NOTHING ALTERS A RIVER AS TOTALLY AS A DAM
From: COALITION FOR SUSITNA DAM ALTERNATIVES
To: Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington DC 20426
Subject: Scoping Comments for Susitna-Watana Hydroelectric Project
For the record, CSDA is opposed to this proposed project and supports the No Action Alternative. A dam on this wild, free-flowing river, one of the last remaining large rivers in the world not dammed, would be an economic and ecological disaster.
TO BUILD OR NOT TO BUILD
We want to remind the Federal Energy Regulatory Commission (FERC) that
even though they are in the business of licensing dams, they do not have to
license this project.
We believe that FERC should deny this license based on the fact that the public interest would not be served.
In the previous application for the Susitna Dams in the mid 1980’s, there was no formal declaration of No Significant Impact. When the license application was pulled by the applicant, there were many unresolved issues: 12 fisheries, 19 wildlife, 8 recreation, 2 aesthetic, 2 cultural resource, 2 air quality, 2 dam safety, 8 socioeconomic, and 1 land acquisition. (Alaska Power Authority, Susitna Hydroelectric Project, Issues List, March 6, 1984)
In 1986 the US Congress passed the Electric Consumers Protection Act which amended the Federal Power Act and requires that FERC give equal consideration to the preservation of the natural environment and the nonpower uses of a river. We believe that FERC should deny this license based on the fact that the public interest would not be served.
I. Project Purpose and Proposed Need for Power
The need for the dam as expressed by the applicant in the Preliminary
Permit, Preliminary Application Document (PAD), FERC Scoping Document 1, statements to the Alaska state legislature and to the public is as follows: to carry out the Alaska Legislature’s goal of generating 50% of the state’s electricity from renewable energy sources by 2025; the majority source of current Railbelt electrical generation Cook Inlet natural gas is running out; to establish low cost, reliable power.
A. State’s 50% Renewable Goal
House Bill 306 was passed in 2010 that established the 50% renewable goal
by 2025; and in that same session, an appropriation was passed to study a large
hydroelectric railbelt project. By November 23, 2010, the state decided the
Susitna Dam was the only way to meet this goal. It was all very convenient, and
it has become one of the primary drivers for the dam. In the actual legislation,
the 50% renewable is not a legal requirement; it is only a goal. Looking at the
big picture, the state already has 24% of current electrical generation of 1500
gigawatt hours from renewable energy sources. Thus, the state only needs 26%
or 1750 gigawatt hours to meet that goal. This could be met by a combination
of smaller scale renewable projects which is actually happening now. A diverse
portfolio of investments is more desirable than 1 major investment. The dam is
B. Cook Inlet Natural Gas is It Really Running Out?
The recent April 12, 2012 testimony by geophysicist consultants and state
geologists to the Alaska House Special Committee on Energy, shows that we are
NOT running out of Cook Inlet natural gas. It is a fake crisis. There is 860 billion
cubic feet left in existing fields called gas reserves. The railbelt demand for
natural gas is about 90 billion cubic feet annually. The problem is this is not a
large enough market for the petroleum companies. There are also estimates of
approximately 7.5 trillion cubic feet in the Cook Inlet Basin gas resource which is
the undiscovered, conventionally recovered natural gas fields. (We are not
talking about having to use hydraulicfracking.) That is enough resource to meet
current southcentral utility demand for electrical generation and space heating
for 100 years.
But once again, the big petroleum companies aren’t interested in
exploring and producing that for railbelt use because of low profits, and the
small independent producers can’t afford the capital cost investment. As the
Regulatory Commission of Alaska has said, “Investment capital in Cook Inlet
must compete with investment opportunities worldwide (and) risk associated
with exploration must be compensated or exploration will go elsewhere.”
The solution is for the state of Alaska to subsidize continuing Cook Inlet
production. We concur with the March 2012 Natural Heritage Institute’s study
evaluations. The state of Alaska financing to find and develop its Cook Inlet gas
resource could be as little as 50% of the required investment in the hydropower
dam, but will provide four times the energy as the dam, enough to meet current
Railbelt energy needs for the next 100 years, at one-half the price/mmBtu as the
dam. State financing, development, ownership, and operation of new Cook
Inlet gas fields appears to be the most cost-effective and most secure of the
energy supply alternatives, with significantly less environmental impact than a
Susitna River power dam.1
C. Stable, low cost energy
Affordable stable energy pricing in the long term for the railbelt will only
occur with state subsidy. This is just the reality. Without a subsidy, the real cost of
electricity from a Susitna Dam to retail residential customers would be in the
range of $0.17-$0.21 Kwh. This is much higher than what Anchorage currently
pays but cheaper than what Fairbanks pays now. But with state subsidy of 50%
of capital construction costs, the price could be much less. But yet we don’t
know if that is really correct, because AEA has not talked about the cost
One item to keep in mind is that the state does not have a
comprehensive energy plan. One is needed in order to discuss future options.
The 2010 Railbelt Integrated Resource Plan(RIRP) provides data but does not
D. The Real Need For Power
AEA constantly states publicly that the dam would provide 50% of railbelt
energy, but this is not an accurate statement. The dam would only provide 25%
of the Railbelt’s total energy requirements when one considers both electric
power and space heating. So even with a dam, the railbelt will need to get 75%
of its energy from other sources.
The dam would NOT eliminate the need for natural gas, only reduce the
use by 25%. Thus, the dam does not solve the railbelt energy problems. Indeed,
FERC must evaluate this fact and also consider that the existence of a dam
could/would encourage industries to locate here. A dramatic increase in
power needs by industrial consumers only exacerbates railbelt energy problems.
The RIRP has stated that it appears conceivable that there will be at least a 1000
MW of new load in the railbelt in the future. RIRP has a 50 year planning horizon
with load forecasts through year 2060 with 2008 data.
With significant negative environmental and socioeconomic impacts from
a dam that does not even solve the problems of railbelt energy needs, we
Alaskans must ask WHAT IS THE POINT?
II. The FERC Licensing Process
The choice of the Integrated Licensing Process (ILP) as the process for the
applicant and FERC to follow is a wrong choice. It is not a good fit for a large,
new controversial project. This has been stated for the record in numerous
letters and meetings by the state and federal resource agencies.
The ILP was created for relicensing efforts which involve projects that are
already on line with baseline data. The ILP’s strict timeline is making the resource
agencies, the public, and even AEA work too fast, and it is causing stress. The
ILP deadline driven schedule is overly restrictive for a program of this size with the
enormous geographic extent and ecosystem and physical complexity. The
agency concerns regarding this aspect have not been addressed.
A two year timeline for studies is insufficient to determine baseline
conditions for hydrology, fish and wildlife habitat, anadromous species and marine mammals and then to study and understand all of the processes that
control habitat formation and maintenance. This is exemplified by the discussion
in the 1/24/12 Instream Flow Study Planning Meeting with resource agencies,
AEA and its consultants. It was stated by Cardno-Entrix consultant Craig Addley
that ideally, most of the fish studies should be finished first in order to provide the
input needed for the instream flow assessment. But the ILP schedule is such that
study efforts must be conducted in parallel. The integration of modeling and
studies would be challenging.2 With the ILP tight schedule, it seems a lot of
paralleling of studies will be occurring. The question is can good science be
done on a prearranged two year schedule?
Many of the assumptions from the 1980 studies are incorrect or not
applicable with current project understandings. For instance, the terrestrial
wildlife studies in the 1980’s were conducted during relatively mild winters which
means there is one big data gap of the use by wildlife of the proposed reservoir
area during a winter of heavy snowfall.
The AEA project manager has said that AEA can even be doing studies
after the license application is submitted as if making up for the fact everyone
involved is so rushed. This is certainly not kosher, may not be legal and indicates
a fast tracked rush job for this project.
The studies should be done for 5 to 7 years which is the lifetime of a
Chinook salmon. There is even a question in the public’s mind if the resource
agencies have adequate funding to carry out their conditioning authorities and
their constitutional mandates. There must be good science upon which
decisions are based. Flexibility must be enabled in this process regarding the
studies and the comment periods. Thankfully, FERC did grant an extension of
this current comment period.
III. Serious concern: Clean Water Act 401 Certification
In 1999, the Alaska Department of Environmental Conservation (ADEC)
waived its mandatory conditioning authority under the federal Clean Water Act
(CWA) for Section 401 certification for all hydroelectric projects in the state. The
401 authority certifies a hydropower project is in compliance with all the
applicable water quality standards. The public has not seen this waiver. It is not
known if this is a memorandum or a directive from the ADEC commissioner.
Apparently, it is top secret. The public can only conclude that this 401 waiver
shows that the Alaska state administration is taking an unreasonably expedient
approach and a cavalier attitude toward this project.
If, due to the state’s standing 401 waiver, the public cannot expect ADEC
to review whether the project would violate state water quality standards, what
can we expect?
Can FERC license a project without a 401 certification? If so, that would
mean there are no conditions to prevent or mitigate water quality impacts from
construction and operation? Or will FERC have to be a surrogate for ADEC?
What can the public expect? ADEC’s participation in the 2011/2012 technical
meetings of the resource agencies/consultants/AEA has been cursory at best.
Study Plans have to examine if the project meets water quality standards.
Project impacts of concern in a section 401 process include changes in
dissolved oxygen, temperature, turbidity, fisheries, and many more.
Alaska seafood and Alaska fishing adventures are both commonly
marketed with an emphasis on the “pristine” waters of Alaska. The term
“pristine” connotes a higher level of purity than simply falling within the
tolerances allowed for chemical contamination.3
As the Alaska Supreme Court recognizes in Pebble Limited Partnership v.
Parnell, the quality of the state’s water, i.e. their purity, is an important trust
responsibility of the state “for the benefit of all of the people.”
….the state has a “property-like interest” in the waters of the state…We
(have) held that “common law principles incorporated in the common
use clause impose upon the state a trust duty to manage the fish,wildlife,
and water resources of the state for the benefit of all the people.”
…this same logic certainly applies to the quality of the state’s waters,
with harm to these waters having the potential to-at the very least-devastate
Alaska’s tourism and fishing industries and significantly
reduce revenues raised from related taxes and licenses.4
Inquiring minds want and need to know what resources within the FERC
process the public can count on to protect our Susitna River water quality.
IV. Alternatives to the Project
Under NEPA, FERC must consider alternatives to the proposed dam
in the Environmental Impact Statement. Usually the alternative section deals
with different manifestations of the project. It is necessary that FERC deal with
the range of dam heights and the corresponding changes in the reservoir
acreage and inundation areas. In 2011, AEA talked merely of a 700 foot high
dam. Then in the PAD and other 2012 documents there is mention of 700 to 800
foot range of dam heights. The AEA Project Manager has mentioned to the
Alaska Legislature and in other venues the possibility of 880 foot height. FERC
must consider this full range of dam heights from 700 to 880 feet.
B. It is necessary that alternative energy sources be considered in the
NEPA document. Whether this would be a part of the No Action Alternative or a
separate category, it is important to do this.
1. Natural gas
As mentioned above in Purpose for the Dam, it is now known that Cook Inlet
natural gas is not running out. In fact, the supplies of natural gas are so
enormous that only a shift in political desire to state subsidized investment is
required to continue tapping the gas. Natural gas provides the majority of the
heat in the railbelt which means gas must continue to be developed whether
the dam is built or not. And natural gas generating plants are becoming
cleaner and more efficient. The new 183 MW natural gas fired combined-cycle
plant in midtown Anchorage has 3 gas turbines and 1 steam turbine. The waste
heat of the gas turbines is recycled to provide steam for the steam turbine. This
uses ¾ of the gas needed to make 1 kilowatt hour that the older plants make. In
the overall picture, natural gas provides the bridge to other sources of electricity
that are now in development that are cleaner.
2. Energy Conservation and Efficiency
This is a priority that is for the best interest of the railbelt public. The Alaska
Legislature’s goal of increasing energy efficiency by 15% by 2020 will reduce
Railbelt electricity demand by 120 MW which is almost half the energy the dam
would provide. This makes the dam even less necessary. Furthermore, in
February, 2010 the study RAILBELT ELECTRICAL EFFICIENCY LANDSCAPE IN
ALASKA ROAD MAP prepared for the Alaska Conservation Alliance
(www.akvoice.org) stated that a 50% improvement in the Railbelt’s electrical
efficiency could generate an increase of up to $947,022,100 in economic
output, $290.927,800 in wages, $53,499,850 in business income and 9350 new
jobs. This would reduce demand for electricity by up to 425 MW. The state must
commit significant resources to electrical efficiency.
Too often government agencies and planners seek to increase energy
supply without investigating the most efficient and appropriate ways to meet
the end-use needs of electrical use. In Portland, Oregon, conservation has
eliminated the need for 6 new power plants in the past 3 decades and can
meet 85% of the new power needs in the next 20 years.
There is a necessity for statewide legislation to enable property based
financing and other incentives for energy efficiency and renewable energy
uses, dynamic pricing, time of use rates, inverted block rates, net-metering,
lighting retrofits, heating and ventilation upgrades and Energy Star appliances.
The Pacific Northwest National Lab in Richland, Washington found an average
savings of 25-35% after retrofitting existing heating, ventilation and air
conditioning (HVAC). If 60% of the US commercial buildings did retrofit to
efficient equipment, 16 power plants of 200 MW size would be unnecessary.5
3. Wind Power
Currently statewide, utilities and municipalities are producing 37 MW of
electrical power generation. This has been a salvation for the many bush
communities across the state and the city of Kodiak in saving innumerable
amounts of diesel fuel. In the bush, future plans for new wind projects total 2500
kilowatts. The railbelt has lagged behind.
But two new wind projects are coming on line that changes that. Fire
Island Wind will be an 11 turbine wind field producing 18 MW enough to power
6000 Anchorage households with a capacity to expand in the future to 54 MW.
A transmission line will be built to the mainland. The Eva Creek wind project near
Healy is the largest wind project in Alaska and the first to be built by a railbelt
utility. There will be 12 turbines to provide 24 MW which will be 20% of the peak
Wind generated power is free from fuel price fluctuations due to market
conditions or supply disruptions unlike the power generated from natural gas.
4. Energy Storage
The emerging technology of battery storage is a key part of future renewable
electrical systems. In conjunction with wind farms, the technology of large
battery storage facilities are coming online. Kodiak Electrical Association will
double the capacity of their Pillar Mountain Wind Project by installing a 3 MW
battery storage and management system. This will bring stability to the
intermittent nature of wind systems.
The battery energy storage technology is really evolving to practical use
by large utilities. It is not pie in the sky. The largest facility to date in the US is the
Laurel Mountain Wind Farm’s 32 MW battery facility in Belington, West Virginia
operated by AES Energy Storage. This same company is proposing to Portland
General Electric a commercial scale battery project of four 50 MW projects in
different locations. This is to maintain reliability during peak demand and
provide flexibility that addresses the spikes and dives of wind, solar and other
renewable energy systems. Another advantage is the storage of excess power.
The reality of this proposed project is an alternative to building a new gas fired
plant. The technology and capacity performance of batteries are improving
and costs are coming down.6
5. Tidal Generated Energy
Alaska holds 90% of the country’s potential for tidal power which is as much
as 125,000 MW. Some of these projects could begin to come online before the
dam is generating electricity. There is no current electrical generation from tidal
now. There are around ten areas in Cook Inlet that have the combined
technical tidal potential of a few hundred MW. Ocean Renewable Power Co.
(ORPC) has a 5 MW hydrokinetic tidal energy pilot project, the East Foreland site
near Nikiski. They also have a FERC preliminary permit for the west side of Fire
Island. If the Nikiski project works out, they will pursue the Fire Island site with the
intention of transmitting the power through the transmission line that the Fire
Island Wind project will use. ORPC has received a $600,000 US Department of
Energy grant to collect baseline data on Beluga whale movement in East
Foreland and Fire Island.
In 2011, there was an agreement between AEA and the National
Oceanic and Atmospheric Administration to quantify tidal resource and identify
promising locations. This report is due in spring, 2013.
6. Geothermal Resources
Mt. Spurr is 75 miles west of Anchorage and is the location of a proposed
geothermal project by Ormat Technologies. They purchased $3.5 million of state
leases and conducted exploratory drilling in 2010 and 2011. There is a potential
to produce 50 to 100 MW of electricity. There would have to be a 25 mile road
and a 40 mile transmission line built. If this resource proves viable, the opening
date could be in 2016 with a cost of $170-368 million. The company has
received $18 million from the state for exploration. It is estimate that the
electrical cost would be 12-13 cents per kilowatt hour. For geothermal to be
feasible, there must be a specific combination of heat, water, and rock
permeability. New technologies such as “enhanced geothermal system” may
expand the reach of geothermal programs.
7. Photovoltaic Power: A Potential Contribution to the Electric Power
Generation Mix for the Railbelt and Beyond7
Photovoltaic power is a well established and proven technology. The
components and hardware for everything from mini weekend cabin sized
systems all the way up to and including multi-megawatt utility scale projects
are available off-the-shelf from a broad range of manufacturers and
suppliers. Photovoltaic power systems can be located close to the point of
use which increases overall system efficiency by cutting down on transmission
losses and minimizing the need for high capacity transmission lines extending
over great distances.
Widely distributed utility scale and smaller residential/commercial scale
photovoltaic generation facilities eliminate both the known and
unknown/unpredictable risks of a single mammoth project subject to
everything from objective hazards such as earthquakes to uncertain factors
such as reduced water flow from shrinking glaciers to drought conditions over
which there is no capability for prediction or control. Distributed smaller scale
power production equates to system redundancy and greater reliability.
The cost of photovoltaic capacity has decreased substantially within the
last couple of years. Utility scale projects in the contiguous states currently
come in at around one-third the cost per installed watt of the projected
price tag for the Susitna Dam project exclusive of land acquisition,
transportation corridors, transmission lines and other related externalities. The
$4.5 billion cost of the Susitna project could buy somewhere in the
neighborhood of 1.5 to 1.8 peak rated gigawatts of installed photovoltaic
capacity in the lower 48 as compared to the 600 megawatt peak rated
capacity of the Susitna project. Allowing a factor of 120% for freight and
other higher costs of doing business in Alaska that would still yield 1.25 to 1.5
gigawatts of installed peak photovoltaic capacity, still more than double the
projected output of Susitna.
Photovoltaic power is obviously subject to daily and seasonal variability
but power from a proposed Susitna Dam project would also be constrained
seasonally at the very least and possibly on shorter time scales if river flow
regulation is required by empowered agencies for preservation of salmon
runs, commercial and recreational activities, etc.
Photovoltaic projects can be up and running within a matter of a year or
two from initial concept to commissioning on the grid as a reliable power
source throughout the railbelt or in far flung villages across Alaska. The
Susitna project on the other hand would not produce its first kilowatt hour for
at least a decade or more into the future at the earliest even if all the pieces
fall into place flawlessly.
V. Downstream Resource Impacts
A. Aquatic Resources
A strong case could be made that the proposed dam and its footprint on
the Susitna Basin would be in legal conflict with Alaska’s Sustainable Salmon
Fisheries Policy as set forth in 5AAC 39.222. The Alaska Board of Fisheries and the
Alaska Department of Fish and Game are constitutionally mandated “to
effectively assure sustained yield and habitat protection for wild salmon stocks
with the policy goal to ensure the conservation of salmon and salmon’s required
marine and aquatic habitats, protection of customary and traditional
subsistence uses and other issues, and the sustained economic health of
Alaska’s fishing communities.”8
“In the face of uncertainty, salmon fisheries and salmon essential habitats
shall be managed conservatively using a precautionary approach that requires
consideration of the needs of future generations and avoidance of potentially
irreversible changes, that where the impact of resource use is uncertain but likely
presents a measurable risk to sustained yield, priority should be given to
conserving the productive capacity of the fishery.”9 The precautionary
approach to regulate activities that affects essential salmon habitat must be
applied to this proposed project. We cannot risk our valuable salmon fisheries in
the Susitna River Basin. The EIS must show how this project will comply with these
The EIS must list and consult the Cook Inlet Regional Salmon Enhancement
Planning Phase II Plan: 2006-2025 promulgated by the Cook Inlet Regional
Planning Team January 2007. State legislation created this team which is made
up of 3 representatives from Cook Inlet Aquaculture Association and 3
representatives from the Alaska Department of Fish and Game. It is important to
note the importance of habitat protection in this plan. “The strategy to achieve
habitat protection may appear to be the most removed from dealing directly
with the salmon stocks; but in fact, it is one of the most important keys to the
long-term health of the resource. It involves the systematic and long-term
concern for the preservation of the quality and quantity of the required
supporting habitat based on the premise that suitable habitat is an essential
component of stable salmon production.”10
It is readily apparent, that the Susitna River salmon stocks are in crisis. In
2008, the Alaska Board of Fisheries (BOF) designated the Susitna River sockeye salmon a stock of yield concern11. In February of 2011, the Alaska Department of
Fish and Game (ADFG) recommended that the designation continue. In
February of 2011 the BOF designated the Willow Creek and Goose Creek
Chinook populations a stock of yield concern.12 In 2011, ADFG recommended
that the Alexander Creek Chinook population be listed as a stock of
management concern.13 In 2008, the Susitna River chum population was
recommended by the Mat Su Borough to be listed as a stock of management
concern. It was not designated, but the effort influenced the Alaska Legislature
to create a fund for a Cook Inlet Salmon Task Force to examine conservation
and allocation. A four year study was established, but there are results
published only from 2009. It is not currently a stock of management concern.14
In 2011, 12 of 17 Northern Cook Inlet streams failed to achieve their
escapement goals for Chinook salmon. Seven of those are Susitna River
tributary streams: Chunilna (Clear) Creek, Goose Creek, Montana Creek, Prairie
Creek, Sheep Creek, Willow Creek, Alexander Creek. A 5/1/12 ADFG Division of
Sport Fishing press release stating the Emergency Order for Chinook salmon sport
and commercial fishing restrictions for the 12 tributaries for this summer shows
that the crisis continues.15 These fisheries will be managed very conservatively in
response to a below average outlook for this summer. This will negatively impact
the economies of the communities of the Susitna Basin. With our salmon stocks
in crisis, the region does not need the negative impacts from the proposed dam.
The Susitna River is home to 19 fish species. Five of these species are the
prey species for the federally recognized endangered Cook Inlet Beluga Whale.
FERC must ensure that there are studies that assess the effects of the project on
the Susitna River tributaries and their fisheries. Due to deep freezing and minimal
winter water flows, tributaries such as Chunilna Creek will have no resident winter
fish unless there is a deep water lake in the system. Their winter fish populations
move out into the mainstem Susitna River, and the fish are vulnerable to
disruptions produced by a dam and the electric demand driven releases.
Chunilna Creek and the Talkeetna River are legislatively designated as State Recreation Rivers due to the importance of the anadromous fisheries and the
water dependent recreational activities.
B. Susitna River Hydrology
The 1980 studies did NOT thoroughly assess the hydrological regime on the
Susitna River from the Chulitna River confluence to the mouth. There was a false
premise that there would be little or no impact from the project that far. We
now know that is not true.
On 12/29/11 when AEA released the PAD, the project operation was
changed to load following. Load following operations present the most extreme
changes to the natural hydrological regime for a glacial river such as the Susitna
River which derives most if not all of its winter flows from groundwater. The winter
flows will fluctuate from 3,000 to 10,000 cubic feet per second (cfs) within 24
hours. This will have major adverse affects on anadromous fish and their habitats
during the critical egg incubation and hatching, emergence, fry migration and
the juvenile overwintering life stages. Not only will there be constant water
fluctuations daily, but enormous amounts of water that will be released.
There will be enormous variations in the Susitna River flow volumes in the
months of November-April. Comparing the winter flow data of the natural flow
pre-dam with the post-dam flow data from AEA’s Preliminary Application
Document the following was concluded. (the numbers are rough rounded)
Post-dam with an average flow of 6500 cfs the flow will be 300% greater at Gold
Creek, 100% greater at Sunshine (below the confluence of the Chulitna and
Talkeetna Rivers) and 50% greater at Susitna Station (below the Yentna River).
With a peak release of 10,000 cfs the flows would be 560% greater at Gold
Creek, 170% greater at Sunshine, and 100% at Susitna Station. With a maximum
release of 14,500 cfs, the flows would be 850% greater at Gold Creek, 260%
greater at Sunshine, and 130% greater at Susitna Station. 16
This is a radical change. Not only that, but it shows that the Susitna River
basin above Gold Creek plays a significant hydrological role; more than the
average of 16% of the total river discharge at the mouth especially during
The whole hydrological regime of the river will be changed. Only the
smaller sediment particles will pass downstream. The dam in the reservoir will
trap the larger particles. The substrate size for proper incubation varies by
salmon species, but what is guaranteed that the appropriate sizes will be
present for healthy salmon redds?
The natural condition of winter ice cover maintains upwelling in the side
sloughs. Reduction in winter ice due to warmer water temperatures and
constant fluctuating flows will reduce the hydrostatic pressure which in turn will
reduce the localized upwelling. It is this very upwelling in the streams that could
be very important locations where salmon exist in the winter. Eliminate that and
negative impacts will follow.
The AEA consultants’ data gap reports and the PAD present pre-project
physiochemical conditions of the water that can affect aquatic resources if the
conditions become bioavailable. A review of the data from the 1980 studies
shows concentrations of metals at some locations in the Susitna River Basin
exceed water quality criteria. The metal concentrations periodically exceeded
the toxic thresholds for salmon and rainbow trout. These metals were aluminum,
cadmium, copper, manganese, mercury, and zinc. Blasting rock and dredging
the river channel during dam construction will free up more metals and result in
In 2008 and 2009 from May to September, Cook Inletkeeper testing
showed 13 Susitna River tributaries had temperature criteria that exceeded the
thresholds for spawning. They were the creeks of Alexander, Buyers, Cache,
Chijuk, Deception, Kroto (Deshka), Little Willow, Montana, Moose (Talkeetna),
Trapper, Troublesome, Willow and the East Fork of the Chulitna River.18 The 1980
studies showed that some places in the mainstem exceeded temperature
criteria for salmon migration.19
All of the above information gives cause for concern. As mentioned
previously, major segments of this state’s tourism and fishing industries depend
upon maintaining the actual and perceived purity of the Susitna River waters.
The two dynamic river processes of winter ice and spring floods will be
altered significantly by a dam. With the reduction of ice cover, this eliminates
the scouring activity on the riparian vegetation in the channel and the sloughs.
Late successional vegetation of shrubs and trees will become the norm. This will
reduce valuable moose browse year round. This browse is important especially
in the winter when the moose can be expected to congregate along the river
to exist. The moose during a heavy snow year such as this year, are in retreat
from the forest and into the river area where the snow is more packed providing
refuge and shelter. Susitna Valley residents have seen this. Some entire river
sloughs could be eliminated by the lack of these river processes.
VI. Dam Site/Reservoir and Upstream Impacts
The creation of the dam, permanent access and transportation roads,
facilities, a permanent airport, transmission corridors, multiple open pit gravel
mines and other spin-off developments will have devastating impacts on the fish
and wildlife and subsistence resources. This is the very heart of Game
Management Unit 13 which is world class caribou, moose, and bear habitat.
Human made development of a natural resource area provides the
conditions for the establishment and increase of flora and fauna that were not
natural to the area previously. These are called and classified many times as
weeds and/or invasive and noxious species; and herbicide treatments are
initiated to “solve” the problem. We are opposed to herbicide use, and the
public will not be receptive to this solution.
A. The Nelchina Caribou Herd20
Increased human access and development in the remote areas of the
Nelchina caribou herd range is detrimental. The Talkeetna Mountain calving
grounds are currently remote and inaccessible to human activity. These
grounds are considered the most important single geographic area to the herd.
A large segment of the herd crosses the Susitna River and moves through the
proposed impoundment area during the spring migration to the Talkeetna
The area along the Susitna River between Deadman Creek and Jay’s
Creek is a well established migration route. The proposed Denali corridor, one of
the three proposed access and transmission routes, bisects the summer and
winter range for the Upper Susitna Nenana subherd. For human society, the
Nelchina caribou herd is the only large caribou herd in the state accessible by
road by the major Alaskan urban centers. Thus, it is an important resource.
Historically GMU 13 has been one of the most important moose hunting
and viewing areas in the state. Moose populations cross the proposed
impoundment area year round, but it is used particularly substantially during mid
to late winter through April.
Project construction will result in habitat loss and alteration of habitat
through a variety of mechanisms so there will be both short and long term
changes in moose carrying capacity of the area.
The 1980’s data shows that there was a large population of brown bears
that numbered 327 in the project area. Data extrapolation shows impoundment
would eliminate annual carrying capacity for 60 brown bears. The Prairie Creek
area supported the most concentrated king salmon spawning area in Upper
Cook Inlet region, and in 1984-85 an average of 50-60 brown bear used this area
at any one time with 70-120 bears total using the area. The amount of
disturbance to this area from the project is uncertain, but this must be taken into
The black bear population in the project area was 107. Project impacts
could reduce their carrying capacity by 32 bears. The shrub lands where there
are many berries, an important food source, is an area that is favored for
constructions camps, borrow areas and permanent residences between
Tsusena and Deadman Creeks.
The proposed reservoir ice will be unstable due to the water fluctuations in
the surface elevations resulting from different flow regimes. This will make it
difficult and downright unsafe for animals to cross. Impacts to wildlife as the
reservoir is being filled need to be assessed. This is in reference to the well known
incident in the Quebec/Labrador peninsula area in September 1984 of the
death of 10,000 caribou (1.5% of the herd) that took place. The exact cause of
death is unknown, but the filling of the reservoir on the Caniapiscau River from
1981-1984 was thought to be involved.22
D. Reservoir Methylmercury
Elevated mercury levels in dam reservoir fish were first documented in the
late 1970’s. The decomposing organic material in the reservoir causes high
levels of methyl mercury which become a part of the aquatic food chain. This
happens because microbes in the upper level of the reservoir sediment
consume oxygen which creates a condition where ferric iron becomes ferrous
iron and that dissolves in water and releases metals that had been adsorbed
onto the ferrous iron compound. As metals are released, they become
available for uptake by organisms. Methylmercury is one of the deadliest of
these metals released.23 This was exemplified by “…scientists from Canada’s Department of Fisheries and Oceans say that fish mercury concentrations ‘have increased in all
reservoirs for which pre- and post-impoundment data have been collected.’
The best researched case is at the La Grande hydrocomplex in Quebec which is
part of the James Bay Project. Ten years after the La Grande 2 Reservoir was first
impounded, mercury levels in pike and walleye had risen to six times their prereservoir
level and showed no signs of leveling off. As fish are a major part of the
traditional diet of the local Cree native people, mercury levels in their bodies
have risen dangerously. By 1984, six years after that dam was completed, 64%
of the Cree on the La Grande estuary had blood mercury levels far exceeding
the World Health Organization tolerance limit.”24
E. Evaporation of Reservoir Water
The EIS needs to consider what the evaporation rate of the water in
the reservoir will be and what is the significance of such to the local ecology
“Storing water in a reservoir changes the amount and timing of
evaporation into the atmosphere, which in turn changes the dynamics of local
air masses, including their temperature, humidity, and ability to release
precipitation. Water lost to evaporation from reservoirs reduces the net amount
of water that flows downstream in rivers.”25
F. Dissolved Gases in Reservoir Water
According to the PAD, for all but the highest flood levels, when the flow
is released through the spillways, the supersaturated dissolved gas (nitrogen)
levels are not expected to be increased by project operations.26 But what does
this mean? This issue needs to be clarified because of the potential
catastrophic damage to downriver fisheries.
In the late May to early June of 2011, due to heavy rains, the Bureau of
Reclamation released large amounts of water from Grand Coulee Dam in order
to protect the dam structure. By doing that it released large amounts of
nitrogen that killed 100’s of thousands of fish.27 This is a very sobering incident.
Certain amounts of dissolved oxygen in water are important for water to
purify itself of excess nutrients and organic matter. Dissolved oxygen depletion hurts fish and can cause release of heavy metals and toxic compounds. As
stated in the PAD on page 4-74, the amount of dissolved oxygen in the reservoir
waters is unknown, but it is expected that the inflow will have high dissolved
oxygen concentration. It also states that the relatively weak stratification in the
reservoir may limit oxygen replenishment in the hypolimnion, and the extent of
the mixing from the spring turnover is unknown.
Thus, it can be theorized that during low flow electrical generation, water
will be withdrawn primarily from the surface strata where the dissolved oxygen is
higher. With higher flow electrical operations, water is drawn from the lower
oxygen deficient stratas so that the water flowing downriver has low dissolved
oxygen levels. This data is important to ascertain. Reservoir water is
changed chemically. Some hydroelectric dams have developed and installed
costly aeration systems or actually pump oxygen into the reservoir waters. The
EIS must deal with this resource issue.
VII. Seismic Catastrophic Risks
Seismic events and their impacts on the dam, reservoir and downstream
communities must be studied and considered in a significant way. Two
unresolved issues from the previous FERC license application were determination
of significance of risk and effects of catastrophic dam failure and formulation of
emergency warning plan.
A. Reservoir Induced Seismicity
Reservoir induced seismicity (RIS) is a known fact. Some of the experts are
calling this phenomenon now reservoir triggered seismicity. The existence of the
reservoir water can hasten earthquakes if the conditions already exist.
According to the 1980’s studies, there were 68 cases recognized and accepted
world –wide. The best known example is the 1967 magnitude 6.3 earthquake in
central India that was triggered by the Koyna Dam and caused serious damage
and about 200 deaths. Other examples where the quakes exceeded
magnitude 6 were in Kremasta, Greece, Kariba, Zambia, Xinfengjiang, China.28
There are a growing number of US and Chinese scientists that state that the 2008
Sichuan Province, China earthquake, magnitude 7.9 was triggered by the 4 year
old Zipingpu Reservoir built near a geologic fault line. China geophysicists found
the dam caused significant seismic changes before the actual quake.29 The factors that can create this phenomenon are the reservoir depth and volume, the reservoir filling history, the state of the tectonic stress in the shallow crust beneath the reservoir, the existing pore pressures, and the permeability of the rock under the reservoir. The Susitna Dam already has some characteristics that make it susceptible to this. The maximum reservoir depth is significant at 700 feet, and it is within an active tectonic region.30
B. The Current Seismic Situation
The up-to-date information that the public has now is the 7/2/09 R& M
Geotechnical Memorandum stating that there are 13 known mapped shallow
faults or lineaments in the project area. Data says there is no evidence of
recent displacement (rupture within the past 100,000 years). There is the possible
existence of a northwest dipping thrust fault through Broad Pass, 35-40 kilometers
northwest of the project area. Recent earthquake studies identified 2 new
sources known to have produced earthquakes within the past 100 years and
close enough to produce notable ground motions in the project area. These
are the Susitna Glacier Fault which was the location of the 2002 magnitude 7.9
earthquake and the Susitna Seismic zone which is a band of historic seismic
activity not associated with any known faults. In section 4.3.2. of AEA’s PAD the
2002 earthquake was mentioned but not that it had previously been an
unknown fault. This is 65 Km. north of the project area.
To summarize in miles, the project area is 45 miles from the Denali Fault, 40 miles
from the Susitna Glacier Fault, 60 miles from the Castle Mountain Fault, 90 miles
from the Megathrust Zone, 30 miles from the Wadati Benioff Zone, 25 miles from
the Susitna Seismic Zone.
One wonders how many unknown faults are present? The specific
seismic parameters for the dam design must be for greater than a 7.6
Although there have been advances in earthquake science, seismologists
still cannot predict when earthquakes will happen. There are no proven theories
of earthquake prediction.31 Earthquakes are happening in areas that
seismologists did not expect them to be triggered.
In the 2011 AEA informational meetings and the 2012 scoping meetings,
the public has been very concerned that the dam would be just 45 miles from
the Denali Fault. From the 2002 quake, a whole side of Mt. McGinnis washed
across the Black Rapids Glacier and up the other side of the mountain. The pile
of debris looked to be 250 feet high, half a mile wide, and 3 miles long and was
probably dozens of times over the cubic mass of the dam. This is anecdotal
information, but this landslide data should be studied. It was an awesome
power that was unleashed and moved mountains.
AEA consultants assured us that a dam can be built to withstand
earthquakes. Yet there have been 11 catastrophic dam failures in the US since
1972. The March 2011 Japanese earthquake caused a dam break in the
Fukushima region and at least 7 other dams were damaged. But the experts tell
us that it won’t happen here. Many residents and property owners along the
Susitna River are intensely concerned about compensation if there is dam failure
due to seismic activity. Are they going to be able to get insurance? Will there
be an emergency preparedness program enacted?
Other seismic hazards that must be studied are soil failure (landslides,
liquefaction, settlement, lateral spreading) and seiches which are oscillation of
lake surfaces. To explain further, “one of the most dangerous affects of major
earthquakes is liquefaction, a process in which the pressure created by seismic
waves temporarily turn moist, poorly drained sediment-especially those bearing
great weights, such as from buildings-into something akin to quicksand. During
the megaquake in March in Japan, ground motions that lasted several minutes
triggered liquefaction that damaged homes, buildings and infrastructure such
as roads, port facilities.”32
C. Permafrost Conditions
Permafrost conditions exist to a depth of 120 feet on the south abutment
of the dam and up to 60 feet on the north abutment. Temperature
measurements show the permafrost to be “warm” i.e. within l degree F (1
degree C) of freezing. What will be the seepage effect of thawing permafrost
on the reservoir slope stability, the liquefaction potential from a earthquake, and
the settlement of surface facilities constructed in an area of deep overburden
north of the dam site?
VIII. Socioeconomic Impacts
A. Vibrant Economy
The Susitna River Basin has a vibrant long term economy that is a result of
our undeveloped lands and waters and our valuable fish and wildlife
populations and habitats. This is an economy based on tourism, hunting, fishing, recreation and which needs healthy fish and wildlife populations, unpolluted
waters and scenic vistas of undeveloped lands. A strong, healthy, rural and
remote residential quality of life has evolved that residents and property owners
have invested much time and energy to protect those very resources that are
the backbone of our economy. Reports bear this out.
The 2007 Matanuska Susitna Borough funded Cole Report found that the
non-consumptive uses exceed the consumptive uses of the natural resources by
a ratio of about 20 to 1 which is $363 million in tourist expenditures compared to
$18 million for consumptive uses such as commercial logging.
The 8/31/09 ECONOMIC IMPORTANCE OF SPORTFISHING IN THE MAT SU
BOROUGH prepared for the borough showed that in 2007, resident and
nonresident anglers fished almost 300,000 days spending between $63 million
and $163 million on goods and services primarily used for sport fishing, creating
between 900 and 1900 jobs and generating between $6 million and $15 million
in state and local taxes.
The Alaska Department of Fish and Game, Division of Sport Fishing has
estimated that for 2007, in southcentral Alaska, $989 million ($561 million from
residents, $428 from non-residents) was spent by sport fishers on fishing trips,
equipment, development and maintenance of land use. The “opportunity to
go fishing has a value often difficult to measure in dollars. But it is an important
part of the economy and a vital source of income to many in small towns and
While these reports were for all of the borough and southcentral Alaska
respectively, they are important indicators for the Susitna River Valley. Hopefully,
the socioeconomic studies by the applicant will update this. However, it is
recognized that there are many factors that threaten the important renewable
The Mat Su Salmon Partnership, a coalition of government and nongovernmental
groups, has publicized maps that show data specifically quantifying the biological values of the salmon habitats of the watersheds in the borough and showing the variables of patterns of human activities that negatively impact watersheds. The Susitna River basin shows high biological values for salmon habitat. That is the good news. However, the mid and lower Susitna River basin shows median to high vulnerability due to the factors of road
density, culverts that impede fish passage, impervious and converted land cover, platted subdivisions, water quality, invasive northern pike, conservation management status and instream flow. This shows what is at stake. The data of negative impacts to high biological values is one more example behind the support for a no action alternative to the proposed dam. We are struggling with a lot of negative factors now without the dam. The risks of a dam to our valuable non-consumptive natural resources far outweigh the benefits. This was shown by the October 4, 2011 advisory vote for all voters within the Talkeetna Community Council Inc. boundaries that was 82.7% voting against the dam. (109 to 19 opposed). This vote signifies no amount of mitigation can alleviate negative cumulative impacts of a dam.
As Paul Roderick, owner of Talkeetna Air Taxi stated in the 3/28/12 scoping
meeting, “Tourists and visitors do not expect massive development, and they
are thrilled to see a pristine place. The flights and tours we operate have
everything to do with showing people all over the world Alaska’s awe-inspiring
expansive wilderness. And this is what attracts people to Alaska, and especially
Talkeetna….Untouched wildness has tremendous economic and social value.
And we feel this is what defines this part of Alaska.”
The figure for the year 2011 is 205,000 visitors to Talkeetna. Figures such as
that lead one to ask how much is one king salmon worth to the economy? As
mentioned earlier, many segments of the region’s tourism and fishing industries
depend upon maintaining the actual and perceived purity of our waters. Any
real and perceived threats to that purity threaten the current and future
FERC will be conditioning the license for the dam for environmental
conditions. However, FERC just as equally needs to condition the license also for
socioeconomic and cultural goals. For instance, a dam construction boom
economy would means more societal services such as police, emergency
technicians, school expansion, housing, etc., and the license process must
consider this. For Alaskans, a corresponding question is would the state of
Alaska be willing to pay for the increased services? To the extent that the state
fails to fully fund services, it is likely that property-owners in the Matanuska Susitna
Borough will see their already considerable property tax burden significantly
B. Ecosystem Services
As part of the socioeconomic studies, the NEPA process must put a value
on the ecosystem services of the Susitna Basin. Ecosystem services have been
defined as the conditions and process through which the natural ecosystems
and their species in those systems sustain and fulfill human life.33 The four
categories to describe ecosystem services are: supportive functions and
structures such as nutrient cycling, pollination and seed dispersal; regulating
services such as soil retention and disturbance regulation; provisioning services
such as fresh water, timber, food; cultural services such as opportunities for
recreation and spiritual activities.34
C. The Susitna River as a Transportation and Recreational Corridor
Besides the Susitna Valley’s tourism, hunting, fishing economies, an
Important economic engine is recreation. One has only to travel the Parks
Highway year round to notice vehicles with or without trailers transporting
snowmachines, all terrain vehicles, boats, kayaks, rafts, bicycles, skiis, dogs and
sleds to anecdotally know this.
The Susitna River and its tributaries are recreation and transportation
corridors. This must be quantified equally in the studies as non-power uses of the
rivers. People who live in the remote roadless areas use the rivers as access
routes to their homes. A dam with its fluctuating winter water levels that cause
shelf ice and overflow conditions will be a safety issue and impede the use of
the river by people and animals the whole length of the river. Anyone who has
experienced certain overflow conditions knows the tricky perilous conditions
that can occur. Dog mushers use the Susitna River to train for races and for
recreation purposes. The way the river will change in the winter with the dam
flows will impact this use.
The winter use of the unplowed Denali Highway by users must be
considered. The dam project will upgrade and keep plowed year round the first
twenty miles of the highway if that is the access route chosen. So that situation
will close off that winter recreation use. This must be quantitated in the studies.
IX. Climate Change
A sizeable and growing body of science has shown that there can be no
denying climate change in the northern latitudes. This is documented by the
following changes in Alaska and the Susitna River watershed.35
-changing hydrology determined by historical data and data synthesis by the US
Geological Survey (USGS)
-increase in stream temperatures studied by USGS
-reasonably accurate warming temperature projections downscaled by
appropriate global models by the Scenarios Network for Alaska Planning
-reduced productivity of some salmonid populations
-documentation of increased length of growing season and changes in
-multiple species range expansions
-declining glacial mass-balance trends
-alterations in sediment transport
-altered frequency and intensity of forest fires and associated mass wasting
-other manifestations measured, estimated and reported by many academic
and natural resource management agencies.
This must be considered in the assessment of this project which is
dependent on a multitude of climate-affected resources and must be
incorporated into all the study plans. Anecdotal information by Talkeetna area
residents who have worked and climbed in the Alaska Range is that in the 1980-
1990’s the glaciers started changing fast. They were and are dropping fast.
These are the very glaciers that are producing water for the Susitna River, and
they are reducing at an astronomical rate.
Now AEA is commissioning a study about the glacial wasting in the
glaciers above the dam. That seems to be all that they are interested in. But
AEA and FERC need to be concerned about the glaciers that provide water to
Talkeetna, Yentna, and Chulitna Rivers.
X. Hydropower as Green Energy/Greenhouse Gas Emissions
This category is closely related to climate change because there are many
well-publicized statements that hydroelectric power does not produce
greenhouse gas emissions. Thus, it is seen as environmental friendly and not
contributing to climate change. But the tide is turning on the mistaken mantra
that large hydropower projects are a green source of energy. There is a need
for a comprehensive accounting of the dam project’s contribution to global
A. Carbon Footprint
There will be a large carbon footprint just from the construction of the
dam. There are the emissions from the use of fossil fuels from the production of
cement, steel and other materials to construct the dam itself, the transportation
of the materials, construction workers and the people who conduct the studies,
and the clearing of land for the access roads and transmission lines.
The project footprint itself which is the development of the natural land
can itself cause climate change and exacerbate already occurring changes.
The value of an intact forest is imperative in this time of climate change where
shifting weather patterns impact fish, wildlife, and plant ranges, and habitat. It is
being proven that an intact boreal forest that is NOT fragmented by roads and
human development that clears land, is more resilient to climactic changes.
Natural forests that are diverse complex systems form their own sheltering and
buffering microclimates which slow the rate of change and allow resident
species time to adapt to climate changes. Resilient ecosystems can regenerate better after disturbances, and resist and recover from pests, diseases, temperature changes and water availability.36
B. Reservoir Induced Greenhouse Gas (GHG) Emissions
Research suggests reservoirs can make a significant contribution to global
warming climate change. It varies from one dam reservoir to another; but in
some cases, it could be more than the amount of an equivalent fossil fuel
burning power plant.
Inundated reservoir vegetation produces GHG emissions of carbon
dioxide or methane which are released into the atmosphere when the water
passes through the dam turbines or from the surface water. When organic
material decays it is due to bacterial action. If it is well aerated, carbon dioxide
is produced. But when oxygen is limited like at the bottom of a reservoir, a
group of bacteria called methogens break material down into methane.
Methane is a potent GHG that can trap heat 21 times more effectively than
The trees in the forest, the shrubs and grasslands that were once carbon
sinks or carbon storage will become sources of GHG emissions. The Freshwater
Institute of the Canadian government estimated that there are substantial
emissions of carbon dioxide and methane from reservoirs in northern Canada.
Researchers measured per-hectare gas releases from flooded forests and bogs
and extrapolated these findings to estimate the average annual emissions over
50 years of two large hydroelectric reservoirs in northern Manitoba. They
concluded that the emissions at Grand Rapids Dam was around the same as a
gas-fired plant while the Churchill/Nelson hydro project contributed an eighth as
much as a gas plant.37
Permafrost is a carbon sink. As mentioned previously, there is a significant
amount of permafrost in the dam abutment area that is already close to
melting now. As the permafrost thaws due to climate change or due to the
dam project construction, the carbon is released and becomes either carbon
dioxide or methane. It is necessary to know the extent of permafrost in the
project area and its contribution to climate change through GHG emissions.
XI. Project Economics
The capital cost of this project is too high to be privately financed due to
to the significant long term project risk. Half of the project is to be paid for by
state appropriation, and the other half with bonds to be backed by state credit
This is the way that the Bradley Lake Hydroelectric Project located on the
Kenai Peninsula was financed in the 1980’s and 1990’s. This model seems to be
the only option that AEA is considering. But the Bradley Lake model as a whole
cannot be totally duplicated because market financing conditions and legal
constraints are different. There are three ways that the current financing plans
cannot follow the model.
With Bradley Lake, the state used an arbitrage strategy that borrowed for
the full project amount with variable rate demand bonds. The unspent
proceeds after project costs were invested at a higher taxable rate interest and
became an additional source of project capital which paid for 9% of the project
costs. At the end of the construction, the bonds were refinanced (paid off) with
revenue bonds at a low interest rate. But this cannot be done now. The 1986
Tax Act passed by US Congress eliminated this ability to use tax exempt bond
proceeds to earn arbitrage.
The Bradley Lake project was fast tracked, similar to what is happening
now with the Susitna Dam proposal, and moved along due to two waivers. The
project received a federal exemption that allowed the use of tax exempt
financing even though the project served three boroughs. This might not
happen again. The state legislature exempted the Bradley Lake’s Power Service
Agreement from the Alaska Public Utilities Commission review. It is extremely
unlikely due to the controversial nature of the Susitna Dam that this will happen
Bradley Lake was made possible due to the state’s high investment grade
credit rating. But will the state always have this great credit rating? An 8/31/11
report from the Legislative Research Services concludes that the Governor’s
plan to reduce oil taxes by up to $2 billion per year could imperil the state credit
rating. Thus, we might not be able to count on the current high credit rating to
keep finance costs low.
The concerned public needs to know the financial parameters of the
project cost. This must include interest rates, other finance charges and the cost
of the transmission line upgrades. There also needs to be a cost/benefit analysis.
The Alaska State Legislature is considering several in state natural gas
pipeline options to transport North Slope natural gas to southcentral. It is very
likely that there would be political opposition to more than one large
southcentral energy subsidized funding project. The debt financing for one.southcentral project could limit the ability to finance other energy projects with high investment risks.
B. The Cost of Susitna Dam Power
One of the major political reasons behind this project is that it will stabilize
the monthly energy bill. We contend that this is erroneous. The project might
keep prices from rising fast, but prices will rise if the price of the 75% of other
electrical generation sources rise. It goes hand in hand especially if the
electrical demand increases significantly.
We do not know what the costs per kilowatt hour are going to be. AEA
has actively avoided this subject. There is a high probability that the power
costs will be higher than the figure used now which negates the project’s
economic benefits. There needs to be quite a bit of discussion on whether the
state project subsidies will enable the cost to be 6.5 cents a kilowatt hour.
C. Dam Decommissioning Costs
The cost of studies to decommission the dam, the cost of the actual
decommissioning, and the restoration of the Susitna River must be included in
the project cost. This is usually an ignored cost.
Since 1999 more than 900 dams have been removed in the US. The
removal of the 2 dams on the Elwha River in 2011 was the biggest project
removal yet. The cost for the actual removal was $26.9 million, but the total cost
of the Elwha River Restoration is $324.7 million. The dam removal discussion
began in the 1980’s with the relicensing process culminating in the US Congress
passing the 1992 Elwha River Ecosystem and Fisheries Act which began the
process of consideration which included a NEPA Environmental Impact
Statement process. Over thirty years leading up to the actual removal program.
The future four dam removals on the Klamath River have had lengthy
scientific study and have been very controversial. Those projects are slated to
happen in 2020 for the cost of $291.6 million. The point of mentioning these
examples are to show the steep costs of dam decommissioning, and the
lengthy time to make it happen.
XII. Scope of Cumulative Effects
The Scoping Document 1 does not identify any resources that could be
cumulatively effected by this project action added to other past, present, and
reasonably foreseeable future actions. We believe that there are actions that
along with proposed action would cumulatively impact the resources of the
project area and the adjacent legislatively designated Nelchina Public Use
Area (NPUA). These are both direct and indirect effects on wildlife, subsistence,
habitat, recreation, cultural and other resource categories. NEPA considers the
terms effects and impacts synonomous.
List of Actions
A. Joint Pacific Alaska Range Complex (JPARC)
Currently, the draft Modernization and Enhancement EIS of JPARC is out
for public comment ending June 7, 2012. The proposal is to greatly expand the
current Military Operations Area (MOA) and add a new MOA. The proposed
Susitna Dam project area is particularly impacted by Fox 3 MOA. The draft EIS is
proposing that jets could fly as low as 500 feet, and Night Joint Training would
occur in the MOA’s.
There are great concerns on impacts to caribou and moose migration
and calving areas, trumpeter swan and migratory bird breeding grounds,
subsistence, recreation and tourist activities, and commercial aviation access
from the noise and other polluting factors.
B. Mineral Exploration/Production
There is active mineral exploration on claims by the company Pure
Nickel’s Man Alaska Project (2009-2014). These are 240 square miles of claims on
state land called the Denali Block and some on federal Bureau of Land
Management land. The production could be open pit or underground mining.
Both methods involve waste rock dumps, tailing stacks and ponds, toxic dust
from ore trucks, mine drainage, transmission lines and access roads. While not
located exactly in the proposed Susitna Dam project area, it will affect the
same migratory wildlife; increase human access and activity in the area; and
create a momentum for mining exploration near the project area. Other
impacts are air and noise pollution and negative impacts on recreation and
C. Denali Air Special Recreational Use Permit
Denali Air is requesting to be able to conduct scenic glacier landings by
fixed-wing aircraft near Mt. Deborah on portions of the Yanert and Gillian
Glaciers with up to 3 departures daily from May 10 to October 10. Currently BLM
is conducting an Environmental Assessment. While located north of the Susitna
Project area, this can impact the same migratory wildlife of the project area
and impact the aesthetic, recreational, and subsistence resources of the
D. Nelchina Public Use Area
What has been not been mentioned in the PAD nor the Scoping
Document 1 is the cumulative effects of the proposed dam on the Nelchina
Public Use Area (NPUA).
The NPUA encompasses 2.5 million acres of state land in the Talkeetna
Mountains and was established by the state legislature in 1985. AS 41.23.010
states that the mandate is to protect, perpetuate and enhance the fish and
wildlife habitat and the public enjoyment of such habitat by the activities of
fishing, hunting, trapping, recreation and additional public uses. In particular,
the Nelchina Caribou calving grounds, trumpeter swan nesting areas, and
habitats for Dall sheep and brown bear are to be protected. Under As
41.23.020, the Alaska Department of Natural Resources is directed to adopt a
management plan, but this has never been done. It has been managed for
multiple use under the guidelines of the 1985 Susitna Area Plan and now under
the 2010 Susitna Matanuska Area Plan which is currently being appealed in state
superior court. Not enough attention is being given to the proposed project
impacts on this legislatively designated area which is vulnerable to project
impacts because there is no specific management plan. Because of this
project proposal, the NPUA needs a management plan. All this needs to be
considered by the EIS.
For all of the above reasons, these comments are in support of the No Action Alternative. The value of a free flowing Susitna River with some of the last
remaining wild salmon fisheries in the world encompassing a 15,000 year old
ecosystem with bountiful biodiversity of plants, wildlife, and aquatic resources is
of national, state, and local significance.
For the River,
Boards of Directors
Coalition for Susitna Dam Alternatives
1Watana~The Case For A Susitna Dam: Does It Hold Water, Jan Konigsberg, Natural Heritage Institute,
March 2012, Executive Summary, p 3‐4.
2 Meeting Summary Aquatic and Terrestrial Resources Study Planning Meetings, 1/24/12, p. 11
3 ACAT, ET AL. V. HARTIG, ET AL., 3PA‐11‐01604 CI, pg 21
4 PEBBLE LIMITED PARTNERSHIP V. PARNELL, 215 P.3d 1064, 1074
5 Energy Controls Could Mean Big Savings for Building Owners, Oregon Public Broadcasting, 4/12/12
6 Sustainable Business Oregon, 4/4/12
7 This section written by George Menard, Trapper Creek Photovoltaic Business Owner of InverTech Alaska
8 5 AAC 39.222 Policy for Management of Sustained Salmon Fishery
9 5 AAC 39.222(c)(5)
10 Cook Inlet Regional Salmon enhancement Planning Phase II plan: 2006‐2025, p. 2‐7.
12 A stock of yield concern is the chronic inability despite the use of special management measures, to maintain expected yields, or harvestable surpluses, above a stock’s escapement needs. Alaska Energy Authority Preliminary
Application Document (PAD) Susitna‐Watana Hydroelectric Project, December, 2011, p.4‐99.
13 A stock of management concerns is the chronic inability despite use of special management measures, to
maintain an escapement for salmon stock within the bounds of SEG, BEG, or OEC or other specified management
objectives for the fishery. PAD, p.4‐100.
14 PAD, p. 4‐110.
15 www.adfg.alaska.gov/index.cfm?adfg=fishingSportFishingInfo.NR&NRID=1601&year=2012 regarding Emergency
16 Analysis prepared by Jan Konigsberg, Natural Heritage Institute
17 Susitna‐Watana Hydro Project: Water Quality and Sediment Data Gap Analysis, Tetra Tech, Inc., 7/26/11, p.
18 Ibid, p. 25‐28.
19 Ibid. p. 29‐
20 Data from this section is from Susitna Hydro Project, Final Report, Big Game Studies, Volume IV, Kenneth W.
Pitcher, April 1987.
21 Data about bears from this section is from Susitna Hydroelectric Project Final Report, Big Game Studies Volume
VI Black Bear and Brown Bear, Sterling D. Miller, August 1987.
23 Ellen Wohl, A World of Rivers,(Chicago:University of Chicago Press, 2011), p.330.
24 Silenced Rivers The Ecology and Politics of Large Dams (London: Zed Books), Patrick McCully, p. 40.
25 A World of Rivers, p.329.
26 PAD, p. 4‐74.
27 High Country News, 12/26/11, p.7
28 Woodward‐Clyde Consultants, Final Report on Seismic Studies for Susitna Hydroelectric Project, February, 1982.
29 Possible Link Between Dam and China Quake, New York Times, 2/5/09
30 Alaska Railbelt Large Hydro Engineering Services, Briefing Memo on Reservoir Triggered Seismicity, 6/30/11, p 5.
31Susan Hough, Predicting the Unpredictable, The Tumultuous Science of Earthquake Prediction, (Princeton:
Princeton University Press, 2010.
32Science News, December 3, 2011
33Nature’s Services, Island Press 1997
34Millenium Ecosystem Assessment, World Resources Institute, 2005
35 2/29/12 letter from James Balsiger, Administrator Alaska Region National Marine Fisheries Service to AEA
36 Dr. Jim Pojar, A New Climate for Conservation.
37 Silenced Rivers, p. 144.
38 Hydroelectric Project Risk Analyses and the Bradley Lake Funding Model, summary Report, SNW (Seattle),