroelectric·projecc. I regret that,
because of ocher comm:itments in Juneau, I am unable to personally del.iver
these comments.
At the invi.tat:i.on of the Alaska Power Authority, che Department of
Natural Resources has been working informally with the Authority over
th~ last two years to help formulate and carry out studies ~esigned to
answer t:he questions which ultimately "'ill ~etermine whether the Susicna
Dam proposa~ are feasible. !he purt:~ose of t:.h.is tes timouy t:.od.ay is
tvofold: First, to ident:Lfy Susitua aydroelect-ri.e issues that are
within the sphere of DNR's author:f.ey; and second, co ~ke recommenda-
tions to the Board of Directors on the cont:inua.tion of pcojecc develop-
ment, as requested in the January Z6 letter froa. Mr. Conway.
SUSimA HYD.ROE!.EC'l'RIC REL\TED ISSUES WI'IRIN 'OlE. PURVIEW OF niE DEP AR'nf..EN'I'
OF NATURAL RESOURCES
!he Department of Natural Resources nl..l be requi-red to :n.ake decisions
on t'W"O major facets of the Sus:f.tna Hydroc!l.ectri.c Project. !hese are:
l. DNR responsibil.ic:f.es for water appropriac:f.ou (and possibly inscream
flow reservations) from the-Susitna River.
2. Ri.ghts-of-Way permits for access into the dam s:!.tes and transmission
line routes. Other land use· permits for access to const:ruccion sites,
gravel for·cousc:uccion, and other land use related needs as they or"
on st.ate owned lands.
The role of the Department of Natural. Resources in water rights appro-
pr:uu:ion will be an adjudicatory one. According to Alaslc.a. Statute
46.LS.080 (b), the impacts of water appropri.ation on the publ.ic interest:
shall be considered during adjudication. Areas of public i.ncerest are
defined in the Statute as follows:
1. !he benefic to the applicanc resulc:f.ng from the proposed
appropr:!.ation.
2. !he effece-of the econom..ic activ'i.cy result:.ing from the proposed
appropri.ac:Lon.
3. The effect on fish and game resource:s. and on J?ubl.ic rec:rea.t::!.onal
opporeuni.t:!.es.
4. The effect on publ.ic health.
5. The effect of loss of alternate uses of ~acer chat ~ighc be
made ~ithin ~easonable time 1! not precluded or hindered by the
proposed appropriation.
6. Ham to othe.r persons resulting f=om the proposed appropriation.
7". The intent: and abili.ty of the applicant: to complete the appro-
pria.t:i.on.
8. The effect upon access co navigable ~aters.
The DliR ~iLl be looking co the Feasibility Study data and informati.on to
describe the relati.ouship be~een various screamilo~ levels and he~ they
~ill iQpact fisheries and aquati.c habitat downstream. Thus, from this
Depar~euc's perspective, instream flo~ studies and the relationship of
various flo~ levels co aquatic habitats and fi.sher::l.es resources are
vital. The studies administered by the AEA will be the fundamental.
source of data and informacion used by D~R co make the public interest
findings described above. We are eager co review and comment upon the
present and future plans for instream flo~ studies. To date, ~e have
not been provided an opportunity to review or c.omm.ent upon the instream
flow study approach.
!he access co the dam sites and the policy surrounding the ~~tent of
access after construc~on wiLl lead to one of the most: significant:
~paces of the project:. The Power Authority has stated chat the permit:
for use of a "pioneer road" is needed· in 1982 (before a. F .E.R.C. perm.i.t:
is issued) if the paYer is to· be on. line eleven years lacer. One signi.fi.-
cant issue is the possibility of the ~onstruccion of a road to the.
proposed dam sites and a subsequent decision by the state not co construct
the dams. lt ~auld appear to be in the best interest of the Power
Authority, the land managing agencies, and t:he public co idenc.:ify other. --p:{
alternatives which will allo~ the necessary access to the proposed dam
sites in a manner ~hich prevents irreversible impacc.s. rn order co
prevent this issue fr~ being a pocential delay in progress, we recommend
that t:he APA take the lead in convening· a mulc.i-agency, multi-disciplinary
effort: co accomplish the goal stated above.
The second issue is the long term land use iMplications of access to the
proposed dam sites. The provision of access to the dam sit::es should not
unwittingly dec.e:rmi.ne the types and e.~c.ent of land use impacc. on the jG. '1
surrounding lands in the upper Susitna Valley. Carefully dec.ermia.ed
access route decisions could result in a muLtiple purpose route whi~~
could fac.illtate and enhance ocher uses of the surrounding lands. In
order to accomplish this, the dam access route decision should be made
in conjunction with surrounding land owners, land managers. and the
general public. As on the other issue above, the DNR is 101l.ll..ing to
participate cooperatively with ~~e Alaska Fo~er Authority, other agencies,
and t:he public to resolve t:his matter so that· it does noc become a .
pocential delaying factor for the proposed project or a future manage-
ment:: probl~ for land owners and managers.
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SUMMARY AND RECOMMENDATIONS
!n summary, che Deparcaent of Natural Resources has three recom=enda-
tions:
1. !he Deparment sup pores cont:inued studies in the soc.io-econom:Lc,
technical, and enviroameutal areas. The preliminary york accomplished
so far indicates that the project is technically feasible. Furcher
YOrk is needed to establish the info~at:ion and data for wacer
appropriation and fishery ~itigation. Additionally, we recommend
furcher work on ehe timing, rouce and conditions of access to the
proposed dam sites.
2. With respect co the question of tJhether it is desirable to
submit an application to the F.E.R.C. on Sepce=ber 30, 1982, we
offer the following comments. "nle A2A Board of Directors and the
sea££ should carefully Yeigh the advantages and disadvantages of
subm.:f.tcing the formal application on September 30, 1982.. If that
course of acti.on Youl.d result in the A2A acquiring a: F.E.R.c.
pe~t to construct in the most: t~ely and econo~cal way, then
that course of action makes sense. Kowever, if on the ocher hand,
a formal application would result in delays, increased potentials
for litigation, and a hardening of adversaria~ roles bet~een the
A2A, other agenci.es, and other interested part:ies, then· the. possibility
of these delays should be considered. We believe that t:.he ~A
Board and the Sell££ are in the best posic:i.on to evaluat-e pros
and cons and to deter.nina whecher a. 'E .E.R.C. applicat:i.on on
September 30, 1982., is desirable or aot. From our more narrow
agency standpoint:, DNR is not opposed to a F.E.R.C. application so
long as our agency concerns and responsibilities can be fully and
openly decel:lllined througn the traditional intervenor process.
3. We compliment the AFA 3oard of Direcco~s and staff for. encour-
aging inter-agency interdisciplinary app_roach to identify Yays co
imp~ove the coordination and ulcimat:ely the resulcs of the feasibility
studies. We believe th.a.c strengthening tbi.s approach will facil:i.cace
a more coope~acive and constnc:ive role for those agencies. or..m.icll
have responsibilities that require them co take aecion on the
Susitna. Kydroelectric P~oject:. Specifically, we recommend strength-
ening and enhancing the role of a g~oup similar to the Susicna
Kydroelect:i.c Steering Committee: w1ch has been providing i:Lfor=al
agency com:nents to· the };2A. on this project for the lase l:".;o years.
Testimony presented to the Alaska PoYer Authority Board by Deputy
Regional Director LeRoy SoYl, U.S. Fish and Wildlife Service, on April
16, 1982, concerning the Susitna Hydroelectric Project.
!he mission of the U.S. Fish and ~ildlife Service is to:
Prov'ide the fe.cieral. leadership t:o conserve, 'protect, and
enhance fish and ':IUdlife and their habitat for the coo.t:Uluing
bene£it.of people.
You might ask~ therefore, ':lby is the Fish and ~llcili.fe Service concern-
ing itself ':lith a State energy project?
The Susit:na Rydro Project must be licensed by FERC before construction
begiD.s. !he Fish and Ilild.life Coordina.cion Act requires chat:
fish and ':lildlife conservation be given equal consideration Yith other
features of a proposal throughout the planning and decision processes.
FER.C is fu.tther required to consult ':lith state and federal. fish. and
vtidlife resource agencies to deter.:.iue vbether there u1.ll be project
rel.ated lasses of fish and. ':lildl:i.fe resources.
!he Coordination Act and Section 102(2) (3) of che. Natioo.a.l Env'il::onmental.
Policy Act: beth requi.re:
(l) A description and quantliic.ation of che existing fish and
vildli.fe and their habitat ~thin the· araa of project tmpaccs;
(2) A description and quaati.fication of anticipated project:
~acts on chese resources; and
(3) Delineation of specific mitigation necessary to avoid, minicize,
or compensate for chese impacts.
The Fish and ~lldlife Service has reviewed the draft fe.asibilit:y report:
"Jith respect co its area of exper1:ise. Deficiencies are readily apparent
Yi.th respec'f: to al.L three require:::aents. There h.as been a failure to
quantify the habita'f: types present? antic:ipar:e che impacts or t:a identify
required z:a.it:igatioa. All of chase deficiencies are directly realted co
t:he unrealistic time·constraints placed on data collection.
Some of the spec:i:fic deficiencies we have noted are~ as follows:
(1) Terreseri.a1 sOldies. have focused ou che i.llq:loundments and their
immediate vicinities. The assessment of YiJ.dlif e and fishery ft G
resources muse be extended co dololtlstream areas, cransmission
and access corridors, and areas of sec:oa.d.ary or indirect
:impac:'f:s.
(2)
(3)
(4)
(5)
) '
(6)
Q
(7)
/' -(J) '
r-
(8) ,-
-
-2-
The terrestrial studies have been qualitative. ·Qua.ntificacion,
through an acceptable methodology, is essential to the evaluation
of habitat values. the probable i=pacts and the selection of
appropriate cli.tigation. A2A has stated its objective as "no tJ 11 "'-L
nee loss." Wit:hout methodology co quancify either losses or
utigat:ion there is no Yay co assess Yh.en chis goal has been
achieved.
Fisheries studies have. been conducted for only one year. A
· st:udy of this scope: is sufficient: only for a preliminary
evaluation of the ~paces and to provide for refinement and
focusing of longer ter: st:ud.ias. One year fs not enough time
to provide the data necessary t:o fully describe the resource.
Any· attempt to assess impacts . or p~a.c. mitigation '011thin the ·
concexe of the l.icense app~ic:acion vould be ~equate.
There are inadequate data to descr:tbe r:he rel.at:.iousb;i.p beetJeen
vari.ous scream flovs and the product:l.vi.ty of fisheries and
aquatic habica.t do~tteam from the proposed Devti Canyon Dam.
A fully thaughc-ouc ~str~ flov study vould provide the
quant::l.fication necessary for any impacts evaluation and
~:~.it:igacion. planning. Withouc. this iu.format:l.on any evalu.atioa.
of project: i=llpact on fishery resource is missing an essential
compon.ent:, and effect:l.ve m:itigat.ion pLanning is seriously
hampered.
Anticipated \r.lCer temperatures and curbid.it:y levels ~ the
Jc:.. I
reservoirs and downstream from DevU Canyon have. nee been f., v)
satisfactorUy investi.gated. An adverse temperature regime r-
has severe il:plicat:i.ons for t:he fisheries; dmm.st:ream from
Devil Ca.nyoa. as well as any potential fishery ill the reservoirs.
!he terrestrial ~pacts assessment: and mit::igat:i.on options put
forth by the consultants are quite general, not. sufficiently
thought through, <!l1d provide an inadequate basi.s for a full ~ )./DL...J...-
discussion of the project:. This is directly related t.o the
lack of an acceptable methodology for quantification.
Public access and t:he mode and route of coa.structi.on access
need to be fully addressed within the cont:ext: of mitigation.
The e:nvironmenca.l consultants have recognued that public
access poses the greatest threat: to the terrestrial resources,
princi.pally through disturbance. It is complecel.y incongruous
given this assessment: and A:iA' s goal of "no net loss'" that the
consultant should attempt: to divorce access from consideration
of llli.tigat:ion as they have done.
A pioneer road conscrucced prior to FERC licensing. is proposed.
The sole purtJOsa. of chis road is t:o facili.t:a.te project: const::uction.
W'e do. a.ot: expect:. FERC approval for this proposa~. FElU: cannot
-3-
give ics approval Yithout an environmental impact scac~enc.
In addicion, ha.bit<!-C losses susta.ined ausc be justified by r:he
need for a project:. The c.eed is _proven. ~o~hen., in the case of a
power facility. the license is issued. P"rior to tha.c paine.
there is no project: and there is c.o habitat degradation that
can be just:i.fied.
~e believe that: alternatives to Susi~a mus: also cont:i.Ilue to be studied.
Comparison a£ tradeoffs for fish and Yi.ldl.i.fe resources att:endent: to the
North Slope nacural gas, Cook ~et: ~atural gas, Beluga coal, other
hydroelectric generating a..lternat:ives, conservation, and other options .
have c.ot: been evaluated to an acceptq.ble level. Cantinued studies ~o~oul.d
al.lov for a full evaluation of the envizcnmental. costs.
!he APA proposes to submit a licence appLication to FERC on September
30, 1982. !he applicati.on ~ be based on the feasibility report.
Given the numerous de£iciences I have just: noted a submission on the ·
proposed da.t:e "WOul.d be premature.
The Fisa and YildJ jfe Se.rvic~ bas had m.inima.l involve:~..en.t TJith the
Susit:na. project: during the last: Z and l/Z years. Ye believe "lie have
cousiderable. experti-se to offer APA in de•rel.oping an adequate license
application for submission to FERC.
One parti.cul.ar area in. wh.ich we believe we. could add substantially to
the study is in quantifying the fish and wi.ldlife data. for ev.al.uating
~pacts and formulating ~tigation plans. The Service's Habitat Evaluation
Procedures "lloul.d provide a framework w-ithin which habitat val.ue can. be
evaluated. Thi.s methodology was used in both the Ter=or Lake and the
Bradley Lake Hydroelectric Projects. Our Increnent:al Instr~ Flow
Methodology allows for the quaa.tificat:icn of the ancicipat~ impacts of
proposed flow regimes on aquatic habitat. Modificat:i.ott woul.d need to
occur to this methodology bue Ye fuLly believe that it provides the
groundvork upon TJhich to buil.d.. It: was util.i.:ed in the Te----ror La.k.e
Project to evaluate ±=pacts and for-mulate mitigation ae.asures to protect:
the fisheries resources.
The Board shou.ld rea~ize that the very decision to file the application
with FER.C "IIOuld automatically change the relationship bet:veen APA, its
consultants. and the Fish and l~Ud.li.fe Service. With t:he decision to
file. our attention !!lUSt i.mmediat:ely focus on the licensing process. ~e
no longer would have sufficient t~e and manpower to assist: and provide
expertise to A:PA and its consultants. ~e would expect: that ocher
federal. agencies You.ld be similar~y affected.
~e recommend that: the deci.si.oa "llbecher or not to submit an application
to FER.C shou.l.d be deferred unt:il. d.ac.a gathered this year has been
evaluated. We lli.USt bave a better underst.anding of the fishery-habitat
relationships; a. lDDre· t:bcraugh understanding of t:he re.l.a.t:i.ouship of the
aquati.;: habit.at: to flovs and temperatures; an understanding of wha.t the
terrestrial t:radeoffs are; and a greater comprehension of the reserroirs'
temperature and turbidity regimes.
-
~e greatly appreciate the oppor~uaity to present this testimony and look
forward to a continued ~orking relationship.
,.. ~(.1•·-... f. .. !"" .,.,
U nitec States Department of the Inter1or 2920/0LJ
8UR£AU CF L.ANO MANAGC::~ENT
A~chor2~e Discric: Office
~700 ~~s: 72n~ Avenue
.\ncho:~ge, Alas~~ 99507 APR 1 ::. 1982
Alaska Po~er Authority
Board of Directors
334 ,,Jest Fifth Avenue
Anchorage, Alaska 99501
Gentle!llen:
The Bureau of Land Manage!llent appreciates che opportunity co address and
comment co chis board on the proposed Susicoa Hydroelectric Project.
Curt ~cVee, Alaska BL.~ State Director regrets that he is unable co
attend and comment today due to ocher commitments. I am Dick Vernimen,
Associate District Manager, BL~ Anchorage District.
Since che Anchorage District will be the office ~~ng the reco~en
dations on che project I ~ill be speaking from chat posicion.
The 3L~'s charge as a multiple-use agency is co allov the use of che
public lands co its highest capacity and values and to mitigate ~pacts
where possible. In the case of this project we are involved ~ith a
!lli.xed land pat:t.ern requiring us co ace as interim land !IIanagers in
regards co unc:onveyed Native and Scace selecl:ed lands. Our charge is
che same but the land status requires more concurrence concerning decisions
on ~hac is allo~ed to happen on these lands.
Based an what: we know about the projec:c today from reviewing documents
and ~eecL•gs ~ith bach ACRES and APA ~e do not: forsee any reason ~hy che
concinuacion ai projecr:. development should noc proceed. We offer che
follo~ing informacion for your use:
l. Pioneer Road Routes.
As we underst:and the situation, for those routes that: originat:e
eicher on the Alaska Railroad or the Parks Highway, che
Pionee·r Road would have co be constructed during che years
1983-:-1984 in order co arrive ac improved access during 1985
and ~arly 1986, ~hich would then provide for a st:ace of
cont:inuous access from the middle of 1986 onwards. The
Pioneer Road concept requires road rights-of-way and =elated
permits during che year oi 1982 ~hich is prior to the ?ERC
licensing process. There are obviously several preble~
with che Piqneer Road concept. As ~e nov understand the
situation, r:"hey are as follows:
l.
2.
Early construc=ion of che ?ioncer Road would have co be
permi.tted by a BLH righc-oi-•..,oay c:,.ac •..,oould require an
environment:al impact scacemenc separate frum chose
documencs no~ being prepared for che project:. Approach-
ing che Pioneer Road ?roject: in a separate EIS without
e•1aluating the .antire Susit:J.a Project may lead co a
legal challenge of piecemealing a bigger project. In
ocher words, we could be challenged that the road is
merely a pare of a. larger overall hydroelectric project:·
which should be analyzed a.t one time.
!he Pioneer Road would deviate from the location of
the final access road particularly on the route south
of the Susitna River betYeen Devil's Canyon and the
Wacana site.
3. !he Pioneer Road concept requires decision making by
the Cook Inlet Mative Corporation, State of Alaska, and
the Rureau of Land Management:, prior co licensing by
FERC. We are very much concerned chat a decision on
the pioneer road may lead to serious .anviro~eo.tal and
economic consequences prior co the a.ccual licensing
of the project. While ic is not: likely a FL~C license
will be denied after the feasibilicy of the ?toject has
been established, time has a ~ay of changing the values
set by many of our past decisions and we as separa.te
agencies cannot cake the Pioneer Road concept lightly.
There are three ocher aspects of che Pioneer Road
concept: we should oencion. Those are: 1) it: is very
likely a Section 10 permit will be required for crossing
navigable waters (Susitna River), 2) a Section 404
pe:t1llit for wetlands 1.1ill be required froo the Cor-p of
Engineers, and 3) the decision on the ?ioneer Road
concept will be elavated to che level of L~e Secretary
2
of the Int:erior. All of che ~encioo.ed problem areas
t<tl~e cime and, as time is o£ the essence, it is excremely
important: chat:, if a route is chosen chat: requires
Pioneer Road construction, chat the decision be o.ade
as early as possible and chat: the application for right-
of-way and other permits be made co the Depar~nt: of
·.·Interior a.nd Department: of De.feose agencies at the
earliest: possible moment.
2. Environmental Impacts:
We are concerned about. che relat:i•1e environmental tradeoffs
chat: muse. be made if this project: is co be consc=uct:ed. We
cannot: at t:his time recommend to you a preferred access route
and !llode. There are obviously some rouces hoYever chac
pose relatively higher environmental costs. Those routes
are che one south of che Susitna Ri~er b~tween Jevil's Canyon
and Watana and secondly, the corridor parallelling the
Indian River. Also of significant environmental concern is
che rouce proposed south from the Denali Highway. The i.m:pacc
here is some•..that llli.t::igated by che wescern rouce as opposed
co the route via Butte Lake. It is still unclear as co the
relative magnicude of che impact on caribou posed by the
western route south from the Denali Highway. ~~1ile we are
concerned as co the impact on chat caribou herd, we feel that
che environmental tradeoff i~ question is one of impacts
on the caribou herd versus the impacts of more productive
habitats in che area of Indian River or Fog Lakes area.
From an environmental standpoint, the route southerly from
the Denali Kigh~ay seems preferrable from the aspect of
minimizing disturbance of productive habitat. The route
from the DenaLi, ho~ever, poses a secondary impact, chat of
human access co the project area after construction. Public
access co the project area is a t~o-edged svord. We recognize
that the Wacana Project may provide a valuable recreation
source for people of the southcentral Alaska. I~ is also
recognized ho~ever, chat public recreacion can be a very
destructive activity. We submit that control of the access,
che State Game Laws, and che project management, after
construction, are tools chat can be used co l!lZnage the a.dverse
effects of increased recreation opportun~t~es. !he question
of public access co the project area is a spinoff of the type
of access chat is developed for project construction. wnile
cany problems are present we submit to you che following
conclusions:
a. Both rail and road access will be required for construe-
cion. We feel this concept provides adequate flexibility
and logistics during construction phases.
b. It is improbable the State of Alaska can construct a
project of this magnitude Yithouc some form of readily
available public access as a residual product.
c. The entire Susitna project is surrounded by primarily
·c:vo kinds of lana ovnership, approximately 215,000 acres
of private lands, in Native ownerships, and a very
large acreage of State Land. The Cook Inlet Region
Corporation has indicated they prefer develo?ment of
their lauds as a means of generating revenue. We can
deduce chat the State of Alaska likevise is committed
to the;development of the highest: and best use of its
land. ·This land ownership pattern and the respective
management philosophies lead one to believe chat road
access will be supported by these two very important
landowners in the area of che project.
Ic is our posicion co work wich you on che projec: proposal in che mosc
~xpediant manner •..,re cJ.n while working •..,rithin che lJ.ws ;lnd regula:ions
placed upon us. If chere are further quescions concerning our comments
please concacc me at (907) 267-1246. Thank you.
~~~u~
Richard J~ernimen
Associace District Manager
United States Department of the Interior 2920 (013)
BUREAU OF LANO MANAGEMENT
Anchorage Dist=~c: of:ice
4700 gast i2nd Av~nue
Anchorage, .Uask.1 99507 JAN 7 198Z
l"'.r. Eric YaW.d, ~.Jt:i.ve· Direc-._or
Al.a.ska. PC"M!r Aur:i::l.orlcy
3.34 W 4th Ave., 2nd noor
ft.nc:h.orage. AJ.a.ska. 99501
De.a::r: Ml:. Youl.d:
The &..."! has been c:oru:ac'Ced by Acres Pme_"'"ic:an reques~ fotmal c:cord.i.Dat:ion
cmd review co. five Susitr..a Bydroe.l.ed:rlc Project: doCUients • Cmxrent:.s en d:l.ese
. cioc:xnenr:-s c.ai!Oet be accrrnpl 1 shed under the gu:L:iar..ce of t±-.e ACRES Cocr.cdinatian
P'Lic. und.l a coorciinat:ed int:e!:'agpncy a:pprcacb. is c:ieveloped for r~Tie.w and
crnmenrs. Such a process. h.as been reccmre,.,ded by cb.e. Susit!"'..a. Steer ...... -,g Can-
mir:-...re ani is· ~t:il:g ~ approvaL
!cur recem: let:t:et3 md br.!..efil:tgs have brought: into foc:s several aspects erE
;~--,, access s t::::J.d:r that: I ~d like co car:mmt: co.. 'I:bose sub j ec:t. areas a:re
Land st:at:.Js , Pi~ Road coocepc:. etiQ"f_-•• orme.ntal. impacts , and t;he pi.ecemal
e"f: ec:: CD. t::i"le. pre j ec;t:_
Br:i efly, t:he land s1:.a.OJ.s oo t:b.e project; area. has not: dl.anged si gni fi candy
within the Lase ~; ~, Oe:re -a:re seve:::al. prob lam c::::lOCe-~ l..aDd
st'..a.C.ls ~ feel should be brou.g!:lt: tD yot::J:J: at.""'.....enrion. Th.ese problems ~ are
as follCJ'(NS:
L Th.e Oli.c..~om Nac::i.ve Coroarat:.i.c:n' s ad:m pj st::'at:i ve a:aoe.a.l to BL.'f
Int:e:rim ~ N::J. zas. ·J:U.ch c.cnveyeci 1..m.Cs t:0. Cede Inlet
Regioo Inc~ (C!RI) , c.asefile No. vl..S-30-l, has been <ti srrri ssed by the
Alaa k.a Nad. ve C1..dm:s Appeal Board ( ANCAB) •
2. Anot'be:r act::i.oa filed by the Cllic..lc;tloon Uativ-e Corporat:ion is a dvil
suit: filed i.n U.So Dist::"'.....ct Ccu:1: (casefile rro:rber A-80-207). Th.:f.s
cou.rt suit ~ filed. on village deficiency 1..mds ..ru.ch enc.cmpass the.
em:1:re project: ares... 1b..ere are also 1..ands ~t±dn this a:rea that:
have been select:ad bv d:le State of Alaska and ClRI. Mr. Dennis
E!cpeell of the u.s: ~ cf Im:er.....or Reg:!..ona.l Solicitcrrrs
Qfft ce is the At::r:r:Tt:!:Js! on the abc.rve case for the lJe?art:cent: af
Im::.e:::icr. 'Ihe c:f.:vil ccm::1: <:3Se ~ be a consid.erat:i.on in the
granrtng of any rigb.t:-<Jf-ways by the Cepararent of !nt:a...-:ior fer
access t::l:l t:::he ~ject:. t.hile t:h.e ~ rm.y gram: rlght:-of-~
pel:mit:s oa. Lulds under lit:igat::ia1, t±le standa:rd Cep.art:m.!nc pracd..ce
-
-'
~ll:Ces ncc::ificaci....~ of the olai.nciff (Cri.ck.alccn) a£ ,..:..,~ orooosed
i.ssu;mce of ~...ghc-c£~. ~ practice allcw"S tb.e pl..a..i.D.r f:f co
file for a re.::rt:=ajpirg orde:= ::bar: ;.;auld scco r:::-.e issuance. af ti"...e
rigtu:-of -r,.;:a;y-. ~ =eccmre"'.d tb.a.t: the APA ~s c..; ga r:e .f-=:b.er, · ... -it±.
the 5D! and t:b.e Regi.cnal Solici.tcr 's Offics, tbe qt:e.Sd.or'.s a£ lar..d
and litigat:ion s t:aO..lS -
3. The end.--e a:r:e.a. 'rit::b.in. the Cock Inlec. agreerent b.crunc:ia:ry is laDd
cccside.red en as Appe::d:ix A l.aods.
!be secood COI:l.C.ept: ..:e ·~d li..~ to disc..:ss is t.he pioneer read as proposed by
At=es .:1..aeri.can duri....cg the O~...ober ZOt:!l brief.: ~g thi.s year. As ~..e t=lde-..-st:ao.d
the sitw:t:i.on~ for t±.cse rcur:.es t!:lat: or.i.ginate eit:b.er on :he Ce!-..a.li Ei..g;t,.;c:ry,
Ala.ska RaiL"'"'Oad; or t±.e Pa-.-ks Higtr'..;ay, oe ~....oneer Read. ·..o.lld have to be
ccos"t:r"~...ed drrr=fng tbe. ye.m:3 1983-1984-itt orC.e.r to ar:::i~ at: Umrcved a..ccess
dx::::r....=tg 1985 aod earl7 1986, ~ '-iCUl.d t:±:.eJ. provide fer a st:a.t:e .. of cont:iDous
access f:rc:m t:be uriddle aE 1986 ~. The ·Picoeer Road coru:.e!)t: reau:i=es
road r"...gb.t-d-r.o:a:y .md related pe::::rit:s diJ:::"i...r::g the yesr of 1982 -:.i:ri..d:J. i..s ·p:::i..o:
to r:..e FERC lic,....,s.i.Dg process. '!he:::a are. cbvioosly s~al prcble!::l • .. i.th t:b.e
~onee?' Road ~t-.A& -:.oe ~ ~t:md the sitcat:i.cn,. tb.ese are. sar:e of
t:he prcb 1.e::s • ..
l. Ea:rly c:r:cs~-Cn c:E ::he ?!.cr..eer Rc.ad ·~d have to be pe:::::I!i..r:-~ by
a. BIM. :igi:lt:~~ ~o· ~d.. reqai....-e an eavi-~O'IE!ltal ~~
st:aterern: separate fran. t±ose ciocr:m!.."lts o::w ':e-i,..g prepared for the
~ Susi'!a pro jed:. Approad:li.ng the ?"~..eer ·Road P:=o j f!C!: in a.
sepa:rat:e ITS 'Ooi.tb.ct:::t:: ~uat:::L:.11g it-le em:i:e. Susio::a ?=ojec= rra:'f lea.ci
t:o a. legal oaJ1 enge cf piecerm.sling a bi.g:ger projec=. In adler
r,.;ards-, -.e· could be c::.a..ll..e:Dged tb.at. the road is ~ely a parr: of a.
lai:;e:r ~--.ill. ~....c pro j ec:: .tti.dl shcu.ld t:e ;ma.ly---ed at: cr!2
t:ia:e.
2. The Piooeer Road "..O'..lld devi...a.!:e. f=o::n tb.e. locat:ion c£ t..'""!e f:i!:.al access
road par.::ic:,Jarly en d:l.e roti!:e sout::!::l o£ t±:.e Susii""a Ri.v~ bee-~
[)evil's C:mjon and t..1.e ~Qma. 3ite.
3. 'Ille ?4.....oneer Road coccept: requires d.ec.:i.si.co. tmlC.I:g by the Cook L."llet:
Native Car.xJ:cat::im. State af A.la.ska. and the Bureau of Land Ma.oage-
em:., pr....Dr to the 1,. C"""":ting by' FERC. ·..;e are cooc~~.i ~at: a
deci..sioo. en. t±.e pj oceer . Road r:rs:r lead to envi.~~t:al and eccnan:ic
conseqoeo.c:es p:c:Lor to t±e act:oal H '"'<"T.Si..."lg of t..~ ~ject. r..lrlJ.e it:
:U oot: W<.ely a EERC U cense will re denied ai'!:er the fe.:1Sibility af
dJe project: has been est:abllsh.ed, t::i.Ire has a ...:rr of charging the
values set: by tJitttY of car past: eec:Ls:i.Dns and ·~ c.:mcoc: take d:le
Pioneer· Read coccept: llgtltly .· 'llle:!:e are three otbe:r ~ec=s cf the
Piatlee:r Road concent: "'te shculd mend.on. 'Ihose are: 1) it: is. verr
lilaa.l.y a Sect:!.on io pe:tmi.:. will be reqcired fer crossing n.avigab le
~t:e::s (Susi.tlla River), 2) a Secticn 41)4. pe~t: for ·..;;erlo;mds will be
requi:rerl f:rcn t::b.e Corps of Engineers, and 3) r+.e d.ec.i.sion on the
Piaoee:r Read coc.cept: ~1 likely re elevated to t.b.e level of the
2
St:c=et:.ary cf t:!le l:lte..~or. All GI: t..":c afcrc!!".e..o-:.r.:rr:cd prcb lc:n areas
take t::.::e and, as t::=e is a£ t..'":.e essence, it. i..s e..t-e:ml:r i.m;or-._:mt
tbat: i£ a. :rot.tt:e is 6os en C:lac :re-::ru.i=ed ~...:.."'!leer ?.cad c=r-..s t=uc=:i.cn
;'"-e decisicn be made a.s e:rrl"'T as oossi.ble and r:.."u!.t :..~ aoolic:.a::::icn
for r.-.mt:-o.f~ ai:.d 0~ :=.e._..-:m_t.i be :mee ::.:J r:.~e ~a.rt:::ED.t: oi the
Int.e:::"'..Dl: and De?a-.~ cf ~rec!Je agc~c--es at: :-7-<e earliest. possible '
TTX'l'TI!T'r.
Th.e thi..."""Ci m.jor S"oJbjed: brought: ~ car ac:--....ent::i.Dn is eu:J; :::crmenral
~-3. As agencies ~.-e are all ~...ed abaar: the relative. en-
v'i.:J.H "enral o:adeci:fs that: n:ust: be made i£ t!::..is proje~ is to be
comt:rtl.C:t:ed. ~ c.:mcot, ~, at: thi..s t:iJ:l:e, ::e!":::mrer:d to 'J'CU a
prefer.:ed access route and !ICde. ~e are cbviausly sa:oe rcu1:..:s
that: pest: rela.t:!.;ve.l. y hi gber env:f..:rorment:.a.l. c.os t:3 • Those routes are,
t.b.e cce sour:b. of the Susitca. Ri. ve:::-'c:e ~ Devil' s Canyon and
).;acma., a:od seccndJ y. a. si.gc:f...f:i.c. area af env.i::::: om euca I coo cern is ,~
the. corr..dm: pa:ralJeUng the. !ndi;m River. Also, a. sigoific.ailt
e.a:vi..."""C!J'TP!'lta I · ccr:cem is posed by tbe rcur:e sou:t::l. f::cm the Dena 1 i
Hi~. '!he in;wcr b.e:re is scmerNhat: mi.C,gated by t±.e. ~ste:!'.':l l:'CU%:e ,.
Da.J orefe::=ed as CO'CCSed. to t!:e. route ~...a.· 3t:tt:::e I..a.ke. It: is sd.ll
11DC 1 ear as to t:he re 1 at:i"re. megt;i t-•de cf ~e ~act: en c:ari_bou. posed.
by tile ~ :otl%:e. som±t. f:::m t:b.e Dena 1 "' 'P'.; gtr-.::a.y. r..J:rl.le •.;e. a:re
great:ly cmcP'f'tled a.ixru:t: the ~t: ctt t±::.at: ~..lx:u. b.ed, ·.;e. fee--l
t!::l:a.t: t::he ~ t=adeoff. in qc.est:!.cn is· cne af ~t:s en r:±le
c~......'bou b.e:rd ~ tbe impa.~...s af !ICre prodo.ct:ive habi::at:!! in. t.be ,.
a:rea. cf roman Ri.ver ar Fog I..ak.es. Fran an e!I"l'Uocnoenc.al st:.atld-
poitlr7" the n:x1t.a sonrt:erl y f:.tJ::~o O.e DEma Ii ?'..i.g!T"'<:S.)' see'!l.S prefe=::ilile
.-.em .. t.ne aspecr of. urinimf.,...ng di.s~-mce af £h.-..duc::::..7e 1--pbit:at:.
The 1:0UX:.e frtm t±l.e Dena 1 :t ... ~ • poses a. sec::r"..cia:l:y impact:, tba.c
of hr:man ~a. t:.c ::be: p:rojee!: dre.a a:f+"'""' c::mst::::'!.:!:t:i.cn. Pt:bllc
access to tbe proj e~ area is a t"'·••"O--e--'....ged S'to."01:::i. ~ :-ec.....--gDi=e t:b.a:t.:
the '\.:a~ . Project: my provide· a v:_alu.able ~ .sow:r:2 for ,-
~le -:: =.:: .. ~~t=ll Alaska. lt is also reccgm.zea. h.cweveT:
d:lat:. public rec:eat:f..oo c.:m be a. dest::".Jet:i~ acti.Yicy. 1Ne submit
r:::hal: c::cm:::'Ol af t::tla a.cr.:::ess, tr..e St::&te G.:m! L;n.;s, ,u::.ci :."'..e iJrOjec::
mmsg~ a.ft:er const::t'tld:ial, 4n! tools t:Me em be. tl!led t.o ~
tb.e ~e effec:t:s af i.t:u:::::e.ased. rec=eat:ion cooort:t."nid...es • '!be
·qcest'ial cf. pcbl.:L:. a.c:cess-to the. project: area iS· a spinoff a:f tb.e. ,
type of acr:ess. t:b.ar. u deve1.oped for project: coost::uct:!.on-~e
mmy problam. are presem: ~ submit:. to you. the fallC".wing c::o.clu-
s:i.ccs: '
a._ Both rail .m,d road a.cce.ss ~1 be -reqa:L..-ecf for CCDSo:-.JCt:ion..
~ feel. tb:f.:J concept: provides a.deqt:a~ fle::dbi, .; cy ar.d log:i:l-
t:ic:r .dn:d ng c:ocst:rt:ct:ial phases.
b. It is ~bable the State of Alaska C3%l const::ucr a project: of
tb:is' magrd t:cde wi.tbcut. Sc.:ID! fum of :=ead.Uy ~ le pub lie.
access as a residual prodoc:t.
c e 'Ihe. ent:iJ:e Susi.t:::la project: is su:cot:...""lded by pr~...l7 t"..;o ld..Dd.s
of land. ~ F ~ely 215,000 ac:=es c:f private l.ai::lds
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in Nat:i"\'1!! ~::ups, ar..d a 'lt=>::Y large ac=eage c£ St3.ta l..and.
The Cock !clec 'Region Co-rporaC:.On has L.~ca.t2d t~ey p::-eier
deve..lcpm!Ilt: af t:he.i= l.ands as a ;::;:eans cf 6 er~at:i.o..g -:a~.J"el:'!Ue
'We can dednco t.b.a.c the State cf A.Llska l.ikeNi!le i3 c:::n:mi.::ted to
the develcpu:ect: cf. tbe hi ghesc and best: cse o£ it:3 ~-!b.is
laDd. ~-ne:rship par-._em. and the re.specti. ve rm.n.agerte.OI: philo-
scphi.es-le.ad · or.e to be!.f.e.;.e tb.a:t: road access ~1 be ~ed
by dlesa Coila: ve:rr ll:;xlrt:::ant: ~ in the a:ea. af tb.e
pro jed:.
The 1993 t::ilm fr~· Fm-~~-l!.:c.e desdllie. has been a ~y CCllc:rovtar.!i.aJ.
subjeC: aiJd it is CCC ~ uc.cierstood hew t:hi:3 ·.;as e.st:abllih.ed. ~ ~d
appreciaa c.lar'...Bcadcn af t:le jusMficat:ion for esabl.ishiog 1993 as a
p 1 ami ng ab j ec::::i'li'e • '
I.t: is hoped t:ba:t t:D:is lec-..e:r cl..a:l:'f...:fies PL"i' s posi H on aa land sc.Cls , EIS, and
RCW' gx:aw..;ng, li:.ttC:~ .met c:xli:di;rurdm... Sbculd ]OlL ~ fu:r:::b.er quest::l..aos c:bat:
requi_~ el.a.bora:d.m· aDd elt~Mdad..cn. feel E=ee to c:ccr.a.ct.!IJ!.
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i i i I i :.._
: i i1 iJ-1_':) I
DEPT. OF ENVIRON~IENT.o\.L CONSERVATION
(907) 465-2600
Mr. Charles Conway
Chairman, Board of Directors
The Alaska Power Authority
821 N Street, Suite 201
Anchorage, AK 99501
Dear Mr. Conway:
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.JAYS. HAMMOND, GOVERNOR
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; POUCH 0-JUNEAU 99111
April 21, 1982
Subject: Decisions on the Proposed
Susitna River Hydroelectric Project
As we are all aware by now, a decision on further work on the
proposed Susitna hydroelectric project will not be an easy one,
especiaily considering the legal constraints we are under. There
are a number of alternatives which the Authority should consider,
not only those recommended by Executive Director Eric Yould, but
several intermediate ones. In order to understand this situation
better, I would l"ike to share with you my ideas on several of
the factors we are required to consider when making our decisions:
A. Economic feasibility and financial considerations. The
Acres feasibility study and the Battelle Susitna alternative
study determine economic feasibility using different mechanisms.
Acres derives a "net economic benefit" formula which derives a
present worth for the difference between the cost of the Susitna
project over its projected economic life and the cost of the
"best thermal alternative." Battelle derives a "levelized cost
of power" which demonstrates the per killowatt-hour costs of
several alternatives, one of which is Susitna. Although both
studies predict that the Susitna project is "feasible," in that
it presents a positive "net economic benefit" and a lower
"levelized cost of power," the actual figures are quite close to
those of the thermal alternatives, and are quite sensitive to a
number of exogenous factors such as demand rates, cost of fossil
fuel, discount rates1 cost of borrowed money, inflation, cost
escalation, and unknown technical factors. Further, the differen-
tial in costs between Susitna and its alternatives may be less
than the inherent error in the calculations.
Acres indicates in its analysis that the Susitna project will
suffer an "inflationary financing deficit" for at least the first
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Mr. Charles Conway 2 April 21, 1982
twelve years of its existence. This factor results in a projected
production cost of the Susitna project of 30 cents per kilowatt-
hour and of the base case thermal plan of 14 cents per kilowatt-
hour. The "inflationary financing deficit" would begin to be
repaid after the first twelve years of life of the Susitna
project, but Acres does not speculate as to when it would be
"zeroed out." Acres goes on to recommend that the State essen-
tially pay for the "inflationary financing deficit" in advance so
that the project can be "competitive" with the base case thermal
option--that is, that it will generate power at, or cheaper than,
thermally generated power. This analysis is sensitive to the
same factors as the "net economic }Jenefit" analysis--the thermal
option costs are especially sensitive to price escalation of fuel.
AJ.so, Acres compares a subsidized Susitna project with an unsub-
sidized base case. It would be of value to see the projected
energy costs from a variety of equally-subsidized comparisons
of Susitna and the base case •
All this indicates that the economic feasibility of the Susitna
project has not been demonstrated, at least to my satisfaction.
Of equal· concern are the financial considerations. In a very real
sense, Susitna's financing is tied to the price of crude oil.
If the price of crude oil is high, Susitna looks inviting when
compared to the base case thermal option, and the State may have
the oil revenues to provide the front-end subsidy Acres recom-
mends, albeit not without sacrificing other capital projects.
At present, however, the real price of crude oil is low, thermal
generation may b'e more economically efficient than Susitna, and
the State treasury cannot fund the "inflationary financing
deficit" without severe sacrifice to the State's general fund
budget. Also, revenue bond interest rates are so high as to
potentially adversely affect the economic feasibility of this
project.
Under the economic and financial analysis performed by Acres,
the "net economic benefit" of the Susitna project does not inure
to the Alaska Power Authority or the State treasury, it goes to
individual ratepayers. In view of the fact that current legisla-
tion requires neither a repayment nor a rate of return on the ·
State's cash investment in this project, regardless of the size
of that "benefit," the State treasury will actually lose its
investment in the power project, andt the long-term opportunity
costs associated with that loss.
The alternative to ·partial,_or .total, State financing of the
Susitna projec:t is to use revenue bonds; -with perhaps some form
o£ guarantee by the State, or some other form of bonding. If,
however, the project were to be required to repay the entire
costs, including in1;er~st,_of the project, the "inflationary
_ ~inancing deficit"·<may result in early-yea~ costs of, power which~:
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Mr. Charles Conway 3 April 21, 1982
are twice those of the base case. It would be necessary, under
this scenario, to require participating utilities to purchase
power from the project on a "take or pay" basis where each
utility must guarantee it will either purchase a minimum amount
of power at the project's cost, or pay the equivalent amount to
the project if it doesn't need that power. In this way, the
Authority can assure it will recover sufficient revenues to pay
the bond payments. The willingness of the pertinent utilities to
enter into such agreements, knowing they may be able to generate 1
less expensive power at least in the early years, is speculative.
B. Environmental and technical considerations. It woultl
appear that, by and large, the Acres feasibility study adequately
addresses most of the technical aspects of engineering design and
construction. It also would appear that, with the possible
exception of relict river channels, that sufficient information
has been generated from field investigations to begin detailed
design. It may be that new field information needs will emerge
over the next few years of work on the project. However, it is
not likely that this would result in sufficiently radical design
changes to increase the project cost substantially.
On the other hand, there appears to be substantial question on
the amount and quality of environmental information and the type
and extent of mitigating measures, if any, that would be
associated with this project. Virtually all federal and State
resource agencies were critical of the level of information
gathered to date, and several suggested that· at least an addi-
tional year of data is required to understand the biological
populations and physical environment. Further analysis was also
indicated for an adequate understanding of the effects of this
project on the living resources and other environmental factors.
The mitigating measures incorporated into this proposed project
have a direct bearing on its costs and economic feasibility. In
my view, both the capital and operating costs of the mitigating
measures, be they fish hatcheries or other means, is a legitimate
project cost and should not be left to the whims of the Legisla-
ture's appropriation process. It is not certain to what extent
these measures were incorporated into the Acres and Ebasco cost
estimates of this project. However, of even more importance is
the impact of controlled flows on fisheries, and the in-stream
flow needs of the resident aquatic populations. If the Susitna
River discharge is managed to protect fishery habitat, a concomi-
tant decrease in potential power generation may result. At
present, there is no agreement between the staff of the Power
Authority and the resource agencies on what the stream flow should
be, however, a substantial deviation from the Acres optimal needs
may result in the project becoming economically infeasible.
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Mr. Charles Conway 4 April 21, 1982
C. Alternatives to Susitna. I don't think anyone would be
surprised by a characterization of the Battelle study as
"disappointing.~~ Although Battelle did review ~ome traditional
sources of electric power which might be alternatives to the
Susitna project, but did not review in depth some options which,
in my opinion, seem viable and quite possibly economically com-
petitive with Susitna. In addition, Battelle did not review
possible non-cost means of subsidizing public power in the rail-
belt area. Further, Battelle apparently considered at least some
options as having substantial environmental objections which, at
least in my opinion, are not all justified. Battelle did not
adequately treat the options of using gas to generate power at
Prudhoe·Bay and transmitting it to Fairbanks and Anchorage, or
of building a gas pipeline, independent of ANGTS, t~ Fairbanks
and Anchorage, and using gas for home heating and electrical
generation of the railbelt. Battelle did not thoroughly consider.
using Healy coal to fire a series of 200mw steam-electric power
plants. The coal option was apparently criticized as causing
air pollution problems and contributing to the "greenhouse effect"
and "acid rain." Although the increase in ambient atmospheric G0 2 is not to be scoffed at, the contribution of six 200mw coal-fired
plants to ambient C02 is probably negligible. As to local air
pollution, that depends substantially on the location of the·
plants, but considering the type of coal involved and the type
of technology available today, it is not likely that a perceiv-
able Lmpact on visibility would even result from a properly
designed and operated plant. In addition, the low sulfur content
of the Alaska coal available would argue against a potential
decrease in the pH of precipitation. ·
Battelle al.so did not look at the possibility of the State using
its natural resources, rather than cash, to subsidize an energy
project. For example, the State could dedicate a portion of its
North Slope royalty natural gas to.the Alaska Power Authority at
no charge: the Power Authority could then build a gas-fired power.
plant and the necessary transmission lines to carry power from
the North Slope to the railbelt. Likewise, the State could ,
dedicate some of its coal reserves to the Authority for use in
coal-fired generating plants. Although I ~ sure there would be
legal and technical problems associated with this approach, it
is at least worthy of investigation.
o. The Federal Energy Regulatory Commission license process.
The Susi.tna project may well be one of the largest non-federal~.
power projects ever constructed. As a result, FERC wi~~ doubt-
less have a large number of intervenors who dbject to ·part, or
all, of the State's application. I ful.l.y expect that a number
of national environmental organizations, as wel~ as their Alaska
counterparts, will intervene in the FERC proceedings .. and contest
the Susi.~ project as the "pork barrel" water resource project
Mr. Charles Conway 5 April 21, 1982
of the 80s. Their success in intervention and/or contesting the
required Environmental Impact Statement will depend upon the
quality of the application before the Commission, the reaction of
State and federal agencies to the project, and the environmental
organ1zations' own resources and objectives. APA and the State
have no influence over the latter factor, but we do control the
quality of the application, and can work directly with affected
agencies to address their consensus. At pr'esent, however, the
reaction of resource agencies seems to range from ignorance of
the project to something akin to opposition. Most agree, however,
that more information and more planning is needed before an
application is submitted to FERC. Submission of an application
before these concerns are completely addressed will likely cause
delay in the project because of the very adversarial nature of
the FERC process, and will provide substantial and effective
ammunition to project opponents.
The alternative of submitting a preliminary application for a
FERC license has not been recently discussed by the Board. A
number of witnesses suggested ~uch an action, and indicated that
it might be a way of involving the federal agencies, including
PERC, in the project so that the Board might know more about what
would be required to submit a satisfactory, complete FERC applica-
tion. In addition, the preliminary application might well cause
potential intervenors to identify themselves, and their concerns
discussed.
E. Recommendations. Regardless of the decision by the
Alaska Power Authority regarding Susitna, substantial new electric
power generation facilities will be needed in the railbelt area,
both to replace facilities being retired and to meet new demand.
In the normal course of events, those facilities would be con-
structed by the utilities involved, however, the prospect of
Susitna's construction has led to a hiatus in planning by public
utilities for long-term, base load needs. Further, there may be
substantial economic and resource efficiencies gained by central
construction of generating facilities to serve all railbelt
utilities. At present, the only institution that can construct
central facilities is APA. To allow utilities time to plan for
their needs, it is essential that APA make a firm decision and
commitment within the next 2-5 years. Because of the economic
uncertainties involving the Susitna project, and their sensitivity
to timing of decisions, it may not be possible to meet the needs
of the utilities and also make a firm commitment on Susitna at
its most opportune time.
Considering all of the unknowns arising out of the Acres feasi-
bility study and the Battelle report, I suggest that the Power
Authority take the following action:
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Mr. Charles Conway 6 April 21, 1982
{1) Defer deciding upon submission of a formal
application to the Federal Energy Regulatory Commission
for at least one year.
(2} Investigate the possibility of filing a
preliminary application and, if it is found to be to
the Authority•s advantage to do so, file such an
application at the earliest opportunity.
(3} Continue studies of fish and wildlife and
accelerate, when possible, design of mitigating
measures.
(4) Continue work toward design of the project
and any further associated field data collection.
(5} Investigate the possibility of entering into
formal memoranda of agreement with resource agencies,
especially the federal agencies, so that they can.be
provided with a formal avenue of communications with
the Authority, and the fun.ds necessary t0 properly
evaluate this project.
(6) Inaugurate a new study of alternatives·so
that the analysis of alternatives required by the
FERC EIS process will be adequate, and so that APA
and the State can be assured of selection of that
alternative which is optimal in economic efficiency,
environmental, socio-cultural impacts, and other
relevant factors. This study may be conducted by
others, but it should be understood that the funda-
mental responsibility for its adequacy lies with the
Authority.
(7) Recommend to the Governor that he formally
designate, through an administrative order, an
organization representing the affected State agencies,
to work directly with the APA Board and staff. This
group would help assure that the consensus of these
agencies are addressed in some organized manner, rather
than being revealed in the FERC intervenor process, as
was suggested by the Department of Natural Resources.
Of course, all of the above is predicated upon the Authority
receiving sufficient funding from the l982 Session of the Legis-
lature. Although that is, at this point, yet unknown, I have
every confidence that our Susitna budget request will be honored.
Mr. Charles Conway 7 April 21, 1982
I would be pleased to discuss these proposals in detail at the
Board of Directors 1 meeting April 22, and trust the Board will
award them every considerati~o~---------
Vice
cc: APA Board Members
Sue Greene, Office of
the Governor
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APPENDIX EllG
CORRESPONDENCE RELATING TO
ADDITIONAL STUDIES AND PROJECT REFINEMENT
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APPENDIX ll.G
ADDITIONAL STUDIES AND PROJECT REFIN£1111ENT
In response to agency concerns and in recognition that further studies,
especially in the area of fisheries3 were warranted prior to submitting a
FERC license appli-cation, the decision was made by ti;Je Alaska Power Authority
to delay the license application date. Studies and project refinements that
received agency review included the wildlife/habitat issue, water quality
and flow modeling, access plans, and downstream flow release schedule. Agency
consultation took the form of Steering Committee meetings, modeling workshop,
Fish and Wildlife Mitigation Review Group meetings, and request for written
comment on the revised access plan. Correspondence, minutes of meetings,
and meeting schedules are contained in the following pages.
Correspondence is presented primarily in chronological order. However, in
some cases, a response to a letter direct1y follows the letter to facilitate
an understanding of the flow of communication. This results in an interruption
in the chrono 1 og i ca 1 sequence.
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Ms. lee McAnerney
Department of Community and
P.egfonal Affairs
Pouch B
Juneau, Alaska 98111
Dear Ms. MCAnerney:
Febru~ry 25, 1932
P57DO.ll. 92
T.l533
Susftna Hydroelectric Project
Agency Coordination Meetings
.'\s an agency representative of the tl1storica1 and Archeological Group
reviewing the Susftna Hydroelectric Project you are invited to a meeting
on the morning of ~arch 15, 1982 in the offices of Acres ~~erfcan Inc.,
1577 "C" Street, Suite 305, Anchorage, Alaska. Tlie purpose of this meeting
will be to review the results of the Phase I archeological studies, assess
mitigation options and discuss future study programs.
If you have any questions relating to these meet1ngs, please contact
~~r. Vern Smith of Acres. at ( 907) 276-4333.
KRY/ljr
Sincerely,
John D. lawrence
Project r-,anager
f~r. Roy Huhndorf
Pre:i1dent
Cook Inlet Re~1on. Incorporated
P.O. r.rawer 4F:
r~nchorage, Alaska 99509
~e~ru~ry 25, 1Sc2
P570:J.ll.50
T.l537
Dear Mr. Huhndorf: Susftna Hy1roel ectrfc Project
A7ency Coord1natfon ~eetfngs
As a member of the Aesthetics and land Use Group reviewing the Sus1tna
~y~roelcctric Project you are 1nv1te~ to a m~eting on the afternoon of
~~arch 15. 1932 fn th~ offices of Acres American Inc.~ 1577 11 C" Street.
Suite 305, Anchorage, Alaska. The purpose of thf5 n~et1ng will be to
discuss the results of the Phase I studfes and to review the alt2rr.atfve
and proposed recreation plans.
If you have any questions relating to these ~eetfn;s, please contact
Hr. Vern Smith of Acres at (907) 276-4388.
KRY/ljr
Sincerely,
John D. lawrence
Project ~~anager
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Mr. Keith Schreiner
ncgfonal Director. Region 7
!J .S. r1sh Jnd tHl dli fe Service
lOll E, Tudor !toad
Anchorage~ Alaska 99503
Dear r.r. Schreiner:
F~h~uary 25, !q~2
PS700.11.71
T .1537
Susitna Hydroelectric Project
ft.gency Coordination tJJeet1nos
,,:; a mt!r.~cr of th! A~tth~tics/land t!se an1 ?~cr~atio!'l Cro•Jps rav'f~1ing the
Susitna 4ydroele~trfc ?roject you are invited to a m'!!etfn~ or: th~ afternoon
o7 :-tarch 15, 1932 in the offices of Acres ,,m~r1can Inc., 1577 "C" Street,
Suit~ 305, ~nchora~e. :!\laska. The purpose of this meeting \ifll be to dhcuss
tr.e results of the Phase I stu~fes and to review th~ alternative an1 pro-
posed recreation plans.
If you h:!Ve any questions relatfncr to these meetings, please contact
r'r. Ver:1 Smfth of .t\cres at ( 907) 276-4,988.
KRY /ljr
Sincerely,
John n. LaHrence
rroject 1-'!unager
Mr. Ronald 0. Skoog
Commissioner
State of Alaska ·
Department of Ffsh and Game
Subpart Building
Juneau, Alaska 99801
February 25, 1982
P5700 .11. 92
T .1531
Dear Mr. Skoog: Susitna Hydroelectric Project
Agency Coordination Meetfng~a
As an agency representative of the Historical and Archeological Group
revfewfng the Susftna Hydroelectric Project you are fnvfted to a meeting
on the morning of r-~arch 15, 1982 1n the offices of Acres American Inc.,
1577 "Cu Street, Suite 305. Anchorage, Alaska. The purpose of this meeting
will be to review the results of the Phase I archeological studies. assess
mft1gatfon options and discuss future study programs.
As a member of the Recreation and Aesthetics/land Use Groups you are also
invited to a meeting at the same location on the afternoon of ~arch 15, 1982
to discuss the results of the Phase I studies and to review the alternative
and proposed recreation plans. •
If you have any questions relating to these meetings, please contact
Mr. Vern Smith of Acres at (907) 276-4888.
KllY/ljr
cc: Mr. Thomas Trent
State of Alaska
Department of Fish and Game
2207 Spenard Road
Anchorage. Alaska 99502
Sincerely.
John D. lawrence
Project ~anager
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~1r. Robert McVey
Director. Alaska Region
National f".arine Fisheries Service
NOM
P.O. Sox 1668
Juneau, Alaska 99802
february 25, 1982
P5700.11.92
T.l535
Dear Mr. McVey: Susftna Hydroelectric Project
Agency Coordination Meetings
--
As a representative of the Recreation Group rev1ewfng the Susitna Hydro-
electric Project you are invited to a meeting on the afternoon of t~Zlrch 15,
1982 in the offices of Acres American Inc., 1577 "c• Street, Suite 305.
Anchorage, Alaska. The purpose of this meeting will be to discuss the
results of the Phase I studies and to revie~ the.a1t~rnat1ve and proposed
recreation plans.
If you have any questions relating to these meetings, please contact
!1r. Vern So1th of Acres at (907) 276-4883.
KRY/ljr
cc: Mr. Ron Morris
Sincerely,
John D. Lawrence
Project Manager
Director. Anchorage Field Offfce
~lational Marine Fisheries Service
701 11 c• Street
Box 43
Anchorage, A 1 as ka 99513
Mr. John E. Cook
Acting Regional Director
Alaska Office
~lational Park Service
5~0 West Fifth Avenue
Anchorage, Alaska 99501
Dear Mr. Cook:
February 25. 13'S2
P5700 .11. 92
T .1532
Susitna Hydroelectric Project
Aqency Coordination Meetings
As an agency representative of the Historical and Archeological Group
revie~1ng the Sus1tna Hydroelectric Project you are invited to a meeting
on the morning of r•larch 15, 1982 in the offices of .~cres A;-:1erican Inc.,
1577 ··c .. Street, Suite 305, Anchorage. Alaska. The purpose of this meeting
will be to review the results of the Phase I ~rcheoloaical studies. assess
miti9at1on options and discuss future study programs.-
As a member of the Recreation and Aesthetics/Land Use Groups you are also
fnvfted to a meeting at the same location on the afternoon of ~4rch 15, 19822
to discuss the results of the Phase I studies and to review the alternative
and proposed recreation plans.
If you have any questions relating to these meetings, please contact
Mr. Vern Smith of Acres at (907) 276-4888.
KRY/ljr
cc! Mr. larry \·!right
Niitional Park Service
lOll E. Tudor Road, Sufte 297
Anchora1e, A1 aska 99503
Sincerely,
John D. Lavtrence
Project Ha na ger
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!~. Tv ~i1liclane State-~istoric Preservation Off1cer
Alaskn Oepsrtr...:nt of Natural Resources
D1v1s1on of Parks
619 Harehouse Avenue, Suite 210
Anchorage, Alaska 99501
~~erch 2~ lq82
~ :700.11.92
T .1534
Dear nr. Shaw: Susitna Hydroe1ectrfc ?reject
Aaency C~rdinat1on Y.~~tfr.Qs
As an agency representative of the Historfcal and Archeological Group
reviewing the Susitna HyJroelectric Project you are invited to a meeting
on the r:lOnling of !:~arch 15~ 1982 in the offices of Acres Jtrnerican Inc ••
1577 .. C" Street, Suite 3Q5~ ,!l.,nchorage; AlAska. The nurnose of this
meeting 'ofill be to review the results of the ?ht.se I archeolo11ca 1
studi~s. ass:ss dtiqaticn option!: ar.d discuss futu~ study f!roor-:il:1S.
If you have any questions relating to these r:-eetincs. rlea!:~ contact
Mr. Vern Smith of :lcr~s ~t ( 907) 276-l.:--Bn.
KRY:dlp
cc: rr. -' 1 an CJ r!'-on
Sincerely,
John D. lil'.lr~nce
Project l'lanat1F'!r
~ivisicn of fies~!rch ; l~~e1o~m~nt
De':'!artn~t:nt of ~~atura1 Re$O:Jrc~s
!'o:J-::!1 7-:}.;5
Anchorage. Alas~a ~~5~1
I : ('~
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UEI".'\.HT.:HE."'"T OF ~-ATUil.-\L H.E.SOURCF.S
DIVISION OF RESEARCH & O£V£LCPM£NT
Mar~"l .S, 1982
Eric Yould
Execucive D~reccor
Al.ask.a. Paver Authority
334 \.les c 5 r:h Avenue
Anchorage, Al.ask.a 99501
Dear Mr. Yould:.
I
I
I
/
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I
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?ouch ?.:.oos
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ANCHORAGe. A~ASKA~995~J
fiE: C E I yEn·
'.1AR 9 1982
Alaska 0
S ept. ot Fi Pan F. ISh &. G .rsn;susitna H arne
Ydro
In the past: 18 monchs, t:he Susicn.a Hydroelectric Steering Comm.itcee
(SHSC) has revieved many aspeccs of c:he Susitna Hydroeleccric Feasibility
Plan of Study. \.le have been briefed by, and have consu~ced vi.t.h many of
the Acres American, Inc., concraccors and subconcra~tors. On Noveober 21,
1930, the SH.SC c:ransmitced to A2A a comprehensive reviev of c:he entire
Task 7 (environmental and socio-economic) Plan of Study for c:he proposed
Susic:na Hydroeleccric Project. Dur~g the s~er of 1981, ~osc of the
SHSC members part:icipated ia a field crip to the pro?osed dam sites and
to some of t:he field c~ps ~here invescigacions Yere ongoing.
As a result: oi these and ot:her Susit:na Hydroelecc:ric relat:ed meecings
and discussions, c:he m~bers of the Sceering Committ:ee are probably the
best: informed representatives of chose agenc;ies >.Tho Yi~l par.:ici.pate in
the decision 1:1aking and pe=iccing pt:ocess. ·· The SHSC az.e::~.bers believe it
is desirable co identify the mosc important: issues pr~or to the issuance
of the draf c feasibilit:y sc:udy for revieY and comment:. i-le hope this
~ill achieve c:hree t:hings: (1) provide a basis for agre~enc bec:~een
SHSC and the Alaska Paver Authoric:y on the status of icporcanc !ask i
issues and concerns; (2) provide the vital informacion co those not vell
in.fomed so they can be avare Yhen they reviev che findings provided in
th~ draic feasibLlit.y study; (3) vhere appropriate, co ident::i.fy potencial
remedial accions to c:he APA to minicize if not: resolve che concerns chac
are raised.
The pt:ocess thac the SP.SC Yent through in creating this leccer vas co
request. alL the SHSC 1:1e~bers c:o compile a lise of issues and concerns
that: meric:ed actencion o£ che APA. This list Yas then drafted, re-
vieYed, and approved by the SHSC members.
!he issues identified belov have been placed in c:~o cacegories. The
firsc encic~ed "Overall Study Approach" deals Yith those issues and
concerns vhich transcend specific studies. These concerns are act
entirely in c:he scope of the feasibility study contract: or necessarily
the sole responsibility of the ?over Auchority. Hovever, t:he decisions
c:he APA and Legislature may make vic:h respect. c:o the Susicna project: in
c:he nexc 60 days could obviac:e these concerns. The other cacegory is
entitled "S c:udy Specific Issues" and is self-explanacory.
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E:ic Yould 2 M.arch 5, 1982
The follovi~g are che overall scudy approach probleos identified:
OVERALL S111DY APPROACH
L The most: urgent and mosc imporcaoc issue is t:he relationship bet·..reen
the timing of findings from studies conducted by Acres American and ics
subcontractors and ~hen the State of Alaska will decide ~hecher co build
Susicna. The problem is chat existing laY may result: in a decision by
the scat:e as co ;;hecher the dams should be built: before the socio-
economic and environmental costs, impacts, and crade-offs are kno~.
Although the March 15, 1982, Susit:na Hydroelectric Feasibility Study ~ay
assist in determining if the dams can be built in a narro~ technical
(engineeri:lg and conscruccabilicy) sense, it cannot speak co sign:lficant
public policy questions such as:
a. is it in the best: interests of Alaskans to use their money co
build the dams?
b. vhac are the environcental and socio-economic icpacts and
crade-offs chat have co be made if it: is decided co build the dans?
In dece~ining ans~ers co such questions, there are accepted me~hods
uhich should be rigorously applied. No one uould consider building che
Susicna dams ~ithouc anYering all questions about soils stability and
eart:hquake hazards. The same level of assured kno"t.:ledge needs co be
acquired co ansver questions about environmental and socio-econo~c
effects of the dams.
this issue may be our:side the scope of the Acres conr:ract and the sole
purvieY of t:he Po~er Authority. A combined effort of the PoYer Authority
and c.he Governor's Office may be needed :o comprehensively frame the
issue and devise methods co deal ~ith them.
2. There appears t:o be a lack of necessary coordination becveen the
various study casks. Unless ex~raordinary corrective efforts are made,
it is uol.ikely chat: an integrated, relevan~. and complete environmental
assessment ~hich is accept:able to s~ate and federal agencies and to the
Federal Energy Regulacory Commission (FER.C) <Jill be produced •. This need
vas identified early by the SKSC. The Nove:ber Zl, 1980, revieY of the
Plan of Study says: "The Steering Colllll:l.itcee members believe the 'll.osc
co::lpelling need is for. a <Jell conceived process co impro~e c.he linkage
and coordination of the various studies." As an example of chis, I
:eier you to point number l bela~.
The follo~ing are studies specific issues:
SPECIFIC ISSUES
l. A coherent:. an,d coordinated Fish and Wildlife i:ti.t:i.gacicn policy and
plan needs co be established il::mediately. !t is our underst:andi:tg t:hat:,
unlike the <Jildlife t11itigation options, the fisher-ies :nitigaciot: options
Eri..c Yould J March 5, 1982
and the overall Susitna Hydroelectric Project fish and vildliie citiga-
tion policy have yet co produce an agreed u?on produce. The follo~ng
issues still require resolution: agreement on mitigation policy, agree-
men~ on the roles definition of the APA. the agencies ~t:h fish and
Yildlife authority and ~~ert:ise, the Federal £nergy Regulatory Com-
mission (F~~C). and those agencies vith land and Yater management
authority. Until these issues have been resolved, determination of the
full costs and impacts of the proposed Susit:J.a Hydroelectric project are
not possible. Failure to settle these issues Yill dramatically increase
the probab~ty of delay in action by the FERC, unnecessary confrontation
be~een the APA and government maoagement and regulatory agencies and
Litigation in the courts. Once resolut:ion of the identified issues
occurs. the FERC applicat:ion process may be the appropriate forum to
resolve specific mitigat:ion issues.
2. There is a lack of iaiorma~ion to describe the relacionshi.p bet:ueen
various stream fl~ levels and the product:ivity of fisheries and aquatic
habitat: do~stream from the proposed Devil Canyon Dam. Exhibit E of the
FE.RC application for license requires quantification of c:he ant:icipated
dovnstream impacts.
J. The fisheries studies have not been going on long enough co acquire
the comprehensive dac:a and knovledge oeedec c:o assess project impacts.
This, coupled uith inadequate instream flou s~udies. provides for a
less-than-sati.sfac'l:ory ansuer to questions on the impact of the proposed
hydroelecc:ric projec: on fishery populac:ions.
4. ~ildlife sc:udies and Yildlife mitigation appear much fur'l:her developed
than the fisheries issues described above. H~ever, there are issues
yet to be resolved in che Yildlife area. r re£er you co the February 16.
1982, letter from the Depar~me~t of Fish and Game to Rober~ Mohn of APA.
lt appears chat additional 'I.:'Ork is needed to identify realistic ::u.tJ.gation
ceasures for lost ~ildli!e habitat and on relating ~~ldlife use of an
area ~o habitat the characteristics.
5. Public revieY of the Phase I environmental reports and of most
clitigation options discussion papers is nou scheduled to occur separately
from the distribution and public revieu of the draft feasibil!ty re?ort:.
we do understand that the decision to delay for 90 days the applicat:ion
for a license co FERC (assumL,g that that is the decision from the State
of Alaska). c:he public and agencies vill be provided the.opport:unity to
revieu the detailed study results and data repqrt:s for a period of 60 days
before final agency comments on che feasibility study are due.
6. !he Fairbanks-to-Anchorage lntertie study and the Susitna feasibilic:y
study should be integrated. We suggest that the intertie assessment be
included in the Susit:na feasibility study revieY pack.age.
7. !he decision on access to the d~ sites and the policies surrounding
their use a.fter construction vill be one of the most significant i:lpacts
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E.::-ic Yould !1.arch 5, 1982
of che project:. The Yukon River co Prudhoe Bay 'daul Road bui.lc in con-
junction t.'i. ch the const::uccion of the Trans-Alaskan oil. pipeline is a
comparable situation. 1.1ere is no need to restate the cotl:l:lencs made by
the SHSC and their parent agencies co che A2A on this cac:t:er. Hoveve::-,
it is appropriate to identify eva of the majol" issues l.li.th respec!: co
the access question. First, APA' s need co begin construccion of a ·
pioneer :-oad prior to F!RC licensing of the dams raises some serious
public policy issues. Second, the decision as to the mode of access
(rai:l versus c.onvent:.ion:a.l road) may well be the determining factor for
the e."<teoc and r:ype of public. access once c.onstruct.ion is completed.
8. The socio-ec.onolUic im.pl.icacions of the availability of 1600 megavac ts
of electrical p~er in the ra.ilbelt region of .Uaska; need to be fully.
described and discussed in a public forum. It vould appear that this
amount of elec.crical energy could result in industrialization and socio-
ec.onom.ic i.mpac.cs on the same order of a~.agnicude as would petrochemical
development. Because t:he: Scace of Alaska is sponsori.ng this hydroelectric.
proposal. it is incumbent: upon t·he stace co provide and present .in a
public forum, informat:ion regarding c:he end use of che pover aod advan-
-=.ages and disadvancages of the socio-economic i.:pact.s of chis end use.
The SnSC recotrml'ends con·sideracion of an approach sil:U~ar to t:.ha.c t.Thich
t.Tas done for :he Do~-Shell petroc.h~ical proposal.
The SHSC uill be advising their respec~ive parent age~c.ies ot the
conr:ents of th.is letr.er in order co insure diac foc:~al agency cocmen::s
co t:he proposed Susitna feasibility S'tudy fully address the issues· anci
concerns decai.led above. In order r:o alleviate the proble!!ls icienci.=ied
above, the SHSC recommends the follouing~ (1) The ~~A should cake an
interdisciplinary interagency approach in identifying ~ays co il:l.prove
coorciina.cion of the environmental and socio-economic s t:udies to insure
that the scope of and the methodology used in the s::udies are acceptable
and ger:llane. This approach should be funded and st.aff ed appropriacel.y
and shoul.d have the responsibility. auchoricy ami independence to
accomplish t:h.is objective. (2) The draft instream flo..: study plan
should be updat.e.d and made publ.ic. co provide opport.unicy for agencies
and other groups to part.icipat:e. in the development of t:.he neeessary
instl"eam flov studies. (3) Compre.~ensively evaluate all pocencial and
secondary i.J::apac:s co fish and -.rildlife bach above and bela..: the Devil
Canyon and Wacana Dam sites. (4) Provide public. par::ic.ipat:ion oppor-
cuni:ies co: infer= the public of the feasibility S'tudy and c:.he socio-
economic i.cpact.s of this ?reject and co provide a.o oppor~unicy for the
publi.c t:o give comments and advice· to cl}e Power Authorit:y Board of
Directors before the state deceru.ines vhac course of ac..cion ir. should
cake on this project:.
aecause of the nar.ure of some of t.,ese sugges.t:Lons as ..,.ell as. che extent:
of discussion ve .anticipate -.rill be rettuired before .A:PA and its
Eric Yould 5 Marc~ 5, 1982
concractors fully comprehend our concerns, ~he SHSC is ?Ce?ared co ceec
~ith you, your scaff and contractors ~heoever you vish.
Sincerely,
Al Carson, Chairman
Susicna Hydroeleccric Steering Co~iccee
cc: SHSC Members
Charles Conuay, Chairman, APA
Ernesc Mueiler, Commissioner, Dept of Environmencal Conservacion
Ronald Skoog, Commissioner, Depc of Fish & Game
John Katz, Commissioner, Dept of Natural Resources
Lee ~1cAnerney, Coc::missioner, Dept of Communicy & Regional Affairs
Curtis ~cVee, State Director, Bureau of Land Manage~ent
Robert Hevey, Regional Direc::or, National Marine Fisheries
Keith M. Schreiner, Regional Director, US Fish & ~ildlife Se~•ice
Reed Scoops, Director, Division a£ Research & Developme:lc
S. Leopold
Quentin Edson, FERC
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Mr. Robert Shaw
State Historic Preservation Off1ce~
State of Alaska
Department of Natural Resources
D1v1s1on of Parks
619 Warehouse Avenue
A~chorage, AK 99501
De'ar Mr. Shaw:
May 4. 1981
P5700.11.74
. T.868
Sus1tna ~roelectr1c Project
Cultural Resources Investiqation
In response to your request during our· meeting of April 7. 1981, I am
forwarding a copy of the Sus1tna Procedures Manual for the Cultural
Resources Investigations. In addition, I have enclosed a copy of the
Cultural Resources section from our Plan of Study.
I trust this will aid in your continued review of our program. Any
specific questions on this component of our study should be referred to
t·1r. lewis M. Cutler of Terrestrial Environmental Specialists, RD Box 388,
Phoenix, NY 14135.
KY:adh
Enclosures
Yours truly,
KeJlin Young
Env1ronmenta1 Coordinator
MEMORANDUM .:..~
DEPARTm:NT OF NATURAL RESOURCES.
ro:
FROM:
ERIC YOULD
Executive Director
Alaslc.a. Pover Author! ty
JZ::
Director
State of Alaska
DIVISION OF RESEARCH AND DEVELOPM'f:aT
DATE:
FILE NO:
TElEPHONE NO:
SUBJECT:
October ll, 1982
Proposed Suaitna
lb"dro Project
The Departaent -of Batural Resources appreciates the opportunity to comment
on pmJ,ect impacts on the proposed Susitna Hydropower ProJect and to
~ecommend mitigation strategies. The depart=ent baa cooperated vith Alaska
Pover Authority (APA) on tbis proposed proJect during the last tvo years and
ret'ers the APA to es.rlier comments, specifieal.ly DBR' s testi1:10ny on April
16, 1982, to APA 'e Board. of Directors (attached). The issues listed in
DHR's testimony, vater appropriations,. instream floV reservations, and
access to the project, continue to be maJor concerns. Additional. colllllents
ar-e listed below. In some cases coccents 12\f repea.t earlier DNR collllXle.Qt.s.
As you are a.vt~.re .-the department is nov in the process of preparing a.
regional land use plan 1n cooperation vith the Ma.tanuska-8uaitna. Borough
vhich includes the ~ds surrounding the ~dro project. This plan,. vhich
vill be eoa:;pl.eted in 1983, v1U resul.t in l.a.nd use designations and l.and
management policies tor state and borough lands throughout the area.
To ~te, the planning team responsible !or developing this land use plan bas
conscious~ avoided aqy direct inTOlveaent in Susitna Hydro issues, relying .
instead on the rore detailed vork being done by other individuals vithin Dmi
s.nd DF&!G. The planning process 1s nov at a point were it makes J:IOre sense
that there be closer coordinat~on betveen the tvo projects • specirical.ly in
the tvo areas outlined be1ov.
1) The planiling team can rertev and comment on information regarding
regional, indirect impacts of the plan (e .. g. population growth.
changes in resource deJ:Ialld, etc.).
i
2) The pl.a.a can be used ns a tool to guide use of public 1s.nds to
tnitigate or contro1 secondary impacts of the proposed project.
I suggest that you designate a sta~~ per~on to coordinate these tvo
projects vith Chris Beck (Susitna Plan proJect J:IB.nager),.
As stated in DliR's recent coi:Jiiien.ts on recreation planning, \le are concerned
that recree.tiona1 facilities planned in conjunction vith the hydropover
project may be under-utilized. A related concern 1-s the high cost to the'
stu.te of Jna1nta1n.1ng potentially ove~-developed, under-used. p.1blic
recreation facilities.
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Suaitna ~dro Project -2-October ll, 1982
The DiYiaion ot Geological. o.ncl Geopb,yei.ca1 Burvq bu completed a detailed
reY1e11 or the ~oils e.nd geology components ot' the tea.aibility study. 'l'hoee
eo~ameata (a~teJued) an intended to bo int'o~ and t'o'r the eonaidera.tioa ot
APA and ita eontraetora. other geological aad ge~1ca.l eoncerna are
listed be1ov.
1) Exiat.i:ng int'ormati~ ind.icatee that gl.aciera 1n the proJoc.t arc&
at"e re'tre&tins; this and their aeaaona.l nature 'lliii;J' atteet w.te'r
ava1lab111t7•
2) 'l'he tvo l.arge bodies ot vater created by the propo•~ project ms:y
. artcct the ld.cro-cl1m&te or the area.
3) 'rbe dame, by bloeking sedil:leat traval, atq increase erosion
downstream.
4) 'l'bere ma:r be a aubatant1&l. change 111 the are& between the tvo da.ma
over a periOd ot time 111 reapoa•«t to changes in nov ng~, the
allliOUJl't ot' sediment introduced an4 tr&Qaporte4, and the b;ydraul.1e
geometr:T ot the valle:r (gra41eat. '¥14th. depth• d1ach&rge, and
veloci-ey-ot the dl&lmel).
'rbe department request• that attr t~ f'elle4 1D the proJeet ba lll&de
e.vailable to the p.tbllc aad tb&t commereia.l quantities ot torest products be
-.de a:n.il.a.bl.e to the COJIIBierelal. eollli!Wl1:ey-tor barTeat a.D4 utillz:ation.
At~hmenta
cet Chris Beck, DRD
Leila Vi.ae., D.RD
Al Carsoil, DRD
RS.t LV 1 ll.D
Dear Ill:
Enclosed for your review are,the proposed
project study plans in the disciplines of
birds, furbearers, and non-game mammals.
submitted directly to the Power Authority
April 2, 1982
Susitna Hydroelectric Project
Proposal Phase II Wildlife/
Vegetation Studies
Pha.se II Susitna Hydroelectric
vegetation, vegetation/habitat,
Studies for big game will be
by AOF&G.
The enclosed study plans, as well as the big game study plans, were devel-
oped based on Phase I study results, input from the Fish and Wildlife Miti-
gation Review Group on March 10, 1982, and the discussions of the Wildlife
Core Group on March 11 -12, 1982. Please review these studies to determine
if they accurately reflect the results of our meetings. Please note bird
and small mammal studies in the Upper Basin have been added.
Because of the necessity to begin spring studies, please review these items
as soon as possible and notify me in writing of your agreement or of any
discrepancies. These study plans will then be forwarded to the Power
Authority for their consideration. Thank you.
MG:jk
Enclosures
cc: Ed Reed
E. Yould
Sincerely,
Michael Grubb
Senior Scientist
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Preceeding Letter Sent To:
Dr. A.W.F. Banfield
Rangifer Associates, Ltd.
37 Yates Street
St. Catherines, Ontario L2R 5R3
Canada
Dr. Richard Taber
2024 23rd Avenue, East
Seattle, WA 98112
Dr. Philip Gipson
Alaska Cooperative Wildlife
Research Unit
209 Fairbanks Building
University of Alaska
Fairbanks, AK 99701
Dr. Jay McKendrick
Agriculatural Experiment
Station
Box AE
Palmer, AK 99645
Dr. Brina Kessel
Box 80211
College, AK 99708
Mr. Karl Schneider
Division of Game
Alaska Department of Fish and
Game
333 Raspberry Road
Anchorage, AK 99502
DEPARTJUENT OF FISII AND GAltiE
April 27, 1982
Michael Grubb
The Liberty Bank Bldg.,
Main at Court
Buffalo, New York 14202
Dear Mike;
JAYS. HAMMOND. GOVERNOR
333 RASPBERRY ROAD
ANCHORAGE, ALASKA 99502
We had an informal meeting in Juneau to discuss the best approach for a
habitat based analysis of the effects of the Susitna Hydroelectric Project
on big game. In addition to members of my staff, the meeting was attended
by Drs. Richard Taber and Ken Raedeke from the University of Washington
and Wayne Reglin, who recently transferred from USFWS to ADF&G. Jay
HcKendrick attended the first part of the meeting.
l!y main objective for the meeting was to identify major components of a
study approach for budgeting purposes. I feel we need to give the Alaska
Power Authority a ball park estimate of cost as soon as possible, even
though details of design will have to be worked out later.
Everyone would like some quantification of the "value" of lost habitat.
This would facilitate measurement of impacts and comparisons of mitigation
options. Most of us associated with big game studies favor expressing
value in terms of carrying capacity rather than some sort of arbitrary
index. We can design a system to produce either, but both are attempts
to express complicated dynamic processes in simple static terms. There
is a very real danger that we may oversimplify things to the point where
serious errors in judgement will be made. We should not waste time and
money on a study approach that will yield results we can't trust.
We used Dr. Taber's Toward~ Program of Habitat Analysis as a basis of
our discussion. This program focuses on cow moose in the upstream area
during late winter and spring. This approach has considerable merit as
it focuses on critical time periods and segments of the population. How-
ever, there are some basic problems that may limit the effectiveness of
this and other similar approaches.
We believe that the proposed impoundment areas may be critical for moose
for only a few weeks each year and environmental conditions may greatly
influence the area's importance from year to year. Even if we obtain
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Michael Grubb (2) April 27, 1982
accurate estimates of forage production ~e ~ill have trouble interpreting
the data. If ~e estimate 1000 moose days of forage we need to know if it
is used by 10 moose for 100 days or 100 moose for 10 days. The latter
situation would be quite difficult to accurately assess. In spring, timing
of availabilty might be more important than quantity produced. During
severe winters availability might be more a function of snow depths than
bro~se production.
Dr. Taber's and similar approaches are likely to underestimate the value
of the habitat to be lost unless the actual conditions we wish to evalu-
ate oc.cur during the study and the intensity of sampling is adequate to
quantitatively measure habitat selectivity at that time.
We.concluded that our knowledge of the mechanisms determining moose
carrying capacity in the impoundments is inadequate and it may be beyond
our ability to design a study approach that will provide nice neat, yet
reliable, estimates of value of habitat that will be innundated.
We concluded that it is more important to gain a better understanding of
the mechanisms of impact. Ho~ well we can quantify them will depend on
the nature of these mechanisms. Specifically we are recommending expanded
studies to determine what moose are using during late winter and spring
and determine the availability of those habitat characteristics inside
and outside the areas to be impacted. Phenology, particularly timing of
snow melt and emergence of vegetation are important concerns. The key
question is whether higher quality food becomes available significantly
sooner in areas to be impacted, thereby improving a moose's ability to
recover more co;~pletely from the nutritional stress of winter before
calving.
We have not attempted to design this study but it would probably consist
of determining moose food habit£: through fecal analysis and by tracking
moose and observing plant use. Snow characteristics and emergence of
plant species used by moose would be correlated with time, elevation,
slope, aspect, vegetation type etc. We should be able to address spring
use of impoundments by bears at the same time~
This study should be the primary responsibility of the plant ecology groups
but I feel it is important that I designate an individual from the big game
studies to work with the plant people to ensure a coordinated effort. I
believe we should plan on two field seasons. If Jay McKendrick can get in
the field immediately he might be able to learn enough this year to design
a sampling procedure for next year. However, it may already be to late.
I found the plant ecology plans of study difficult to evaluate because of
a lack of detail. We can discuss this at our meeting during the week of
May 17.
Sincerely,
/~ '
Karl Schneider
Reser.rch Coordinator
cc: Ed Reed -TES
Jk. Gary Stackhouse
U.S. Fish and Wildlife Service
1011 East Tudor Road
Anchorage, AK 99503
Dear Gary:
April 27, 1982
P5700.11.71
T .1685
Sus,tna Hydroelectric Project
.Fish arid Wildlife Mitigation
Review Group Meeting
You are invited to attend the next meeting of the Susitna Hydroelectric
Ffsh and Wildlife Mitigation Review Group to be held at 8:30a.m., May 17,
in Room C121 at the Federal Building, 6th and C Street. Anchorage. The
purpose of thfs meeting ~11 be to discuss the Draft Wildlife Mitigation
Options Paper mailed to you on Apr1'1 21, 1982. Please review this document
prfor to this meeting.
The issue of quantification of habitat loss will be discussed at a work-
shop on May 18th. This workshop w111 be attended by mambers of the Susitna
Hydroelectric Project Wildlife Core Group, ADF&G, and USFWS. I have asked
Lenny Carin to determine who the USFWS attendees will be and ask you to
contact him for further details. The objective of the meeting on the 18th
will be to reach concensus on:
1. The objectives of the habitat evaluation system we will develop.
2. A general description of the system.
In keeping with past procedures, the Susitna Wildlife Core Group will then
develop the technical specifics of the system.
I am enclosing a Phase I Habitat Evaluation Report written by TES which
applies a modified Konkel et al system (as discussed in the Environmental
Analysis of Alternative Access Plans Report) to the impoundment and
surrounding areas. I ~11, hopefully, also forward to you before the
meeting a general system developed by Dr. Taber which may be specifically
applied to moose.
It is mY intention to discuss these two systems, as well as HEP, at the
workshop. I am asking all attendees to come with an open'mind so that we
may have a constructive session and work towards the common goal of
obtaining satisfactory mitigation for wildlife/vegetation impacts
associated with the Susitna Project.
-
-
-
-
-
Mr. Ga~ Stackhouse u.s. Fish and W11dl1fe Service
I look forward to your attendance on the 17th.
~tG:ccv
Enclosure
cc: D. Wozniak -APA
E. Reed -TES
Sincerely.
Micllael Grubb
Senior Scientist
&prfl Z7. 1982
- 2
Mr. lenny Corin
U.S. Fish and Wildlife Service
733 West Fourth Avenue
Suite 101
Anchorage, AK 99501
Dear Lenny:
Apr11 27, 1982
P5700.11.71
T .1686
Susitna Hydroelectric Project
Fish and Wildlife Mitigation
Review Group Meeting
You are invited to attend the next meeting of the Susitna Hydroelectric
Fish and Wildlife Mitigation Review Group to be held at 8:30 a.m., May 17th,
in Room C121 at the Federal Building, 6th and C Street, Anchorage. The
purpose of this meeting w111 be to discuss the Draft Wildlife Mitigation
Options Paper mailed to you on April 21, 1982.
The issue of quantification of habitat loss will be discussed at a \~rk
shop on May 1Bth. This workshop will be attended by members of the
Susitna Hydroelectric Project Wildlife Core Group, including Karl Schneider,
who may bring other representatives of AOF&G with him. In order to keep
the \'lorkshop size to a reasonable nUMber, I have asked Karl to bring no
more than two other people. I am inviting you to attend this workshop on
the 18th and, if you desire, bring two other US~IS representatives with
you. We suggest and would appreciate if Mr. Greg Konkel could attend.
This meeting will be held in Room Cl09.
The objectives of the meeting on the 18th will be to reach concensus on:
1. The objectives of the habitat evaluation system we will develop.
2. A general approach to developing this syttem.
In keeping with past practice, the Core Group will then develop the
technical specifics of the system or systems.
I am enclosing a Phase I Habitat Evaluation Report written by TES which
applies a modified Konkel el al system (as discussed 1n the Environmental
Analysis of Alternative Access Plans Report) to the impoundment and
surrounding areas. I will, hopefullyt also forward to you before the
meeting a general system developed by Dr. Taber which may be specifically
applied to moose.
It is my intention to discuss these two systems, as well as HEP, at the
workshop. I am asking all attendees to come with an open mind so that we
-
-
-
-
-
·-
-
Mil-Lenny Corin
U.S. Ffsh and Wildlife Service
Aprfl 27, 1932
- 2
m~ have a constructive session and work towards the common goal of
obtaining satisfactory mitigation for w11d11fe/vegetat1on impacts
associated with the Susitne Project.
I look fowward to your attendance on the 17th and 18th.
MG:ccv
Enclosure
cc: D. Wozniak -APA
E. Reed -TES
Sincerely,
Michael Grubb
Senior Scfentfst
Mr. Karl Schneider
Alaska Department of Fish and Game
333 Raspberry Road
Anchorage. AK 99502
Dear Karl:
April 28. 1982
P5700.11.70
T .1687
Susi.tna Hydroelectric Project
Mitigation Workshop
As discussed. the workshop to discuss a habitat evaluation JYStem 1s
scheduled forM~ 18th. at 8:30a.m., in room Cl09 of the Fedeaal Building,
6th and C Street, Anchorage. The workshop will be attended by members of
the Susitna Wildlife Core Group and, for the first day. the U.S. Fish and
Wildlife Service and ADF&G employees whom you select. The purpose of this
workshop wfll be to reach consensus on:
1. Objectives of the habitat evaluation system.
2. A general approach to this system.
Following this meeting, the Core Group will develop the technical details
of the systan.
I am enclosing a Phase I Habitat Evaluation Report prepared by TES which
applies a modified Konkel et al system to the impoundment zone and
surrounding areas. I wfll. hopefully, also forward to you prior to the
meeting a general system developed by Dr. Taber which m~ be specifically
applied to moose.
It fs nw intention to discuss these two systems. as well as HEP, at the
workshop. I am asking all attendees to come with an open mind so that we
may have a constructive session and works towards the common goal of
obtaining satisfactory mitigation for wildlife/vegetation impacts associated
with the Susitna Project. The Core Group will continue meeting on the 19th.
20th, and 21st (if necessary); please be available ff at all possible.
Thank you for your help.
MG:ccv
Enclosure
Sincerely,
~1fchael Grubb
Senior Scfentiat
-
.-
-
Susi _.t::::: tiyoroelectric Project
Habi~ Evaluation Meeting
Date: 'May il9, 1982
Atterr~: See Attached List
Held ~ federal Building, Anchorage
May 25, l982
The pwT?DSe ·Of the meeting was to proceed with planning for habitat eval-
uatiorr, schemes.
Karl Sch:neicfer explained more fully the Delphi approach. It involves a
group nf exp·erts assigning values to parcels of land with the value repre':'"
sentir1~ their opinion on the quality of the habitat for a particular species.
This fs a more straight-forward and quicker process than the formal HEP
proce~s. A s·imilar exercise is conducted for mitigation lands. Karl
Schnef::ler, Phil Gipson, and Brian Kessel will provide names to LGL on who
they feel should be on the various panels.
The cc·~cept of digitizing data was again discussed. This would be done by
digitizing the vegetation mapping and utilizing ADF&G digitized moose and
bear c~llar locations and then correlating the results. Karl Schneider
and Steve Fancy will meet with USFWS to discuss the practicality of this
approcch.
An alternative method would be to use a cell approach. The study area
would be divided by a grid system, with each cell being approximately 40
acres in size. The slope, elevation, grid, aspect, cover type and number
of moose and bear sightings would be calculated for each grid and correla-
tions developed.
Karl Schneider, Dr. Taber and Jay have suggested a phenology study to better
understand impact mechanism and to determine what foods and habitat charac-
teristics moose are using during late winter and spring and determine the
availability of those habitat characteristics inside and outside the area
to be impacted. This study would involve determining moose food habits
(through fecal analysis), measuring snow characteristics and emergence of
vegetation and correlating it with elevation, slope and aspect. McKendrick
is proceeding to set up transects in the field and equipment. He and Karl
will be preparing a scope of work and budget for this. The study will be
repeated next spring. Seven transects in the Watana area and two in the
Devil Canyon area will be established, with three points along each transect.
Vegetation mapping may have to be expanded at the 111 = 1 mile scale because
current mapping does not include the home range of all moose in the area.
Karl will develop a winter contingency budget to study moose distribution
in case of a severe winter.
Three impact zones need to be delineated; these are the primary impact zone,
secondary or temporary impact zone and disturbance impact zone. The with
and without project scenario must include the project area assuming no change
Page 2
and also assuming what reasonable land use developments (mining, etc.} may
occur. The future land items should be expressed to correlate with pro-
posed dates for present study activities, construction, fillinq, operation.
The browse studies to be conducted in the upper basin will begin in mid-
July and end in mid-September.
The BLM burn vegetation study will include base mapping at a 1:24,000 scale.
Vegetation species list, composition and annual production studies will
commence in July. ADF&G will plot baseline moose sighting information on
the vegetation maps.
The Jay Creek lick study by McKendrick will include soil analysis inside
and outside the lick. Acres should attempt to determine what erosion
patterns may occur.
The species list of May 18 was studied and revised. Moose, black bear and
brown bear were included as big game species as they best fit the estab-
lished criteria. The other big game species did not. Birds chosen were
the yellow-winged warbler, tree sparrow, golden eagle, and furbearers, the
marten and beaver.
MMG:dlp
-
-
Jay McKendrick
Ph'Jl Gipson
Brian Kessel
Kemneth Raedeke
Richard Fleming
Michael Grubb
Richard Taber
Karl Schneider
Joe McMullen
Ed Reed
Dot: <Helm
ATTENDEES
REPRESENTING
University of Alaska
University of Alaska
University of Alaska Museum
University of Washington
Alaska Power Authority
Acres American
University of Washington
Alaska Dept. of Fish & Game
TES
TES
University of Alaska
Susitna Hydroelectric Project
Wildlife Mitigation Meeting
Date: May 18, 1982
Attendees: See Attached List
Held at Federal Building, Anchorage
May 25, 1982
The purpose of this meeting was to discuss general objectives and general
approach for a habitat evaluation system.
A list of objectives for the system was developed (~ttachment 1). Ann
Rappoport of USFWS presented an approach based on HEP. After much dis-
cussion it was decided the approach taken would be to:
1. Develop criteria for selection of species for which habitat
evaluation would be conducted.
2. Develop species list.
3. Develop habitat evaluation procedures for each species which will
·include field work or a Delphi session or both.
4. Test the procedures on a pilot program this summer, on small areas
in and outside of impact area.
Existing data would be utilized whenever possible. The habitat evaluation
procedures would begin with the U of A subs and K. Schneider and LGL con-
ducting Delphi sessions, reviewing the HEP models and determining what
parameters and criteria should be utilized. Documentation was stressed.
The Terror Lake situation was discussed as an example. The technical as-
pects of this study for mitigation involved three afternoon sessions and
2-3 months of effort to obtain quantitative comparison of land for mitiga-
tion.
Official HEP models were discussed. Mucb concern'was expressed about their
accuracy, applicability, validity and assumptions which must be used in
their application. It was decided the TES report on habitat evaluation
would not be suitable for mitigation purposes.
Digitizing of data was discussed. Because of the large amount of time re-
quired, it was felt it may not be cost effective for this project. Deci-
sion would be based on development of habitat procedures. Available sources
of information incliJde:
1. Feasibility Report and Phase I Final Report.
2. TES/U of A prepared vegetative cover map, which are 1:24,000 in
impoundment zone.
3. Digital Terrain model from USGS.
4. USFS-SCS vegetation data (digitized?) for Susitna Basin.
5. DNR land use plan for Talkeetna sub-basin and Willow sub-basin
The criteria for species selection were developed (attachment 2) and the
species list (attachment 3). The species list would be refined following
closer examination of the criteria. It was decided indicator bird species
were more appropriate than guilds.
MMG:dlp
ATTACHMENT 1
Objectives of Habitat Evaluation System
1. Integrate habitat characteristics with animal use
-2. Quantify value of habitat 1 ost
3. Utilize existing data, if possible
4. Determine mechanisms affecting wildlife
5. Quantify differential habitat values
6. Determine appropriate mitigation
-
....
-
ATTACHMENT 2
Criteria for Selecting Wildlife Species
1. Consumptive use
2. Non-consumptive use
3. Ecological importance
4. Vulnerability to project disturbance
5. Responsiveness to mitigation
6. Species susceptible to habitat loss
7. Data availability and predictability of response
-
,, .... ATTACHMENT 3
Species for Consideration -
1. Moose 8. Wilson's warbler
2. Black bear 9. Tree or Savannah sparrow
I '"" 3. Brown bear 10. Dipper
4. Beaver 11. Golden Eagle
5. Red fox 12. Spruce grouse
6. Pine Marten 13. Meadow vole
7. Yellow rumped warbler 14. Mink
,_
-
-
Michael Grubb
Kenneth J. Raedeke
Richard Fleming
Brina Kessel
Karl Schneider
Carl Yamagawa
Gary Stackhouse
Steve Fancy
PhilipS. Gipson
Joe tkMu 11 en
Dot Helm
Jay N. McKendrick
Ed Reed
Leonard P. Corin
Greg Konke1
Ann Rappoport
Dick Taber
ATTENDEES
May 18, 1982
Representing
Acres American
;
University of Washington
APA
University of Alaska Museum
ADF&G
ADF&G
USFWS
LGL Alaska
AK. Coop. Wildlife Res. Unit
TES
University of Alaska
University of Alaska
TES
USFWS
USFWS
USFWS
University of Washington
J 8 ~ _ l't C. /'{ cu .• u.J
,_ . D6t-1-/dh, ·. --.fl7. A. /llcAtL~ .
~ E/~ed _
~~o.~~ 9 Gt--;'-
. __ --Grrx.:J ~o11k~ L
"" ~1 ~ ~PI'tr'<±
~ ltA.-1~
-
-~/lA.
7.£3-3
\A~~~'S. -·-·· ---....
v{<; Ft..vS
l) .s l?t.~ j
~bW~--~
Aleeke ReMerch Auocllltea, Inc.
17 July 1982
Michael Grubb
Acres American, Inc.
The Liberty Bank Bldg.
Main at Court
Buffalo, NY 1420
Dear Michael:
P.O. Box 80607, Fairbanks, Ala5ka 99708 (9071479-6519/479-2669
Telex 35 · 355
LGL Alaska recently became involved with the terrestrial environmental
studies being conducted for the Susitna Hydroelectric Project. We are
responsible for assessing the impacts of the project on vegetation and
wildlife, using data collected by the Alaska Department of Fish and Game
and our University of Alaska subcontractors. LGL is also responsible
for developing a plan to mitigate any adverse impacts on terrestrial
wildlife and vegetation.
We will use systems analysis as a means for organizing the terrestrial
environmental program. The attached document explains the reasons for
using the approach and the steps involved in the process. We would like
to invite you to a one-week workshop scheduled for 23-27 August 1982, to
be held in the Ketchikan Room of the Anchorage Holiday Inn, beginning at
8:30 AM on the 23rd. The workshop will be intensively focused and will
require long days from all. We have reserved a room for you at the Holiday Inn
for Sunday through Friday nights, but you will need to make your own
travel arrangements. Following the initial workshop, the mo.del will be
refined during one or two technical meetings (lasting 1 or 2 days each)
with each subgroup in the fall, and during future modeling workshops to
be held once or twice each year.
LGL' s Program Manager is Dr. Robin Sener, who is located at our
Anchorage office (274-5725). Dr. Joe Truett of LGL will be the workshop
facilitator. The modeling team will be composed of modelers from LGL,
Environmental and Social Systems Analysts (ESSA), and the Western Energy
Land Use Team (USFWS) of Boulder, Colorado.
We will be contacting you in person or by telephone to provide you with
additional details on the workshop. We look forward to having you
participate in the project, and hope you will find the approach to be a
useful and realistic means for impact quantification and mitigation plan
development. Please feel free to call me if you have any questions
about the workshop.
Sincerely,
Robin Sener
Program Manager
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SUSITNA HYDROELECTRIC PROJECT
SU1ULATION t«<DELING WORKSHOP
FOR
TERRESTRIAL WILDLIFE AND HABITAT
Anchorage, Alaska August 23-27, 1982
WORKSHOP OBJECTIVES
1. Develop a preliminary simulation model of hydrology, vegetation,
and wildlife interactions in the Susitna Basin.
--and through future refinements --
2. Use the model to ,help predict and quantify project impacts to
wildlife and habitat.
3. Use the model to help assess the probable effectiveness of
proposed mitigation alternatives.
WORKSHOP AGENDA
Monday, August 23: 8:30AM -5:00 PM
INTRODUCTION
BOUNDING THE MODEL o Project Actions
o Indicators
o Spatial Boundaries
o Temporal Boundaries
LOOKING OUTWARD
1
Tuesday, August 24: 8:30 AM -5:00 PM
LOOKING OUTWARD (Continued)
SUB-MODEL DEVELOPMENT
7:30 -9:30 PM: DISCUSSION OF EVALUATION PROCEDURES
Wednesday, August 25: 8: 30 AM -5:00 Pr-1
SUB-MODEL DEVELOPMENT (Continued)
Thursday, August 26: 8:30 AM -5:00 PM
PRESENTATION OF SUB-MODELS
DEVELOPMENT OF HYPOTHETICAL MITIGATION STRATEGIES
Friday, August 26: 8:30 AM -5:00 PM
GAMING OF THE MODEL
FUTURE DIRECTIONS (Discussion)
2
-
Robert Mohn
Dave Wozniak
Eric Yould
Richard Fleming
George Gleason
* Bob Weeden
* Keith Bayha
Gary Stackhouse
Lenny Carin
Ann Rappoport
Al Carson
Reed Stoops
Marjorie Willits
Keith Quintavell
*Carl Yanagawa
Karl Schneider
Ron Modafferi
Sterling Miller
Warren Ballard
Wayne Regelin
Tom Trent
Bob Martin
Bob Lamke
Larry Wright
Brad Smith
Bill Lawrence
Bill Riley
John "Rego
Mike Scott
Jay McKendrick
Erina Kessel
Phil Gipson
Ed Murphy
John Hayden
Mike Grubb
Bob Butera
* Bruce Apple
Dave Cline
Roland Shanks
TERRESTRIAL ENVIRONMENTAL WORKSHOP
Invited Participants
Alaska Power Authority
Alaska Power Authority
Alaska Power Authority
Alaska Power Authority
Alaska Power Authority
Alaska Power Authority/University of Alaska
U.S. Fish and Wildlife Service
U.S. Fish and Wildlife S~rvice
U.S. Fish and Wildlife Service
U.S. Fish and Wildlife Service
Alaska Department of Natural Resources
Alaska Department of Natural Resources
Alaska Department of Natural Resources
Alaska Department of Natural Resources
Alaska Department of Fish and Game
Alaska Department of Fish and Game
Alaska Department of Fish and Game
Alaska Department of Fish and Game
Alaska Department of Fish and Game
Alaska Department of Fish and Game
Alaska Department of Fish and Game
Alaska Department of Environmental Conservation
U.S. Geological Survey
National Park Service
National Marine Fisheries Service
Environmental Protection Agency
Environmental Protection Agency
Bureau of Land Management
Bureau of Land Management
University of Alaska
University of Alaska
University of Alaska
University of Alaska
Acres American
Acres American
R&M Consultants
National ~ildlife Federation
National Audubon Society
Cook Inlet Region, Inc.
*will not be able to attend
SUSITNA HYDROELECTRIC PROJECT
TERRESTRIAL ENVIRONMENTAL WORKSHOP
23-27 August 1982
INTRODUCTION
The technical feasibility, economic viability, and environmental
impacts of a hydroelectric development in the Susitna River Basin are
being studied by Acres American, Inc. (Acres) on behalf of the Alaska
Power Authority. As part of these studie~, Acres recently contracted
LGL Alaska Research Associates, Inc. (LGL) to coordinate the
terrestrial environmental studies being performed by the Alaska
Department of Fish and Game and, as subcpntractors to LGL, several
University of Alaska research groups. LGL is responsible for further
quantifying the potential impacts of the project on terrestrial wildlife
and vegetation, and for developing a plan to mitigate adverse impacts
on the terrestrial environment. The impact assessment and mitigation
plan will be included as part of a license application to the Federal
Energy Regulatory Commission (FERC) scheduled for the first quarter
of 1983.
The quantification of impacts, mitigation planning, and design of
future research is being organized using a computer simulation
modelling approach. Through a series of workshops attended by
researchers, resource managers, and policy-makers, a computer model
is being developed and refined. This model will assist project
personnel in identifying impacts on terrestrial wildlife and vegetation
and in evaluating different mitigation measures such as habitat
enhancement and the designation of replacement lands to be managed as
wildlife habitat. The simulation modelling approach is being used for
the following reasons:
1. It provides a means to incorporate and coordinate the
professional judgments of scientists, resource managers,
and policy-makers. Mitigation planning will include many
subjective evaluations, and therefore all parties must
-
maintain continuing
program.
communication throughout the
2. It utilizes existing data to focus future research in areas
that are decided by the workshop participants to be the
most important. The approach will also insure that the
data are collected in the proper units, sampling schemes,
and time-frames to promote integration of data from the
different disciplines (e.g. , hydrology, furbearers,
vegetation).
3. It allows great flexibility. · The selected indicators
{environmental items of interest) can include population
attributes (e.g. , cha,nges in the number of beavers with
and without the project, and with different mitigation
options); habitat units or important descriptive variables
(e.g., amount of browse available in late winter); or any
number of alternative indicators as selected by the
workshop participants. Data on habitat, predation,
weather, and other biophysical system components is
incorporated into the models as needed.
Eventually, ·the model will represent the best available
understanding of the biophysical system, and as such will provide an
'!ecological laboratoryn for helping to evaluate mitigation options.
The mitigation plan will be developed in two steps, an immediate
effort based on existing. data, and a longer-term effort that will apply
data yet to be gathered. Some mitigation measures, such as controlling
dust along roads, leaving clumps of trees along the reservoir margin
for eagle nesting, minimizing aircraft disturbance, and locating
recreation facilities away from critical wildlife areas, are rather easily
defined and agreed to, and these measures will be developed prior to
submittal of the FERC application to allow adequate time for
incorporation into project design and the application. It is recognized,
however, that final agreement on some mitigation measures such as
habitat enhancement or compensation lands may require several more
years of research and discussion, and that the mitigation plan must be
flexible to allow changes necessitated by information from long-term
monitoring studies. Thus the final comprehensive mitigation plan will
not be. complete at the time of license application submittal, but the
modelling workshops provide a framework for development of the final
plan by increasing communication between scientists and policy-makers.
WORKSHOP ACTIVITIES
The intitial simulation model was constructed during the one-week
workshop held in Anchorage 23-27 August. 1982. The participants at
the workshop are listed in Table 1. The workshop facilitators were
members of LGL Alaska (Fairbanks and Anchorage), ESSA Environmental
and Social Systems Analysts Ltd. (Vancouver, Canada), and U.S. Fish
and Wildlife Service (USFWS) personnel from the Western Energy and
Land Use Team (WELUT) office in Fort Collins, Colorado.
The main objective of the workshop was to initiate development of
a dynamic simulation model of the hydrology/wildlife/vegetation system
in the Susitna Basin. The participants provided the knowledge of the
system; the facilitators translated that knowledge first in to a conceptual
model and then into computer code.
Bounding
On the first day of the workshop, the bounds of the model were
defined. The first step in this exercise involved defining all the
actions to which we wanted the model to respond. In the context of
the model, the actions were the various activities associated with
construction and operation of the impoundments and the current
collection of mitigation activities (Table 2).
The next step in the bounding exercise was the identification of
the key indicators (environmental attributes of interest such as moose
numbers, habitat quality, etc.) for which the model must be able to
generate values over time. The predicted changes in these indicators
are used to help determine the impacts of an action, and in turn,
evaluate the quantity, quality and timing of appropriate mitigation
-
-
Table 1. Participants in Susitna Terrestrial Modelling Workshop, 23-27
September 1982.
NAME
Tom Arminski
Greg Auble
Warren Ballard
Bruce Bedard
AFFILIATION
Alaska Department of
Fish and Game
USFWS -WELUT
Alaska Department of
Fish and Gam~
ADDRESS
333 Raspberry Road
Anchorage, AK 99502
2625 Redwing Road
Fort Collins, CO 80526
P.O. Box 47
Glennallen, AK 99588
Alaska Power Authority 334 -5th Avenue
Anchorage, AK 99501
Steve Bredthauer R&M Consultants P.O. Box 6087
5025 Cordova Street
Anchorage, AK 99503
Leonard Corin USFWS 605 West 4th, #G-81
Anchorage, AK 99501
Ike Ellison USFWS ~ WELUT 2625 Redwing Road
John Ernst
Bob "Everitt
Steve Fancy
Richard Fleming
Bill Gazey
Philip Gipson
LGL
ESSA Ltd.
LGL
Fort Collins, CO 80526
1577 "C" Street
Anchorage, AK 99501
678 West Broadway
Vancouver, B.C.
P .0. Box 80607
Fairbanks, AK 99708
Alaska Power Authority 334 -5th Avenue
Anchorage, AK 99501
LGL 1410 Cavitt Street
Bryan, TX 77840
Alaska Cooperative University of Alaska
Wildlife Research Unit Fairbanks, AK 99701
Table 1 (continued)
NAME
Michael Grubb
John Hayden
Dot Helm
Brina Kessel
Sterling Miller
Suzanne Miller
Carl Neufelder
Wayne Regelin
Butch Roelle
David Roseneau
Karl Schneider
Robin Sener
Nicholas Sonntag
Robert Starling
AFFILIATION
Acres American
Acres American
University of Alaska
Agricultural Experi-
ment Station
University of Alaska
Museum
Alaska Department of
Fish and Game
Alaska Department of
Fish and Game
Bureau of Land
Management
Alaska Department of
Fish and Game
USFWS -WELUT
LGL
Alaska Department of
Fish and Game
LGL
ESSA Ltd.
NORTEC
ADDRESS
900 Liberty Bank Building
Buffalo, NY 14202
1577 "C" Street
Anchorage, AK 99501
P.O. Box AE
Palmer, AK 99645
P.O. Box 80211
Fairbanks, AK 99708
333 Raspberry Road
Anchorage, AK 99502
333 Raspberry Road
Anchorage, AK 99502
4700 East 72nd Avenue
Anchorage, AK 99501
1300 College Road
Fairbanks, AK 99701
2625 Redwing Road
Fort Collins, CO 8052{)
P.O. Box 80607
Fairbanks, AK 99708
333 Raspberry Road
Anchorage. AK 99502
1577 "C" Street
Anchorage, AK 99501
678 West Broadway
Vancouver, B.C.
750 West 2nd Avenue, #100
Anchorage, AK 99501
-
~-
Table 1 (continued)
NAME
Bill Steigers
Thomas Trent
Joe Truett
Larry Underwood
Jack Whitman
Marjorie Willits
AFFILIATION
University of Alaska
Agricultural Experi-
ment Station
Alaska Department of
Fish and Game,
SU Hydro Aquatic
LGL
AEIDC
Alaska Department of
Fish and Game
Alaska Department of
Natural Resources
ADDRESS
P.O. Box AE
Palmer, AK 99645
2207 Spenard Road
Anchorage, AK 99503
P.O. Box 1745
Grand Junction, CO 81502
707 "A" Street
Anchorage, AK 99501
P.O. Box 47
Glennallen, AK 99588
555 Cordova Street
Anchorage, AK 99510
Table 2. Actions identified at Sus tina Terrestrial Modelling Workshop,
23-27 August 1982. Exactly how these are implemented in the
model will be described in a later report.
I. Reservoirs
a. Construction
• road building
• borrow pits
• transmission lines
• camp sites
• village sites
• temporary diversions
• mining of river bed
• reservoir clearing
• disposal of spoil
.. construction of air strip
• aircraft use
• staging areas
b. Operation
• operating rule curves
II. Recreation/ Access
III. General
• reservoir recreational development (access and f£cilities
• recreational use (backbacking, hunting, fishing)
• increased traffic on existing roads/railroads
• timber harvest
• changes in land use patterns (mining, oil and gas
development)
• increased population in surrounding communities
IV. Mitigation
• habitat enhancement
controlled burn
fire protection .
vegetation crushing
• flow regulation for fish· and wildlife
• control of access
• hunting/fishing regulation
• scheduling of construction activities
• siting of roads
• reclamation/revegetation
actions. The indicators identified at the workshop are shown in
Table 3.
After establishing the actions and indicators, the next step was
the definition of the spatial and temporal bounds of the model.
Spatially the area was divided at Devil Canyon into the upstream
portion and downstream portion of the Susitna River (Figure 1).
The upstream area included all of the upper Susitna Basin and the
" Prairie Creek-Stephan Lakes area. Within the upstream area the Watana
and Devil Canyon impoundment areas were considered separately.
The region downstream of Devil Canyon was separated into two
units --an area on each side of the river, paralleling it and extending
away from the river the estimated maximum diameter of a moose's home
range. Currently the area considered by the model extends as far
downstream as Talkeetna. Because the effects of the project
downstream of Talkeetna will be tempered by the contributions of the
Chulitna and Talkeetna rivers and other tributaries, hydrological and
vegetation data south of that confluence have not been collected in as
much detail as north of Talkeetna.
Within both upstream and downstream areas, the flood plain and
upland habitats were considered separately, such that a floodplain area
was defined within each of the four major spatial divisions. Each
floodplain and non-floodplain area was further subdivided into
vegetation types, of which there are fourteen in the project area
(Table 4).
The chosen time step of the model was annual, although each
subsystem had the option of developing time dynamics on a shorter
scale if appropriate. The time horizon for the model runs was set at 70
to 80 years.
The final step in bounding the model, the 11 looking-outward"
exercise, involved first dividing the system as defined up to this point
(i.e., the actions, indicators, space and time) into four disciplinary
subsystems. The subsystems were:
Table 3. Indicators identified at Susitna Terrestrial Modelling
Workshop, 23-27 August 1982.
Hydrology
• instream flows
Vegetation
• hectares of selected vegetation types
Wildlife
• population levels of: moose
black bear
brown bear
sheep
wolves
rap tors
caribou
wolverine
small mammals
selected birds
• carrying capacity of habitat for the above populations
• species diversity of birds
• numbers of animals harvested by hunters
"hunter success
• habitat quality
Recreation
• number of user days
• non-consumptive uses of wild)ife
J
I
Cltl/itna I
/
· Rlv•r'f'...
,/
/
,.. .... ..,.
] -~ ]
I
(
I I
I I --· L..--... ---,-' ,. I I .
I
/ . , __ _
I
WILLOW
..... , ....... __ .... ~ -
MILES
o'F=~· ~1=0~~~20
0 10 20 30
KILOMETERS
I
Figure 1:· Suggested boundaries for study area and subareas for simulation modeling
purposes.
l
,.
Table 4. The vegetation types found on the Susitna Hydro Project
Area.
Conifer forest
•woodland
•open
Deciduous and Mixed Forest
Tundra
Tall shrub -alder
Medium Shrub
Low shrub
•birch
•willow
•mixed
Unvegetated
•water
•rock/ snow /ice
Disturbed
•temporary
•permanent
Pioneer
-
Hydrology I Development I Land Use I Recreation
Vegetation
FurbearersiBirds
Large Mammals
Participants V)lere then separated into four subgroups. Each
subgroup, with the help of one of the workshop facilitators, began
building a computer model of one of the subsystems. The interactions
between each subsystem were defined by filling in the "looking-outward
matrix" (Figure 2). To do so the participants in each subgroup
identified what information they required from the other subsystems in
order to build their submodel.
Submodel Construction
At the conclusion of the "looking-outward" exercise, each
subgroup had all the information required to construct and code its
submodel independently of the rest of the participants. Where possible,
data from the Susitna basin were incorporated into the structure of
each submodel. In the absence of data, the expertise of the
participants was used to develop hypotheses to help refine the
structure --hypotheses that hopefully could be tested in future field
work and/or analysis.
Scenario Construction
On Thursday afternoon, the workshop participants discussed a
number of representative· construction (action) and mitigation scenarios
to be tried on the model. Three scenarios were developed. The first
was the no-project option to establish indicator behavior under
undisturbed conditions. The second was the construction of the
complete project (Watana and Devil Canyon) using the optimum flow
regime for power generation. . The third scenario considered Watana
development only, had restricted access to the area by the public, and
Figure z. looking Outward Matrix
Hydrology/Development
Recreatf on
Vegetatf on
Furbearers/Birds
large MarMiillS
llydro 1 ogy/Deve 1 opment
Recreation Vegetation,
- 3 day peak flows
-location~ and hectares
of development activities
-surface area exposed fn
floodplain
-hectares of intensive
beaver use by vegetation type
-consumption (kg/ha) of forage
species by season and type
Furbearers/Bfrds
-date of breakup,freezeup on
lakes, ponds, streams
-date of first ~now cover and
exposure of 302:
-km of open water in river
-km of sloughs and side channels
with at least .5 m of unfrozen
water
-reservoir elevations
-levels of human disturbance
-areas of vegetation types (ha)
-productivity (kg/ha) of:
Paper birch
Balsam poplar
8 i rch shrubs
Black spruce
White spruce
Hillow spruce
Aspen
large Manmals
-date of fee breakup
-amount of fee shelving
March 15 to June 15
-snow depths at 150m
elevation intervals,
monthly
-trips/day on access road
by season
-train trips/day, Nov-Mar
-recreational use days
-areas of vegetation
types (ha)
-ha of berries suitable
for bear food
production of berries
(kg/ha)
-standing crop (kg/ha) of
Paper bl rch
Bal~am poplar
Wf 11 ow shrub
Aspen
lowbush Cranberry
-
used the flow regime considered best for maintaining instream flow
requirements of wildlife. Little experimentation with mitigation options
was carried out at this stage, largely due ·to the preliminary state of
the model and the available time. The workshop report will discuss
these and other scenarios in more depth.
EVALUATION
Ultimately in the development of any mitigation strategy there is a
need to evaluate the alternatives and select the preferred option.
However, the major difficulty is structuring the evaluation. When
dealing with a possible change in wildlife populations or available
habitat as a consequence of the project, putting value on that change is
invariably subjective and open to criticism. In any case, such
evaluations are necessary both in evaluating mitigation options as well
as establishing appropriate compensation.
Ultimately, the simulation model developed at the workshop will
help in the evaluation of mitigation options. Exactly how they will be
evaluated is, at this time, not certain. Various approaches have been
applied in the past (e.g., Habitat Evaluation Procedures (HEP), Rapid
Assessment Methodology (RAM), or Delphi) , some with more success
than others. Although "evaluation" as an issue was not the subject of
this first workshop, an evening discussion (facilitated by Ann
Rappaport of the USFWS) was held on this topic to initiate development
of some of the ideas to be pursued after the workshop.
REPORT
The workshop report is now being prepared by ·. the workshop
facilitators/modellers. This report will summarize the workshop
activities and give detailed descriptions of each of the submodels. It
will also discuss the relationship between mitigation planning and the
modelling effort as well as the major research needs identified by the
workshop participants.
NAME
,.... Bob Everitt
""" .Joe Truett
David G. Roseneau ....
Steve Fancy
Philip s. Gipson
,.... Ann G. Rappoport
Larry M. Wright
Leonard P. Corin
Thomas w. Trent
Carl Neufelder
,..., Richard Fleming
!
Tom Arminski -Michael Grubb
~ Bruce R. Bedard
Warren Ballard -Nancy Tankersley
Karl Schneider
John Hayden
.... Bill Gazey
Greg Auble -
Ike Eillison
-
SUSITNA TERRESTRIAL MODELING WORKSHOP
AUGUST 23-27, 1982
AFFILIATION
ESSA Ltd.
LGL
LGL
LGL
AK Coop. Wldl. Res. Unit
ADDRESS
678 W. Broadway, Vancouver, B.C.
604-872-0691
P.O. Box 1745, Grand Jet., CO 81502
P.O. Box 80607, Fbnx, AK 99708
907-479-2669
P.O. Box 80607, Fbnx, AK 99708
907-479-2669
Uni. of AK, Fbnx, AK 99701
USFWS-Western AK Ecological Serr. 605 W. 4th #G-81, Anch, AK 99501
Nat'l Park Ser.
USF & WS
ADF & G, SU Hydro Aquatic
BLM -Anch.
AK Power Authority
AK Dept. of Fish & Game
Acres American
AK Power Authority
AK Dept. of Fish & Game
AK Dpet. of Fish & Game
AK Dept. of Fish & Game
Acres American
LGL
USFWS-Welut
USFWS-Welut
CONTINUED
540 W. 5th, Anch, AlC 99501
605 W. 4th, #G-81, Anch. AK 99501
2207 Spenard Rd. Anch, AK 99503
4700 E. 72 Ave, Anch, AK 99507
334 5th Ave, Anch, AK 99501
333 Raspberry Rd. Anch, AK 99502
900 Liberty Bank Bldg.
Buffalo, NY 14202
334 5th Ave, Anch, AK 99501
P.O. Box 47, Glennallen, AK 99588
333 Raspberry Rd., Anch, AK 99502
333 Raspberry Rd., Anch, AK 99502
1577 "C" St. Anch, AK 99501
1410 Cavitt St. Bryan, TX 77840
2625 Redwing Rd.
Fort Collins, CO 90526
2625 Redwing Rd.
Fort Collins, CO 80526
NAME AFFILIATION
Steve Bredthauer R & M Consultants
Brina Kessel Univ. AK Museum
Majorie Willits AK Dept. of Natural Res.
Butch Roelle USFWS-Welut
Wayne Regelin AI< Dept. of Fish.·& Game
Bill Steigers Univ. AK Ag. Exp. Sta.
Dot Helm Univ. AK.Ag. Exp. Sta.
Robin Sener LGL
Nicholas Sonntag ESSA Ltd.
John Ernst LGL
Suzanne Miller AI< Dept. of Fish & Game
Sterling Miller AK Dept. of Fish & Game
Jack Whitman AI< Dept of Fish & Game
Robert N. Starling Nortec
Larry Underwood AEIDC
ADDRESS
P.O. Box 6087, 5024 Cordova
Anch. AK 99503
P.O. Box 80211, College, AK 99703 ~···
555 Cordova St. Anch, AK 99510
2625 Redwing Rd.
Fort Collins, CO 80526
1300 College Rd. Fbnx, AK 99701
P.O. Box AE, Palmer, AK 99645
P.O. Box AE, Palmer, AK 99645
1577 "C" St. Anch., AK 99501
678 W. Broadway, Vancouver, B.C.
1577 "C" St. Anch, AK 99501
333 Raspberry Rd. Anch, AK 99502
333 Raspberry Rd. Anch, AI< 99502
P.O. Box 47, Glennallen, AK 99588
750 W. 2nd Ave, Suite 100
Anch, AK 99501
707 "A" St. Anch, AK 99501
-
....
....
L (... L R E c. , b a /t e, I 8 2... ea~
ce: ~~c~~b FL.EHtA.JGr
U.S. FISH Q~~ntcr~~~~CE
UNITED STATES GOVERNMENT
memorandum
WESTERN ALASKA ECOLOGICAL SERVICES
733 W. 4th Avenue, Suite 101
Anchorage, Alaska 99501
(907) 27!-457 5
TO: Su Hydro Files
c. e. : so~ 1.J J·h~· 'r'hEN
S.TE~ C. tAr..J '-"
FROM: Ann Rappoport, Fish & Wildlife Biologist
('I''V"--
DATE: ~ 8 AUG 198Z
SUBJECT: Beaver Survey, Talkeetna to Montana Creek
On August 5 and 6, I joined Jim Durst and Dave Volsen of the University of
Alaska, Fairbanks, on the second of their three downstream beaver surveys for
the proposed Susitna hydroelectric project. We surveyed 11 sample miles
within the 24 mile stretch of the Susitna River from just below its confluence
with Montana Creek to Talkeetna. Purpose of my participation was to
familiarize myself with data being collected and determine the applicability
of HEP to the Su Hydro beaver study.
Jim, Dave, and principal investigator, Dr. Phil Gipson, had previously
surveyed the Takeetna to Devil's Canyon portion of the Susitna River; Phil was
to join them the next week for the remaining survey from Montana Creek to the
Delta Islands. Upstream areas bad been briefly evaluated during the previous
year's furbearer work. An aerial count of food caches will be undertaken this
fall.
Following is a brief description of the beaver survey methodology, qualitative
study findings, data needs and applicability of HEP.
Methodology
Traveled upriver in University's 20' riverboat. River miles had been marked
~tnd llllfllh~r£!d on J" .. t,OOO' blttcl< IHUI ~thft11 photoli wfrh nnH numhHr fnr t.ht! tHtBt
river bank and one number for the west river bank. One river mile long sample
sites were surveyed by boat. Sloughs and freshwater streams adjacent to those
sample miles and within the area expected to be impacted by project-caused
flow changes were also surveyed. Where impossible to survey an area by boat
or foot, a helicopter was to be used the following week. Data collected
included: beaver sign (tracks, cuttings, "skid"' trails, lodges, bank burrows,
and dens), bank type (e.g. mud, rock, etc.), water depth, water velocity,
dominant tree and shrub cover type~ other wildlife sign, and presence or sign
of human disturbance •
R7·J
qualitative results
Eleven sample sites were surveyed. Each site consisted of one mile stretch of
river bank along one side of the river and the adjacent sloughs and streams.
River banks were typically heavily vegetated and ranged from 1 -3' in height
to 40-50' with gravel rocks to 6" or bare mud at the water's edge. Occasional
exposed, barren cliffs of 30-50' in height were also present. Vegetation
along the river is primarily deciduous. Dense alder to 30' predominated with
some interspersed tall willow shrubs. The cottonwood and birch overstory
ranged from open to closed with intermixed spruce along the top of the banks.
Devil' s club, ferns, berries (high bush cranberry, elderberry, and wild rose),
and grass typically £omprised the understory. Willow and poplar seedlings
were usually scattered in the grass/sedge/equisitum cover on flats and
vegetated islands.
At least three beaver were observed during the survey. Beaver sign (tracks
along mud banks, cuttings of willow and poplar (one cut alder was found),
"skid" trails where cut vegetation has been dragged to the water, and beaver
lodges and dams was common in areas of suitable habitat. Key factors
contributing to suitable habitat were:
(1) sloughs or clear-water streams of slower-moving water adjacent to the main
river channel; apparently limiting water velocities are unknown;
(2) availability of food -University researchers are preliminarily concluding
that lack of willow limits beaver use along the Susitna River. It is
unknown why alder is the early successional stage rather than willow in
some locations is unknown.
(3) banks which provide stable substrates for burrowing;
(4) absence of human disturbance --a few areas of highly suitable habitat
(i.e. willow was present, side sloughs and sand/mud banks offered suitable
building sites) lacked any beaver sign. Howe;er in all cases these areas
were easily accessible to the road and supported an enthusiastic
population of 10-20 fisherpersons and abundant empty beer cans and other
trash; and
(5) at least 30" water depth in winter.
Data Needs/Applicability of HEP
Lack of information on both vegetation succession and the hydrologic regime
anticipated with project development are the major limitations to determining
project impacts to beaver. Data being collected should provide a good
baseline assessment of beaver populations and habitat uses downstream of the
Devil's Canyon dam si~e. A baseline HEP analysis could likely be performed
with existing data and the University of Alaska researchers' input.
I discussed HEP with Jim and Dave. They were interested to learn of the
availability of color IR photos of the area (from u.s. SCS/FS studies of the
Susitna River Basin) which could help in identifying v~getation cover in areas
not directly surveyed. We considered ways of modifying the beaver habitat
model as was done for the Bradley Lake and Willow Subbasin studies, yet the
model could be improved with the site information collected for the Susitna
project. Model modification should involve assigning suitability index values
on the basis of available water plus adjacent suitable vegetation cover.
cc: FW'S-ROES
Lenny Corin, WAES
Phil Gipso·n, University of Alaska, Fairbanks
Robin Sener~ LGL
APPENDIX EllH
COMMENTS RECEIVED DURINCi NOVEMBER 1982 WORKSHOP
APPENDIX ll.H
MEETING NOTES FROM NOVEMBER WORKSHOP
-
On November 15~ ]982, a Draft Exhibit E of the license application was
,-distributed to the appropriate federal, state, and local agencies for· review
and comment. To assi:st agencies in reviewing the Draft Exhibit E, a four-day
workshop was held in Anchorage from November 29 to December 2, 1982.
This appendix contains a list of agencies that were sent the Draft Exhibit E
and notes of the workshop meetings.
-
P5700. 70.0100-00
SUSITNA HYDROELECTRIC PROJECT
FERC License Application Exhibit E Presentation and Discussion
Anchorage, Alaska
Holiday Inn
Objectives
November 29 -December 2, 1982
1. Update Federal, State and local agencies regarding significant
changes in project features since the Feasibility Report was
published in March, 1982.
2. Use the presentations and discussions as an interactive process
whereby Federal, State and local agency review of the draft Exhibit
E can be facilitated.
3. Develop a mechanism for continued interaction as the finalized
Exhibit E is prepared for submission to FERC.
Monday, Novanber 29
Introduction
AGENDA
l : 00 P.M.
Project Operational Description
Wa ta na Darn
Devil Canyon Dam
Access
Transmission
Schedule for Preparation of Exhibit E
Group Definition
Tuesday, November 30 9:00A.M.
Group Water Use and Quality and Fishery Resources (l4. Oyck, L. Moutton.
Group 2 Wildlife and Botanical Resources (R. Sener, M. Grubb)
Group 3 Socioeconomic/Land Use (P. Rogers, P. Lukens, K. Young)
Group 4 Cultural Resources (G. Smith, D. Follows)
Wednesday, December 1 9:00 A.M.
Group Water Use and Quality and Fishery Resources
Group 2 Wildlife and Botanical Resources
Group 3 Recreation and Aesthetics (R. Erickson, J. Chappell)
Thursday, December 2 9:00 A.M.
Group 1 Water Use and Quality and Fishery Resources
Group 2 Wildlife and Botanical Resources
-
....
LIST OF ATTENDEES
SUSITNA HYDROELECTRIC PROJECT WORKSHOP
Name
Michael P. Storonsky
Philip Hoover
Thomas Lavender
Tony Burgess
Michael Grubb
Charlotte Thomas
Steve Fancy
Martha Raynolds
Robert Sener
Dave Tremont
Ro 1 and Shanks
Priscilla Lukens
Michele Urban
Tom Arminski
Leonard Carin
Larry Moulton
Jean Baldridge
Keith Quintavell
Robert Mohn
George Gleason
John Sizer
Jack Robinson
Randy Fairbanks
Gary Lawley
George S. Smith
E. James Dixon
B. Agnes Brown
Carole A. Ellerbee
Robert M. Erickson
Tim Smith
Richard Fleming
Bob Madison
Bob Lamke
Bob Martin
Don McKay
George Cunningham
Randy Cowart
Al Carson
Paul Janke
Gary Prokosch
Mary Lu Harle
Robin Hi 11
Peter Rogers
Steve Zrake
Holiday Inn, Anchorage, AK
Monday, November 29, 1982
Organization
Acres
Acres
Acres
Acres
Acres
Alaska Power Authority
LGL Alaska
LGL Alaska
LGL Alaska
Dept. ,Commuoity
Regional Affairs
Cook Inlet Region, Inc.
Acres
Harza/Ebasco
Alaska Power Authority
tJSFWS
Woodward-Clyde
Woodward-Clyde
DNR -DLWM
Alaska Power Authority
Alaska Power Authority
Harza/Ebasco
Ha rza/ Ebasco
Ha rza/ Ebasco
Harza/Ebasco
University of AK Museum
University of AK Museum
Tyonek Native Corp.
Tyonek Native Corp.
EDAW, .Inc.
DNR-Parks (History and
Archaeology)
Alaska Power Authority
USGS-WRD
USGS-WRD
ADEC
ADF&G
ADF&G
ADNR-R&D
ADNR
ADNR
ADNR-Water
ADNR-Water Management
Frank Orth & Associates
Frank Orth & Associates
ADEC
Telephone
276-4888
II
11
11
716-853-7525
276-0001
479 ... 2669
274-5714
274-5714
264-2206
274-8638
276-4888
277-1561
276-0001
271-4575
276-2335
276-2335
276-2653
276-0001
II
277-1561
II
474-7818
II
272-4548
11
274-3036
264-2139
276-0001
271-4138
II
274-2533
267-2284
344-0541
276-2653
276-2653
11
276-2653
II
206-455-3507
11
274-2533
LIST OF ATTENDEES-cont ..
Name
Jan Ha 11
Gary Stackhouse
Brad Smith
Bill Lawrence
Floyd Sharrock
Bruce Bedard
Ann Rappoport
Bob Everett
Eric Myers
John Rego
Lee Adler
Bill Wilson
Chris Godfrey
Ted Rockwe11
Larry M. Wright
Organization
USFWS
USFWS
NMFS
U.S. EPA
NPS
A1aska Power Authority
USFWS-WAES
ESSA Ltd.
NAEC
BU~
AHTNA Inc.
AE:IDC
COE
USCE Reg. Function
NPS
Telephone
263-3403
263-3475
271-5006
271-5083
271-4216
276-0001
271-4575
274-5714
276-4244
267-1273
822-3476
279-4523
552-4942
II
271-4236
LIST OF ABBREVIATIONS USED FOR AGENCIES
Alaska Power Authority
Alaska Department of Community and Regional Affairs
Alaska Department of Environmental Conservation
Alaska Department of Fish and Game
A 1 ask a Department of Natura 1 Resources
Artie Environmental Information and Data Center
(University of Alaska)
Cook Inlet Region, Inc.
National Marine Fisheries Service
National Parks Service
Northern Alaska Environmental Center
United States Bureau of Land Management
United States Corps of Engineers
United States Environmental Protection Agency
United States Fish and Wildlife Service
APA
ADCRA
AOEC
ADF&G
ADNR
AEIDC
CIRI
NMFS
NPS
NAEC
BLM
COE
US EPA
USFWS
-Minutes of Meeting -
Subject: Susitna Hydroelectric Project Workshop-FERC License Application
Exhibit E, Presentation and Discussion
Location: Holiday Inn, Anchorage, Alaska
Attendees: see attached
Date: Monday, November 29, 1982 1:00 P.M.
Minutes recorded by: Michael P. Storonsky
I. Introduction -Dr. Richard Fleming (APA)
A) Summary:
Dr. Fleming provided an overview of the purpose of the workshop, the
schedule of the license application process and introduced some of the
attendees.
B) Purpose of Workshop:
To provide an informal informational session for the various agency
attendees. Solicit comments and concerns to improve the final license
document to be submitted to the FERC.
C) ~&Jl1ic~ticon:
submitted draft Exhibit £ to the FERC and the various agencies
November 15, 1982
-workshop November 29 -December 2
prepare and distribute a copy of the minutes of workshop week of
December 6
-incorporating agency comments into draft as received
-meet with FERC staff 14 December to review Engineering Exhibits
meeting with the FERC staff December 28 to receive their comments on
Exhibit E of draft application
-agency comments due January 15, 1983
-submitting license application to the FERC February 15, 1983
.....
- a supplementary report of 1982 fisheries information and analysis to
be submitted in June 1983.
-additional supplemental information as required.
0) Introduced representatives of the Harza/Ebasco/ team that wi 11 be
handling Phase II of the Susitna Project.
II. Project Operational Description -Dr. John Hayden (Acres)
A) Summary
Dr. Hayden first provided a slide presentation of the major project
features and location, and then a series of overhead viewgraphs of the
filling and operational processes. Through the use of wall maps Dr.
Hayden provided a description of the acce.ss routes and transmission
lines, their locations and schedules of development. Following an
intermission Dr. Hayden outlined the organization of the workshop for
the b a 1 ance of the week.
B) Major Project features -Watana
-overview of the drainage basin and the relative position of the dams
-location of the proposed damsite looking both upstream and dDwnstream
-location of the proposed borrow areas O&E, existing field camp,
intake tunnel, emergency spillway
project features discussed incltJding the 54 mile length of reservoir,
upstream boundary -just above the confluence with the Oshetna River,
site of construction camp and villa.ge, and location of access road
-construction development schedule described
• access road construction
. diversion tunnel excavation
• completion of diversion cofferdams
• diversion of water through 2 tunnels, to be ultimately sealed
• plug tunnels 4 -5 years into construction .and begin filling
reservoir
complete dam, power facilities and above ground structures
-operation
• 1993
• 6 units x 170 MW = 1020 MW
120' depth of intake structures rather than previous 140' depth
. 4 intakes levels
outlet facilities
ma.in spillway for floods> 1:50 years
• emergency spillway for flood> 1:10,000 years.
C) Devil Canyon Project Features
-location of the proposed site looking both upstream and downstream
-pertinent features
. access routes
• borrow area locations
powerhouse location on north side of river
. long tailrace proposed to provide additional head
4 units at 150 MW = 600 MW Total capacity
• Fixed-cone values will be used to maintain instream flow during
fill·ing as well as prevent gas supersaturation during operation •
• multiple level intake structure - 2 intakes within upper 50 feet of
the reservoir.
-Operational Data
• 50' drawdown in August of some years
• commissioning date 2002
D) Filling and Operation Processes
(i) Mimimum flow requirements at Gold Creek
-Filling
1000 cfs in winter
6000 cfs in spring
• flows spiked to 12,000 cfs in August and through mid Sept.
-Operation
• 5,000 cfs in winter
spring and summer same as during filling
-
(ii) Filling Process for Three Filling Scenarios Based Upon the 32
Years of Historical Hydrologic Data
-three year filling flow scenarios examined with
. 90% chance of exceedence
50% chance of exceedence
. 10% chance of exceedence
-filling begins 1991 -1993
-not a lot of difference between 3 scenarios
(iii) Comparison of Monthly Average Pre-prdject and Filling Flows
at Gold Creek, Sunshine and Susitna Station
-greatest % change in the summer time
(iv) Operational Water Levels at Watana
-normal maximum elevation 2185 1
-surcharged to 2190 1 during September after the risk of floods
diminished
-mean drawdown los•
-maximum drawdown 120•
-maximum, minimum and mean drawdown scenarios compared
-very slight water level change with Devil Canyon on line
(v) Devil Canyon Water Levels
-wet years; reservoir full all year
-mean years; so• drawdown in August and September with filling
as rapidly as possible in October
-dry years; slight drawdowns during April -May also
(vi) Comparison of Monthly and Annual Pre-project and Post-project
flows with Watana alone and with both projects on line
(vii) Operation of Projects
-Watana alone will be operated as a base-load plant
-with Devil Canyon on line, Watana will be peaked and Devil
Canyon wi 11 be base-load
(viii) Temperature conditions
-modeling taking place
-may need to consider a low-level intake to achieve more
desirable fall temperatures
E} Access Roads -wa 11 maps
(i} Watana Route
-railroad transfer point at Cantwell
-use Denali Highway for 21 miles to Watana access road
from Denali Highway, 43 miles south to damsite
(ii) Construction Schedule-Watana
-begin immediately after issuance of license
-construct a primitive access road from Denali Highway to Watana
damsite first
-within 1 - 2 years upgrade to allow for additional construction
traffic
-following 1993 it is uncertain as to whether the access road
will be public or private, this decision will be made at a
later date
(iii} Devil Canyon
road from. Watana to Devil Canyon north of river
railroad access from Gold Creek to damsite, south of river
-schedule not as critical
-public vs. private road to be decided at a later date
F) Transmission Line
-two lines from Watana to the intertie
-two lines from Devil Canyon to the intertie
-winter construction of a significant portion of corridor, therefore
avoid need for "access road"
-use existing trail from Cheechako Creek to the intertie
G) Other
-pursuant to a question from the audience
-• outlined project boundary
-
....
• identified land holdings in the area: native~ private and state
-set of drawings of project reproduced from Exhibit F provided
INTERIYIISSION
Hl Organization for Balance of Workshop
Identified groups~ group leaders, and locations and times of meetings
-(see attached agenda).
MEETING ADJOURNED
SYNOPSIS OF WORKSHOP ON SOCIOECONOMICS
NOVEMBER 30, 1982
Frank Orth & Associates, Inc. lead a discussion in which the following topics
were addressed: objectives of Section 5 of Exhibit E; the methodology and
assumptions used in the socioeconomic analysis; the major areas of impacts;
and the proposed mIt r gat 1 on process. CopIes of the agenda and the I I st of
particIpants for thIs workshop are attached. SignIfIcant Issues brought up
by participants are summarized below:
1. It was requested that clarification be provided on the reasons that
impacts resulting from the use of the power that the project wl I I
provIde are not inc I uded In the FERC I i cense app I I cation. Discuss I on
tot lowed on the distinction between direct/indirect and Induced impacts.
2. The possibi I ity of dam tal lure and the need for an alarm system for
res I dents I i vI ng near the rIver, downstream of the project, was
suggested.
3. One participant suggested land use restrictions In the areas that could
be affected by flooding in case of dam failure.
4. Several participants commented on the need for pol lcles that would
encourage local hire at the community level. Suggestions Included
requiring unions to enroll workers from rural areas, use of tax
policies, and review of NANA Corporation's local hire requirements at
the Red Dog mining project.
5. It was requested that more discussion of the possible magnitude and
significance of people that wil I come from other areas of the
country, without finding work on the project, be provided. It was
stressed that this could change the magnitude of Impacts significantly.
6. A table I !sting the various assumptions regarding the origin and
characteristics of the construction work force was recommended.
7. One participant commented that the assumption that 50 percent of the
workers whose Jobs are terminated upon completion of Watana will remain
Jn the area may be too high. He cited the small economic base and
resultant lack of job opportunities In the smal I communities as the
reason.
8. One participant asked about the possible access of local planners to the
study team's socioeconomic Impact model.
9. It was asked whether cumulative Impacts that Included other projects In
the Impact area were taken Into account.
10. Several questions were asked and Issues were raised concerning the work
camps/vii lage Including: a) who pays for the camp; b) whether the
workers would pay rent; c) the concerns of the Mat-Su Borough and
Individual communities; d) the degree of access; and e) the Implications
of the camps on land use In the Upper Susltna Basin.
1
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11. A discussion of the objectives of the mitigation process occurred.
Several participants emphasized the need tor a continuing mitigation
process that wll I anticipate Impacts and Initiate measures to mitigate
impacts before they occur, In which other agencies be Included.
12. One participant suggested additional clarification be put into the
section concerning the ongoing studies on impacts to fish and wildlife
user groups.
13. It was suggested that more research be con~ucted on part-time and
subsIstence use of resources In the Impact area. Another particIpant
commented on the need to Include discussion of subsistence
considerations In Section 810 of ANCSA.
14. Additional use of resources on private land by individuals gaining
access with the projects's access road was mentioned as a possible
adverse Impact that should be monitored and mitigated.
15. Additional use of aircraft to transport workers was mentioned as a
possible mitigation tool.
16. It was commented that ranges of population influx, or some form of
confidence levels associated with the projections, would make the
discussion of impacts more useful to the communities. Threshold levels
of population Influx that would spur the need for new publ lc facilities
were also suggested.
2
Randy Cowart
AI Carson
Ron Stanek
Kevin Young
Robert Mohn
Herbert Smelcer
S. 0. Simmons
Ed Busch
Ken Hunt
Bruce Bedard
Robert M. Er·ickson
Charlotte Thomas
Nancy Blunck
Jim Richardson
Peter Rogers
Rob In Hill
LIST Of PARTICIPANTS
SOCIOECONOMIC IMPACT WORKSHOP
NOVEMBER 30, 1982
AGENCY
ADNR, Research and Development
Alaska Dept. of Natural Resources
Alaska Dept. of Community and Regional
Affairs
Acres American
Alaska Power Authority
Ahtna, Inc.
Harza-Ebasco
ADCRA Anc., Div. of Community Planning
Alaska Dept. of Natural Resources. Water
Mgmt.
Alaska Power Authority
EDAW. Inc.
Alaska Power Authority
Alaska Power Authority
Frank Orth & Associates, Inc.
Frank Orth & Associates, Inc.
Frank Orth & Associates, Inc.
3
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CULTURAL RESOURCES MEETING
Anchorage Holiday Inn
November 30, 1982
Subject: Mitigation Planning for Susttna
Purpose: To review research design and methodology used in 1980-82 work.
To review and discuss draft FERC License Application.
To discuss cost effective means by which the initial survey may
be completed.
To seek approval from the SHPO on the overall mitigation approach.
In Attendance: Beth Walton, State Archeologist, Bureau of Land Management
Diana Riggs, Department Natural Resources
Tim Smith, State Office of History and Archeology
Floyd Sharro~k, Chief Archeologist, National Park Service
George Smith, Project Leader, University of Alaska Museum
E. James Dixon, Curator of Archeology, University of Alaska
Museum
Richard fleming, Alaska Power Authority
Don Follows, Acres American, Incorporated
Guests: Phil Hoover, Acres American, Incorporated
Jack Lobdell, Consultant
The Cultural Resources Program Manager, Don Follows, opened the meeting at
9:10a.m. in Room 227 of the Holiday Inn, Anchorage. After the introductions,
the point was made how critical the cultural resourcesare to the hydroelectric
project schedule. Compliance with Section 106 of the Historic Preservation Act
of 1966, Executive Order 11593 and Title 36, Part 800, Code of Federal Regu-
lations and related laws direct the process for Cultural Resources investiga-
tion and mitigation planning.
Dr. Dixon presented a synopsis of the field work which has been completed
and reported on over the past three field seasons. To date, about 50 percent
of the total project area has been surveyed. Of special interest is the
location of four tephras which provide dating references for the artifacts
recovered. It is hoped that the cultural chronology of the region can be,
for the first time, established.
Dr. Dixon explained that in his approach to mitigation planning the term
11 potentia1 impacts 11 had been developed to a,ddress those sites outside the
adversely effected areas. This third category allows for a more flexible
means by which to address the large number of sites recorded (167) to date,
many of which will not be impacted directly, and only p9tentially in the
future. Potentially~ impacted sites would not require systematic testing
at this time, but should be monitored from time to time by the appropriate
CULTURAL RESOURCES - 2
land managers to determine conditions. If conditions warrant, mitigation
would then be required.
Dr. Sharrock {NPS) asked at what point the Advisory Council on Historic
Preservation should become involved in the project. The information that
both Acres and the Power Authority had received in separate meetings with
FERC ·in Washington, D.C. was that FERC would not contact the council until
the basic reconnaissance was completed.
Serious scheduling problems could arise if FERC requires the Cultural
Resources field survey to be completed next summer. The Alaska summer is
only two and a half months long. The project size and remoteness introduce
unique conditions under which a large workforce can become less efficient
because of support logistics required. Based on his many years of Alaska
experience, Dr. Dixon felt it would be unrealistic to expect completion
in one year. It was the group consensus that two years would be best.
Another significant factor in attempting to complete the work in one field
season is the Alaska Power Authority fiscal year which begins July 1. Unless
funds are available at present time to launch the spring 1983 workforce,
the goal will be difficult to attain because of the University•s administrative
procedural delays in hiring employees. ·
Dr. Fleming said that a decision on whether to proceed with a one or two year
program will be made by the end of January, 1983.
In summary, the group consensus seemed to favor a two year survey program as
outlined in the mitigation plan, and the early (if possible) involvement of
the Advisory Council on Historic Preservation so that procedures can be
established which satisfy both the FERC scheduling concerns and the Advisory
Council.
·Phi 1 Hoover wi 11 meet with F£RC the end of December to discuss the involve-
ment of the Advisory Council.
,,,,,,
. ~
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LAND USE
Questions & Comments
1. CIRI and the village corporations asked that the Power Authority request
that DNR identify lands suitable for exchange. They feel that land
exchange with the state may offer one mechanism for the Power Authority
to acquire project lands from them. Potential lands for exchange are
becomming limited. DNR has not commenced such a study.
2. Clarification was requested on the content of Section 24 of the Federal
Power Act.
3. Discussion occurred regarding induced land ~se changes on Native
corporation owned land resulting in public pressure to provide increased
access, e.g.: potential of fishermen wanting improved access to Portage
Creek. Natives are concerned that the project not lead to trespass on
their lands.
4. Concern was expressed about the compatab i 1 ity of the proposed access
plan with the Denali Scenic Highway plan.
-Discussion related to potential recommendations of the ongoing study.
The report on Denali Scenic Highway wi 11 need to be adopted by the
Land Use Council before being released. As identified by BLM, the
only incompatabi1ity with the Denali scenic Highway would be temporary
transmission going into the Watana site.
5. It was suggested that an assessment should be conducted on the long term
economics value of having a more appealing access road.
6. A suggestion was made that a land use committee be established. The
potential of having the Power Authority participate on the Mat Su land
use planning team was discussed as an option.
7. A request was made that a substation and distribution be located at
Cantwell as part of supplying construction power to the site, and thus
make Intertie power available to that community.
8. It was suggested that additional assessment of land use changes at the
community level will be undertaken, particularly with respect to
Cant we 11.
9. It was mentioned that Native concerns should be presented in the FERC
license application.
10. The Native corporations will not initiate planning until definite
project requirements are received •
11. The Native corporations propose the following methods for the Power
Authority t9 acquire project lands: purchase, lease or exchange.
12. Effects of land acquisition procedures on land use development were
d i SCUS'Sed.
ATTENDANCE LIST
Land Use Workshop
Tuesday, ll/30/82
Charlotte Thomas
Robin Hill
Ron Stanek
Herb Smelcer
Bruce Bedard
Steve Simmons
Nancy Blunck
Randy Cowart
Robert Erickson
Dave Tremont
Priscilla Lukens
Kevin Young
Alaska Power Authority
Frank Orth & Associates
Alaska Dept. Fish & Game
AHTNA Inc.
Alaska Power Authority
Harza-Ebasco
Alaska Power Authority
ADNR-R&D
EDAW, Inc.
Alaska Dept. of Cortmunity & Regional Affairs
Acres American
Acres American
r---
"'"'
COMMENTS RECEIVED
WORKSHOP ON RECREATION
December 1, 1982
1. Questions were asked regarding FERC policy on location of facilities
off-site. When recreation resources are off-site or when there are
problems developing the res~rvoir, FERC has.accepted developJllent of
off-site facilities. State Parks concurs with this position
agreement.
The Power Authority stated their position is to a) take advantage of
project facilities (roads & reservoirs), b) be responsive to landowners
concerns (avoid trespass), c) direct use away from sensitive fish,
wildlife and archaeologic resources.
2. Why is an expansion of Brushkana campground recommended? The need has
been discussed already by BLM and it appears in their management plan.
The project would increase demand for camping along the Denali Highway
and this is a logical location. It would also keep some auto traffic
and camping from penetrating the project area. BLM would manage the
area, and BLM and Power Authority would enter into a memorandum of
understanding regarding construction, operation and rna intenance.
3. State Parks Department is pleased with the plan as presented and
confirmed that the plan is in agreement with the state-wide recreation
plan. DNR supports the plan.
State Division of Parks will open a new trail along Curry Ridge line,
from Coal Creek to Traub lesome Creek, in 1983. They would like .. the
Power Authority to consider adding three whistlestops, consisting of
small campsites and possibly shelter cabins, at Gold Creek, Curry Ridge
and Indian River.
4. Question: Is a.full range of recreation facilities provided at Watana
Village and are facilities provided for other than rugged hikersJ
Answer -Power Authority: Yes, extensive recreation facilities and
activities are included in the plan for the village. There is a full
range of recreation opportunities provided in the recreation plan, from
driving and pull-offs along the road, to a visitor center with
educational exhbits, to rugged hiking.
5. Question: There are no improved trails in Denali National Park. Why
does State Parks want improved trails?
Answer -State Parks: Brushing out and hardening is done only where
necessary (e.g., inclose-in forested areas). In further out open
areas , rock cairns may be all that is necessary.
6. Concern was mentioned about Caribou kills on the Watana access road.
The reports recommends lower design speed and lower profile for that
road (Section 8, Aesthetics). Caribou kills are not known to be a
COMMENTS RECEIVED
WORKSHOP ON RECREATION - 2
problem on the Denali Highway now. The Denali Highway presently has an
AADT of 50 vehicles; Parks Highway~ 200. The project is projecting 20
truck trips/day. While no firm traffic projections on the Denali
access road are available~ it will be much lower than the Parks Highway
today and lower than the Denali Highway at that time. Recreation
traffic will be limited primarily to July~ August and September.
7. Question: Are any facilities proposed adjacent to the Watana access
road?
Answer: In addition to the turn-outs and trailheads shown on the
project maps, rehabilitation of borrow areas for camping is a 11 Phase 5 11
item. They cannot be located at this time because the loation of
borrow areas is not know. A note to this effect will be added to the
map of recreation facilities.
8. Question: Why do we assume that demand will build up over time and not
be instantaneous when the facilities open (p E-7-42)?
Answer: National Park Service experience has shown this to be the
case, even in well-known recreation areas. It takes time to build a
sustained marked. If a new salmon fishing area close to Anchorage were
opened, it would get immediate heavy use. Project facilities will not
be that type of area.
9. Demand figures were discussed and agreed with; if anything, they may be
high. This is why some facilities have been put in Phase 5.
10. What is the capacity of the Susitna River Boat Launch? 6 vehicle
places. This will be checked against DOT's Denali Highway Study.
11. Three facilities require Native concurrence -the Chulitna trail, Fog
Lakes trail and campground, and Stephan Lake trail.
Question: Is there a statement that says land acquisition costs will
be in addition?
Answer: Yes. The plan also recognizes that additional private
recreation development may take place on private land.
12. The plan should mention that snowmobiling will probably increase along
the Denali Highway. No specific areas need to be set aside.
13. Page E-7-39, paragraph 3 states fishing is decreasing. The data source
should be re-checked to confirm this.
14. Capital investments will be part of Power Authority project financing.
Operational costs will be partly done as part of regular operations.
MOU's with the agency would detail arrangements.
15. Effects on downstream recreation appear to be mixed. Water quality
will improve but quantity will decrease during the open water season.
See Chapter 2 -Water Quantity and Quality.
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ATTENDANCE LIST
WORKSHOP ON RECREATION
December 1, 1982
Larry Wright, USNPS
Randy Cowart, ADNR
Gary Stackhouse, USFWS
Dave Dapkus, USBLM
Mike Mills, ADF&G
Roland Shanks, CIRI
Jack Wiles, ADNR
Richard Fleming, APA
Bruce Bedard, APA
Nancy Blunck, APA
Gary Lawley, Harza-Ebasco
Jack Robinson, Harza-Ebasco
Peter Rogers, Frank Orth & Associates
Robin Hill, Frank Orth & Associates
Bob Erickson, EDAW, Inc.
Jim Chappell, EDAW, Inc.
Kevin Young, ACRES
Priscilla Lukens, ACRES
COMMEMTS RECEIVED
Workshop on Aesthetics
December 1, 1982
1. Be sure that discussion of Watana access road clearly states EDAw•s
recommended restudy of that alignment.
2. It was suggested that a mitigation measure be to take a film of the
river from Tyone River to Gold Creek today, and again periodically after
construction, in a 11 time-lapse 11 fashion.
3. Discussions of the construction camps and the townsite took place, with
agreement that additional location studies and design studies are
required.
4. Discussions of the transmission lines took place, with agreement the
north and south stubs need additional location studies but the line from
the powerhouses to the intertie is well located. (The alignment between
Watana and Gold Creek which was assessed in the application and
discussed at the workshop was subsequently relocated to provide improved
access for construction and operation.)
,i~
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ATTENDANCE LIST
WORKSHOP ON AESTHETICS
December 1, 1982
Larry Wright, USNPS
Randy Cowart, ADNR
Gary Stackhouse, USFWS
Roland Shanks, CIRI
Jack Wiles, ADNR
Bruce Bedard, APA
Nancy Blunck, APA
Bob Erickson, EDAW, Inc.
Jim Chappell, EDAW, Inc.
SYPNOSIS OF AGENCY COI'IIMENTS
AND QUESTIONS
REVIEW OF DRAFT EXHIBIT E OF FERC LICENSE APPLICATION
WILDLIFE AND BOTANICAL RESOURCES GROUP
ATTENDEES
Name
Lee Adler (LA)
Roseann Densmore (RD)
Bob Everitt (BE)
Randy Fairbanks (RF)
Steve Fancy (SF)
Michael Grubb (MG)
Gary L iepitz (GL)
Ann Rappoport ( AR)
Martha Raynolds (MR)
Karl Schneider (KS)
Robert Sener (RS)
Gary Stackhouse (GS)
Judy Zimicki (JZ)
Tuesday, November 30, 1982
Room 225, Holiday Inn, Anchorage
Organization
Ahtna
Envirosphere
ESSA Ltd.
Envirosphere
LGL Alaska
Acres American
ADF&G
FWS
LGL Alaska
ADF&G
LGL Alaska
FWS
No. Ak. Environ. Ctr.
Address
Box 6 Copper Ctr.
Anchorage
Vancouver, B.C.
Seattle
Fairbanks
Buff a l o
Anchorage
Anchorage
Anchorage
Anchorage
Anchorage
Anchorage
Anchorage
Phone No.
822-3476
277-1561
604-872-0691
206-451-4620
479-2669
716-853-7525
344-0541x281
271-45 75
274-5714
344-0541
274-5714
263-3475
277-2134
Discussion of Preparation of Exhibit E: Baseline Description, Impact Section
and Mitigation Section.
KS-What will the February and June submittals entail?
What data will be in which document?
Discussion of Schedule for Submitting Documents and Agency Review Procedures.
AR -What about after June 30? Will there be continuing studies?
When will those data be incorporated?
Discussion of Schedule after June 1983. Discussion of Baseline Vegetation
Description.
LA -Is the Susitna basin key winter moose range?
Discussion of Areas That Might be Critical During a Severe Winter.
AR -Is a new classification system being used to· help characterize moose
habitat?
-
WILDLIFE AND BOTANICAL RESOURCES GROUP - 2
Discussion of Viereck & Dyrness System and Relation to Moose Browse
Identification.
RF -Was all vegetation mapping described in Exhibit E done from 1:120,000
1980 U2 photography?
AR -Does Exhibit E conta·in all work completed up to this point, so that new
data will go into the June 30 document?
Discussion of Threatened or Endangered Wildlife Species, Prioritization of
Species, Moose Baseline Description.
KS -New census this fa 11 showed more moose on the Sus itna River downstream
of Devil Canyon than have ever been measured there before.
Discusion of .MooseCalving, Food Habits and Mortality.
KS -Black bear predation on moose calves is important as well as brown bear
predation. Early green-up of vegetation in the river valley may be
important to cows th,at are about to calve, even if the area is not a
true winter range.
Discussion of the Caribou in the Area, and Dall Sheep.
KS -Sheep sighted in the Watana Mountain -Grebe Mountain area are probably
a sub-group of the main Talkeetna Mountains group. The number within
the Susitna watershed could vary.
Discussion of Brown Bear Baseline Description.
KS -Yes, one would expect brown bear population to decrease downriver due
to poorer habitat and lower elevation.
Discussion of Black Bear, Wolves, Coyotes, Wolverine, Belukha.
KS -Belukha feed on anadromous fish. Smelt runs in Cook Inlet are also an
important food source. Have they been studied?
Discussion of Furbearer, Bird and Small Mammal Baseline Descriptions.
AR -What is your perception of the completeness of the baseline
information?
AR -How about information on population increases or decreases, or the
quality of the habitat? Are there any gaps in that type of
information? Are the data being gathered? When will they be
available?
WILDLIFE AND BOTANICAL RESOURCES GROUP - 3
Discussion of Data Gaps and 1983 Field Season.
KS - I hope we can get the 1983 field program set up this winter. All issues
should be identified.
AR-1 1 m glad to see the vegetation mapping is being re-done and that you
(LGL) are not just accepting the inadequacy of the earlier data.
Will the original researchers (principal investigators) be given the new
vegetation maps to re-work their data?
Discussion of Importance of Early Planning, Expecially if This is a
Severe Winter. Discussion of Impacts to Moose Due to Watana Development.
AR-Hunting regulations are political, and these are not predictable.
Unless commitments are actually a part of the license, they will not
necessarily be followed.
KS -Project personnel are easier to regulate than the public. Many
different regulatory options are available. Permitting to restrict
harvest is easier than closing the road.
Discussion of License Application Approach to Issues Outside the Power
Authority's Jurisdiction.
LA -Has any consideration been given to regulations Natives may impose?
They can control access -trespass -but can 1 t directly regulate
hunting.
Discussion of Moose Impacts and Moose Browse Studies.
AR-Both summer and winter vegetation sampling will be needed to accurately
determine energy and protein content of browse.
Discussion of Planned Moose Studies and Those in Progress.
AR -The document (Exhibit E) should clearly describe any work that is going
to be done, and its schedule.
Discussion of Species Prioritization and Mitigation Tradeoffs.
KS -In many cases, compensation may be the major mitigative technique.
·-
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'~
WILDLIFE AfllD BOTANICAl RESOURCES GROUP -4
Discussion of Impacts to Downstream Moose and Caribou.
RF -How is FERC going to respond to the lack of specificity in the caribou
impact and mitigation section?
KS -The effects on caribou are difficult to mitigate except through the no
project 0ption. Out-of-kind mitigation will be determined after impacts
have been assessed during construction and operation.
Discussion of Impacts to Dall Sheep.
KS -Might be useful to do a slope stability study of Jay Creek sheep lick.
Inundation might even enhance the lick through erosion exposing fresh
mineral soil.
Discussion of Impacts to Brown Bear and Black Bear.
KS -Both bear species use several different, scattered food sources, which
wi 11 be more or less important in different years. Pinpointing the
factor limitin9 bear populations is difficult, consequently the effect
of the dams is difficult to predict.
Discussion of Impacts to Wolves of Watana Development.
KS -Activity sensors on wolves showed that helicopters caused reactions, but
the wolves, even one in a den with pups, became habituated. Good data
are available on the optimum time of day and season to minimize
disturbance.
Discussion of Impacts on Wolverine, Belukha, Beaver, Marten, Raptor,
Waterfowl, and Small Mammals.
AR -Looking at the project as a whole, is diversity being maintained through
mitigation or are moose being favored to the neglect of other species?
In some areas, different species may be more important than moose.
Discussion of the Impacts of Devil Canyon and the Access Roads.
AR -Are there any plans to quantify the impact of different alternative
construction methods?
Discussion of FERC • s Request to Emphasize Commitments Ove·r Options and
Recommendations in the license. Application.
KS -If the project is not clearly defined, with the associated impacts of
each decision, then reviewing the project is difficult.
WILDLIFE AND BOTANICAL RESOURCES GROUP - 5
AR -The construction method with the least impact should be strongly
supported.
GS -Are the costs of the different options included?
Ar -Exhibit E should contain a table of project impacts and corresponding
mitigation measures. All project aspects should be presented and
evaluated.
GS -It is important for the groups to keep up with any changes.
KS -Is there any mechanism to let agencies know of any changes?
Discussion of Decision Making Process.
AR -What was the level of communication during the engineering design?
Discussion of Formal and Informal Interactions.
GS-Access route has potentially severe impacts. Strong recommendation may
be made to FERC to change it. The road between the dams might change,
too, due to Native bargaining.
Discussion of the Impact of the Access Roads.
KS -There is not a direct relationship between caribou herd size and range
size. Management goals for the Nelchina herd are now +20,000, but that
could change. Changes in potential caribou habitat are important, even
if the population is not immediately affected. 70,000 is too high a
population for that herd caused a crash, however a higher ceiling is
being considered, 30,000-40,000. You should asstJme an eventual
population of 40,000.
LA-The population is presently increasing and will continue to increase
unless there is some regulatory change.
KS-When access increases, hunting demand will increase.
Further Discussion of Access Road and Traffic Patterns.
KS -Traffic data averaged over a year is not good enough. It is important
to know about peak traffic flows -when they occur and what the maximum
number of vehicles would be. The impact on animals depends on the time
of year.
GS -We need clear traffic data to be able to estimate impacts.
KS -The time of day of peak traffic might be more important than the time
of year.
WILDLIFE AND BOTANICAL RESOURCES GROUP - 6
AR -Suggestions aren•t being followed in the Terror Lake project. Need to
tie mitigation down, be specific.
KS -We should request some socioeconomic data on traffic predictions.
Discussion of Impacts of Railroad Traffic.
KS-Trains should be scheduled to minimize moose encounters. Scheduling
trains close together and using longer trains would also minimize
encounters.
GL -Have the effects of the access road mentioned earlier -roadside dust,
ATV use -been quantified in terms of loss of habitat or an·imals?
RF -Roadside dust could actually be beneficial~ causing earlier melting and
thus early browse.
KS -Impacts should be examined to determine if their effects are
significant.
Discussion of Mitigation Measures for Borrow Sites, Access Roads,
Transmission Corridors.
AR -Do Exhibit E transmission corridor studies include the intertie?
Helicopter construction was agreed to on some sections, but then
maintenance was not going to be done by helicopter. The result was less
~"""" helicopter use.
MG -How do these issues get dropped through the cr~cks?
AR The decisions are not written down. If it is written in the permit,
then it happens. But if only recommendations are made, then they aren•t
always followed.
Discussion of Areas of Uncertainty.
AR -Gray areas (where changes are possible) should be identified, so that if
things change we have some idea of the impacts of the new option.
Construction bids should include all details to make sure the
stipulations don•t get forgotten.
Discussion of Actions Outside Power Authority Jurisdiction.
LA-Ahtna has no plans to develop project area land if Susitna is built -
there is no cash incentive.
WILDLIFE AND BOTANICAL RESOURCES GROUP - 7
Discussion of Plan for Periodic Spring Floods.
AR -Has the plan for 30,000 cfs spring floods been discussed with the
aquatic group?
KS -How about the legal effect of causing destruction of property?
Discussion of Negotiations Required for Compensatory Mitigation Measures.
KS -Enhancement of moose habitat is possible, but some impacts cannot be
mitigated. Quantification of impacts is perhaps not too important in
these cases. General enhancement actions could be taken to preserve the
quality of the area (i.e. preserve Stephan Lake area from development).
Discussion of Monitoring Programs.
KS -the cost of mitigatian options is difficult to estimate. There may be
some trading of State land, and some outright purchase.
REVIEW OF DRAFT EXHIBIT E OF FERC LICENSE APPLICATION
WILDLIFE AND BOTANICAL RESOURCES GROUP
Tuesday, November 30, 1982
Room 225, Holiday Inn, Anchorage
-ATTENDEES
~·
-
Name
Lee Adler (LA)
Roseann Densmore (RD)
Bob Ever i tt ( BE )
Randy Fairbanks (RF)
Steve Fancy (SF)
Michael Grubb (MG)
Gary Liepitz (GL)
Ann Rappoport ( AR)
Martha Rayno l ds ( MR)
Karl Schneider (KS)
Robert Sener (RS)
Gary Stackhouse (GS)
Judy Zimi cki ( JZ)
Organization
Ahtna
Env irosphere
ESSA Ltd.
Envirosphere
LGL Alaska
Acres American
ADF&G
FWS
LGL Alaska
ADF&G
LGL Alaska
FWS
No. Ak. Environ. Ctr.
Address
Box 6 Copper Ctr.
Anchorage
Vancouver, B.C.
Seatt1e
Fairbanks
Buffalo
Anchorage
Anchorage
Anchorage
Anchorage
Anchorage
Anchorage
Anchorage
Phone No.
822-3476
277-1561
604-872-0691
206-451-4620
479-2669
716-853-7525
344-0541x281
271-45 75
274-5714
344-0541
274-5714
263-3475
277-2134
RS began the meeting with a description of the preparation of the Wildlife
and Botanical Resources sections of Exh-ibit E. Research reports from ADF&G
and the University of Alaska provided much of the data for the baseline
description. These data were substantially supplemented with a thorough
literature review. The impact section was prepared in a mann~r consistent
with the Susitna Project Fish and Wildlife Mitigation Policy. Impacts were
prioritized by:
1) percent of population affected;
2) certainty of impact occurring; and
3) severity of impact.
The mitigation section is still in progress.
Sf Following FERC • s request, the impact section assumed normal eng.ineering
practices with no special mitigation measures.
RS -Continued his description of the mitigation section.
KS-What do the February and June submittals entail?
John Hayden (JH) entered, and the question was deferred to him.
JH -We expect feedback from FERC on December 28, which will result in
correction of the document before the February submittal. FERC wi 11
WILDLIFE AND BOTANICAL RESOURCES GROUP - 2
have a 60-d ay review period, then any further requirements can be
addressed by June 30. We have 90 days to respond to FERC's request for
improvements. The June 30 document will be a response to FERC's
evaluation, not a total re-write of Exhibit E.
AR-How about after June 30? Will there be continuing studies?
JH -After June 30, FERC hopes to have enough data to be able to start an
EIS. FERC will then incorporate 1983 data as they come in from
fisheries, wildlife, and archeological studies. Approval could be
contingent on certain aspects of 1983 field data. Not until the EIS is
prepared will the agencies have an official comment time, probably in
fall 1983.
SF began the presentation of the baseline descriptions. He emphasized the
draft nature of the document, particularly the literature cited, the tables
and figures, and the mitigation section. An effort was made to be
comprehensive and supply all the background material that the reviewing
agencies wou 1 d need.
No endangered plant species were found. Vegetation maps are inaccurate, and
will be re-done with a more detailed classification system (still Viereck and
Dyrness) and large scale imagery.
LA -Is the Susitna Basin key winter moose range?
SF Yes, particularly when the snow is deep. Sampling revealed 20%
utilization of browse. This winter might reveal browsing patterns in
severe winters.
AR -Is a new classification system being used to help characterize moose
habitat?
SF -No, still Viereck and Dyrness, but past Level 3 to subcategories. The
goal is to stratify browse so that heavy and light browse areas can be
separated.
RF -Was all vegetation mapping described in Exhibit E done from 1:120,000
1980 U2 photography?
SF -Yes.
AR -Does Exhibit E contain all work completed up to this point, so that new
data will go into the June 30 document?
RS -Yes. We will indicate work in progress if it is not complete.
-
-
WILDLIFE AND BOTANICAL RESOURCES GROUP - 3
SF Described the ground truth data available. No endangered wildlife species
were found except 2 transient peregrine falcons sighted in 1974.
Prioritization of species: 1) moose, 2) caribou, 3) brown bear, 4) black
bear, 5) other big game, 6) furbearers, 7) raptors, 8) waterfowl, and 9)
other birds and small mammals. Moose in the middle basin were studied
separately from moose along the downstream floodplain.
KS-New census this full showed more moose in the Susitha River downstream
of Devil Canyon than have ever been measured there before.
SF described moose calving areas, food habits, and mortality. A strong
relationship was found between calf mortality an~ snow depth. Brown bear
predation was also important.
KS -Black bear predation is important as well. Early green-up of vegetation
in the river valley may be important to cows that are about to calve,
even if the area is not a true winter range.
SF discussed the Nelchina Caribou Herd, its present and historical size and
range, traditional calving areas, and its subgroups. He then described Dall
sheep in the project area.
KS -Sheep sighted in the Watana Mountain -Grebe Mountain area are probably
a subgroup of the main Ta-lkeetna Mountains group. The number within the
Susitna watershed could vary.
SF discussed brown bear, their denning habits, food sources, density
estimates for the impoundment areas and downstream.
KS -Yes, one would expect brown bear populations to decrease downstream due
to poorer habitat and lower elevation.
SF discussed brown bear productivity and hunter harvest. He then discussed
-black bears, their distribution, denning habits, food sources, and mortality.
He further described the wolf packs of the middle Susitna basin, the lack of
coyotes, the ranges and densities of wolverine, and the studies of belukhas
in Cook Inlet.
KS -Belukhas feed on anadromous fish. Smelt runs in Cook Inlet are also an
important food source. Have they been studied?
15 Minute Break
SF continued his presentation with the baseline descriptions of beaver,
muskrat, marten, red fox, lynx, coyote, and weasels. He then described the
field work that has been done to characterize birds in the project area
135 species were recorded in the middle basin, including, in 1981, active
nests of 6 golden eagles, 5 bald eagles, 1 gyrfalcon, 2 goshawks, and many
raven. Relatively low numbers of waterfowl were found in the middle basin.
WILDLIFE AND BOTANICAL RESOURCES GROUP - 4
The data from these years of small mammal trapping were used to characterize
these species.
AR -What is your perception of the completeness of the baseline information?
How about information on population increases or decreases, or the
quality of the habitat?
SF -Much of that information is included in Exhibit E.
AR -Are there any gaps in that type of information? Are the data being
gathered? When will they be available?
SF -Yes, some gaps have been identified.
RS -We are still trying to determine which gaps are most important and
design the 1983 field season around these data needs. We have made
preliminary recommendations to the Power Authority, but the actual
program is still being worked out.
SF -We are expecting input from USFWS and other investigators.
RS-Technical meetings between now and December 6 should also provide some
input.
SF -Ann, do you have any particular data gaps in mind?
AR-No, since I haven•t had time to read Chapter 3 yet, I don•t know what•s
already covered.
KS - I hope we can get the 1983 field program set up this winter. All issues
should be identified.
AR -r•m glad to see the vegetation mapp-ing is be-ing re-done and that you are
not just accepting the inadequacy of the earlier data.
SF -The new vegetation maps will change some of the wildlife population
estimates that are based on densities.
AR -Will the original researchers (principal investigators) be given the new
vegetation maps to rework their data?
SF -All the data will be reworked, but not necessarily by the original
researchers. The new vegetation maps will be digitized.
RS -Early planning for field studies will be important, especially if this
is the severe winter we have all been waiting for. We need a
contingency plan to see where the moose are during a severe winter, and
to conduct early spring vegetation studies to check the importance of
green-up for moose.
r-WILDLIFE AND BOTANICAL RESOURCES GROUP - 5
.-AR -Are there any bear studies being planned?
-
SF -Yes, but those studies will be done in August, so there•s more time for
planning.
SF then began a description of the impacts of Watana development on moose.
Prioritized impacts included: 1) permanent loss of habitat, 2) blockage of
movement, 3) disturbance, 4) accidental mortality, 5) alteration of habitat,
and 6) increased hunting mortality.
AR -Hunting regulations are political, and thus are not predictable. Unless
recommendations are actually part of the license, they will not
necessarily be followed.
KS -Project personnel are easier to regulate than the public~ Many
different regulatory options are available. Permitting to restrict
harvest is easier than closing the road.
RS-The license application can state what the Power Authority will do, but
can only state options for issues under ADF&G jurisdiction.
LA-Has any consideration been given to regulations that Native corporations
may impose? They can control access -trespass -but can•t directly
regulate hunting.
RS -This is another issue that is not directly under Power Authority
jurisdiction. We are not presently planning to discuss options open to
private landowners.
SF resumed the discussion of moose impact. Two approaches are being used to
predict impacts to moose: a population based assessment, and a habitat based
energetics model. To determine the quality of moose habitat, energy and
protein content of browse must be known. Vertical distribution of browse,
and consequently the amount available at different snow depths, is also
important. In order to get this data, trial moose browse sampling studies
will be conducted in the field next summer and the vegetation of the area
will be re-mapped to identify variation in moose browse potential.
AR -Both summer and winter vegetation sampling will be necessary to
accurately determine energy and protein content of browse.
SF agreed, though most work would have to be done in the summer when the
whole plant was available for sampling; some sampling would have to be done
in the winter. Brown bear predation and critical winters are probably two
factors limiting moose population. A large browse sampling program is
planned for the summer of 1984, the data will be worked up that fall, then
mode 11 i ng wi 11 be done the next spring (1985).
WILDLIFE AND BOTANICAL RESOURCES GROUP - 6
AR -The document (Exhibit E) should clearly describe any work that is going
to be done, and its schedule.
SF -We are also working on mitigation and enhancement techniques, and
identifying candidate areas.
KS -Compensation may be the main mitigative technique for moose.
SF described impacts to downstream moose. Changes in vegetation succession
should favor moose during the license period. Frozen condensation on
vegetation due to open water could reduce browse availability. Open water
could cause changes in plant phenology and will act as a barrier to moose
movements.
Although caribou are excellent swimmers, the impoundment may influence their
movements, as may ice shelving and drifted snow. Long-term monitoring
programs will be necessary to determine impacts.
RF -How is FERC going to respond to this lack of specificity with respect to
caribou?
KS -These types of impacts are difficult to mitigate except through the no
project option. Out-of-kind mitigation will be discussed after the
impacts have been assessed during construction and operation.
RS-FERC realizes the limitations of biological prediction and would prefer
no numbers to unreliable numbers. Indicating that further
investigations will be done is acceptable, if sufficient detail is
provided.
SF discussed the impact of borrow areas on caribou, then went on to Dall
sheep. The two major impacts on Dall sheep are: 1) aircraft disturbance,
and 2) inundation of 20-40% of Jay Creek mineral lick. The consequences of
the inundation of the lick are not certain.
KS -It might be useful to do some slope stability studies of the lick.
Inundation might even enhance it through erosion exposing fresh mineral
so·i 1.
30 Minute Lunch Break
SF continued the description of impacts likely to result from Watana
development. There will be no poplation effects on brown bear due to
facilities or borrow areas. However, the impoundment might alter movement
patterns. Any mitigation measures to enhance brown bear populations will
conflict with moose mitigation since brown bears are their predators.
The resident bear black bear population in the Watana area could be
eliminated due to the inundation of den sites. The transient black bear
-
WILDLIFE AND BOTANICAL RESOURCES GROUP - 7
population might be affected by decreases in salmon runs.
KS -Both bear species use several different, scattered food sources which
will be more or less important in different years. Pinpointing the
factor limiting bear populations is difficult, consequently the effect
of the dam is difficult to predict.
SF -No known wolf dens or rendezvous sites will be flooded. Disturbance
during the denning season could cause increased pup mortality.
KS -Activity sensors on wolves showed that heli~opters caused reactions, but
the wolves, even one in a den with pups, becom~ habituated. Good data
are available on the optimum time of day and season to minimize
disturbance.
SF -Human harvest of wolves seems to be the limiting factor, not food
supply. The same is true of wolverines.
Impacts on belukha whales could occur through changes in water temperature on
fish runs, as has been shown for the St. Lawrence River. Neither is expected
to change detectably at the Susitna mouth as a result of the project. Bears
are expected to benefit from downstream flow regulation. Marten will lose
habitat and are also expected to suffer from increased trapping pressure.
More precise data 'On the altitude of raptor nests is necessary to quantify
impacts. Possible mitigation methods include: 1) building new nest
structures, 2) moving nests, 3) exposing new nesting rock by blasting, 4)
building artificial cliffs, or 5) topping trees to improve their nesting
potential.
Waterfowl should benefit from the increased open water. Other birds and
small mammals will suffer from habitat loss. Some species will benefit from
the mitigation measures proposed for moose.
AR -Looking at the project as a whole, is wildlife diversity being
maintained or are moose being favored to the neglect of other species?
In some areas different species may be more important than moose.
SF -Other species are being considered, but there has to be some
prioritization of species.
Impacts due to Devil Canyon are similar to those expected to result from
Watana development, but generally less severe because of the smaller size of
the impoundment and the steeper slopes of inundated terrain.
Transmission line impacts will be minimized by constructing in the winter
time or using helicopter support. Some trees will be cut, but brush will be
left -no clear cutting.
WILDLIFE AND BOTANICAL RESOURCES GROUP - 8
AR -Do you have any p 1 ans to quantify the impacts of different alternative
construction methods?
RS -No, Chapter 3 is not supposed to review options, but rather to present
the impacts of the chosen option.
KS -If the project is not clearly defined, with the associated impacts of
each decision, then reviewing the project is difficult.
AR -The construction method with the least impact should be strongly
supported.
GS -Are the costs of different options included?
AR -Exhibit E should contain a table of project impacts and corresponding
mitigation measures. All project aspects should be presented and
evaluated.
GS -It is important for the reviewing groups to keep up with any changes.
KS -Is there any mechanism to let agencies know of any change?
RS-The Power Authority would do that. Decisions such as the access road
design speed have been changed due to environmental involvement, and we
have written Chapter 3 according to the new decision, but we haven't
seen the maps from R&M incorporating that decision yet.
AR What was the level of communication during the engineering design?
RS -We have had formal interaction by memorandum (RS passed around several
examples), and also much informal communication in meetings with project
engineers.
GS -The access road has potentially severe impacts. A strong recommendation
may be made to FERC to change it. The road between the dams might
change also, due to Native bargaining.
RS -That would not be surprising, since the environmental issues really
haven't changed. However, we are writing Exhibit E as if the decision
on access was firm, and ·including mitigative measures relevant to the
route in question.
SF described the impacts of the access road including increassed hunting
pressure, increased road mortality, increased disturbance, increased ATV
use.
KS -There is not a direct relationship between caribou herd size and range
size. Management goals for the Nelchina herd are now +20,000, but that
could change. Changes in potentia 1 caribou habit at are important, even
if the population is not immediately affected. 70,000 is too high a
population for that herd, and historically caused a population crash.
-
WILDLIFE AND BOTANICAL RESOURCES GROUP - 9
However, a higher ceiling of 30,000-40,000 is being considered and
should be used for your planning.
LA-The population is presently increasing and will continue to increase
unless there is some regu,atory change.
KS-When access increases, hunting demand will increase.
SF described the potential effects of the access roads on caribou. Predicted
road traffic levels are low: 20-30 trucks/day.
KS -Traffic data averaged over a year is not good enough. It is important
to know about peak traffic flows: when they occurr and what the maximum
number of vehicles would be. The impact on animals depends on the time
of year.
GS -We need clean traffic data to be able to estimate impacts.
KS -The time of day of peak traffic might be more important than the time of
year.
AR -Suggestions are not being followed in the Terror Lake project. We need
to tie mitigation down, to be specific.
KS -We should request some socioeconomic data on traffic predictions.
AR -The access plan includes a railroad which will also have an effect on
moose.
SF-In Canada, plowing railroad tracks with a wide plow that left no berm
did not decrease moose mortality. Eighty additional train cars per week
will be travelling as a result of the project.
KS-The trains should be scheduled to minimize moose encounters. Scheduling
trains close together and using longer trains would also minimize
encounters.
GL -Have the effects of the access route mentioned earlier -roadside dust
and ATV use -been quantified in terms of loss of habitat on animals?
RF -Roadside dust could actually be beneficial, causing earlier melting, and
thus early browse.
KS -Impacts should be examined to see if theytre significant.
RS described in-kind mitigation. Borrow sites will be upland areas
preferentially. First level terraces will be mined using draglines.
Guidelines to minimize ·impacts of borrow areas were described. Locations of
borrow sites for Watana and Devil Canyon dams were also described.
Guidelines for camp facilities, access roads, and transmission lines were
reviewed.
WILDLIFE AND BOTANICAL RESOURCES GROUP -10
AR -Do Exhibit E transmission corridor studies include the intertie?
RS -Yes, but most of the data is from the Environmental Assessment Report
prepared by Commonwealth Associates.
AR -Helicopter construction was agreed to on some sections of the intertie,
but then maintenance wasn't going to be done by helicopter. The result
was less helicopter use.
MG -How do these things get dropped through the cracks?
AR -The decisions are not written down.
JZ -It is not clear exactly when the decisions are made.
AR -If a decision is written into the permit, then it will happen. But if
only recomendations are made, they often aren't followed.
RS -The scope of work for subcontractors has to be very detailed. Salary
and schedule provisions should be established in the design consultants•
contracts to facilitate their working as a team with the project
environmental specialists. At present, a few gray areas still exist -
the regulation of access by workers during construction, extent of
clearing and helicopter support for building and maintaining the
transmission corridor. But these are basically policy decisions.
AR -These gray areas should be identified, so that if things change, we have
some idea of the impacts of the new option. Construction bids should
include all details to make sure the stipulations don't get forgotten.
RS -So far we have only prepared guidelines, but our portion of the
application assumes that they will be followed. There is an important
need for consistency, to make sure the commitments are really acceptable
to all parties, and are reflected in all sections of the license
application.
RS went over the list of environmental guidelines, which are included as an
appendix of Chapter 3 in Exhibit E. Management decisions by some
organizations other than the Power Authority will have an effect on
mitigation plans: ADF&G, USFWS, BLM, etc.
LA -Ahtna has no plans to develop land if Susitna is built -there is no
cash incentive.
RS discussed the recreation plan developed by EDAW, which includes phased
implementation, with interagency review and concurrence between phases. He
described biological input to that plan.
SF discussed ~sing periodic flood releases (30,000 cfs) to mitigate for
maturation of downtream floodplain vegetation.
-
-
WILDLIFE AND BOTANICAL RESOURCES GROUP -11
AR Have these plans been discussed with the aquatic group?
KS -How about the legal impacts of causing property destruction?
SF -These questions and others such as candidate areas and alternative
methods for habitat enhancement will all take lots of negotiation.
Ideas such as controlled burning, irregular selective logging,
vegetation crushing are all being considered.
KS -Enhancement of moose habitat is possible, but some impacts cannot be
mitigated. Quantification of impacts is perhap~ not too important in
these cases. General enhancement actions could be taken to preseve the
quality of the area, such as proserving Stephan Lake from development.
RS -FERC is interested in the mitigation process that is being set up,
including long-term monitoring studies. They want a description of the
program, expected products, and the schedule.
RF - I •m interested to learn specifics of what wi 11 be in the FERC license
application, and FERC•s response to non-specificity.
RS -FERC wants a mitigation plan, not a plan for a plan. However, FERC
realizes that some aspects of planning may be beyond the Power
Authority•s jurisdiction. They are also interested in cost estimates
for the mitigation plan.
KS -The cost of mitigation options is difficult to estimate. There may be
some trading of State land, and some outright purchase of compensation
lands.
RS -Some measures are easier to assign a cost to, such as engineering design
modifications, incinerators, and other points mentioned in the
environmental guidelines. The cost of long-term compensatory measures
is much more difficult to ascertain, especially since some decisions
won•t be made until later in the project.
WETLANDS MEETING
Thursday, December 2, 1982
Holiday Inn, Anchorage, Alaska
ATTENDEES
Name Organization Address Phone No.
Bruce Bedard (BB) Alaska Power Authority Anchorage 276-0001
Roseann Densmore (RD) Envirosphere Anchorage 277-1561
Richard Fleming (RF) Alaska Power Authority Anchorage 276-0001
Chris Godfrey (CG) USCE Reg. Functions Anchorage 552-4942
Michael Grubb (MG) Acres American Inc. Buffalo 716-853-7525
Jon Hall (JH) USFWS, NWI Anchorage 263-3403
Priscilla Lukens (PL) Acres American Inc. Anchorage 276-4888
Dave McGillivary (DM) USFWS, Regional Office Anchorage 276-3800
Ann Rappoport (AR) USFWS, WAES Anchorage 271-4575
Martha Rayno 1 ds ( MR) LGL Alaska Anchorage 274-5714
Ted Rock we 11 (TR) USCE Reg. Functions Anchorage 552-4942
Robert Sener (RS) LGL Alaska Anchorage 274-5714
Bill Steigers (BS) U of A, Ag. Exp. Sta. Palmer 745-3257
Judy Zimicki (JZ) No.Ak. Environmental Ctr. Anchorage 277-2134
RS introduced the meeting. He discussed the ambiguity of the wetlands
classification system used in previous mapping. The goal of this meeting was
to come up with a practical method of defining and mapping wetlands to
facilitate USFWS review and Army Corps of Engineers (USCE) permitting under
Section 404 of the Clean Water Act and possibly Section 10 of the Rivers and
Harbors Act of 1899, and to aid facility siting. LGL is looking into the
possibility of incorporating wetlands mapping as part of the vegetation
re-mapping program.
MR presented a summary of wetlands work that has been done to date. Some
work was done to characterize aquatic vegetation of ponds in the project
area. That work has been presented as part of Chapter 3 in Exhibit E.
Wetlands mapping was done using the Cowardin classification system of the
U.S. Fish and Wildlife Service (USFWS). Two sets of maps were produced.
One, at a scale of 1:24,000, consists of 7 maps of the two impoundment areas.
The other, a set of 3 maps at a scale of 1:63,000, mapped alternative access
routes. Vegetation maps of the same scale were used as base maps. A system
for converting Viereck and Dyrness vegetation classes to Cowardin vegetation
classes was developed (see Table 46, Phase I Report, Plant Ecology). Using
Cowardin•s definition of wetlands, all wet herbaceous, all shrub, and all
forest vegetation-types were mapped as potential wetlands. A subjective
judgment of slope was made to eliminate steep, well-drained areas. No
re-interpretation of the imagery or ground truthing was done.
JH, when asked how USFWS maps wetlands, replied that they use aerial
photography, following the Cowardin system, look for one of three
characteristics: flooding, hydrophytes, or hydric soils.
r
i
WEllANDS 1"1EETING - 2
RF -According to Cowardin's definition then, wetlands were appropriately
mapped for the Susitna Project.
JH -Some plant species occur only in wetlands. Many, however, occur in both
wetland and upland areas. Then you ha\<e to look at the other criteria.
RS -In order to identify procedures and criteria for wetland mapping, we
need to know if the Corps accepts Cowardin for Section 404 permitting.
TR -We accept and use Cowardin, but it is not always sufficient for Section:
404 decisions. Often the USCE jurisdictional boundaries are different
from the wet 1 and bound aries. The Nat ion a 1 Wet 1 anels Inventory (NWI) maps,
are at a good seale for 1 arge projects. However, we often need soi 1
data because all three parameters (flooding, hydrophytes, and hydric
soi 1) are necessary to define USCE wet 1 ands. The Corps a 1 so needs
hydrologic data to know how a given wetland ties into the watershed.
~ Rf -The huge scale of the project area (over 60,000 acres) makes it
difficult to map. How, much sampling would be necessary?
TR -Sampling areas can be representative of other areas. 1"1aps are only
needed of impact areas: roads, borrow sites, camp sites, etc. No
wetlands maps of the impoundment areas are needed.
r JH For USFWS, you do need wet 1 and maps of the impoundment area.
.....
Rf-No need for soils maps of the impoundment.
JH -Slopes should not be arbitrarily excluded from wetland categories.
Larger scale color infra-red photography should have been used. In the
Tanana River basin, USFWS is using the Viereck and Dyrness
classification system and a wetlands modifier to map the area. The
result,ing map is easy to convert to the Cowardin classification system.
The water regime modifiers in Cowardin's system are especially useful to
USCE.
RS -Remapping of vegetation wi 11 be done to Lev e 1 3 and beyond for moose
browse vegetation types.
RF -For most areas, we have vegetation maps and slope is available from
contour maps. Might ne~d more soil work •
TR -Once we have maps of the vegetation, hydrolog,y;, and project impacts,
we' n be able to, see where more data such; as soil types is: necessary.
RS -Are. the so<i 1 pate>ameters IJSCE needs available from engineering borings
and soil pits?
WETLANDS MEETING - 3
RF-Some soil maps exist, though I don 1 t know their scale or adequacy.
RS -The Soil Conservation Service has not mapped all of the Susitna area.
Several questions still need to be answered:
1) Appropriate level of detail of vegetation mapping to be useful for
wetlands classification?
2) What soil parameters are important to USCE?
JH-Even Level 4 of the Viereck and Dyrness system doesn 1 t allow direct
conversion to wetland categories. Often, other data are needed.
TR-Ground truthing will be very useful. The IJSCE personnel who will be
responsible for permitting should go along.
RF -What time of year is best for ground truthing?
TR -Anytime during the growing season.
RS The people doing the vegetation mapping will be working on the ground
truthing next summer.
JH -With a group of people who are familiar with the area, we should be able
to sit down with the USCE and a wetlands map and decide which areas need
USCE permits and which areas are marginal and need ground-checking.
RS -Is it proper procedure to involve USFWS and USCE in the preliminary
process and ask you to review drafts?
JH -I 1 d be glad to work with you.
TR -Yes, certainly, we prefer it that way.
BB -Have you discussed the types of permits required? They are:
USCOE Section 404-all waters of the U.S.
II II Section 10 -navigable waters -below Devil Canyon.
U.S. Coast Guard -navigable waters -south of Portage Creek.
TR -The USCE definition of navigable waters may not be the same as other
agencies. If Section 10 jurisdiction hasn 1 t been taken yet by USCE,
then it will not be.
RS -We need to alter the approach to vegetation ~apping to be sure to
distinguish wetlands. We may need to map more vegetation types beyond
Leve 1 3.
RF -Only ·in .access and transmission corridors.
WETLANDS MEETING - 4
RS -We can restrict the mapping to known corridors and impact zones. The
major borrow areas for the dams have also been identified. The borrow
,_ areas for the access road have not been fi na 1 i zed, but some potentia 1
borrow areas have been indicated.
RF -Those potential borrow areas aren•t likely to chang~ much.
RS -What should be included in FERC application? I would suggest:
1) Wetland maps already prepared.
2) Discussion of their preparation and coverage.
3) Plans to rectify problems.
4) Revised maps coming later. (The new maps can be submitted as
supplements when they are done).
~IH - I wou 1 d be concerned about inc 1 ud i ng the o 1 d maps.
TR -Could you modify the old maps by double-checking them with some aerial
photography?
RF -Might be possible, but probably not by February 15.
JH -It would only take 3-4 days to map wetlands in the whole area
(impoundments only). The cartographic work, however, would take awhile.
From the slides (John Hayden•s talk on Monday), upland wetland areas
looked fairly easy to define.
RS -We want to confirm to FERC that we are handling wetlands thoroughly. We
should list soil features that will be supplied to USCE.
TR -USCE needs soil profiles, from the litter layer down to ground water,
depth to ground water, chroma, mottling, gleying, soil type, location of
soil pits. Primary interest is in the root zone, the top 18 11
-24 11
• We
would be glad to work with any field personnel for a few days to explain
the USCE requirements and sampling methods.
TR - A few days work should give us a fairly good jurisdictional map.
JH -The first step would be a wetlands map; regulatory wetlands will be a
-subset of that.
-
-·
TR -Final COE regulations are expected by December 15. Our jurisdiction
could change.
DM -JH might be interested in talking to Dr. Talbot who did some vegetation
sampling in the Susitna basin several years ago.
WETLANDS MEETING - 5
AR - I would like to clarify the timing -the vegetation maps will be drawn
up first, so there wi 11 be no new maps by February 15. Would the new
wetlands map be ready by June?
RS The vegetation and wetlands mapping will take all spring. We hope to
have the preliminary maps by June 30. Ground truthing wi 11 be done
during the suiTITier, then the final maps will be dr,awn up. FERC has
stated that they will welcome any new data or maps after the June 30
submittal.
RS -To summarize our agenda:
1) Get together with Jon Hall and Ted Rockwell to identify
appropriate level of detail for vegetation mapping.
2) Clean up previous wor,k using aerial photography.
3) Prepare discussion of mapping, past and future, for February 15
submi tta 1.
4) Coordinate with USCE to get soils data.
5) Summer ground truthing.
6) Fall: final maps available.
TR When do you expect to need the first USCE permit?
RS -For building the access road.
MG -Access road construction is scheduled to begin spring 1985.
TR-After the final maps are available in late fall 1983, there will still
be time for further field work in the summer of 1984. If construction
begins before 1985, then all permit fieldwork has to be done next
summer.
RS -There may be wetlands perm·its requir-ed for test drilling and other
pre-construction field activities that are planned for next summer.
TR -If so, they should be identified this winter to avoid any permitting
delays.
BB-There will be a major staging area around Cantwell, widening the Denali
Highway, .and a transmission line from Cantwell to Watana. These
activities may also need permits. Will the Section 404 permits require
socioeconomic input?
TR -Section 404 is not strictly biological, but must also consider the
,public interest which includes socioeconomics, etc.
RS -How should wetlands be included in various sections of the FERC
application?
-
-
-
WETLANDS MEETING - 6
MG -The wh.ole wetlands section could be repeated verbatim in both the
Botanical and land Use sections.
RS - I would suggest that permit related discussions go into the Land Use
cfrlapter of Exhibit E, and biological discussions into the Botanical
Resources section of Chapter 3.
RS - I would like to set up a project/agency group that will work together on
a regular basis. (General agreement).
BB -Someone should look into the Section 10 question.
TR -I' 11 do that and use R:S and Rf as contacts.
AR -Any plans for future work on wetlands should be clearly laid out in the
application.
AGENDA
WATER USE AND QUALITY ANU FISHERY RESOUI{CES
Monday, November 29 1:00 P.M.
Introduction
Project Operational Description
Watana Dam
Dev i1 Canyon Dam
Access
Transmission
Schedule for Preparation of Exhibit E
Review Process and Group Definition
Tuesday, November 30 9:00 A.M.
9:00 -10:45 A.M. Baseline, Reservoir Filling and Post Project Flows
and Water Levels
10:45 -11:00 A.M. Break
11:00 -12:00 A.M. Reservoir and Downstream Sedimentation and River
Morphology Changes
12:00 -1:00 P.M. Lunch
1:00 -2:30 P.M. Reservoir and Downstream Water Temperatures
2:30 -2:45 P.M. Break
2:45 -4:30P.M. Ice Processes -Existing, Construction, Reservoir
Filling and Operation
Wednesday, December 1 9:00 A.M.
9:00 -10:45 A.M. Groundwater Upwelling and Water Temperatures in
Sloughs
10:45 -11:00 A.M. Break
11:00 -12:00 A.M. Other Water Use and Quality Concerns
12:00 -1:00 P.M. Lunch
1:00 -2:30 P.M. Fishery Phenology of Susitna River System
Impoundment, Devil Canyon to Talkeetna, Talkeetna
to Cook In let.
2:30 -2:45 P.M. Break
2:45 -4:30P.M. Presentation of 1982 Fishery Data
-
-
-
-
-
-
-
9:00 -10:45 A~M. F i s II e r y lu1p d c t s d rH 1 M i t i q J t i o n s -C ow; t r u c t i on
10:45 -11:00 1\.M. Break
11:00-12:00 A.M. Fishery Impacts and Mitigations -Reservoir
F i 11 i ng
12:00 -1:00 P.M.
1:00 -2:30 P.M.
2:30 -2:45 P.M.
Lunch
Fishery Impacts and Mitigations -Filling and
Operation
Break
2:45 -4:30 P.M. Fishery Impacts and Mitigation -Operation
Friday, December 3 9:00 A.M.
Summary Session -Reports by Each Group Leader
-Minutes of Meeting -
Subject: Susitna Hydroelectric Project Water Use and Quality and Fishery
Resources Workshop (see attached agenda)
Location: Holiday Inn (Anchorage Room)
Anchorage, Alaska
Attendees: see attached
Date: Tuesday, November 30, 1982 9:00 A.M.
Minutes recorded by: Michael P. Storonsky
I. Base 1 i ne ~ F i 11 i ng and Operational F 1 ows and Water Leve 1 s -Wayne Dyok
(Acres)
A) Summary
Mr. Wayne Dyok provided an overview of the existing, and the proposed
filling and operational flows and water level conditions aided by the
use of overhead view graphs.
B) Baseline Flow Conditions
(i) Flows
location of gaging stations
identified the process by which the 32 year flow scenario was
developed from the available data
-various Susitna River basin flow contributions to Cook Inlet
-monthly flow duration curves
• winter low flow provided by ground water
May -breakup occurs with substantial variation in flows
• August flows > 10,000 cfs approximately 97 -98% of the time
-1, 3, 7, and 14 day low flow frequency curves at Gold Creek
for July and August
-1, 3, 7, and 14 day high flow frequency curves at Gold Creek
for July and August
-I
I
r
Annual flood frequency curve at Gold Creek
. mean annual flood 49,000 cfs
(ii) Water Levels
-cross-section near Sherman at River Mile (RM) 131
. water level elevation with various discharges
6,000 cfs MSL 604 1
52,000 cfs MSL 611 11
C) Construction -Watana
( i) Flows
( i i )
-no interruption of flow
-a sill will be maintained during construction of the tunnels,
then removed when the lower tunnel is complete
-lower tunnel diameter 38 1
, between MSL elevations 1420 1 and
1458 1
thalweg of river MSL 1450 1
-upper tunnel for higher flows only
Water Leve 1 s
-winter
. pool maintained at elevation 1470 1
• backwater effect approximately 1/2 mile
-surrmer
. mean annual flood increase elevation from 1468 1 to 1520 1 at dam
. backwater effect 2 miles
D) Filling -Watana
-minimum flow requirements at Gold Creek
• November-April 1,000 cfs
-descr·ibed expected downstream flows, based upon pre-project
conditions for the three hydrological sequences: 10%, 50% and 90%
exceedence
. little difference during winter
• October significant difference during 1992
-Gold Creek choosen as representation of Talkeetna to Watana reach
-water levels at River Mile 131
. during August, with 22,000 cfs pre-project average vs. 12,000 cfs
filling average, there will be a 1 1/2 foot change
. approximately 3 foot change during early summer
however, maintain at least 2 feet of water in river channel at all
summer f 1 ows
-compared Gold Creek, Sunshine and Susitna Station and indicated that
differences in both flows and water levels will be moderated as you
progress downstream
E) Operation -Watana
-minimum downstream flows 5,000 cfs during winter
-post-project flows at Watana, Gold Creek and Sunshine
-Flow variability -Natural and Filling Conditions -Discharge at
Gold Creek
-Summarized operational change expected
• substantially increase winter flows
• substantially reduce summer flows
Question
Answer
Is there any upper limit to winter discharge and if so is
it based upon fisheries requirements or power demand?
-Maximum Watana powerhouse flows will be 19,000 cfs.
-no upper limit has been established yet
-it may be desirable in future to establish maximum winter
flow criteria
-Gold Creek post-project winter flows will average 10,000
-can probably establish a maximum winter flow of 14,000 cfs
at Go 1 d Creek
-Sunshine post project flow
• still substantial winter increase from baseline
• May and summer much closer to baseline
-Susitna Station post-project
winter substantial increase
summer -very little difference
-
-
....
F)
-
Question
Answer
Question
Answer
Answer
What is the difference between winter pre-project vs.
operational flows at Susitna?
14,000 cfs operational flow vs. 7,000 cfs pre-project,
therefore, winter flows will be doubled at Susitna Station
How will Watana operate if Devil Canyon is never built?
~ave impacts been assessed for Watana alone or with both
dams operational?
Watana will be base-load. Most of impact
assessment has been concentrated with both dams on line •
Consideration of peaking should not be ruled out. It is
possible to peak if only Watana is built. May have
sufficient attenuation of peaks downstream in a short
distance if peaks are of short enough duration, with only
minor impacts further downstream as a result of
attenuation.
Filling -Devil Canyon
2 stage scenario
-1st stage
. 76,000 ac-ft.
. fill within a couple of weeks
• maximum elevation 1,135 1
-one year at constant elevation 1,135 to plug diversion tunnel and
camp lete dam
-2nd stage
. fi 11 as quickly as possible
. fi 11ing wi 11 take approximately 5-8 weeks depending on energy
demand
25 foot drop in Watana water level
G) Operation -Watana and Devil Canyon
-Watana peak
-Devil Canyon baseloaded
-Devil Canyon outflow similar to with Watana alone
-Devil Canyon will experience approximately a 1 foot daily drawdown
with Watana peaking
H) Watana Drawdown and Flow Scenario Derivation
(i) Minimum flow requirements
- 7 scenarios studied
-no difference between winter flows; all 5,000 cfs
different summer flows
-August was determined the critical time frame because of the
need for salmon to gain access to the sloughs
(ii) Net benefit from project ($) vs. August flows
-10,000 cfs $1,220 x 106
-12,000 cfs $1,140 x 106
-14,000 cfs $1,050 x 106
-selected 12,000 cfs
• compromises economics somewhat
. provides a starting point upon which mitigation can be based
Question Are the economics of the project based upon the 1981
Batelle forecast?
Answer
Question
Yes
How would the benefits vs. flow scenario change if the
Batelle load forecast is incorrect and the load is
reduced?
I~
Answer Not able to answer without further investigation. (Ed. note
-shape of curve would basically remain the same.
absolute value of benefits would decrease with lower demand
forecast)
II. Baseline Slough Information -Woody Trihey (Acres Consultant)
A) Surmnary
Mr. Woody Trihey provided a description of a side slough in the Susitna
River including morphological characteristics (cross sectional profile,
gradients), flows, and water profiles with various flows.
B) Introduction -River System and Typical Slough
-river broken into 3 segments
-only discuss the Watana to Talkeetna segment
-will look at flow regime only, however, quality and availability of
habitat may also be affected
several different types of habitat in the river system
. mainstem
tributary
. side channel
. side slough
-will talk about side slough habitat only, potential for most impact
-currently evaluating August as most important time of the year
-typical slough and river sketch
. interim channels have eroded from river to side sloughs
. very often no water through the interim channels
-flows
sloughs typically clear water, low flows
. river turbid
• backwater effect at mouth of s laughs
-hi-gh flows
heads of sloughs can be overtopped at high flows causing turbid
flows
. flows up to l,OOO's of cfs during flood conditions
• flush out the fines
. act as a side channel during flood
------·--------------------------------~----------------------------------------
C) Slough 9
(i) Longitudinal profile
-noticeable gradient difference between upper and lower ends
. upper 18ft/mile
• lower
• river
5 ft/mile
11 ft/mi le
(ii) Flows and Stage
-irregular nature of the sloughs causes pools to occur at low
water
/
. discharge of 3 cfs. creates three pools of approximately
0.7 feet, 1.5 feet and 3.0 feet.
-staff gage at mouth of slough
. 11,000 cfs 590 1 MSL
. 33,000 cfs 594 1 MSL
slough profiles provided at various mainstem flows
• 12,500 cfs
16,000 cfs
. 18,000 cfs
. 22,000 cfs
. between 18,000 -22,500 cfs remove barrier to upstream areas
of the slough
. 16,000 cfs creates 0.25 1 depth for 140 1 length of slough
. 20,000 cfs creates 0.5 1 depth for 30 1 length
Question Where are the spawning areas in Slough 9?
Answer Some chum salmon were observed during 1982 above the first
barrier, however many were observed attempting to spawn at
the mouth of the slough. However, August 1982 had
unusually low flows of 11,000 -12,000 cfs and salmon had
difficulty attaining access to slDughs. Normally, flows
are in the 18,000 -25,000 cfs and access is not usually a
problem
!"""
i
F""
-
r
III.
r
A)
Question
Answer
Question
Answer
Question
Answer
Question
Answer
It looks like 14,000-17,000 cfs is needed to obtain
access to slough?
Yes, if only looking at flow, however utilizing engineering
techniques, backwater effects could improve access.
How did we arrive at 12,000 cfs? Don't we need flushing
flows to clean out sloughs?
We believe that this is a starting· point and that we are
progressing towards a set of unique flows for each month,
not there yet.
Isn't the backwater effect going to change with reduced
flows?
Yes
What percentages of sloughs with 12,000 cfs flows will
salmon have difficulty with access?
Can't answer right now, but should have a better handle
next summer.
Reservoir and Downstream Sedimentation -Mr. Brent Drage (Peratrovich,
Nottingham and Drage)
Summary
Mr. Brent Drage provided a description of the anticipated sedimentation
process in the reservoirs, among the major topics included were the
mechanisms influencing sedimentation, the existing situation, and the
expected changes in particle size distribution, suspended sediment
concentrations and turbidity.
B) Sedimentation Process Factors
-if 100% trap efficiency assumed, over 100 years, only 5% of the
reservoir volume lost, or 12% of active storage
-factors influencing sedimentation
• operational schemes
mean monthly volume
live storage volume
. dead storage volume
. change in surface elevation from the previous month
-driving mechanisms
• inflow
outflow
• flow thru velocity
• detention time
. ice cover presernt
• mean ambient temperature
• mean reservoir temperature
. thermal trend
• inflow temperature
• flow pattern
• mixing potential
• thermal current velocity
• wind driven current velocity
C) Existing Conditions at Gold Creek
(i} Suspended sediment concentrations
-minimum range 10 200 mg/l
-average range 200 -1,000 mg/1
-maximum range 2,000 3,000 mg/1
at Gold Creek -May -Sept.
(ii) Average monthly particle size distribution
-May, June, July and August
fine silt and clay particles less than 12 microns most
important
-
-
D) Expected Conditions
( i)
( i i )
(iii)
( iv)
Part i c 1 e size range pass in;g through
- 3 - 4 micron range particles wi 11 pass through during quiescent
conditions
-mixing act ion of wind and waves will al· low up to the 12 micron
size range to pass through the Watana Reservoir
Set t 1 i ng rates -Sto 1 kes Law
-assume quiescent conditions at 40 oF
5 micron glacial particle, 3.7 x 10 -5 ft/sec.
5 micron spherical particle, 4.3 x 10 -5 ft/sec.
Depth of particle settl-ing over time -quiescent conditions
-2 micron particle -400 days to settle 200 ft
-5 micron particle -60 days to settle 200 ft
-10 micron particle -20 days to settle 200 ft
Settling column study
-sample taken at Watana at flows of 17,200 cfs
-10 foot column
-350 mg/1 at time 0
-10 -20 mg/1 after 72 hours
(v) Effects of wind and waves
-wind waves will significantly effect settling within 25' of
surf ace
10 -12 micron particles wi 11 be re-entrained within the top
25 feet
-wind waves will effect at 50 1 depth signigicantly less
(vi) Preaiction of particle size distributions -using Camp's (1943)
solution
-gives us an idea of the size of the particles that will settle
and amount of s.ediment for different settling conditions
-results for maximum mixing, minimum mixing and quiescent
conditions
(vii) Results of deposit model runs
-maximum and average mixing
(viii) Turbidity vs. suspended sediment concentrations
-appears to be direct correlation
maximum mixing 100 -200 mg /1 = 20 -40 NTU
norma 1 mi x·ing 80 -120 mg/1 = 15 -25 NTU
minimum mixing 10 -30 mg/1 = 2 - 5 NTU
(ix) Literature search
Question
Answer
Question
Answer
-extensive search conducted, but not much information available
-however Eklutna Lake appeared to have the most similar
characteristics
What will the difference be between pre-project vs.
post-project turbidities during winter?
Probably safe to say it will be between 20 -40 NTU
post-project discharge.
Has input from other sources been included?
They were considered, but not included in the model. It is
expected that the material contributed from other sources
will be coarser and settle out shortly, contributions should
not be significant.
IV. Eklutna Lake Study -Steve Bredthauer (R&M Consultants)
A) Summary
Mr. Steve Bredthauer provided the following discussion regarding the
Eklutna Lake turbidity studies that were conducted due to the lake•s
close similarities to the Watana Reservoir.
-
-
B) Information Collected
-Kamloops Lake, British Columbia, information available
-sampling scheme at Eklutna
-results
• April under ice 7-10 NTU
. May isothermal 7-10 NTU
mid June starting to increase, 14 -15 NTU at the lower end of
reservoir
• mid July thermocline developing, plume ~as evident in the 10 -30
meter range at head of lake, down the lake-turbidity diminished
• September -unusual turbidity at reservoir bottom -flows probably
entering as underflow
-summary -Eklutna Lake data indicates the sedimentation process at
Watana will be heavily dictated by densities of the river and
reservoir waters
V. River Morphology-Steve Bredthauer (R&M Consultants)
A) Summary
Mr. Steve Bredthauer utilized overhead view graphs to facilitate his
River Morphology presentation which highlighted the basic morphological
systems of the river, a breakdown of the river by morphological reaches
concentrating on the river downstream of Devil Canyon and the expected
morphological changes.
B) Morphology of the River
(i) Four basic systems
-main channel
-side or split channel -(Sloughs)
-braided channel -floodplain 1-2 miles wide, large bedload
movement
-Delta Islands 50 -60 miles upstream of the mouth
(ii) Morphological reaches of the river
-upstream of Devil Canyon
. first 20 miles braided headwaters
. next 55 miles split channel
west from Tyone River to Devil Canyon dams ite-steep canyons
-Below Devil Canyon
RM 144 -149 -single channel
RM 139 -144
RM 129.5 -139
RM 119 -129. 5
-valley broadens, with split channel
well defined split channels, sloughs
-split channel configurations, stable
shoreline
RM 104-119 -well defined single channel
RM 95 -104 -Susitna-Chulitna confluence -braided system,
aerial photo comparison shows this section to
be a very dynamic area of the river
RM 61 -95 -braided, debris damming, very dynamic
RM 42 -61 -Delta Islands -rapid erosion evident
Rl~ 0 42 Yentna River confluence, major tributary,
of river flow
(iii) Expected Changes
-bedload movement curves
• 10-30 mm size range moved with 10,000-20,000 cfs flow
immediately downstream
40%
. armouring will allow a well defined stable channel to occur
-tributaries
analyzed 17 streams for degradation
. six were found to have potential problems with either
perching or degradation
-in summary the river wi 11 be better defined, more stable and
more deeply extrenched
-
-
-
-
VI. Eklutna Lake Water Temperature Study -Steve Bredthauer (R&M
Consultants)
A) Summary
Following lunch, Mr. Steve Bredthauer provided a discussion of the
results of the 1982 Eklutna Lake water temperature montoring program and
the Susitna River temperature data that is being and will be used to
calibrate the DYRESM temperature model for Watana.
B) Results -Eklutna
May 2S
June 18
July 2
July 14
July 2S
August 10
August 24
Sept. 9
Sept. 21
Oct. 14
Nov. 4
isothermal 4 -soc
a little surface warming to S°C
gradual warming
sharp thermocline in some areas, gradual temperature
variation in others, 12°C -soc
same as above
sharp thermocline maximum 13°C
15°C maximum, lessening thermocline
cooling
isothermal 7 -goc
isothermal 6 -soc
i sot herma 1 5 oc
C) Susitna River Data
average weekly temperatures at Watana gaging site
. October-April ooc
• May starts to climb
• maximum of 12 -l4°C during summer
-1981 temperature variations at Vee Canyon, Denali and Susitna Station
• warming with distance downstream
1981 Denali and Watana water temperature comparison
-1982 Susitna River vs. Indian River and Portage Creek temperatures
lower temperatures in tributaries than mainsteam
• temperature varies between tributaries
VII. Reservoir Temperatures -Mr. Wayne Dyok (Acres American)
A) Editor's Summary
Mr. Wayne Oyok provided a generic description of expected reservoir and
outflow temperatures during the filling and operation processes and the
DYRESM model used to estimate the temperatures.
B) Filling -Watana
-1st year fill fram 1470 1
-1800 ft
• outflow temperatures will be a composite of inflow temperatures
• low level outlet will not allow the normal temperature variation
-from autumn of the 1st year until powerhouse is available for use,
4°C temperature water will be discharged
. no mechanism for mitigation at this time
C) DYRESM Model
-investigated all available temperature models and found DYRESM to be
as good as any
used successfully in Australia and British Columbia
Question
Answer
How close will DYRESM model the Watana temperatures?
Currently working on it. We feel confortable with the summer
modeling that has taken place. Ice cover subroutine has some
bugs but we are working with the author to correct them.
D) Temperatures
(i) Reservoir temperature profile June 1 -September 30
-Eklutna Lake inflow water temperature 3°C
• glaciers very close to head of lake
-Watana inflow temperatures as high as l0°C
different thermal structures between the two reservoirs
-
,.,..
'
( i i )
Question
Answer
Question
-multi-level intake structures
• 4 intakes within upper 120' of the reservoir
Watana outflow temperatures
-July -mid September, we feel confortable that we can maintain
very close to natural temperatures
-mid-September-early winter, we will only be able to provide
4°C water
• 0°C water that naturally occurs will not be possible
• over the course of the winter, temperatures will drop to about
2°C
Where will the thermocline be during winter?
Probably very close to surface as was observed at Eklutna.
Within the first two meters the temperature was 3.6°C and
virtually isothermal below.
Are these downstream temperatures at the immediate outlet of
the project?
Answer Yes.
Question
Answer
Question
Answer
Discussed water temperatures at Williston Reservoir on the
Peace River where a gradual winter profile varying form 0°C
at the surface to 3°C at 300 feet existed.
Best guess when ice cover on reservoir will form?
Depends on wind conditions, ambient air temperatures, and
when an isothermal situation occurs.
Has the model been run for winter yet?
No, but we are estimating that outflow temperatures will
probably be between 2 -4°C.
Question
Answer
Investigations into the expected winds on the reservoir?
Will wind increase?
Yes, Lake Ontario has 20% higher winds than adjacent lands.
A lake this small may have about a 3-4% increase in winds
over what currently exists.
(iii) Devil Canyon Temperatures
-temperatures will largely reflect Watana temperatures
-DYRESM model not run yet for Devil Canyon.
VIII. Downstream Temperatures -Mr. Tom Lavender (Acres)
A) Summary
Mr. Tom Lavender provided a description of the Heatsim heat budget model
that is being used to describe expected downstream temperatures during
the various phases of the project.
B) Heatsim -Heat Budget Model for River Reaches
-streamwise, daily heat balance, reach by reach from prescribed
upstream boundary thermograph and inflow hydrograph
-uses: air temperature; vapor pressure; wind speed; solar radiation;
cloud cover; albedo; i.e., a complete heat balance
-accounts for: heat content of rainfall and snowfall, insulating
effect of ice cover on small (well mixed) reservoirs; hydraulic
mean depth and velocity of stream in each reach
yields: components of heat balance; net daily heat gain or loss to
river reach; inflow and outflow temperatures for reach; length of
ice-free reach (optional)
-based on (in large measure): J.M. Raphael, ASCE Journal of the Power
Division, V88, No. P02, p. 157, July 1962.
C)
-
-
-
-
-
Temperatures
-pre-project
-Watana alone
-Watana/Devil Canyon
Question
Answer
Question
Answer
Question
Answer
Question
Answer
Question
Answer
Question
Answer
Did you use the ice formation option of model to determine
ice cover formation location?
We will cover that in my next discussion
Analyzed temperature variations with mainstem discharge
yet?
We have not done a sensitivity analysis yet. During summer
probably not significant variation during winter could be
more significant.
If Watana peaks will it affect temperatures?
No not on a daily average basis.
What flows is the model based upon?
Normal operational flows expected, not minimum flow
requirements.
Need for sensitivity analysis with various climatic and flow
conditions?
Yes
Why multiple intakes at Devil Canyon if temperatures will not
be altered from Watana?
Two month residence time will create slight variations, try
to match outflow temperatures as close as possible to
natural.
Question Will there be additional graphics in the report that further
describe the expected minimum winter temperatures of 2°C+
when both projects are operating?
Answer Yes
IX. Ice Processes, Causes and Effects -Tom Lavender (Acres)
A) Summary
Mr. Tom Lavender presented a description of the major factors
influencing the ice processes, namely the hydrologic and thermal regimes
and their impacts upon the ice front location, water levels and the ice
cover.
B) Hydrologic and Thermal Regimes
-described existing variations throughout annual cycle
principal factor controlling the ice process is flows
described proposed hydraulic and thermal regimes
• flows will be smoothed out throughout the year
. thermal energy will be transferred from summer to winter
C) Ice Front Formation
(i) Natural lodgement points are a constriction in the river where
the ice cover formation process begins
-construction of the Watana dam will not affect the ice cover
formation process since a natural lodgement point exists
(ii) Temperature immediately downstream
-water temperature
. when bulk water temperature reaches O.l°C, ice will begin
to form at surface of river
-air temperature
• discussed ice front location with warm, average and cold
climatic conditions and regulated discharges
(iii) Expected ice front location
D) Water Levels Leading Edge Stability (Froude No.)
-Froude No. will be between 0.08 and 0.154
-gives the range of the change in the water surface elevation given
the discharge rate
• 3' -4' increased river stage between Sherman, and Talkeetna
-areas with an ice cover will experience increased stage levels
-areas without the ice cover may experience slightly lower stage levels
than normal winter conditions
E) Ice Cover Thickness
-effects of discharge
• thickness dictated to a large measure by discharge at the time of
freeze-up
F) Effects of Varying Discharges on Ice
-same processes govern spring break-up as govern freeze-up
-hinging of ice occurs with raised water level
Question
Answer
Question
Answer
Will there be an increased ice
thickness at Susitna Station due to doubled winter flows?
Yes
Will there be problems with ice breakup due to this increased
ice thickness?
No, due to the thermal degredat ion of ice in the upper
Susitna and the regulated flows.
Question
Answer
Question
Answer
Question
Answer
Question
Answer
Question
Answer
Question
Answer
Will increased flows and staging cause flooding of sloughs
during winter with accompanying increased ice thickness?
It will depend upon the elevation of the upstream berm.
Will the magnitude of breakup in the downstream reaches be
more severe or less severe?
Magnitude unknown. (Ed. note ~ breakup should be less severe)
Do you know if ice will form and where between Devil Canyon
and Talkeetna?
It will depend upon climatic conditions.
What will the stage increases be?
3' -4' increase between Sherman and Talketna.
Definitely have overtoppng of sloughs with these increases.
Will erosion problems occur with these increased flows?
None that don't already occur under natural flow conditions
with ice jams. With ice jams, velocities can reach 9 -10
ft/sec. Normally 3ft/sec velocity under ice is required
before the ice front can progress upstream.
Will any analysis be done of impacts to sloughs from ice
processes?
Talk to AEIDC, who will be handling the impact assessment.
No comment from AEIDC.
Question
Answer
-
How will sloughs be affected morphologically from ice
processes?
Have to do a detailed analysis of existing conditions first.
LIST OF ADDENDEES
WATER USE AND QUALITY & FISHERY RESOURCES
Holiday Inn, Anchorage, AK
Tuesday, November 30, 1982
Name Organization Teleehone
Wayne Dyok Acres 276-4888
Woody Trihey Acres Consultant 274-7583
Steve Bredthauer R&M Consultants 279-0483
Tony Burgess Acres 716-853-7525
Bill Lawrence U.S. EPA 271-5083
Brad Smith NMFS 271-5006
Len Carin USFWS 271-4575
Mary Lu Harle ADNR-Water Management 276-2653
Gary J. Prokosch ADNR-Water Management II
Ken Florey Fish & Game 344-0541
Eric Myers NAEC 276-4244
Tom Lavender Acres 276-4888
Tom Arminski Alaska Power Authority 276-0001
Steve Zrake ADEC 274-2533
Gary Lawley Harza/Ebasco 277-1561
John R. Bizer Harza/Ebasco .II
Jack Robinson Harza/Ebasco II
Leslie Griffiths Peratrovich,Nottingham,Drage 277-8633
Brent Drage Peratrovich,Nottingham,Drage II
Phil Brna ADF&G 344-0541
Bill Wilson AEIDC 279-4523
Ken Voos AEIDC II
Larry Moulton Woodward-Clyde 276-2335
Jean Baldridge Woodward-Clyde II
Michael P. Storonsky Acres 276-4888
Kevin Delaney ADF&G 344-0541
David Wangaard USFWS 263-3316
-Minutes of Meeting -
Subject: Susitna Hydroelectric Project Water Use and Quality and Fishery
Resources Workshop
Location: Holiday Inn (Anchorage Room)
Anchorage, Alaska
Attendees: see attached
Date: Wednesday, December 1, 1982 9:00 A.M.
Minutes recorded by: Michael P. Storonsky
I.
A)
Slough Access Mitigation Ideas -Woody Trihey
Summary
Mr. Woody Trihey presented some possible mitigation techniques that
should be considered for muintenance of adequate slough water levels,
namely increased mainstem discharges, amplication of backwater effects
at the mouth of slough, increased flow through the sloughs~ or
modification of slough channel and entrance.
B) Introduction
profile of slough discussed yesterday with flow effects on various
barriers to upstream movement
-pre-project August flows
. 18,000 + cfs very common occurence
. 10 -12,000 cfs very rare occurence, however these flows are
natural occurences in early September
flows of 12,000 will provide problems for fish to gain access
C) Mitigation Ideas
(i) Increase mainstem discharge
-variability of tributary inflow
• Project should not have significant effect on weather patterns
in river valley therefore, natural tributary variability would
occur and create downstream flows of 20 -25,000 cfs •
. Try to quantify the occurrence and magnitude of these
-use of controlled releases variable spikes
• duration and magnitude of variable spikes sufficient to avoid
attenuation and provide access
(ii) Amplify mainstem backwater effect
-submerge a sill downstream of mouth of slough
-construct dike to protude into mainstem and cause back water
effect in slough
(iii) Increase flow in slough
-collect and concentrate local surface runoff and channelize
-divert water from mainstem
-withdraw water from a local storage pond
• stored via natural runoff
. pumped from river
• pond could contribute to local groundwater upwelling
-increase groundwater inflow
(iv) Modify slough channel and entrance
-deeper entrance of some sloughs
have to be careful if deepening slough, spawning
habitat could be degraded since most spawning is in riffle
areas, need to maintain riffle/pool ratios
-constrict channel width, therefore deeper water levels
-submerged weirs, create pool and drop scenario
(v) Summary
-Mr. Trihey does not recommend any of above at this time,, but
providing them as possibilities for everybody to think about.
Question
Answer
Question -
Answer
Answer
How many sloughs are we talking about? number being used?
how many can we modify?
Get a better answer if you ask later, Tom Trent•s unit more
f ami 1 i ar
• 12 -15 sloughs quite heavily used -similar to slough 9
• trying to maintain the chum and sockeye fishery above
Talkeetna
• approximately 38 sloughs between Talkeetna and Devil Canyon
Are there problems with ice, with the use of weirs and
submerged sills?
Not advocating any of these alternatives, there could be
problems with ice. We have to look at all the various sloughs
more closely and evaluate the alternative mitigation more
thoroughly before deciding. Just trying to emphasize that
there are many ways to attain access to sloughs besides
increasing flow. A lot of work still needed.
Emphasized that he was only talking about access to the
sloughs and not the quality of habitat that will be
available.
May get variations in slough morphology due to ice processes
and flow. Look at the gradation of material and the ra·infall
events that might alter slough morphology.
Not a lot of change in sloughs expected, cobble size substrate
at most slough mouths, little change anticipated. However,
significant changes in tributary mouth morphology expected.
Ice processes are probably the primary force causing slough
formation.
Ice probably a major factor but flows can also work to form
sloughs.
High flows move sand and silts, but there is larger substrate
at the slough mouths and probably will not be greatly
altered.
Larry Moulton•s group will be discussing these thoughts in
further detail.
II. Groundwater Upwelling and Water Temperature in Sloughs -Tony Burgess
(Acres)
A) Summary
Mr. Tony Burgess presented a discussion on the various factors that
influence slough groundwater regimes, the investigations that have
occured, the modeling that has been conducted, and the conclusions that
have been drawn. In addition, he discussed the factors that influence
ground water temperatures and the impacts expected.
B) Introduction
(i) Slough morphology
-bar separates slough from mainstem
-bar may be overtopped
• as ice front passes through
• during breakup jams
• under open water storm discharge
(ii) Stratigraphy
-silt/sand up to 6 feet deep
-sand/gravel/cobbles/boulders -possibly occur with depth
-bedrock at unknown depth
• drilling to 40' has not reached bedrock
C) Groundwater I nves trig at ion
( i) Techniques
-walk overs
-test pits and installation of standpipes,
-soil drilling and installation of piezometers and glycol tubes
-observations of surface and ground~ate~ elevations, water
temperatures, slough discharge, seepage flux
(ii) Slough 9
-drill holes identified
-continuous monitoring
-Slough 9 overtops at approximately 20,000 cfs
-significant ice jam last winter -bulk of river flow went
through Slough 9 rather than through the mainstem
(iii) Seepage flux measurements
identified upwelling area
-estimate flux into sloughs
-haven't done many of these yet and haven't reduced data yet
(iv) Slough BA
-groundwater gradient approximately the same as river gradient
(v) Slaugh 9
-general gradient in downstream direction
D) Groundwater Modeling
-geometry, boundary conditions and material properties all influence
the constitutive relationships that in turn create a response
-constitutive relationships
• Laplace's equation
• Darcy • s law
Q = K i A
flow = (Hydrologic conductivity) (gradient) (cross section)
Flow lines orthogonal to and from river
-groundwater flows - 3 types
-geometry
. shape of area being mode 11 ed
. 3-D, 2-D (plan, cross section) 1-D (along flow line), thickness (D)
-boundary conditions
• values of dependent variables (head, flow) along boundaries
material properties
. hydraulic conductivity (K) (permeability)
. porosity (n)
• transmissivity (T = K x 0)
• storage coefficient (S)
-hydraulic conductivity
. laboratory grain size analyses with empirical formula
K = (100 to 150) x dlo2
. field tests in drillholes
constant head
falling head
pumping test
flow net sketching and discharge measurement
response of aquifer to well defined boundary event
-Grain size analysis of Slough 9 bank
. gravel and sand
-Slough 9 flow net
. identified flow lines
Hydrographic Response
. sudden change in mainstem water level influences the aquifer
looked at the response in the Slough 8 wells from a sudden change in
water level. Reasonable response on the increasing limb of the
hydrograph, however higher than expected water levels occurred on
the decreasing limb of the hydrograph. We will continue to
i n v e s t i g ate •
-Summary of Results
. grain size analysis
K = 6 x 10-2 cm/s
• field tests
not yet completed
-
r
-
• Flow net
T = 9000 ft-1 dm/x
for 0 = 100' (assumed)
K = 3.2 x 10-2 cm/s
• Hydrograph response
T = 1200 to 306000 ft2/d
for 0 = 100' (assumed)
K = 4.27 x 10-3 to 1.09 cm/s
-Modelling
• Groundwater flow
flow net sketches and hand calculations
finite element analyses using computer
. Temperature
no flow thermal regime
coupled groundwater-thermal regime
-graphic slough model
-contours -boundary heads
-flu xes
-contours
fixed heads in mainstem and sloughs
identified high bedrock and valley side slope
• remainder of slough constant saturated thickness
-Conclusions
. General groundwater regime can be modelled using 2-0 plan
idealization. Locally, match not so good: may be due to variation
in saturated thickness, variation in hydraulic conductivity, or
boundary recharge •
• Flow is generally downstream and laterally towards slough from
up 1 and areas.
E) Thermal Processes and Modelling
( i ) Baseline
-Susitna mainstem
• mid October to mid April 0°C
• maximum +10°C July
. Annual mean approximately 3°C
-Talkeetna air temperatures
. minimum mean monthly -13°C
• maximum mean monthly +14.5°C
. annual mean +0.5°C
-groundwater
• upwelling approximately +3°C
• wells 0.05°C (May) to 6-8°C (September), locally as high
as 11 °C
(ii) Preliminary conclusions
-Air temperature variations do not have a significant direct
impact on groundwater
-Upwelling t€mperatures nearly constant but shallow well
temperatures show seasonal fluctuation lagging main stem
-Upwelling temperature is approximately mean annual main stem
temperature
(iii) Dispersion
-Dispersion theory developed for contaminant transport
-apply to thermal problems by making temperature equivalent to
contaminant concentration
-dispersion occurs in all porous media. The extent of dispersion
increases as the medium becomes more heterogeneous
. diagrams of dilution variations with different materials
• example cited
(iv) Conclusions
-upwelling temperatures can be explained in terms of dispersion
(mixing) of mainstem seasonal variations within groundwater flow
path
-but why do near surface grounwater temperatures show less
mixing?
Possible factors:
• path length shorter
. gradient steeper
materials more homogeneous
-recent deeper drilling, piezometer and glycol tube installations
should provide important data
-
-
-
F) Project Impacts
( i )
( i i )
Geometry
May be some changes due to deposition and scour.
Material properties
Generally will not change except possibly due to scour/deposition
effects.
(iii) Boundary Conditions
River stage: higher in winter, lower in spring/summer with
less variabi 1 ity
-Temperature: mean annual little change, slightly higher in fall
and lower in summer.
(iv) Response to Stage Change
Based on data from September hydrograph, response is quite rapid,
in near surface wells. Deeper wells may respond slower due to
longer flow path.
(v) Effect of Stage Change on Extent of Upwelling
(vi)
Question
Answer
Could be modelled but unlikely that sufficient data (spatial
variation of K) available. Field monitoring and observation
preferred.
Mitigation
Not looked at yet
Will river stage be higher during winter or lower?
There could be lower water levels without an ice cover
depending on the particular circumstances. Ice cover will be
variable.
Question
Answer
Question
Answer
Question
Answer
Question
Answer
Both upper and lower water levels would drop equally therefore
the same gradients would still exist so groundwater flow will
continue but at lower elevations.
Does the storage of water in the gravel from late summer flow
provide winter groundwater flows?
Some water is stored. but not alot. There were rapid
responses observed in the wells due to mainstem discharges.
During October upwelling continued with a decreased discharge.
If there is not much storage from late summer flow. this would
indicate upwelling continues at low discharge.
A fair amount of upwelling occurred throughout February and
March.
Freezing near the banks cold be concentrating upwelling
towards the middle of the slough.
If you drop the invert elevation 3 - 4 feet would it intercept
more grounwater?
No, that only amounts to a small portion of the 2000 feet of
head upstream of the slough.
Is there a monitoring program envisioned for grounwater
upwelling?
Recommended continuous temperature and flow monitoring in
wells. Half-barrel technique to quantify seasonal variation.
So far only 1 field trip to a half-a-dozen locations.
Isn't there variability between the sloughs? Why only slough
9 investigated?
Trying to understand the processes, first. Now we can look at
other sloughs and determine the variability.
-
-
-
Question
Answer
Question
Answer
With post-project winter flows of 10,000 cfs, will the
location of ice formation dictate upwelling?
Probably not change upwelling, upstream and downstream
elevations experience equal change, therefore the gradient is
the same.
Will absence of flushing flows cause disturbances to upwelling
locations?
Only affect near surface sediment, may move upwelling area
slightly.
May shift location of upstream most upwelling areas.
III. Other Water Quality Concerns -Mr. Steve Bredthauer (R&M Consultants)
A) Summary
B)
Following an intermission, Mr. Steve Bredthauer discussed the balance of
the major water quality concerns including nitrogen supersaturation,
eutrophication, leaching, and dissolved oxygen.
Nitrogen Supersaturation
-caused by high plunging spills
-measurements above and below Devil Canyon indicate s~persaturation
currently exists
-project will employ fixed-cone valves to avoid plunging spills that
might create a problem
C) Eutrophication
-limited data available for the four nutrients, N, P, C, Si
-phosphorous is the limiting nutrient
-two methods available
• Dillon and Rigler model -rejected due to the limited ability to
estimate phosphorous retention coefficient
• Vollenweider model chosen -used at Crescent Lake, Alaska with good
resu 1 ts
-Vollenweider model used by Larry Pederson of Fairbanks
• predicted oligotrophic situation
• need approximately 115,000 residents dumping untreated waste into
Watana reservoir to produce eutrophic situation
D) Leaching
-increased concentrations of metals and other parameters immediately
after closure of dam
-decreased leaching with time -Watana
. buried with inorganic glacial sediment
• most readily dissolvable materials will dissolve first
-effects of leaching at Devil Canyon will remain longer
. little sedimentation expected
effects expected to be confined to reservoir bottom
-no significant impacts anticipated
E) Dissolved Oxygen
-decreased potential for oxygen saturation with increased depth
-COD coming into reservoir is low
-no vegetative growth expected along shoreline during drawdown
-no dissolved oxygen problems expected in the upper levels of
reservoirs or downstream
Question
Answer
If you expect the reservoir to act as a nutrient trap, how
will this effect the productivity downstream?
You do not see organisms taking aavantage of nutrients ·in the
mainstem since the nutrients are so low. Most organisms
taking advantage of nutrients in the system are in the
backwater areas and tributary mouths.
-
,....
i
r
Question
Impacts from reduced nutrient concentrations should not affect
the rearing that is taking place in the tributary. mouths.
Most primary and secondary productivity is occurring in the
side sloughs, side channels and tributary mouths.
Very high levels of hydrogen sulfide were observed at a hydro
project in southern Alaska. Is a simil'ar problem expected?
Answer No
IV. Summary of Water Quality Discussions Mr. Wayne Dyok (Acres)
A) Summary
Mr. Dyok provided a sumary of the water quality discussions of the last
day and one half including: flows and water levels, temperatures, ice,
suspended sediment and turbidity, and sloughs.
B) Flows and Water Levels
1. Construction: Impacts limited to immediate area of damsites
2. Filling: Winter flows -similar to natural regime except for
reduction in October and November 1992 at Gold Creek. Summer flows
-substantial reduction at Gold Creek. Downstream -reduced
percentage difference (maximum reduction 18 percent Susitna
Station). Stage reduction up to four feet May through July. Stage
reduction of about two feet during August, Talkeetna to Devil
Canyon.
3. Operation: Winter flows increased to about 10,000 cfs at Gold Creek
with extremes at 6,000 cfs and 13,400 cfs. Susitna Station flows
increased by a factor of two. Sumner Gold Creek flows reduced to
12,000 cfs during August. Susitna Station monthly flows reduced by
maximum of 13 percent. Water levels -Watana reservoir maximum
drawdown 120 feet. Devil Canyon drawdown up to 50 feet August and
September. Summer water levels Talkeetna to Devil Canyon reduced by
about two feet in August. Minimal water level changes downstream of
Talkeetna during summer.
Question
Answer
Where is the information on expected water level changes in
the Report on Water Use and Quality?
Not included, water levels changes will be addressed in final
document.
B) Temperature
1. Construction: No impact.
2. Filling: 4°C water at outlet during second year of filling. Gold
Creek temperatures could be as low as 6°C.
3. Operation: By selective withdrawal Watana outlet temperatures can
be made to approx·imate natural regime during summer. Fall
temperatures will be warmer than natural at outlet and for some
distance downstream. Winter outlet temperatures will ikely be
between 2°C to 4°C.
C) Ice
1. Construction: No impact due to natural lodgement point near
Watana damsite.
-
.....
-
2. Filling: Minimal impact bec~use natural flows are approximated
during freeze up and natural temperatures are attained at Devil
Canyon. Reduced ice jamming during spring breakup because of
decreased f1ows from Devil Canyon to Watana and thermal decay.
3. Operation: Approximately three to four foot increase in stage
during freeze up with effects to Cook Inlet. Reduced ice jamming
during breakup Devi 1 Canyon to Cook Inlet. Watana alone -ice front
will be between Sherman and Portage Creek. Watana/Devil Canyon -
ice front will be between Talkeetna and Sherman.
Question It was indicated that there will be a reduced ice breakup
downstream nearer to Cook Inlet. Is this correct, since there
will be an increase in ice thickness due to higher flows?
Answer
Question
Answer
Although there will be more ice, spring flows will be reduced
and therefore ice jams should be fewer and less severe.
Ice wi 11 be gone above T a·l keetna before the rest of the river
breaks up, therefore no ice going downstream from the upper
Susitna.
What effect will the change in flows and water levels have on
the estuary?
Resource Management Associates modeled the change in salinity.
The model indicated a 1 1/2 part per thousand (ppt) maximum
change from natural conditions. The salinity range under
project conditions is expectd to be less than which presently
occurs. This change is not expected to be significant.
-D) Suspended Sediment
r-
1
Particle sizes of three to four microns will pass through reservoir.
Approximately 80 percent of suspended sediment will be removed.
Turbidity at Watana outlet will be between 10 to 50 NTU. Lower sul11ller
turbidity. Higher winter turbidity. Downstream channel will remain
stable because of armoring.
E) Sloughs
-Backwater effects
-Surface water runoff?
-Groundwater upwelling -dominant flow in direction of mainstem flow-
upwelling flow rates basically unchanged although there is a potential
for dewatering spawning areas in upper locations of some sloughs that
are adjacent to ice free reaches of the mainstem Susitna.
-Groundwater upwelling temperature -function of long term average
annual mainstem Susitna River temperature.
Overtopping under post-project conditions where ice in mainstem is
adjacent to sloughs.
-Morphological changes?
Question
Answer
Have navigation and recreation impacts been addressed?
Yes, River divided into sections above and below Talkeetna.
Numerous cross-sections studied, no problems were immediately
identified above Talkeetna. However, one site located between
sloughs 8 an9 9 was difficult to navigate this past summer
with natural flow conditions. The area was navigable. During
post-project conditions caution will be needed in this one
section. The normal variations in river morphology that
currently occur below Talkeetna-probably will not be as
significant. Kayaking will be eliminated in the Devil Canyon
reach. Recreational boating on the reservoirs will be
available if the reservoirs are open to public.
Additional information available i~ the Recreation Report.
-
Question
Answer
Question
Answer
Question
Answer
Question
Answer -
-Question
Answer
Question
Answer
Increased stage impacts to sloughs from ice? Impacts to
sloughs from the thermal degredation of ice rather than the
flushing out of this ice that normally occurs? Impacts to
sloughs from lack of flushing flows to rid them of rotting
salmon carcasses and the putrification that will result?
If a major ice jam occurs, river flows could be directed
through s laughs.
What if no ice jams occur and the ice is not flushed out?
The ice cover will melt in place if there is no diversion from
the mainstem. It will disappear at a later date. Look at the
current system for ice blocks that thermally degrade to get an
idea of what will occur. Some ice blocks have been evident
until the end of June.
Can temperature model estimate these ice conditions?
Probably can with a combination of river temperatures and
groundwater temperatures.
Is there a problem for the salmon if the ice remains in the
sloughs?
Could be depending on the habitat and its type of use by
species involved.
How can we mitigate the putrification problem in sloughs?
Possibly flush system during wet years.
How often do we need to flush?
Don't know, a lot of variaiblity in the different sloughs.
V. Possible Flow Variations -Dr. John Hayden (Acres)
A) Summary
Dr. Hayden provided a brief impromptu discussion about possible
variations in river flows that might be available to benefit salmon.
B) Selective Flow Spikes
-spring, 6 days at 20,000 cfs to facilitate outmigration and flush
system
-summer, 12 days at 20,000 cfs to facilitate entrance to sloughs
-we have to learn more about the fishery system to determine the most
desirable time frames for these spikes
Statement We also have to keep in mind the other uses of the river,
i.e., recreation, when considering spikes.
Question
Answer
The impacts of increased temperatures on over-wintering fish
is not discussed in report. Increased temperatures will cause
increased metabolic rates in the over-wintering salmon without
an available food supply. As a result these fish could go
into the next spring in a weakened condition.
This will be addressed in the Fisheries Presentation.
We don't have enough information on the over-wintering
locations to assess impacts and provide mitigation at this
point ·in time.
.--
LIST OF ATTENDEES
WATER USE AND QUALITY & FISHERIES WORKSHOP {2nd Day)
Holiday Inn, Anchorage, AK
r-Wednesday, December 1, 1982
-9:00 a.m. Name Organization Telephone
,..... Jean Baldridge 1~oodward-Cl yde 276-2335
Michael P. Storonsky Acres 276-4888
Tom Lavender Acres II
Tony Burgess Acres II
Woody Trihey Acres Consultant 274-7583
Steve Bredthauer R&r~ Consultants 279-0483
Bill Lawrence U.S. EPA 271-5083
~~ Brad Smith NMPS 271-5006
Len Carin USFWS 271-4575
Mary Lu Harle ADNR-Water Management 276-2653
Gary J. Prokosch AONR -l.Jater 276-2653
Chris Godfrey U.S. COE-Reg. Function 552-4942
Ken Florey Fish & Game 344-0541
Eric Myers NAEC 276-4244
John Wiles State Parks 264-2115
Dave Wangaard USFWS 263-3316
John Hayden Acres 276-4888
Wayne Dyok Acres II
Bill Wi1 son AEIDC 279-4523
Ken Voos AEIDC 279-4523
John R. Sizer Harza/Ebasco 277-1651
Steve Zrake ADEC 274-2533
Stuart Burnell Morrison Knudsen 263-3611
F"'
Larry ~1oul ton Woodward-Clyde 276-2335
1 :00 p.m. Additional Attendees:
F" Judy Zimicki NAEC 277-2134
Larry Hechart AOF&G 344-0541
Kevin Delaney AOF&G II -Mike Mills AOF&G II
Dan Wi 1 kerson AOEC 274-2533
Tom Trent ADF&G 274-7583
Dana Schmidt AOF&G II
Bruce Barrett ADF&G II
Christopher Estes ADF&G II
Alan Bingham ADF&G II
I""' Richard Fleming Alaska Power Authority 276-0001
-
MEETING SUMMARY
EXHIBIT E
Water Use and Quality and Fisheries Resources Section
Holiday Inn, Anchorage, Alaska
Name
Judy Zimicki
Woody Trihey
Bill La~Hence
Brad Smith
Len Corin
Mary Lu Harle
Gary J. Prokosch
Chris Godfrey
Ken Florey
Eric Myers
John Wiles
Dave Wangaard
John Hayden
Wayne Dyok
Ken Voos
December 1, 1982 Afternoon Session
Attendees
e'rganization
NAEC
Acres
EPA
NMFS
USFWS
ADNR
ADNR
COE
ADF&G
NAEC
State Parks
USFWS
Acres
Acres
AEIDC
Name
John R. Bizer
Steve Zrake
Larry Moulton
Jean Baldrige
Larry Hechart
Kevin Delaney
Mike Mills
Dan Wilkerson
Tom Trent
Dana Schmidt
Bruce Barrett
Christopher Estes
Alan Bingham
Richard Fleming
Organization
Harza/Ebasco
ADEC
Woodward-Clyde
Woodward-Clyde
ADF&G
ADF&G
ADF&G
ADF&G
ADF&G
ADF&G
ADF&G
ADF&G
ADF&G
APA
INTRODUCTION -Larry Moulton, Woodward-Clyde Consultants (WCC)
We have
planning.
detailed
focused on habitat for impact assessment and mitigation
Although we cannot presently quantify impacts or present a
mitigation plan, we can discuss "the general types and
magnitudes of fisheries impacts likely to occur. Studies to quantify
impacts and determine the level of mitigation necessary are either
ongoing or in the planning stage.
1
-
-
-
-
We have divided the river into four general habitat types:
o mainstem,
o side channel,
o slough, and
o tributary.
We considered three general reaches of the river:
o Impoundments Zone,
o Talkeetna to Devil Canyon, and
o Cook Inlet to Talkeetna.
Each reach will have different impacts associated with the various
stages of the development.
We did select evaluation species based on the criteria developed by
U.S. Fish and Wildlife (USFWS) and Alaska Department of Fish and Game
(ADF&G). Because of expected impacts, we focused on salmon spawning
activities in slough habitats between Talkeetna and Devil Canyon
(Table 1).
1. Chum salmon are most abundant in these habitats.
2. Sockeye salmon are not as abundant as chums but sloughs
provide almost all spawning habitat for sockeye in this
reach.
3. Chinook and coho salmon do not spawn in the sloughs. So
here we are mainly concerned about juvenile fish which rear
in slough and mainstem habitats.
4. Pink salmon spawn mainly in tributaries with only slight use
of slough habitats.
For the Impoundment Zone, we selected Arctic grayling as the
evaluation species.
2
The different species occupy the river at slightly different times
(presented phenology chart, Figure 1).
Q Could some of th£ differences from 1981 to 1982 could be due to
differences in catchability of fish between the high and low flows
experienced between 1981 and 1982.
A ADF&G (Su hydro) staff will be here shortly to answer your
question.
CONSTRUCTION IMPACTS
Impacts expected during construction are expected to be similar to
those experienced by other major construction projects. In the case
of the two dams. the impacts are expected to be fairly localized. A
construction practices manual will be prepared to assist the
contractor in avoiding and minimizing environmental damage.
Major Impacts
1. Loss of habitat in mainstem due to river diversion.
2. Diversion tunnel will have high velocities and fish losses
are expected to result.
3. Short-term turbidity problems.
4. Concrete hatching operation will produce effluent requiring
treatment.
5. Accidental spills are a consideration.
6. Material sites and borrow areas will be located within the
impoundment with the exception of Borrow area E, known as
the Tsusena Creek borrow area. This area will be
rehabilitated to provide aquatic habitat.
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FISHERIES BASELINE STUDIES
Tom Trent (ADF&G Su Hydro Project Manager}
ADF&G conducted reconnaissance during the winter of 80-81. We began
full scale investigations in June 1981. Presently, we have completed
two cycles of open-water season studies and are getting the winter
1982-83 program underway. Our program is divided into three areas:
o Adult anadromous,
o Resident and juvenile anadromous, and
o Aquatic habitat and instream flow studies.
Our task is mainly one of data ~ollection but we are doing some
analysis to describe preproject relationships. Our reporting schedule
includes our basic data reports which will be produced by Jan. 31,
1983. These will contain very little analysis. Our interpretive
reports which will contain our analyses will be produced by
June 30, 1983.
Christopher Estes (ADF&G Su Hydro -Aquatic habitat and instream flow
program}
Discussed ADF&G 1981 reports and 1982 habitat report.
During the 1982 field season, the aquatic habitat program collected
habitat data to assess the influence of the mainstem discharge on
other habitat types. We established study sites in slough habitat and
collected water quality, hydraulic, and substrate data in six side
sloughs upstream of Talkeetna: SA, 9, 11, 16, 19 and 21.
Downstream of Talkeetna we established study sites in two areas, Chum
channel, a side channel and Rabideaux slough. We will evaluate the
influence of mainstem discharge on these habitats.
The aquatic habitat program also provided support for the resident and
juvenile anadromous studies.
Dana Schmidt (ADF&G Su Hydro -Resident and juvenile anadromous fish
program)
In addition to the resident and juvenile anadromous program, I have
also been involved in a dissolved gas study upon which I recently
presented a paper at the American Fisheries Society meeting in Sitka.
Devil Canyon has larye plunge pools which cause entrainment of air
resulting in nitrogen supersaturation. A continuous recorder was
installed near the mouth of the canyon to measure nitrogen
concentrations in the canyon. Measurements were collected to
determine the downstream dissolved gas profile to assess the decay
rate of nitrogen in the system. Peak concentrations of 117% were
recorded in the canyon.
Resident and juvenile anadromous fish program.
The adult anadromous program is tracking the adult salmon. We will be
following through with the incubation of the embryos. In conjunction
with the USFWS, we will determine development rates under various
temperature regimes. In addition we will be evaluating:
o Rearing habitat in sloughs and side channels,
o Timing of outmigration (smolt trap 6/18 to 10/10)
o Population estimates of grayling in the impoundment zone.
(These estimates will be stratified by age classes and may
be available by Jan. 31.)
We will be determining fish distribution and relative abundance,
through electrofishing and minnow trapping. , Telemetry studies are
being conducted on rainbow and burbot.
We will be assessing changes in habitat in response to changes in
flow.
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We have begun a study of food habits and availability of invertebrate
populations.
Bruce Barrett (ADF&G Su Hydro -Adult Anadromous Program)
Conducted adult anadromous investigations from the confluence of Devil
Creek to the estuary mainly on eulacon, salmon, aqd Bering cisco.
Eulachon studies were conducted from May 15.to ~une 9 using gill nets
and electrofishing units. Spawning activity was located from RM 4.5
to RM 48 primarily below the Yentna River confluence. There appears
to be two populations of eulachon using the lower Susitna River. The
size of the run is in millions of fish. The spawning run is mainly
composed of 3 year old fish. The fish were spawning in riffle zones
with unconsolidated sands and small gravel and relatively high
velocities.
Salmon
5 stations with side-scan sonar and fish wheels were established.
Milling activity and mainstem spawning were evaluated with
electrofishing and gill nets. Spawning surveys were conducted from
RM 100 to 160.
Chinook Studies
Population estimates were determined from tag and recapture. The
escapement in 1982 was far greater than in 81 • They were near the
1976 levels. There was lots of milling in the canyon. Chinook were
found above the Devil Canyon Dam site in Cheechako and Chinook Creeks.
Sockeye Salmon
We had a larger escapement of sockeye salmon in 82 than in 81. Most
of the sockeye were found in the sloughs. Sockeye did spawn in Chase
Creek, a tributary to Indian River and Prairie Creek in the Talkeetna
6
Drainage. Sockeye spawned in 9 sloughs between Talkeetna and Devil
Canyon. We did document an early run of sockeye in the Talkeetna
Drainage.
Pink Salmon
The escapement was less than average for an even year. Pink salmon
spawn mainly in the tributaries. We found pink salmon using mainstem
spawning sites in addition to slough habitats.
Coho Salmon
Coho salmon spawn mainly in tributaries. One mainstem site was
located and coho were found spawning in one slough.
No mainstem spawning areas were located below Talkeetna.
Bering Cisco
We had a much smaller run than last year. Fish were spawning in the
same area (near Montana Creek) as they did last year. We had one
repeat spawner from last year and fish were 3 and 4 years old.
QUESTIONS
Q Kevin Delaney (ADF&G) How many sloughs are there?
A We have located 33 sloughs. 10 are heavily utilized for
spawning.
Q Kevin Delaney (ADF&G) How many are mapped?
A We have planemetric maps on 6 sloughs and will be able to
assess access in these sloughs.
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Q
A
Brad Smith (NMFS) How important are mainstem spawning sites?
Some areas are heavily utilized. We may have 1000 fish in one
area. The majority of the mainstem is not used.
Q Ken Florey (ADF&G) How are the chum salmon spawning densities?
A
Given the flow we had, how is the habitat utilization?
We had good utilization of existing habitat. We are fairly
close to capacity with 82 populations and flow conditions.
Q Ken Florey (ADF&G) Is the utilization of the sloughs dependent
on flow levels or are they density dependent?
A Our population estimates show an increased number of salmon in
the system this year and fish moved faster in low water. Low
levels kept fish out of the sloughs until late.
Q Ken Florey (ADF&G) With regard to pulsing the discharge in the
spring and during the spawning season, is there any evidence to
support this concept? I realize that the studies are not
complete enough to define pulses.
A
Q
A
We did observe fish passing into sloughs when flows came up in
September, which lends some credibility to the pulse concept.
However, both mainstem and slough flow increased.
Are you going to do any winter food habitats study?
We will be looking at the distribution of fish in slough and
water temperatures will be monitored but we are not doing food
habits. We will have some information on growth but the small
number of fish scattered over the large channel makes sampling
difficult.
8
Q Will you be able to tell turnover rate in overwintering
habitats?
A No. We don't have the resources to determine the relationship
between fish overwintering in sloughs and fish overwintering in
the mainstem.
Q Brad Smith (NMFS) Does the large amount of milling behavior
mean that fish will go upstream if they have the opportunity?
A We think they ~ill as evidenced by the movement of chinook this
year into Devil Canyon. We see a lot of interbasin movements
and we have a sizeable population in Portage Creek.
Q Has anyone taken a look at the parent year to see what the
flows were?
A We only had about 50 fish upstream of Devil Canyon and no
scales were collected. We attempted to trap juvenile fish but
didn't find any salmon.
Q Lenny Corin (USFWS) Will you generate a new estimates of the
grayling population in the impoundment?
A Yes. We expect to have a substantial increase in the
population estimate. We will have some information on Watana
Creek and we have divided the Oshetna River into riffle pool
reaches to refine our estimates.
Q Ken Florey (ADF&G) Were there any age differences relative to
the two runs of smelt?
A Most fish were 3 yr old.
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Q
A
Ken Florey (ADF&G) Any repeat spawners?
No way to tell. Males have a longer spawning period than
females probably 5 day as opposed to 1 day. The two runs
appear to be genetically different due to size and weight.
Q Ken Florey (ADF&G) How long is incubation,?
A We could not recover eggs but it is probably 2 weeks. ADF&G
Interpretive Report Dana Schmidt (ADF&G Su Hydro). Our June
report will integrate data from the various programs into a
common base to determine the relative.importance of populations
at risk and the response to changes associated with natural
variation. The report will be confined to the lower river and
will integrate by species data on:
1. Adult migration and spawning
2. Embryo development
3. Freshwater rearing
a. habitat selection
b. response to changes in discharge and water quality
4. Outmigration timing
It will address:
o Relationship of behavioral response and changes in flow
o Hydraulic change in habitat
o Change in surfac.e area
o Change in availability of cover and substrate
o Response of chum and sockeye salmon embryos to thermal
variation which presently exists in the habitat
END OF SESSION
MEETING SUMMARY
EXHIBIT E WORKSHOP
Water Use and Quality and Fishery Resources Section
Holiday Inn, Anchorage, Alaska
December 2, 1982
ATTENDEES
Name Organization Name Organization
Jean Baldrige Woodward-Clyde Larry Rundquist Woodward-Clyde
Larry Moulton Woodward-Clyde Eric Myers NAEC
Brad Smith NMFS Bill Lawrence EPA
Garry Stackhouse USFWS Dan Wilkerson ADEC
Kevin Delaney ADF&G Paul Krasnowski ADF&G
Michael D. Kelly AEIDC Bill Wilson AEIDC
Mike Prewitt AEIDC Kevin Young Acres American
Wayne Dyok Acres American Tony Burgess Acres American
Dave Wangaard USFWS Gary Lawley Harza/Ebasco
John Bizer Harza/Ebasco Paul Janke ADNR
Tom Trent ADF&G Kevin Florey ADF&G
Gary Prokosch ADNR Steve Zrake ADEC
Nancy Blunck APA Tom Arminski APA
Mary Lu Harle ADNR Dave McGillivary USFWS
Patricia Lukens Acres American
MITIGATION FRAMEWORK -Larry Moulton (Woodward-Clyde Consultants)
Approach to mitigation was based on the USFWS and ADF&G mitigation policies
which present the criteria and categories contained in Figure E 3.1
(Exhibit E). Keeping these criteria in mind let's review the impacts.
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IMPOUNDMENT
Impoundment Impacts:
Lotic habitat will be innundated as a result of filling Watana
Reservoir. Figure 2 shows the portions of the mainstem and tributaries
innundated by Watana Reservoir. We believe that much of the grayling
population presently occupying this habitat will be lost. The summer
habitat in the streams seem to be fairly well occupied so few additional
grayling could probably be accomodated in adjacent habitats. Grayling are
not generally found in turbid lakes. In addition grayling may encounter
difficulties in sucessfully incubating embryos spawned during reservoir
operation. Spawning under reservoir operation will be difficult for most
species. As the reservoir fills, sediments carried by the tributaries will
settle out over the spawning areas, suffocating the eggs. Figure 3
illustrates how reservoir operation and biological activities overlap. The
portion of the streams near the reservoir will be innundated by the
reservoir filling schedule before the embryos hatch. The portion of the
grayling population spawning in habitats above the 2135 ft level will not
be affected by the reservoir filling schedule as these embryos would hatch
before the habitat would be inundated. Table 1 indicated the miles of
tributary innundated by the reservoir during the grayling spawning and
incubation period. The amount of overwintering habitat is expected to
increase.
A population of Lake trout may develop in the reservoir but again
production is expected to be limited. Figure 3 shows that most of the
available spawning habitat will be dewatered during the winter before the
lake trout embryos have completed their development. The spawning depths
for lake trout, whitefish and burbot were taken from Morrow's Freshwater
Fishes of Alaska. Some deep spawing lake trout may survive. The
probablility of sucessful whitefish or burbot production appears slight.
If these fish spawn in tributary channels the embryos may survive.
We expect a little different situation in Devil Canyon Reservoir.
The reservoir will innundate riverine habitat and the grayling populations
occupying those habitats may be lost. However, grayling populations in
these streams do not appear to be as large as those in the Watana Reservoir
streams. The streams in Devil Canyon Reservoir are fairly steep and many
appear to have migration barriers which will not be innundated by the
reservoir.
Q Silt load covering deposited eggs interfering with success. Also,
what will the fish be feeding on?
A Upwelling may clear some of the gravels. Loss of riverine habitat
in impoundmeat zone with very little gained. Do not expect a
productive littoral area and do not expect much food production.
Q Is there an access problem if fish overwinter in the reservoir?
A May actually improve accessibility as some fish barriers will be
removed, e.g. falls on Deadman Creek will be inundated. Dollys have
the best chance of surviving and may occupy reservoir habitats.
Mitigation for the Impoundment Zones -Larry Moulton (WCC)
Since the impacts for the reservoir can not be avoided, mimimized
or rectified, compensation is planned for the lost resource. The best way
to compensate these losses is with inkind replacement of grayling. We
propose investigating the possibility of implanting grayling in barren
lakes in the project area or possibly other lakes in southcentral Alaska if
none are found within the vicinity of the project. Grayling could be
raised in a hatchery and released in suitable lakes. It may be effective to
deepen some lakes to provide overwintering habitat.
Q Has the success of such a hatchery program been proven?
A ADF&G has a grayling program at Big Lake Hatchery
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Agency Comment -I'm familiar with the ADF&G program which is at Clear Ak.
and it is my impression that the technology is not all that dependable. I
don't believe it can be done on this scale.
There were successful plantings in southeastern Alaska where the fish began
reproducing on their own.
ACCESS ROADS -Larry Moulton (WCC)
The primary impacts to aquatic habitat expected to occur are related
to road crossings and borrow pits. To the extent practical borrow areas
for the access road have been moved to upland sites. Road crossings will
be designed according to ADF&G fish passage criteria in accordance with the
title 16 draft regulations. If desirable, the borrow areas near lake may
be rehabilitated to provide aquatic habitat.
Access to this area may result in an impact from the additional
fishing pressures. Natural populations in streams and lakes could be
protected if more restrictive harvest techniques and bag limits were placed
on areas such as Deadman Creek. The lakes that are stocked with grayling
may provide a place for the guy who just wants to catch a lot of fish while
the natural streams could provide more of a quality fishing experience.
The road has been routed as far away from Deadman Creek as the corridor
allows.
Q
A
Do you expect people to drive 200 miles to fish in a gravel pit?
Yes, they drive that far now. We expect people to leave Anchorage or
Fairbanks with a camper or Winnebago, pull up to one of these areas
and fish for the weekend.
Q Are you familiar with Copper Highway gravel pits?
A Yes.
Q Is this access discussion only for the Denali-Watana portion?
A No both segments are discussed.
Q What is the type of borrow material? Volume?
A The borrow material should be relatively easy to get. We need about
200 surface acres for Denali-Watana and about same for Watana-Devil
Canyon portion. We feel we can get this from upland sites and will
not need to use any streambed material.
Q If borrow areas are so easy to locate, how about alignment of the
road?
A They have done some realignment.
Agency Comment -We have not yet quantified loss, but we don't think that
there is any way to raise the number of fish that we are talking about.
There is no compensation for unique experience that can be had today at the
mouths of some of these streams.
DOWNSTREAM IMPACTS-Jean Baldrige (WCC)
Before we begin on the downstream impacts I would just like to take
a few minutes to discuss our approach to assessing downstream impacts and
where we are in the process. Our approach is based on habitat. We looked
at areas where the project would alter habitat conditions. Then, we
evaluated the changes to determine if they would impact the fishery
resources. This is basically a sequential process. First we have to know
what the project area is and how the system works. Then we can overlay the
project operating scenario and determine the project impacts. After
assessing the impacts we develop a mitigation plan to address the expected
impacts.
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Where are we in this process? Well, we have a good general
understanding of how the basin works, what the processes are, the general
distribution, and timing of the fishery resources. We know what habitats
are important. We have identified generically, the type of impacts likely
to occur and we have developed a conceptual approach to mitigation and
established some priorities. We have some concepts regarding mitigation
features. Larry Moulton will talk more about mitigation later today.
In reviewing the physical processes in the basin as Wayne Dyok and
other talked about yesterday, most of the changes will occur in the
Talkeetna to Devil Canyon section. We expect most of the changes to occur
under the filling and operation of Watana. Devil Canyon Dam may result in
slight increases in the types of impacts which will occur under development
of Watana.
Q
A
Q
A
What is filling time for the Devil Canyon?
About a month. Downstream flows would be maintained at 5000 cfs.
(Ed. note -actual filling time from elevation 1135 to 1455 will be
in the order of 5 to 8 weeks)
Why stick with a 5000 cfs value? Do we know enough to say that's
what we need?
That is what we have had to work with. We feel that in the 8-10 yr
period in which Watana alone would operate, a new fishery habitat
will develop and substantially changing the established regime will
hurt that new fishery.
WATANA FILLING -Jean Baldrige (WCC)
Filling Watana Reservoir is expected to take three years. This
figure presents a comparison of streamflows :expected for filling Watana
reservoir. I have combined parts of the second" 'and third years to show the
months of the greatest changes expected. Many of the changes expected
during the open-water season will occur during the initial filling of the
reservoir. We expect changes in:
o Streamflows
o Water quality
o Water temperature
Mainstem and Side-channel Habitat
Mainstem and/side-channel habitats will be directed influenced by
the project.
o Outmigration
Break-up will be diminished which may affect outmigration. Sufficient
water will exist to transport fry downstream but both the rising water
levels and temperatures that may stimulate outmigration may not occur under
post project condition.
Q Asked whether the reduced flows are indeed sufficient for the fish
passage.
A Yes, for river migration.
o Chinook inmigration
There should be sufficient water to pass fish upstream. Studies on
navigation by the ADNR show that there will be depths of at least two feet
in the shallowest cross-section which is located between sloughs 8 and 9.
Chinook will also be able to gain acess to tributary habitats under filling
flows as R & M discussed yesterday. Chinook are also expected to be able
to ascend the canyon and utilize tributary habitats below the Watana dam.
Q These effects during filling -what about operation?
A Similar effects.
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Q Would you really get a decrease in velocity through Devil Canyon.
A Yes, due to the rectangular shape and the confined nature of the
canyon, we expect that when we decrease the discharge, the
velocities will be reduced. There will still be high velocities in
the cayon but chinook should be able to pass.
o Spawning season
A few spawning areas were located in mainstem and side-channel
areas. Lower flows during the spawning season may adversely affect some
mainstem and side channel spawning areas. Many of these areas are located
on the margins of the system in areas protected from high flows. Because
these habitats are located on the perifery of the system they are more
susceptible to dewatering.
o Water temperatures
During the second year of filling we expect water temperatures in
the range of 5 to 6 °C during the summer time. Temperatures in this range
may deter adults form entering the system. If they do enter the system,
the cool temperatures may retard sexual maturity and delay spawning
activity. Low water temperatures could affect resident and juvenile
anadromous fish by retarding growth or by causing fish to move into warmer
waters in the tributaries and sloughs.
Slou~h Habitat
Slough habitats will be slightly buffered from changes in the
mainstem, but we expect some adverse impacts in these habitats. In the
spring, under the filling flows we will not have the kind of break-up and
flushing action we have now. However, we will still have some increase in
slough discharge and stage from the increase in local surface runoff as the
snow melts and the rains come. This may provide sufficient stimuli for the
fry to outmigrate.
In August under 12,000 cfs we may have some passage problems as
Woody Trihey discussed yesterday. This afternoon we will discuss ways to
rectify this situation. We may also see some reduction in the areal extent
of upwelling and perhaps the rate of upwelling. As the backwater effects
from the mainstem are reduced, some of the lower spawning areas may be
affected. A decrease in depth may reduce the amount of spawning area
available as well as affect holding areas.
Another result of regulated flows would come from increased beaver
activity. Beaver dams have already caused some passage problems. At
slough 8A, the beaver dams precluded upstream migration until the flow
levels increased in September. Then with the additional stage and
backwater effects the fish were able to pass.
Q What is the source of flow and ice formation in the slough.
A Right now the sloughs form a thin ice cover over much of their·
length. At the slough mouths, the ice may resemble the ice cover in the
mainstem in its thickness. At slough 8A ADF&G observed that the slough was
overtopped as the ice front proceeded upstream past the slough. The
discharge increased to 150 cf s. In the spring, the ice melts off the
sloughs earlier than break-up in the mianstem. In April the slough are
open and free flowing.
Q Is there a spawning population in these sloughs? What velocities
are we talking about?
A We don't expect that the velocities are high enough under ice
formation to cause scouring.
Comment -Acres clarified the path length of the groundwater flow that
influences upwelling on the slough picture.
Groundwater moves along the downriver gradient and not really cross wise
through the island.
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Tributaries
The only portion of the tributary which will be influenced by the
project will be the tributary mouths. As in slough habitats, the mainstem
causes a backwater to form which provides passage and rearing habitat for
residents and juvenile anadromous species. R & M performed an analysis
that indicates that, with an exception of three, the tributary mouth will
not become perched. The backwater zone may be slightly reduced. Tributary
habitat above Devil Canyon will become available to chinook salmon as we
discussed earlier.
Q Of those streams that are going to be perched, why is it that they
will perch.
A Size of stream bed material.
WATANA OPERATION
Under operation, the flows will be a bit higher in the spring and
fall, definitely higher in the winter and about the same much of the
summer. We will have greater control on the downstream temperatures. In
addition we will reduce the number and magnitude of floods in the system.
Presently we have an annual flood of 50,000 cfs. Under operation that
annual flood will be about 13,000. We will also have a change in the
sediment transport in the system. Right now the system carries lots of
sand suspended in the water. You can hear it hit your boat. The reservoir
will remove the sand. The river will pick up some sediments below the dam
and will carry some sediment but it will be much clearer than the existing
conditions.
Because of these physical changes we expect rearing conditions to
improve in mainstem and side-channel habitats. We expect increased benthic
production from improved light penetration and reduction of suspended sands
which presently sandblast the substrate.
Q Is there a seasonal consideration of your discussion with regard to
increased benthic production in mainstem habitats?
A Mainly summer.
Winter Conditions
Discharges will be higher in the winter. Water temperatures will
also be increased. Upstream of Portage or Sherman, temperatures will be 2
to 4 °C at the dam outlet thus there would be no ice on that portion of the
river. Warmer water temperatures are expected to benefit overwintering
fish by reducing mortalities associated with freezing. Stable flows will
prevent dewatering of overwintering habitat and spawning areas available
under the postproject summer flows. Warmer water temperatures may alter
the embryo development rates. Temperature increases may result in early
emergence, which has been linked to decreased survival. If these fish move
downstream, they will encounter 0°C water in the Chulitna and may
experience thermal shock. Chum slamon would be less susceptable as they
select areas with upwelling, which would buffer the embryos from mainstem
temperature changes. The suspended sediments will increase slightly during
the winter.
Downstream of Sherman, we will have an ice cover. Here again,
increased winter discharge is not expected to adversely affect rearing
fish. We may have some increased velocities but we expect there will be
sufficent areas along the margins of the river and in pools for fish to
overwinter. Juveniles spend much of their time in or near the substrate
so mean column velocities may not be as important to them in the winter as
they are in the summer.
Sloughs
The change in ice processes will affect slough habitats. Upstream
of the ice front we will have open-water condition. As Tom Lavender
discussed· yesterday we will have less stage than under the present ice
cover. Since winter and summer discharges are virtually the same, spawning
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habitat available under the post project summer flows should be maintained
by the winter flows.
Downstream of the ice front we expect an increase in stage over
pre-project conditions. This stage is expected to increase sufficiently to
overtop the sloughs at the head end which would allow cooler mainstem water
to enter the slough system. This would reduce ~urface temperatures in the
sloughs and may adversely affect the quality of overwintering habitat.
If this process causes aufeis formations in the upper portion of the
sloughs, water temperatures in the sloughs may be reduced well into June.
No flushing flow would be available to remove the ice and it would have to
melt. If cooler water temperatures persist through the spring it could
adversely afffect nursey areas for emergent fry.
Q What river mile is Watana? So we are talking about 30-55 miles of
open river under post-project winter ice conditions.
A Yes •
Q
A
Q
A
What temperature is causing this? I thought the ice front would be
at Talkeetna.
Under the operation of Watana we expect the ice cover to be between
Portage Creek and Sherman. Under the operation of Devil Canyon we
expect the ice cover to be somewhere between Sherman and Talkeetna.
Do we have any idea of relative percentages of overwintering in
mainstem vs. sloughs.
Do not have percentages but both habitats are being used.
Q Aren't we also seeing a lot of stranded river ice now?
A Yes, but they are much smaller than an aufeis field.
Q Juvenile fish coming out of tributaries -will there be enough water
to get back into sloughs?
A Outmigration from tributaries occurs all summer long.
Q What do Indian and Portage contribute to flow.
A The contribution is relatively small.
A (Acres) Gave some numbers.
Q When we hear discharge at Gold Creek, that is not the discharge at
Watana.
A That is correct. We will have immediate feedback of Gold Creek
streamflow data to modify releases at the dam.
Q Trying to figure out slough access comments in FERC -Exhibit E
(Chapter 2). What is most sloughs?
A Access not a well-defined factor on a slough-by-slough basis. Fish
did get into many sloughs under 12,000 cfs but access was difficult.
}
Wayne Dyok (Acres) presented some information on ice processes in sloughs.
Reiterated that presently the ice front causes mainstem water to flow
through the slough and the mainstem ice cover progresses up the slough.
This is probably of short duration.
Q Ground water seeps small -Will large flows cause scour?
A We don't expect they will but we don't know.
Q Won't this have an effect on changing the upstream berm?
A They may change the height of the berm at the upstream end. We will
have to evaluate this.
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DEVIL CANYON
Filling of Devil Canyon will be a short time, 5 weeks. We reported
5 months in the Exhibit E. Filling will be accomplished in the winter.
Downstream discharges will be maintained at 5000 cfs. Under the operation
of Devil Canyon you can see that we have small increases in the percent
change of streamflow (Figure). We do not expect these changes to result in
new impacts but the magnitude of impacts discussed under the operation of
Watana will be slightly increased. One notable difference as we mentioned
earlier, the ice front will be between Talkeetna and Sherman after Devil
Canyon ·comes on line.
DOWNSTREAM OF TALKEETNA
Let's just take a brief look at the system below Talkeetna. You can
see here at Sunshine station (Figure) that the changes are of a smaller
magnitude. In addition we do not expect much difference in either the
temperature regime nor the sediment transport processes.
Moving down to Susitna station we see even a further dampening of project
effects. The Eulachon will be in the system in May which has a decrease of
about 10 per cent. Changes of this magitude are not expected to
significantly affect the Eulachon spawners.
Q Have you considered the relatively short time that the Euluchon are
in the system and does mean monthly represent the situation?
A It may not but under peak flows the percent reduction would be less.
This will be looked at when the data is available. We will be
trying to get into daily and weekly streamflow values for all fish
and the entire system if appropriate. AEIDC will be looking at this
in their quantitative impact assessment.
Q Processes will remain the same as under Watana, just be more of it.
A Wayne Dyok (Acres) Yes.
Q During filling and operation may there be large slides into
reservoir affecting water quality downstream.
A There will be some slumping especially under the initial filling,
but we do not expect much effect downstream. The slide would
contain large soil particles which would probably settle out in the
reservoir.
Q With the loss of some sloughs can something be done to mitigate by
making new sleughs or are they a total loss.
A We do have some ideas on slough mitigation which we will discuss
now.
Q What level of turbidity do you expect downstream in winter months?
A Slightly higher than now.
Q What is that comparable to under present conditions up-and
downstream of Talkeetna?
A Similar to those experienced in September.
Q How is this all going to be compiled into a composite impact?
A (WCC) (ADF&G-SuHydro) and (AEIDC) will be doing this in the next
several months.
Q Will also have to integrate the terrestrial and other studies.
A There is coordination between the different groups.
Agency Comment -ADF&G had a good point on cumulative impacts.
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Q I'm not happy with the philosophy of "We have only a 10 percent
change and therefore we don't expect alot of impact." Many of our
species already at the edge of a range and 10% can push it over the
edge.
A We are still trying to refine and define these problems.
Wayne Dyok (Acres) made announcement regarding handout •
Larry Moulton (WCC) announced typo changes on Table E34.
MITIGATION -Larry Moulton (WCC)
Water Temperature
The muliple level outlet will provide some temperature control
during operation and the last year of filling. Temperatures during the
second year of filling are still a problem. We may be able to solve this
problem by including a low-level intake. This would also give us more
temerpature control during the spring and fall when we may want to provide
warmer or cooler water. The engineers are pres'ently looking into this.
Streamflow
Under the present operating senario, we can't avoid all impacts to
the fish, but we may be able to rectify some of these impacts through
habitat modification. One concept is through slough modification. (Figure
E 3.9). We would modify a slough using downstream control structures to
increase the depth and allow fish passage. The upper end of the slough
would be diked off to prevent the mainstem discharge from entering. A gate
with a pipe would allow us to have flow through the slough for flushing or
for outmigrants.
Q Do you have a generic price to go along with the generic design?
A $3-$4 x 10 6 per 30 million eggs.
Q How many would be built.
A However many are required to mitigate the loss.
Q Have you compared this to hat~hery costs.
A Yes, It appears to be about ~ the cost.
Q Who would operat~ the valve?
A Manual operat:ion.
Q You are thus proposing to design an artificial slough?
A We woula use an existing slough.
Q Do the flow control weirs get removed for flushing?
A They will be dropped or laid back but we haven't worked out the
details yet.
Q How would you get to these areas for maintenance?
A Most of these areas will be near the existing railroad.
Q Will the juvenile chinnok and coho be able to use the sloughs for
overwintering?
A We presently have no mechanism for them to get in but can consider
it.
Q When holding the chum, do the coho and chinook feed on the chum?
A They probably would.
Agency Comment - I think they would really be able to chow down since the
chum would be held in confined areas.
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Q How is the time of emergence span going to be accounted for on the
release schedule.
A We don't have that information yet as to when the emergence time is
and what flows would be required.
Q We tried feeding chum in Cold Bay and the fish wouldn't leave. How
are you going to get the fish out?
A We were proposing to feed the fry only if we had early emergence and
downstream conditions were not suitable. With the recent results of
groundwater studies it looks as though we will not have to feed the
fry.
Project Comment -These are proposed mitigation measures and combined with
flow regulation, we have some flexibility. We will probably use a
combination of mitigation techniques. Some sloughs may not require
modifications, others may require a structure at the entrance to help the
fish get in, others may require only the berm at the head end. The goal is
to maintain as natural and passaive a set of modifications as possible.
Agency Comment -There are no spawning channels in operation in Alaska.
The ones at Fourth of July Creek in Seward were washed out. I think you
will probably have a lot of problems with these.
Agency Comment -Beaver will love these channels and will be hard to
control.
Q
A
Are we going to talk about priorities.
emphasis on alternative flows.
We have been covering this.
1st is flow regimes
2nd is modification of sloughs
3rd is hatchery.
I'd like to see more
Agency Comment -Seems like these slough modifications are getting down to
the bottom of the list.
Agency Comment -We have already covered flows. These plans are "a joke".
I don't think they will work. We might as well be looking at hatcheries.
Q Do you know what the effects of time would have on these plans.
River changes abandoning slough.
A We would not ~ropose a mitigation that would be abandoned.
Acres Comment -Ice scour is not a problem under project operation and we
do not expect the river to change its channel.
Q What is the objective of this slough modification program?
Q Are you trying to create new habitat or maintain existing habitat?
A We are trying to maintain the existing habitat.
Q Is the information that ADF&G and AEIDC will provide going to be
helpful in defining which areas will need this mitigation?
Agency Comment -That's right -if it is not broken, don't fix it.
A Yes definitely, The information on habitat relationships and
impacts will provide the basis for mitigation. This is a sequential
process. We are going to undertake a feasibility study to determine
if these concepts are practical. We need to understand better how
specific sloughs work and then design a specific mitigation for each
slough.
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DEMONSTRATION SLOUGH -Jean Baldrige (WCC)
First, I would like to review the problems in slough habitat under
operation of the project. Through.slough modification we would attempt to
resolve these problems:
o Access for adult salmon
o Winter thermal regime (overflow from mainstem)
o Reduced upwelling
o Sedimentation
o Vegetation encroachment
o Beaver activity
The objective of the demonstration project is to test the feasibiliy of
slough modification as a mitigative measure for the Susitna Project. We
propose to modify a slough to demonstrate that we can provide access and/or
enhance upwelling.
We have started a site selection process to find a suitable area to
use. At the end of October, Woodward-Clyde in conjunction with Fish and
Game conducted a reconnaisance to find some candidate sloughs. We
established some criteria to assist us in this selection.
o Marginal fish use
o Ground water upwelling
o Suitable substrate
o Surface water source
o Adequate water quality
o Accessibility for heavy equipment
We are in the process of screening the sloughs according to this
criteria. We hope to identify likely candidates to begin a baseline data
collection program on this next field season and we will then be able to
actually modify a slough after that. Presently we don't understand
[specific] slough processes well enough to be able to design a modification
progam that we know will work.
Acres Comment -With regard to the sloughs, we have a pretty good handle on
the processes. The ~jor missing link is applying the processes to each of
the sloughs individually to get the impacts to each slough. A few sloughs
have been studied and results will be available. We may find that no
modification is necessary for some sloughs, minor modifications for others,
and major modifications (artificial channels) to others. Is it worth doing
the major channel modification? We don't know enough right now to decide.
ADF&G (Su hydro) Comment -Exhibit E Has been prepared on one flow regime.
Mitigation is based on one operational flow. One problem to be dealt with
is avoidance. Flow may be available for avoidance but it may not be
prudent to go with that flow and the flow regime will still be under
negotiation. Our studies and AEIDC's models will help address the question
of flows.
Q Is slough modification a technique proposed to the agencies or is
this the mitigation proposed in Exhibit E?
A This is a proposed mitigation for the project.
Q We aren't going to know until we try it. If it doesn't work what
happens since the project will be well along the way?
A Most FERC licenses stipulate a certain acceptable limit of
escapement or production that is monitored during construction and
operation. If the mitigation does not work then we can undertake
additional mitigation.
Agency Comment -Whenever we are mitigating, we have to mitigate whatever
potential there is under natural patterns.
Agency Comment -Mitigation policy has been established but a program is
needed to outline a plan for monitoring.
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A It's included in the Exhibit E.
mitigation plan.
Monitoring is part of the
Q Is the slough modification project going to look at improving an
existing slough.
A Yes.
Q Are you using the fish to see the effects of mitigation. You aren't
doing anything about fish production to evaluate the impacts or
effectiveness of these modifications. How is fish production being
evaluated?
A We do not evaluate the habitat in terms of x number of coho units.
Q
A
We are constrained to use the physical parameters, we identify
current conditions and try to maintain those conditions. The
measure of success of those modifications would be in terms of
escapement or fry production as gathered through a monitoring
program.
I didn't get the idea how conceptual are the mitigation plans that
are proposed in the Exhibit E. Today' s presentation has cleared
this up. No one wants to see hatcheries on the Susitna River except
as the last alternative but why aren't hatcheries mentioned in
Exhibit E. Don't you want to include some hatchery program to
address what can be done if the other mitigation prove not to work.
What would be the senario with a hatchery?
Krammer, Chin and Mayo have just completed a hatchery siting study.
FRED division is looking at upper basin enhancement possiblities
without the project.
Comment -We have already selected a case that allows release such that
hatcheries are not required •
Q What is your perception as to how FERC looks at these mitigation
approaches. What is your understanding of these approaches. Are
they put in to placate the agencies?
A We can not state what FERC will do.
ACHS Comment -FERC has not reacted to anything proposed to them yet. That
is the way FERC works -they will not plan the project for the Alaska Power
Authority.
Alaska Power Authority Comment -We are dealing with a continuous series of
mitigation schemes and a continuous series of flow regimes to deal with
changes in a continuous series of habitat types.
Q Are we where we should be on the mitigation plans for the FERC
process?
A Regs say that a workable design drawing is required, but definition
of a design drawing is vague. Design drawings usually not required
except where an integral part of the dam, though schematics for
systems usually are included.
Agency Comment -It is a continuum; they may request more data or accept it
as is. We may feel that we are not very far up on the continuum, but FERC
may not be concerned about this. They may require that problems be worked
out between the Alaska Power Authority and the agencies and return to FERC
with resolution. How is FERC going to properly review the Exhibit in the
short time frame?
A This is a Draft review.
Q What is FERC going to come back with.
A We don't know.
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Wayne Dyok (Acres) gav~,a handout.
John Hayden (Acres) thanked everyone.
MEETING ADJORNED