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HomeMy WebLinkAboutGrant Lake Hydroelectric Project Federal Energy Regulatory Commission application 1987Kenai Hydro,ihc. Hydroelectric Planning S Deve1dp►pgfF(1,E OF THE St�f'. 1987 19AY I PH 2' 18 REGULATORY COMMISSION May 6, 1987 Feeera'_ Energy Regulatory Commission Office of Fv?ropower Licensing 825.North Capitol Washington, D.C. 20126 Dear Sirs: F.nclosee are agency comments and an instream flow study for Grant Lake Hydroelectric Project 7633-002. These comments were made on the draft study submirTtty 7?e. 17, 1987 to the agencies as requested by your letter of August 19, 1986. The additional in- formation supplements the Grant Lake License Application of December 20, 1984 and submissions after that date: Project Alternative I, developed from studied and submitted project arrangements, provides for habitat preservation in Grant Creek as requested by the Agencies and has been submitted to the agencies for review. This Alternative provides for equal consideration of power, fish and wildlife protection, recrea- tion and other aspects of environmental quality. Alternative I is within the scope of project material submitted to FERC in previous submissions for the Grant Lake Project. JMH/jP Enc. Si cerely, r� GJonathaAn M. Hanson President FERC7 DOCKETED P.O. Box 1776 Lummi Island, WA 98262 (206) 758-2252 C ka.. ar . .,L`_Cc If�ct �f KENAI HYDRO, INC. Grant Lake Hydroelectric Project FERC No, 7633-002 Instream Flow Studies and Agency Responses May 4, 1987 w Kenai Hydro, Inc. Hydroelectric Planning & Development Dr. Robert McVey U.S. Department National Marine P.O. Box 1688 Juneau, Alaska Dear Dr. McVey: of Commerce Fisheries Service May 4, 1987 Kenai Hydro has provided additional information to FERC and the agencies for the Grant Lake Hydroelectric Project, 7633-002, in accordance with the request of FERC of August 19, 1986. The additional information supplements the Grant Lake License Appli- cation of December 20, 1984 and additional information and sub- missions after that date. Project Alternative I, developed from studied and submitted project arrangements, provides for habitat preservation in Grant Creek as requested by the agencies and has been submitted to the agencies for review. This Alternative provides for equal consideration of power, fish and wildlife protection, recreation and other aspects of environmental quality. The following is presented in reply to your letter of April 6, 1987. Information is drawn from the License application, addendum, correspondence and recent surveys at Grant Creek referred to in the presentations. 1. T!?e monthly operation curve shows one scenario by which the plant may be operated. The demand and energy curves for the area are relatively flat and the curve may be more of a straight line than is projected, i.e. straight across at 200 cfs. The curve presented is the most likely since the need for power is higher in the winter in south-central Alaska (Seward has increased summer activity making the curve flatter). The curve has made allowance for summer spawning and appropriate flows are shown in June -August. The reduced September flow would enhance the Coro spawning since they like flows less than Chinook. Dumping and hedging are possible in March -May and October since these months have no spawning activ- ity or reduced activity. The reservoir management curve was left as is since it represents an ideal curve. P.O. Box 1776 Lumml Island, WA 98262 (206) 758.2252 NMFS Page 2 Flows recorded by Cook Inlet Aquaculture ranged from 46 to 210 cfs in 1985 and 48 to 800 cfs in 1986 from August to October. Coho spawning was essentially over by October 1, with peaks in mid -September. According to the stream flow analysis the WUA does not decrease more than 20 percent until we reach 200 cfs with the maximum at 350 cfs. CIAA flow data shows less than 200 cfs is regularly recorded under natural conditions (CIAA Grant Creek Reports for 1985 and 1986). According to these reports, holding the CFS above 100 may actually increase the WUA. The generated curves represent the optimum condition. The high flow in 1986 actually blew the Coho right out of the creek. 2. The timing and collection of the field data was critical due to several factors: (1) a bank full measurement provides the optimum modeling condition; (2) Winter conditions were eminent and the stream could fall extremely rapidly due to freezing conditions; (3) Uncertain winter conditions i.e., long cold winter may cause the collection of data to be put off until spring; (4) Uncertain breakup and spring conditions would place the sampling in extreme fluctuating conditions; (5) Project timing would be displaced by more than a year if these conditions existed. The factors of uncertainty and the need to proceed caused Kenai to act prudently and sample the stream. 3. The paragraph concerning minimum instream flows reads: "Minimum instream flow requirements have been developed for Grant Creek (emphasis added) with provisions for Chinook etc." As pointed out in the paragraph 1 above, plant management could actually enhance Coho spawning with reduced flows. Rainbow trout have been added to the affected species in Grant Creek in the instream flow report. Chinook salmon was the target species according to our previous discussion. Rainbow are found in Grant Creek in small numbers and the size of fish found is small (less than 106mm). 4. Stranding area does not increase significantly until the stream drops from 100 to 50 cfs. The curve is misleading since the incremental plots were done on the average, not the range. The model was run in 50 cfs increments, 200-150, 150-100, and 100-50 cfs. The graph was plotted at the mid -point of the increment. The point should have been placed at the lower value of the increment. Strand able area would thus not show a significant increase until the water is dropped from 100 to 50 cfs. The CIAA data shows how well the stream holds up to 28.5 cfs. 5. The point of release'for the fish from the by-pass was chosen for three reasons: (1) Economically this is the cheapest place to release the fish (less pipe and construction). (2) The fish would spend less time in a confined pipe and (3) The fish were naturally required to emmigrate from the lake via this route. The fow during the peak of migration would be 8 cfs (see Instream Flow Graph). The out migration appears to be triggered by temperatures NMFS Page 3 and no migration was noted when temperatures were less than 40C: Water could be concentrated during the out migration period June - September, with flows during other periods through the turbines. 6. Emergency water is provided from two sources (Additional Information, page 4) and shown in conceptual drawings IV-20A and IV-22A. If the turbines and generators are shut down, flow is continued through a by-pass valve at the powerhouse.. In the event the penstock is shut down, water is drawn from the lake via the fish by-pass pipe. These all supply water to the tailrace - powerhouse discharge channel. 7. Enclosed is a conceptual plan for the powerhouse discharge channel. The channel is designed for maximum use as a spawning area u and will provide approximately 30,000 square feet of spawning area. The long term maintenance and operation plan would depend only on extreme damage to the system. Kenai does not propose any main- tenance or operation other than normal plant operation and instream flow maintenance. The channel represents a large increase in spawning area and would require a catastrophic event to substantially change the channel. A natural, self -maintaining system is proposed similar to a natural stream. B. The assumption that WUA will fall with project operation assumes that the stream flow will always be 350 cfs as on the ideal curve. As pointed out in paragraph 1 this is not true. The range measured by CIAA is well below the ideal 350 cfs during August when Chinook and Sockeye are spawning in Grant Creek. WUA would be subject to the extreme fluctuations of the natural creek flows and �.. not the ideal generated curve. The proposed flows are well within the range of normally occurring flows and minimize the risk of lower or higher flows. The fact that spawning may occur in 0.5 or 1.0 or 2.0 feet becomes mute when extreme fluctuation occurs. Modifi- cation of the natural bed to reduce strandable areas and depth fluctuations would reduce those impacts i.e., flattening of gravel bars and placement of rock weirs. 9. The transects extend up the banks to a measured mark at stations 2 and 3. At station 1 the bank disappeared into a morass of roots well above the water. The bank at 2 and 3 was considered representative of the bank in the sample area and measurements at these stations was used to provide the profile at station 1. Out of bank flows do not appear common at Grant Creek. Enclosed are the data compiled from the field notes. Measurements at .2, .6 and .S of depth confirm the .32 and 6.62 fps readings referred to in the additional information. The column labeled rFS should read FPS. Figure 12 is given as water width, not total transect length, and the widths should be 63, 613 and 75 not 63, 70 and 72 feet. 10. We too, are unable to accurately predict the effects of NMFS Page 4 w.- oil and gas. A recent memorandum from the Office of the Governor also demonstrates their flustration. Note, they too are tied to .1981-1983 predictions. The bottom line of our economic analysis is actual competition with existing rates and the prediction by the utility of prices which it will have to pay in the future. Summary 1. The WSP/IFG-2 model developed by ENVIRONSPHERE from data provided by Kenai Hydro has been shown to preform from 50-400 cfs. Data from CIAA confirmed the model was accurate to 30 cfs. 2. Strandable area does not increase substantially until flows fall below 100 cfs. 3. Natural flows 48-800 cfs were recorded in 1985 and 1986 for the period August to October. WUA could actually be increased by maintaining flows 100-350 cfs during spawning season. 4. Transects at stations 2 and 3 extend up the bank and pro- vide profiles needed to permit the model to be extrapolated to 400 cfs, beyond projected impact. 5. Actual project flows may fluctuate from minimum stream flow to maximum turbine flows of 377 cfs (both turbines running at full gate). The best gate for the 1500 KW turbine is 80 cfs and the 3500 KW is 216 cfs with a total of 296 cfs. When either is running alone or in concert an effort will be made to obtain maximum efficiency which will provide the most energy (bestgate). When capacity is a target however, the maximum output will be up to full gate. Under extreme conditions the turbines may be run at low efficiencies to conserve water (see the turbine performance curves). Project flows may thus be any combination of the turbines to provide the needs and approximate the available water. To pre- vent the spills during good water years there will be an increase in turbine flow and during low flows the flows will decrease. Monitoring of snowfall and rainfall will provide data to program use. Figure 16 and 16A are both versions of the use of 200 cfs annual flow. Figure 16A provides higher winter capacity with summer spawning flows. The reduced size of the turbines (7 to 5 MW) reduces the possible project- flows. project flows will protect minimum flows and provide for maximum capacity and energy as pro- jected in the material presented. 6. Enclosed are projections for Bradley Lake which incorporates the most recent information for state oil and gas projections. I-. NMFS Page 5 The material presented here should be incorporated in the Grant Lake Hydroelectric Application 7633-002 in accordance with the FERC letter of August 19, 1986. Alternative I, developed from submitted and studied Alternatives is provided in compliance with the Electric Consumers Protection Act of 1986 which requires equal consideration of environment and power. We would like to schedule an all day meeting in the next 20 days to discuss the adequacy of data and a detailed request for any additional data. The revised instream flow report by Environsphere is attached for your review. Sincerely, Richard Poole RP/jp Encl. Kenai Hydro, Inc. Hydroelectric Planning & Development May 4, 1987 Mr. Robert Bowker U.S. Fish and Wildlife Service Sunshine Plaza, Suite 2B 411 West 4th Avenue Anchorage, Alaska 99501 Dear Mr. Bowker: Kenai Hydro has provided additional information to FERC and the agencies for the Grant Lake Hydroelectric Project, 7633-002, in accordance with the request of FFRC of August 19, 1986. The additional information supplements the Grant Lake License Appli- cation of December 90, 1984 and additional information and sub- missions after that date. Project Alternative I, developed from studied and submitted project arrangements, provides for habitat preservation in Grant Creek as requested by the agencies and has been submitted to the agencies for review. This Alternative provides for equal consideration of power, fish and wildlife protection, recreation and other aspects of environmental quality. The following is presented in reply to your letter of April 6, 1987. Information is drawn from the License application, addendum, correspondence and recent surveys at Grant Creek referred to in the presentations. 1. The WSP model requires that data be collected during stable flows is not entirely true. Data for the model can be collected during other flow if the model can be calibrated. Methods for adjusting flows are presented in the IFG manuals and allow the use of data if it is mathematically correct. We cannot always be in the field at the ideal time or predict the analysis of the data in advance. P.O. Box 1776 Lummi Island, WA 98262 (206) 758.2252 U.S.F&WS Page 2 Proper field procedures compensate for unsteady flows. The measurements were made downstream each time which would tend to make the hydraulic gradient steeper. The progressive decrease in flow shown by the Grant Creek measurements can be dealt with by calibration of the model with each measured flow and comparing the flow with the measured cross-section. The sections were compared using a single "N" number which indicated a good match. The use of the staff gage reading allowed the model to be calibrated as indicated in the methodology of the report. The model preformed well through the ranges indicated in the report from 50 to 400 cfs. Even though the useful range of extrapolation is defined as 0.4 to 2.5 times the calibration (246 cfs) the model appeared to easily preform to 50 cfs. 2. The accuracy of the model is confirmed by a stream flow measurement made by Cook Inlet Aquaculture, February 24, 1987, at station T1. Using a PVM-2A Montedora-Whitney current meter, the stream velocities at one foot intervals was measured. The depth was also measured at each station to provide an average mean column flow. The measurements showed the stream flow to be 28.5 cfs. The profile was compared with the measurements made by Kenai Hydro on October 24, 1986 and found to be a reasonable match. Comparison of model flows with the measured flow, indicate the model flows to be somewhat conservative; i.e, predicted flows are somewhat lower than actual. The additional data collection by the Cook Inlet Biologist Pat Markison, who has studied Grant Creek for the past three years, confirms the validity of the Kenai Hydro data and its use to predict the effects of plant operation. Attached is the data and comparisons. During the field survey by the agencies and Kenai Hydro, the stream was flowing in excess of the measurements made by Kenai. No out of bank flows were noted during the visit and it appeared there was considerable room for much larger flows within the normal bank. The field data confirms those observations and bank measurements made at stations 2 and 3 are considered representative of the banks of Grant Creek in the study area. Observations during the field surveys indicate that out of bank flows do not occur except in extreme conditions (i.e. no gravel bars, marks on trees, brush piles etc. are evident along Grant Creek). As indicated in the methodology of the additional information, three measurements were made at each station at .2, .6, and .8 of depth (page 10, Paragraph 1 and paragraph 1). This data is present Ilcre for YOM review. page 11, paragraph 1 indicates the average U.S. F&WS Page 3 column velocity was used to determine stream flow. The numbers in Table 1-3 are the measurements at .6 of depth and were used in the model. The columns are mislabeled and do represent FPS not CFS. The total discharge is correctly computed. 3. The ends of the transects did not end at the waters edge. At stations 2 and 3 measurement extended up the bank 2-4 feet. A high bank exist on the north bank and a lower bank on the south side of the creek. The profiles correctly show the bank to extend .3 and 1.96 feet above the measured water surface 2-3 feet from the waters edge. The measurements are consistent with the stream charact- eristics of a straight tube with the stream confined to a relatively stable bank. Stream flows of 400 cfs do not represent over the bank flows and due to the straight sides of the banks no stranding potential is represented by the sides of the stream as shown by the profiles. 4. Extropolation to the limits of the model on the upper end is not necessary to determine project effects. The penstock will only carry 377 cfs maximum and project effects will normally only extend to that limit. Higher flows would occur naturally when the lake spilled. Note the natural. flows have exceeded 1500 cfs during extreme high water years. Stranding resulting from natural occurrences is not the result of project activity. The project would be operating normally during the high water period and may be considered an additive effect, however, the flows occurring during extreme high water periods exceed project flows and will occur regardless of project activity. Normal reservoir management would keep spills to a minimum and such occurrances would be less than 3 percent of the time (See exceedance curves and Table). Additional discussion is added to the Instream Flow Report concerning stranding and habitat analysis. The stranding analysis is somewhat misleading due to the increments used and the Cook Inlet data shows how well the stream holds up due to the increase in "roughness" of the bottom. Strandable area does not increase substantially until the water is dropped from 100 to 50 cfs. At the 28 cfs, measured by Cook Inlet, the stream is bank to bank at Station T-1. As previously stated, Kenai feels project impacts between 100 and 400 cfs will. be minimal. Actual. project flows will exceed 100 cfs most of the time and average 200 cfs. 5. Minimum instream flow maintenance is described on page 4 and shown in the conceptual drawings, Figures IV-20A and IV-22A. Normally instream flow is maintained by discharge from the power- house (50-377 cfs). The range of 50-377 is the maximum limits of U.S.F&WS Page 4 the turbines and operation will not normally be in this range. The 1500 KW turbine operates most efficiently at 80-90 cfs and the 3500 KW turbine at 216 cfs. Efficient operation would call for operations to exist between 80-300 cfs for maximum use of the water. The 3500 KW generator would operate from 140-270 cfs. Average monthly turbine flows are presented for low, medium and high flows in Figure 1 in Instream Flow Report. These flows are projected to occur once every 33 years (Table 5, page 16). The flows in the license reflect the possibility of hedging or dumping to provide for lake management in March and April and in October. In the event the turbines shut down a valve in the power house is actuated to provide flows to the tailrace. The 16 inch valve utilizes water from the penstock and furnishes 100 cfs directly at the power house (Figure IV-22A). In the event the penstock is shut down the stream is supplied with water from the lake via an 18 inch pipe to the top of the falls (Figure IV-20A). This valve is automatically actuated when the gates are closed. Water is thus supplied to the head of the canyon. Since the tailrace is in the streambed the water from any of these sources will insure a supply of water is available for maintenance of stream flows as required. The penstock carries water directly from Grant Lake to the powerhouse without falling through the canyon. The water discharged from Grant Lake at the water ice interface is 2oC and with slight increases due to depth of intake the temperature at the lake would be approximately 30c, however, due to the time of passage through the pipe of approximately 7 minute, the water would cool only slightly. 1'he projected discharge temperature in Figure 2-6A reflects the lack of cooling that could occur in the canyon due to extreme tur- bulence. Immediately upon discharge from the penstock, however, the water will begin to cool and will be 0 0 C by the time it is discharged in Trail Lake. The heat exchange effect created by the rough bottom (turbulence) will be most extreme during very cold weather and wind. The discharge temperature shown will not have the effect which you project due to the rapid cooling which will occur in the stream bed. The slight increase will probably be beneficial since emergence at Grant Creek is normally June or July. Minnow trapping did not produce young of year Chinook until August. 6. In order to recover lost head, due to moving the plant to Grant Creek, Kenai will excavate a channel from the powerhouse 500 feet downstream (page 27 of Information). The channel will be lined with 4-6" rock, 1.5 to 2.0 feet deep. Rock gabions will be placed at 200 foot intervals to prevent rock from washing away during extreme high weer. A conceptual drawing is presented. U.S.F&WS Page 5 The powerhouse discharge will provide 30,000 square feet of spawning area, roughly 2 times what now exists. The low gradient in the channel will maintain the gravel and the rock gabions will stop rock from moving extensively. This will also insure that at any flow the streambed will be wetted bank to bank (no slope bank to bank). The depth and size of gravel will allow Sockeye or Chinook to successfully use the area. Since the channel represents extensive improvement to the existing available area, Kenai does not propose any maintenance to the channel except under extreme conditions. The flows normally found during project operation should have no effect on the channel. A very high natural flow may alter the channel and make repairs necessary. This event is remote and according to records would be a 50 year flood. Kenai does not feel extensive planning and repair schedules are warranted due to the circumstances. Lake management reduces the likelihood this event will ever occur. 7. The outlet for the fish bypass pipe is at elevation 650 near the falls. The pipe can exit in a relatively tranquill area since we can construct such a setting, and then permit the fish to exit to the natural stream bed. The discharge rate from the pipe has been presented on several occasions to the agencies (See Figure in Appendix, Instream Flow Maintenance). The releases would be as follows: 5 cfs September to April, 7 cfs in May and 8 cfs June to September. This could be adjusted to provide more water June -October and less November to June. Fry migration during the June to September period was the highest when water temperature significantly increases. No smolts passed out of the lake when temperatures were below 40C according to U.S. Forest Service surveys. It may be more appropriate to concentrate the water during the out migration period (if the enhancement project proves feasible). 8. ENVIRONSPHERE is revising the Draft instream flow study according to Agency comments. A .final report will be submitted to you when it is completed. Your comments should make the report more suitable for Grant Creek. Summary Kenai hydro is confident the data collected by Kenai provides a model that will. analyses stream flows from 50-400 cfs. The data is confirmed by comparison with stream flows taken in February 1987 by Cook Inlet Aquaculture. While CIAA data is inadequate to be incorporated in the IFG-2 model, it does confirm the model produced by data collected by Kenai in October is valid. Environsphere is revising the draft according to your comment. U.S. F&WS Page 6 Details of the tailrace channel are provided to show the conceptual design features. While the channel is simple, it will greatly increase the spawning habitat in Grant Creek. A roughness of the edge could provide some rearing habitat. The material presented here should be incorporated in the Grant Lake Hydroelectric Application 7633-002 in accordance with the FERC letter of August 19, 1986. Alternative I, developed from submitted and studied Alternatives is provided in compliance with the Electric Consumers Protection Act of 1986 which requires equal consideration of environment and power. We would like to schedule an all day meeting in the next 20 days to discuss the adequacy of data and a detailed request for any additional data. The revised instream flow report by Environsphere is attached for your review. Sincerely, Richard Poole RP/jp Encl. Kenai Hydro, Inc. Hydroelectric Planning & Development May 4, 1987 Mr. Donald O. McKay Alaska Department of Fish and Came Habitat Division 333 Raspberry Road Anchorage, Alaska 99518-1599 Dear Mr. McKay: Kenai Hydro has provided additional information to FERC and the agencies for the Grant Lake Hydroelectric Project, 7633-002, in accordance with the request of FERC of August 19, 1986. The additional information supplements the Grant Lake License Appli- cation of December 20, 1984 and additional information and sub- missions after that date. Project Alternative I, developed from studied and submitted project arrangement, provides for habitat preservation in Grant Creek as requested by the agencies and has been submitted to the agencies for review. This Alternative provides for equal consideration of power, fish and wildlife protection, recreation and other aspects of environmental quality. The following is presented in reply to your letter of April 1, 1987. Information is drawn from the License application, addendum, correspondence and recent surveys at Grant Creek referred to in the presentations. 1. Field data presented in the report represents a summary of data from field notes. The description is correct in providing the method of establishing the end of the transect prior to commencing the actual measurements. This procedure is discussed in IFG methods and reduces potential needs for data calibration. The data does show measurements above the surface water measurements and provides profiles needed to extrapolate flows above measured flows. P.O. Box 1776 Lummi Island, WA 98262 (206) 758.2252 ADF&G Page 2 While the data was collected during a drop in water flow it calibrated and the model preforms well from 50 to 400 cfs. The progressive drop in flows indicates correct measurements were made at all stations. The lower flows were confirmed by data collected by Cook Inlet Aquaculture Association February 24, 1487. The profile of the measurements made by CIAA corresponded reasonably well with Kenai's measurements at station 1. The data shows the model to be somewhat conservative i.e., model flows slightly lower than measured flows. The data provided a valid modelwhich was used in the Instream Flow Report. 2. The Tennant method was not used to support ramping, but to support minimum instream flows. The Tennant method is used for seasonal averages but is also commonly averaged on an annual basis. The original license application provides a discussion of the negoti.- ations using the Tennant method. 3. A conceptual drawing of the powerhouse discharge channel is presented which updates the original presentation. Water to the channel is normally provided by turbine flows from the power- house. Emergency water is provided from two sources (Additional information page 4) and shown in conceptual drawings IV-20A and IV-22A. If the turbines and generators are shut down, flow is continued through a by-pass valve at the powerhouse. In the event the penstock is shutdown, flow is drawn from the lake via the fish - bypass pipe. These all supply water to the tail -race -powerhouse discharge channel. The channel will provide 30,000 square feet of spawning and rearing habitat, nearly two times as much as now exists in Grant Creek. 4. Long term maintenance and operation will depend only on extreme damage to the system. The channel represents a large in- crease in available spawning area and would require a catastrophic event to reduce the available area. A natural, self-sustaining system similar to a natural stream is proposed. 5. The stranding curve is misleading since the incremental plots were done on the average, not the range. The model was run in 50 cfs increments i.e., 200-150, 150-100 and 100-50 cfs. The graph was plotted at the mid -point of the increment. The point should have been placed at the lower valve of the increment. Stranding potential thus does not increase substantially until the flow rate drops below 100 cfs. The model demonstrates how well the stream flows hold up at lower flows. ADF&G Page 3 6. Naturally occurring fluctuations in stream flow are recorded by CIAA and presented in their reports in 1985 and 1986. Flows in August to October ranged from 46-210 cfs in 1985 and 48-800 cfs in 1986. The WUA curve presented in the stream analysis shows maximum spawning habitat at 350 cfs. However, it appears that flows less than 100 cfs are regularily recorded in Grant Creek during spawning season. Project flows from 50-377 cfs are within the range of natural flows. The low flows would be eliminated and extreme high flows would be reduced. The overall effect would be a stabilization of flows and spawning habitat. Flows in 1986 of 800 cfs actually blew Coho out of Grant Creek. The material presented here should be incorporated in the Grant Lake Hydroelectric Application 7633-002 in accordance with the FERC letter of August 19, 1986. Alternative I, developed from submitted and studied Alternatives is provided in compliance with the Electric Consumers Protection Act of 1986 which requires equal consideration of environment and power. We would like to schedule an all day meeting in the next 20 days to discuss the adequacy of data and a detailed request for any additional data. The revised instream flow report by Environsphere is attached for your review. Sincerely, j� R'chard Poole RP/jp Encl. RESPONSE TO USFWS COMMENTS Response to General Comment 4, Page 2 The habitat curves will be adjusted in the final report to more clearly reflect comments made by the USFWS and to revise errors in the draft. We believe that the description provided in the text (i.e., any substrate less than 12 inches in diameter was considered spawnable [=1.0 suitability] for both chinook and sockeye) is sufficient and that a curve does not need to be depicted. Response to General Comment 5, Page 2 A reference is attached concerning the stranding analysis. This reference describes the technique used to quantify potential effects of daily flow fluctuations at Grant Creek on stranding of juvenile salmonids. Response to Comment on Page 11, Paragraph 2 Change in discharge during a WSP measurement period is not uncommon. In fact, it is truly rare to find discharges measured at successive cross -sections which do not vary by 10 percent or more. This is largely because cross -sections for habitat analysis are rarely consistent with respect to their bedform, substrate and roughness and uniformity of flow. Stated another way, the actual discharge through a measured reach could have no variation during the measurement period, and discharge calculations at each cross-section could vary substantially, even if they were measured as accurately as possible. Such discrepancies are impossible to reconcile through mathematic proportionation because their source is complex hydraulics, not simple change in discharge. Detection of an unsteady flow event, then, should not be done by comparing discharge measurements at different cross -sections through the day, but by measuring discharge «- at the same (preferably the most uniform) cross-section at two or more times during the day. This cross-section may not even be one of the IFIM cross -sections. Further, these measurements should be made simultaneously with precise water surface elevation measurements at the selected cross-section. Regarding the Grant Creek data, it is not possible to determine the exact discharge change during the day because sequential measurements were not taken at a discharge measurement cross-section. Two points tend to support the hypothesis that the measured flows reflected a reduction in discharge during the measurement period. First, the calculated discharges at the three cross -sections descended in an orderly fashion during the day (297, 261 and 246 cfs, respectively). Second, the staff gage reading descended 0.21 ft during the measurement period, which proved to be very near the model stage reduction when velocities were reduced proportional to the difference in calculated discharges. (See methods section of our report.) -2- This does not eliminate the possibility that anomalous discharge variation existed, it simply shows that some of the variation may be reconciled using simple proportionation techniques. Ultimately, the effects of discharge variation on reliability of the predictive model must become a matter of mutual agreement among the parties enjoined in the study. Neither the Instream Flow Group nor the USGS has published an exact level of discharge variation above which all hydraulic simulation results become unacceptable; nor will they comment consistently on the merits of correction techniques. The Grant Creek measurement discharge variation problem has been given minimal collective analysis to determine: (1) actual source of the variation; (2) extent to which the corrections resulted in a reasonable predictive model; and (3) ultimate effects which the evaluation and corrections might have on the reliability of habitat estimates. The agencies should either state that 20 percent variation is too much and cite the sources of their decision, or elect to convene a meeting to discuss an evaluation process. Response to Comment on Page 11, Paragraph 6 Comment noted. The final report will reflect these corrections. Response to Comment on Page 21, Paragraph 3 The stranding analysis defines the potential for stranding based on gravel -bar slope and substrate. The analysis does not establish ramping rates. Response to Comment on Page 9, Paragraph 4 The revised report states that certain chinook and sockeye results may represent habitat relationships for some life stages of coho, rainbow trout and Dolly Varden. Generally, however, the actual instream flow study results for all target species should be based on a detailed, final list of evaluation species provided by the agencies along with any prioritization rankings they may have. It is not the applicant's responsibility to determine evaluation species; the agencies should provide a list of species and proposed analyses, preferably rior to seeing the results of the instream flow studies. Response to Comment on Paqe 10. Para4raohs 3 and 4 The development of values for suitable substrate for spawning chinook and sockeye salmon were intended to cover a much wider range than might be found in the Grant Creek system. This was none to assure that all possible substrate types that might be used for spawning would be included. Substrate suitability values for sockeye were derived from information in Estes and Vincent -Lang (1984) which was generated from extensive studies on the Susitna River, Alaska, by the Alaska Department of Fish and Game and literature review. The values they used were: -3- Particle Size Suitability Index Silt 0 Sand 0 1/8-1" 0.5 1-3" 1.0 3-5" 1.0 6-10" 0.25 > 10" 0 This implies that substrate up to nearly 10 inches could be suitable, but optimum values are in the 3 to 5 inch range. As stated in the Envirosphere report, observations of substrate sizes from Kenai Hydro were fairly broad in nature. Therefore, to assure that all possible substrate lies suitable for spawning were encompassed, all substrate less than 12 inches was considered suitable. Any greater than 12 inches was considered unsuitable. Estes and Vincent Lang (1984) developed substrate suitability curves for chinook salmon, again from extensive studies by the Alaska Department of Fish and Game on the Susitna River, Alaska, and literature review. The values they used were: Particle Size Suitability Index Silt 0 Sand 0 1/8-1" 0 1-3" 0.65 3-5" 1.00 5-10" 0.70 > 10" 0 Intermediate values also exist, but sizes less than 10 inches are potentially suitable, whereas those greater than 10 inches are not. We have been unable to locate the data referenced by the U.S. Fish and Wildlife in Estes and Vincent -Lang (1984). Therefore, we request that the U.S. Fish and Wildlife Service send us either the data or the specific reference (page, paragraph, and line) where the USFWS found this data. This would greatly assist us in understanding the USFWS comment. In a manner similar to the analysis for sockeye, it was assumed that all substrate sizes less than 12 inches are spawnable by chinook, and anything greater than that is not utilized. This extra margin was considered to encompass most sizes that were spawnable and to account for the fairly broad range of substrate sizes described by Kenai Hydro. Response to Comment on Page 21, Figure 2 Although Figure 2 indicates that a minimum depth of two feet is needed to obtain a suitability of 1.0, the text (Page 11, lines 2-4) states that any depth over 1.0 foot is considered potentially spawnable (i.e., suitability=1.0). Therefore, the figure (and any changes that might occur in the model) is in error and will be revised in the final report. -4- Response to Comment on Page 13, Figure 3 The suitability curve depicted on Figure 3 is actually a curve developed by Bechtel Civil and Minerals (1983) for a proposed project on the Chackachamna River, located across Cook Inlet from the Kenai Peninsula. Therefore, it is incorrectly identified in the figure. We will use the Burger et al. (1983) curve for the final report, as it encompasses a wider range of velocities as being suitable. Response to Comment on Page 15, Figure 4 Comment noted. These figures will be revised in the final report. Response to ADFG Comment on ADFG Letter, Page 2, Paragraph 2 ` The report text indicates that any depth greater than 1.0 foot were considered to have a suitability value of 1.0. As correctly pointed out, the figure is in error and will be corrected in the final report. Also, the modeling will be revised accordingly. Response to NMFS Comment on Page 21, Rampin<_Rates Figure 2 of the draft report may be somewhat confusing. Although on a gross level it appears that strandable area increases below about 125 cfs, this is not the case. The stranding model was run in 50 cfs increments of flow change. These were, for example, 200 to 150, 150 to 100, and 100 to 50 cfs. When the figure was developed, the amount of strandable area was placed at the midpoint of the increment (for example, 175, 125, and 75 cfs). A different graphic representation will be included in the final report to clarify the results. These results will indicate that strandable area does not show a dramatic increase until the discharge is decreased in the increment of 100 to 50 cfs. Response to NMFS Comment, Page 3, Page 10, Paragraph 4, Chinook Adults The curves used for spawning chinook were derived from Estes and Vincent Lang (1984). The text in the draft report reflects a 1.0 foot depth as having a suitability value of 1.0. The accompanying figure (Figure 2) in the draft report is incorrect and should reflect a habitat value of 1.0 at 1.0 foot depth. This figure and any changes in the model results will he described in the final report. Ic'Iv:u,r�nu (� UinrVn "� � Z a 3 d U j 1 m oL o \\ CY ly 1� Z i �- O W i 1 a t v J 1 3 0 N A O I p �I f � r r Q �) � v S 4 1- W �i- N d: x � IT Z B � U � t�� T J f r W W a e' N v a u,, a< F' Z UI .[ W (� U J a J, N L;4 O 9 Ml � c v 0 s w r� J W J d x •Z , 6 .g rI' 1 �, F� Z bu.K 0-- a{o 1 2.65 z,P IZ-S_ $1 _7;85 L_ - 3_ _ n(—K_— - PA - lk - -Z_- - 3,08 7750..55, E .. ;,M 735 o,e8 ' S,zE � _8, . _8.L5 8<LS 8'0 z _ _ 9 44s5 3vOJ _13; u J 1_0.80_ 47'1d /I 51 11 13 59 4 ts_L•3$ 61 i 16 /NG� —4a 2. _ 44 3 5._ f _ Z_ 46 > L..l 2,/ 4,Zli� 4.0- 2,�6 1.1 _ z--g-- z -g _Z4_ ,(:-14_.B,bz _G LD 3_G - 16_ -- - - ------------ - - - ----- 3.41 3,7? 2.37 ' 7} _4.10 _3.4i 5,10 3.6T j5p z,4y� 4L - _ - --- - ---- - - - - - - - -- ntiLKh �rLS wJ1�P � .1I T,Z SOA I°-zV.es Prr+ 3 � ( Ot f - - - r TI _ Z .4--k 2 , s6 _ Sr1,r _ 7. 62 3 p.z1 Z,)o z,L: 10-/6 7J9_,u( I¢.s /0_18 8r05_95. z < 4 5 3u.—ow �8 (S-Ld itiy5—) : T 2 S --- S,�u _ A-6 7 ZR¢ 3, IY _z�?8 .5,04 2. 38 3 S 4.35 3,z1 z4 8-, 19 l04 - I 7 - � / - '_3D 11- Z.�4. 3.Z3_ ,3�s 121? bt?51•� 94m4 `16- I -10 S._51f1. -Y 14 1._Os 3, 7 __B.B ID _8..6ohr OJ - 1¢ / S z _.1 b_G_l7 P,77 3,7_7 3,44 !—Z-IS -�5,7s _l.so L•C7 ro-x4 �.iF`z .qr _ off ----- -- --- — j It 8T - �s+,tiv Ol Flea -' .04 pu.�e5 fur �lvw dl.& �i- M c [ • J 1l1 , Eq d9 06 klZ N t - I N N �d C4 M P► M a-• ",9 q co00 N NMN rJ M'� M, id 1 N V- In A M _. - - - ti �1 .l Q, eY rl f 1 ��� N� kD bN NNn�1N' p ai dy 5+Ar1o)J -r1 CURRENT METER WORK SHEET wood &+,ka 4, k?Oj s4nj � r � ,ocation G RA Cfz� �K- 60 S-noff Cab @ //no . r a • —T—1 A�� n ;o enta WAJ ,clear - r✓o iCe fil CCa11M IMP C:: r1ont-dorA /,ithey Gar (^lpfgr >istance from Length of Depth Average Velocity Average' Discharr,e .nitial point Section (ft) Depth (ft/sec) Velocity ift/sec) " (ft)' (ft) Aft) (ft/sec) iAA A B C Axsxc ......._ �, 1, ,_ ...... ` ,Z :.......... v .o0 41 �, _ Af Of 1.2 _ r 36 7 .Go3i 43 13 r o ... � 45 I.D3 751 / . D Z.22.3 4} Z �4 •7 SG L ' -19� oS .7D! CURRENT METER WORK SHEET ,ocation (n-,/A i%A C_.! & (l, t t 1 :omments Z listance from .nitial point (ft) Length of Section (ft) A Depth- (ft) Average Depth p (ft) B -Velocity (ft/sec) Average' Velocity (ft/sec) C Discharge (ft/sec) AXBzC 41 n • •' :.. • � ,63 z5z ,3Z IZ8 ,ODS j,�,, -to Si ................. , S C.� S. tR ACT, ........ . Instream Flow Chronicle A. Training Announcement January, 1986 Vol. II, No. 4 CSIJ Conference Services A Technique for Quantifying Effects of Daily Flow Fluctuations On Stranding of Juvenile Salmonids by C. Mike Prewitt Senior Aquatic Biologist and Cliff Whitmus Associate Fishery Biologist Envirosphere Co. Bellevue, K'ashington Backoround Envionmenta? effects of fluctuating water discharge levels below hydroelectric dams have been the subject of considerable recent study. In many instances, daily fluctuation impacts have been greater than those fror, steady changes in weekly or monthly flow. Daily flow fluctuations have had negative effects on anadromous salmonids particularly during the spawning/ incubation period and during juvenile rearing and smolt outmigration. In the case of spawning/incuba- tion, impacts have resulted from flow fluctuations which dewater redds located within the area dewatered on a daily basis. Rearing and outmigrating salmonids are typically affected through stranding during a rapid water level drop (or "downramp"). Stranding, either on large gravel bars or in isolated potholes, has been shown to cause significant mortality on certain salmon and steelhead stocks in Washington State. Abiotic factors which influence daily fluctuation effects are generally related to channel morphology, specifically depth, velocity and substrate for spawn- ing/incubation effects and gravel -bar slope and substrate for stranding. In the case of stranding, there is good evidence to indicate that stranding frequency increases with decreasing gravel -bar slope. Expansive, flat bars are generally associated with higher standing rate than are steeper -sided areas. Conversely, stranding appears to increase with increasing substrate size because of the tendency for juvenile fish to seek cover in the larger substrate interstices (Stober et al. 1981, 1982). Use of PHABSIM To quantify the effects of daily fluctuations on juvenile salmonid stranding, a variation on tradi- tional use of the U.S. Fish and Wildlife Service Physical Habitat Simulation (PHABSIM) system was used. From information in the literature, it was determined that gravel -bar slopes le•.s than four percent were more likely to cause stranding (Sauers- feld 1978); conversely, those greater than 9 percent were felt to provide enough gradient to reduce strand- ing (Bauersfeld 1977). Using these gradients as general guidelines, a curve relating gradient and stranding probability (or factor) could be drawn (Figure 1). Similarly, a curve relating substrate to stranding probability (or factor) might appear as in Figure 1 (lower). Here, the substrate codes 1 through 15 are associated with for example, sand (=2), gravel (=5), cobble (=7), boulders (=10), etc. The input to the PHABSIM hydraulic simulation computer programs normally consists of channel cross-section coordinates and substrate sizes. With respect to slope only, Figure 2 illustrates a hypothetical stream channel with various cross -sectional slope conditions. If a daily downramp were from Q+ to Qi, a relatively large, low slope area would be exposed, with high risk of stranding. If discharge was reduced from Qi to Qr in a daily downramp, a smaller area of higher slope would be exposed, causing generally lower concern for stranding. If substrate were also of concern, the joint stranding factor (from multi- plying slope stranding factor x substrate stranding factor) could also be determined. To predict total strandable area associated with any downramp incre- ment, standard PHABSIM software provides all necessary hydraulic simulation and habitat (or stranding) calculations. (See Figures 1, 2, and 3 on page 2) Inside: • Evaluation of Habitat Quality and Quantity • What the IFIM User Must Know • Instream Flow Information Systems (IFIS)"STUDIES Data Base • IFIS'STRATEGIES Data Set • Publications in the Opportunity Series • IFG Training In actual use, it was necessary to make certain modifications or additions to normal PHABSIM processing in order to obtain results. These included: -Use of depth and velocity preference curves which reflected preference of 1 for all depths and velocities. This allowed depth and velocity to be retained for hydraulic simulation purposes but negated in the habitat analysis. -Use of the PHABSIM cover code to incorporate slope/ substrate joint stranding factor. -Use of a computer program to compute slope within the individual cross -sectional cells, and to enter those slopes in the substrate/cover space of an IFG-4 data deck. Interpretation of Results Recalling that the primary concern for stranding was the difference between the peak afternoon discharge and minimum after the evening downramp, (defined as ramping amplitude), the analysis involved plotting weighted stranding area vs. incremental decreases in discharge as in Figure 3. In this example, it is apparent that stranding area increases rapidly with fluctuations in the 11,000 to 9,000 cfs range. Fluctuations in the 12,000 to 15,000 and 4,000 to 7,000 cfs ranges appear to cause less stranding concern. This relationship would be valuable to hydropower planners to highlight discharge ranges within which fluctuations would be especially likely to cause stranding, as well as those within which fluctuations might not be problematic. A further analytic step would be determination of a maximum permissible ramping amplitude given a fixed average flow. Again, based on Figure 3, for example, if the average flow was 12,000 cfs, a daily amplitude of ± 1000 cfs would not cause concern for stranding. Amplitudes of ± 2,000 or ± 3,000 cfs however, would greatly increase stranding risk. Such guidelines would be of obvious use in design and feasibility studies of unconstructed hydroelectric projects and could also be used to quantitatively assess alternative operating regimes of existing hydropower projects. This method addresses only the stranding effects of flow fluctuations as they relate to certain salmonid life stages. Comprehensive assessment of flow fluctuation should include consid- eration of egg dessicatlon as addressed using the HABSP program described in the IFG Technical Note 15 and in Bovee (1985) or other techniques. Although the stranding assessment technique has not yet been formally applied, we feel that it has at least two positive potentials: First, it has illustrated that the PHABSIM software system may be used in a variety of ways when basic channel -related variables are considered. The ability to use PHABSIM software allowed us to calculate an area -weighted index using an accepted process, without the need for extensive computer programming. Second, the effort should encourage communications between aquatic biologists and hydropower planners which should help ensure that operating criteria with respect to flo fluctuations will be incorporated in the project feasibility studies and ultimately in design and operation. Such coordinated efforts are increasingly i.portant as hydropower projects must meet more stringent environmental and economic requirements. 9 P r o R T R E N N T I I N A 0 L T U T R E N N 0 T t i N A o L SLOPE SUBSTRATE 511t Figure 1. Hypothetical relationships between stranding potential and gravel -bar slope and substrate size STREAM CHANNEL SLOPE w.e c of uoeE-,n �� w.S.E.O SIOeE •S\ aoeE•,\ smarono anu O4Mri M PSCMMOE Figure 2. Representation of stream channel slope at various water surface elevations, and potential stranding areas CHANGEIN 75 STRANDING AREA flit x 1000) 50 25 15 to 13 12 11 10 e 6 7 6 5 a 3 DISCHARGE N CFS a10G0 Figure 3. Discharge (as 1000 cfs downramp increments) vs. change in stranding area relationship Literature Baunsfeld, K. 1977. Effects of peaking (stranding) of Columbia River dams on juvenile anadtomous fishes below the Dalles Dam, 1974 and 1975. Wash. Dept. Fuh., Tech. Rept. No. 31, 117 p. Bauetsfeld, K. 1978. Stranding of juvenile salmon by flow reductions at Mayfield Dam on the Cowlitz River, 1976. Wash. Dept. Fish., Tech. Rept. No. 36. 36 pp. Bovee, K.D. 1985. Evaluation of the effects of hydropeaking on aquatic macroinvertebrates using PHASSIM. pp. 236-241. In Proceedings of the Symposium on Small Hydropower and Fisheries, F.W. Olson, R.G. While, and R.N Itamrq eck Amer. Fish Sur, Bethesda, MD, Sinber, Q.1., S.C. Crumley, E.D. Fast, E.S. Killebrew, and R.M. Woodin. Trial. the effects of hydroelectnc tinchatgr fluctuallnns on salmon and steelhead survival in the Skagit River, Washington. FRE-UW-6127. 211 pp. Stobeq Q.I. S.C. Crumley, D.E. Fast, LS. Killebrew, R.M. Wnodin, G. Eng- man, and G. Tutmark. 1982. Effects of hydroelectric discharge fluctua- tions on salmon and steelhead in the Skagit River, Washington, FRI-UW- 8216. final Report for Seattle City Light. 302 pp. Evaluation of Habitat Quality and Quantity by lean Baldridgee In instream flow assessments using the Instream Flow Incremental Methodology (IFIM), our evaluation is based on a habitat index -- Weighted Usable Area (WUA). WUA, a familiar term to all IFIM Users, represents a measure of available habitat for a particular species and life stage at a specific streamflow. WUA represents the combination of both habitat quality and quantity. In the habitat simula- tion process, WUA is computed for each cell by muliti- plying an area of the cell by a factor describing the suitability of its physical microhabitat character- istics called the composite suitability index. The WUA's for all cells are su-.-red to get the total WUA for each stream segment. A WL;A of 100 may represent 1,900 sq it with a lo.-level suitability of 0.1 or Too sq ft of optimal habitat with a suitability of I.C. The best interest of the fishery may not be served by trading optimal habitat for a larger amount of marginal habitat even though the WUA values may be the same. The similarity in WUA indices for such different habitat conditions has been a longstanding criticism of the IFIM. In some assessments, decisions regarding flow allocation or fisheries management may be facilitated by evaluating the two components (quality and quantity) of WUA separately. Both habitat quality and quantity can be easily derived in an IFIM anlysis. Habitat area (HA) can be defined as the area having positive WUA. It is the quantity component of habitat and represents the actual area of the stream usable by the species and life stage evaluated. It may be derived by using binary criteria in a normally con- figured HABITAT simulation. In binary criteria, the usable habitat has a suitability of 1.0 and unusable habitat has a suitability of 0.0. Thus, the WUA output from binary criteria is no longer "weighted" and portrays an actual area, the gross habitat area. -Jean Baldridge is a project scientist with Entrix Inc., Anchorage, AK. HA derived in this fashion is expressed as sq it per 1000 lineal ft of stream and pertains to only one life stage.' Habitat quality in IFIM modeling is represented by composite suitability indices. Composite suitability indices are computed for each cell in the study site by multiplying the habitat suitability indices for each microhabitat variable (i.e., depth, velocity, substrate and cover) together. Habitat quality can be evaluated as a function of streamflow by calculat- ing the average composite suitability index for each species and life stage. This index is developed by dividing the WUA value by the corresponding habitat area (HA). The resultant ratio which ranges from 0 to 1 is termed the habitat quality index (IIQi). Since WUA is computed by summing the products of the composite suitability index of each cell and its area, development of the HQI simply reverses the process and divides WUA for the entire site by its gross habitat area. HQI's can be used to compare habitat quality between sites or between species and life stages. The mechanics used to develop these additional stream - flow -specific indices can be used in other ways. The quantity of optimal (suitability of 1.0) or good (suitability of 0.5 or greater) habitat can be evaluated by changing the binary criteria to reflect the desired habitat range. Thus we can evaluate gains and losses in higher quality habitat as flow changes. Development of both HA and HQI can benefit fisheries resource managers and we routinely calculate them in our IFIM assessments. These indices remove some of the uncertainty associated with WUA values by iden- tifying the component (quality or quantity) of WUA that is sensitive to changes in flow. They can be easily determined using IFIM software and simple division. 'Composite habitat areas for all life stages of each species evaluated in a HABTAT run are found on TAPER, but habitat areas for specific life stages can be evaluated only by making separate runs. Seminar on Instream Flow Methodologies (Contact: Maureen Lenihan, EPRI, (415)855-2127) February 25, 1986, Crystal Gateway Marriott, Arlington, VA This seminar is based on a recent Electric Power Research Institute study to evaluate techniques for establishing instream flow releases. The study reviewed over 50 methods, including the U.S. Fish and Wildlife Service Instream Flow Incremental Methodology (IFIM). Some of the methods were designed to estab- lish biologically appropriate flow releases from dams and diversions. Others developed functional relation- ships between indices of habitat quality and instream flows. Several used flow along with other input variables to characterize stream habitat quality, and a few were intended to predict measurable biological responses, including fish standing crop and width of riparian vegetation. Most aspects of model develop- ment and verification were considered, and the results of all available model testing and validation were included. This seminar, presented by the authors of the EPRI study, will describe the approach used in the evaluation, the conclusions, and the recommenda- tions for future research, MEMORANDUM State of Alaska office of the Governor Division of Policy TO: The Honorable Steve Cowper DATE: February 25, 1987 Governor FROM: Mary Halloran W111� PHONE:465-3568 Director Jack i Seniorr Analystalyst(//`/� � SUBJECT: Bradley Lake Hydroelectric Project In April 1985, the Office of Management and Budget (OMB) determined that the proposed Bradley Lake hydroelectric project was econom- ically feasible and recommended to former governor Sheffield that the project be approved. As you are aware, a number of factors affecting the project have changed substantially in the nearly two years since that recommendation was made. These factors, most of which are linked to the recent sharp decline in petroleum prices, include: (1) the long-te Inlet, with (2) current and (3) the State's $218 millio Legislature :m outlook for prices of natural gas in Cook which Bradley Lake power must compete; forecast power demand in the Railbelt region; fiscal position and ability to appropriate the n equity investment originally approved by the for Bradley Lake; and, (4) the terms under which the Railbelt utilities will agree to purchase power from the the project, especially the provision which makes the revised power sales agreements contingent on full State funding of the proposed Railbelt transmission intertie system. Because of these changes in key project parameters and the magnitude of the State's financial commitment to the Bradley Lake project, the Division of Policy has undertaken a thorough review of the economic and financial feasibility of the project in light of Governer Steve Cowper Page 2 February 25, 1986 current conditions and the best available estimates of future trends. This memorandum summarizes the results of our review and discusses the options available for completing, delaying -and - terminating the project. Summary of Findings • Our review indicates that the Bradley Lake hydroelectric project is still economically feasible, although the projected net benefits of the project are now substantially lower than estimated in the 1983 project feasibility study. This reduction in net benefits has resulted primarily from the sharp decline in current and forecast Cook Inlet gas prices during the last two years. If construction of Bradley Lake had not already begun and over $45 million been spent on the project, we would now consider the project to be only marginally feasible and would not endorse construction of the project without a more comprehensive reevaluation of project design and feasibility. However, when the sunk costs of the project are considered, including additional expenses which would be incurred if the project were terminated, completion of the project becomes more attractive than if the project had not entered the construction phase. Other factors in addition to the project's sunk costs have partially offset the negative impact of falling gas prices on the feasibility of Bradley Lake. A construction financing arrangement has been implemented which is expected to reduce financing costs by about $30 million from the level estimated in the 1983 project feasibility study. The construction cost of the project is also expected to be substantially lower than originally estimated because of lower than projected inflation rates and a recent downward trend in construction costs for major projects of this type, both in Alaska and nationally. This downward cost trend is supported by the experience of the federal Alaska Power Administration, which is nearing completion of a major generation addition to the Snettisham hydro project near Juneau at an expected cost which is at least 15 percent less than the original project cost estimate. • Demand projections by Railbelt utilities are now much lower than in 1983, but this change does not appear to affect the feasibility or timing.of the Bradley Lake project. At 90 megawatts, Bradley Lake is a relatively small project in comparison to total Southcentral or Railbelt power demand. Even with no load growth over the next ten to fifteen years, a large percentage of the existing gas generation capacity Govern:>r Steve Cowper Page 3 February 25, 1986 is expected to require replacement between 1988 and 1997. Two years ago, utilities expected to install new gas generation in the 1989-90 period, in addition to receiving power from Bradley Lake. Now with lower demand projections, it is expected that Bradley Lake power would forestall the need for new gas generation until the mid-1990s, but utility officials state that if Bradley Lake is not completed, an equivalent amount of gas generation would have to be installed by 1989-90. The rate impacts of Bradley Lake depend on final financing arrangements and the number of utilities participating in the project. Although additional analysis is necessary, it appears that relatively small increases in retail rates may be required during the first years of project operation -- a few percent at most. The potential for unacceptable rate impacts is greatest for the Homer Electric Association, because of the utility's small size, high debt load and the possibility of major declines in the system's power sales. over the life of the project, Bradley Lake will produce power at substantially lower rates than gas generation, due in part to the economic advantage of the project and in part to the State's equity investment subsidy in the project. • Economic feasibility is only one of several key issues concerning Bradley Lake. The plan of finance for the project and the status of power sales agreements are of equal importance in the decision whether to continue project construction. The revised power sales agreements which will be submitted to the APA board for approval on February 27 are now contingent on full State funding of the Railbelt intertie system. In essence, these proposed contracts merge the Bradley Lake and intertie projects and invalidate the Bradley Lake plan of finance which was approved by OMB, as required by statute, in 1985. This issue is highly complex and is discussed in detail in the body of this report. On February 18, 1987, the Attorney General issued an opinion which confirms that the Anchorage Municipal Light 6 Power utility cannot commit to a power sales agreement for Bradley Lake without advance approval of the agreement by the Alaska Public Utilities Commission (APUC). The implications of this ruling must be carefully considered before proceeding with further contract awards for Bradley Lake. a Governor Steve Cowper Page 4 February 25, 1986 Recommendations • Although the projected net benefits of the Bradley Lake project are now substantially lower than in 1985 when OMB recommended approval of the project, our review indicates that the project is still economically feasible and that completing the project is likely to provide lower long term power costs than alternative gas generation. • However, we do not believe that additional construction or procurement contracts for Bradley Lake should be awarded or released for bid until final, unconditional power sales agreements have been signed by the purchasing utilities. The APA board is being asked to approve proposed power sales agreements which are clearly conditional contracts, pending legislative appropriation of funds for the Railbelt intertie system. Obligating additional State funds for Bradley Lake construction based on these conditional agreements appears to violate both a legislative statement of intent which was attached to a prior Bradley Lake appropriation, and the formally adopted policy of the APA board of directors. Although the APA staff has suggested that the existing signed contracts with the Chugach and Homer Electric Associations satisfy the requirement for unconditional agreements, there is disagreement on the enforceability of these contracts. • If construction of Bradley Lake is to proceed, we feel ti re are two basic options for the Alaska Power Authority: (1) Negotiate with the Railbelt utilities to delete the conditional link of the revised contracts to legislative funding of the intertie system, and to develop a workable power displacement agreement; or, (2) Delay the award and bid of additional project contracts until the Legislature acts, or fails to act, on an appropriation for the interties. If the second option is pursued, consideration should be given to reducing expenditures for work in progress in order to reduce project termination costs in the event that the Legislature fails to make the necessary intertie appropriation and the utilities are unwilling to accept Bradley Lake as a stand-alone project. • Feasibility studies on the Railbelt intertie system are now in progress and will be completed in late April. Although the Legislature is free to appropriate funds for the construction of the interties at any time, we do not believe the APA should endorse or support the intertie projects nnt.il the feasibility studies have been completed and reviewed by the board. ro do otherwise would be to lgnoro� Governor Steve Cowper Page 5 February 2', 1986 the systematic project approval process which is required under AS 43.83.177-44.83.185 and APA regulations. Project Overview proigct History. The Bradley Lake hydroelectric project was first studied by the U.S. Army Corps of Engineers, beginning in the late 1950's. Although the project was authorized for construction by Congress in 1962, no appropriations for project construction were ever made. After efforts by the State of Alaska to develop a joint construction arrangement with the federal government proved unsuccessful, the Alaska Legislature approved transfer of the project to State control in 1982. A Bradley Lake feasibility study was completed for the Alaska Power Authority (APA) in 1983. The study concluded that the project was economically feasible. In 1984, the Legislature authorized construction of the project at a cost of $300 million (in 1983 dollars). The Legislature also appropriated $50 million for project design and construction as part 'of a four-year, $200 million appropriation later struck down by a court ruling. In prior years, $18 million had been appropriated for project design and licensing. In 1985, the Federal Energy Regulatory Commission (FERC) issued a construction license to the APA. In June 1985, conditional power sales agreements for Bradley Lake were signed by the Chugach Electric Association and the Homer electric Association. The Legislature appropriated an additional $50 million for the project, raising the total amount of project appropriations to $118 million. In 1986, an additional $50 million was appropriated by the Legislature, but was subsequently restricted by former governor Sheffield in August to limit the State's growing deficit. A contract for site preparation for the project valued at $22.9 million was awarded by the APA, with onsite work begun in June, 1986. Cmrrent project Status.. Approximately 16 percent of the overall pr.nject construction has been completed. The site preparation contract is about 80 percent complete; most of the project access roads and the airstrip have been finished; the Bradley River diversion tunnel is nearing completion; the powerhouse site is being excavated, and permanent project housing and offices are more than half finished. Bids for the turbine/generator procurement contract were opened by the APA on January 29, but have not been awarded pending approval by the APA board of directors and revision of certain bid elements. Governor Steve Cowper Page 6 February 25, 1986 a Apparent low bid was $12 million, which is $2.5 million or 17 percent less than the project budget amount of $14.5 million. Under the current project schedule, the main general civil construction contract is slated to be released for bid in March and awarded by June, with onsite work to begin in July. Proiect Exuenditurea nd eudq�. As of January 31, 1987, expenditures on the Bradley Lake project totalled $45,377,000. If site preparation and project design work continues as scheduled, a total of about $55 million will be expended by May, 1987. The current official construction cost estimate for the project is $356 million, in nominal or as -built dollars. The APA does not intend to formally modify this estimate until after bids are received for the main construction contract. However, the APA staff believes that the official cost estimate is probably high, for three reasons: (1) The estimate is based on July 1983 prices escalated at inflation factors ranging from 5.5 percent to 6.5 percent over the course of project development and construction. Actual inflation during 1986 was less than 2 percent and has not exceeded 4 percent during the last four years. Even if inflation returns to the 5.5 to 6.5 percent range during the next several years, the completed cost of the project should be lower than the estimate because of the low inflation rates from 1983 to 1986. (2) The current construction market for major projects such as Bradley Lake is currently depressed both in Alaska and nationally. As a result of increased competition for the fewer projects under development, construction and equipment procurement bids have shown a distinctly lower trend during the last two to three years. For example, the federal Alaska Power Administration is nearing completion of the Crater Lake addition to the Snettisham hydro project near Juneau, and expects to complete the project for at least 15 percent less than the original project cost estimate. Also, the Bradley Lake site preparation contract was bid at $23 million, compared to the engineer's estimate of $33 million. As mentioned earlier, the low turbine/generator procurement bid was $2.5 million under the estimated cost of $14.5 million. (3) The current project budget includes a contingency allowance of approximately $59 million, or 17 percent of the total project cost of $356 million. The original project budget was based on a contingency amount of $48.7 million (14 percent); however, the amounts saved through lower than Governor Steve Cowper Page 7 February 25, 1986 estimated bids on the site preparation, design, and construction management contracts have been shifted into the project contingency for accounting purposes. Additional reserves are still being held for the remaining work on these contracts, but the actual savings for work completed to date total about $10.4 million. The project contingency allowance could conservatively be reduced to the originally budgeted amount of $48.7 million to reflect these savings, as this would preserve the original contingency with over 16 percent of the project completed. Based on these three considerations, the APA project staff believe it should be possible to reduce the total cost of the Bradley Lake project to approximately $328 million. Our review of the staff analysis generally supports this conclusion. However, we do not believe that power sales agreements and legislative appropriations emu. should be based on this lower cost estimate until it is supported by the bids for the main construction contract. Economic Feasibility The key factors which determine the economic feasibility of the Bradley Lake project, now that construction has already commenced, are: • The marginal cost of completing the project; • The initial cost, escalation rate, and availability of gas supplies in Cook Inlet; and, • The need for new generation capacity in the Railbelt, which is a function of trends in power demand and the requirement to replace existing generators as they wear out or become uneconomic to operate. In the limited time available for this review, we have focused our efforts on evaluating the effects of recent changes in these three key parameters on Bradley Lake. Thus, our analysis is based largely on previous Bradley Lake studies, with adjustments made to account for differences in these three factors. A brief summary of previous economic studies of Bradley Lake is necessary to provide a basis for comparison with our analysis and conclusions. 7983 rea•ibility Study• The 1985 review by OMB of the economic feasibility of the Bradley Lake project was based primarily on the L983 project feasibility study prepared by the engineering firm of Stone and Webster. This study used a sophisticated generation planning model which calculated the relative costs of Bradley Lake and other generation alternatives for both the Railbelt region as a Governor Steve Cowper Page 8 February 25, 1986 whole and the Kenai Peninsula alone. The 1983 study used the following major assumptions in the base case analysis: Bradley Lake Cost: $300 million (1983 dollars). Construction financing was assumed to be obtained through the issuance of long-term bonds at the outset of construction, with an interest during construction cost in real terms of 3.5 percent per year. The project construction cost was estimated to increase through inflation at 5.5 percent to 6.5 percent per year. Natural Gas Prices: The base case assumed that Cook Inlet natural gas prices would increase at the following rates, starting with a 1983 price of $2.77 per thousand cubic feet (mcf). A pipeline delivery charge of 30 cents/mcf was included in the projected gas prices. 1985-1988 0.0% 1989-2010 3.0% 2011-2020 2.5% 2021-2030 1.5% 2031-2040 1.0% Power Demand Forecast: The demand forecast in the base case projected an average annual compound load growth rate of 2.8 percent from 1983 through 2010. This growth rate resulted in projected Anchorage -Kenai Peninsula peak demand doubling from 469 MW in 1983 to 961 MW in 2010. E.., The reference or base case economic analysis in the 1983 feasibility concluded that the net benefits of the 90 megawatt Bradley Lake configuration for the Kenai Peninsula were $305 million, with the thermal generation alternative expected to cost 1.51 times as much as the Bradley Lake alternative. Project benefits were discounted at a real rate of 3.5 percent and no State subsidy was included in the benefit calculations. 8y �� 1Q86 Uy�atG• Stone and Webster conducted an additional economic analysis of Bradley Lake in August, 1986 in order to clarify the effect of varying natural gas prices on the feasibility of the project. This analysis was based on a simple comparison of Bradley Lake with a 90 MW gas turbine and did not incorporate the complex generation planning model used in the 1983 feasibility study. The A gust update was based on the 'original project cost estimate and financing method, and did not reflect the less costly variable rate bond financing that was in effect at the time. Gas turbine Governor Steve Cowper Page 9 February 25, 1986 capital costs were based on a recently installed unit on the Kenai Peninsula. The study did not consider the effect of changes in power demand on Bradley Lake benefits. This economic analysis compared the effect of three gas price escalation rates: no escalation, 3 percent per year escalation, and a breakeven escalation case of about 2 percent per year. In all cases, the 1986 wellhead value was assumed to be $1.60/mcf. A delivery fee of 40 cents/mcf was added to produce an expected delivered price of $2.00 in 1986. The analysis concluded that with 3 percent annual escalation in real gas prices, the Bradley Lake project would produce a net benefit of $72 million. At zero escalation, Bradley Lake would be $87 million more expensive than gas generation. An annual increase of 2 percent in real gas prices produced a breakeven result over the 50 year period. The August analysis produced much lower net benefits for the Bradley Lake project, in comparison to the 1983 feasibility study, because of the lower starting gas price. Even at the 3 percent escalation rate, real gas prices projected for the year 2000 in the August update were $2.82/mcf, compared to $3.99/mcf in the feasibility study, or 29 percent lower. Our Analysis. Based on data supplied by Railbelt utilities and APA staff, we have revised Stone and Webster's August 1986 feasibility update to incorporate different assumptions for the cost of the Bradley Lake project and for natural gas prices. The most important adjustment we have made in our analysis is deducting the already committed or sunk costs of Bradley Lake from the calculation of net benefits. While an analysis based on total project costs is useful in that it suggests whether the project would be undertaken now if construction had not already begun, the real decision today is whether to complete the Bradley Lake project at its marginal cost -- defined as the total project cost less costs incurred or obligated to date -- or to suspend or abandon the project and pursue gas generation or other alternatives. This type of marginal cost analysis is appropriate because if Bradley Lake were terminated, the projectes sunk costs could not be applied to new gas generation; the gas plant would have to be built from scratch at its full cost of construction and operation. over $45 million has already been spent on Bradley Lake design, licensing and construction. Current estimates of total sunk costs for Bradley Lake range from $60 to $90 million, depending on the extent of site restoration which would be required by FERC if the project. were terminated. Using a mid -point figure of. $75 mi.]1ion, over 20 percent of the total project cost has already been spent or Governor Steve Cowper. Page 10 February 25, 1986 committed, and the marginal cost of completing the project is about $281 million ($356 - $75). These sunk costs increase the net benefits of completing Bradley Lake by an equivalent amount, so that from today's perspective, the economic benefit of completing Bradley Lake is about roughly $75 million higher relative to the gas alternative than it would be if project design and construction had not been initiated. Accounting for the sunk costs of the project in this manner partially offsets the effect of lower gas prices on Bradley Lake feasibility and the decision whether to complete the project. The second major adjustment made to the August 1986 Stone and Webster study was to incorporate the APA's preliminary revised cost estimate of $328 million, for a savings of $28 million (356-328). For the reasons discussed earlier, we believe that this cost reduction is credible and very likely to be realized if the project is continued. An additional adjustment which must be made pertains to fact that financing costs for the project are now expected to be about $30 million less than was assumed in the 1983 feasibility study. The feasibility study assumed that the construction of Bradley Lake would be financed through the issuance of long-term revenue bonds issued at the start of project construction. This assumption meant that the project was expected to accumulate $21.6 million in interest during construction charges (IDC). When developing the plan of finance for Bradley Lake, the APA was able to implement a much more favorable financing approach based on the use of short-term, variable rate notes, coupled with arbitrage earnings on the reinvestment of the borrowed funds. The net result is that instead of paying out $21.6 million for IDC, the APA is expected to receive about $10 million in arbitrage earnings. Higher issuance costs reduce the net savings over the standard bonding approach to about $30 million. The feasibility study was correct in basing its analysis on the standard bonding approach, because the variable rate financing approach had not yet been approved or implemented. However, now that this less costly financing is in place, it is necessary to account for the resulting savings in the cost of the Bradley Lake project. It does not appear that a similar financing arrangement could be arranged for the alternative gas generation plant. However, to maintain comparability, we have excluded interest during construction costs from the calculation of gas generation costs. Construction financing costs are a relatively minor concern for gas generation because of its low capital cost and short construct Lon perir)d. "' Governor Steve Cowper Page 11 February 25, 1986 a Combining the $75 million estimate for Bradley Lake costs with the additional $28 million reduction in construction costs and $30 - million in financing costs produces a total reduction in the marginal cost of completing Bradley Lake of $133 million. Financing costs for Bradley Lake have always been budgeted in addition to the $356 million construction cost estimate, so that it is incorrect to deduct the $30 million savings in financing costs from the $356 million construction cost estimate. The original total cost of the project was estimated at $408.3 million ($356 million construction + $52.4 million financing cost). The net effect of these three adjustments is therefore to reduce the total marginal cost of completing Bradley Lake from $408 million to $275 million, a reduction of almost one third. Natural Gas Prices. The 1983 APA Bradley Lake feasibility study was based on a forecast of natural gas prices prepared by Sherman H. Clark Associates. The reference case used the following real escalation rates: 1985-1988 0.0% 1989-2010 3.0% 2011-2020 2.5% 2021-2030 1.5% 2031-2040 1.0% The base 1983 gas price used was $2.47/mcf, plus a 30C/mcf pipeline transportation charge. The $2.47 figure was derived from a netback value calculation based on the export market for liquified natural gas (LNG). There is widespread agreement among both the Railbelt utilities and the Cook Inlet gas producers that both the escalation rates, in particular the 3 percent real escalation rate from 1989 to 2010, and the base gas prices assumed in the Sherman Clark forecasts are too high for today's Cook Inlet gas outlook. Views on gas escalation rates vary considerably; however, there is a general consensus that an upper limit for the base price of new gas supplies is about $1.70/mcf. This is the price paid by Chugach Electric in its 1986 short-term contracts for peaking gas supplies from the Beluga field producers. Chugach officials are confident that they will be able to secure new long-term gas supplies at a price of $1.70 or less. 'rhe key questions are: (1.) Is new Cook Inlcft gas likely to he priced substantially lower than this upper limit price; and Governor Steve Cowper Page 12 February 25, 1986 (2) What is the most probable rate, or range of rates, at which Cook Inlet gas prices will increase during the 50 year economic life of the Bradley Lake project. Figure 1 summarizes our projections of the net benefits of the Bradley Lake project in comparison to gas -fired generation at various prices for new gas and real escalation rates. This chart incorporates the adjustments to Bradley Lake costs which have been discussed: (1) the reflection of the $75 million in sunk costs in the marginal cost of completing the project; (2) the reduction of project financing costs based on the current variable rate financing and arbitrage earnings; and (3) the reduction in total project construction cost from $356 million to $328 million. An additional important assumption incorporated in Figure 1 is that no delivery charge is added to the wellhead price of gas; in other words, it assumes that all new generation will be located at a producing field. This assumption differs from both the 1983 feasibility study and the Stone and Webster August 1986 feasibility update, which assumed that delivery charges of 30 cents/mcf and 40 cents/mcf, respectively would be added to the wellhead price of gas. The justification for adding the delivery charge is that both the Bernice Lake and Soldotna it generating stations now pay a delivery charge of about 60 cents/mcf to Enstar for their gas supplies. Chugach Electric officials believe, however, that t::ey will be able to buy new gas supplies at a wellhead price, with no delivery fee. For this reason, and to be conservative, we have not included a delivery charge in the analysis summarized in Figure 1. Figure 1 shows that at a real gas escalation rate of 2 percent and a price for new gas of $1.40/mcf or more, Bradley Lake power would be substantially less expensive than gas -fired generation over the period of analysis (50 years). Net benefits range from about $50 million at a new gas price of $1.40/mcf to $100 million at a gas price of $1.70/mcf. However, at lower escalation rates and/or .lower base gas prices, Bradley net benefits become marginal or negative. Each 10 cent/mcf change in base gas prices increases or reduces Bradley net benefits by about $15 million. The results shown in Figure 1 can be compared to Stone and Webster's August 1986 feasibility update. The Stone and Webster analysis concluded that at a base gas price of $1.60/mcf, plus a 40 cents/mcf delivery charge, a real escalation rate of 2 percent annually produced a breakeven result for Bradley Lake net benefits. Figure 1 shows that when sunk costs, reduced construction costs, and financing savings are incorporated into the analysis, a gas price of $1.60/mcf results in a breakeven escalation rate of about 0.3 percent per year. If the 40 cent delivery charge were added to the gas prices shown in Figure 1, the breakeven escalation rate at $1.60/mcf would be about negative 1.0 percent. Put another way, Governor Steve Cowper Page 13 February 25, 1986 Lake by about $65 million. A sample printout of the model used to determine the net benefits shown in Figure 1 is included in Appendix A. Because Figure 1 is based on 24 runs of this model, we have not included the detailed printout for each run. This model was developed by APA staff and modified to incorporate our own assumptions on gas prices and escalation rates. Cook Inlet producers claim that new gas is likely to be sold at prices which would render'Bradley Lake infeasible, but these producers have no recent contracts to support their contention and have an obvious interest in the termination of Bradley Lake in order to improve the market for their gas. As a result, the producers' point of view must be considered in light of their clear financial interest in the fate of the Bradley Lake project. A more objective index of the value of new Cook Inlet gas is the gas contract negotiated in 1982 by Enstar (Alaska Pipeline Company), which supplies gas to Chugach Electric, Anchorage Municipal Light and Power, and the Alaska Electric Generation and Transmission cooperative, which operates the 39 MW Soldotna it gas turbine unit. Although the base price of the contract in 1982 was $2.32/mcf, future gas prices under the contract were tied to the price of fuel oil at the Tesoro refinery on the Kenai Peninsula. This tie to current oil prices has reduced the price of gas under this contract from $2.32 to $1.47/mcf (as of January 1, 1987). Based on this contract, a price for new gas of $1.50/mcf appears to be a reasonable mid -range figure. At a real escalation rate of 2 percent per year, this gas price produces net benefits for Bradley Lake of about $70 million. with respect to future trends in gas prices, we have referred to forecasts by the Department of Revenue (DOR) and Chugach Electric. DOR states in the January, 1987 petroleum revenue forecast that Cook Inlet gas prices are expected to track crude oil prices. DOR's projections of average crude oil prices assume average real escalation between 1987 and 2003 of about 2.01. DOR also makes an explicit forecast of average Cook Inlet gas prices. This forecast, as well as that of Chugach Electric, is shown in Figure 2. The gas prices shown in this chart are not comparable to those included in Figure 1, because Figure 2 is in nominal dollars and includes melded prices for all gas, not just new gas. However, Figure 2 does indicate a fairly close correlation between the forecasts by DOR and Chugach Electric. In summary, the economic feasibility of the Bradley Lake project continues to remai.n very sensitive to prices of new gas supplies and future price trends. Although these factors are subject to a Governor Steve Cowper Page 14 February 25, 1986 and future price trends. Although these factors are subject to a high level of uncertainty, current gas price forecasts by the Department of Revenue and Chugach Electric suggest that Bradley _ Lake is still likely to be less expensive than gas generation over the 50 year period of analysis. Railbelt Power Demand. The decline in oil prices and resulting slowdown in Alaska's economy has resulted in a major reduction in demand forecasts by Railbelt utilities. For example, the Chugach Electric Association, which two years ago was projecting load growth of 5-6 percent per year, is now estimating that demand will increase by an average of only 0.55 percent per year from now to the year 2000. Similar reductions in load forecasts have been made by other Railbelt utilities. These lower load forecasts mean that much less additional N generation capacity will be needed in the Railbelt over the next ten to fifteen years than was expected two or more years ago. The obvious question is whether Bradley Lake's power is still needed, given the lower demand forecasts. Our research indicates that even with flat or slightly declining demand, new generation will be required in Southcentral Alaska in the 1990-95 period. Because of time constraints, we focused our review of the demand issue on Chugach Electric, which would be the major purchaser of Bradley Lake power if the project is completed. Even with the basically flat load forecast cited above, Chugach expects to require at least 45 MW of new capacity by 1990. A planned retirement of an 8 MW unit at the Bernice Lake plant accounts for a portion of this capacity requirement. Chugach now has a contract with Anchorage Municipal Light and Power for the purchase of 40 MW. This contract will decline by 10 MW per year and terminate in 1990. Chugach now plans to replace this capacity with 45 MW from Bradley Lake, but if Bradley is not completed, gas generation would be installed instead. Over the longer term, Chugach expects to retire over 250 MW of existing capacity by 1997. The effect of Chugach's lower load forecast on planned capacity requirements is that two years ago, Chugach was expecting to need a new. 87 MW gas plant in addition to 72 MW from Bradley Lake. Now the utility expects Bradley Lake power to delay the need for new gas generation until the mid-1990s. Figure 3 shows current and projected peak demand and installed capacity for Chugach Electric. The dotted line shows the effect of plant retirements on total installed capacity if the plants are not replaced. 'fwo additional points are relevant concerning the demand issue. First, gas generation capacity is inexpensive compared to the cost Governor Steve Cowper Page 15 February 25, 1986 a of fuel to run the plant. Thus, the question of excess capacity is less important than gas price trends. Second, the effect of demand trends on the Bradley Lake project is much different from the hydro projects in the 4-dam pool. These projects, with the exception of Solomon Gulch, were intentionally constructed with generation capacities much larger than the total demand of their service area, in order to allow for load growth. For these projects, a decline in forecast demand produces an equal decline in project revenues and requires higher power rates to recover the revenue shortfall. Bradley Lake, by contrast, would be a small portion of the demand in Southcentral Alaska and the Railbelt, so that declining demand does not create the revenue reduction.and rate problem that the 4-dam pool projects could face. Power Sales Agreements In June 1985, the Chugach Electric Association and Homer Electric Association signed conditional power sales agreements for the purchase of Bradley Lake power. At the time, these agreements were presented to the APA board as binding documents, but controversy has developed over the enforceability of the contracts and their current legal status is unclear. At the request of the Railbelt utilities, the APA staff has v,. negotiated revised agreements which the board is being asked to approve on February 27. The revised agreements have certain favorable features, such as the inclusion of all seven Railbelt utilities and a provision for equal sharing of project costs between the State and the utilities, up to $350 million ($175 million each). However, final approval of the revised agreements by the utilities is now contingent on full State financing of the Anchorage -Kenai and Anchorage -Fairbanks transmission interties, at a cost of up to $200 million. This linking of the Bradley Lake power sales agreements to funding of the interties raises two major policy issues. First, the conditional agreements, if approved by the APA board, would once again put the State in the position of proceeding with project construction without final, unconditional agreements for the sale of the project output. This situation clearly puts the State at risk for project costs and adversely affects the bargaining position of the State in negotiating final contracts. Both the Legislature and the APA board have required final, binding power sales agreements to be in place before proceeding with project construction. A second concern is that in accepting the revised Bradley agreements, the Board would effectively be endorsing funding and construction of the intertie systems before the feasibility studies Governor Steve Cowper Page 16 February 25, 1986 a on the interties are completed. Such a position would conflict „ with the APA's statutory and regulatory requirements to follow a prescribed project approval process for any new project. The utilities' responses to these policy concerns have been that the intertie systems are the only way that all seven Railbelt utilities can receive firm Bradley Lake power. We believe that a feasible power displacement agreement could be developed which would provide most of the benefits of the intertie systems at much lower cost. While it is true that the existing Kenai intertie cannot provide firm power,' the cost of maintaining reserve generation must be balanced against the cost of the interties. Although a displacement agreement would be a complex undertaking, it is clearthat this option has not been adequately explored by the utilities, because they would prefer to take advantage of $200 million in State funds for the interties. Displacement agreements are commonly used in lower 48 grid systems, and we have seen no firm evidence that similar arrangements could not be used in the Railbelt. Delaying the Project Delaying additional work on Bradley Lake may be unavoidable, depending on the APA board's actions and the responses of the utilities and the Legislature. However, it does not appear that an intentional delay in project construction of a year or more would be cost effective. APA staff has estimated that a one year delay would increase project costs by about $10 million, including the expense of a FERC license amendment, escalation in construction costs, site maintenance and other costs. Delaying the project could also increase financing costs. The Bradley Lake project was granted a special tax-exempt status in the recent federal tax legislation. This exemption expires in December 1990. If the project were delayed longer than one year, long-term bonds would have to be issued prior to project completion, rather than after completion as planned. By placing some completion and cost overrun risk on the bond holders, this earlier issuance of bonds could result in higher interest rates. UCO C p�\ o \ t0 O O O OU �O CV W O >O O 1C) O • i o � r p N Ir s N Co z r mE E W Co J�-W ��. co / r U I ' Z m > C T (� r 000acoaC) 0 00 N O 00 cD �r N N T T to T T C N O CID a mo I-'N Q zE �0 J .n U) C U O .0 N > �- O N LL V�/J) i1 O Q O U U ';= .- C o 0 ►_ O V W E V co O � _ C ,0 � O U � o U U) c� U cn O U- U O U O M u- U) O U � 00000000000 00000000000 0000(�664c6N*-6 T V33 1IL W CC 2 0 LL. T N O MTT W O ' W O It O N O O o N O 00 O c0 O �F O rn 0 rn M �U C O Q- m U �U -p O N N "— O ..0 cd Q -4- to U U) C -- U -p O O CCU I" I'I L.L V L C U Co w E 0 U cu a� cc�m a C [V m ci E 1 �CL cr c a C� I 3 c c co I d J i i / I I I 1 I I I I f O p N O 00 h . 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O��mN F�.�NN YT i R.'-N �Q NMNMNNMNN����N�NNNNNN NNFM MN�����.f-��mWNppryry ((..��RR (V(yy �(�(pp��mrym(I (n(nyy ♦n♦n �(�(pp��mnmn♦♦♦♦♦♦ pNpN (7 �Sryory�j"�jRy((R�(��,(yryylFf(�yB�yF'�&(ffiyg8n�n.}� �i,`eiSS"�i�3,PB,nSd9�8!'8�F1�RSF� d am NNNNNNNNNNNDiDidvttttDIttttttttttttuuu---l-lttA�AIIA�AAA�AA�ARAAxxJ�J�a� cc V n W b h W ff Pf O A p O W !f N O PI !1 O n f V V V V V f f V� f f f V V V W R R R R R i Z H J H � gg gggg gggg gggg gg a--------R##RRRRRRRRRRRRRRRiZRRRRRRRRF�RR��RRlZ�RF IN REPLY REFER TO: ANC-FWE United States Department of the Interior Fish and Wildlife Service Anchorage Fish and Wildlife Enhancement Sunshine Plaza, Siute 2B 411 West 4th Avenue Anchorage, Alaska 99501 Richard Poole Vice President Kenai Hydro, Inc. P.O. Box 1776 Lummi Island, Washington 98262 — hear Mr. Poole: MAR 2 Z MOT Re: Grant Lake Hydroelectric Project FERC Project No. 7633-002 The U.S. Fish and Wildife Service (FWS) has reviewed the Additional Information and Instream Flow and Fish Habitat Analysis, both dated February, 1987. The following comments are intended to facilitate your project planning, and supplement our previous letters on this project. General Comments We appreciate the efforts of Kenai Hydro, Inc., in quantifying the habitat losses and gains attributable to the proposed project. However, as detailed in our specific comments, we believe that additional data collection and analysis is warranted. We have identified the following five major concerns related to the analysis which should receive your specific attention prior to submittal of your license application to the Federal Energy Regulatory Commission (FERO : 1. A major assumption of the Water Surface Profile (WSP) model is that the flows were stable during the collection of the data. When the field measurements were taken flows were not stable, varying by 51.5 cubic feet per second (cfs) (20.7 percent change). 2. The field data cannot be extrapolated below 98 cfs (0.4 x 246 cfs), assurring the data are good (see S1 above). This does not allow for an analysis of habitat at the proposed minimum flows. Also, since we are concerned with the acceptability of the data collected, our confidence in the modeling and stranding analysis at the lower extrapolation extreme is low. We are not certain of the upper limits for data extrapolation since it is unclear where the transects begin and end. If the transects were taken from water's edge to water's edge as indicated in the discussion (see Additional Information page 10, paragraph 2), then the model cannot estimate available habitat above 246 cfs. However, the data (see Appendix A Tables 1 through 3) indicate that the transects were initiated and ended at some point on the streambank, out of the water. 3. The data presented in Appendix A is questionable. The greatest velocity in the field data is 5.95 feet per second (fps). However, the discussion reports velocities ranging from 0.32 to 6.62 fps (see Additional Information page 11, paragraph 6). 4. The habitat suitability curves are questionable. Detailed comments are provided in our Specific Comments section.' These curves, and curves which are not presented (e.g., substrate) are the basis for all habitat values analysis and, with the noted errors, the habitat values are unreliable. 5. The stranding analysis is not clear. The reference cited is unpublished, and the methodology is thus essentially unknown. A detailed explanation of the methodology should be provided, or the reference attached. Specific Comments on: Grant Lake Hydroelectric Project Additional Information, dated February 15, 1987. Page 1; paragraph 3: Salmon spawning and rearing were identified above the outlet of the proposed tailrace facility during the 1981-1982 studies (see page E-3-21 of the Grant Lake Hydroelectric Project license application). A properly designed tailrace facility and acceptable instream flow regime should mitigate for the loss of this habitat. Reference is made to maintaining flows, . by alternate means " in the event of a shutdown. The design of this bypass device and its design -- capacity should be provided. The outlet should be into the tailrace facility to maintain the habitat provided. Page 3; paragraph 4: This is a misrepresentation of the Tenants Method.` What is not indicated is that different flow rates are set for different seasons. The Tennants Method could be used to support instream flow recommendations of 200 cfa and 100 cfs for this project. Page 4; paragraph 4: To evaluate the adequacy of the bypass pipe it would be useful to know the discharge rate and the situation the fish would be released to (i.e., would the fish have to survive a 100-foot free fall, or would they be released into a relatively tranquil setting). Flows need to be provided to the tailrace to maintain the habitat created. Consideration should be given to having one bypass structure, releasing into the tailrace channel. Page 5; paragraph 1: The referenced meeting minutes were not attached. Please provide a copy of these minutes. Page 7; paragraph 7: The study would have more credibility if the data had been collected when the discharge was 100 cfs to 125 cfs as recommended by the agency personnel at the October 21, 1986, meeting and on October 23, 1986, at the site survey. Kenai Hydro, Inc., was informed on site that the water was too high to model the lower instream flows being proposed. Page 10; paragraph 2: It is indicated that the ends of the transects were located at the water's edge. If this is true then the WSP model cannot estimate habitat for flows greater than those that were measured. The model has no information of a higher streambank to spread water over during higher w discharge amounts. This deficiency in data collection limits the applicability of the model to the range of 246 cfs to 98 cfs (0.4 x 246 cfs). This limitation means that the WSP model will not be able to model habitat availability under average winter flows, average summer flows, project proposed winter minimum flows and high with —project operating flows. However, Appendix A Tables 1 through 3 and the cross —sectional profiles (page 20) indicate that the transects did extend shoreward from the water surface. This apparent discrepancy should be clarified. We strongly recommend that a second set of data be obtained to verify the original data set, extend the landward ends of the original transects to allow modeling of higher flows (up to the extrapo limits of 615 cfs), and to extend the modeling limits down to the proposed 50 cfs winter minimum flows. Page 11; paragraph 2: It is stated that the flows dropped from 297.3 cfs to 245.868 cfs, a decline of approximately 21 percent during the data collection period. This violated a major assumption of the WSP model, that the data be collected during stable flows. Although unstable flow data can be mathematically corrected, the magnitude of the change in the flow measurements decreases our confidence in it, and further justifies an additional set of data. Page 11; paragraph 6: The velocities are reported as ranging from 0.32 to 6.62 fps. However, the greatest velocity shown in the field data (Appendix A Table 1) is 5.95 fps. We have assumed that the FLOW READING column of Appendix A Table 1 is mislabeled and is velocities (fps) and not discharge (cfs). If this assumption is incorrect than the total discharge is only about 50 cfs rather than 246 cfs as reported. Page 13; paragraph 6: Please provide a reference for the statement, "During this period egg incubation is occurring and for the four month period the eggs -ire essentially in a holding phase due to the low temperatures which limit `--development." Page 21; paragraph 1: It is stated that March is a low target energy and capacity month. However, projected discharges (see Figure IV 16—A) are shown as approximately 200 percent higher than what was proposed in the license application. Please discuss these discrepancies. Page 21; paragraph 3: In consideration of the lack of confidence that could be placed on the data collected we cannot concur with the conclusion that proposed project flow changes would not result in stranding. Additional discussion should be provided relating the stranding analysis in the instream flow report (page 24) to the proposed ramping rates. Page 23; paragraph 1: Additional discussion should be provided concerning temperature —related project impacts.. Based upon accumulated temperature units with the project versus natural temperature regimes (without project), time to hatching of chinook enbryos would be nearly unaffected (October 23 with project versus October 29 without project). However, the amount of time for fry to reach the button —up stage would he greatly affected (March 27 with project versus May 28 without project). These estimates of hatching and button —up times were calculated from the temperature curves, Figure 2-6A, and assumes a spawning date of August 21. Page 25; paragraph 5: We consider the tailrace channel as mitigation for the loss of habitat upstream of the tailrace outfall. As such, spawning and incubation conditions must be maintained throughout the life of the project. That is, gravels lost during flood flows would have to be replaced, weirs maintained, and an instream flow regime would need to be provided. The channel should be designed so that a minimum depth of one foot is maintained during the spawning period and sufficient flow'is provided during incubation to wet the spawning gravels and prevent freezing. In addition, an emergency water source to this channel would be required to maintain flows in the event of project shutdown. Page 27; paragraph 5: Please reference our comments immediately above. We consider the habitat provided by the tailrace channel to be a mitigation feature. Specific Comments on: Instream Flow and Fish Habitat Analysis for Grant Creek, Alaska in Relation to a Proposed Hydroelectric Facility, dated Februarv. 1987. Page 1; paragraph 1: The Grant Creek weir intercepted 1,113 coho salmon during the 1985 season. Of these, 73 percent (812 fish) were attributed to the release of fry into Grant Lake. The remaining 300 fish may be either natural Grant Creek stocks or strays from adjacent systems. However, in consideration of the number encountered it should be assumed that these fish encompass a natural Grant Creek stock. Page 3; Figure 1: The anticipated occurrence of the "High" and "Low" flows should be indicated (e.g., one -in -ten-year events). Page 9; paragraph 4: We disagree that an analysis based upon the requirements of chinook and sockeye salmon would be representative for rainbow trout. Rainbow trout spawn in the spring under different flow conditions and are not at all represented by the discharge/habitat relationships of chinook or -' sockeye salmon. It would be appropriate, therefore, to add rainbow trout to the list of species for evaluation. Page 10; paragraphs 3 and 4: Habitat suitability curves for substrate should be provided. It is stated that all substrate less than 12 inches is suitable. This is not true for sockeye salmon and may not be true for chinook salmon in Grant Creek. Studies of the tributaries of the middle Susitna River (Estes and Vincent -Lang 1984) assumed a curve for chinook based upon the following: 6.5 inches 0.1 index rating 8.5 inches 1.0 index rating 12.5 inches 0.15 index rating 13.5 inches 0.0 index rating It is recommended that the suitability criteria used in this study be re-examined and verified with a biologist familiar with the fisheries in the Grant Creek drainage. Page 12; Figure 2: The habitat suitability curve for depth developed for tributaries of the middle Susitna River (Estes and Vincent -Lang 1984) uses a rating of 1.0 at a depth of one foot. Please discuss why a depth of two feet is used for attaining an index rating of 1.0 in Figure 2. Curves should be validated with the assistance of a field biologist familiar with the Grant Creek drainage. Page 13; Figure 3: The habitat suitability curve for chinook fry (juveniles) 51 to 100 mm does not agree with Burger et al. (1983). Please provide a more accurate rendition or discuss why a curve which is radically different from the data referenced was used. Page 15; Figure 4: The suitability curves appear to be mislabeled. Please review and correct the curves. Page 17; Table 1: Although the periodicity table shows the "Egg Incubation and Early Intragravel" life stage for chinook and sockeye salmon, no analysis is presented for this stage for either species. This table should show all species and life stages to show that those included in this study represent all other species and life stages utilizing the drainage system. Please provide these analyses and information. Page 18; paragraph 1: Please refer to our comments on the Additional Information page 10, paragraph 2. Depending upon the extent of the transects away from the water's edge, the extrapolation limits of the data gathered may be as narrow as 246 cfs to 98 cfs. Page 18; paragraph 2: The stranding analysis is not clear. The methodology is essentially unknown. Please provide additional discussion on this methodology and its underlying assumptions. Summary During the discussions held on October 21, 1986, between representatives of Kenai Hydro, Inc., and the FWS, Alaska Department of Fish and Game, and the National Marine Fisheries Service it was concluded that one set of transects may be adequate to model the habitat contained in Grant Creek and evaluate project related impacts to that habitat. The probability of additional transects being needed to adequately accomplish the modeling was also discussed at that time (see Additional Information page 5, paragraph 2; page 7, paragraphs 1 and 5; page 9, paragraph 2; and Instream Flow and Fish Habitat Analysis page 4, paragraph 2). We have concluded that, based upon the concerns expressed in this letter, a second set of data is needed to extend the transects out from the water's edge, allowing quantification of habitat availability during average summer flows and high with -project flows, and to validate the model for the lower flow conditions. Actual depths and velocities, as measured in the field, for a discharge of 50 to 125 cfs should be compared to the estimates from the model for the same discharge. Additional details should be provided on the tailrace channel. Instream flow requirements for Grant Creek should also be appropriate for maintaining the tailrace channel habitat for spawning and incubation. The mitigation plan should provide for monitoring, and maintenance of this feature throughout the project life. Thank you for the opportunity to comment on the Grant Lake Hydroelectric Project Additional Information and the Instream Flow and Fish Habitat Analysis. Please provide this office with a copy of the complete draft license application prior to its submittal to the FERC. If you wish to discuss our comments, you may contact Mr. Leonard P. Corin, of my staff, at (907) 271-4575. Sincerely, �JJ���� v r� " Field Supervisor cc: The Honorable Kenneth F. Plumb - FERC - Washington, D.C. Mr. Robert LaResche - APA - Anchorage, AK Mr. Eric Eisen, Esq. - Birch, Horton, Bittner, Pestinger & Anderson - Washington, D.C. Mr. Russ Redick - Alaska Sport Fishing Assoc. - Anchorage, AK Mr. Robert Alder, Esq. - Trustees for Alaska - Anchorage, AK Mr. Geoffrey Y. Parker, Esq. - Anchorage, AK Ms. Catherine Dennerlein - Wildlife Federation of Alaska - Anchorage, AK Mr. Ron Morris - NMFS - Anchorage, AK Mr. Ben Rosenthal - WS - Juneau, AK Mr. Dan Wilkerson - ADEC - Anchorage, AK Mr. Don McKay - ADF&G/Habitat - Anchorage, AK Mr. Gary Prokosch - ADNR/SCRO Water - Anchorage, AK Mr. Tom Mears - CIAA - Soldotna, AK USDI - Office of the Solicitor - Washington, D.C. FWS - Office of the Director - Washington, D.C. FWS - Regional Director - Anchorage, AK I STEVE COWPER, GOVERNOR /I"ADA&U 1'MEWT O FISH AND GAME 319 HASI'ULHIIY IILIA H ANCHORAGE, ALASKA 995181599 PHONE: (907) 344-0541 April 1, 1987 Mr. Richard Poole Kenai Hydro lnc. P. O, Box 1776 Lummi Island, Washington 98262 Dear Mr. Poole: The Alaska Department of Fish and Game (ADF&G) has reviewed the information submitted to the Federal Energy Regulatory Commission on 17 February 1987 for the Grant Lake Hydroelectric Project (Project No. 7633-002). Our primary concern is the instream flow report. The document is difficult to evaluate due to incomplete and or lack of documentation to support the analyses. It had been originally suggested that you use data from one low flow measurement to run their WSP model and collect additional data to test the validity of using the WSP analysis. The additional flow data were to be collected to test the calibration range of their model. From the data presented, it appears the calibration data were collected during a period of higher flows than suggested and during a period of higher flow variation than is recommended by the IFG. Therefore, a major assumption of the WSP model appears to have been violated because field data were collected during a period of unstable flow conditions. The discussion of methods on page 10 suggests that measurements along transects were initiated at the waters edge. However, field data in Appendix A and plotted in Figure 5 (Instream Flow Report) suggests that some elevations were measured above the water level. These two concerns cause the validity of the data and the analysis to be questionable. The analysis of flows cannot be extrapolated for flows above the elevation of the stream cross sections that were measured. These basic problems need to be clarified. Additional field data may need to be collected to support the analysis. The Tennant analysis was not presented properly, nor is it clear why or how it fits into this report. It should be Mr. Richard Poole -2- 4/1/87 stressed that the Tennant analysis is a good method when adjusted to regional hydrological conditions, but it does not provide a basis for evaluating ramping effects. Habitat suitability curves used in the analysis need to be evaluated and revised. Some curves are mislabled. The depth suitability curve to chinook spawning should be revised. Estes and Vincent -Lang (1984) report a depth of 1.0 ft. to have a suitability value of 1.0 for tributaries of the Middle Susitna River. These streams are similar in size to Grant Creek. Once these problems have been addressed we recommend that an additional set of data be collected for a discharge of 50 to 100 cfs and that these be compared to estimates from the model at the same discharge. This would indicate how well the model predicts below 100 cfs. A more complete description of project design is required so that mitigation requirements can be more completely addressed. Perhaps this could be addressed by combining the instream flow report into the license application. We are ✓ particularly interested in the design of the tailrace to evaluate the quantity of spawning and rearing habitat that this project feature will provide. We are also interested in how water will be maintained in the tailrace during periods when the plant is not operating. The discussion of ramping rates needs to be revised to include an analysis of the change of flow on fish habitat. Although it is stated that flow would change at a rate of not greater than 100 cfs per hour, there is no discussion of the effects of this change on habitat and fish. The following specific questions and comments are provided for your consideration. Page 4 - Does the project design include a bypass around the,, turbines to the tailrace? Page 10 - It is stated that "The ends of the transect were established by measuring water level at each end of the tag line prior to commencing the measurements across i the stream." However, the field data in Appendix A indicates some measurements were collected beyond the waters edge. Page 11 - It is stated that the stream flow dropped 46 cfs during the period measurements were taken. This appears to violate an assumption of stable flow for the WSP model. Mr. Richard Poole -3- 4/1/87 Page 19 - The information on the return of coho salmon to Grant Creek in 1986 is incomplete. Cook Inlet Aquaculture Association estimated that 846 coho returned in 1986. Therefore the number of fish that were estimated to have returned from the stocking of fry in Grant Lake in 1984 is 79 percent of 846 or 668. The remainder of the escapement is thought to be fish naturally produced or from the lake stocking in 1983. Page 25 - Based on more complete analysis of project impacts that will occur in the future, it may be necessary to plan Lo maintain spawning and rearing Habitat In the tailrace. Should you wish to discuss these comments, please contact me in Anchorage at (907) 267-2284. Sincerely, \\ V"-J � 'm C �c ..--) Donald O. McKay Habitat Biologist Habitat Division 267-2284 cc: B. Deibel, FERC C. Estes, ADF&G B. Hauser, ADF&G L. Corin, USFWS B. Smith, NMFS S. Lyons, USFWS UNITED STATES DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration �.,�,•''7 National Marine Fisheries Service P.O. Box 1668 Juneau, Alaska 99802 April 6, 1987 Mr. Richard Poole Kenai Hydro, Inc. P.O. Box 1776 Lummi Island, WA. 98262 Dear Mr. Poole: We have received the Additional. Information - Grant Lake Hydroelectric Project, February 1987. We assume materials presented here will be incorporated into the project application as an amendment as outlined in your letter dated July 23, 1986. Having reviewed this document, we offer the following comments. General The report on habitat/flow relationships for chinook and sockeye salmon provides valuable information on project impacts. The quality of these data and the confidence which can be applied to its extrapolation are limited, however. These failings appear to be due to a significantly reduced streamflow which occurred during the time of recording, and to the limits of the hydraulic model itself, given one data point. Considering these limita- tions and the fact that habitat suitability curves used were developed on other systems, some error in the WUA projections is expected. The information quality could be improved, however, if additional measurements are taken at other flows, as previ- ously recommended by our agency and others. Cross -sectional profiles themselves might provide the most useful available information. These profiles indicate that project flows would reduce the area available to adult chinook salmon during spawning periods. On the benefit side, it is likely the effective spawning area would be less diminished, as the extreme minimum winter flows would be avoided. To allow a more informed view of actual project impacts from salmon spawning to egg survival, it would be useful to generate an incubation curve to quantify any change with respect to egg survival. S eci.fic Comments page 3, para. 4. How has increasing stream flow to optimize spawning requirements been considered in the monthly operational scheme? We note th K August, September, and October powerhouse releases have been reduced from those previously presented (Figure IV-16 of the December 1984 FERC license application). September flows are less than one half that originally proposed. page 5, para. 1. We cannot locate the referenced minutes from the subject meeting within the appendix. page 7, para. 7. We question the statement that "Due to the timing, Kenai Hydro collected stream data October 2.7, 1986 at approximately stations 5 and 6". Kenai hydro was repeatedly informed of the need to gather flow data in a valid manner, including taking measure- ments after flows had stabilized. These measurements were not made during steady flow and have therefore violated a major assumption of the WSP model. page 21, para. 1. March is described as being a low target energy and capacity month; however, project flows (fig. IV 16-A) show high March releases, a 200 percent increase above the flow originally proposed. Why is this flow so high? page 21, para. 2. It is misleading to state that minimum flow requirements have been developed for these species. Although it is appropriate to select chinook and sockeye salmon as flow (IFG) evaluation species, consideration of other species, including rainbow trout, must also occur. We anticipate any revisions to the proposed release schedule necessitated by this evaluation would be done during the latter stages of licensing. page 21, Ramping rates. Changes in powerhouse flow must not adversely impact spawning, rearing, incubation, or migration. Based on the stranding information provided, we have some concern for flow changes when powerhouse releases are at or below 120 cfs. It may be prudent to limit the maximum rate of change to 10 cfs per hour for any decreases from powerhouse flows at or below 120 cfs. More discussion is necessary to relate the information in this section to the stranding analysis. page 24, Project Discharge Temperatures. The revised temperature data are significantly changed from that presented in the original license application. We are pleased you have incorporated the multi -level intake feature into the revised plan and believe it should lessen adverse impacts to downstream fisheries. page 2.7, para. 1. The collection and release of juvenile fish through the by-pass system/fish egress facility by means of an inclined screen is acceptable. It may not be advisable, however, to release these 3 fish at the suggested point in the canyon. Would 5.8 cfs be sufficient flow to pass these fish downstream from this point? Additionally, if the powerhouse tailrace is designed as a mitigation feature by providing spawning habitat, it will he necessary to provide an emergency water source to this channel. In this case, it may be possible to combine the fish by-pass and emergency flow systems. page 27, para. 7. We strongly support plans to develop the tailrace to accommodate chinook salmon spawning. Detailed plans for this feature should be developed and should include provisions for emergency flow during shut -down, energy dissipation to minimize erosion, and a long-term operation and maintenance plan. Instream Flow and Fish Habitat Analysis page 3 - flows The low and high flows presented should be one -in -ten statistical events. page 10, para. 4. Chinook Adults. The assumptions regarding spawning depths used in this report serve to minimize project impacts to chinook spawning habitat. It does not seem conservative to consider 0.5 feet the minimum depth for spawning. Based the research discussed here, it would be more conservative to set 1.0 feet as the minimum spawning depth. It is apparent from the cross -sections in figure 5 that post project WUA would fall considerably if the 1.0 foot, rather than 0.5 foot minimum depth was used. page 16, para. 3. In scaling the downstream transect to meet the data gathered from transect 1 and 2, were the depths as well as velocities scaled by the 246/297 ratio? < Appendix Fig. IV - 16A The proposed project flows should be depicted as a range of monthly or weekly flows within the limits bounded by 1 in 10 events and/or recommended minimum flows. It will be necessary for a project flow regime to be developed which considers the results of the fisheries analysis. The proposed August and September flows are significantly lower than the original flow releases as shown in fig. IV-16 of the December 1984 License Application. This lowered flow will also decrease the WUA values for chinook salmon, as spawning habitat will be reduced. Similarly, flow decreases in October may not benefit spawning coho salmon. How can the regulated reservoir operation ele- vation remain exactly the same as the original application even though significant flow changes have been made? In summary, we question the accuracy of the projected discharges, and recommend that further discussion be presented on this important issue. 0 Appendix A. Field Data from Kenai. Hvdro.. Inc. The data presented appear questionable and the recording procedures improper. on table one, no figure is given as to the date or time of measurement. No scale is presented for the DISTANCE column. The FLOW READING column is listed as being CFS; however we would think these figures should be in feet per second. Also, the transect seems to have begun at water's edge. Without extending measurements beyond the stream channel, it is impossible for the WSP model to predict flows above that measured. Because of this discrepancy, we are unable to understand how these data could be used to generate the cross - sectional profiles for flows of 300 cfs (page 20). The velocity range presented on page 11 (0.32 to 6.62 fps) does not seem to agree with figures in the FLOW READING column; i.e., these figures do not appear. The total transect lengths of 65, 70, and 86 feet differ from figure 2 (page 12) which depicts lengths of 63, 70, and 72 feet. Summary We find the additional information presented furthers our understanding of the potential impacts resulting from the Grant Lake Project. We believe that confidence in the hydraulic model might be improved through additional data gathering and updated runs through the existing model. This would allow verification of the model and perhaps, improve its applicability to lower flows. Specifically, we recommend additional measurements be made at the existing transects at flows between 100 and 150 cfs. Using this information and a detailed projection of proposed powerhouse flows, a project flow regime should be developed which accommodates evaluation species. It appears that minimum flows of 50 to 100 cfs would only be experienced during shut -downs. Thus it is important to evaluate actual project flows. We feel this project has the potential to benefit some species through flow regulation, (moderating extremes), through thermal changes, and through structural means. While the revised plan to locate the powerhouse release into Grant Creek has greatly reduced potential. impact, it is important to quantify all habitat gains or losses and prepare a plan to mitigate adverse impact. The development of a chinook spawning channel within the tailrace looks to be a very promising mitigation feature. A detailed mitigation plan, incorporating this feature and describing monitoring and mai-ntenance efforts should be presented in the revised application amendment to FERC. We appreciate Kenai Hydro's effort to address our original comments on the economic feasibility analysis. Significant aLrldes have been made with respect to the use of a more appropriate interest rate for debt service estimation, the provision of a financial plan, and clarification of differential transmission loss rates utilized in calculating the relative J performance of the several alternative sources of electrical power considered in that analysis. However, we continue to have serious concerns about the economic feasibility analysis. As we pointed out in our original remarks, dated necemhnr 1, 198fi, the continued reliance upon 1981-1982 data for development of assumptions on oil and gas price trends, which are clearly inappropriate given market performance over the period 1982-1987 and current industry projections, place the entire resultant "comparative economic analysis" in doubt. We urge you to review our original comments on the economic feasibility analysis and incorporate the most recent information available in reexamining the comparative economics of the Grant Lake project. We hope these comments will assist you in your licensing efforts. Please call us if we can answer any questions. We. request a copy of the complete draft License Application be provided for our review prior to submittal to FERC. Sincerely, Y � � i tl� RcSbezt W. McVey c/ J irector, Alaska Region Instream Flow and Habitat Analysis Grant Lake Hydroelectric Project Kenai Hydro, Inc. Prepared by nvirosphere Company ' 0900 N.E. 8th Street' ......................................: ........................................... vue, Washington 98004 (206) 451-4600 April 1987 INSTREAM FLOW AND FISH HABITAT ANALYSIS GRANT LAKE, HYDROELECTRIC PROJECT PREPARED FOR KENAI HYDRO, INC. BY ENVIROSPHERE COMPANY 10900 NE 8TH STREET BELLEVUE, WASHINGTON 98004 APRIL 1987 5192a TABLE OF CONTENTS 1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . 1.1 BACKGROUND . . . . . . . . . . . . . . . . . . . . . . 1.2 OBJECTIVES . . . . . . . . . . . . . . . . . . . . . . 1.3 SCOPE OF STUDY . . . . . . . . . . . . . . . . . . . . 2.0 APPROACH . . . . . . . . . . . . . . . . . . . . . . . . . 2.1 EXISTING DATA . . . . . . . . . . . . . . . . . . . . 2.1 .l Discharge . . . . . . . . . . . . . . . . . . . 2.1 .2 Habitat . . . . . . . . . . . . . . . . . . . . 2.1.3 Fish . . . . . . . . . . . . . . . . . . . . . 2.2 FIELD DATA COLLECTION . . . . . . . . . . . . . . . . . 2.3 FISH HABITAT SUITABILITY CURVES . . . . . . . . . . . . 2.3.1 Chinook . . . . . . . . . . . . . . . . . . . . 2.3.2 Sockeye . . . . . . . . . . . . . . . . . . . . 2.4 TIMING OF LIFE HISTORY STAGES OF CHINOOK AND SOCKEYE SALMON IN GRANT CREEK . . . . . . . 2.5 DATA ANALYSIS . . . . . . . . . . . . . . . . . . . . . 3.0 RESULTS . . . . . . . . . . . . . . . . . . . . . . . . . . 4.0 CONCLUSIONS . . . . . . . . . . . . . . . . . . . . . . . . 5.0 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . APPENDIX A - SUMMARIZED FIELD DATA FROM KENAI HYDRO INC. APPENDIX B - MODEL INPUT DATA 5192a ii Page 1 1 2 4 6 6 6 6 7 11 11 11 14 17 19 22 35 37 LIST OF FIGURES Page Figure No. 1 NATURAL (AVERAGE) AND WITH PROJECT FLOWS (WITH PROJECT "HIGH," "AVERAGE," OR "LOW" REFER TO THE TYPE OF WATFR YEAR THAT TIIE BASIN IS EXPERIENCING) 3 I2 HABITAT SUITABILITY FOR CHINOOK ADULTS 12 3 HABITAT SUITABILITY FOR CHINOOK JUVENILES 15 4 HABITAT SUITABILIIY IOR S(ILKLYL ADULTS 16 5 CROSS -SECTIONAL PROFILES FOR GRANT CREEK TRANSECTS. STATION 0+00 = DOWNSTREAM TRANSECT, 0+33 = MIDDLE TRANSECT, AND 0+52 = UPSTREAM TRANSECT 23 6 WEIGHTED USABLE AREA (WUA) FOR SPAWNING CHINOOK SALMON 24 I7 WEIGTHED USABLE AREA (WUA) FOR REARING JUVENILE CHINOOK (35-50 mm) IN GRANT CREEK 25 8 WEIGHTED USABLE AREA (WUA) FOR REARING JUVENILE N CHINOOK (50-100 mm) IN GRANT CREEK 26 9 WEIGHTED USABLE AREA (WUA) FOR SPAWNING SOCKEYE SALMON 28 10 POSSIBLE COMPARISON OF KENAI HYDRO DATA TO CIAA DATA AT TRANSECT 1 (3 FIGURES - A, B, and C) 29 11 CHANGE IN STRANDING AREA FOR GRANT CREEK CHINOOK FRY (35-50 mm) 33 12 INCREMENTAL CHANGES IN STRANDING AREA FOR GRANT CREEK (INITIAL DISCHARGE IS 450 CFS. THE FLUCTUATION AMPLITUDE IS THE DECREASE IN CFS FROM 450 CFS) 34 5192a iii LIST OF TABLES Table No. 1 LIFE fIISIURY PIWA LS UI CHINOOK AND SOCKEYE SALMON IN GRANT CREEK, 5192a iv Page f7 1.0 INTRODUCTION 1.1 BACKGROUND Grant Lake is located in the central part of the Kenai Peninsula, Alaska approximately 1.5 miles due east of Moose Pass and 27 miles northeast of Seward. This lake is drained by Grant Creek, which flows for about one mile from the outlet of Grant Lake to the Trail Lakes system. The upper portion, approximately one-half mile, of Grant Creek flows through a narrow canyon. The steep gradient and falls within the canyon are a complete barrier to upstream migration of fish into Grant Lake. Lower Grant Creek is utilized, to a limited extent, by chinook (Oncorhynchus tshawytscha) and sockeye (0. nerka) salmon. Rainbow trout (Salmo gairdneri) and Dolly Varden (Salvelinus malma) char have also been noted to exist (Alaska Power Authority (APA) 1984). Evaluations are currently underway by the Cook Inlet Aquaculture Association (CIAA) to determine if a coho planting program is viable for this site. In recent years, artificial introduction of coho (0. kisutch) fry in Grant Lake has resulted in returns to the lower portion of Grant Creek. The objective of these plantings has been to utilize the potential rearing capacity of Grant Lake to supplement existing runs in the Kenai River system. Kenai Hydro, Inc. has proposed to develop a hydroelectric project at this site. The project would take advantage of the head that could be created by the sharp drop in elevation between Grant Lake and the Trail Lakes system. The intake for the project would be on Grant Lake. The water would be conveyed to a powerhouse on Grant Creek. The discharge from the powerhouse would be upstream of the area most utilized by fish in Grant Creek. This general site has been studied previously for potential hydropower development. In 1980, the City of Seward examined the site. For this 5192a feasibility stud), fish habitat in Grant Creek was only briefly considered, primarily because with the preferred alternative, most of the water would be conve)ed to a powerhouse on Upper Trail Lake, thereby leaving Grant Creek mostly dewatered. The Alaska Power Authority (1984) also examined the site and performed extensive environmental and engineering field investigations. The Power Authority's preferred alternative was similar to that for the City of Seward in that a powerhouse would be sited on Upper Trail Lake, thus significantly reducing flows or dewatering Grant Creek. The Power Authority study examined the resources of Grant Creek and performed some general instream flow analyses, primarily those of Tennant (1976). This methodology provides a habitat quality designation based on given percentages of the average monthly discharge. 1.2 OBJECTIVES Kenai Hydro's project differs from previous preferred alternatives in that the powerhouse will be on Grant Creek. Thus, under this proposed siting, water would not be removed from Grant Creek. However, the existing flow regime would be altered. Figure 1 shows the average natural discharge over the 33 years of record (11.5 years of USGS records at Grant Creek and 22 years of synthesized data from the Power Authority studies (1984)). This figure also shows anticipated average with -project discharges for years when low, average, and high amounts of water are available in the watershed. The natural flow regime has peak flows in the summer with June, July, and August being the peak months. The highest discharge occurs in July, with an average of 504 cfs. In contrast to these high flows, winter discharges are very low, ranging down to 27 to 41 cfs (averaged from January to April). 5192a 2 �-E O U W D ry O O O O O O O t00 LO It M N O 3 U W 0 O Z C) U O F- a w V) 0 Q 7 t m W LL Z Q 7 a With -project flows would decrease the summer flows and increase the winter flows. Minimum flows of 50 cfs from October through April and 100 cfs from June through September have been proposed by Kenai Hydro (and di;ru,,rl with Ilir rr­.ouiIV I(IVn( inf.) a, providinq adrvpntr, fi'.h habitat in Grant Creek. The U.S. Federal Energy Regulatory Commission (FERC) has requested that an instream flow study be performed for, this project. The study is to encompass a quantification of the relationship between the amount of suitable habitat and flow for each life history stage of salmon and trout present in Grant Creek. In addition, the FERC requested that an identification be made of the physical habitat type that is limiting production in Grant Creek. In initial consultations between Kenai Hydro and resource agencies (the National Marine Fisheries Service (NMFS), Alaska Department of Fish and Game (ADF&G), U.S. Fish and Wildlife Service (USFWS), and U.S. Forest Service) concerning the FERC request, daily fluctuation of discharges in the area downstream of the powerhouse was also identified as a potential area of concern and in need of analysis. As a result of the above requests or consultations, it was decided to 1) quantify the relationship between suitable habitat and flow for each life history stage of key fish species in Grant Creek, and 2) develop the relationship between daily fluctuations and potential fry stranding. Both analyses were to be conducted based on data collected for the Instream Flow Incremented Methodology (IFIM, Bovee and Milhous, 1978). 1.3 SCOPE OF STUDY Kenai Hydro conducted the initial consultations with the resource agencies and performed the field investigations related to the IFIM study. Envirosphere Company was contracted to analyze the field data 5192a 4 and provide results cf the ccmputer analysis for fish Weighted Usable Area (WUA) and stranding. Results presented in this report are considered provisional pending agency review and comment. 5192a 5 2.0 APPROACH 2.1 EXISTING DATA A considerable amount of data is available on the physical, chemical, and biological attributes of the the Grant Lake/Grant Creek system. A major portion of this information was developed during the Power Authority's feasibility analysis of the site (APA 1984) and in association with recent evaluations by the Cook Inlet Aquaculture Association (CIAA) concerning the introduction of coho salmon to the Grant Lake system. In addition, the U.S. Geological Survey maintained a stream gage on Grant Creek for 11.5 years starting in 1948. i Following is a brief sketch of information available from past studies. 2.1.1 Discharge In addition to the 11.5 years of USGS records, the Power Authority synthesized an additional 22 years of data using the HEC-4 Monthly Streamflow Simulation Model. This modeling effort incorporated streamflow information from other, nearby systems. The Power Authority also installed continuous recording gaging stations during their feasibility studies. 2.1.2 Habitat The Power Authority aquatic studies of Grant Creek involved collection of information on the presence and distribution of fish species, periphyton, and macroinvertebrates. Particular attention was given to spawner surveys for adult salmon and abundance of juvenile salmonids. In general, fish habitat studies in relation to instream flow were restricted to a brief examination of optimum flows based on Tennant's Method (1976). As previously mentioned, the reason that more extensive 5192a 11 studies were not undertaken was that discharge from the Power Authority's preferred project would be into Upper Trail Lake; thus, Grant Creek would essentially be dewatered and the existing habitat lost. The Power Authorlty planned to mitigate this loss by several means described in the feasibility report (APA 1984). 2.1.3 Fish The Power Authority's studies did establish information about the existing fish resources of Grant Creek. Important information for the salmon and trout (including char) can be summarized as follows: Chinook 1. Adults a. Spawn during August and September b. Based on surveys by ADF&G (1952 to 1981)'and the Power Authority in 1982 (APA 1984), the average peak salmon spawning ground count for the creek over these years was 19 fish. Weir counts by the CIAA indicate that this number may be somewhat larger, but generally indicate that there are less than 50 adult chinook that return each year. 2. Juveniles a. Juveniles (age 1+) have been observed throughout the year (APA 1984); however, the low numbers observed during March, May, and June suggest that they are either very inactive during these months or they have left the system to rear elsewhere prior to downstream migration. 5192a 7 Ib. Natural emergence of age zero chinook may be later than June because none were observed (in minnow traps) until August during the Power Authority studies (APA 1984). However, some were observed in May during electrofishing, but these appeared to have been stimulated out of the gravel from the Ielectrofishing activities. Sockeye 1. Adults a. Spawn during August and September. b. The combined average peak salmon spawning count by ADF&G from 1952 to 1981 and the Power Authority (1984) was about 61 fish. Weir counts by the CIAA show higher numbers at approximately 400 fish in 1985 and 675 in 1986 (Marcuson 1986a, 1986b). 2. Juveniles a. Previous observations indicate that sockeye juveniles do not rear in Grant Creek. Juvenile sockeye typically rear in a lake habitat. Therefore, Grant Creek juvenile sockeye probably rear in one of the many lakes in the Kenai River System. Coho Salmon 1. Adults a. No adult coho were observed either during previous spawning ground surveys by ADF&G from 1952 to 1981 or by the Power Authority (1984). 5192a 8 b. The artificial introduction of coho fry to Grant Lake has produced a return of approximately 1,000 fish (based on weir counts by the CIAA in 1985 and 1986). Some of these appear to be native fish; however, none were observed in previous studies (see No. 1). C. Peak returns occur in August and September, with a few returning in October. 2. Juveniles a. Previous studies showed that some coho rear in the lower reaches of Grant Creek but are less abundant and were not as widely distributed as juvenile chinook (APA 1984). b. The fact that some extremely small juvenile (less than 40 mm) coho were trapped in August 1982 (APA 1984) in Grant Creek strongly indicates that some natural spawning does occur. Rainbow Trout 1. Adults a. No spawning adults have been observed; however, small young -of -the -year (45-50 mm) were observed in October 19829 which suggests that spring spawning may occur (APA 1984). 2. Juveniles/Adults a. Rainbow trout appear to be evenly distributed in Grant Creek and are found in most habitat types. Rainbow captured during 1982 studies by APA (1984) ranged from 43 to 106 mm in length. 5192a 9 Dolly Varden Char 1. Adults a. No spawning adults have been observed (APA 1984). b. Larger fish may move into Grant Creek during late summer to feed and to avoid the high turbidity of the Trail Lakes System. 2. Juveniles a. Sizes observed during the Power Authority studies ranged from 55 mm to 30 cm. The above species are found throughout the Kenai River system. In terms of commercial and sport value, the most important of these species in this system are the Chinook and sockeye salmon. Coho salmon are also very important. The numbers of chinook, sockeye and coho in Grant Creek represent a relatively small portion of the total escapement to the Kenai system. The continued existence of a coho planting program in Grant Lake is currently being evaluated. Therefore, it is uncertain if this run will be maintained. Rainbow trout and Dolly Varden char represent a small local sport fishery in Grant Creek. Due to its inaccessibility and often high turbidity during the fishing season, angling pressure is considered relatively light for these species (APA 1984). Based on these considerations, the key species selected for habitat analysis in Grant Creek were chinook and sockeye salmon. In summary, the evaluation species and their life stage selected for habitat analysis were: o Chinook - spawning and rearing o Sockeye - spawning 5192a 10 2.2 FIELD DATA COLLECTION All field data for the instream flow habitat analysis were collected on October 24, 1986, by personnel from Kenai Hydro. Three transects were placed across the stream. Depth, velocity, and substrate were recorded. Measurement for bed elevations were made at intervals of 2 to 4 feet apart at each transect and velocities were measured at 0.2, 0.6, and 0.8 of the depth (R. Poole, Kenai Hydro, personal communication 1987). Appendix A contains a summary of the original field notes. 2.3 FISH HABITAT SUITABILITY CURVES Suitability curves for the various life stages of chinook and sockeye were developed from information found in the literature. This was believed to be a reasonable approach because a considerable amount of information is available in Alaska on suitability of habitat for certain species with some information directly derived from the Kenai River system (e.g., Burger et al. 1983) Following is a brief description of the sources or the rationale for each curve. 2.3.1 Chinook Adults Burger et al. (1983) found that velocities measured in Kenai River tributaries at 0.6 of total depth had mean values of about 1.5 to 3.0 feet per second (fps) in the pit of chinook redds and 2.3 to 3.7 fps in the tailspill. Burger et al. (1983) also suggested that Kenai mainstem spawners may utilize velocities of 0.9 to 4.6 fps (measured at 0.2 total depth). Collins et al. (1972) found a preferred range of 1.0 to 2.25 fps. From this information, a suitability curve was developed with ranges from 0 (not suitable) to 1 (entirely suitable). A broad range of velocities was established for the suitability analysis. This curve is shown in Figure 2. 5192a 11 0 1.0 0.8 '' 0.6 a m 0.4 N 0.2 0.0 0 1 2 3 4 depth (feet) FIGURE 2. HABITAT SUITABILITY FOR CHINOOK ADULTS Habitat Suitability Chinook - Adults Velocity Velocity Suitability 0.0 0.0 0.5 0.0 0.8 1.0 3.6 1.0 4.6 0.0 1 2 3 4 5 velocity (fps) Depth (Estes and Vincent -Lang 1984a) Depth Suitability 0.0 0.0 0.5 0.0 1.0 1.0 4.0 1.0 12 Burger et al. (1983) found chinook redds in a tributary of the Kenai River to be at a depth of 2 to 2.3 feet. Other researchers elsewhere (Collins et al. 1972) indicated that a preferred range is from 1.0 to 1.75 feet. A multitude of other ranges have been described in the literature (Reiser and Bjornn 1979); however, they are all quite similar. To encompass a wide range in the habitat analysis, it was assumed that no spawning would occur at depths of less than 0.5 feet. Also, because maximum depths of 6.5 feet have been reported (Smith 1973) and the maximum depth in the Grant Creek is in this general range, any depth over 1.0 foot was considered to be entirely suitable for spawning. The resultant curve (Figure 2) is the same curve as that reported by Estes and Vincent -Lang (1984a). That curve was developed from studies on the Susitna River Basin, Alaska and from professional judgment of the authors. Again, this curve is believed to encompass a wide range of possible values. Successful growth and incubation of chinook eggs and alevins can occur over a wide range of substrate sizes and particle size distributions. The substrate observations taken by Kenai Hydro were fairly broad in their description (see Appendix A). This makes it somewhat difficult to define precise suitability curves for Grant Creek. Studies by Estes and Vincent -Lang (1984a) resulted in suitability values of: Size (inches) Suitability Index Silt 0 Sand 0 1/8-1 0 1 to 3 0.65 3to5 1.0 5 to 10 0.70 greater than 10 0 5192a 13 Therefore, it was assumed that substrate sizes 12 inches or larger in diameter were not suitable (equal to 0) while sizes less than 12 inches in diameter were usable (equal to 1). Again, this is believed to be a wide range because the optimum sizes for chinook range from 0.5 to 4 inches in diameter (Reiser and Bjornn 1979). Juveniles Burger et al. (1983) examined the depth and velocity preferences for chinook juveniles in the Kenai River system. Figure 3 shows the curves developed from their data. These were adapted for use in the habitat analysis for Grant Creek. There are some differences noted in velocity suitabilities in fish at 35 to 50 mm and those from 51 to 100 mm. For depth, the curves are the same. Substrate for chinook juveniles was primarily considered for the stranding analysis. The field results from Kenai Hydro indicated that most of the material observed was fairly large (greater than 2 inches in diameter). Therefore, all of the substrate in the study section was considered to have the potential for stranding. The potential for stranding was only considered for chinook less than 50 mm. The rationale for this is that juveniles greater than 50 mm would be much more capable of escaping potential stranding situations (Prewitt and Whitmus 1986). 2.3.2 Sockeye Adults The depth, velocity, and substrate suitability curves for spawning by sockeye were adapted from studies by Estes and Vincent -Lang (1984b). The study area was the Susitna River, Alaska. Figure 4 shows the curves for depth and velocity. The suitability that Estes and Vincent -Lang used for substrate was: 5192a 14 tm N Habitat .Suitability Chinook - Juveniles Velocity - Fry: 35 to 50 mm (Bu(gor et al. 1983) 0.0 0.2 0.4 0.6 0.8 1.0 1.2 1.4 1.6 1.8 2.0 velocity (fps) Velocity - Fry: 51 to 100 mm (Burger et al. 1983) 1.0 0.8 T y 0.6 m 0.4 N 0.2 0.0 0.0 0.2 0.4 0.6 0.8 1.0 1.2 1.4 1.6 1.8 2.0 2.2 2.4 velocity (fps) 1 Depth - Fry: (Burger et al. 1983) Velocity Suitability 0.0 0.5 0.2 1.0 0.3 1.0 0.5 0.5 1.6 0.1 2.0 0.0 Velocity Suitability 0.0 1.0 0.5 1.0 0.6 0.8 2.25 0.0 Depth Suitability 0.0 0.0 0.1 0.0 0.2 1.0 1.0 1.0 0.0 0.2 0.4 0.6 0.8 1.0 depth (feet) FIGURE 3. HABITAT SUITABILITY FOR CHINOOK JUVENILES 15 Habitat Suitability Sockeye - Adults Velocity (Estes and Vincent -Lang 1984b) 1.0 0.8 0.6 a A 0.4 N a... 0.2 0.0 0 �_.. 1.0 0.8 '' 0.6 z 0.4 N 0.2 0.0 0.0 1 2 3 4 5 velocity (fps) Depth (Estes and Vincent -Lang 1984b) 0.2 0.4 0.6 0.8 1.0 depth (feet) FIGURE 4. HABITAT SUITABILITY FOR SOCKEYE ADULTS 16 Velocity Suitability 0.0 1.0 1.0 1.0 2.0 0.5 3.0 0.1 4.5 0.0 Depth Suitability 0.0 0.0 0.2 0.0 0.3 0.2 0.5 0.9 0.75 1.0 1.0 1.0 Size (inches) Suitability Index Silt 0.0 Sand 0.0 1/8 to 1 0.5 1 to 3 1.0 3 to 5 1.0 6 to 10 0.25 greater than 10 0.0 As with the chinook suitability curves, any substrate less than 12 inches in diameter was considered suitable (equal to a suitability of 1). Any 12 inches or larger was considered unsuitable (equal to �. 0). This assumption was believed to encompass a wide range of possible values. Juveniles Juvenile sockeye were not considered in the habitat analysis because ILI previous studies of Grant Creek generally indicate that the juveniles rear in downstream areas and not in Grant Creek (APA 1984). 1 2.4 TIMING OF LIFE HISTORY STAGES OF CHINOOK AND SOCKEYE SALMON IN GRANT CREEK Table 1 summarizes the general life history stages of chinook and sockeye salmon in Grant Creek. In general, the adult phase is easily defined through previous studies by the Power Authority, ADF&G, and the CIAA. The incubation phase is somewhat more difficult; however, inferences have been made from observations of the appearance of small juveniles (less than 50 mm) in the summer. Rearing by juveniles is fairly well defined with juvenile chinook apparently present year-round and juvenile sockeye moving rapidly downstream. Ir5192a 17 TABLE 1 LIFE HISTORY PHASES OF CHINOOK AND SOCKEYE SALMON IN GRANT CREEK Stage Chinook o Adults o Egg Incubation and Early Intragravel o Juveniles Sockeye o Adults o Egg Incubation and Early Intragravel o Juveniles 5192a 18 When Present August -September August-May/June All Year August -September August-May/June Move Downstream and Rear Elsewhere 2.5 DATA ANALYSIS The analysis of habitat was performed in a stepwise manner as follows: 1. A summary of the field data (submitted to Envirosphere by Kenai Hydro) was reviewed (Appendix A). 2. Minor adjustments or corrections were made to the basic Kenai data so that the data would conform to modeling inputs. These changes were: Transect 1 a. The staff reading for the "surface" was changed from 7.86 to 6.86. This would appear to be a reasonable correction because the surface on the opposite bank was 6.86. It appears that a 1.0 foot error was made by Kenai Hydro in the field data. The measurement for distance at this station was considered to be 0. b. A "distance" of 65 feet for station number 18 was inserted into the data base. No distance was originally provided, however, a staff reading of 5.05 was taken. It was assumed that because other distance measurements between stations ranged from 2 to 4 feet, a distance of 2 feet would be a reasonable number to use. C. The stage level decrease recorded at the end of the day was change from 0.25 to 0.21. The rationale for this change was that a subtraction error was made in the original data (6.86 - 6.65 does not equal 0.25, it equals 0.21). 5192a 19 M Transects 2 and 3 No adjustments were made at these transects except a distance of 0 was inserted at the stake for Transect 3. 3. Envirosphere transformed the resultant data to develop input for the WSP model. This process consisted of scaling the water surface elevation (WSEL) at Transect 1 to 100.0 feet elevation (see Appendix B), calculating depths, and utilizing the 0.6 foot depth velocities from the original data. 4. Codes were assigned to the Kenai Hydro substrate data. If the average of the substrate range was less than 12 inches in diameter, a value of 3 (unsuitable) was assigned to this substrate. If the average was equal to or greater than 12, a code of 4 (unsuitable) was assigned. This designation was for the habitat analysis. For the stranding analysis, all substrate was considered strandable. The adjusted data from Kenai Hydro (Appendix Tables B-1 through B-3) were analyzed by calibrating a standard Water Surface Profile (WSP) program (Bovee and Milhous 1978). The Manning's N was adjusted at the three cross -sections to calibrate to the water surface elevation (WSEL) using a calibration flow of 246 cfs. This step required four runs with WSEL's calibrating to 0.01 foot. The model calibrated well for the lower and middle transects; however, some adjustment was needed for the upstream transect. The reason for this was that the model was calibrated to 246 cfs, but the WSEL at the upstream cross-section was obtained at 297 cfs. Two steps were taken to evaluate this discrepancy. First, calibration velocities were scaled down proportionally (246/297) to represent what measured velocities might 5192a 20 M have been at the lower discharge. The model was then calibrated to the adjusted velocities. Next, the predicted water surface elevation for 246 cfs modeled discharge was compared to a WSEL adjusted by subtracting the total daily stage differential (0.21 feet measured at the staff gage) from the WSEL measured at 297 cfs (100.00). The resulting WSEL (99.79) was .02 ft less than the predicted WSEL after the velocity adjustment. Once the WSP model was calibrated, the HABTAT model was run to determine weighted usable area (WUA) for the various life history stages (for additional details about this methodology see Bovee and Milhous 1978). The flow range examined was from 50 cfs to 450. One set of field measurements (taken on October 24, 1986) was provided by Kenai Hydro for the analysis. A supplemental set of field measurements were taken by the CIAA on February 24, 1987. These measurements were taken at Transect 1. The discharge was 28 cfs. The field notes on this data were provided to Envirosphere by Kenai Hydro. This information was not used to supplement the WSP model because the data were taken for discharge calculations and not for habitat analysis (the procedures and measurements are not the same). However, to provide a check on the WSP model, the data were examined. Stranding potential was analyzed by the methodology described by Prewitt and Whitrtus (1986). In general, this methodology uses information on the slope (of the transect across the stream), substrate, and discharge to determine stranding potential. In the situation for Grant Creek, chinook juveniles less than 50 mm were the key species for investigation. However, the analysis would generally apply to all salmonid species less than 50 mm (e.g., sockeye, rainbow, or Dolly Varden). 5192a 21 3.0 RESULTS Cross -Sectional Profiles Figure 5 presents the cross -sectional profiles at each of the transects. Station 0+00 represents the downstream transect, Station 0+33 is in the middle of the study reach, and Station 0+52 is the upstream transect. Also shown on this figure are WSEL for discharges of 50, 100, 300, and 400 cfs. In general, the major portion of the streambed at each transect is covered at about 100 cfs. Habitat Relationships Figures 6 through 8 show the relationship between WUA and discharge for: o Adult Chinook Spawning (Figure 6) o Juvenile Chinook Rearing - less than 50 mm (Figure 7) - greater than 50 mm (Figure 8) The WUA applies to this study site and represents the amount of area (in square feet) per 1,000 ft of stream. The discharges encompass most of the average discharge levels measured in Grant Creek; however, extrapolations to higher or lower discharges were not done because these were felt to possibly be beyond the range of good predictions for the WSP model. The adult Chinook spawning curve shows that WUA increases with discharge up to about 350 cfs. It then begins to decline. The probable reason for this is that at the higher flows, velocities increase beyond those preferred for spawning. (It should be noted that the curves are considered to encompass a wide range of possible spawning habitat, i.e., if suitable substrate sizes were less than 5192a 22 ('R011e-5ECTIONAL PROFILE 104 103 102 f01 100 it • •7 0 10 40 •o •o 01•TANct Cm CROSS -SECTIONAL PROFILE 104 100 102 101 100 • •• •7 0 20 40 •o DISTANc[ (FT) CROSS -SECTIONAL PROFILE STATION 0402 $04 103 102 101 100 QQQ111 • •• •7 O 20 40 •o DISTANcz cm FIGURE 5. CROSS SECTIONAL PROFILES FOR GRANT CREEK TRANSECTS. STATION 0+00 IS THE DOWNSTREAM TRANSECT, 0+33 = MIDDLE, AND 0452 = UPSTREAM TRANSECT. 23 V Z >Z n� n U) v W LLI Y (If O u O t- Z = C7 U Q 1-1 tO N O 00 lD It N O 00 LD d' N O 00 '- (spuosnoyl) O u) ,It I Z O z O O M f _ J V) N W UY v o O W z N Ox N Q S � U V) z O 3 d O � O N O w 3 24 CD Z Q W V O O Y Z_ W W = U U F- Z E g E O Q t0 In In to It to to 4 M (spuosnoyl) (,A-j) *v-n'M 25 M tn CV 0 to 0 O It O to M O U) O O 1 O to CD Q� LL O z W LEI _ C) U � z O O O Ln Q N O 0) 00 r tD Ln (spuosnoyl) 26 0 to M w L J vZ w w> OO 0 � N Q = z 0 s In ¢ O O o 3 w J m In O w Ln LO co 6 inches in diameter rather than the 12 inches used in this analysis or suitable velocities were less, the WUA would have been less also.) The WUA (Figure 7) for Juvenile chinook less than 50 ami shows a peak at about 150 cfs and decreases at both higher and lower discharges. The curve for juvenile chinook greater (Figure 8) than 50 mm also shows a similar peak at about 150 cfs. Sockeye Figure 9 shows the WUA for adult sockeye. In general, the WUA is similar between 50 and 250 cfs. However, at discharges greater than 200 cfs, the WUA decreases significantly. This most likely occurs because higher velocities are associated with the increased discharge. rison of Kenai Hydro Data to the CIAA Data at Low Flow In examining the CIAA data, the first problem encountered was the missing water surface elevations and the tie-in, by leveling, to the Kenai Hydro benchmark. This causes difficulty in matching the CIAA data points to the original data and therefore does not provide sufficient data to use it for habitat modelling. Thus, the CIAA data do not add substantially to the capabilities for prediction of habitat at low flow. However, a cross-section bed profile was developed to see if the CIAA's profile matched the Kenai Hydro data. Figures 10A, 10B, and IOC show the Kenai Hydro profile for T1 and CIAA's profile. The two are reasonably similar. These also show possible matchups of the bottom profile with the CIAA water surface elevation at 28 cfs and the model's water surface at 30 cfs. The matching of the model to the CIAA data or vice versa does show some potentially important features. For example, the model generated is considered to be conservative for low flows; i.e., water surface elevations would be expected to be slightly lower than actual values. This is probably because at lower discharges, the "roughness" increases. The model does not account for this because a single "N" value was used for all flows. Therefore, for 5192a 27 Q i Z Y Z W W U V) 9 U W Y U O c� co in N lQ In 1n LO I' N I-� l0 ui 4 M (spuoenoyl) (-u) dnm O LO It 0 u> M U v O WU N N Q w S w U Y N V o C7 Z Z 3 Q d N O O to 3 Q w w J C] d N 0 w 1- O = N w 3 M rn w c� LL 91 O cc G _ m w 9 U V r♦ c Y r o rn co r O O O O O Ol m O1 OA) NOLLV/313 W U Z F- m O v i I 1 W f _J lL n J N < N Z + O U Z O w /fin V ) Uv U It r'') N O O O O O ff O) O) O) (l:I) NOIIVA3-13 30 e 5 ,It n N O m 00 n 0 0 0 0 0 am m rn (.U) NOI.LVA313 31 analyses such as stranding, the "strandable area" developed from the model would be expected to be somewhat larger than it is in reality. Because the CIAA data show a water surface elevation higher than that predicted in the model, the model confirms what should happen at lower flows given the single Manning's value used in the simulation. Stranding Figure 11 shows the stranding area associated with various incremental changes in discharge from Grant Creek. In general, the changes are similar from 450 cfs to about 10U cfs. At flows less than 100 cfs, the stranding area increases significantly. The changes apparent in this figure are a function of the bottom configuration at each cross-section. At discharges greater than about 100 cfs, the change in wetted perimeter is much less than for changes at 100 cfs or less. Figure 12 shows the relationship of potential stranding to flow fluctuation. This figure assumes an initial flow of 450 cfs. From this flow, the graph shows how the physical area (stranding area) would change as the flow is decreased in 50 cfs increments. For example, changes from 450 cfs to any other flow from 50 to 350 cfs less result in a small change in stranding area. However, a decrease in flow by any incremental change of 350 cfs or greater results in a significant .... increase in stranding area. 5192a 32 Y O O Z U Y W W z Z 9 0 00 I� lD In �F M N O M M I� W 0 'q- M N r• O (epuoenoyl) (1 4) V-: iJV JNIGNVJ1S NI 30NHH0 33 O I 0 O N 0 0 N i O LO N O I O Ln It L) U v W 0 Q 2 U W C7 U _N 0 w x to LL U O V M _l Q F- w cv LL O J L `1 W U CXQ L z QN^ ,^ V / 0 LL U f ■ O LO a� rq N N co l0 '-t CA O co to It N 0 (spuosnoyl) GiJ) V3�:IH ONICINV�J1S ■ 34 4.0 CONCLUSIONS The analyses contained in this report are sufficient to discuss a negotiated flow regime for the Grant Creek Project. However, the modeling is considered potentially unreliable at flows below about 100 cfs. This is mainly important in considering the low winter flows under natural conditions. With -project flows will not approach these. The following preliminary conclusions can be made based on the information provided by Kenai Hydro: 1. High natural flows in August and September can affect WUA for spawning chinook, particularly at flows greater than about 350 cfs, where WUA begins to decrease from its maximum. 2. High natural flows in August and September result in significantly lower WUA's for sockeye spawning than for flows less than 200 cfs. Therefore, with -project flows will potentially result in a significant increase in WUA for sockeye spawners. 3. The WUA for juvenile chinook less than 50 mm shows that an optimum occurs at about 150 cfs. If fish of this size are present during the summer months, then the high natural flows also result in WUA's that are much lower than optimum. Project flows will generally approach the optimum much more consistently than natural flows. Winter conditions were generally not considered for these small fish because they were expected to remain within the gravel and would not be in the water column. 5192a 35 4. The shape of the WUA curve for juveniles greater than 50 mm is similar to that for the smaller juveniles. Under natural conditions, the low winter flows would severely affect habitat whereas under with -project conditions for this period, the WUA would be larger. During the summer period, the WUA under with -project conditions may demonstrate an improvement over natural conditions. 5. The comparison of predictions made by the model using Kenai Hydro data and the data taken at low flow (28 cfs) by CIAA shows that the model may predict reasonably well even for low flows. Measurements should be taken using methods developed for habitat analysis (e.g., differential leveling) and not for discharge, as was done by the CIAA. 6. When considering potential stranding, it is apparent that at this study site, the potential for stranding increases significantly when flows are decreased below about 100 cfs. For fluctuations greater than this, little effect is apparent. i 5192a 36 5.0 REFERENCES Alaska Dept. of Fish and Game. 1952/1980. Escapement count surveys, Grant Creek. Unpublished. (On file at Alaska Dept. of Fish and Game, Soldotna, Alaska.) Alaska Power Authority (APA). 1984. Grant Lake Hydroelectric Project detailed feasibility analysis - Volume 2 - Environmental Report. Prepared for the Power Authority by Ebasco Services. Bovee, K.D. and R. Milhous. 1978. Hydraulic simulation in instream flow studies: Theory and techniques. Instream Flow Information Paper No. 5. USFWS Cooperative. 131 pp. Burger, C.U., D.B. Wangaard, R.L. Wilmot, and A.N. Palmisano. 1983. Salmon investigations in the Kenai River, Alaska, 1979-1981. USFWS, Nat. Fish. Res. Center, Seattle, Alaska Field Station. Anchorage, AK. 178 pp. Collings, M.R., R.W. Smith, and G.T. Higgins. 1972. Hydrology of four streams in western Washington as related to several Pacific salmon species: Humptulips, Elochoman, Green, and Wynoochee Rivers. U.S. Geological Survey. Tacoma, Washington, 1972. Estes, C., and D.S. Vincent -Lang, eds. 1984a. Report No. 3. Aquatic habitat and instream flow investigations (May -October 1983). Chapter 9: Habitat suitability criteria for chinook, coho, and pink salmon spawning in tributaries of the middle Susitna River. Susitna Hydro Aquatic Studies, Alaska Dept. of Fish and Game. Report to the Alaska Power Authority. Anchorage, AK. Doc. 1938. Estes, C., and D.S. Vincent -Lang, eds. 1984b. Report No. 3. Aquatic habitat and instream flow investigations (May -October 1983). 5192a 37 Chapter 7: an evaluation of chum and sockeye salmon spawning habitat and sloughs and side channels of the middle Susitna River. Susitna Hydro Aquatic Studies, Alaska Dept. of Fish and Game. Report to the Alaska Power Authority. Anchorage, AK. Doc. 1936. Marcuson, P. 1986a. Grant Creek Project - Progress Report: First Coho Salmon Returns From Fry Stocking. Cook Inlet Aquaculture Association, Soldotna, Alaska. 10 pp. Marcuson, P. 1986b. Grant Creek Project - Progress Report: Coho Salmon Returns From Fry Stocking. Cook Inlet Aquaculture Association, Soldotna, Alaska. 11 pp. Prewitt, C.M., and C.J. Whitmus. 1986. A technique for quantifying effects of daily flow fluctuations on stranding of juvenile salmonids. In: Instream Flow Chronicle, Vol. II, No. 4 Colorado State University Conference Services. Pages 1 to 3. Reiser, D.W. and T.C. Bjornn. 1979. Influence of forest and rangeland management on anadromous fish habitat in western North America: habitat requirements of anadromous salmonids. U.S. Dept. of Ag., Forest Service. 54 pp. Seward, City of. 1980. Feasibility assessment. Hydropower development at Grant Lake. Prepared for the City of Seward by CH M Hill Company. Smith, A.K. 1973. Development and application of spawning velocity and depth criteria for Oregon salmonids. Trans. Am. Fish. Soc. 10(2):312-316. Tennant, D.C. 1976. Instream flow regimes for fish, wildlife, and recreation and related environmental resources. Page 359 to 373 In Instream Flow Needs, American Fisheries Society. 5192a 38 U.S. Geological Survey. 1981. Surface water quality records, southcentral Alaska, 1949-1974. Unpublished computer printout. 5192a 39 APPENDIX A SUMMARIZED FIELD DATA FROM KENAI HYDRO, INC. r5192a �I 0) ko m IP In m N d' .o m m �O N O, O, kO N ,D W C m O, rn m rn -r M in tV kD r In M r u) r4 --i rl -A .-1 rt --J .-4 ro In N r0 \ \ \ \ \ \ \ \ \ \ \ \ \ \ U) v U) N m r m to CO N N 7 f N m Vl /if)N CO l0 ' D' U O' N N d' .--I Un I � M N .D V1 ,-i 0 m 0 ro r r r L� 7 to w to x F ; s u ci a H ro IV m" m V CC m m O N v m m O O (D .O 10 .O W m F I NI I I M rl N ,-I .-V ,H .-I H I I -i LI U) Q) N I f j N N I I I I I 1 M M :1 1J ro N m d %D �o %D 10 IV m ro �D 1 ,--1 In U) w a In m If) N In O OD ID m M lO -i V' rl d In I a D D �D r M r In m In o m m d' M .--I D I w . . . . . . . . . . . . . . . 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