by Phillip Manning ~ March 6th, 2014
On Wednesday, a letter from employees of the U.S. Fish and Wildlife Service and the National Marine Fisheries Service concerning the Alaska Energy Authority’s plans for the Susitna-Watana Project was made public. The letter criticizes the AEA’s current schedule of meetings and timing of upcoming research. NMFS and Fish and Wildlife say that, due to short notice, lack of collaboration, schedule conflicts, and lack of advance meeting materials, that the two Services may not be able to participate in currently scheduled meetings.
Specifically, NMFS and Fish and Wildlife express concern that AEA have planned a series of Proof of Concept meetings for a time in April when scientists from the U.S. Geological Service will not be able to participate. The federal Services say the scientists work in “key” areas such as instream flow, geomorphology, and groundwater. The letter also states that the Servies and USGS expressed concerns about the project’s scientific modeling method at a meeting last November.
The letter concludes by stating that any studies conducted before the release of the project’s Initial Study Report in June are outside of the licensing process as defined by the Federal Energy Regulatory Commission. NMFS and Fish and Wildlife say that AEA would take a “significant risk” in conducting more studies at this time, since the meetings that could result in changes to the study plan will not conclude until October. The letter from the Services claims that AEA’s current plans for “unspecified studies” skips the opportunity for study plans to be altered due to input from licensing stakeholders.
Requests for comment from the Alaska Energy Authority were not returned.
The complete text of the letter from the U.S. Fish and Wildlife Service and National Marine Fisheries is included below:
Susan H Walker, Juneau, AK.
This note addresses the Alaska Energy Authority‚Äôs request for National Marine Fisheries Service and U.S. Fish and Wildlife Service reconsideration of AEAs proposed March through April 2014 meeting schedule for the proposed Susitna dam and hydropower project.
USFWS and NMFS have prioritized workload and scheduling to meet the ILP schedule and to actively participate in technical meetings with AEA to the extent possible. The Services appreciate the collaborative intent of these meetings and view our and our contractor‚Äôs participation in the March and April meetings as a priority, but, due to short schedule notification, lack of collaboration on participant availability, conflicts with previously scheduled meetings and lack of AEAs provision of advance meeting materials to facilitate our active and meaningful participation, we may not be able to engage in many of the meetings as scheduled.
Prior to AEA releasing the March and April meeting schedules (which continue to change) the Services committed to participation on other projects with conflicting schedules. As AEAs proposed Sustina meetings this spring are outside of the ILP process, they have a lower priority than projects which are continuing on schedule, especially given the funding uncertainties and delays that the Susitna project is now facing.
At this time we do not have all technical expert contractors available for March and April meetings with the exception of USGS for the March 21 date. We may have some contractors on board for some of the meetings and we are working now with ADNR-OPMP to request proposals for that work under our MOA and the Reimbursable Services agreement.
On February 21st we informed AEA that the USGS Ft. Collins scientists are unavailable for the April 15th through 17th Proof of Concept (POC) meetings. We are surprised that AEA would plan this very important meeting absent participation of key scientists from USGS in key topic areas of instream flow, geomorphology and groundwater. During the November 2013 Model Integration workshop the Services with USGS and other experts expressed serious concerns about the uncertainties of the model integration process – which is the basis of study for the Susitna project. It is disappointing that AEA did not reschedule this critically important meeting as AEA suggested it could do, and instead is planning to hold this meeting with no notification of your decision not to reschedule. While the Services may be able to attend, we would not be effective without our expert advisers who are not available, and this very important (and expensive) meeting would not be effective.
With the revised ILP study schedule there should be plenty of time to discuss the POC prior to submission of the ISR, as we discussed on Feb 21. At that meeting AEA suggested that the POC assessment be submitted to FERC at a later date than June 3 if FERC approved of that variance.
As previously discussed and confirmed by FERC, AEA undertakes significant risk by conducting any studies in 2014 prior to filing of the final ISR and following the FERC ISR review process. While we may attend meetings and discuss 2014 study plans according to our availability, the ILP process provides for filing formal 2nd year study recommendations and additional study requests following the ISR meeting in October, under FERC regulations. Study modifications and recommendations for additional studies are appropriate at that time. AEAs recent meetings notifications indicate apparent planning of unspecified studies continuing this coming summer season, and that those are being considered by AEA as second year studies for the ILP process, so long as the study plan is not changed from the final study plan. This process skips the final ISR steps that allow for necessary modifications to second year studies based on initial study results and recommendations from licensing participants after their review of the ISR. The Services (and FERC and other licensing participants) have not been told how any “year two” studies would be decided on, or would be dealt with in terms of reporting and reviewing results.
Any studies conducted this summer are outside of the ILP process, without benefit from ISR reporting, review and requests for study modifications or new studies by the Services and other licensing participants.
We are e-filing this comment with FERC to make this information available to all licensing participants, and we look forward to working with AEA, FERC, and other licensing participants to develop a workable solution for this unusual process.
Sue Walker for NMFS and Lori Verbrugge for USFWS